See the latest EHS federal and state regulatory updates due to COVID-19


The Pennsylvania Department of Environmental Protection (PADEP) published draft guidance under 25 PA. Code Ch. 245-Storage Tank Regulations, to assist certified companies, inspectors, installers, and owners and operators in their understanding of the classification of storage tank system modifications and maintenance activities. The draft guidance also provides insight as to what kinds of activities require certified installers and inspectors. This guidance is related to aboveground storage tanks (ASTs) and underground storage tanks (USTs).

To determine when certified installers and inspectors are required, owners and operators of ASTs and USTs must first classify the tank activity as a major modification, minor modification, or maintenance activity - See the decision chart in Figure 1 below.

Picture1

Figure 1 Source: Storage Tank Modification and Maintenance Issues

Modifications, Maintenance and Tank Handling Activities

Major and minor modifications are described differently for ASTs and USTs. Modifications are generally classified as tank handling activities, which are activities to install, modify, perform change in service, or close all or part of a storage tank system or storage tank facility. This does not include maintenance activities. The DEP provided a draft list of maintenance activities for ASTs and USTs in the draft guidance.

Tank handling activities must be performed by or supervised under the control of a DEP certified installer. Tank handling activities to field-constructed tanks and large ASTs (21,000 gallons or more) must be inspected by a DEP certified inspector. Modification inspections also require certified inspectors. Details of such requirements are available in the Storage Tank Modification and Maintenance Issues guidance document.

Operator Training

The PADEP has also published separate draft guidance on requirements of UST Class A and Class B operator training requirements. Operators must undergo the appropriate level of training for their respective responsibilities. The Underground Storage Tank Class A and Class B Operator Training Courses guidance document provides details on mandatory retraining of Class A and Class B operators, training course approval and renewal, and required training course subjects for Class A and Class B operators.

Comments for both guidance documents can be submitted until September 9, 2019.

For additional assistance with certified inspector or certified installer requirements or UST operator training requirements, pplease contact Christie Heath, Manager of Trinity's Philadelphia office, at cheath@trinityconsultants.com or call (610) 280-3902; or contact Ian Donaldson, Manager of Trinity's Pittsburgh office, at idonaldson@trinityconsultants.com or call (724) 935-2611.