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Storage Tank Enforcement: Proposed Tennessee Department of Environmental Conservation Order to Establish a Retail Motor Storage Tank in Knoxville
The Tennessee Department of Environment and Conservation (“TDEC”) issued an Order and Assessment (“Order”) to CGS Stores, LLC (“CGS”) on August 1, addressing alleged violations of the Tennessee Underground Storage Tank (UST) regulations. See Case No. UST-23-0207.
The order states that CGS is the registered owner of four UST systems in Knoxville, Tennessee.
Personnel from TDEC’s Underground Storage Tanks Division (“Division”) are reported to have conducted a compliance audit at the facility on May 16, 2023.
The inspection allegedly identified the following violations, which have not been remedied:
- The pipeline leak detection system has not been installed, calibrated, operated or maintained in accordance with the manufacturer’s instructions.
- Accessories and restraint systems were not installed according to the manufacturer’s installation instructions.
The department is said to have sent letters to the BGS criticising the violations identified during the inspection and the failure to restore conformity.
It is stated that CGS has not fully cooperated and continues to violate the department’s regulations.
The order provides that if CGS fails to comply with the order or does not file an appeal within the specified time periods, the facility will be placed on the delivery ban list and the filling openings or fuel pumps will be marked red until the order is complied with again.
A civil penalty of $4,800.00 is proposed.
CGS is also required to take all necessary actions to correct any remaining violations and bring the facility back into compliance with the law. The department must provide documentation of the corrective actions taken that is sufficient to demonstrate restoration of full compliance.
A schedule will be provided for these actions.
The regulation provides for certain rights of appeal.
A copy of the order can be downloaded here.
