California Environmental Reporting System (CERS)

Question: How does a UPA ensure that the CERS generated Report 6 provides current, accurate information?

Answer:Much of the data reported in the CERS UST reports is based on ‘Accepted’ submittals.  If a submittal has not been reviewed (status = ‘submitted’), or its’ status has been set to ‘under review’ or ‘not accepted’ the results will not be included in these reports.  This was intentional to ensure that the data from the reports is based on UPA-validated data.  The following will assist UPAs in evaluating the UST related data in CERS and will identify actions to take to resolve inconsistencies.  Once completed, as long as the UPA maintains the data as described below the UST reports in CERS should be valid for the Water Board, US EPA and your own use.

Developing an accurate Report 6 in CERS for the first time

Step 1: Run Report 6 twice, once without a date range and once with the desired date range.  Set the date range to match Report 6 required window (January 1 through June 30 or July 1 through December 31).  Comparing these two versions will highlight changes that occurred during the selected date range.  

• Check the box ‘Include Breakdown Detail’ to view CERS IDs included in the Report 6 summary.

Later you can compare this data with the results from the Facility/Tank Data Download report.

Select the ‘Breakdown Detail’ tab at the bottom of the report to display the details:

Step 2: Verify the number of UST Facilities in Report 6 is correct

• CERS Report 6 facility count includes only facilities where the UST Reporting requirement is set = ‘Applicable’ or ‘Always Applicable’ as of the date the report is run.
• Note: For sites where all tanks have been closed during a reporting period do not set the UST Reporting requirement = ‘Not Applicable’ until after the reporting period deadline has passed (March 1 or September 1).   Explanation: Tank closure counts will be reported correctly but these facilities will still be included as active UST facilities so your report to State Water Board will need to advise of the discrepancy in active facility counts. If the UST Reporting requirement is set = ‘Not Applicable’ before the reporting deadline the facility and tanks will not be included in the report.
• Facilities with UST Reporting requirement = ‘Applicable’ or ‘Always Applicable’ but without an accepted UST submittal will be reported in CERS Report 6 with 0 tanks.
• Exception: Tanks without an installation date will not be included in any report run with a date range.  If install date is unknown require facility to report 1/1/1900 in a submittal that can be accepted or accepted with conditions.
• Tank closure counts are based on reported closures in accepted submittals where the closure date occurred during the reporting period and the submittal was accepted or accepted with conditions as of the date the report is run.
• Compare facility and tank counts in CERS UST Facility / Tank Data Download Report. If there are discrepancies investigate and resolve as needed. Note that the UST Facility / Tank Data Download Report includes tank data from accepted submittals regardless of the UST Reporting requirement setting.

• If the search results total number matches the correct number of UST facilities in your jurisdiction you can move on to step 3. If not, you need to identify which facilities are causing the inconsistency. Follow these steps:
  • Run a UST Facility/Tank Data Download report from the Reports section with no date range. Click on the button ‘Export to Excel (details)‘ to get a complete list of UST sites.
    
    
    
    
    
    
  • Compare the table with the list of CERS IDs in the Breakdown detail of Report 6 to find the facilities that are not on both tables. Investigate to determine the reason for the inconsistency for each facility and take appropriate action. These tables must match with few exceptions and must include all known UST sites in your jurisdiction before going to the next step.  Exception: Sites where all tanks have been permanently closed or removed will be listed in the UST Facility/Tank Data Download, provided there is at least one ‘accepted’ UST submittal, but they will not be in Report 6 if the UST submittal element has been set to ‘not applicable’. Report this as an anomaly on your Report 6 or in the email certification if you are reporting using the paperless process.   Note: this inconsistency should be corrected in CERS 4.

