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LG 162-2 3 - 4. Has the definition of " pipe" changed for USTs installed on or after July 1 , 2003? Yes . Vent piping , vapor recovery piping , and fill pipes that are beneath the surface of the ground and installed in conjunction with a UST system on or after July 1 , 2003 are regulated "pipe" and are subject to secondary containment requirements . [H &S Code , §25290 . 20) .] 5. Are the piping exemptions provided in H &S Code, Section 25281 .5(a) (4) and ( b)( 1 ) , and the secondary containment exemptions in Section 2636 (a) , Title 23 , CCR applicable to USTs installed on or after July 1 , 2003? No . The piping exemptions provided in H &S Code , Section 25281 . 5 (a) (4) and (b) ( 1 ) , are not applicable for UST systems installed on or after July 1 , 2003 . [H &S Code , §25290 . 20 ) .] Additionally , the secondary containment exemptions (for vent and tank riser piping , vapor recovery piping , and safe suction piping) in Section 2636 (a) , Title 23 , CCR are not applicable for USTs installed on or after July 1 , 2003 . There are no exemptions from the secondary containment requirement for USTs installed on or after July 1 , 2003 , 6 . What type of post-installation testing is required for USTs installed on or after July 1 , 2003, and when should the testing be completed ? The UST must be tested after installation , and before it is placed into use , using one of the following three test methods : ( 1 ) enhanced leak detection ( ELD) , (2) an inert gas pressure test certified by a third-party and approved by the State Water Board , or (3) a test method deemed equivalent to ELD and approved by the State Water Board in regulation . [H &S Code , §25290 . 2(i) .] As of the date of this letter, three tests have been determined to meet the ELD performance criteria and are allowable for post-installation testing : Vendor Test Method Praxair Services , Inc. Enhanced Tracer Tight° iota° VaporTite - V005 and CGRS , Inc. Enhanced Tracer Tight® Leak Detection Technologies , Inc MD Leak The three ELD test methods can be used when there is no fuel in the system . The Enhanced Tracer Tight® test and the MD Leak test may also be conducted with fuel in the UST. To conduct either test with fuel , the owner or operator should first obtain approval from the local agency to have fuel delivered to the UST. Prior to approving a fuel delivery , the local agency may need to verify that all pertinent installation requirements have been met. A UST system should not be put into service until the facility has been issued a valid operating permit by the local agency. California Environmental Protection Agency CO Recycled Paper