August 30, 2011 | Vol. 61, No. 18
|Dear PEI Member:
PEI has created a page on our website―called the UST Component Compatibility Library―where tank owners, equipment distributors, environmental officials, fire regulators and underground storage tank (UST) system installers can go to make certain particular UST equipment is compatible with higher ethanol and biodiesel blends. In anticipation that the demand for a central place to access compatibility information will increase once E15 is permitted for sale, we are asking manufacturers of UST components to provide us with this information so interested parties will have it when needed at www.pei.org/compatibility.
Background. EPA published guidance in the July 5, 2011, Federal Register regarding compatibility of UST systems with biofuel blends. The guidance discusses how owners and operators who wish to store gasoline containing more than 10 percent ethanol or diesel containing more than 20 percent biodiesel in their UST systems may demonstrate compliance with the compatibility requirement in 40 CFR 280.32.
In order to ensure the safe storage of higher ethanol (>E10) and biodiesel (>B20) blends, owners and operators must meet the existing compatibility requirement for UST systems. The UST compatibility requirement in 40 CFR 280.32 states: "Owners and operators must use an UST system made of or lined with materials that are compatible with the substance stored in the UST system." EPA explains that "because the chemical and physical properties of ethanol and biodiesel blends may make them more aggressive to certain UST system materials than petroleum, it is important that all UST system components in contact with ethanol or biodiesel blends are materially compatible with that fuel."
UST components that must be compatible. EPA considers the following parts of the UST system to be "critical" for demonstrating compatibility:
Options for meeting the compatibility requirement. EPA lists three acceptable methods owners and operators of UST systems can use to demonstrate compatibility. They are:
EPA is quite specific about what it considers an acceptable form for manufacturer approval. The approval must:
by e-mail to the editor, Robert Renkes at email@example.com
or join the discussion in the Petroleum Equipment Forum
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What PEI will do. PEI will post the following types of letters from manufacturers on the PEI website:
Manufacturers of UST system components identified by EPA as being "critical for demonstrating compatibility" are encouraged to write a letter on company letterhead if they have produced listed equipment and/or have deemed equipment compatible with ethanol blends greater than 10 percent or ethanol or biodiesel blends greater than 20 percent biodiesel. If the manufacturer has approved equipment for higher biofuel blends―as opposed to having the equipment listed―the letter needs to include the four elements mentioned by EPA above. Although not required, we suggest the letter be dated, submitted in Acrobat PDF format, signed by a corporate officer and include contact information provided for that person. Send those letters to firstname.lastname@example.org and, after review, we will put them on our website where all manufacturer statements of listing/compatibility will reside. The website is available to all and is not password protected. Questions or comments should be directed to Bob Renkes at email@example.com.
EPA is clear that if the UST owner and operator is not able to demonstrate that the UST system is made of materials that are compatible with the ethanol or biodiesel blend stored, according to 40 CFR 280.32, the UST owner and operator may not use the system to store these fuels. Manufacturers of UST system components are encouraged but not required to submit letters to PEI demonstrating compatibility so all interested parties have a single place to go for authoritative information about higher biofuel blends and their legacy equipment.
PEI BOARD ELECTIONS COMPLETED: CARLYLE ELECTED; ARN REPLACES RUSSELL
Joey Arn, Petroleum Containment Inc., is the new director from Manufacturer District 11. He was runner-up to Paula Russell of Goodyear, who recently left the company and accepted employment in another industry.
All newly elected directors will be installed at the Membership Breakfast in Chicago on October 3. If you have not sent in your RSVP, please do so now. This helps us provide accurate seating and food.
INTEREST IN AUTOMOTIVE SERVICE EQUIPMENT CONFERENCE SOUGHT
A letter from PEI was emailed August 22 to all PEI distributor, affiliate and service/construction division members. The letter described potential topics for the conference and asked members to complete a brief online survey to help the PEI Board of Directors gauge interest in sponsoring such a conference. If you haven't responded to the letter by participating in the survey, click here. Deadline for responses is Friday, September 2.
STI PRESENTS TANK VENTING WEBINAR
CALIFORNIA FUEL DISTRIBUTOR TO PAY $3 MILLION UST SETTLEMENT
PETROLEUM MARKETING BRIEFS
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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.