Dear PEI Member:
We believe that this is the first document to ever address the installation of bulk plants. The recommended practices apply to underground, aboveground, atmospheric, and shop-fabricated tanks, associated piping, diking, spill containment, and equipment intended for the bulk storage and transfer of petroleum, biofuels, and related products to and from wheeled delivery-vehicle tanks. They apply to single- and double-walled horizontal and vertical tanks, as well as insulated and fire-protected (resistant) tanks. Piping associated with the tanks covered in the recommended practices may be underground, aboveground, or a combination of the two.
The document, which was 18 months in the making, was written by the PEI Bulk Plant Installation Committee: Terry D. Cooper (chairman), Acterra Group; Georges Boyazis, Innovative Petroleum Products; A. Roy Creley, Lakes Region Environmental Contractors; Wayne Geyer, Steel Tank Institute; Mark Lipa, Neumayer Equipment Company; Dave MacDonald, Prevent-A-Spill; Bill Morgan, Collins Equipment Corporation; Charlene Numrych, Liquid Controls; Brian Savage, Savage Associates, Inc.; John Steward, Blackmer - A Dover Company; and Rick Zillig, Morrison Bros. Co.
If you build bulk plants, you should have a copy of this document. We
urge you not to use the draft mailed in November of 2007 since public
comments to that draft resulted in significant changes to the document. PEI/RP800-08 is copyrighted and may not be photocopied or
otherwise reproduced. Order online ($40 for members; $95 for nonmembers) at
www.pei.org/rp800 or request an order
form by calling PEI at 918-494-9696. The order form can also be downloaded
at the above address.
PEI Bulk Plant Installation RP Available
Thoughts on USTs
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THOUGHTS ON UNDERGROUND STORAGE TANKS
"We may not get paid top dollar, but at least we have job security. As long as there are underground storage tanks, our work will never be completed." That comment, made to me recently by a state underground storage tank (UST) program manager, caused me to reflect on the industry's ability to prevent new releases and cleanup existing ones.
For nearly 25 years, significant progress has been made in preventing, detecting, and cleaning up petroleum leaks from USTs. The UST population has been reduced from over 2 million to 630,00 over that period of time. But despite that vast reduction in numbers, an average of 9,000 new leaks are found each year and 110,000 old leaks have yet to be cleaned up.
EPA cites the lack of proper operation and maintenance of UST systems as a main cause of these new releases. With only 63 percent of the facilities having achieved "significant operational compliance"—defined as having the necessary equipment required by current regulations to prevent and detect releases and performing the necessary UST system operation and maintenance—it is clear that the problem of leaking UST systems is not going to go away.
The Energy Act of 2005 will help some. The tank release prevention programs are becoming stronger with mandatory inspections, owner-operator training, tag-out systems at non-complying facilities, and secondary containment mandates.
Let's look back to 1984 when President Reagan signed the UST Act and think about what has changed in the last 25 years. The equipment? It has been greatly improved, but it is not perfect and cannot be expected to last forever when subjected to the adverse conditions of today's UST environment. The installers? Again, great progress has been made in that regard, but we still are not batting 1,000, and we never will. The facility owners/operators? Billions of dollars have been spent, tremendous strides have been made, but still less than two-thirds have achieved significant operational compliance.
So I found myself agreeing that UST regulators can have a job for life if they want it. And so can PEI members who do that sort of work. The challenges and opportunities for our industry presented by UST systems will always be with us.
COMMENT DEADLINE FOR RP200 REVISION IS
We wrote in that newsletter that the owner or operator of a new area source must comply with the final rules when they are published in the Federal Register (January 10, 2008) or upon initial startup, which ever is later. We went on to say that the owner of an existing area source must comply with all of the requirements within three years of final rule publication. All of that information was correct.
Many of us in the industry assumed that "existing" area sources would be those that existed on the date the rules became final and that "new" area sources would be those that started up sometime after the rules were finalized, i.e., January 10, 2008. That is where we made our mistake. The rule defines a new area source as one that commenced construction after November 9, 2006, and not when the rule was finalized. In other words, if a retail gasoline dispensing facility, built after November 9, 2006, has a throughput of 100,000 gallons or more of gasoline per month, it must already have Stage I vapor recovery. That facility must comply immediately.
The rule doesn't make sense to us, but when it comes to regulations, it evidently doesn't have to make sense. We don't know how many stations were built between November 9, 2006, and January 10, 2008, that dispense over 100,00 gallons per month that were not equipped with Stage I at startup. We suspect only a few. If you know of any, please pass this information along to them.
NACS RELEASES 2007 INDUSTRY PERFORMANCE DATA
MINNESOTA'S NEW UST RULES
AWARDS AND CELEBRATIONS
PEI MEMBER NOTES
ADMITTED TO PEI
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The TulsaLetter (ISSN 0193-9467) is published two or three times each month by the Petroleum Equipment Institute. Robert N. Renkes, Executive Vice President, Editor. Opinions expressed are the opinions of the Editor. Basic circulation confined to PEI members.