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Frequently Asked Questions

    Application

  1. To whom do the Storage Tank Systems for Petroleum Products and Allied Petroleum Products Regulations apply?
  2. If I am a private owner of one or more storage tanks, do the Regulations apply to me?
  3. What types of tanks are regulated?
  4. Do the Regulations apply only to new storage tank systems (installed after June, 2008) or to existing ones (installed before June, 2008) as well?
  5. Are pressure vessels subject to the Storage Tank Regulations?
  6. Are propane tanks captured by the Storage Tank Regulations?
  7. Are storage tank systems that contain airport de-icing fluids captured by the Regulations?
  8. Is a storage tank located inside a building exempt from the Regulations?
  9. What volume of secondary containment must be provided by the building?

  10. Definitions

  11. What is a petroleum product?
  12. What is an allied petroleum product?
  13. What is federal land?
  14. General

  15. Does a component of a storage tank system have to be functional in order to be considered present?
  16. How are the Regulations different from provincial and territorial storage tank regulations?
  17. If my storage tank system is subject to the Storage Tank Regulations do I also have to comply with the National Fire Code of Canada?
  18. What reports are owners required to submit?
  19. Tanks Located in Buildings

  20. Is a double-walled storage tank located inside a building exempt from the Regulations?
  21. What volume of secondary containment must be provided by the building?
  22. Compliance and Enforcement

  23. Who is responsible for complying with the Regulations?
  24. What happens if an owner fails to comply with the Regulations?
  25. Are owners required to submit to inspections?
  26. Transfer Area

  27. Are owners obligated to have a transfer area that is designed to contain spills or can they accept the risk that there may be clean-up required when a transfer area is not designed to contain spills?
  28. Is the transfer area the same as the dispensing area?
  29. Do used oil tanks have transfer areas?
  30. What is the deadline by which a transfer area must contain spills for storage tank systems installed before June 12, 2008?
  31. What is the deadline by which a transfer area must contain spills for storage tank systems installed after June 12, 2008?
  32. As-built Drawings

  33. Are as-built drawings required for all storage tank systems?
  34. Can the design drawings of a storage tank system be used as the as-built drawings?
  35. One of the requirements for as-built drawings is that they indicate property lines. How should property lines be indicated when they are outside the scale of the drawing?
  36. Emergency Plans

  37. Do the Regulations require an emergency plan?
  38. There are “factors to consider” that must be included in the emergency plan. Do all of them need to be mentioned in the emergency plan? What if a factor does not apply to a specific situation?
  39. Permanent Withdrawal From Service

  40. After a storage tank system has been permanently withdrawn from service, and if a timeline is not specified in the Regulations, how soon is it required to be removed?
  41. What storage tank systems must be removed prior to June 12, 2012?
  42. Which storage tank systems are requred to be removed once they leak?
  43. Can a storage tank system that has been withdrawn from service for more than two years be used again?
  44. Identification Process

  45. Who is required to identify a storage tank system?
  46. Who issues the identification number?
  47. Must owners identify storage tank systems even if they do not meet all of the requirements of the Regulations?
  48. What information must be provided to identify a storage tank system?
  49. What do I do if I need to change the identification information?
  50. Is information submitted to Environment Canada kept confidential?
  51. How should compartment tanks be identified? Is the tank all one storage tank system or multiple systems?
  52. I have already identified my tanks under one identification number and now realize that they should have been identified as two storage tank systems, not just one. I need to generate another identification number. What do I do?
  53. I have already identified my tanks and have an Environment Canada identification number. One of my tanks is a compartment tank and I need an additional Environment Canada identification number. What do I do?
  54. I have one identification number for tanks at my location but I have multiple tanks that are not interconnected. Do I need additional identification numbers?
  55. All of the information to identify a storage tank system has been completed in FIRSTS but the “Submit Identification” button is not activated. What needs to be done?
  56. Product Delivery

  57. As a petroleum product supplier, what am I required to do when transferring petroleum products?
  58. How To Get More Information

  59. How can I get more information?

Application

1. To whom do the Storage Tank Regulations for Petroleum Products and Allied Petroleum Products (Storage Tank Regulations) apply?
1. The Regulations apply to storage tank systems located in Canada, in which petroleum products or allied petroleum products are stored and which:
a) are operated by a federal department, board or agency or Crown corporation, or belongs to Her Majestry in right of Canada;
b) are operated by or belongs to a railway, airport or port authority;
c) are located on Aboriginal or federal lands.

