Guide to PEI RP-1200 Forms for UST Service Providers
What is RP-1200 and Why It Matters
PEI RP-1200 is the Petroleum Equipment Institute’s Recommended Practice 1200, a comprehensive standard for testing and verifying critical equipment on underground storage tank (UST) systems. It was developed by a committee of UST experts (service contractors, regulators, operators, etc.) in response to industry requests for a single authoritative source of procedures . RP-1200 provides general guidelines for inspecting and testing leak detection, release prevention, and overfill prevention equipment at UST facilities . In practice, it helps ensure that spill containment, overfill shutoff devices, leak detectors, and other safety components are functioning properly to prevent leaks and protect the environment.
This recommended practice matters because it is widely recognized by regulators. In fact, the U.S. EPA explicitly cites PEI RP-1200 as an acceptable code of practice to meet federal UST testing requirements . After the 2015 federal UST regulation updates (effective 2018) mandated periodic equipment testing, having a consistent industry standard became “critically important for the industry” to ensure everyone performs these new tests and inspections correctly . Following RP-1200 helps UST service providers and owners stay in compliance with regulations and, more importantly, maintain equipment that protects our soil and groundwater from fuel leaks .
Structure of RP-1200 and Its Forms
PEI RP-1200 is organized into chapters detailing test procedures for various UST components, and it includes a series of sample forms (data sheets) in the appendices. These forms are essentially standardized checklists and report templates for documenting inspections and tests. Appendix C of RP-1200 contains “Sample Test Data Sheets” labeled C-1 through C-11, each corresponding to a specific piece of equipment or test . Each form provides fields for site information, the equipment being checked, test criteria (often yes/no checkboxes or measurements), and a section for results and technician sign-off.
Key forms included in RP-1200 (Appendix C) cover the following areas :
Secondary Containment Testing Forms: Tank secondary containment and piping secondary containment integrity test sheets (Appendices C-1 and C-2), as well as forms for spill bucket testing and containment sump testing(Appendices C-3, C-4, and C-4A) . These are used to document tightness tests (hydrostatic, vacuum, or low-liquid-level tests) of sumps, spill basins, and interstitial spaces.
Overfill Prevention Inspection Forms: Forms for inspecting overfill prevention devices – including the automatic shutoff valve (flapper) in the fill pipe (Appendix C-5) and the ball float valve in the vent (Appendix C-5A) – and for testing overfill alarms (Appendix C-6) . (Notably, RP-1200 recommends phasing out ball float valves and replacing them with other overfill prevention devices , but a form is provided to inspect them if present.)
Leak Detection Equipment Test Forms: Data sheets to verify proper operation of electronic leak detection systems. These include forms for automatic tank gauge (ATG) operation (Appendix C-7), liquid level sensors in sumps or tanks (Appendix C-8), and line leak detector performance for pressurized piping (Appendix C-9) . They serve as both a checklist of functional tests and a report of results.
Safety and Emergency Equipment Forms: Checklists for inspecting shear valves (pump shut-off valves typically under dispensers) in Appendix C-10 and emergency stop switches in Appendix C-11 . These forms guide service techs through verifying that emergency shutoff systems will operate correctly (an important safety step during maintenance or annual checks).
Each form is structured to prompt the service provider through the required inspection or test steps and record the outcomes. For example, the automatic overfill shutoff device inspection form (Appendix C-5) lists steps like removing the drop tube, checking the float/poppet for free movement, and confirming the device will shut off flow at 95% tank capacity . There are checkboxes for “Yes/No” responses, and a note that any “No” indicates a test failure requiring attention . At the bottom of each form, the technician records the overall result (Pass/Fail), adds comments, and signs and dates the form – creating an official record of that inspection or test.
When and How to Use Each Form
UST service providers should use the RP-1200 forms whenever they conduct the periodic tests or inspections mandated for UST systems, as well as during routine maintenance visits where these components are evaluated. The timing/frequency of using each form generally aligns with regulatory requirements and industry best practices:
Spill Containment & Sump Test Forms: Use the spill bucket and containment sump test data sheets (C-3, C-4, etc.) at least once every three years, or whenever a containment area is repaired or suspected of leaking. Federal rules require spill buckets and any sump used for interstitial monitoring to be tested triennially for liquid tightness (unless continuously monitored by sensors). Service contractors will typically fill out these forms during the three-year compliance tests: for example, performing a hydrostatic test by filling the sump and recording the water level drop (if any) on the form. If the site’s sumps are double-walled and under continuous interstitial monitoring, formal testing may not be as frequent, but whenever a test is done the forms should be completed to document method, conditions, and results.
