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Chapman Engineering
March 2008 Newsletter 

TCEQ Changing How It Picks Places to Inspect

TCEQ is changing how it decides who to inspect and when – if US EPA decides to allow this new approach.  Called the “Risk-Based Investigation System” (RBIS), TCEQ management hopes to use this approach to get inspectors seeing the most important facilities more frequently. 

Similar in philosophy to the “risk-based assessment” approach to site assessment and cleanup, the RBIS idea takes a bunch of attributes about a regulated facility and ranks it.  How much hazard does a facility possibly pose to people, plants and animals around it?  That’s the simplest way to look at this program. 

For PST facilities, we hope most will be ranked pretty low in risk or hazard.  A PST site on a lake, bay, river or the Gulf, or one that sits over the Edwards Aquifer recharge zone might be considered pretty high in risk.  But TCEQ has problems with numbers, more than anything else.  It now has about 225,000 total facilities registered, permitted, or otherwise regulated – for air, water or waste matters.  And it has slightly more than 500 inspectors across the state.  So you quickly get the idea of how hard it is for them to physically get to and inspect every facility.

Complicating matters further, the Federal Energy Act of 2005 makes TCEQ inspect every PST facility every three years.  There are about 29,000 active PST facilities in Texas at this writing, far fewer than the 80,000 active sites that registered back in the 1986 to 1991 time frame.  The agency feels it has a very poor chance of inspecting all the PST sites in a three-year rotation, and is still negotiating with US EPA on how this mandate can be handled. 

Insurance Renewals

Our staff is in the midst of helping many of you catch up on cathodic protection system tests, line leak detector testing, and other requirements that help renew your pollution liability insurance policies.  Many of you are doing an excellent job of dealing with all these records!  Thanks for that diligence.  Tell your friends who need help that we can get them through the process.  We’ve been practicing now for about 19 years . . .

Remember to keep your paperwork together, and teach your staff to refer a regulatory person to your company’s designated expert for this stuff!  We see a lot of confusion caused when the person answering your phone doesn’t know who to “hand off” to.

For questions or to refer a friend to us who needs help, please call Mack Brice or myself at 800-375-7747.  The best for you this spring and THANKS, as always, for your business!

-Cal Chapman