TASTP/TCEQ Q & A

August 11, 2009

Q. 1) Will the TCEQ be issuing guidelines for hydrostatically testing dispenser sumps, submersible sumps and double wall piping for installation and three year testing?

A. 1) No, there are no plans to issue new guidelines.  The Chapter 334 rules will remain the same.

Q. 2) Dispenser sumps and submersible sumps by design hold quite a few gallons of water.  The test at startup will not require water disposal because the sumps and the piping interstitial will not contain hydrocarbons.  However, after the first test on a new site and the hydrostatic testing for sites already in operation will require the disposal of hundreds of gallons of water.  Based on the fact that there is a recognized need to conserve water, has the agency considered other alternatives to hydrostatic testing for these facilities in an effort to reduce the need for the large quantities of water and also the significant cost associated with the testing.  Suggestions might be that many sites have a high and measurable water table and if they do, filling the sumps with water might result in a passing test when in fact all that has happened is that the water on the inside of the sump and the water on the outside of the sump are at equilibrium?

A. 2) Contamination can be minimized if clean water is used and the volume of water can be minimized if you add to the water as needed.

Q. 3) Has consideration been given to requiring that the interstitial piping be pressure tested rather than hydrostatically tested to minimize the potential impact on current sites that have flex piping and the impact of causing the interstitial to receive hydrocarbon residue from the dispenser sumps and further potentially damage the piping?

A. 3) Make sure the sump is clean before putting the test water in the sump.  Testing remains the same in accordance with current rules.

Q. 4) What is the TCEQ’s position on sump leak repair? If the sump leaks at a bulkhead fitting can repair kits be used for the repair or does the sump need to be removed and replaced with a new one?

A. 4) Repairs are allowed.  You do not have to replace the sump.

Q. 5) Is there certain equipment that has been installed (sumps or piping) that the TCEQ is considering that may need to be replaced in order to comply with the New Regulations on existing sites?

A. 5) The TCEQ stated that no retroactive application is required.

Q. 6) Is Stage 1 Vapor Recovery soon to be required in all areas of Texas at stations & Bulk facilities (underground and aboveground)?

A. 6) Stage I is already required by federal rule.

Q. 7) Is TCEQ going to regulate diesel exhaust fluid (DEF) storage and dispensing equipment and will it be required to be available at all locations that sell diesel?

A. 7) The TCEQ does not have any plans at this time.  The DEF supplies will be market driven and will be available is various quantities, primarily in small containers.  The storage of DEF is not intended for underground storage tanks.

Q. 8) What is the latest regarding operator training?

A. 8) The TCEQ plans to introduce rule making in February 2010.  TASTP will be a stakeholder in the rule making process.