california special: ensuring compliance for epa’s current regulations
DESCRIPTION
California Special: Ensuring Compliance for EPA’s Current Regulations Tank Management and CERSTRANSCRIPT
California Special: Ensuring Compliance for EPA’s Current
Regulations
Tank Management and CERS
July 25, 2013
Moderator
Brian TorrezAlliance Marketing Manager
(303) 228-2387
Presenter
Jennifer BlakeKPA Northwest District Manager
(510) 493-7492
If you have questions during the presentation, please submit them using the “Questions” feature
Questions will be answered at the end of the webinar
QUESTIONSQuestions
California Special: Ensuring Compliance for EPA’s Current
Regulations
Tank Management and CERS
July 25, 2013
Webinar Highlights
• History of Used Oil• Board of Equalization vs. Local Regulators• Small Quantity Generators vs. Large Quantity
Generators• Navigating Title 22 Requirements• Tank Management• Accurate CUPA and State Reporting• California’s Electronic Reporting System
Let’s Talk about Used Oil
1960s: Oil as Disposable Liquid2013: Oil as a Commodity
Used Oil in the 90s
• 10 Years of Large Oils Spills• Frenzied legislation• Used Oil Management Regulations Redefined• Generator status at the time
• Refineries - Large Quantity Generators• Auto Dealers – Small Quantity Generators
More on Generator Status
• Small Quantity Generators 1,000 kilograms• 119 gallons or 1.1 tons
• Annual Board of Equalization Fee• Used oil is not counted
• Annual CUPA Fee• Stance on used oil not standard
• Guidance from your regulator• Relaxed approach to this subject• If it’s recycled should it count as a waste?
Large Quantity Generator Status (LQG)
Department of Toxic Substances Control (DTSC)• Firm stance that used oil is considered and
managed as hazardous waste • Even if it is recycled
• Recycled used oil is counted into your generator status.
• 1,000 gallons used oil = 8,345 kilograms• LGQ < 1,000 kilograms
http://www.dtsc.ca.gov/hazardouswaste/automotive/index.cfm
LQG Requirements
• Correct reporting • Documented daily hazardous waste
inspections• Used oil and waste antifreeze tanks
• Employee training• SPCC Plans• Tanks Integrity Testing
• PE Stamped mathematical report determining probability of tank failure.
Hazardous Waste Tank Management
• Tank venting and anchoring• 360o View• Secondary Containment
• Oil in the interstitial space
• Monitoring and Alarms• Housekeeping
• Spill Absorbent
• Daily inspections• Work Plans
Where do we start?
CUPAs • Local Enforcement Arm of the DTSC • Spreading this message• Mentioned in Notice of Corrections and Violations
• 30 Days to comply• Accepting work plans
• Accurate reporting is the 1st Step• Hazardous Materials Business Plan• Electronic through CERS• Auditing your generator status requirements remotely
Include your KPA representative in the process!
– KPA CONFIDENTIAL –
Accurate Reporting for 2013
• AB 2289: All CA dealerships must file their annual hazardous materials business plan or HMBP electronically in 2013.
• California Electronic Reporting System (CERS) • CUPA have been promoting CERS and their portals• Businesses are not required to use portals after
January 1, 2013
• Annual or specific due dates for submittals
http://cers.calepa.ca.gov/
Navigating the CERS Website
• Several ways to access your CERS Plan– Accept invite from KPA Rep – Create a login and search for existing plan– CUPA designated access
• Every facility address has a designated CERS ID #• Review all electronic plan elements• Certify Owner Operator page
– Name and date of certification
• Submit all electronic plan elements• Plan is then sent to regulatory agency for review• Annual CUPA Fee generated
KPA CERS Support
Jennifer BlakeNW District Manager(510) [email protected]
MJ ZappeField Office Manager (510) [email protected]
Tabatha PerrinsCERS Database Intern (510) [email protected]
Include your KPA representative in the process.
Executive Summary
1. The state has refocused on Large Quantity Generators and are
including auto dealers into these categories.
2. Hazardous waste tank management is important. Talk with you KPA
representative to ensure program requirements are being achieved.
3. Tank integrity testing is an important part of large quantity generator
compliance.
4. Dealers must submit their Hazardous Materials Business Plan via
CERS before COB December 31st, 2013 (or sooner).
5. Start your CERS process by creating your login and utilize your
engineer and our support staff through submittal process.
6. KPA, is here to help with our unique onsite and online approach for
CNCDA dealers.
Contact Us
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Jennifer BlakeKPA Northwest District Manager
(510) 493-7492
Brian TorrezAlliance Marketing Manager
(303) 228-2387