(Reference: Section 2)

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2. If I am a private owner of one or more storage tanks, do the Regulations apply to me?
The Regulations may apply to you if your storage tanks are located on Aboriginal or federal lands.

(Reference: Section 2)

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3. What types of tanks are regulated?
The Regulations apply to all outside aboveground, underground and partially buried storage tank systems containing petroleum and allied petroleum products, except aboveground storage tank systems that have a capacity of 2,500 L or less and that are connected to a heating appliance or emergency generator.

(Reference: Section 2 and definitions of "petroleum product" and "allied petroleum product")

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4. Do the Regulations apply only to new storage tank systems (installed after June, 2008) or to existing ones (installed before June, 2008) as well?
The Regulations apply to new and existing storage tank systems. Under the Regulations, new storage tank systems (installed after June, 2008) are required to meet the technical requirements before they can be operated. Existing storage tank systems (installed before June, 2008) that do not meet the regulatory technical provisions must be upgraded or removed within a specified period of time.

(Reference: Section 2 and various sections that specify timelines)

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5. Are pressure vessels subject to the Storage Tank Regulations?
The Regulations apply to storage tanks that operate at atmospheric pressure. Refer to the definitions of "aboveground tank" and "underground tank" for information. Pressure vessels such as propane tanks are not captured by the Regulations.

(Reference: Section 2 and definitions of "aboveground tank" and "underground tank")

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6. Are propane tanks captured by the Storage Tank Regulations?
No. Propane is excluded from the definition of "petroleum product". Also propane tanks are pressure vesssels (i.e. operate above atmospheric pressure) and so are not considered to be "aboveground tanks" for the purpose of the Regulations.

(Reference: Section 2 and definitions of "aboveground tank" and "underground tank")

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7. Are storage tank systems that contain airport de-icing fluids captured by the Regulations?
The Regulations apply to storage tank systems that contain petroleum products and allied petroleum products including uninhibited ethylene glycol (CGSB 3-GP-855; see Schedule 1 of the Regulations). De-icing fluids used at airports are often ethylene glycol, diethylene glycol or propylene glycol that contains corrosion inhibitors. Ethylene glycol that contains corrosion inhibitors is "inhibited" and is therefore not captured by the Regulations. The Regulations do not apply to diethylene glycol or propylene glycol as they are not petroleum products or allied petroleum products for the purposes of the Regulations.

(Reference:Section 2 and Shedule 1)

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8. Is a storage tank located inside a building exempt from the Regulations?
No, not necessarily. The Regulations do not apply to storage tank systems that are located in a building that provides secondary containment equivalent to a maximum hydraulic conductivity of 1 X 10-6 cm/s on a continuous basis. The building must provide secondary containment regardless of whether or not the tank itself provides secondary containment (for example, a double walled storage tank located inside a building is not automatically exempt).

(Reference: Section 2)

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9. What volume of secondary containment must be provided by the building?
There is no volume specified under clause 2(2)(a). The definition of secondary containment is "containment that prevents liquids that leak from a storage tank system from reaching outside the containment area...".

(Reference: Section 1 and definition of "secondary containment")

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Definitions

10. What is a petroleum product?
A petroleum product within the meaning of the Regulations is a hydrocarbon or mixture of at least 70 percent hydrocarbon, by volume, other than an allied petroleum product, refined from crude oil, that could be used as a fuel, lubricant, or power transmitter. Petroleum products include used oil, but exclude propane, paint and solvents.

