TASTP/TCEQ Q & A

June 9 , 2009

Q. 1) The Commission will be considering at the June 3 meeting, amendments to tank testing rules before degassing operation of tanks are started.  Will or do these changes effect our industry for tank (ust & ast) removal?  Does the TAC 115.542 apply to our industry?

A. 1) Yes, but it looked like it had been pulled or maybe moved down.  The rules do apply to our industry, but only in the Stage II areas.

Q. 2) Will there be Category II cleanup standards for MTBE, as there are for BTEX constituents?

A. 2) Yes. The value is 0.36 for both category I and category II.

Q. 3) If a site has a single wall tank and is not using an ATG and still using stick readings to reconcile inventory control and they are performing at a .1 gallon per hour test annually, are they compliant?  Or do they need to be using SIR?

A. 3) No, they are not compliant. They can use any release detection method allowed by rule.

Q. 4) What is the status of ICC in assisting the TCEQ with developing the tests for facility operators?

A. 4) The agency is communicating with ICC, TPCA and API.  The TCEQ has to have a plan by August 8, 2009 and all operators must be trained by August 8, 2012.

Q. 5)Did the Legislature pass any bills affecting the PST Program?

A. 5) Yes.  The appropriation bill has language that will allow the agencies FTE cap to be exceeded.  PSTR money would be available for third party contractors.

Q. 6) How are proctored sites chosen for the CBT Program?  Who makes the decision of CBT locations?

A. 6)A representative from the training area of the TCEQ was not presented.  Wanda Curio was given as the contact.

Q. 7) Has the TCEQ made any plans towards Diesel Emission Fluids.

A. 7) No, not at this time.

Q. 8) A TCEQ response was received indicating that theoretical vapor calculations had been calculated for a site, resulting in a request for a field vapor survey.  Can the formula for this calculation be provided?  Are there other site specific parameters (other than site specific concentrations), or is this run using all defaults?

A. 8) See page 16 of RG-36.

Q. 9) When is it anticipated that a revised RG-411 will come out?

A. 9) The draft is available and is going to publication within approximately 30–60 days.

Q. 10) Will Category II cleanup numbers be issued for MTBE?

A. 10) Yes, they have those established.

Q. 11) Will MTBE have delineation requirements now?

A. 11) The TCEQ is following current policies and the delineation will be receptor driven.

Q. 12) With the transition back to 334, are TRRP quality laboratory analytical reports unnecessary?

A. 12) The quality of data is still considered important.  The new RG-411 will reference quality data on page 34.

Q. 13)Low flow sampling was recommended at TRRP sites.  Can 334 sites revert back to bailing 3 well volumes?

A. 13) Low flow will still be recommended.