TIP TIPS Newsletter. April 14, 2014 Volume 14 Number 3 Phone Number Change

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1 TIP TIPS Newsletter April 14, 2014 Volume 14 Number 3 Phone Number Change THIS ISSUE TIP PHONE NUMBER CHANGE PADEP TRAINING DEP TANK MODIFICATION DOCUMENT REVISED TIP CURRENT BOARD The TIP phone number has changed to effective immediately. When calling you will hear: For Ben Hieber, TIP President or Steve Hieber, TIP Legislative Liaison, PWI, Inc. Dial 101. For Greg Dubas, TIP Treasurer, Pine Run Construction, Dial 102. To leave a message in the TIP General Mailbox, dial 100 (Pat Tarby, Administration Pine Run Construction) PADEP Training TIP successfully provided PADEP Certification Renewal Training in Allentown on March 26, 2014 and Pittsburgh on April 2, A total of 77 attendees received training in Underground and/or Aboveground installation and removal. Our instructor, Buddy Bayliss, of PEI, provided very professional and interesting training sessions. New DEP Guidance Document Visit us on the web Members only pages user id = 14member password = tanks PADEP has issued a new Guidance Document (copy attached) concerning Storage Tank Modification and Maintenance Issues of both underground and aboveground tank systems. TIP made comments on the proposed changes which had an impact on the final document (copy attached). Note that all comments received by DEP were from TIP or TIP s officers and directors. OFFICERS/DIRECTORS President Ben Hieber (PWI) Vice-President Brian Dubas (Pine Run Construction) Treasurer/Past President Greg Dubas (Pine Run Construction) Directors Steve Muckin (Bayard) Scott Hafer (Hafer Petroleum) Steve Hieber (PWI) Don Carlucci (Carlucci Const.) Ed Tropper (Jemko) Frank DiDonato (SIS) Craig Smith (Francis Smith & Sons)

2 Comment and Response Document for Storage Tank Modification and Maintenance Issues Bureau of Environmental Cleanup and Brownfields January 30, 2014

3 Introduction This is a list of corporations, organizations and interested individuals from whom the Pennsylvania Department of Environmental Protection ( Department ) has received comments regarding the above referenced technical guidance document. The draft technical guidance document was published in the Pennsylvania Bulletin on September 28, 2013, with a 30-day public comment period. During the comment period, the Department received 17 comments from 7 individuals, corporations and organizations. The following table lists these commentators. The Commentator ID number is found in parenthesis following the comments in the comment/response document. 1. J. Stephen Hieber PWI, Incorporated New Oxford, PA Frank J. DiDonato PA DEP Certified Individual 3. Scott Hafer, President Hafer Equipment Reading, PA Gregory E. Dubas, President Pine Run Construction Doylestown, PA Tank Installers of Pennsylvania Lewisberry, PA Brian Dubas, Vice-President Pine Run Construction Doylestown, PA Craig Smith Francis Smith and Sons, Inc. Chinchilla, PA Commentators: - i -

4 COMMENTS AND RESPONSES General Comments 1. Comment: The activity and experience requirements, as currently stated in regulation, that serve as prerequisites for individuals seeking initial UMX certification should be modified. Suggest that a certified manufacturer provide training for the current tank installation requirement. The individual would then need to be involved with nine tank handling activities over a 1-year period. Current prerequisites require an individual be involved with nine tank installations over a 3-year period. There are not enough tank installations being performed to meet this requirement. By making this change, certified companies would be able to increase the number of employees with UMX certification and would avoid PA DEP from creating any additional certification categories. (2) Response: This comment addresses issues beyond the scope of the Department s Draft Technical Guidance Storage Tank Modification and Maintenance Issues. The Department will consider this comment during the next revision to Chapter Comment: The listed examples of activities should be numbered, rather than bulleted, to make it easier to review within the document. (3) Response: The Department acknowledges the commentator s concern but believes that a bulleted format is preferable as compared to numbering. Numbering may give the false impression that the activities are being listed in order of importance, which they are not. 3. Comment: In order to assist the PA DEP with allowing activities such as automatic tank gauge console replacement and line leak detector installation to be performed by a technician holding current certification from the manufacturer, rather than a PA DEP certified installer, allow the PA DEP certified company representative to submit the PA DEP Modification Report in place of a PA DEP certified individual. (3) Response: This comment addresses issues beyond the scope of the Department s Draft Technical Guidance Storage Tank Modification and Maintenance Issues. The Department will consider this comment during the next revision to Chapter 245. Minor Modification Activities: Underground Storage Tank Systems 4. Comment: Bullet #1 states Staking and placing of concrete forms, and/or pouring concrete, over the tank field and piping runs. Staking and placing forms prior to the actual pouring of concrete is the critical portion of this activity. Pouring concrete once the forms are set presents no danger to the tanks and piping and can be done by an uncertified person. The phrase pouring concrete should be removed. (3) (4) (5) (6) (7) Response: The Department agrees that the staking and placing of forms over the tank field and piping runs is the critical part of the activity. However, ensuring the correct thickness of the grade slab is also important in providing anchoring of the tank system or protection of the underground storage tank system components from vehicular traffic. The Department acknowledges that while a Department certified installer need not be - 1 -

