RP100: UST SYSTEM INSTALLATION
Since 1988, the federal UST rule ( 40 CFR 280) has
stated that UST systems must be installed in accordance
with a recognized code of practice developed by a nationally
recognized association or independent testing laboratory.
Of the two comprehensive installation codes of practice mentioned in the regulations, only PEI/RP100:
Recommended Practices for Installation of Underground
Liquid Storage Systems has been updated and revised regularly during the past 30 years. The 2017 edition is the ninth
revision of PEI/RP100 since the document’s debut. For PEI/
RP100-17, the PEI Tank Installation Committee reviewed
and acted on more than 30 public comments submitted by
regulators, manufacturers, installers and industry consultants.
“The RP100 committee and the PEI staff made my job
easy once again,” said Chairman Leland M. Freeman, of
Petroleum Solutions Inc. “It could not have happened with-
out the willingness of our committee members to give their
Among the most signi;cant changes in the document are
• The 2011 edition of RP100 contained cautions against
vent restriction devices (ball ;oat valves). PEI/RP100-17
goes further, stating, “Vent restriction devices should not
be installed” for over;ll prevention.
• Although the document does not directly recommend
double-walled spill buckets, it lists them as an installation
option that should be considered (Section 8. 2).
• The committee substantially revised procedures, measurements and time requirements for the testing of
containment sumps (Section 8. 5. 4).
• The committee rewrote, reorganized and expanded the
“Release Detection” chapter in the 2011 edition into a
new “Leak Detection” chapter that, among other things,
contains detailed practices for double-walled tanks and
• The revised document also contains new graphics on
suction pumping, piping layouts and ;exible connectors.
RP900: UST SYSTEM INSPEC TION, MAINTENANCE
“RP900 represents the best practices for performing
inspections that will ensure that UST systems are working
properly, and will also help achieve compliance with the
2015 EPA UST regulations,” said Chairman Brad Hoffman,
of Tanknology. “The committee members collectively
have hundreds of years of experience with UST’s, and have
worked diligently to produce a document that will be helpful for many in the UST industry, including tank owners
and operators, contractors, inspectors, testers, as well as the
Because PEI typically revises its recommended practices every ;ve years, the 2008 edition of PEI/RP900:
Recommended Practices for the Inspection and Maintenance
of UST Systems;normally would have been updated in
2013. The PEI UST System Inspection and Maintenance
Committee, which is responsible for RP900, however,
deferred work on the next edition until the most recent
federal tank rule was published.
For the ;rst time, the 2015 federal rule requires tank
owners and operators to conduct periodic walkthrough
inspections of spill prevention equipment, release detection equipment and containment sumps. The federal
rule speci;cally recognizes RP900 as a code of practice
that may be used to meet the walkthrough inspection