The Wise Report

The Wise Report

Henry M. Wise, P.G.

October 11, 2008

The TCEQ has released the TRRP guidance document RG-366/TRRP-10 Selecting Target Chemicals of Concern.  It can be found at http://www.tceq.state.tx.us/comm_exec/forms_pubs/pubs/rg/rg-366_trrp_10.html  

TRRP-10 answers the question “What chemicals must I analyze for when doing a TRRP assessment?” Those chemicals are the focus of the document and are called “target chemicals of concern (COCs).”   Rather than providing expansive lists of chemicals, the document describes a logical process consisting of 8 steps:

1. Evaluate permit, order or program requirements.  If these are very specific, the process can stop here.

2. Evaluate project objectives.  A site in VCP must consider all releases; a tank closure can focus on the contents of the tank.

3. Collect information.  Look for relevant information on current and past operations.

4. Review the information using professional judgment.  Look for data gaps.

5. Select options when information is “insufficient.”  Fill data gaps with several options.

6. Designate target COCs.  Make the call based on the preceding steps.

7. Conduct the assessment.  If additional COCs are found, repeat the process.

8. Document and report results.  Describe in the APAR the basis for the target COC list.

TRRP-10 handles several other subjects in appendices:
 

A.  References where some of the information for Step 3 can be found;

B.  How to handle daughter and companion chemicals; and

C.  Treatment of tentatively identified compounds.

Please contact Paul Lewis at 512-239-2341 if you have any questions

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Athough I didn't see it in the Texas Register, the TCEQ has evidently adopted rulemaking that extends the Petroleum Storage Tank reimbursement program (and related remediation and reimbursement deadlines) for eligible leaking petroleum storage tank (LPST) sites; eliminate annual registration fees for underground and aboveground storage tanks; address financial assurance requirements for underground storage tanks (USTs); incorporate UST Secondary Containment requirements for new UST systems in Federal law (The Energy Policy Act of 2005); amend certain technical standards for UST systems related to Federal requirements; and remove LPST sites from Texas Risk Reduction Program (TRRP) requirements and place them in the RBCA rules once again.  This new rule is to take effect on October 30, 2008.  For more information go to: http://www.tceq.state.tx.us/rules/adopt.html

Henry M. Wise, P.G.

The Wise Report

10/11/2008