(Reference: Definition of "petroleum product")

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11. What is an allied petroleum product?
Allied petroleum products are other substances covered by the Regulations. The complete list is provided in Schedule 1 of the Regulations.

(Reference: Definition of "allied petroleum product" and Schedule 1)

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12. What is federal land?
Federal land, as defined in the Canadian Environmental Protection Act, 1999 (CEPA 1999), means :
(a) land, including any water, that belongs to Her Majesty in right of Canada, or that Her Majesty in right of Canada has the right to dispose of, and the air and all layers of the atmosphere above and the subsurface below that land; and
(b) the following land and areas, namely,
(i) the internal waters of Canada as determined under the Oceans Act, including the seabed and subsoil below and the airspace above those waters, and
(ii) the territorial sea of Canada as determined under the Oceans Act, including the seabed and subsoil below and the air and all layers of the atmosphere above that sea.

(Reference: Section 2 of the Storage Tank Regulations and sub-section 3(1) of the Canadian Environmental Protection Act, 1999 )

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General

13. Does a component of a storage tank system have to be functional in order to be considered present?
Yes, devices must be functional. For example, a storage tank system whose overfill prevention device is not providing shutoff at or below 95% of the nominal tank capacity is not considered to have overfill prevention.

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14. How are the Regulations different from provincial and territorial storage tank regulations?
Most provinces and territories have enacted environmental regulations for storage tank systems that are similar to the federal regulations. These regulations vary between the provinces and territories. The federal Regulations do not apply to the same regulated communities as the provincial and territorial regulations. For the federal government, one of the most important objectives of the Regulations is to ensure that equivalent regulatory requirements apply to federal operations and works and undertakings as those that apply to provincially regulated entities.

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15. If my storage tank system is subject to the Storage Tank Regulations do I also have to comply with the National Fire Code of Canada?
Yes. The purpose, and typically the application, of these two documents are different. The National Fire Code of Canada contains technical requirements designed to provide a level of safety. The Storage Tank Regulations are designed to reduce leaks and spills to the environment from storage tank systems.

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16. What reports are owners required to submit?
Owners of storage tank systems are required to submit the following documents to Environment Canada, where applicable:

  • An identification form, within a year of the date that the Regulations come into force for existing systems (installed before June, 2008), and before the first transfer of product for new systems (installed after June, 2008);
  • Changes to the identification information, within 60 days of the change;
  • For releases greater than 100 L, a written report confirming, amending, or correcting the information provided orally on the release, as soon as possible after the date of the release.

(Reference: Section 28, Schedule 2 and section 41)

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Tanks Located in Buildings

17. Is a storage tank located inside a building exempt from the Regulations?
No, not necessarily. The Regulations do not apply to storage tank systems that are located in a building that provides secondary containment equivalent to a maximum hydraulic conductivity of 1 X 10-6 cm/s on a continuous basis. The building must provide secondary containment regardless of whether or not the tank itself provides secondary containment. For example, a double walled storage tank located inside a building is not automatically exempt.

(Reference: Section 2)


18. What volume of secondary containment must be provided by the building?
Although there is no volume specified under Section 2(2)(a), the definition of secondary containment is “containment that prevents liquids that leak from a storage tank system from reaching outside the containment area...”.

(Reference: Section 2 and definition of "secondary containment")

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Compliance and Enforcement

19. Who is responsible for complying with the Regulations?
Owners and operators of storage tank systems are responsible for complying with the Regulations. Environment Canada enforcement officers will periodically verify compliance with the Regulations under CEPA 1999, Part 9, following the principles of Environment Canada's Compliance and Enforcement Policy.

(Reference: Various portions of the Regulations refer to "owner", "operator" and "owner or operator")

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20. What happens if an owner fails to comply with the Regulations?
Compliance with the Regulations is mandatory. While owners are required to comply with some elements of the Regulations upon their coming into force, there is a time period within which owners can upgrade or replace their storage tank systems. If an owner does not comply, Environment Canada will enforce the Regulations following the principles set out in its Compliance and Enforcement Policy. The policy outlines the philosophy and key principles used by enforcement officers to ensure a fair, predictable, and consistent application of the law. It sets out the range of possible responses to violations, including warnings, directions and environmental protection compliance orders issued by enforcement officers, ticketing, ministerial orders, injunctions, and prosecution.