5 present during the actual act of pouring concrete, the certified installer must confirm that the correct thickness is applied and should be consulted throughout the process. Chapter (a)(7) supports the Department s assertion by requiring certified installers to certify that both certified activities and nontank handling activities be performed in accordance with Department regulations when both have been performed as part of the overall project. Rather than remove the phrase pouring concrete as the commentators suggest, the Department has rephrased bullet #1 to read Staking and placing of concrete forms, and assurance of proper concrete or grade slab installation, over the tank field and piping runs. 5. Comment: Bullet #5 states Replacement or removal of leak detector/pump-manifold (packer) assembly. Replacement of a leak detector can be performed by an uncertified service technician. There seems to be confusion regarding the packer assembly and the manifold. The packer assembly is the extractable part of a submersible pump; the manifold is the portion that is threaded onto the four (4) inch riser. Removal and replacement of the packer assembly is a normal maintenance function in the replacement of a sub pump motor. Submersible turbine pump (STP) manifold is the proper nomenclature and should be performed by a certified installer. The phrase leak detector/pump-manifold (packer) should be replaced with submersible pump manifold. (1) (3) (4) (5) (6) Response: The Department acknowledges that the replacement of like-kind line leak detectors can be accomplished by non-certified individuals without the oversight of a Department-certified installer. However, the initial installation of a line leak detector and changing the type of line leak detector, from mechanical to electronic for example, remains a tank handling activity requiring the direct oversight of a Department-certified installer. The Department agrees with the commentators regarding classifying the removal and replacement of the packer assembly as a normal maintenance function and has subsequently replaced leak detector/pump-manifold (packer) with submersible pump manifold. 6. Comment: Bullet #6 states Replacement, removal or disconnection of piping connectors. The term piping connectors is considered too vague. I am not sure what this means in relation to the fueling system s piping. Is this a pipe coupling or perhaps a pipe union? Clarification on the term piping connectors is requested. (3) Response: The Department acknowledges the commentator s concern. The Department uses the term piping connector to mean any piping fitting or section of piping, such as a flexible connector, which interconnects regulated piping. The Department has rephrased bullet #6 to read Replacement, removal or disconnection of any piping fitting or section of piping, such as a flexible connector, which interconnects regulated piping. 7. Comment: Bullet #7 states Replacement, removal or disconnection of break-away (shear) valves. The usage of the term break-away is incorrect as it is understood in the industry. Replace the term break-away with impact or emergency valve. A breakaway device is part of the hanging hardware. The requirement for a certified individual should only be for a complete valve replacement. Replacement of an emergency valve top should be considered a maintenance activity. (1) (3) (4) (5) (6) (7) - 2 -

