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TASTP/TCEQ Q & A

April 13 , 2010

Q. 1) Has Texas decided to request or enforce CFR 40 Part 63 testing? During the last TCEQ seminar, Texas and EPA had not come to any agreement as to who the test should be filed with. EPA is requiring, but doesn’t want the test...TCEQ wasn’t interested in the testing and didn’t want same. How does the RP comply?

A. 1) TCEQ suggested that the testing records should be kept on site with the delivery manifest. This is an EPA requirement, but they have not specified reporting instructions.

Q. 2) Is the TCEQ going to hire contractors to inspect UST locations?

A. 2) The TCEQ is currently utilizing contracted inspectors in Region 4. The statewide bids will be going out soon.

Q. 3) What is the latest on Operator Training?

A. 3) The TCEQ is evaluating several options.  A public hearing is scheduled for April 27, 2010 at 1:30 p.m. in Room E-201S in Building E at the TCEQ complex.

Q. 4) Are the rules going to be opened up soon, for new or updated changes?

Q. 5) How is the DEF (Diesel Exhaust Fluid) program going? Any reactions?

A. 5) The TCEQ will not regulate DEF.

Q. 6) Is the TCEQ now requiring that pressure lines with electronic line leak detectors be precision tested annually?

A. 6) No more than they ever have.

Q. 7) Are there any requirements that a tank tightness test shall be conducted at least once every 5 years for any tank in a UST system?

A. 7) No, unless your insurance company requires it.

Q. 8) Are there any TCEQ requirements for testing the operability of an ATG system to verify the probes, sensors, overfill alarms, etc. are working? Rule 334.50 mentions “maintained in accordance with the manufacture” but Veeder-Root Operability Testing Guide Manual #577013-814 states that periodic operability testing is not required if the Federal, State, and/or Local regulations do not require the testing.

A. 8) There is a requirements to make sure that it is working properly.

Q. 9) TCEQ personnel told an audience at a recent TCEQ seminar that painting the tank number on the concrete next to the manhole cover is not acceptable per 334.8(c)(5)(C). The description is “legible tag, label, or marking”. If this is true, the term marking is misleading. What is the TCEQ position on this?

A. 9) It is okay to paint on the concrete.

Q. 10) We recently removed 3 tanks from an existing site. The tanks were numbered Tank 1, Tank 2, and Tank 3. We installed 2 new tanks at the same site. The new registration form was sent to the TCEQ with the new tanks labeled as Tank 1 unleaded, Tank 2A super, and Tank 2B diesel. The TCEQ Registration personnel would not allow the new tanks to have any of the old tanks numbers (1,2,3). They made the client number the new tanks, Tank 4 unleaded, Tank 5A super and Tank 5B diesel. This is confusing because there are a number of sites where the new tanks are registered using the same numbering system as the old tanks were numbered. Also, 334.8(c)(5)(C) states that the identification numbers must begin with the number 1 and must proceed sequentially without skipping numbers and compartment tanks will be labeled with letters.

A. 10) Yes, this requirement has been in the rules for 10 years. Repetition of numbers is not allowed.