Many of the comments were accepted in one form or another. A few suggestions that were not incorporated into RP900 are also of some significance to users of the document.
Here is a summary:
The scope of the recommended practice was NOT expanded to include UST systems and associated equipment other than that used to store and dispense gasoline, diesel and related petroleum products at vehicle fueling facilities. In other words, the document is not intended to apply to marinas, aviation-fueling facilities, farms, emergency generators, etc.The committee did broaden the scope to include the shear valve.
The Committee recognized that, in many instances, the new federal inspection requirements that became effective October 13, 2015, were less comprehensive than the inspection practices contained in the 2008 edition of RP900. After reviewing all the inspection requirements of the federal rule, the Committee revised the document to meet or exceed the walkthrough inspection requirements and frequencies contained in the federal regulations. In a few instances, the Committee included recommended procedures for walkthrough inspections in the document that were not included in the federal rule. The Committee also rejected several proposals to increase the frequency of some inspections (e.g., spill bucket drain valves, interstitial space of drain valves).
A number of comments dealt with water and the quality of fuel in the UST. The Committee made a few tweaks to Section 7.6.5.1 that now requires the owner to check to see if water is present and, if found, to notify the appropriate person in the company. Section 7.6.5.1 also will direct the owner to a new appendix that will discuss water issues and suggest strategies to keep water out of the tank. The appendix will be available for public review and comment before it is included in the 2016 edition of RP900.
