Category: Petroleum Storage Tank Systems

In Fenton, Michigan lied the old Fairbanks gas station that was once a Marathon. It had been in the Fairbanks family for over 55 years when the station closed down in 2003 and was finally demolished in early October 2018.

A petroleum leak was first found at the station’s Underground Storage Tank (UST) site in 2015 after a follow-up investigation years after the station’s closure in 2003. According to investigators and the Tri-County Times press release, the contents in the UST taken after the initial investigation surpassed the Department of Licensing and Regulatory Affairs (LARA) limits.

The investigation showed the surrounding soil and groundwater was contaminated and had migrated off-site. The settlement agreement concluded in May 2018 with the landowner responsible for resolving the cleanup obligations. Also, the agreement allowed the DEQ to initiate site cleanup and work began in September 2018.

Clean-up and restoration activities include removal of the UST’s and contaminated soil and asbestos building materials. In addition to removal, sheet piling will be installed to ensure that the excavation efforts do not damage roadways or pavement. The total removal, cleanup, and demolition will total $595,000. Once cleanup efforts conclude, the site will continue to be monitored for leak detection and soil contamination for a year after excavation. Once their initial investigation concludes, the DEQ will create a report documenting the release available in January 2019.

Overfill prevention and testing of overfill at sites is critical for staying in compliance, and for the protection of the environment. A fuel station in Marquette, Michigan was accidentally overfilled, causing a spill of gasoline into the street and into the storm drain system according to the EPA and Michigan Department of Environmental Quality. While the EPA estimated 400-700 gallons, inventory controls and the state determine around 180 gallons were spilled during the incident. Upon review of the site, it was found that the overfill alarm had an intrusion of ice into the system which was a manufacturer defect. Cleanup efforts have taken place at the site, the sewer system, and the nearby river is currently being monitored for potential contamination. As of yet, no contamination in the soil or air has been detected in the surrounding area. More information on this story can be found here.
The State of Washington has now filed for its next rule proposal phase (CR-102), which was filed with the legislature on 1/24/2018. This proposal incorporates federal rule changes needed to maintain their state program approval for their underground storage tank program. The comment period on the new proposed rules will remain open until March 16, 2018. The public comment form can be found on their webpage here. If you are interested in learning more about the proposed rules, Washington will be hosting a webinar and in-person hearing on February 28th, 2018 at 1pm PST (4pm EST). A link to the webinar can be found here. The proposed rules changes include the following: Tank Installation
  • Corrosion assessments used to avoid installing cathodic protection must be performed every 5 years after installation and reports are sent to the department for determination
  • Eliminating secondary barriers for hazardous substance UST systems installed on or before 10/1/12
  • UDCs must be factory built or machine-tooled until otherwise approved by department
  • Compatibility demonstration requirements for USTs including hazardous substances; records retained for life of UST or change in service
  • Existing and previously deferred USTs must maintain upgrade records be maintained for life of UST in addition to repairs
Operation and Maintenance
  • Product deliverers must comply with spill and overfill requirements and report spills to Owner/operator
  • Walkthrough inspections (30 days) begin upon installation (after effective date) or one year after effective date for UST systems installed before effective date
    • 3 years of inspections must be maintained
  • 24 hour notification to corrosion expert for cathodic protection not operating correctly
  • Record retention for cathodic protection tests changed to 6 years; rectifier inspections maintained for 3 years.
  • Spill prevention and sump tightness testing must be performed by certified provider and reported to agency
  • Periodic monitoring of sumps/spill buckets be retained for 3 years
  • Tightness test documents retained for 6 years
  • Overfill prevention inspections must be performed by certified provider and be reported
  • Flow restrictors that are broken must be replaced with other overfill protection
  • Testing after repairs to UST system within 30 days; records retained for 3 years. Testing is reported
  • Monitoring or tightness testing of containment sumps used for interstitial monitoring of piping, monitoring or tightness testing of spill prevention equipment (spill buckets), Inspections of overfill prevention equipment, and tests of release detection equipment has specific implementation dates based on your facility compliance tag number
    • If your facility compliance tag number is even, then these must be completed within two years after the effective date of rule
    • If you facility compliance tag number is odd, then then these must be completed within three years after the effective date of rule
A more comprehensive, detailed list of proposed rule changes can be found here. The full rule document with all tracked changes can be found here. For more information, please visit the State of Washington’s regulatory update page.

