Regulated Emergency Generator Tanks and other Potential Pitfalls

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Regulated Emergency Generator Tanks and other
Potential Pitfalls

• Generator tanks are regulated by the PADEP???

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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

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What do they look like?
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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

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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 (isnt moved)
• 90 or more above ground
• Contains a regulated substance

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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?

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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
• HoweverTanks larger than 1100 gallons are
  regulated and must be registered with the PADEP

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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

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What does Noncommercial purposes 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.

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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
• AMMX stands for Aboveground Manufactured
  Metallic Storage Tank Installation and
  Modification
• The PADEP certified installer must have direct,
  onsite supervision and control of the installation

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What does a Storage Tank Registration Form Look
Like???
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Where can I find an AMMX?
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Forms and Informationon the Web

• www.depweb.state.pa.us
• DEP Programs A-Z
• Storage Tanks

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What if I dont 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.

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(No Transcript)
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Hey wait!There is no on-site installation
requiredWe just lift it off the flatbed
trailer, set it in place, and wire it in!
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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

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SooWhat 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

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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

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Arent 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

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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.

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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

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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

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Anything else?

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

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Venting

• Normal Venting(Inhale, Exhale)
• The primary tank requires an appropriately sized
  normal vent
• lt2,500 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 manufacturers specifications

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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 manufacturers specifications

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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.

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Labeling

• Is that an emergency generator
• or an air conditioning unit???

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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)

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Safety and Security (contd)

• Does this tank appear to be adequately protected
  from vehicular collisions?

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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

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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

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Summary (contd)

• 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

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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 arent moved, they are regarded
  as Stationary

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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

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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

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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

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Have Questions???

• In PA 1-800- 42-TANKS
• Local Out of State 1-717-772-5599