(Reference: Compliance and Enforcement Policy for CEPA (1999) PROVIDE LINK)

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21. Are owners required to submit to inspections?
Yes. Under CEPA 1999, enforcement officers are authorized to conduct inspections in order to verify compliance with the Act and its regulations. The Act also requires that the owner or the individual in charge give the enforcement officer and CEPA analyst reasonable assistance in their duties.

(Reference: XXXXXXXXXXXXX)

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Transfer Area

22. Are owners obligated to have a transfer area that is designed to contain spills that occur during the transfer process or can they accept the risk that there may be clean-up required when a transfer area is not designed to contain spills?
Owners or operators are obligated to ensrue that a transfer area is designed to contain spills that occur during the transfer process. Simply choosing to accept the cleanup costs of a spill occurring during transfer does not meet Section 15 of the Regulations.

(Reference: Section 15 and definition of "transfer area")

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23. Is the transfer area the same as the dispensing area?
The transfer area and the dispensing area may physically overlap but they are not described as the same area. "Transfer area" is defined in the Regulations as "the area around the connection point between a delivery truck, railcar, aircraft or vessel and a storage tank system in which the tanks have an aggregate capacity of more than 2,500 litres"; it’s the area where the tank is filled with product. "Dispensing area" is not defined in the Regulations but in ordinary use means the area where product is dispensed from the system to vehicles or other containers. The dispensing area may or may not be part of the transfer area. In some situations the product might be delivered in the same area as the product is removed (dispensed) from the system but this is not always the case. The Regulations have specific requirements for the transfer area.

(Reference: Definition of "transfer area" and Section 15)

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24. Do used oil tanks have transfer areas?
“Transfer area” is defined in the Regulations as “the area around the connection point between a delivery truck, railcar, aircraft or vessel and a storage tank system in which the tanks have an aggregate capacity of more than 2,500 litres”.  If a used oil tank system is filled manually (for example, by bucket) then the system is not considered to have a transfer area.  In the case where a used oil storage system receives product from a delivery vehicle as stated in the definition and where the system is greater than 2500 L in aggregate capacity, the system is considered to have a transfer area.

(Reference: Definition of "transfer area" and Section 15)

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25. What is the deadline by which a transfer area must contain spills for storage tank systems installed before June 12, 2008?
Storage tank systems that were installed before June 12, 2008 must have a transfer area that is designed to contain spills that occur during the transfer process by June 12, 2012.

(Reference: Section 15)

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26. What is the deadline by which a transfer area must contain spills for storage tank systems installed after June 12, 2008?
Systems that are installed after June 12, 2008 must have a transfer area that is designed to contain spills that occur during the transfer process before the system is filled with product for the first time.

(Reference: Section 15)

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As-built Drawings

27. Are as-built drawings required for all storage tank systems?
All storage tank systems installed after June 12, 2008 require as-built drawings.
Performing upgrades to storage tank systems that were installed before June 12, 2008 provides a good opportunity to create as-built drawings. If the upgrades will affect one of the six items listed under subsection 34(2) of the Regulations, as built-drawings must be updated or, if not already in existence, should be created.

(Reference: Section 34)

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28. Can the design drawings of a storage tank system be used as the as-built drawings?
As long as the system was installed exactly as the design drawings indicate, the drawings include the information required under subsection 34(2) of the Regulations and they bear the stamp and signature of a professional engineer, design drawings can be used.

(Reference: Section 34)

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29. One of the requirements for as-built drawings is that they indicate property lines. How should property lines be indicated when they are outside the scale of the drawing?
Engineering practice allows that arrows indicating direction and an indication of distance to the property lines can be used. Small scale, large scale or exploded view drawings can be generated.

