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November 28, 2017 | Vol. 67, No. 23

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In This Issue

Dear PEI Member:

Since mid-2015, the District of Columbia and 38 states with State Program Approval (SPA) status have been working to update their underground storage tank (UST) regulations. To meet federal Environmental Protection Agency (EPA) requirements, these jurisdictions must amend their existing state plans and reapply for SPA status by Oct. 18, 2018.

As the amendment process unfolds across the country, no single question is receiving more attention than how best to test containment sumps used for interstitial monitoring of piping. Under the 2015 federal regulations, containment sumps used for interstitial monitoring must be tested at least every three years by a vacuum, pressure or hydrostatic method that ensures the sump is liquid-tight. Moreover, this test must be conducted according to:

  • Requirements developed by the equipment manufacturer;
  • A code of practice developed by a nationally recognized association or independent testing laboratory; or
  • Procedures that the EPA determines are no less protective of the environment than either of the first two methods.

At present, the federal regulations accept only one code of practice for containment sump testing: PEI/RP1200: Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities. The PEI/RP1200 hydrostatic testing method requires the owner or operator to fill the sump with water to a depth of at least four inches above the sump’s highest penetration or sidewall seam. The sump passes the test if the water level in the sump drops by less than 1/8 inch after one hour. If the water level drops by 1/8 inch or more, the sump fails.

Any SPA state that is uncomfortable with the RP1200 hydrostatic test must adopt an alternative test method that is equally protective of the environment. In the technical compendium accompanying its 2015 federal regulations, EPA has even outlined a package of test requirements it would consider sufficient:

  • A liquid level sensor mounted at the lowest point in the sump;
  • Periodic testing of the sensor according to the manufacturer’s requirements, with the owner or operator maintaining records of such requirements and test results;
  • Positive shutoff of the pump whenever product activates the sensor;
  • Positive shutoff of the applicable dispenser(s) whenever product activates the sensor; and
  • Staffing the facility at all times when the pumps are operational.

Containment Sump Testing Options

University of Innovative Distribution

E15 Developments

PEI Young Executives Conference




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Although the Petroleum Marketers Association of America (PMAA) is lobbying state regulators to reject the RP1200 method in favor of some form of low-water-level test, the committee that drafted RP1200 continues to believe its recommended procedure offers the best, most balanced and most environmentally protective approach to this important task.

The composition of the RP1200 committee was carefully structured to reflect the diversity of the industry. Experts from large fuel marketers, small fuel marketers, environmental firms, fiberglass and steel tank manufacturer associations, distributors, contractors, testing companies, state regulators and even the EPA itself were all represented.

This diversity ensures that the consensus recommendations in the document took into account the perspectives of all major UST stakeholders. By contrast, the stakeholders advancing alternative test methods represent a much narrower range of interests.

Before reaching its final decisions, the RP1200 committee also actively solicited input from the industry through a lengthy public comment period. Many of the commenters offered suggestions on containment sump testing—from changing the water level to lengthening the test period to adjusting the pass/fail criteria to incorporating other technologies into the analysis. In the end, three fundamental factors led the committee to recommend the high-water-level sump test.

First, any meaningful test must ensure that the sides, bottom and penetration points of the sump are liquid-tight. Penetration points and side seams are the most likely points of failure in sumps. RP1200’s hydrostatic test protocol directly addresses these problem areas. Low-water-level tests do not.

Second, in a busy fueling station environment, containment sump sensors can be and often are jostled, damaged or moved from their designed locations. A test that relies on the accuracy and precise placement of a sensor is inherently risky. Faulty calibration, inadequate anchoring, equipment malfunction or a sensor placed too high in the sump can easily nullify the effectiveness of a low-water-level test. The RP1200 protocol is much more objective and much less prone to error than a sensor-based test.

Finally, alternative sump testing procedures that appear to be more convenient and less expensive may not be over the long term. Comparative data from major testing organizations show that the RP1200 hydrostatic test uncovers more sump failures than low-water-level tests. For owners and operators who truly are interested in protecting the environment, spending a little more now to reduce the risk of an undiscovered leak or catastrophic failure later is a small price.

Early bird registration is open for the 2018 University of Innovative Distribution (UID), March 11-14, at the JW Marriott in Indianapolis.

Now in its 25th year, UID is a concentrated educational program tailored specifically for professionals in the wholesale distribution industry. Attendees can choose from more than 40 classes to plan a program perfectly suited to their needs. CEOs, branch managers, sales and marketing professionals, operations managers, purchasing and inventory personnel, and manufacturers all can benefit from UID. PEI members who have attended in recent years have given the event rave reviews.

As a proud sponsor of the program, PEI is offering $600 scholarships to the first 30 PEI members who register. PEI also will host a special dinner during the conference just for PEI attendees, providing an excellent opportunity to network with your industry peers.

To view the full menu of courses and register online, visit www.pei.org/uid. Note: Many UID classes sell out well in advance, so early registration is strongly encouraged.

The Renewable Fuels Association (RFA) announced on Nov. 14 that nearly 90 percent of 2018 model-year vehicles are approved for E15. That’s up from 81 percent of 2017 model-year vehicles. Subaru, Mercedes-Benz and Mazda represent the largest E15 holdouts, with a collective 7.5 percent share of the U.S. market.

RFA and PMAA also have been busy on Capitol Hill during the past few weeks. PMAA kicked things off with a Nov. 9 letter to the Senate Environment and Public Works Committee stating that “95 percent of all gasoline outlets in the United States cannot legally store or dispense ethanol blends higher than 10 percent.” Four days later, RFA responded, protesting that PMAA’s statistics were “grossly overstated.”

