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October 22, 2019 | Vol. 69, No. 20

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In This Issue
Dear PEI Member:

PEI has released a new edition of RP1200: Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities. The revised RP1200-19 adds detailed low liquid level containment sump testing procedures to Chapter 6: Spill Bucket and Containment Sump Testing.

The 2015 federal underground storage tank (UST) regulations require testing of containment sumps used for interstitial monitoring at least once every three years. The U.S. Environmental Protection Agency (EPA) accepts the hydrostatic testing method in Section 6.5 of RP1200 as sufficient to meet this requirement. For that test, the owner or operator must fill the sump with water to a depth of at least 4 inches above the sump's highest penetration or sidewall seam.

In June 2018, the EPA issued guidance on a low liquid level sump test method that also would be sufficient to meet its sump testing requirements. The new Section 6.6 in RP1200-19 provides recommended practices for such tests, including:

  • General information on the purpose and limitations of low liquid level sump tests
  • Test requirements
  • Required test equipment
  • Seven test preparation steps
  • Twelve test procedures for electronic and stand-alone sump sensors
  • Seven test procedures for under dispenser containment (UDC) mechanical float devices
  • Pass/fail criteria

RP1200-19 also includes a new Appendix C-4-A containing a checklist to help owners and operators complete the Section 6.6 low liquid level test.

PEI thanks the members of the PEI Overfill, Release Detection and Release Prevention Equipment Testing Committee for their work on this important revision:

RP1200 Adds Low-Level Sump Test

EPA UST System Database

PEI Opens Public Comments on Aviation Fueling Systems RP

EPA Announces Supplemental RFS Rulemaking

NAW Protests Government Procurement Favoring Amazon




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  • Edward S. Kubinsky, Jr., Crompco LLC, chairman
  • Danny Brevard, Accent Environmental Services Inc.
  • Jim Brown, Belshire Environmental Services Inc.
  • Todd Darrough, QuikTrip
  • Brian Derge, Tanknology Inc.
  • Bruce Garrett, Volta Oil Co.
  • Ryan Haerer, U.S. EPA
  • Brian Harmon, Tait Environmental Services Inc.
  • Kevin Henderson, Kevin Henderson Consulting LLC
  • Jim Howard, Speedway LLC
  • Ron Kingsbury, UST Services Corp.
  • Brian Weigert, R&A Risk Professionals

PEI members may purchase RP1200-19 for $50 (nonmembers, $195).

The EPA is developing a national database on USTs, leaking USTs and UST facilities. The data will help states and other stakeholders identify facilities that may be prone to flooding, assess the resulting risk and prioritize cleanup efforts.

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) hosted an Oct. 10 webinar to explain the new resource to state regulators. A recording of the one-hour webinar is available here. The EPA will make the database publicly available at a later date.

The EPA announced a supplemental notice of proposed rulemaking on required renewable fuel volumes for 2020. (See July 23, 2019, TL.)

The supplemental proposal would base the volume of gasoline and diesel exempt from the Renewable Fuel Standard (RFS) on a three-year average of Department of Energy (DOE) recommendations. EPA will hold an Oct. 30 public hearing on the supplemental proposed rulemaking. Comments are due by Nov. 29.

PEI is seeking comments on RP1300: Recommended Practices for the Design, Installation, Service, Repair and Maintenance of Aviation Fueling Systems.

Most recently revised in 2013, RP1300 provides recommendations to promote the proper design, construction and safe operation of aviation fueling systems; minimize the possibility of fueling system failure; avoid unnecessary costs; and minimize environmental impacts and hazards. The recommended practices are limited to aircraft fueling systems at aviation fuel provider facilities. They do not cover hydrant systems or ground equipment fueling systems.

To submit suggestions for improving RP1300, visit and click the “Comment Now” button. Comments must be submitted by Wednesday, Nov. 20 to be considered for the next edition.

The National Association of Wholesaler-Distributors (NAW) asked the Department of Justice (DOJ) and the Federal Trade Commission (FTC) to investigate a General Services Administration (GSA) proposal that could give Amazon exclusive access to more than $50 billion in government contracts.

The National Defense Authorization Act (NDAA) directs the GSA to establish a program to help federal agencies procure commercial-off-the-shelf products (COTS) through e-commerce portals. An Oct. 1 GSA request for proposal contains specifications and requirements that can be met only by Amazon, thereby excluding other e-commerce providers from this lucrative market. In Oct. 17 letters to the DOJ and FTC, NAW stressed the importance of fostering competition and ensuring other e-commerce providers have an opportunity to compete in this process. For additional details, see NAW’s summary of the issue.

NAW is composed of distribution companies and line-of-trade associations, including PEI, that represent the $6.1 trillion wholesale distribution industry.

Minnesota Gov. Tim Walz and South Dakota Gov. Kristi Noem, chair and vice chair of the Governors Biofuels Coalition, respectively, wrote President Trump on Oct. 4 to request four executive actions to boost ethanol and other biofuels:

  • Replace toxic gasoline aromatics with ethanol.
  • Give ethanol blends up to E30 the same Reid Vapor Pressure (RVP) summertime waiver that makes year-round sales of E10 and E15 possible.
  • Update EPA emissions studies to show the environmental benefits of ethanol.
  • Resume review and approval of cellulosic ethanol production applications.

