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December 2, 2008 | Vol. 58, No. 21

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Dear PEI Member:

The U.S. Environmental Protection Agency (EPA) has finalized amendments to its Spill Prevention, Control and Countermeasure (SPCC) rules. The amendments are meant to clarify some regulatory requirements, tailor requirements to specific industry sectors, and streamline certain requirements for regulated facility owners. Regulated facilities must develop and implement SPCC plans that establish procedures and meet equipment requirements to help prevent oil discharges from reaching navigable waters or adjoining shorelines.

EPA finalized some changes in its November 2008 amendments that are important to aboveground tank owners as well as PEI members who prepare SPCC plans and supply equipment and services for these owners.

  • Home heating oil tanks exempt. The amendments exempt residential heating oil containers (i.e., those used solely at single-family residences) from SPCC regulations.
  • "Loading rack" defined. Tank car and tank truck loading/unloading racks are subject to specific requirements, including sized secondary containment. Since sized secondary containment requires equipment sufficient to contain a release from the single largest compartment of the cargo tank vehicle, the area described in the definition of loading rack is critical. Section 112.2 defines loading rack this way: "A fixed structure (such as a platform, gangway) necessary for loading or unloading a tank truck or tank car, which is located at a facility subject to the requirements of this part. A loading/unloading rack includes a loading or unloading arm and may include any combination of the following: pipe assemblages, valves, pumps, shut-off devices, overfill sensors, or personnel safety devices."
  • Other loading rack issues. Loading racks attached to underground storage tanks exempt from the SPCC rule are regulated under these amendments and must be equipped with sized secondary containment. Exempted underground storage tanks, at an otherwise regulated SPCC facility, equipped with a transfer area (for example, dispenser or other transfer equipment) must meet the general secondary containment requirements of Section 112.7(c). That section provides many options to contain spills or releases from that equipment and are less onerous than sized secondary containment.  

EPA Amends SPCC Requirements

Stage II Action Requested

RP200 Revised and Available


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  • Security. EPA modified existing language to allow the tank owner or operator to design the security arrangements at the facility to address the unique, specific geographical/spatial factors that apply. The more prescriptive fencing and other security requirements mandated in the past have been eliminated. Instead, the owner or operator will describe in the SPCC plan "how he will secure and control access to all oil handling, processing and storage areas; secure master flow and drain valves; prevent unauthorized access to starter controls on oil pumps; secure out-of-service and loading/unloading connections of oil pipelines; and address the appropriateness of security lighting to prevent acts of vandalism and assist in the discovery of oil discharges." EPA believes this will eliminate the need for PE-certified environmentally equivalent alternatives to the specified security requirements.
  • Bulk plants under 10,000 gallons. Under the new language, in lieu of preparing a full SPCC plan that is PE- or self-certified, an owner or operator of a Tier I qualified facility will have the option to complete a new SPCC plan template found in the rule. Tier I facilities are defined as having a facility under 10,000 gallons of aggregate capacity with no single storage tank greater than 5,000 gallons. A Tier II qualified facility has an aggregate aboveground oil storage capacity of 10,000 gallons or less but has a storage tank capable of storing over 5,000 gallons. While owners and operators of Tier II facilities are still permitted to draft, revise and self-certify their own SPCC plans, any deviation from the SPCC requirements must be PE-certified.
  • Tank integrity testing. The bulk storage container testing requirements were amended to provide more flexibility to all facilities subject to the integrity testing provision. Specifically, EPA will now allow an owner or operator to consult and rely on industry standards to determine the appropriate qualifications for tank inspectors/testing personnel and the type and frequency of integrity testing required for a particular container size and configuration. Where an alternative integrity testing procedure is used that is not a recognized industry standard, a PE would need to certify the reason for the deviation and that the alternative measures are environmentally equivalent.
  • Proposed SPCC compliance deadline. In a proposed rule announced the same day, EPA proposed to extend the SPCC deadline for revising and implementing SPCC plans from July 1, 2009, to November 30, 2009. 
  • Effective date. The regulations are effective 60 days after publication in the Federal Register, which has not yet occurred. Pre-publication copies of the 276-page rule, together with the proposed compliance deadline proposal and fact sheets on the changes, are available at

Four trade associations representing petroleum marketers in the United States have formally asked the Environmental Protection Agency (EPA) to release its findings on Onboard Refueling Vapor Recovery (ORVR) technology.

When Congress passed the Clean Air Amendments in 1990, it permitted EPA to remove Stage II requirements when onboard canisters on motor vehicles are in "widespread use." Until EPA determines a definition for widespread use, however, states are unable to develop a plan to phase out Stage II vapor recovery. A copy of the letter from the trade associations to EPA is available here.

Numerous changes have been made to the text and drawings of PEI's Recommended Practices for Installation of Aboveground Storage Systems for Motor-Vehicle Fueling (PEI/RP200), which is now available for purchase from PEI. The 2008 edition supercedes and replaces the 2003 edition of RP200, which was written and revised in response to the environmental considerations and emerging technology that prompted the industry to use aboveground tanks to store motor-vehicle fuel.