(Reference: Section 34)

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Emergency Plans

30. Do the Regulations require an emergency plan?
Yes, the Regulations require owners or operators of storage tank systems to develop an emergency plan. The Regulations clearly define the framework and items that should be included in the plan. The owners or operators ensure that the emergency plan is ready to be implemented.

(Reference: Sections 30-32)

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31. There are “factors to consider” that must be included in the emergency plan. Do all of them need to be mentioned in the emergency plan? What if a factor does not apply to a specific situation?
Even if a factor does not seem to be relevant to a specific situation, the emergency plan should include a brief statement of why the factor does not apply. This asserts that the factor was “considered.”

(Reference: Sections 30-32)

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Permanent Withdrawal from Service

32. After a storage tank system has been permanently withdrawn from service, and if a timeline is not specified in the Regulations, how soon is it required to be removed?
Unless otherwise specified, once a storage tank system has been permanently withdrawn from service, it must be removed without delay. In most cases permanent withdrawal from service and removal occur at the same time.

(Reference: Sections 44-45)

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33. What storage tank systems must be removed prior to June 12, 2012?
The Regulations require that the following storage tank systems be permanently withdrawn from service and removed prior to June 12, 2012:

  • Systems having single-walled underground storage tanks that did not have cathodic protection and leak detection in place on June 12, 2008
  • Systems having storage tanks that were designed to be installed above ground that were installed underground
  • Systems having storage tanks that were designed to be installed under ground that were installed above ground
  • Systems having partially-buried tanks.

(Reference: Sections 5-7, 9-10 and 44-45)

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34. Which storage tank systems are required to be removed once they leak?
ANSWER

(Reference: Sections 3, 44-45)

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35. Can a storage tank system that has been withdrawn from service for more than two years be used again?
Once a storage tank has been permanently withdrawn from service, any re-use would be considered a new installation. Since one of the requirements for a new installation is that tanks meet a certification standard, it generally means that the tank must be shipped back to the manufacturer to be re-furbished, ensuring that it meets a valid standard. Field-erected aboveground tanks that are intended to be put back into service must be inspected to the appropriate standard.

(Reference:)

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Identification Process

36. Who is required to identify a storage tank system?
The owner of the storage tank system must identify the tanks with Environment Canada within one year of the coming into force of the Regulations and, in the case of new tank systems, before the first transfer of product into the system.

(Reference: Section 28)

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37. Who issues the identification number?
Environment Canada issues a unique identification number to each system, following receipt of the information provided by the owner. The owner or operator will have to display the identification number in a readily visible location on or near the storage tank system.

(Reference: Section 28)

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38. Must owners identify storage tank systems even if they do not meet all of the requirements of the Regulations?
Yes. Compliance verification is not a step in the identification process. Identification requires that all mandatory pieces of information be provided, as listed in Schedule 2 of the Regulations.

(Reference:Section 28 and Schedule 2)

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39. What information must be provided to identify a storage tank system?
ANSWER

(Reference: Section 28 and Schedule 2)

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40. What do I do if I need to change my identification information?
Changes to the information submitted to identify the storage tank system must be sent to Environment Canada within 60 days of the change.

(Reference: Section 28)

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41. Is information submitted to Environment Canada kept confidential?
Information submitted to Environment Canada is subject to the Access to Information Act and the Privacy Act. CEPA 1999 allows any person submitting information to Environment Canada to request that this information be treated as confidential. The request for confidentiality must be made in writing.

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42. How should compartment tanks be identified? Is the tank all one storage tank system or multiple systems?
Each storage tank system requires its own Environment Canada identification number. For the purpose of the Regulations each compartment should be identified as a separate storage tank system unless the compartment is interconnected (i.e. shares the same product) with another tank or tank compartment. Compartments often store different products, have separate fill points and do not share piping, making each compartment a stand-alone storage tank system for the purpose of the Regulations. Note that sharing a common dispenser does not mean that the compartments are “interconnected”.

