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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° CGRS, Inc. iota° VaporTite - V005 and 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 Zai Recycled Paper