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January 20, 2021 | Vol. 71, No. 2

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In This Issue
Dear PEI Member:

The U.S. Environmental Protection Agency (EPA) has opened a 90-day comment period on a proposed rulemaking to modify or eliminate E15 dispenser labels and loosen underground storage tank (UST) system compatibility requirements.

Background. Because biobased fuels such as ethanol can be more degrading to UST components than petroleum, the 2015 federal UST regulations set special compatibility and recordkeeping requirements for systems storing fuel containing more than 10% ethanol or 20% biodiesel. However, other EPA actions have encouraged and facilitated the sale of E15:

  • 2010: Approval of E15 for 2007 and newer light-duty vehicles.
  • 2011: Approval of E15 for 2001-2006 light-duty vehicles.
  • 2019: Authorization of the nationwide, year-round sale of E15.

EPA describes its new rulemaking as another move that would “provide additional opportunity for E15 within the fuels marketplace.”

E15 Labels. Today’s orange-and-black E15 dispenser label serves two purposes. First, to identify the vehicles for which E15 is approved. Second, to warn consumers against using the fuel in non-approved vehicles, boats and gasoline-powered equipment. The rulemaking proposes two possible changes for E15 labels:

EPA Launches E15, UST Compatibility Rulemaking

Fueling-Related Fires at Gas Stations Rare

U.S. C-Store Count Falls

UID Registration Opens

PEI Membership, Staff Updates





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The first option would modify the current label by:

  • Removing the “Attention” stripe.
  • Replacing “E15” with “contains up to 15% ethanol.”
  • Changing “Use only in” to “Safe for use in” when referencing E15-approved vehicles.
  • Changing “Don’t use in” to “Avoid use in” when referencing non-E15-approved uses.
  • Removing the bold and italic formatting from the word “Prohibited.”
  • Changing the orange-and-black color scheme to a softer blue, white and black.

The second option would eliminate the EPA-required E15 dispenser label. EPA’s stated goal for this option is to “encourage the use of E15 by consumers who can lawfully use E15 but who do not do so because they are confused by the label.”

If the EPA-required label is eliminated, the EPA also seeks comments on whether state and local governments could require their own E15 dispenser labels.

Compatibility Requirements. The new rulemaking includes three proposals to help owners and operators meet today’s E15 compatibility requirements and pave the way for even higher ethanol blends in the future:

  1. Secondary Containment. Owners and operators would not be required to demonstrate compatibility of existing UST systems that (a) have secondarily contained tanks and piping and (b) use interstitial monitoring.

    Because this requirement would protect only against leaks inside a UST system’s secondary containment, the EPA will encourage (but not require) owners and operators to replace other components for which they cannot demonstrate compatibility if the equipment is accessible from ground level and replaceable with “minimal investment.”

  2. Already Compatible Tanks and Piping. Owners and operators also would not be required to demonstrate compatibility for:
    • Steel and fiberglass tanks manufactured after July 2005;
    • Fiberglass reinforced plastic (FRP) piping.
  3. New UST Installations and Replacements. Owners and operators storing over-the-road vehicle fuel would have to ensure that all new UST systems or replaced UST components (including pipe dopes and sealants) installed after the effective date of the rule are compatible with ethanol blends up to 100%.

    This would include UST systems and components storing diesel fuel for over-the-road vehicles. The proposed rule explains that this is necessary because the UST owner or operator could repurpose the system to store gasoline with higher ethanol blends in the future. USTs storing fuel for emergency power generators and other off-road uses (e.g., construction equipment) would not be covered by this rule.

The proposals would take effect one year after the final regulation’s effective date. However, states with State Program Approval (SPA) status would have three years from the effective date to submit a revised SPA plan that meets the new requirements.

In a conversation with PEI staff hours before the rulemaking launched, EPA OUST stressed how important PEI member input will be to this rulemaking process. For more information on how to submit comments, click here. EPA also will schedule a public hearing on the proposal.

New National Fire Protection Association (NFPA) research shows that refueling is rarely the cause of fires at vehicle fueling facilities. Key findings from the Service or Gas Station Fires report include:

  • From 2014 to 2018, local fire departments responded to an average of 4,150 gas station fires each year.
  • Cumulatively, gas station fires caused an average of $30 million in property damage per year.
  • Vehicles accounted for 56% of the gas station fires. However, 75% of the vehicle fires were caused by mechanical issues, electrical failures or other vehicle malfunctions.
  • Of the 20% of vehicle fires attributable to gasoline ignition, only 2% involved the fuel tank or vehicle fuel line. Another 3% started on the vehicle’s exterior.
  • Electrical distribution and lighting (21%) and cooking (19%) were the top two causes of site structure fires. Only 4% of structure fires began with gasoline ignition.