(Reference: Definition of "storage tank system")

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43. I have already identified my tanks under one Environment Canada identification numberand now realize that they should have been identified as two separate storage tank systems, not just one. I need to generate another identification number. What do I do?

Scenario 1: If you identified your storage tank systems online using the FIRSTS database follow the following steps:

  • Log into FIRSTS and use “New Identification” to generate another identification number for one of the compartments that you previously identified.
  • Then send an e-mail to tankregistry_idstockage@ec.gc.ca asking the administrators to delete the original instance of the tank by using something like the text in the example below.

Scenario 2: If you submitted a hard copy form to identify your storage tank system(s) please send an e-mail to tankregistry_idstockage@ec.gc.ca OR a fax to 819-953-7253 asking the administrators to delete the original instance of the tank by using something like the text in the example below.

  • Example text:(Owners should fill in the square brackets [ ] with appropriate information)
  • “I am correcting the identification of my storage tank system(s) to indicate that one of the systems is a compartment tank.
  • Original identification number: [EC-12345678]
  • Affected tank in original identification: [Tank #2 of 2] which is [1300] litres capacity, storing [gasoline]
  • The new identification number that was generated for this compartment is [EC-92345679].

44. I have already identified my tanks and have an Environment Canada identification number. One of my tanks is a compartment tank and I need an additional Environment Canada identification number. What do I do?

Scenario 1: If you identified your storage tank systems online using the FIRSTS database follow the following steps:

  • Log into FIRSTS and use “New Identification” to generate another identification number for one of the compartments that you previously identified.
  • Then send an e-mail to tankregistry_idstockage@ec.gc.ca asking the administrators to delete the original instance of the tank by using something like the text in the example below.

Scenario 2: If you submitted a hard copy form to identify your storage tank system(s) please send an e-mail to tankregistry_idstockage@ec.gc.ca OR a fax to 819-953-7253 asking the administrators to delete the original instance of the tank by using something like the text in the example below.

  • Example text:(Owners should fill in the square brackets [ ] with appropriate information)
  • “I am correcting the identification of my storage tank system(s) to indicate that one of the systems is a compartment tank.
  • Original identification number: [EC-12345678]
  • Affected tank in original identification: [Tank #2 of 2] which is [1300] litres capacity, storing [gasoline]
  • The new identification number that was generated for this compartment is [EC-92345679].

45. I have one identification number for all the tanks at my location but I have multiple tanks that are not interconnected. Do I need additional identification numbers??
ANSWER

(Reference: Definition of "storage tank system")

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46. All of the information to identify a storage tank system has been completed in FIRSTS but the “Submit Identification” button is not activated. What needs to be done?
If there is no green check mark beside the “Contacts” section in the right hand menu bar, follow these steps:

  • Click on the Contacts section. Click on“Edit”.
  • Use the dropdown list to click on the name of the appropriate owner contact. Click on “Select”.
  • Use the dropdown list to click on the name of the appropriate operator contact. Click on “Select”.
  • Click on “Save and Continue” at the bottom of the page. There should now be a green check mark beside the “Contacts” section in the right-hand menu bar and the “Submit Identification” button should now be activated. Click on “Submit Identification” and follow the steps to receive the Environment Canada identification number for the storage tank system.
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Product Delivery

47. As a petroleum product supplier, what am I required to do when transferring petroleum products?
The Regulations do not cover the handling or transport of petroleum products or allied petroleum products. The obligations of suppliers under the Regulations are limited to the following three requirements:
a) The supplier can transfer products to storage tank systems only if the Identification number is visible;
b) The supplier must record the Identification number of the storage tank system;
c) The supplier must immediately inform the operator of spills or leaks occurring during the transfer process.

(Reference: Section 29)

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How to Get More Information

48. How can I get more information?
If you can't find what you're looking for on Environment Canada's web site, you can contact the staff responsible for promoting the Regulations at the Environment Canada office in your region. Their names and contact information are available under the Regional Offices page.

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