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???
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
What do they look like?
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
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

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?
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
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
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.
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
What does a Storage Tank
Registration Form Look Like???
Where can I find an AMMX?
Forms and Information
on the Web…
www.depweb.state.pa.us
 DEP
Programs A-Z
 “Storage Tanks”
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.”
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!
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
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
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
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
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.
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
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
Anything else?
 Block valves on all
product lines
 A solenoid valve or
anti-siphon device, if
appropriate (See
PEI RP 200)
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
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
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.
Labeling
Is that an emergency generator
or an air conditioning unit???
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)
Safety and Security (cont’d)
Does this tank appear to be adequately
protected from vehicular collisions?
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
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

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
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”
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
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
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
Have Questions???
 In PA: 1-800- 42-TANKS
 Local & Out of State: 1-717-772-5599
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