6 Response: The Department agrees with the commentators initial suggestion and has replaced the term break-away (shear) with emergency shutoff (impact). The Department does not agree that the replacement of the top portion of the emergency shutoff valve should be considered a maintenance activity that could be performed without the oversight of a Department-certified installer. A repair of the top portion of the emergency shutoff valve is considered a repair of the emergency shutoff valve itself, which is an integral part of a storage tank system. 8. Comment: Bullet #12 states Initial installation of a line leak detector. The initial installation of a line leak detector should not require UMX certification but should only be performed by a technician holding current certification from the manufacturer. (1) Response: The Department does not agree that the initial installation of release detection equipment should be accomplished by non-certified individuals without the oversight of a Department-certified installer. Line leak detectors are routinely used to satisfy the regulatory requirement for piping release detection. Chapter defines a tank handling activity as activities to install, modify or remove all or part of a storage tank system or storage tank facility Further, the definitions for both storage tank system and storage tank facility include release detection components that control or monitor the flow of product. In accordance with Chapter (a), tank handling activities must be performed by, or under the direct onsite supervision and control of, a Departmentcertified installer. As noted on page 6 of the draft technical guidance document, the Department recognizes that equipment manufacturers may require trained or manufacturer-licensed technicians to perform certain activities on their equipment. Also, Chapter (a)(2) states that release detection equipment must be installed and calibrated in accordance with the manufacturer s instructions. Therefore, a manufacturerlicensed technician, who is not a Department-certified installer, may install a line leak detector, but the activity must be overseen by a Department-certified installer. 9. Comment: Bullet #13 states Changing the type of line leak detector, such as mechanical to electronic. Changing the type of line leak detector from mechanical to electronic, for example, is frequently performed by a non-certified but manufacturertrained technician. The activity should not require UMX certification. The activity should be allowed to be performed by a technician who is trained and certified by the manufacturer, and the activity documented by a certified installer with submission of a Modification Report. (1) (3) (4) (5) (6) Response: The Department does not agree that changing the method of line leak detection should be accomplished by non-certified individuals without the oversight of a Department certified installer. As this activity would involve the initial installation of the new type of line leak detector, see the Response to Comment 8. Changing the type of line leak detector, from mechanical to electronic for example, remains a tank handling activity requiring a Department-certified installer. Additionally, Chapter (a)(2) and (a)(6) do not support the submittal of a Modification Report by a Department-certified installer for a tank handling activity that was not performed or overseen by the Department certified installer

7 10. Comment: Bullet #15 states Installation, repair or replacement of spill containment devices, including the installation or replacement of drain valves or plugs. Clarification should be made that replacement of spill containment devices, including drain valves or plugs, that requires excavation, is a major modification. (3) (4) (5) (6) (7) Response: This example activity is listed in the Department s Draft Technical Guidance Storage Tank Modification and Maintenance Issues under the heading of Minor Modification Activities. Included in the paragraph beneath this heading is qualifying text that specifically states the listed activities may not involve excavations during their performance. However, to further clarify the Department s position, and to remain consistent with other listed activities under that heading, the Department has added the phrase without excavation to the end of bullet # Comment: Bullet #16 states Initial installation or complete replacement of an automatic tank gauging system, or the replacement of an automatic tank gauge console. The initial installation or replacement of an automatic tank gauging system and the installation or replacement of an automatic tank gauge console is frequently performed by non-certified individuals who have been trained and certified by the manufacturer. The activity should be allowed to be performed by a technician who is trained and certified by the manufacturer, and the activity documented by a certified installer with submission of a Modification Report to the PA DEP. (3) (4) (5) (6) Response: The Department does not agree that the initial installation or replacement of release detection equipment (other than with like-kind line leak detectors) should be accomplished by non-certified individuals. The Department has consistently maintained the position that the initial installation of release detection equipment must be performed by, or under the direct onsite supervision and control of, a Department-certified installer. Also see the responses to Comments 8 and 12. Additionally, Chapter (a)(2) and (a)(6) do not support the submittal of a Modification Report by a Department-certified installer for a tank handling activity that was not performed or overseen by the Department-certified installer. 12. Comment: Bullet #16 states Initial installation or complete replacement of an automatic tank gauging system, or the replacement of an automatic tank gauge console. The last portion or the replacement of an automatic tank gauge console should be deleted. The replacement of an automatic tank gauge console should not require UMX certification. But the activity should be performed by a technician holding current certification from the manufacturer. (1) Response: The Department s position is that the replacement of an automatic tank gauge (ATG) console should be performed under the direct, onsite supervision of a Departmentcertified installer. The ATG console is routinely used to satisfy regulatory requirements for both tank and piping release detection. Correct programming of the ATG console is required to prevent significant environmental harm resulting from an undetected release of product. Chapter defines a tank handling activity as activities to install, modify or remove all or part of a storage tank system or storage tank facility Further, the definitions for both storage tank system and storage tank facility include release detection and monitoring equipment. In accordance with Chapter (a), tank handling - 4 -

