Tag Archives: RP1200

PEI Response to RP900 Public Comments

PEI is the leading authority for fuel and fluid handling equipment.

PEI’s Underground Storage Tank (UST) System Inspection and Maintenance Committee met earlier this month and acted on 98 public comments offered to update PEI’s Recommended Practices for the Inspection and Maintenance of UST Systems (PEI/RP900)

Many of the comments were accepted in one form or another. A few suggestions that were not incorporated into RP900 are also of some significance to users of the document.

Here is a summary:

  • The scope of the recommended practice was NOT expanded to include UST systems and associated equipment other than that used to store and dispense gasoline, diesel and related petroleum products at vehicle fueling facilities. In other words, the document is not intended to apply to marinas, aviation-fueling facilities, farms, emergency generators, etc. The committee did broaden the scope to include the shear valve.
  • The Committee recognized that, in many instances, the new federal inspection requirements that became effective October 13, 2015, were less comprehensive than the inspection practices contained in the 2008 edition of RP900. After reviewing all the inspection requirements of the federal rule, the Committee revised the document to meet or exceed the walkthrough inspection requirements and frequencies contained in the federal regulations. In a few instances, the Committee included recommended procedures for walkthrough inspections in the document that were not included in the federal rule. The Committee also rejected several proposals to increase the frequency of some inspections (e.g., spill bucket drain valves, interstitial space of drain valves).
  • A number of comments dealt with water and the quality of fuel in the UST. The Committee made a few tweaks to Section 7.6.5.1 that now requires the owner to check to see if water is present and, if found, to notify the appropriate person in the company. Section 7.6.5.1 also will direct the owner to a new appendix that will discuss water issues and suggest strategies to keep water out of the tank. The appendix will be available for public review and comment before it is included in the 2016 edition of RP900.
  • All of the testing requirements contained in RP900 were removed from the document and will be considered for inclusion in PEI’s Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities (PEI/RP1200). By this action, the Committee opted to provide one document to use for walkthrough inspections of UST systems (RP900) and another to test the equipment and verify it is working properly (RP1200). As a result of this decision, both RP900 and RP1200 will be released simultaneously, probably sometime this summer.

Meet Brian Harmon – Regulatory Affairs Manager at Tait

Brian Harmon helped author the newly published PEI Recommended Practice 1200. Proposed EPA regulatory changes makes the content of this manual especially valuable. Brian served as part of the PEI Overfill, Leak Detection and Release Prevention Equipment Testing Committee and was very important in the publication of this manual, entitled, Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities. 

Want to get to know a little more about Tait’s Regulatory Affairs manager, Brian? He shares with us his story, below:

I graduated high school in 1976. When I volunteered for the Navy in 1977 I signed up for 6 years so I could pick the training i wanted. I was a Sonar Technician, went through one year of training. After I completed my training I was stationed on two ships in Yokosuka Japan, the USS Worden CG-18 and the USS Parsons DDG-33. In 1980 I was transferred to San Diego and stationed on the USS Decatur DDG-31. This is when I realized that I like living in Southern California.

USS Worden

USS Worden

After I got out of the Navy in 1983 I went back home to Aldan Pennsylvania to start a new chapter in my life. While I was talking to a friend who I met in the Navy and now  worked for Sunoco, he told me that he got involved testing Underground Storage Tanks. That sounded interesting! Then he said that Sunoco had to sell their Underground Storage Tank division because the EPA wanted the oil companies to conduct third party testing. He said that the new company would be hiring in March and suggested that I apply, which I did. I started my training in Ft Lauderdale, Florida for three months. My new partner and I relocated to Houston, Texas in July where we started covering a new area for the company. We were the only crew in Texas and we were responsible for Texas, Oklahoma, Alabama and Arkansas. I did not realize how big the country was until we started driving  and working. I know I saw a lot of the country but most of it was through the windshield and at night. After 4 months the company decided that they need another crew, sent out a new work truck (for him), hired two more people and promoted me to team lead and gave me the old work truck. My new partner and I moved to the Dallas area and started testing more tanks. During this time I was able to see the learning curve local agencies had to go through to understand the EPA requirements and forming their own regulations and training the field inspectors.

In October 1984 my company started a division based in Los Angeles California. My partner and I were asked to go out to California to help train the new crews. We got so busy that I was flying back and forth between Los Angeles and Dallas for five months when I told my company to pick a state they wanted me to work in. I was hoping for Los Angeles I would be satisfied where I was as long as I did not involve an airplane. My company picked California so in April 1985 I arrived and started working in Southern California.

Once I arrived, I realized that the California regulations were more stringent than the EPA regulations but most of the inspectors did not understand how to apply them. Also I found that two agencies, California Unified Program Agencies (CUPA) established by California EPA and  is responsible for the liquid portion of the UST system, and the California  Air Resources Board (CARB) and is responsible for the emissions portion of the UST system, did not talk to each other. California was also requiring Vapor Recovery (Stage I and Stage II) systems be install at most of the gas stations throughout the state, so I had to learn how to test and repair the equipment as well. I started working with the local inspectors for both agencies, identifying conflicts between the agencies regulations and how the UST equipment works. This is how I got manufacturer training on most of the UST monitoring systems and the vapor recovery equipment.

From 1986 through 1988 I worked with computer developers to get our Tank Testing equipment up to the 1988 standards required by the EPA. In 1988 the Tank testing division was sold and I started working for other companies learning to use new tank testing equipment. During this time I discovered that the test equipment may improve but the equipment is only as good as the technician using it. I was able to help train other technicians so which ever company I was  working for had the best field technicians available. In 1997 I started working in the office scheduling field crews, helping troubleshoot problems or failures, working with the equipment manufacturers and regulators to help our clients stay in compliance and keeping the equipment operational.

In 2000 I joined the Tait family to help start up the compliance testing division.  This is the time that the CARB started the Enhanced Vapor Recovery (EVR) program, which required vapor recovery equipment manufacturers to develop new equipment to meet the standards in the regulations. I continued work with CARB, the equipment manufacturers and the local districts so that the equipment could meet the regulatory requirements. I also helped train our field crews and kept them informed in the ever changing testing and equipment changes. I also worked with CARB to clean up discrepancies in the manufacturer’s Executive Orders that our technicians found while doing the installation and testing of the new equipment. While we were on site our field crews, with our clients’ permission, would help train the local inspectors (CUPA and the Air district) in the new equipment and test procedures. Some of our clients that got in trouble with the state and/or local agencies so Tait helped implement a compliance program to ensure the agencies that our clients will remain in compliance at all of their locations throughout the state. Over time my role at Tait has changed from direct interface with the field crews and local inspectors to talking to the state agencies directly. Due to the 2005 Energy Act other states were revising their regulations. This allowed Tait to start expanding in other states and I started reviewing the various regulations to ensure we maintained our standard of service that we have established in California.

Working at Tait is a great because we offer a wide variety of services that you can’t find at other companies. Having the various services I have been able to become familiar with problems tank owners can encounter besides UST compliance testing. This has allowed me to develop a better relationship with our clients and has helped Tait start up additional service lines for those clients. I love working here and hope to continue for many more years.