PEI Class 7 Test cheat sheet

PEI RP100/RP200 and API RP 1615 are industry recommended practices; the enforceable requirements come from 40 CFR Part 280 (USTs) and state/local rules that may be stricter.

40 CFR 280.20 requires spill/overfill protection and corrosion protection on new or replaced UST systems; 280.21 covers upgrading existing systems.

Spill buckets are required at fill pipes; overfill protection must be a automatic shutoff device, overfill alarm, or ball-float valve (280.20(c)).

Corrosion protection options: coated-and-cathodically-protected steel, STI-P3 type, fiberglass-reinforced plastic, or cathodic protection with impressed current or sacrificial anodes.

Class 7 work typically requires confined-space entry procedures per OSHA 29 CFR 1910.146: permit, atmospheric testing, attendant, and rescue plan.

Fuel vapors are heavier than air; LEL metering and bonding/grounding before transfer are standard controls. Gasoline LEL is about 1.4% by volume in air.

Reporting: suspected releases must be reported per 280.50 within 24 hours; spills/overfills with no free product and no contamination may be logged and investigated per 280.53.

Secondary containment (double-wall tanks/piping, sumps) is required in many states and for new installations; check state rule because federal Part 280 does not universally mandate it.

Flexible piping must be installed per manufacturer bend-radius limits; kinking or over-bending causes permeability failures and is a common inspection reject.

Slope pressurized supply lines back to the tank or to a sump so product drains and line leak detection can function; slope vapor recovery lines toward the tank or riser.

Secondary-contained piping: the interstitial space must be monitored (liquid sensor in sump or vacuum/pressure monitoring) per manufacturer and state rules.

Pipe joints: fusion for HDPE, solvent cement or heat fusion for FRP, and threaded or flanged steel connections; each has its own cure or torque spec.

Vapor recovery (Stage I/II) lines must be liquid-tight and tested; a blocked or liquid-trapped vapor line causes tank pressure and dispenser shutdowns.

Line leak detection: 3.0 gph annual test, 0.1 gph monthly monitoring, or SIR per 40 CFR 280.43; a line leak detector must be tested annually (280.40(c)).

Piping that is not secondarily contained and is in contact with soil needs corrosion protection; steel piping must be coated and cathodically protected or be FRP.

Pressure-test piping before backfill at the manufacturer's test pressure and hold time; record gauge readings and ambient temperature.

Spill buckets must be liquid-tight, hold at least 5 gallons, and be tested for tightness at installation and periodically per state rule (commonly annual or every 3 years).

Sump testing: hydrostatic test the sump by filling with water above the highest liquid level and observing for a specified hold time; record leaks and drop.

Sump entry fittings and boots must be sealed liquid-tight; unsealed penetrations defeat secondary containment and are a common inspection finding.

Sump sensors must be positioned to detect liquid at the lowest point and be tested with the manufacturer's method; a sensor set too high misses small leaks.

Double-wall sumps require interstitial monitoring; single-wall sumps inside secondary containment need a liquid sensor or visual inspection schedule.

Overfill prevention: ball-float valves must be set to stop flow at 90% tank capacity; drop-tube overfill devices must be inspected and tested per manufacturer.

Spill bucket drain valves must be closed during delivery and opened only after the bucket is emptied; a stuck-open drain causes spill to bypass containment.

Keep sumps clean and free of standing water; product or water in a sump masks sensor function and can corrode fittings.

Tank capacity: fill level is typically 90% for overfill protection; working capacity = tank volume × 0.90, with 95% as the alarm setpoint on many systems.

Tank testing: 0.1 gph monthly monitoring, 0.2 gph annual tank tightness test, or SIR; the annual tightness test is 0.1 gph over the specified test period per 280.43(c).

Spill prevention: overfill device, spill bucket, and drop tube must all be present; a drop tube that does not reach within 6 inches of the tank bottom causes turbulence and static.

STI-P3 tanks use a dielectric coating, sacrificial anodes, and a test station; anode readings and coating condition must be checked at each inspection.

Tank gauging: automatic tank gauging (ATG) with inventory reconciliation; a 1% + 130 gallon variance rule is a common leak-detection trigger.

Vent lines must be unobstructed, slope back to the tank, and have a pressure/vacuum vent or vent cap; a blocked vent causes tank pressure and dispenser problems.

Manways, gaskets, and bungs must be torqued to the manufacturer's spec; over-torquing cracks composite tanks and under-torquing leaks.

Tank registration and financial responsibility records are required; keep tank tightness test results and monitoring records for at least 3 years (280.45).

Release detection methods under 280.43: ATG, interstitial monitoring, vapor monitoring, groundwater monitoring, manual inventory control with tank tightness testing, and SIR.

ATG must be capable of detecting a 0.1 gph leak with a 95% probability of detection and 5% false alarm rate; run tests during quiet periods with no dispensing.

Line leak detection: 3.0 gph annual test, 0.1 gph monthly monitoring, or SIR; a line leak detector must be tested annually (280.40(c)).

Inventory control: stick readings plus dispensed volume; a variance greater than 1% of throughput plus 130 gallons triggers investigation.

SIR uses statistical analysis of inventory and dispensing data; it must be site-specific and validated by a vendor or state-approved method.

Interstitial monitoring: liquid sensor in the annular space or vacuum/pressure monitoring; a sensor alarm must be investigated and logged.

Sensor testing: verify alarm and normal conditions with the manufacturer's test method; record date, tester, and result for each sensor.

Release investigation: confirm a release, report within 24 hours per 280.50, and begin free-product removal and site assessment per state rules.

Pre-installation: verify tank and piping are listed/approved, check for shipping damage, and confirm excavation depth, bedding, and anchor design against the drawings.

Backfill: use pea gravel or specified material, place in lifts, and keep heavy equipment off the tank; hold-down straps or anchors are needed in high-water areas.

Piping pressure test: test at the manufacturer's pressure and hold time before backfill; record gauge readings, ambient temperature, and test duration.

Tank tightness test: use a test method that detects 0.1 gph; the test must be conducted after installation and before product is introduced.

Sump and spill bucket testing: hydrostatic test at installation, then per state schedule; record water level drop and hold time.

Cathodic protection: verify anodes and test station, and record a structure-to-soil potential of at least -850 mV (Cu/CuSO4) for steel tanks and piping.

As-built documentation: record tank and piping locations, depths, materials, and test results; keep records for the life of the system plus the required retention period.

Final inspection: confirm spill/overfill devices, vent caps, sump covers, and monitoring sensors are installed and functional before the system is placed in service.