8 activities must be performed by, or under the direct onsite supervision and control of, a Department-certified installer. As noted on page 6 of the draft technical guidance document, the Department recognizes that equipment manufacturers may require trained or manufacturer-licensed technicians to perform certain activities on their equipment. Also, Chapter (a)(2) states that release detection equipment must be installed and calibrated in accordance with the manufacturer s instructions. Therefore, a manufacturerlicensed technician, who is not a Department-certified installer, may replace an ATG console, but the activity must be overseen by a Department-certified installer. Maintenance Activities: Aboveground and Underground Storage Tank Systems 13. Comment: Bullet #8 states Replacement or repair of the tank pump or submersible turbine (with extractable column) if accessible through the manhole or tank riser sump (not involving removal or disconnect of packer manifold assembly or piping below the ground or grade surface). Proper nomenclature should be used regarding the phrase packer manifold assembly. The term packer should either be deleted or replaced with the term discharge. (1) Response: The Department agrees with the commentator s suggestion and has deleted the term packer from the listed example activity. 14. Comment: Bullet #9 states Repair of line leak detectors and repair or replacement of metering devices (with like kind devices) when accessible from aboveground or through manholes. Line leak detectors generally cannot be repaired. Add the term replacement regarding line leak detectors so that all line leak detectors be repaired or replaced by a manufacturer certified technician. (1) (3) (4) (5) (6) Response: The Department acknowledges the commentators comments and has rephrased the listed activity to Repair or replacement (with like kind devices) of line leak detectors or other metering devices when accessible from aboveground or through manholes. The phrase with like kind devices applies to both line leak detectors and other metering devices. As discussed in the Responses to Comments 8 and 9, the first time installation or changing the type of line leak detectors, from mechanical to electronic for example, remains a tank handling activity requiring the use of a certified individual. 15. Comment: Bullet #10 states Changing or replacing product dispenser components above the break-away (shear) valve (not involving piping disconnect at the valve). The usage of the term break-away is incorrect as it is understood in the industry. Replace the term break-away with impact or emergency valve. Clarification is requested regarding product piping disconnect below the impact valve, which would require the use of a certified individual. Piping above the impact valve may have to be disconnected to replace dispenser components which can be performed by an uncertified service technician. (1) (3) (4) (5) (6) Response: The Department agrees with the commentators initial suggestion and has replaced the term break-away (shear) with emergency shutoff (impact). The Department has also rephrased the listed activity to, Changing or replacing product - 5 -

9 dispenser components above the emergency shutoff (impact) valve (not involving piping disconnect at or below the valve). 16. Comment: Bullet #11 states The decommissioning of a Stage II vapor-recovery system not involving excavation or tank handling activity, such as the replacement or removal of product dispensers, or the replacement, removal or disconnection of product piping, piping connectors or break-away (shear) valves. Replacement, removal or disconnection of vapor piping during the decommission process of Stage II vapor recovery piping should be considered a tank handling activity and should be performed under the direct onsite supervision of a certified installer. The usage of the term breakaway is incorrect as it is understood in the industry. Replace the term break-away with impact or emergency valve. (3) (4) (5) (6) (7) Response: The Department acknowledges the commentators comments and after further review of PEI/RP300-09, Recommended Practices for Installation and Testing of Vapor-Recovery Systems at Vehicle-Fueling Sites, and Chapter has classified the decommissioning of a Stage-II vapor-recovery system as a tank handling activity requiring the use of a Department-certified installer. Chapter of the Storage Tank Regulations defines a tank handling activity as activities to install, modify or remove all or part of a storage tank system or storage tank facility Further, the definitions for both storage tank system and storage tank facility include vapor recovery piping. This activity has been listed under Minor Modification Activities: Underground Storage Tank Systems and reads, The decommissioning of a Stage II vapor-recovery system involving the replacement, removal or disconnection of Stage II vapor-recovery piping. 17. Comment: Bullet #17 states Installing temporary leak clamps. Temporary leak clamps should never be used. Eliminate this item from the list. (3) (4) (5) (6) (7) Response: The Department agrees with the commentators suggestion and has removed the listed activity