Secondary Containment

EPA has proposed changes to established regulations related to secondary containment. They are “established” because they were originally set forth in the Energy Policy Act of 2005 and implemented by the states. 54 out of 56 states implemented secondary containment as part of the federal funding requirements of the Energy Policy Act of 2005.
Summary: EPA is proposing that new systems installed after the effective date of the rule must be upgraded to equipment with an inner and outer barrier with an interstitial pace that is monitored.
Tank – If a tank is removed and replaced. New tank must have secondary containment
Piping – If 50% or more of a piping run must be repaired, then the entire piping run must be upgraded to secondary containment.
Under Dispenser Containment (UDC)– Must be installed on all “new systems”, must be liquid tight and must be able to be monitored or visually inspected.
  • “New” means: both the dispenser system and equipment needed to connect the dispenser system to the UST system are installed at an UST facility.
  • Safe suction piping systems; and
  • Piping systems associated with:
    • Field constructed tank systems
    • Airport hydrant fuel distribution systems
Operational Requirements:
  • Monitoring of the interstitial space required on a 30-day basis
  • Pressurized piping must have an automatic line leak detector.
Discussion: Like the proposed changes to operator training regulations, these changes should only be news and an increased regulatory (and financial) burden to those owners and operators who have systems located:
  • On tribal lands or
  • In states that have rejected the grant money from the Energy Policy Act of 2005. (few and far between)
  • In states that Implemented less stringent definitions of “replace” for piping runs – (about 25% of the states)
All other owners and operators should be implementing these upgrade requirements as well as having proper interstitial monitoring and testing.
If you are not sure if your system is in compliance with the current secondary requirements or plan to upgrade any tank or piping component in the near future, contact 7G.
Operator Training:
The operator training requirements of the proposed federal regulations (proposed regs) mandate what has been required since 2007 by the Energy Policy Act of 2005 (Energy Act). Most states have already implemented (or are in the process of implementing) their own regulations that parrot the proposed regulations and Energy Act guidelines in order to receive federal grant money.
Because most states have already enacted their own operator training regulations, the proposed fed regulations should only be a added burden to UST owners and operators with systems on tribal lands and in states that have not implemented their own rule or their rule fails to meet the federal guidelines.
Here’s the quick and dirty of the proposed regs:>
What are the 3 Classes of Operators:
A Operator – An individual with a broad understanding of the UST regulations capable of making informed decisions about personnel and resources necessary to manage the portfolio of UST systems.
B Operator– An individual with a more specific understanding of the UST systems and the associated regulations, maintenance, and testing. Manages the day-to-day compliance and maintenance of one or more UST Systems.
C Operator– An individual capable of responding to emergencies or alarms resulting from the UST systems. At least one C Operator must be present at all times while the UST systems are operational. (There are special requirements for card-lock or unmanned locations).
Where can I get the training:
A/B Operator Training. States have varying requirements for operator certification and testing from 3rd party online and classroom curriculums, to implementing agency provided curriculums, to the International Code Council curriculum.
C Operator Training. C Operators can complete the same curriculums described for A/B operators, and can also be trained by the UST owner/operator’s designated A or B operator.
The proposed reg allows for “designated operator contractors”, which are 3rd party companies like 7G who take on the Operator A and/or B responsibility for a contracted rate. C operators must be employees.
When do I need to have the training completed (if the proposed regs go through):
You should refer to your state’s rule and implementation schedule (or contact 7G). The proposed reg would institute a tiered implementation schedule based on the age of the USTs present at the facility. Once the schedule ran, A/B operators would need to be trained within 30 days of taking on the responsibility. C operators would need training before they could start.
How do I prove that I have completed the trainings?
You must maintain documents to identify all operators by class and demonstrate the training (or retraining) via a list with names, operator class, date of assumed duties, date of training, and date of any retraining. The records must be kept for 3 years.
All in all the Operator Training regulations should not be a surprise to most. However, while most UST owners/operators have certified an A and B operator, they have not fully implemented a proper training and tracking plan for their C Operators. Due to the high turnover rate of the position corresponding to a C Operator, this requirement could pose a significant burden if the regulation goes through and is actually enforced.
For further information and for links to the federal regulations visit the 7G website Here.
The Effects of Gasoline Drips

By Zachary Poznak

The drops of gasoline that escape from the nozzle when you fill up your car can have a lasting impact of the environment. In a new study by researchers at the Johns Hopkins Bloomberg School of Public Health, they investigate the effect of these drips over time.

Every ten years, “the team conservatively estimated that some 356 gallons of gasoline leak from pumps.” The leaked gas accumulates in the concrete and will eventually reach the soil underneath. Even if only a small proportion of this leaked fuel reaches the soil, it can seep into groundwater and create a hazard for nearby residents. Gasoline contains benzene, which is a known carcinogen.

There has not been extensive research into the health effects of living near gas stations, but these researchers think that should change “especially as newer stations are being built with an increasing number of pumps.”

To see how 7G can help reduce environmental pollution and mitigate health risks, visit our website at or give us a call at 888.400.3511.

Tully, Andy. “Tiny Gasoline Drips Can Create Big Problems.” 9 Oct. 2014. Web. 20 Oct. 2014. <>.
Be careful not to stub your toe when dragging your feet in Michigan.

Michigan has a substantial backlog of cleanups from LUSTs (leaking underground storage tanks). Responsible parties know it and some have opted to create their own remediation timelines contrary to MI rules. Michigan regulators are catching on and taking action. In Department of Natural Resources and Environmental v. Strefling Oil Company, et al., an owner was faced with costs, fines and penalties due to his neglecting official deadlines for completing remediation milestones and submitting supporting documentation. The fine exceeded $800,000.00 and was upheld by the appellate court.

Many facility owners cringe at thought of having to manage remediation and incur the cost associated therewith. However, in Michigan (and many other states), it’s best to move forward in a timely manner (and grumble and curse if necessary) rather than incur the additional cost down the road of penalties and the headaches of litigation.

By: Nichole Crosby, 7G

Credits: Saulius Mikalonis
Over 6,500 fuel hoses are being recalled nationwide. Manufacturer Franklin Fueling Systems has placed a recall on their FLEX-ING FLEX-ON hardwall fuel hoses which are used in junction with nozzles, swivels and breakaways to dispense fuel.
The product has a faulty crimp which can cause the thread to loosen from the hose resulting in leaks and create a fire hazard. It is strongly suggested that consumers stop using the recalled hardware and replace it immediately. Leaking hoses are a threat both to consumer safety and the environment.

Read the full article at