The 2018 PEI Young Executives Winter Conference, originally planned for hurricane-hit San Juan, Puerto Rico, will be held at the Hermitage Hotel in Nashville with the same schedule, speakers and dates (Feb. 7-9, 2018). The Hermitage is Tennessee's only Forbes Five Star hotel.

Open to PEI member company employees age 21-45, the Young Executives Conference fosters an exchange of ideas on everyday business challenges in a relaxed environment that encourages creative thinking.

The conference keynote speaker is Garrison Wynn, author of The Real Truth About Success: What the Top 1% Do Differently, Why They Won't Tell You, and How You Can Do It Anyway! A panel of five industry experts also will discuss “What I Would Tell My Younger Self.” Panelists are:

  • Robert Peavey, 2018 PEI president and president of PumpTex Inc.;
  • Craig Hoyer, 2017 PEI president and president of Kubat Equipment & Service Co.;
  • Sara Hitchcock Beck, former PEI board member and chairman/CEO of Meco, Inc. (Montgomery);
  • Blair Shwedo, 2009 PEI president and president of SouthEastern Petroleum Systems Inc.;
  • Brad Baker, former PEI board member and executive vice president of Husky Corp.

Early bird registration ($495 for YE members and $595 for non-YE members) ends Dec. 15. Guests who do not work in the industry may enjoy conference receptions and meals for $125. Learn more and register at www.pei.org/ye2018.

New for 2018, PEI member companies interested in reaching these young leaders may secure sponsorships of the conference. View the various sponsorship levels here.

Eaton Sales & Service
is opening a new branch at 2000 W. Union Ave., Englewood, Colorado 80100. The branch will focus on lift and lube equipment sales and service, with Mike Feeney as division manager, Russell Dryer as service manager and Megan Coursey as office manager. 
Petro Service Ltd. acquired J.A. Robinson Pump Service. Petro Service, a distributor member based in St. John, New Brunswick, was founded in 1982 and currently has more than 80 employees. Winnipeg-based J.A. Robinson Pump Service will continue to operate as a wholly owned subsidiary of Petro Service Ltd.
Shields, Harper & Co. is celebrating its 100th anniversary this year. Based in Martinez, California, the longtime distributor member also operates eight branches in California, Nevada and Arizona.

“Nissan Motor Co., an early mover in the electric vehicle market, will use the Los Angeles auto show next week to send a message about gasoline-fueled engines: They’re not dead yet.
Shinichi Kiga, head of Nissan’s gasoline engine project group, told Reuters the Japanese automaker is resolved to keep improving internal combustion technology to prolong its usefulness for decades to come.”—New York Times, Nov. 24, 2017
“Volkswagen approved a $40 billion spending plan on Friday that accelerates its efforts to become a global leader in electric cars.
The world’s largest carmaker by unit sales will spend the money on electric cars, autonomous driving and new mobility services by the end of 2022, it said after a meeting of its supervisory board.”—Reuters, Nov. 17, 2017
“The Trump administration is formally rejecting a bid to relieve refiners of their obligation to fulfill annual biofuel quotas… . The formal declaration satisfies EPA Administrator Scott Pruitt’s earlier pledge to senators that he would retain the current structure of the Renewable Fuel Standard, which requires refiners and importers to blend biofuels into transportation fuels.”—Bloomberg Environment, Nov. 22, 2017
“Last week I watched Elon Musk unveil the Tesla Semi… . We don't know what the production truck will achieve when it hits the road, but the Semi has a lot going for it. Nevertheless, the Semi seems most impressive to those who don't know what it's like to be a truck driver.”—Autoblog, Nov. 21, 2017

New York distributor.
Empire Petroleum Services, LLC, 6515 Transit Road, Suite 24, Bowmansville, NY 14026, has applied for distributor division membership. Scott Robinson is general manager for the firm, which was established in 2016. The company services and sells  petroleum equipment, including representation of Catlow, Cree, CentralIL, EmcoWheatn, EmproProd, FreedomElec, GasAdvProd, Gilbarco, NOVFGSys, OMNTEC, PMPCorp, PtrCntmt, RedJacket, Riverside, StanwadeMP, SuprCanopy, Universal, VeederR and Xerxes. Sponsored for PEI membership by Evan Reid, Gilbarco, Greensboro, North Carolina.
Georgia canopy manufacturer. MetalWorks, P. O. Box 2009, Oakwood, GA 30566, has applied for affiliate division membership. Ben Houston is president of the firm, which was established in 2003. The company manufactures pre-painted metal and aluminum canopy panels, gutters & trims and panel clips for canopies. Sponsored for PEI membership by Kristy Martinez, JimcoSales, Fort Worth, Texas.
Kansas manufacturer's representative. Impact Solutions Rep Group LLC, P. O. Box 396, Valley Center, KS 67147, has applied for affiliate division membership. Patrick Corcoran is president of the firm, which was established in 2016. The company represents companies that manufacture pumps, filters, and equipment that cleans or stores fuel, oil, DEF and chemicals. Sponsored for PEI membership by Brian Fedro, GPI, Wichita, Kansas.


  • AUTEC, Inc. Statesville, North Carolina (mfr)
  • Rite-Way Environmental Testing & Compliance, LLC, Lufkin, Texas (S&C)
  • Universal Equipment Maintenance Co., Mableton, Georgia (S&C)
  • EnergiSystems, Billings, Montana (S&C)


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© 2017
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. Richard C. Long, Editor. Opinions expressed are the opinions of the Editor. Basic circulation confined to PEI members.