Guide to Pulling tanks

Managing Leaking Underground Storage Tanks (LUSTs) in Michigan.

Global Environmental’s step-by-step guide helps Michigan gas station owners navigate LUST regulations, manage UST closures, ensure compliance with EGLE and LARA, and reduce environmental and financial risks.

Download Guide

TANK CLOSURE & COMPLIANCE

Across Michigan, many gas stations still operate with aging underground storage tanks (USTs), some of which are already leaking beneath the surface.

Leaking USTs can contaminate soil and groundwater, creating environmental risks and triggering costly regulatory requirements. Managing a Leaking Underground Storage Tank (LUST) involves a structured process of reporting, site assessment, remediation, and regulatory closure, all overseen by EGLE and LARA. Whether removing a tank, responding to a release, or closing a site, gas station owners must follow strict guidelines and work with environmental professionals to ensure compliance, reduce liability, and protect their property.
‍
Download Guide

LEGAL CONSIDERATIONS

LUST reporting requirements for Michigan gas station owners.

Michigan law requires gas station owners to promptly report confirmed or suspected LUST releases to EGLE. Timely reporting ensures compliance, limits environmental damage, and helps avoid penalties.

Report all confirmed or suspected LUST releases to EGLE without delay

Report contamination discovered during routine site work, even without an open release case

Failure to report can result in fines, legal penalties, and increased cleanup costs

Prompt action ensures compliance and supports efficient site resolution

Environmental Investigation

Testing, assessment & closure for LUST sites.

Accurate environmental testing is essential for managing Leaking Underground Storage Tank (LUST) releases, guiding corrective action and ensuring regulatory compliance through every stage of site assessment and closure.

Initial Assessment Report (IAR): Evaluates contamination and includes initial soil, groundwater, and vapor sampling

Final Assessment Report (FAR): Confirms contamination, documents remediation, and supports regulatory closure

Corrective Action & Closure: Implements cleanup, submits Closure Report, and secures EGLE approval

Ongoing Site Management: May include land-use restrictions (e.g., RCs) to ensure long-term safety

Closure process

Proper UST closure follows a regulated process to ensure safety and compliance.

Closure involves notifying regulatory agencies, obtaining permits, removing or decommissioning the tank, conducting soil and groundwater sampling, addressing any contamination, and submitting a Closure Report to EGLE to confirm compliance and eliminate exposure risks.

Download Guide

1. Regulatory Notification & Permits

• Submit a Notification of Intent to Close to the applicable state agency (e.g., EGLE in Michigan).

• Additional coordination with other agencies, such as LARA, may be required depending on the state.

• Obtain necessary permits from local and state authorities.

2. Tank Closure: Emptying, Cleaning, Removal

• After obtaining the necessary permits, empty the tank by removing all fuel and residue to prevent contamination spread.

• If feasible, physically remove the tank and clean it for offsite disposal or scrap.

• A “Closure in Place” is an option if removal is impractical. This involves removing all piping and dispensers and filling the space with an inert material (e.g., concrete or foam).

3. Soil & Groundwater Sampling

• When a UST is removed, collect soil or groundwater samples from the bottom of the excavation to determine if contamination is present.
‍
• A suspect release should be reported to the applicable regulatory agency if visual or olfactory contamination is observed during UST removal activities.

• Confirm a release only after analytical results verify contamination.

4. Corrective Actions (If Necessary)

• If contamination is observed and removal is feasible, verification soil remediation (VSR) samples can be collected to confirm the complete removal of impacted soil.

• If all contamination is removed, a release is not reported, and a report is submitted documenting the UST removal activities and analytical results.

• If residual contamination remains, determine whether the site has an open release: a) If the tank removal is associated with an existing open release, continue with the regulatory process under that case. b) If no open LUST site exists, a new release must be reported, and the site proceeds through the full LUST process, including Initial Assessment Report (IAR), Final Assessment Report (FAR), and Closure.

5. Closure Report Submission

• Compile and submit a Closure Report documenting the removal process, sampling results, and any corrective actions taken.

• Regulatory closure confirms exposure pathways have been eliminated but does not necessarily mean all contamination has been removed.

• Await final approval from EGLE to confirm regulatory closure.