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TIP - 1 of tanks in each uni . Tanks that are not actually used to treat hazardous waste, but are integral to the operE tion 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 disc arge but after having been rendered non-hazardous, do not need to be counted. Tan s used for delivery of chemicals to be used in the treatment of hazardous wastes o not need to be included. What is a "Existin ank system"? An existing tank sys em is any tank or tank system component that was installed or operating' before ei her July 1, 1991 or July 14, 1986. The 1991 trigger date applies to tanks and systems andling non-RCRA wastes. The 1991 date also applies to tanks that hold RCRA wa to 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 andsystemssystems handling RCRA wastes at non-SQG facilities. What is a "New tank) system"? A new tank system i any tank or tank system component that was installed or operating3 after the arget dates discussed above. Do I have to do an a sessment 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. Th s modification does not include the installation of secondary containment for exis ing tanks/systems.4 New tank systemst at replace pumps, valves, seals, piping components such as unions, joints, and elbows and piping hangers or brackets with identical or functionally equivalent parts or c mponents are not required to conduct reassessments. Are there anv excen ions to the requirements for assessments? Underground storag tanks are not subject to the assessment requirements. However, underground tanks a e required to follow the standards for underground storage tanks found in California C de of Regulations, title 23 5. Certain tank owners ay 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 have commenced if the owner/operator has obtained all approvals or permits necessary to begin physical onstruction AND if(1) a continuous on-site physical construction has begun or(2) the owner/operator has entered nto contractual obligations for the construction or installation that can not be cancelled or modified without substan ial financial loss. 2 The definition of RCRA S G can be found in 40 CFR,section 260.10,and is defined as a facility that generates less than 1000 kg. of hazard us waste in a month. A RCRA CESQG is not defined in 40 CFR,but is a subset of the SQG group that does not ge erate more than 100 kg. of hazardous waste in a month. 3 Please see footnote#1. 4 The requirement to assess i new tank's integrity at the time of installation of secondary containment can be found in California Code of Regul tions,title 22,section 66265.192,subd. (a) 5 California Code of Regula ions, title 22,section 66265.191,subd. (f) for existing tanks and section 66265.192, subd. (i) for new tanks.