Overfill Prevention Forms: Utilize the overfill device inspection and alarm test forms every three years as well (or more often if required by local authorities or if an issue is suspected). According to EPA rules, overfill prevention equipment must be inspected at least once every 3 years to ensure it will activate at the correct fuel level . In practice, a technician will remove and inspect the automatic shutoff (“flapper”) or ball float valve and log observations on Appendix C-5 or C-5A. Similarly, overfill alarm function is tested (by simulating a high tank level) and the outcome is recorded on Appendix C-6. These forms serve as checklists to ensure no step is missed (e.g. verifying the float moves freely, alarm sounds at the set point, etc.) and as reports that the device passed or failed the inspection. If an overfill device fails (e.g. a flapper doesn’t drop or an alarm doesn’t activate), the form will indicate failure and the service provider should arrange repairs or replacement immediately, then re-test.
Leak Detection Equipment Forms: Complete the ATG, sensor, and line leak detector test forms annually or per manufacturer requirements. Most leak detection components require yearly functionality testing (for instance, line leak detectors must typically be tested annually to meet leak rate performance criteria). During these annual visits, a technician will use Appendix C-7 to check the automatic tank gauge’s sensors and console alarms (ensuring it correctly detects tank level changes), Appendix C-8 to test each liquid sensor (by tipping it in fluid or lifting it to simulate a leak, etc.), and Appendix C-9 to verify line leak detectors trip at the appropriate leak rate. The forms guide the tester through specific checks and allow recording of measured values (e.g. line leak detector test pressure or leak threshold) to confirm they meet standards. By following RP-1200’s form checklist, service providers ensure consistent testing procedures and provide owners with documentation that the leak detection system is working as intended .
Safety Device Forms: Use the shear valve (C-10) and emergency stop (C-11) inspection forms during routine maintenance or annual safety checks. Shear valves are usually tested at least once a year (often during dispenser servicing or regulatory inspections) by manually tripping the valve to make sure it quickly shuts off fuel flow. The C-10 form lets technicians record that test – confirming the valve was secure and shut fuel when activated. Emergency shut-off switches (the “E-stop” buttons) should also be checked periodically to ensure they cut power to pumps. Appendix C-11 provides an outline to test each emergency switch and document that it functioned. While not always explicitly required by federal UST rules, these checks are considered best practice and are sometimes mandated by fire codes or state regulations. By logging them on RP-1200 forms, service providers create a record that critical safety interlocks are operational.
How to use the forms: Before conducting any test, technicians should review the relevant RP-1200 section for the proper procedure (the forms often reference the section number – e.g. “See RP1200 Section 7 for inspection procedures” is noted on the overfill device form ). During the test or inspection, carry the form on a clipboard or tablet and mark each checklist item as you go. Many service companies use digital versions of these RP-1200 forms, but even electronic checklists should mirror the RP-1200 content. Fill in all equipment details (tank or sump IDs, capacities, etc.), check the appropriate Yes/No boxes or record measurements, and clearly indicate Pass or Fail at the end. If any component fails, the form’s instructions (and RP-1200 guidelines) will direct that it’s a failed test and likely requires immediate correction . It’s good practice to note in the comments what action is taken or needed (e.g. “spill bucket failed – scheduled for replacement on 5/10/25”). Finally, sign and date the form (and have the owner/operator sign if required by local policy) to certify the inspection/test was performed .
Best Practices for Completing and Storing RP-1200 Forms
Completing the forms: Always fill out RP-1200 data sheets thoroughly and accurately. This includes the header information (facility name, address, tank ID numbers, tester’s company and name, date of test, etc.) – providing traceability for the record. Follow any specific instructions on the form: for example, use the manufacturer’s procedure to verify an automatic overfill flapper’s shutoff level as noted on the form , or ensure water level and time are recorded during a sump test. Mark each checklist item clearly as pass (“Yes”) or fail (“No”) so that anyone reviewing the form can quickly see if all criteria were met. If a question is not applicable (e.g. a particular feature isn’t present), mark it accordingly if the form allows (“Not Present” or “N/A”). Many forms have built-in pass/fail criteria – for instance, “A ‘No’ to any item… indicates a test failure” – so pay attention to those notes and immediately communicate any failures to the facility owner. In the comments section, describe any deficiencies or repairs made. Keep your handwriting legible (if using paper) or ensure electronic entries are saved properly. Remember that these documents may be reviewed by regulators or auditors, so professionalism counts.
Storing and recordkeeping: Once completed, RP-1200 forms become part of the official maintenance record for the UST facility. UST regulations require that testing and inspection records be maintained for at least three years , and many owners/operators prefer to keep them for the life of the equipment. As a best practice, service providers should give a copy of each completed form to the tank owner/operator and also retain a copy in their own files. Organize the records by date and by site – for example, keep all of a given station’s RP-1200 test forms together, grouped by year or by tank system. Electronic storage is acceptable (and often convenient), but ensure digital records are backed up and accessible. Some companies use online compliance management systems where they upload these form results; others simply scan paper forms to PDF. Whatever the method, the goal is to be able to readily retrieve any form if asked by an inspector or when planning the next test. It’s wise to also log the completion of these forms in a master maintenance schedule – this helps track when each test is next due (since, say, three years can pass quickly). Lastly, ensure the forms are signed by the certified tester and, if required, by a witness or facility representative. A signed RP-1200 form is essentially a legal document attesting that an inspection/test was done, so treat it with care. Keep originals dry and secure (if physical) and preserve the integrity of the data (no unauthorized edits after the fact; if a correction is needed, it should be done with proper annotation or a new form).