10 DEPARTMENT OF ENVIRONMENTAL PROTECTION Bureau of Environmental Cleanup and Brownfields DOCUMENT NUMBER: TITLE: Storage Tank Modification and Maintenance Issues EFFECTIVE DATE: March 29, 2014 AUTHORITY: POLICY: PURPOSE: APPLICABILITY: DISCLAIMER: The Storage Tank and Spill Prevention Act, P.L. 169, No. 32 of 1989 as amended (Tank Act), and 25 Pa. Code, Chapter 245 (Storage Tank Regulations). It is the policy of the Department of Environmental Protection (DEP) to carry out the provisions of the Storage Tank and Spill Prevention Act of 1989 as amended and related regulations. This guidance specifies the classification of various storage tank system modification and maintenance activities and when certified installers/inspectors are required. This guidance is primarily applicable to certified companies, inspectors and installers, and it may be helpful to owners and operators of aboveground and underground storage tank systems or storage tank facilities. The policies and procedures outlined in this guidance document are intended to supplement existing requirements. Nothing in the policies or procedures shall affect regulatory requirements. The policies and procedures herein are not an adjudication or a regulation. There is no intent on the part of the Department to give these rules that weight or deference. This document establishes the framework within which DEP will exercise its administrative discretion in the future. DEP reserves the discretion to deviate from this policy statement if circumstances warrant. PAGE LENGTH: 10 pages / March 29, 2014 / Page i

11 MODIFICATION AND MAINTENANCE ISSUES DEFINITIONS: The following definitions are found in 25 Pa. Code, and are provided here with added guidance for clarification where noted. Ancillary Equipment Electrical, vapor recovery, access or other systems and devices, including, but not limited to, devices, such as piping, fittings, flanges, valves and pumps used to distribute, meter, monitor or control the flow of regulated substances to or from a storage tank system. Containment Structure or Facility Anything built, installed or established which comes in contact with regulated substances that are spilled, leaked, emitted, discharged, escaped, leached or disposed from a storage tank or storage tank system. The term includes, but is not limited to, a vault, dike, wall, building or secondary containment structure around an underground or aboveground storage tank, or any rock or other fill material placed around an underground storage tank. Emergency Containment A containment structure which serves to convey, capture and contain the total volume of an anticipated release of regulated substance from an aboveground or underground storage tank system and which is expeditiously emptied. Excavation Zone The volume containing the tank system and backfill material bounded by the ground surface, walls and floor of the pit and trenches into which the underground storage tank system is placed at the time of installation. Maintenance The normal operational upkeep to prevent a storage tank system or storage tank facility from releasing regulated substances if the activity involved is not a major modification or minor modification. Major Modification (i) An activity to upgrade, repair, refurbish or restore all or any part of an existing storage tank system or storage tank facility which: (A) (B) Alters the design of that storage tank system or storage tank facility. May affect the integrity of that storage tank system or storage tank facility. (ii) The term includes an activity directly affecting the tank portion of the storage tank system or an activity directly affecting an underground component of the storage tank system. In performing a major modification, the underground component is accessible only by breaking ground which may include breaking and/or removal of concrete or backfill material, but does not include the displacement or removal of backfill material by hand within the extent of the tank and piping installation excavation (added guidance for clarification). Minor Modification (i) An activity to upgrade, repair, refurbish or restore all or part of an existing storage tank system or storage tank facility which does not alter the design of that storage tank system or storage tank facility, but which may affect the integrity of that storage tank system or storage tank facility / March 29, 2014 / Page 1

