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)

book stick variance2413 2441 282214 2118 -961859 1955 961730 1733 31361 1270 -913076 3175 993028 3000 -282836 2843 72437 2320 -1171959 2053 941866 1860 -61587 1608 211119 1118 -11021 1000 -21868 835 -33658 605 -53

3451 3590 1393491 3490 -1

Using PEI RPs for UST management March 18, 2008

© Marcel Moreau Associates 14

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?

Using PEI RPs for UST management March 18, 2008

© Marcel Moreau Associates 20