2018 CUPA Conference. February 7, Presented by a panel of CUPA and CalEPA representatives

Transcription

1 2018 CUPA Conference February 7, 2018 Presented by a panel of CUPA and CalEPA representatives

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3 WHO CAN REVIEW UST SUBMITTALS? ICC UST Inspector Certification required to review and accept ICC not required to set status as under review or mark not accepted in unreviewed backlog See Regulator UST FAQ: Is ICC Certification Required for Submittal Review? Has additional info and regulatory citations for the requirement

4 MINIMALLY REQUIRED FIELDS (MRFs) MRF = minimum fields required for business to make a submittal Applies to field functional forms Problem: Allows businesses to make an incomplete submittal without all of the required information Serves as a starting point MRF identified in presentation How Businesses Use CERS See CalCUPA website for W-N2, Class at 10 a.m. today Inspectors job is to ensure all applicable fields are completed Read Business UST FAQ: General Reporting Requirements for UST Sites

5 TIPS TO IMPROVE YOUR REVIEWING SKILLS 1. Go to CERS Business Training Module and pretend you are a business making an UST submittal 2. Read the UST FAQS on both the Business and Regulator sides of CERS 3. Attend a data mining class 4. Run the submittal processing tool on resubmittals

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7 UST ELEMENTS EXAMPLE May not be required We will go through each submittal element Screenshots provided are only for point of reference

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9 UST FACILITY OPERATING PERMIT Regulators can verify the BOE number at a.ca.gov/boewebserv ices/verification_res ults.jsp If Permit Holder is not the tank operator be sure to look for an Own/Op agreement Check that type of FR matches Cert of FR OK if all NO if nonpetroleum

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11 COMMON ERRORS Tank ID# Do not accept changed Tank ID #!!!!!! (changes coming) See presentation on CalCUPA website for Resolving Duplicate USTs in CERS Has step by step instructions to remove duplicate USTs in CERS

12 COMMON ERRORS FOR CLOSURE Type of Action marked wrong Chose UST Permanent Closure on Site or Removal Date UST Permanently Closed missing Use Additional Description to explain duplicate USTs

13 COMMON ERRORS Date UST Installed Tank Contents click on the field help button UST FAQ How to report tank contents Fill Components Installed All must mark Spill Bucket and Striker Plate Tank Use If MVF you must complete UDC info Do not mark No Dispenser

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15 Marked no for straight drop exempted used oil risers COMMON ERRORS Wrong Model #s Tank Gauging is marked when it is not done Manifolded piping has one LLD for 2 USTs If you mark no for manifolded piping where LLD is in other turbine, be sure to explain in Other Pipeline Monitoring

16 COMMMON ERRORS YES: If flow is stopped at the individual dispensers regardless of whether or not the turbine is active Example: Bravo shallow UDCs with mechanical valves that close shear valve or dispenser power is shut off at dispenser not turbine) NO: If flow is not stopped at the individual dispensers (i.e. the turbine is shutdown). Example: turbine shut off with Veeder Root 208 sensor in deep fiberglass UDC

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18 Fields in CERS do not align with former Form C OLD FORM C EQUIVALENT IN CERS

19 UST CERTIFICATIONS OF INSTALLATION/MODIFICATION Many pre 2013 UST installs/modifications are missing this Form in CERS. Acceptable if UST was installed or modified before 2013/2014 Not acceptable if UST was installed or modified after 2013/2014 Oct. 27, CalEPA UP Guidance Letter says submit using CERS data entry screens Business may upload old Form C under Misc. State Required Documents voluntarily

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21 UST MONITORING SITE PLAN ID where monitoring is performed 23 CCR 2632(d)(1)(C) ID sensor not sump Show UST, piping, auxiliary equipment relative to landmarks Piping problem 23 CCR 2711(a)(8) says on permit application SFS relies on blue prints submitted during permit/plan check for piping location

22 NOT ACCEPTED ACCEPTED Missing Sump monitoring Annular sensors UDC monitoring Monitoring panel NOT TO SCALE

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24 COMMON ERRORS Mechanism Type does not match Facility Info Form Blanks Coverage Period expired Facility Address wrong Signature of Witness missing

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26 UST RESPONSE PLAN Common errors: Not using form and missing required info (spill reporting) Sections III & V This space is for equipment not on site but available Not checking a box for Monitoring Indicators

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28 OWNER/OPERATOR AGREEMENT See HSC (a)(3) What does one write as comment if exempt? operator is both the tank owner and the permit holder

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30 LETTER FROM CHIEF FINANCIAL OFFICER Only applicable if: UST is subject to UST Financial Responsibility Letter from the CFO is the chosen FR mechanism Most popular option Must use prescribed language in 23 CCR (c)(1) Signature required by CFO or owner or operator 150 days after the close of each subsequent fiscal year

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32 OWNER STATEMENT OF UST DESIGNATED OPERATOR COMPLIANCE State form not required but you must identify who your Designated Operator(s) is(are) State DO Form d_operators.shtml Unidocs DO Form

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34 MISC. STATE REQUIRED DOCUMENTS Optional uses include but not limited to uploading: Monitor Certifications Spill Bucket Tests Integrity Tests ELD Lining Certifications Old Form C

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36 REVIEW IS COMPLETE Options Not accepted Be very specific why Improve your chance for a response by also ing the comments directly to the submitter Accepted Data is correct and complete Accepted (with conditions in comments) Allows for non-intensive, completeness review (MRF) Read Two Regulator UST FAQs Setting Accepted Submittal Status (dated 1/28/15) When Can a UST Operating Permit be Issued? (4/13/15) Beware of Evaluation deficiencies Check with management

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