12 (ii) The term does not include an activity directly affecting the tank portion of the storage tank system or an activity directly affecting an underground component of the storage tank system. However, the term may include an activity only affecting ancillary equipment, which is below grade (ground surface), but is readily accessible from aboveground through a manhole or containment sump opening and no excavation is involved in the activity excepting the displacement or removal of backfill material by hand when the activity does not involve the tank or alter the tank system design, as indicated in this guidance (added guidance for clarification). Storage Tank Facility One or more stationary tanks, including associated intrafacility pipelines, fixtures, monitoring devices and other equipment. A facility may include aboveground tanks, underground tanks or a combination of both. For the purposes of the act and this guidance, the associated intrafacility pipelines, fixtures, monitoring devices and other equipment for an aboveground storage tank shall be that which lies within the emergency containment area. The term storage tank facility does not encompass portions of a facility that do not contain storage tank systems. Storage Tank System An underground or aboveground storage tank, associated underground or aboveground piping directly serving that storage tank, and one or more of the following which are directly associated with that storage tank: (i) (ii) (iii) (iv) (v) (vi) Ancillary equipment. Foundation. Containment structure or facility. Corrosion protection system. Release detection system. Spill and overfill protection system. Tank Handling Activity Activities to install, modify or remove all or part of a storage tank system or storage tank facility. The term does not include maintenance activities. The term includes major modification and minor modification activities (added guidance for clarification). TECHNICAL GUIDANCE: The terms Major Modification, Minor Modification and Maintenance are defined in 25 Pa. Code, Chapter 245. Activities performed to upgrade, repair, refurbish or restore an existing storage tank system or storage tank facility can be categorized under one or more of these definitions. Moreover, modification activities are categorized as tank handling activities, while maintenance activities are not. Tank handling activities must be performed by or under the direct, onsite supervision and control of a DEP certified installer meaning the certified installer must be present throughout the duration of any tank handling activity except that the modification of an aboveground nonmetallic storage tank may be performed by the tank manufacturer (see (a)). Tank handling activities conducted on any fieldconstructed storage tank or on a large aboveground storage tank (tank having a capacity greater than 21,000 gallons) must also be inspected by a DEP certified inspector, except in the case of minor modification or tank removal activities (see (b)). For information on which certification categories are required for specific tank handling or related inspection activities, refer to Storage Tank Program Fact Sheet 2630-FS-DEP1647 Understanding the Certification Categories and see or , respectively. Additionally, see for conflict of interest provisions that are applicable to certified inspectors for tank handling activities / March 29, 2014 / Page 2

13 Figure 1 depicts a decision chart to assist one with determining whether an activity is a major or minor modification, or maintenance activity. MAJOR MODIFICATION YES YES NO DOES THE ACTIVITY ALTER THE DESIGN OF THE FACILITY OR SYSTEM? YES DOES IT AFFECT THE TANK PORTION OF THE SYSTEM? DOES IT AFFECT AN UNDERGROUND COMPONENT OF THE SYSTEM? YES NO DOES IT AFFECT THE INTEGRITY OF THE FACILITY OR SYSTEM? NO IS THE COMPONENT ACCESSIBLE WITHOUT BREAKING GROUND? NO NO YES MAINTENANCE (No Certification Required) MINOR MODIFICATION Figure 1 Storage Tank System Modification/Maintenance Activity Decision Chart An activity that directly affects the tank portion of an existing storage tank system is, generally, a major modification. Activities affecting the associated piping or other components of an existing storage tank system or storage tank facility may have an effect on the design and/or integrity of the storage tank system or facility itself. Factors considered in classifying an activity as a modification or maintenance activity include: the position of the component on the storage tank system; the accessibility of the component; the function of the component relative to the storage tank system or storage tank facility; and the nature of the activity and method(s) by which it is conducted / March 29, 2014 / Page 3

14 For aboveground storage tank (AST) systems see the depictions in Figure 2 (below), and Figure 3 and Figure 4 on page 5. Major modifications to aboveground storage tank systems include: Replacement or repair of welded lines or fittings, manways, hot taps, welds on the tank or tank shell penetrations, or other tank shell openings up to the first control valve. Installation of new or additional piping runs within the emergency containment. Minor modifications include: Initial installation of all piping, valves, pumps, gauges and vents for which the tank was designed, and for which fittings exist on the tank. Replacement, repair, cutting, torching, or welding of piping or fittings, downstream from and including the first control valve, and within the emergency containment. Maintenance activities include, when no cutting or welding is involved as part of the activity: Direct replacement (with like kind and function) or repair of threaded lines and fittings, flanged lines and fittings, pumps, valves or other tank appurtenances downstream of the first tank control valve. Direct replacement of gauges and vents for which the tank was designed and for which fittings exist on the tank. Figure 2 Aerial view of example AST Systems within emergency containment / March 29, 2014 / Page 4

15 Figure 3 Small Manufactured AST System (example area shown is within emergency containment) Figure 4 Field-Constructed AST System (example area shown is within emergency containment) / March 29, 2014 / Page 5

