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  Newsletters > December 07

Chapman Engineering
December 2007 Newsletter

TCEQ Rule Changes for LPST-Related Work – Nope, Not Changing!

TCEQ was supposed to be working on a rule change to – slowly but surely – take newer LPST cases out of the “Texas Risk Reduction Program” (TRRP) rule set, and put them back into the Chapter 334 rule set.  This would have saved a lot of money in site assessment and cleanup costs on these newer releases, in our opinion.  But in a HUGE reversal last week, TCEQ has decided that it has the authority to leave LPST work under TRRP!  This is contrary to what the sponsoring legislator wanted to see, and definitely not what various industry organizations were looking for.

From what we hear, it was the way in which the legislation was written that gave TCEQ the ability to leave things as is.  Therefore, we are probably stuck till the next legislative session, in terms of taking LPST work back to the Chapter 334 rules. 

If any of you have had experience with new LPST releases under the TRRP rules, you know that those rules encourage “digging and hauling” to get rid of soil contamination from tank removals.  They encourage a lot of “searching for ground water” and generally involve far more expense in site assessment and reporting.  Pollution liability insurance companies have racked up considerable bills.  Have you seen insurance premium increases attributed to the TRRP rule?

ATG’s, Electronic Line Leak Detectors and Veeder Root® Commentary

At the UST Compliance Seminar last week in Austin, great presentations were given on ATG’s and electronic line leak detection, among other subjects.  ATG’s are the most common tank leak detection process/system used by UST owners and operators.  Veeder Root has a long and interesting discussion at its website of how regulatory changes are being applied to leak detection rules, especially pertaining to how an ATG system is operated, maintained, kept in calibration, and so on.

If you rely on ATG’s or electronic link leak detectors, a TCEQ inspector may ask you to show how you know the system is in calibration, in good working order, etc.  It is a good idea to call your vendor and get periodic inspection visits by them.  The busier your location, the more important this is.  Anton Rozsypal, P. E., the technical support person at TCEQ, is a great resource on this set of subjects – his e-mail is arozsypal@tceq.state.tx.us and we recommend him highly.