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Chapman Engineering
May 2008 Newsletter 

 TCEQ Rule Changes to Chapter 334

TCEQ has a deadline for comments on rule changes proposed to 30 TAC Chapter 334 of June 3, 2008.  That’s a week away, give or take.  The major changes we see are these:

• §334.42 (i) addresses general standards which apply to existing systems, BUT it more specifically addresses liquid tight aspects of sumps, dispenser sumps, manways, overspill containers, or catchment basins.  TCEQ wants to see “tightness testing” of spill protection buckets, sumps around sub pumps, and sumps under dispensers when they are installed.  Also, these sumps must be kept free of liquids and debris.  This could become an inspection violation quite easily;
• The language proposed for §334.45(E)(i) says new tanks must be “double-wall construction” according to draft rule language.  This does not allow a tank owner and installer to use a tank pit and pipe chase liner, at lower cost, as an adequate method of “secondary containment” construction.  We’d like to see the rules allow lined excavations, with the proper safeguarding against rain and flood water getting in and “floating tanks” out of the hold;
• The same section says “accepted alternative” might be used.  But there’s no explanation of what those may be.  US EPA and TCEQ need to state what they consider as reasonable alternatives, since so many tank installation practice and leak detection improvements have come into the marketplace over the last 20 years;
• Proposed language in section §334.45(E)(vii) requires that “liquids in sumps or manways must be removed and properly disposed of within 48 hours of alert or discovery”.  The existing language tells you to “promptly remove” or something similar.  This is an ongoing and painful set of inspection and maintenance exercises; pay attention to these sumps, which means OPEN THEM FREQUENTLY to inspect and document what you find.  If tanker drivers regularly leave you a full spill bucket, make them change their habits!

These rule changes didn’t seem that bad several months ago.  But as the detail emerges, it’s clear that you have to pay attention to some impacts that will come into your business.  Please call your association representatives, and send written comments to the TCEQ.  Hit their website and find the right places to send to – it’s in your interest!

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

Cal Chapman, P. E.