16 For underground storage tank systems, modification activities involving the removal and replacement of an existing dispenser may require the installation of under-dispenser containment. When such activity involves construction at the dispenser island that disturbs the steel mounting frame of the existing dispenser, it is considered a major modification. For additional information, see (e) and Storage Tank Program Fact Sheets 2630-FS-DEP4175 Underground Storage Tank Dispenser Containment and 2630-FS-DEP4176 Containment Testing for Underground Storage Tanks. Whether for aboveground or underground storage tank systems, modification activities and inspections must be properly documented on the appropriate form(s), which must be submitted to DEP. See the following Storage Tank Program forms and accompanying instructions for their completion and submittal requirements: 2630-FM-BECB0575 Underground Storage Tank Modification Report 2630-FM-BECB0151 Aboveground Storage Tank Modification Report 2630-FM-BECB0601 Aboveground Storage Tank Modification Inspection Summary Modification activities may involve or be performed in conjunction with storage tank cleaning activities and/or a partial storage tank system closure. For storage tank cleaning activities, see Storage Tank Program guidance number Storage Tank Cleaning Activities. For removal or partial closure of a storage tank system, see guidance number Closure Requirements for Aboveground Storage Tank Systems and guidance number Closure Requirements for Underground Storage Tank Systems. Equipment manufacturers may require trained or manufacturer-licensed technicians to perform certain types of testing, modification or maintenance activities on specific equipment or system components. Always check the equipment manufacturer warranties and maintenance manuals or equipment performance publications to prevent voiding warranties or performing improper maintenance. All maintenance activities should be performed by someone with appropriate knowledge of the storage tank system and experience in performing required maintenance, and in adherence to occupational safety practices. These definitions, technical guidance, figures and examples are used to determine under which term an activity is classified. This will assist one in determining when a certified installer is required to perform the activity and when a certified inspector is required for field-constructed tanks or large aboveground storage tank major modification activities. For additional information on underground storage tank (UST) maintenance and UST system depictions, see U.S. Environmental Protection Agency (EPA) publications 510-R UST Systems: Inspecting And Maintaining Sumps And Spill Buckets Practical Help And Checklist and 510-B Operating And Maintaining Underground Storage Tank Systems: Practical Help And Checklists at EPA s website ( See also the Petroleum Equipment Institute s (PEI) recommended practices (RP) PEI/RP900 Recommended Practices for the Inspection and Maintenance of UST Systems and PEI/RP1200 Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities. EXAMPLES: These examples of major modification, minor modification, and maintenance activities on aboveground and underground storage tank systems and storage tank facilities may not be allinclusive, but rather reflect most frequently asked questions / March 29, 2014 / Page 6

17 Major Modification Activities: These activities alter the design of a storage tank system or storage tank facility, and may affect the integrity of the storage tank system or storage tank facility. These activities may involve excavation during their performance. Aboveground Storage Tank Systems The following activities performed on field-constructed or large aboveground storage tanks require modification inspections by third-party inspectors appropriately certified by DEP. Replacement or addition of a tank shell plate or plates. Repair or replacement of the tank bottom or any partial repair or replacement of the tank bottom. Installation, repair or replacement of interior (internal) tank lining or coating. Installation, replacement or structural repair of the tank integral roof or of an internal floating roof. Initial penetrations of the tank shell, roof or bottom. Addition, repair or replacement of pipes directly between the tank shell, bottom or tank roof, and the first control valve outside the tank. Repair or replacement of welds on the tank. Installation or addition of equipment or appurtenances such as spill or overfill protection, tank gauging, stairways, platforms, walkways, or other similar additions that may put additional loads or stress on the tank shell, and were not part of the overall design considerations. Installation of new or additional piping runs within the emergency containment. Installation of corrosion protection systems or anodes on cathodic galvanic (sacrificial) and impressed current systems. Installation of new emergency or secondary containment structures. Underground Storage Tank Systems The following activities performed on field-constructed underground storage tanks require modification inspections by third-party inspectors appropriately certified by DEP. Repairing, removing or replacing any part of the tank. Replacing or repairing tank system components (including ancillary equipment and primary or secondary containment structures) when excavation is required. Replacement of a complete dispensing unit when excavation is required (requires liquid tight under dispenser containment, and includes partial system closure activity that must be performed or overseen by a UMR). Adding ancillary equipment. Installation, repair or replacement of internal tank lining or coating for product compatibility. Installation or replacement of corrosion protection systems including the addition or replacement of anodes on cathodic galvanic (sacrificial) and impressed current systems except when installing anode bags or spike anodes to only piping connectors, and excavation is only performed by hand (considered a minor modification) / March 29, 2014 / Page 7

