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TASTP/TCEQ Q & AFebruary 12, 2008Q. 1) What is the latest status regarding the new Federal rules? A. 1) The two most significant issues are being addressed in the proposed changes to PST rules in 30 TAC, Chapter 334. The TCEQ will propose secondary containment rather than financial assurance which will mean double wall piping and tanks or some other agency accepted alternative. The other issue involves operator training. The TCEQ proposes to recognize training as proposed by standards organizations (i.e. PEI, API, etc.). The TCEQ will require training records to be kept for inspection review. Q. 2) What is the status of Chapter 334 Rule changes? A. 2) The anticipated timeline for the rule changes are as follows: Q. 3) Are there any technical changes in the Chapter 334 Rule package? A. 3) Yes. Since the TCEQ did not provide any proposed changes in writing at the Stakeholder Meeting, please review the rule changes as will be published in the Texas Register on May 2, 2008. Q. 4) What is the status regarding Field Operations issuing Field Citations? A. 4)A representative from the field operations division was not available to answer this question. This question will be repeated at the next meeting on April 8, 2008. Q. 5) What is TCEQ’s policy if a UST owner registers his tanks under another persons name? A. 5) The TCEQ stated that it was illegal and a request for investigation should be forwarded to the PST/Dry Cleaner Registration Team of the Permitting and Remediation Support Division. The TCEQ requested as much documentation as can be provided with the request. Q. 6) How will the new occupational Licensing Rules affect training providers and Leaking Petroleum Storage Tank Correction Action Specialists and Project Managers? A. 6) Staff from the Operating Licensing Section was not available and this question will be presented at the next meeting on April 8, 2008. Q. 7) EPA has informally indicated that “wide spread use” of ORVR will not occur until 90% of all the gasoline sold in ozone non-attainment areas is dispensed into vehicles equipped with onboard vapor recovery. EPA estimates that Stage II Vapor Recovery could be completely replaced by ORVR by the year 2011. ORVR has been standard equipment on cars since 2000. Since the state will have to request an amendment to their SIP to prove to the EPA that the 90% widespread use standard has been met, has the TCEQ developed a strategy for this determination? A. 7) The TCEQ stated that wide spread use had been a question and their modelers were estimating the timeframe of 2020-2022. They have not developed a strategy as of this date. Q. 8) We recently had to replace a defective and leaking stainless steel flex connector on a product line inside a STP containment sump. We informed the owner that they needed to have the line precision tested after the repair. Their testing company told them it was not necessary to test the line because the line was inside the containment sump and could be visually inspected for any leaks. Is this correct? A. 8) Yes, it is necessary to test the whole line. Q. 9) Is there a TCEQ minimum percent volume required for a passed periodic test (0.2 GPH) on an automatic tank gauge (ATG)? The ATG manufacturer states that the value tells the system the minimum tank volume required to record a passed periodic test and the value reflects federal, state, and local requirements. A. 9) Yes, there is a minimum required and it is reflected on the 3rd Party Certification. Q. 10) Does the TCEQ or any of its out-sourced inspection agencies inspect any gasoline AST for the required vapor recovery and if so, do they request a copy of the executive order for the vapor recovery system installed? A. 10)Staff from the Chief Engineers Office was not available and this question will be presented at the next meeting on April 8, 2008.
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