The number of U.S. convenience stores fell 1.6% in 2020, with the biggest declines among single-store businesses (down 3.1%), according to the most recent NACS/Nielsen Convenience Industry Store Count. Of the 150,274 stores operating in December 2020, 121,538 (80.9%) sold motor fuels, a 0.4% drop from 2019.

Registration for the 2021 University of Innovative Distribution (UID), is now open. The 2021 conference, which will be held virtually March 15-17, includes 24 live sessions in six tracks (Distribution Strategy, Leadership/Professional Development, Management, Marketing, Operations and Sales).

PEI is offering a $100 scholarship to the first 30 members who choose the $525 all-access registration option. Registrants may also select a single-day pass for $175.

For additional information on UID and instructions for claiming your $100 scholarship, see our website. Because courses may sell out early, PEI encourages interested members to register soon.

2021 NACS Show Booth Selection. PEI Priority Club booth selections for the 2021 NACS Show (Oct. 5-8 in Chicago) will be Feb. 8-10. Other exhibitors will be able to select their booths shortly thereafter. For additional information, contact Julie Shank at
PEI Membership Survey. PEI emailed the 2021 Membership Survey to member company official representatives on Jan. 13. Survey data helps the PEI staff and board of directors evaluate our current offerings and plan future products and services. If you have not yet completed your survey, please do so by Wednesday, Jan. 27.
RP100-20esp Exam. The online exam for PEI/RP100esp: Prácticas Recomendadas para la Instalación de Sistemas de Almacenamiento Subterráneo de Líquidos is now available in Spanish. Learn more about RP100esp and the accompanying exam here.
Recommended Practice Topics Sought. Jan. 31 is the deadline to submit suggestions for future PEI technical documents. (See Jan. 7, 2021 TulsaLetter.) To suggest a topic, email Scott Boorse by Jan. 31 with your proposed title’s purpose, scope and audience.
Staff Promotions. PEI is delighted to announce two recent staff promotions:

  • Teresa Farmer is the association’s new membership director. Farmer joined PEI in 2012 and has served as PEI’s membership manager since December 2017.
  • Julie Shank was promoted to director of marketing and events. Shank has been PEI’s marketing and events manager since August 2019.

Editor’s Note: Teresa and Julie, thanks for all you do for your colleagues, for PEI’s members and for me. Congratulations on these well-deserved promotions!

Robert Moffit
, longtime sales manager at Memphis-based The Southern Co., died Jan. 15. Survivors include: Moffit’s wife of 35 years, Tracey; sons Andrew (Kathleen) and Robert Jr. (Clare); grandson, Wesley; mother, Ann Moffit; sister, Ann Tutor; and brother Donald (Cindy).

Virginia service company.
Total Fuel Management Services Inc., 20099 Ashbrook Place, Suite 170, Ashburn, VA 20147, applied for service and construction division membership. Alexander Marcus is president of the company, which was established in 1994. Total Fuel Management Services Inc. provides fuel testing, analysis, reporting and field services, as well as filtration and fuel supply system equipment maintenance. Sponsored for PEI membership by Walt Cunningham, C.R.C. Industries, Waldorf, Maryland.

Mexican distributor. PetroCalibrations SA de CV, Ave. Alfonso Reyes 1672, Monterrey 64280 Mexico, applied for distributor division membership. Carlos Lebrac Gonzalez V. is commercial director for the firm, which was established in 2012. PetroCalibrations SA de CV distributes petroleum equipment, including metering and pump packages. Sponsored for PEI membership by Shawn Kiefer, Total Control Systems, Fort Wayne, Indiana.

Tennessee installation company. JPS Services LLC, 6016 S. Main St., Lobelville, TN 37097, applied for service and construction division membership. Michael Coblentz is manager/partner for the company, which was established in 1994. JPS Services LLC performs service, installation and general contractor services. Sponsored for PEI membership by Thomas Brown, National Petroleum Equipment, Attalla, Alabama.

Texas service provider. HD Retail Repair, 729 Third Ave., Dallas, TX 75226, applied for service and construction division membership. Nia Khepera is director of the firm, which was established in 2017. HD Retail Repair installs, repairs and removes USTs and petroleum storage tank waste water. Sponsored for PEI membership by Kelly Crellin, Brugg Pipesystems, Rome, Georgia.


  • Crowne Industries Ltd., Streamwood, Illinois (service and construction)
  • Katerina Lambrou, Hellenic Petroleum Cyprus, Nicosia, Cyprus (operations and engineering)
  • William McKown, Robinson Oil Corporation, Gilroy, California (operations and engineering)
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The TulsaLetter 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.