California Environmental Reporting System (CERS)
General Reporting Requirements for UST Sites? (September 11, 2015)
What are the general reporting requirements for Underground Storage Tank (UST) Sites? Does every field have to be completed? (Revised 9/11/2015)
Answer: California Health and Safety Code chapter 6.11 requires that all Unified Program related information be reported electronically. Regulated facilities may report to the California Electronic Reporting System, CERS, or to a local reporting portal, if one is provided by the CUPA. There is a recent exception, CalEPA Unified Program Guidance Letter 14-08. Refer to the UST FAQ Updated: Which UST Forms Must Be Uploaded for more information.
CERS is divided into eleven submittal elements. Facilities with USTs are required to annually report the following submittal elements. Due dates are set by the CUPA. If the CUPA does not set a due date the default date is March 1.
- Facility Information. This includes the Business Activities questionnaire and Business Owner/Operator subsections. (This submittal element must always be submitted with all other submittal elements)
- Hazardous Materials Inventory. This includes both the hazardous materials inventory and a site map showing where hazardous materials are stored.
- Emergency Response Plan and Employee Training Plan.
CERS is divided into eleven submittal elements. Facilities with USTs are required to annually report the following submittal elements. Due dates are set by the CUPA. If the CUPA does not set a due date the default date is March 1.
- Facility Information. This includes the Business Activities questionnaire and Business Owner/Operator subsections. (This submittal element must always be submitted with all other submittal elements)
- Hazardous Materials Inventory. This includes both the hazardous materials inventory and a site map showing where hazardous materials are stored.
- Emergency Response Plan and Employee Training Plan.
- Additional submittal elements may be required if the facility generates hazardous waste.
Annual electronic reporting will be easier after the first complete submission because you can choose to begin a new electronic reporting cycle based on a previous submittal. In this process, CERS replicates your previous submittal, allows you to review, edit as needed and then submit. Since many regulated businesses have few if any changes from year to year, the annual submission process for many will be quick. Regulated businesses may also choose to start a new submittal process from scratch.
Even though CERS allows a submission to be made when some fields are left blank, all information on the CERS data entry screens is required when applicable. Data entry fields in CERS are defined in the California Code of Regulations Title 27 Data Dictionary and are listed in the CERS Data Registry. Submittals with incomplete information may be rejected by the CUPA or Participating Agency (PA) if the latter is the local agency implementing the UST program in their jurisdiction.
The State Water Resources Control Board has been clear that all appropriate UST related fields must be properly completed. A CUPA or PA should reject a submittal if it is incomplete. In some cases, a CUPA or PA may choose to accept a submittal with minor errors with a condition that it be corrected and resubmitted within a specific timeframe and not later than the next annual compliance inspection, depending on the quality of the submittal and other factors. A UPA may change the submittal status at any time from ‘accepted’ to ‘not accepted’. CERS provides automated email notices to the regulated business when a submittal status is changed.
However, not all data entry fields are applicable for all situations. Unless otherwise indicated in CERS, there is no requirement for a business to fill in fields that are not applicable. Information bubbles as shown in the screen shots below are intended to help businesses provide necessary information. For example, fields 440a and 440b specifically apply only when ‘other petroleum’ or ‘other non‐petroleum’ is selected in field 440. Field 406 is only applicable to public agencies. Similarly, field 438 is intended to be used only when the CUPA or PA requests that you provide additional tank or location information is a particular UST, i.e., to identify something unusual. It was not intended as a required field for all USTs.
- Field 445 is an example where direction is provided to the business to enter something even though this field is not applicable for single walled USTs.
- Field 406:
- Field 438
- Field 445:
Please note that the examples in this FAQ may not be a complete list of fields that are not applicable for your facility.
Other UST related FAQs are posted at CERS Help / Training.