The Governors Biofuels Coalition includes 22 states that seek to provide regional and national leadership on ethanol policy.

Ford Motor Co. is expanding charging solutions for its electric vehicles (EVs), including the recently announced "Mustang-inspired" crossover vehicle.

In partnership with Amazon, Ford will install home charging stations able to fully charge a vehicle overnight. Every Ford EV also will come with a mobile charger that can be used in a 240-volt or 120-volt outlet.

In addition, partnerships with Electrify America and other charging networks will give Ford customers access to 12,000 charging stations across the U.S. The FordPass app also will allow drivers to find nearby charging stations and identify locations such as restaurants and stores where drivers can wait while their vehicles charge.

Eurotank Service Group Ltd.
appointed Phillip Brodie group sales manager. Brodie’s career includes experience with both petroleum equipment manufacturers and end users.
Hockman-Lewis Ltd.
named Ravi Kumar Ramamurthy regional sales director-MEA. Ramamurthy has extensive technical and sales experience in the petroleum station equipment industry.
Northeast Petroleum Technologies named Mike Crandall general manager. In his new role, Crandall will oversee operations of the company’s corporate office in Schenectady, New York and branch office in Utica, New York. Crandall will also continue as sales manager.
Matrix Capital Markets Group Inc. advised The Hartley Co., d/b/a Starfire, (Hartley) on the sale of its convenience retailing, petroleum marketing and fuel distribution assets to Ohio-based Campbell Oil Co., d/b/a BellStores.
added Petro Service Ltd, of Saint John, New Brunswick, to its list of distributors. Petro Service will sell and service Washworld vehicle wash systems in Canada.

Louisiana distributor.
Moreau Services LLC, 452 Destrehan Ave., Harvey, LA 70058, applied for distributor division membership. Quincy Moreau is member manager for the company, which was established in 2010. Moreau Services distributes petroleum equipment and performs service and construction work. Sponsored for PEI membership by Louis Theriot, LeBlanc & Theriot Equipment Co. Inc., Metairie, Louisiana.

California service provider. DDS Environmental Inc., 127 E. Arrow Highway, San Dimas, CA 91773, applied for service and construction division membership. Douglas LaCount is president of the company, which was established in June 2018. DDS Environmental provides UST system construction and performs testing for lines, leak detection, automatic tank gauges, sumps, spill buckets and Stage I and II vapor recovery. Sponsored for PEI membership by Martin Hunt, Environmental Laboratories Inc. Travelers Rest, South Carolina.

Florida payment company. Sounds Payments, 12425 28th St. N., St. Petersburg, FL 33716, applied for manufacturer division membership. Ashlye Schlegel is sales/account executive for the firm, which was established in 2016. Sound Payments is a technology company that creates innovative solutions in the payments and financial services industries. Sound Payments sells its products through distributors. Sponsored for PEI membership by Mike Vegeais, Freedom Electronics LLC, Kennesaw, Georgia.

Illinois manufacturer. International Drying Corp., 2510 Route 176, Suite G, Prairie Grove, IL 60014, applied for manufacturer division membership. Arthur Stephens is the owner of the company, which was established in 2001. International Drying Corp. manufactures dryer systems for car washes. The company’s products are sold through distributors. Sponsored for PEI membership by Edward O’Hanrahan Jr., Coleman Hanna Carwash Systems, Largo, Florida.

Maryland service company. Dark Horse Enterprises Inc., 917 Beales Trail, Pasadena, MD 21122, applied for service and construction division membership. Justin Fortney is owner of the firm, which was established in 2014. Dark Horse Enterprises provides aboveground and underground petroleum services including installation, removal, upgrades and compliance.  Sponsored for PEI membership by Tom Dion, Wildco PES, Manchester, New Hampshire.

Maryland service company. Optimal Tank Solutions, 610 Maybrook Drive, Huntingtown, MD 20639, applied for service and construction division membership. Matthew Vaughan is president of the firm, which was established in September 2018. Optimal Tank Solutions performs installation, service and removal of UST, aboveground storage tank (AST) and emergency generator fueling systems. Sponsored for PEI membership by Galen C. Heaps, Petro Supply Inc., Elkridge, Maryland.

Texas service provider. Relevant Fuel Solutions, 20120 E. Hardy Road, Houston, TX 77073, applied for service and construction division membership. Derek DeShaw is global sales director for the company, which was established in 2015. Relevant Fuel Solutions provides fuel and tank quality management programs, products and services, as well as tank cleaning, fuel polishing and permanent polishing solutions. Sponsored for PEI membership by Ron Sickels, Advanced Fuel Services Inc., Gilroy, California.

Texas service and installation provider. LoneStar Fueling, 1550 Katy Gap Road, Unit 110, Katy, TX 77494, applied for service and construction division membership. David Igartua is the owner of the company, which was established in February 2018. LoneStar Fueling offers c-store fueling installation and services. Sponsored for PEI membership by Richard Long, RDM Industrial Electronics Inc., Nebo, North Carolina.


  • Michael Deneff, Schrader Oil Co., Fort Collins, Colorado (operations and engineering)

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© 2019
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.