Step 3: Verify the number of underground tank systems in columns B through H

• Once the number of UST facilities in CERS is correct, the number of tank systems listed in Report 6 should be consistent with the number reported in the UST Facility/Tank Data Download report and with your internal records. Staff familiar with the UST sites should review to ensure that UST facilities properly reported each UST. Note that for compartmented tanks, each compartment must be reported as a separate UST. Any inaccuracies should be reported to the business along with a request for an updated UST submittal. Temporarily closed USTs are not included in the count of active UST systems.
• CERS counts of Petroleum and Hazardous Substance systems are based on the ‘Tank Contents’ field visible in the UST Facility/Tank Data Download report.
  • There are 13 tank contents choices in the dropdown menu for this field. Only two, Used Oil and Other Non-Petroleum are hazardous substances. All others are petroleum. ‘Tank Use’ field data is not included in determining the tank counts in Report 6.
• Make sure all USTs have a valid date in the “Date UST System Installed” box on the UST Tank Information page (field #435). CERS uses this date to calculate the number of active USTs and new UST systems installed in the Report 6.
• Make sure that all permanently closed tanks have a closure date and the correct tank type of action (permanently closed in place or removed).

Step 4: Verifying all Red Tags are entered in CERS

• Run a Red Tag Facility Details report. If all known Red Tags are not listed in this report you will need to enter them in the Compliance section of CERS under Enforcement. Note that the Red Tag report only lists the facility, not which tank(s) is red-tagged. To identify specific tank(s) use the comment field in the Create Enforcement or Edit Enforcement screens. This comment field is displayed as field 925 in the UST CME Download Report referenced in step 5 above. Further details are provided in the ‘How to Enter Red Tag Information FAQ’.


Maintaining an accurate Report 6 and other UST related data in CERS

Once you have established an accurate base of UST related information in CERS maintenance is straightforward. The following outlines the steps to maintaining the UST data so that your agency meets reporting requirements and the Water Board and US EPA can access your agency’s UST data directly in CERS.

Step 5: Require timely UST facility submittals

• CERS Facilities are required to provide notice within 30 days of a significant change in their HMBP. A UST tank removal or installation is a significant change so any facility installing or removing a UST should make submittals to CERS within that timeframe to update both the HMBP and UST submittal elements. Sites where all USTs have been closed or removed and non UST sites that install a new UST can be included in CERS reports based on these submittals. 
  • It may be difficult to get sites that have closed and are no longer regulated to report one last submittal to CERS confirming all tanks have been permanently closed or removed. If the facility does not make such a submittal, CUPAs with Tiers 5 and 6 EDT services can make a proxy submittal that includes the tank closure information. CUPAs and PAs that do not have these EDT services can add themselves to the business organization as a lead user to make a submittal that includes the tank closure information. In both instances, a comment should be added to the additional description field clarifying the reason for the submittal by the UPA.

• Similarly, maintaining the number of UST systems is contingent upon timely submittals from UST facilities.  The count of active and closed USTs in Report 6 is based on UST accepted submittals with installation dates and reporting closures (with closure dates) during the previous reporting period. 
• For routine business reporting tracking, you can run a ‘Facilities Reporting Status’ Report in the Reports section of CERS and select the Export to Excel (Details). It will give you a list of all your regulated facilities as well as the last submittal, last accepted submittal and last inspection for each program element.

Step 6: Provide timely review and ‘acceptance’ of UST submittals

• UST submittals must be reviewed and accepted or accepted with conditions before the data will be included in many of the UST reports, including Report 6 and the UST Facility / Tank Data Download report. When reviewing UST submittals verify that the number of tanks and compartments is reported correctly, that the business has not created a new CERS Tank ID for existing tanks, and that all tanks have an install date and all closed tanks have a closure date. Verify there is at least one financial responsibility mechanism.

Step 7: Provide timely reporting of UST CME data. The TRC determination is automated through the use of the violation library. Certain violations in CERS will directly change the TRC count for that routine inspection. 

Step 8: Periodic CERS Report validation

• Periodically perform steps 1 through 6 to verify that the data in CERS is current and correct.