18 Minor Modification Activities: These activities do not alter the design of the storage tank system or storage tank facility, but may affect the integrity of the storage tank system or storage tank facility. These activities may not (except as noted below) involve excavations during their performance. Aboveground Storage Tank Systems Excavations within the emergency containment, but not under the tank or piping supports. Modifying or repairing emergency or secondary containment structures. Installation of equipment or appurtenances such as spill containment, tank gauging, and vents for which the tank was designed when fittings exist on the tank shell or roof. Repairs involving cutting or welding on aboveground piping runs that are downstream from and including the first control valve, and within the emergency containment. Underground Storage Tank Systems Staking and placing of concrete forms, and assurance of proper concrete or grade slab installation, over the tank field and piping runs. Replacement, repair or removal of aboveground piping associated with the system (excluding dispenser components). Replacement of a complete dispensing unit, without excavation. Replacement, repair or removal of the check valve in a suction system. Replacement or removal of submersible pump manifold assembly. Replacement, removal or disconnection of any piping fitting or section of piping, such as a flexible connector, which interconnects regulated piping. Replacement, removal or disconnection of emergency shutoff (impact) valves. Replacement or removal of primary piping through extraction from the secondary piping or double walled piping systems or double wall piping from a tertiary conduit when accessible from aboveground or through manholes (not involving an excavation). Repairs to cathodic protection systems that only involve replacement of a rectifier unit and/or the reconnecting of wires, so long as the only excavation involved is performed by hand. Installation or replacement of anode bags or spike anodes to piping connectors, so long as the only excavation involved is performed by hand. Installation or replacement of piping isolation boots, so long as the only excavation involved is performed by hand. Initial installation of a line leak detector. Changing the type of line leak detector, such as mechanical to electronic. Installation, repair or replacement of overfill prevention devices. Installation, repair or replacement of spill containment devices, including the installation or replacement of drain valves or plugs without excavation. Initial installation or complete replacement of an automatic tank gauging system, or the replacement of an automatic tank gauge console. Repairs to primary or secondary containment structures including the installation or repair of containment sump entry fittings without excavation. The decommissioning of a Stage II vapor-recovery system involving the replacement, removal or disconnection of Stage II vapor-recovery piping / March 29, 2014 / Page 8

19 Maintenance Activities: The normal operational upkeep to prevent a storage tank system or storage tank facility from releasing regulated substances if the activity involved is not a major or minor modification. These activities do not involve excavations during their performance. Aboveground and Underground Storage Tank Systems Painting the tank system exterior (except where excavation is required). Painting, caulking or minor surface repair to an emergency containment structure. Aboveground storage tank cleaning not performed as part of a tank closure activity, and which does not involve the removal of any lining. Replacing the tank gauge on an aboveground tank when the gauge brackets already exist on the tank. Replacement of flame arrestors, pressure relief valves or conservation vents on aboveground tanks. Replacing product high-level sensors on an aboveground tank. Repair or direct replacement of threaded or flanged ancillary equipment located downstream of first control valve of an aboveground storage tank system. Replacement or repair of the tank pump or submersible turbine (with extractable column) if accessible through the manhole or tank riser sump (not involving removal or disconnect of manifold assembly or piping below the ground or grade surface). Repair or replacement (with like kind devices) of line leak detectors or other metering devices when accessible from aboveground or through manholes. Changing or replacing product dispenser components above the emergency shut off (impact) valve (not involving piping disconnect at or below the valve). Emptying spill containment buckets and sumps. Repairing or replacing small copper lines or tubing accessible from aboveground or a sump. Repair and recalibration of the metering controls or automated console. Testing of the cathodic protection system (requires a qualified cathodic protection tester). Adjustments to rectifier settings (requires evaluation and adjustment determination by a corrosion expert or corrosion engineer). Repairing electrical connections. Changing electronic circuit boards. Changing filters. Gauging tanks. Checking the monitoring or observation wells / March 29, 2014 / Page 9