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Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 1
Using PEI Recommended Practices to Improve the Operation of UST Systems
What Are PEI RPs?
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 2
What Are PEI RPs?
• Recommended practices relating to petroleum marketing
What Are PEI RPs?
• Recommended practicesrelating to petroleum marketing equipment
• Documents describing how things should be done
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 3
What Are PEI RPs?
• Recommended practices relating to petroleum marketing equipment
• Documents describing how things should be done
• Standards by which to judge the adequacy of UST/AST installation and operation
How Are PEI RPs Produced?
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 4
How Are PEI RPs Produced?• Committee of knowledgeable
people is selected
How Are PEI RPs Produced?• Committee of knowledgeable
people is selected
• Manufacturers, installers, regulators, owners, trade associations are represented
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 5
How Are PEI RPs Produced?• Committee of knowledgeable
people is selected
• Manufacturers, installers, regulators, owners, trade associations are represented
• Consensus/compromise process
How Are PEI RPs Produced?• Committee of knowledgeable
people is selected
• Manufacturers, installers, regulators, owners, trade associations are represented
• Consensus/compromise process
• Public review
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 6
How Are PEI RPs Produced?• Committee of knowledgeable
people is selected
• Manufacturers, installers, regulators, owners, trade associations are represented
• Consensus/compromise process
• Public review
• Committee works with consultant
RP 500-05
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 7
RP 900-08
Scope of RP 500 & RP 900
RP 500RP 900
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 8
The Heart of RP500 & RP900
Daily Checklists
Level I Qualified Person
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 9
Monthly Checklists
Level II Qualified Person
Annual Checklists
Qualified Technician
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 10
What RP500 Contains
What RP500 Contains• Daily inspection
Check hanging hardware (Level I)
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 11
What RP500 Contains• Daily inspection
Check hanging hardware (Level I)
• Monthly inspectionLook inside dispenser for leaks (Level II)
What RP500 Contains• Daily inspection
Check hanging hardware (clerk)
• Monthly inspectionLook inside dispenser for leaks (facility manager)
• Annual inspectionFull evaluation of function of all aspects of dispenser (qualified technician)
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 12
What RP500 Contains• Daily inspection
Check hanging hardware (Level I)
• Monthly inspectionLook inside dispenser for leaks (Level II)
• Annual inspectionFull evaluation of function of all aspects of dispenser (qualified technician)
• Post incident inspectionFull evaluation of all components affected by the incident (qualified technician)
What RP900 Contains
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 13
What RP900 Contains
• Daily inspectionSpill buckets, fill pipe, inventory (Level I)
What RP900 Contains
• Daily inspectionSpill buckets, inventory (Level I)
• Monthly inspectionLeak detection, inventory reconciliation, rectifier inspection (Level II)
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Using PEI RPs for UST management March 18, 2008
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What RP900 Contains
• Daily inspectionSpill buckets, inventory (Level I)
• Monthly inspectionLeak detection, inventory reconciliation, rectifier inspection (Level II)
• Annual inspectionSump inspection, overfill
inspection, LLD test, sensor test (qualified technician)
The Role of RPs in Operating USTs
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 15
The Role of RPs in Operating USTs• Raise awareness of owners &
operators on how to properly operate UST systems
The Role of RPs in Operating USTs• Raise awareness of owners &
operators on how to properly operate UST systems
• Provide concrete comprehensive guidance on what to do and when to do it
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 16
The Role of RPs in Operating USTs• Raise awareness of owners &
operators on how to properly operate UST systems
• Provide concrete comprehensive guidance on what to do and when to do it
• Provide a mechanism to document what is done
The Role of RPs in Operating USTs• Provide credible, industry
based guidance on how UST systems should be operated
• Provide concrete comprehensive guidance on what to do and when to do it
• Provide a mechanism to document what is done
• Provide a method of internal checks to help ensure that tasks are done
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 17
How Regulators Can Use RPs
How Regulators Can Use RPs• Provide credible industry
based guidance on how UST systems should be operated
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 18
How Regulators Can Use RPs• Provide credible industry
based guidance on how UST systems should be operated
• Can be adopted or referenced by rules to provide concrete, enforceable guidelines for UST owners
How Regulators Can Use RPs• Provide credible industry
based guidance on how UST systems should be operated
• Can be adopted or referenced by rules to provide concrete, enforceable guidelines for UST owners
• Can provide content for owner/operator training requirements
Using PEI RPs for UST management March 18, 2008
© Marcel Moreau Associates 19
How Regulators Can Use RPs• Provide credible industry
based guidance on how UST systems should be operated
• Can be adopted or referenced by rules to provide concrete, enforceable guidelines for UST owners
• Can provide content for owner/operator training requirements
• Provide guidance on what can reasonably be expected of operators
What’s Wrong With This Picture?