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11 TIP -1 of tanks in each unit. Tanks that are not actually used to treat hazardous waste, but are integral to the operation of the system, such as surge tanks, should be included in the system. Tanks such as pre-treatment tanks that are often used for pH adjustment of wastes prior to discharge but after having been rendered non -hazardous, do not need to be counted. Tanks used for delivery of chemicals to be used in the treatment of hazardous wastes do not need to be included. What is a "Existing tank system"? An existing tank system is any tank or tank system component that was installed or operating' before either July 1, 1991 or July 14, 1986. The 1991 trigger date applies to tanks and systems handling non-RCRA wastes. The 1991 date also applies to tanks that hold RCRA waste when the facility is a RCRA SQG or CESQG2 and tanks that hold RCRA wastes that are not otherwise regulated by RCRA (i.e. exempt). The 1986 date applies to tanks and systems handling RCRA wastes at non-SQG facilities. What is a "New tank system"? A new tank system is any tank or tank system component that was installed or operatincg3 after the target dates discussed above. Do I have to do an assessment if I make changes to my tank/system? In most cases, yes. Modifications to the tank system will result in the need to reassess the tank system. This modification does not include the installation of secondary containment for existing tanks/systems.4 New tank systems that replace pumps, valves, seals, piping components such as unions, joints, and elbows and piping hangers or brackets with identical or functionally equivalent parts or components are not required to conduct reassessments. Are there any exceptions to the requirements for assessments? Underground storage tanks are not subject to the assessment requirements. However, underground tanks are required to follow the standards for underground storage tanks found in California Code of Regulations, title 23 5 Certain tank owners may ask their Certified Unified Program Agency (CUPA) for a three year exemption from conducting assessments. To determine if a tank or tank system is 1 Installation is considered to have commenced if the owner/operator has obtained all approvals or permits necessary to begin physical construction AND if (1) a continuous on-site physical construction has begun or (2) the owner/operator has entered into contractual obligations for the construction or installation that can not be cancelled or modified without substantial financial loss. 2 The definition of RCRA SQG can be found in 40 CFR, section 260. 10, and is defined as a facility that generates less than 1000 kg. of hazardous waste in a month. A RCRA CESQG is not defined in 40 CFR, but is a subset of the SQG group that does not generate more than 100 kg. of hazardous waste in a month. 3 Please see footnote #1 4 The requirement to assess a new tank's integrity at the time of installation of secondary containment can be found in California Code of Regulations, title 22, section 66265 192, subd. (a) 5 California Code of Regulations, title 22, section 66265 191, subd. (f) for existing tanks and section 66265 192, subd. (i) for new tanks.