The 41-page manual provides a concise reference to preferred practices and procedures for the installation of aboveground storage tank systems at service stations, marinas and other fueling sites. The recommended practice contains chapters and drawings on all phases of proper tank installation, including site planning; foundations, supports and anchorage; dikes; vaults and special enclosures; tanks; pumps and valves; fills, gauges and vents; piping and fittings; corrosion protection; environmental protection; electrical installation; testing and inspection; and documentation, maintenance and training. Three appendices describe size calculations for dikes, venting sizing, and fire code requirements. An appendix of documents used for reference is also included.

The single-copy price for RP200/08 is $40 for members; $95 for nonmembers. You can place an order online or download an order form at You can also request an order form from PEI by calling 918-494-9696 or faxing 918-491-9895.

Margo Oge, director of EPA's Office of Transportation & Air Quality, told an audience at the Carbon Market Insight Americas conference on November 13 that the agency will consider allowing ethanol to be blended in conventional gasoline in levels up to 20 percent (E20), provided that it not present "unintended consequences of impacting the environment or impacting vehicles." It is widely understood that EPA is under pressure to find more uses for ethanol, given the 2007 energy law's ever-increasing renewable fuel mandates and the fact that the industry will hit an E10 "blend wall" as soon as 2010. PEI has gone on record with EPA stating the agency should consider the effect E20 has on new and existing petroleum marketing equipment before allowing an ethanol blend higher than 10 percent (E10).

LSI Industries Inc.
, Cincinnati, Ohio, has announced that Walsh, Long & Company, Inc., Naperville, Illinois, will represent LSI in northern Illinois, North Dakota, South Dakota, Wisconsin and Minnesota.
Samson Corporation, Swannanoa, North Carolina, has named Philip J. Parker president of the company. The announcement was made by Alberto Moratiel, chairman of the board of Samson and chairman of Samson's corporate parent, Samoa Group, headquartered in Gijon, Spain.

In summer 2007, the Department of Energy (DOE) initiated a test program to assess the potential impacts of intermediate ethanol blends on legacy vehicles (non-flexible-fuel vehicles) as well as other engines that rely on gasoline. The latter include small engine non-road engines such as those used in lawn and garden equipment and engines for marine applications, motorcycles, and snowmobiles.

DOE's test program focuses specifically on the effects of E15 and E20, but considers both E0 (gasoline) and E10 as baseline fuels. Through a wide range of experimental activities, DOE is evaluating the effects of these intermediate ethanol blends on the emissions (both tailpipe and evaporative), catalyst and engine durability, vehicle driveability or engine operability, and vehicle and engine materials compatibility.

DOE has issued a 136-page report which provides the results available to date from the first stages of the much larger overall test program. The purpose of the initial study was to quickly investigate the effect of adding up to 20 percent ethanol to gasoline. Thirteen vehicles were included in the study. According to DOE, tailpipe emissions were not effected by the ethanol and catalyst temperatures under closed-loop operating conditions were cooler or unchanged with higher levels of ethanol. Six of the tested thirteen vehicles had somewhat higher catalyst temperatures when run at wide-open throttle. No operability or driveability issues were identified.

The U.S. Energy Information Administration (EIA) said that September oil demand figures were just 17.8 million barrels per day (b/d). That is down 2.6 million b/d, or 13 percent, compared to the same month last year. The September number is the lowest monthly demand reading since September 1996, while the year-on-year percentage decline is the biggest since 1980.

An interagency panel
that includes EPA is crafting a plan to research the environmental effects of cellulosic ethanol, a second-generation renewable fuel that has so far garnered less scrutiny than the more-controversial corn ethanol.--INSIDE EPA, November 7, 2008.
The cities of San Francisco, Oakland and San Jose have teamed with Palo Alto-based Better Place to install electric vehicle recharging stations in homes, businesses, parking lots and government buildings by 2012. Better Place would own the batteries in the electric vehicles and charge drivers a subscription fee to use its recharging facilities.--The Mercury News, November 20, 2008. 

PEI is considering sponsoring a one-day conference on diesel exhaust fluid (DEF) for PEI members and their customers (see November 24, 2008 TL). If you would be interested in either attending, presenting and/or exhibiting at such a conference, please respond to this survey. PEI staff will decide this month whether or not to hold a DEF Conference in 2009.   

John Robison
, former chairman of the National Fire Protection Association's Technical Committee on Automotive and Marine Service Stations (NFPA 30A), died suddenly November 22. He was 63. Robison served as Alabama State Fire Marshal for 15 years before his retirement in 2003. Survivors include his wife, Jamie, and three children.

Texas environmental services firm
. Accent Environmental Services Inc., 523 FM 1819, Pollok, Texas 75969, has applied for affiliate division membership. Danny Brevard is president of the company, which was established in 1983. Accent provides UST and AST recordkeeping and consultation. Sponsored for PEI membership by Thomas K. Bagby, Bagby, Pinson, AL.
Wisconsin compliance testing firm. Compliance Testing and Technology, Inc., N106 W13131, Suite 600, Germantown, Wisconsin 53022, has applied for membership in PEI's service and construction division. Greg Goeks is operations manager for the firm, which was established in 2007. The company provides site inspections, tank tightness testing, secondary containment testing, and Stage II vapor recovery testing. Sponsored for PEI membership by Glen Corkill, SourceIL, Arlington Heights, IL.


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Petroleum Equipment Institute
P. O. Box 2380
Tulsa, OK 74101-2380

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.