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TASTP/TCEQ Q & A

October 11, 2005

Q. 1) November 1, 2005 is the deadline for UL971 pipe. It is our understanding that there are two fiberglass and one flexible pipe manufacture approved at this time and there may not be anymore approved until next year. We have approved projects where the pipe quoted and purchased is not UL971 approved. Due to delays in the beginning with obtaining city and county permits some of the equipment (FRP Tanks) will not arrive before the November 1, 2005 deadline. The flexible pipe, fittings and other materials have already been purchased at considerable expense. What will be the TCEQ guidelines for the November 1, 2005 deadline. Will a customer that has already sent in a construction notification form and received a return start date letter still be allowed to install the purchased pipe after the November 1, 2005 deadline or will the customer have to purchase different pipe. He will not be able to return any of the pipe because every distributor in Texas is trying to clear their stock of non-UL971 pipe. It would be a major financial loss to not be able to return the existing pipe and then have to purchase more pipe. What is going to be the deciding factor?

A. 1) If the project has been approved to start and the tank excavation has started prior to November 1, 2005 - the old pipe will be allowed to be installed. Any project that starts after November 1, 2005 will have to install pipe compliant with the new UL-971.

Q.2) Please clarify an issue that was raised several months ago. Does a technician have to hold an A license to install, service, calibrate or repair any part of an ATG system?

A.2) An A type license is required to install an ATG system but not to service, calibrate or repair.

Q.3) Getting reimbursed for PSH recovery during groundwater monitoring is time consuming and difficult at times. Several times when field personnel conducting groundwater monitoring on sites that have PSH, the site is between PSH removal CARFs or PSH has been observed at the site for the first time. Field personnel often get the following responses from the PST coordinators while on-site 1) PSH recovery is verbally approved, please send an e-mail as record of the verbal approval and submit a work plan for PSH recovery. 2) If PSH recovery wasn't requested in the original Groundwater Monitoring work plan and cost proposal, it's not reimburseable but do it anyway. Questions) 1. Can the TCEQ implement a policy that states if PSH is present during groundwater monitoring, field personnel are automatically authorized to bail it w/ out calling the corrdinator on-site? 2. Can the policy include the automatic approval of reimbursement if PSH recovery is conducted during groundwater monitoring or assessment activities and will be reimbursed under the on-going PSH removal CARF or the Groundwater Monitoring/Assessment CARF if no PSH Removal CARF is in progress?

Q.4) Often when submitting a Groundwater Monitoring workplan and cost proposal to include PSH recovery it is not approved in the CARF and the RCAS spends non-reimbursable time contacting the Coordinator to bring it to there attention and get the CARF amended with the correct cost. We often hear that it is difficult for the coordinator to make any formatting changes to the pre-approval sheet. Questions) 1. Can anything be done so that the coordinator can make the changes in the preapproval sheet without having to re-invent the wheel, so to speak? 2. This appears to have been a problem for some time. What can be done to address this issue?

Q.5) The MDPE CARF pre-approval worksheets are very misleading and much non-reimbursable time is spent sorting the approved costs out. When an RCAS questioned two different reimbursement coordinators on the subject of Office/Field Personnel costs and Report Preparation costs, the RCAS got two different responses. One reimbursement coordinator said the RCAS gets the Office/Field Personnel and Report Preparation costs. The other reimbursement coordinator said the RCAS and MDPE personnel splits the Office/Field Personnel costs but the MDPE Personnel gets the entire Report Preparation costs. One RCAS has not been requesting reimbursement on recent MDPE Report Preparation costs because the CARF pre-approval worksheet showed the MDPE personnel got the Report Preparation costs. Questions) 1. Who gets the Office/Field personnel and Report Preparation costs? 2. Shouldn't all the Office/Field personnel and Report Preparation costs fall under the RCAS? 3. Shouldn't all the costs related to the subcontractor fall under the MDPE Personnel and Equipment? 4. If it's a matter of a new format as suggested by one PST Coordinator, Which format is it? See Examples5. If it's a matter of a new format, When was the new format introduced? 6. If it's a matter of a new format, Can the RCAS apply for reimbursement of costs that were not requested based on the old format?