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UST Program - LG 113
Work Group on Leak Detection Evaluations -
Policy Memorandum 1
of Work Group Ground Rules
March 8, 1994; Revised May 1, 2000
I. Work Group Mission
A. "The mission of the Work Group is to:
- Review leak detection system evaluations to determine if each evaluation was performed in accordance with an acceptable leak detection test method protocol and ensure that the leak detection system meets EPA and/or other regulatory performance standards;
- Review only draft and final leak detection test method protocols submitted to the Work Group by a peer review committee to ensure they meet equivalency standards stated in the EPA standard test procedures;
- Make the results of such reviews available to interested parties."
II. Work Group Structure
A. There are normally 10 Work Group members as follows:
- There will continue to be a minimum of 7 state and/or local government members from different states and local governments.
- There will continue to be a minimum of 2 but no more than 3 EPA members from different regions.
- It is desirable for members to have previous experience in the review of third party tests and the review of test protocols.
- Member vacancies will be filled in accordance with Work Group Policy Memorandum #2.
- The Chairperson serves a term of 1 year beginning January 1st of each year.
- The Chairperson is elected in accordance with the Work Group "Decision Making Process".
- Only state or local government members may be elected Chairperson.
- The Chairperson keeps the Work Group's official records.
- The Vice Chairperson serves a term of 1 year beginning Jan. 1st of each year
- The Vice Chairperson is elected in accordance with the Work Group "Decision Making Process".
- Only state or local government members may be elected Vice Chairperson.
- The Secretary serves a term of 1 meeting.
- The Secretary is elected in accordance with the Work Group "Decision Making Process".
- The Secretary is elected during the meeting preceding the meeting for which he/she serves as Secretary.
- The Secretary shall publish and distribute 2 sets of minutes within 60 days after the meeting. One set of minutes is to be distributed by e-mail to Work Group members only. The other is for interested parties outside the Work Group and will be put on EPA's internet home page. The latter minutes shall include only a summary of decisions and issues of general interest to vendors, tank owners, and other interested parties.
E. The Work Group is broken up into teams with a team leader and 1 to 3 team members who review third party evaluations and test method protocols of leak detection methods.
- The team leaders coordinate all team activities.
- The team leaders and team members are elected and removed from teams in accordance with the Work Group "Decision Making Process".
- The team leaders and team members have no team term limitations.
III. Work Group List
A. The Work Group brings together a list which includes:
- Leak detection systems that were third party evaluated and have been determined to be acceptable to the Work Group;
- Leak detection systems that were third party evaluated but are currently under review by the Work Group.
- eak detection test method protocols that were determined to be acceptable to the Work Group.
- Leak detection equipment maintenance checklists that are currently available.
B. The Work Group updates the list approximately twice per year and posts the latest version on the internet continuously.
C. States, local governments, and EPA may decide to use the list to determine which leak detection systems or applications they will approve for use in their jurisdiction.
IV. Outside Participation in the Work Group
A. All regular meetings will be open to members, and local, state and federal regulators.
B. During each regular meeting, there will be 3 one-hour sessions available for vendors, evaluators, protocol authors and other interested parties to make presentations to the Work Group.
V. Work Group Decision Making Process
A. Decisions are made by a majority vote using the following rules:
- There must first be a quorum of 7 members present at meetings and/or involved in conference calls;
- A substitute member may vote if the substitute is employed by the same state agency, local government agency, or EPA regional office;
- In the event of a tie vote, the Chairperson must abstain.
VI. Work Group Conflict of Interest
A. Work Group members must decline any involvement in review of evaluations and protocols in which the member has a conflict of interest based on employment or any other activities within 2 years prior to becoming a Work Group member.
B. Work Group members must take all necessary precautions to avoid being involved in a situation which could be considered a conflict of interest while they are a member of the Work Group.
C. The Work Group members must notify the Chairperson of any attempt to unduly influence member actions within the Work Group.
VII. Work Group Litigation Precautions
A. Members need to make sure their employer will defend them against litigation resulting from work performed related to work group activities.
- PA defends EPA employees when work group activities are listed as part of their job description. It is recommended that state members have work group activities listed in their job description.
- All formal Work Group correspondence should be written on employer's letterhead, and all electronic (computerized or e-mail) communications should be from employer's communication equipment or service.