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Regulated Emergency Generator Tanks and other Potential Pitfalls

Regulated Emergency Generator Tanks and other Potential Pitfalls. Generator tanks are regulated by the PADEP???. Trends and Terminology. For various reasons, more and more facilities are having generators installed Common Terminology: Auxiliary, Emergency, Standby, Backup Two Main Types :

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Regulated Emergency Generator Tanks and other Potential Pitfalls

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  1. Regulated Emergency Generator Tanks and other Potential Pitfalls Generator tanks are regulated by the PADEP???

  2. Trends and Terminology • For various reasons, more and more facilities are having generators installed • Common Terminology: Auxiliary, Emergency, Standby, Backup • Two Main Types: • Sub-Base = The generator sits directly on top of the fuel storage tank (“Integral Part of the Generator Unit”) • Commonly called “GenSets” or “Pedestal” • Usually shipped from the manufacturer as one complete unit • Free Standing = The generator and fuel storage tank are separate and installed side by side

  3. What do they look like?

  4. Storage Tank and Spill Prevention Act and Title 25, Chapter 245 • Storage Tank and Spill Prevention Act - Act of Jul. 6, 1989, P.L. 169, No. 32 • Effective August 5, 1989 • Chapter 245 is: Administration of the Storage Tank and Spill Prevention Act • Effective September 21, 1991

  5. Definition of a Regulated Aboveground Storage Tank • Chapter 245, Subchapter 245.1 Defines an Aboveground Storage Tank as: • Any tank greater than 250 gallons • Stationary (isn’t moved) • 90% or more above ground • Contains a regulated substance

  6. How can I tell if my generator tank is regulated by the PADEP? • 1) Is the tank associated with the generator greater than 1100 gallons in capacity? • 2) Is the tank storing a regulated substance, such as Diesel Fuel or Gasoline? • 3) Is the generator tank permanently installed?

  7. So where does 1100 gallons come in to the picture? • The definition of “Aboveground Storage Tank” contains a few exemptions: • A tank of 1100 gallons or less capacity used for storing motor fuel for noncommercial purposes or motor oil • Numerous other exemptions, but this is the one that takes small (1100 gallon or less) tanks out of regulatory purview • However…Tanks larger than 1100 gallons are regulated and must be registered with the PADEP

  8. What is a Motor Fuel? • 245.1 Defines Motor Fuel as: • “Petroleum or a petroleum based substance that is motor gasoline, aviation gasoline, No.1 or No. 2 diesel fuel or any grade of gasohol, and is typically used in the operation of an internal combustion engine.” • Almost every grade of diesel and gasoline is considered to be a motor fuel

  9. What does Noncommercialpurposes mean? • 245.1 Defines Noncommercial purposes as: • Motor fuel not for resale • Generator tanks generally do contain motor fuel “not for resale,” however, generator tanks greater than 1100 gallons fall outside the exemption and are regulated.

  10. So… My generator tank is regulated. What does that mean? • 1) The tank must be registered with PADEP and the owner must pay annual registration fees • 2) The tank must be installed by a PADEP certified installer • 3) The PADEP certified installer must have AMMX certification • AMMXstands for “Aboveground Manufactured Metallic Storage Tank – Installation and Modification” • The PADEP certified installer must have direct, onsite supervision and control of the installation

  11. What does a Storage Tank Registration Form Look Like???

  12. Where can I find an AMMX?

  13. Forms and Informationon the Web… www.depweb.state.pa.us • DEP Programs A-Z • “Storage Tanks”

  14. What if I don’t register the tank? Who is liable? Section 303(b) of the Storage Tank Act, 35 P.S. §6021.303(b), states, “It shall be unlawful to sell, distribute, deposit, or fill an aboveground storage tank with any regulated substance unless the aboveground storage tank is registered. Any person who knowingly sells, distributes, deposits, or fills any aboveground storage tank in violation of this subsection prior to the discovery of a release shall be liable for any release from the aboveground storage tank, in addition to the remedies provided in section 1302.”

  15. Hey wait!There is no on-site installation required…We just lift it off the flatbed trailer, set it in place, and wire it in!

  16. What does the PADEP certified individual actually do? A PADEP certified installer with AMMX certification must be present during installation to verify that the storage tank, foundation, ancillary equipment, and appurtenances all conform to the requirements of Chapter 245

  17. Soo…What are the requirements of Chapter 245? The tank must be equipped with “Emergency Containment” to capture and contain any spill or release from the tank Three common methods to achieve emergency containment: Dike (e.g. “Tank in Metal Box”) Building (Coated Masonry with no open drains to the Environment) Double walled tank Regardless of the method used, the emergency containment must: Contain the spill for a minimum of 72 hours Contain the total capacity of the tank Be compatible with the substance stored

  18. Other requirements of Chapter 245 The tank must also have “Secondary Containment” to provide a means of detecting a leak before it reaches the environment

  19. Aren’t Secondary Containment and Emergency Containment the same thing? NOPE… • Secondary containment is: • An additional layer of impervious material that creates a space for leak detection • Most often found underneath the tank

  20. What about Double Walled tanks?? The outer wall (secondary tank) of a double walled tank may provide Secondary Containment as well as Emergency Containment, if the tank is properly equipped.