Updates to the RP-1200 Standard (What to Know)
The RP-1200 standard has evolved over time, and UST service providers should stay aware of the changes in each edition:
2012 Edition: This was the first release of RP-1200. It introduced the framework for testing spill, overfill, leak detection, and containment equipment. As the industry’s first attempt at a unified procedure guide, it set the baseline, but some details were refined in later updates.
2017 Edition (RP1200-17): This edition replaced the 2012 version and was a significant update, timed to help the industry comply with the new 2015 EPA UST regulations. The 2017 update made the document easier to read and clarified various items . Importantly, it reinforced best practices and added consistency to certain test methods. For example, it specified that in hydrostatic sump testing, the water level should be at least 4 inches above the highest penetration or seam – a point of confusion previously. It also strongly encouraged phasing out ball float valves for overfill prevention, affirming the 2012 guidance that ball floats should be removed and replaced with another overfill device . Additionally, the vacuum testing procedures for double-walled tanks were standardized in 2017 to ensure fiberglass and steel tanks are tested consistently . Definitions were also tweaked to align with terminology in other PEI RPs . UST service companies that transitioned from the 2012 to 2017 edition needed to adjust to these clarified procedures (for instance, using the 4-inch water height rule in sump tests, and planning to retrofit any remaining ball floats).
2019 Edition (RP1200-19): In 2019, PEI released another revision. The hallmark change in RP1200-19 was the introduction of a new alternative test procedure for containment sumps. The original method (fill to 4 inches above penetrations) was retained, but the 2019 update added a low liquid level testing method for sumps . This low-level test (detailed in Section 6.6 and Appendix C-4A of RP-1200) allows testing a sump’s tightness by adding liquid only up to a lower point (e.g. just high enough to activate a sensor), under specific conditions. The change was made because some older sump designs or field situations made full 4-inch testing difficult or risky (e.g. requiring dispenser removal or posing drowning-out concerns) . The 2019 edition’s inclusion of both procedures meant that service providers had a PEI-sanctioned alternative – if certain criteria are met – to perform tightness tests with less liquid. Many regulators accepted this change: since both the full and low-level methods were now in an official code of practice, either could be used to satisfy the 3-year sump test requirement (when allowed by the jurisdiction). UST testers should familiarize themselves with Appendix C-4A and the conditions under which the low-level test is applicable (for example, typically there must be an automatic liquid sensor at the lowest point and other safety interlocks ).
2024 Edition (RP1200-24): The latest edition (published late 2024) continues to refine the standard. A notable update is that it acknowledges new testing technologies and methods. For instance, RP1200-24 explicitly accepts certain alternative test methods like vacuum-based or dry testing systems for sumps (e.g. devices such as “Dri-sump” that test containment without filling it with liquid) as long as they meet the performance criteria . By incorporating this language, PEI is keeping the standard current with innovation – giving service providers flexibility to use advanced tools while still following an industry-approved procedure. Service providers should obtain the 2024 edition and review changes in detail, as there may be other updates to testing procedures or form documentation requirements. Even if the core tasks (spill bucket tests, overfill inspections, etc.) remain similar, subtle changes in pass/fail criteria or documentation can occur. For example, the low-level sump test method introduced in 2019 is expected to remain, possibly with clarifications, and any new definitions or safety precautions added since 2017 will be in the new text. Staying up-to-date ensures that the testing you perform is aligned with the latest best practices and regulatory expectations – which is crucial, given that EPA and state agencies do look to PEI standards as the benchmark .
Bottom line: RP-1200 is a living document that adapts to regulatory changes and field experience. UST service providers should always use the latest edition as their guide. Doing so not only improves the quality and consistency of inspections but also signals to clients and inspectors that your methods are current. When a new edition is released, take time to train your technicians on the updates, obtain or update the sample forms if they’ve been revised, and incorporate any new procedures (such as alternative test options) into your services. By following RP-1200 and properly using its forms, UST service companies can confidently perform inspections and tests knowing they are meeting industry standards for accuracy and safety . This protects your clients from non-compliance issues and ultimately helps keep our environment safe from UST system failures.
Want to Simplify Compliance and Streamline Field Work?
PASS Symphonics is purpose-built for UST service companies. From assigning inspections to capturing RP-1200 test results in the field, Symphonics automates your workflow, helps you stay organized, and ensures nothing slips through the cracks.
Reach out today to see how Symphonics can support your team.
Sources: The information in this guide is drawn from the Petroleum Equipment Institute’s RP-1200 documentation and related resources, including the PEI website , regulatory references , and industry publications . These sources reflect the consensus of experts and regulators on how UST testing should be conducted and recorded. Service providers are encouraged to refer to the full RP-1200 text for detailed procedures and to use the PEI sample forms as a model for their own inspection and testing reports.
