California Environmental Reporting System (CERS)

Question: Why are my UPA UST facility and/or tank counts inconsistent with reports from CERS?

Answer: The following may help explain why a UST related report from CERS may not exactly match an UPA’s internal records or even other CERS reports in terms of regulated UST facility and tank counts. This FAQ also provides guidance to use reports for comparisons to identify and resolve inconsistencies between reports.

Run reports without a date range to ensure the most complete facility and tank counts for CERS Report 6 and CERS UST Facility Tank Data Download report as well as almost all other reports. If the data appears correct it is much more likely that reports run with a date range will also be correct subject to the exceptions noted below. And if not correct or consistent, it is relatively easy to determine why not.

Facility Search

Facility Search using Submittal Element = ‘Facility Information’ and Reporting Requirement = ‘All Statuses’ and no date range with results = ‘Export to Excel (Details)’

• This export will list all facilities in a jurisdiction regulated under any submittal element. A review will show which facilities previously indicated Yes or No to the UST question, whether the reporting requirement has been set = Applicable/Always Applicable or Not Applicable, if the facility has made a UST submittal, has an accepted UST submittal and if they have had a UST inspection.
• Delete all fields but these six fields:
• Use this table to identify any potential inconsistencies. Active UST facilities should have the following:
  • OwnorOperateUST = Y
  • USTReportingRequirement = Applicable
  • An accepted UST submittal and a UST inspection
• Any facilities not having the above should be investigated to determine if the facility is or isn’t a UST regulated facility and whether or not it should be.

  Note: This export may show reported UST inspections at facilities that were never a UST facility. These inspections should be changed or deleted.

• The total number of facilities where the UST Reporting Requirement is = Applicable will be equal to total number of facilities listed in the CERS Report 6.

CERS Report 6

• Lists all facilities where the UST Reporting Requirement = Applicable.
  • This setting is initially triggered by the Business Activities UST Question = Yes or No but the UPA can control this setting by setting the UST Reporting Requirement to be either Applicable or Always Applicable or Not Applicable. By controlling this setting the UPA controls the number of regulated UST facilities reported in CERS and therefore the number reported in CERS Report 6.
• Lists all active tanks where the UST Reporting Requirement = Applicable and based on the last accepted (including accepted with conditions) submittal.
  • If the UST Reporting Requirement = applicable but there is no accepted submittal the facility will be in CERS Report 6 but the tank count will = 0.
    
  • Note that when the UST Reporting Requirement is set = Not Applicable the facility will no longer be included in CERS Report 6.  Therefore, tank closures from a permanent facility closure will not be counted in the next Report 6 if the facility reporting requirement is set = 'Not Applicable'. If the reporting requirement is not changed to 'Not Applicable' until after the next semiannual reporting is due, the CERS Report 6 will include that facility as a regulated UST facility with 0 tanks and the UPA would need to explain that their CERS Report 6 has one too many UST regulated facilities. CalEPA and SWRCB are considering ways to address this anomaly in Report 6.

CERS UST Facility Tank Data Download

(based on default option: Accepted Submittals Only)

• Lists all facilities where there is an accepted UST submittal (regardless of the reporting requirement applicability).
  
• Lists all tank records, active and closed from all accepted UST submittals. This report will show duplicate tanks and closed tanks not reported as closed from previous accepted submittals.
  • Field 404 from the facility overview tab lists the number of active tanks reported only in the most recent accepted submittal. This number may not equal all active tanks if there are duplicates or other tanks that were not included in the most recent accepted submittal.

Petroleum versus Hazardous Substance Tanks

Determining the number of petroleum product tanks vs the number of hazardous substance tanks is based solely on the Tank Contents (Field 440). Effective April 2, 2019 only two types of contents, #7, Used Oil and #11, Other Non Petroleum count as tanks containing hazardous substances. All other types of tank contents are counted as tanks containing Petroleum.

Prior to 4/2/2019 tanks containing Ethanol (pure) were considered as hazardous substance tanks but this material has been dropped as a tank content type. Tanks containing pure ethanol are to be reported as #11 Other Non Petroleum contents. Tanks containing gasoline/ethanol blends are to be reported using one of the appropriate petroleum fueling content options.

Date Range

Tanks in CERS that do not have an install date will not be included in any report run with a date range because CERS doesn't know if the tank is in or out of the date range.

UPAs should require that all USTs have an install date. If the facility does not know the install date for an existing tank(s) require that they report 1/1/1900 as the install date.

Sequential Acceptance of Submittals

If there are multiple pending submittals for a facility that have not yet been accepted by the UPA, it is very important to always accept submittals in order of oldest to most recent submitted. For example, Report 6 tank count is based on the most recent accepted submittal. If you accept an older submittal with 4 active tanks after the most recent submittal that lists 2 active and 2 closed tanks CERS Report 6 would incorrectly report 4 active tanks, not 2 active and 2 closed.

Creating UST facilities before there are regulated tanks

• FAQ Reporting Requirements for Repairs or New USTs is posted on the CERS Central website that addresses this. Note in that FAQ that requiring a UST submittal as part of the installation process should be as a condition for authorizing the introduction of hazardous materials, not as a condition to obtaining the permit to construct/install. If you require a business to report a tank in CERS prior to its’ being regulated your tank counts will be incorrect in CERS.
  
• Setting the UST reporting requirement = Applicable causes the facility to be included in CERS as a regulated UST facility even if there are no tanks in the ground.
  

If you find that your internal records are inconsistent with what is reported in CERS and not because of any of the above, please contact Dan Firth at daniel.firth@waterboards.ca.gov with the CERS ID of the facility(s).