Changes to the RP900

As the leaders in fuel and fluid handling equipment, PEI is uniquely qualified to provide direction on the best way to manage and maintain your underground storage tanks. Since rules and regulations are constantly evolving, it’s a good business practice to stay on top of inspection tasks.

They have scoured published and unpublished information from manufacturers, contractors, petroleum marketers, and regulatory agencies to provide the most up-to-date recommendations to promote the safety, health, and compliance of your business. Instead of forcing you to scour the internet and archives to find the information you need, PEI keeps it all together in one place. Having one centralized source-of-truth is not just good for your data, but it’s also good for you. 

PEI’s goal (and ours) is to be proactive by identifying potential equipment problems and reducing liability associated with operating underground storage systems.

A quick summary

The biggest changes in the RP900 are all about inspections, who and how they are to be performed in 2022 and beyond. 

As we mentioned before, inspection requirements have changed this year, and these changes have had a trickle down effect to also cause shifts in other areas of the RP900. In addition to noting the changes required by monthly and daily inspections, the RP900 has also changed to reflect the new inspection processes affected by the monthly and daily inspection requirements (or lack thereof). There’s also been a change to the specific language around who can perform inspections to clarify who exactly is qualified and what qualification entails.

This is not to say that all changes are a result of the inspection requirements. However, many of the changes (outlined in more detail below) are a direct result of new processes and requirements from the inspections. 

Recommended Inspection Practices for USTs

Many of the 2021 revisions include updates, modified language, and clarifications. The biggest change is the removal of daily inspections, making them optional and updating monthly and annual inspections requirements to mirror EPA requirements.

The 2021 version includes the following revisions:

• Updated monthly and annual inspections requirements to mirror EPA requirements
• Removed requirement for daily inspection (Chapter 6) and made optional
• Modified monthly inspection process to reflect removal of daily inspection
• Modified daily inspection to an optional periodic operational inspection and moved to Appendix
• Added language that the optional periodic operational inspection is a possible method that can be used to comply with monthly inspection
• Modified language on who should complete monthly and annual inspections by revising the definition for qualified person and removed requirements for Level I and II designation
• Updated periodic, monthly and annual checklists
• Reordered Appendix to reflect changes for monthly, annual and optional periodic operational inspections
• Clarified use of electronics sensors for leak detection
• Clarified use of statistical inventory reconciliation for tank and line leak detection

What hasn’t changed is the amount of data you need for accurate recordkeeping. 

Checklists are designed to help you get things done. When you’re managing monthly and yearly maintenance tasks, keeping track of all that data manually can bog you down. On the PEI website, there are 10 Appendixes alone available to download! When you multiply the number of checklists by 10s or 100s of tanks, your recordkeeping can spiral out of control.

Wrap Up

With Titan, you can store all your documents and comprehensive data in one place. You’ll get more done in less time with automated reports at your fingertips. Best of all, you can stop worrying about delayed reporting, missing paperwork, or losing critical compliance documents.

Those in the business of storing and dispensing fuel can use advanced technology to streamline their UST inspection tasks. 

Learn how Titan can keep your fuel operation efficient and profitable. Schedule a demo today.

Brian Allender

SVP of Product & Technology

Brian has over 15 years’ experience providing a range of solutions to businesses of all kinds, focusing on development, project management, quality assurance, and operations. As the SVP of Product & Technology at Titan, Brian leads the company’s overall product strategy, including process improvement and development operations.