  21. What is required to “Properly Equip” a Double Walled tank for Emergency Containment? • A spill bucket located at the fill port on top of the tank or located on the remote fill is needed to complete the emergency containment on a double walled tank • A spill bucket would also be required on the remote fill of a single walled tank if the remote fill is located outside the emergency containment area

  22. What else is required to “Properly Equip” a Double Walled tank for Emergency Containment? • A form of overfill prevention: • Overfill alarm; or • Prevention device (i.e. drop tube shutoff); or • A level monitoring gauge and a written shutdown procedure

  23. Anything else? • Block valves on all product lines • A solenoid valve or anti-siphon device, if appropriate (See PEI RP 200)

  24. Venting… Normal Venting…(Inhale, Exhale) • The primary tank requires an appropriately sized normal vent • <2,500 gallons = 1 ¼” • 2,500-3,500 gallons = 1 ½” • 3,001-10,000 gallons = 2” • Must be equal or larger in size than the fill line • Check the tank manufacturer’s specifications

  25. Emergency Venting… • Prevents BLEVE - boiling liquid expanding vapor explosion • The primary tank requires an appropriately sized emergency vent • The outer wall (secondary tank) of a double walled tank also requires an appropriately sized emergency vent • Vent size based on “wetted” surface area of tank • Check the tank manufacturer’s specifications

  26. Where should my tank vent to? • Outdoor Installations: If the generator tank is located within a well-ventilated, louvered housing (to protect the generator from the weather), the normal vent(s) and emergency vent(s) may not have to vent to the outside of the enclosure. • Indoor Installations: If the generator tank is located within a building or a non-ventilated structure, the normal vent(s) and emergency vent(s) must vent to the outdoor atmosphere.

  27. Labeling Is that an emergency generator or an air conditioning unit???

  28. Safety and Security Bollards, barriers, and fencing as required to prevent collisions and keep the curious away (see PA Labor and Industry regulations for more detailed information)

  29. Safety and Security (cont’d) Does this tank appear to be adequately protected from vehicular collisions?

  30. Other Requirements • A check of local ordinances, fire codes, and other regulatory agencies should be part of the installation preparation • Owners must keep a record of monthly maintenance inspections • If the tanks are greater than 5,000 gallons they must undergo an integrity inspection by a PADEP certified inspector (IAM) at least once every ten years

  31. Summary • Generator sets that utilize fuel tanks that are greater than 1100 gallons are regulated under the Storage Tank Law (Chapter 245) • These tanks need to be installed by PADEP certified individuals • Installation includes: • Foundation work • Setting the generator unit on the pad • Hooking up the generator unit

  32. Summary (cont’d) • Owner must register tank with DEP • Registration form must be signed by the owner • Registration form must be signed by the PADEP Certified individual (AMMX) • Owner must maintain a record of monthly maintenance inspections • Owner must have Integrity inspections every ten years if the tank is greater than 5,000 gallons capacity

  33. Other Potential Pitfalls • Skid tanks are often regulated… Skid tanks that are not moved may be regulated and need to be registered… If the use of the tank does not require that it be moved for over 1 year, then the tank is regulated and needs to be registered with PADEP • When skid tanks aren’t moved, they are regarded as “Stationary”

  34. Tote tanks • Tote tanks that are not removed in the normal course of their use may also be regulated by the PADEP • Like skid tanks, they may become “Stationary” by permanently installing them or not regularly removing them

  35. Tank cars & Tractor Trailer Tanks • Old railroad tank cars and tractor trailer tanks are often parked and used as “Stationary” tanks • They must be properly supported • Must have secondary and emergency containment • Must be inspected by a PADEP certified inspector to verify condition and compliance with chapter 245 • Must be registered with the PADEP

  36. Compartmented and Manifolded Tanks • Each compartment of a compartmented tank is considered a separate, individual tank • Each compartment could be regulated or not depending on its contents and capacity • Manifolded tanks create unique scenarios that may have to be evaluated by the DEP • Example: • 2 separate 200 gallon new antifreeze tanks that are individually piped = 2 exempt tanks • 2 separate 200 gallon new antifreeze tanks with piping manifolded together = 1- 400 gallon regulated tank system

  37. Have Questions??? • In PA: 1-800- 42-TANKS • Local & Out of State: 1-717-772-5599

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