This article discusses how Encamp handles Tier II reporting in California, as well as provides an overview of California's Tier II program by answering the following questions:
For RY2022, Encamp is equipped to handle the standard Hazardous Materials Business Plan (HMBP) and Aboveground Petroleum Storage Act (APSA) modules from CERS in the app. The standard HMBP is comprised of the Facility Information (Business Activities, Business Owner/Operator Identification), Hazardous Materials Inventory (Hazardous Material Inventory, Site Map), and Emergency Response and Training Plans. The APSA module collects information about a facility's aboveground oil storage capacities.
If your facility requires other submittal elements not listed above, reach out to your Customer Success Manager and we can assist with completing those for RY2022.
For those with facilities regulated by Certified Unified Program Agencies (CUPA) that require reports to be submitted prior to March 1, those facilities are available now to complete updates to products, contacts, etc. Once the report is submitted in Encamp, we will prioritize submitting those prior to their due date.
What is an HMBP?
A Hazardous Materials Business Plan (HMBP) is a requirement established by the California Environmental Protection Agency (CalEPA) to "prevent or minimize harm to public health and safety and the environment from a release or threatened release of a hazardous material". Although the format of the HMBP looks dissimilar from Tier II reports in other states, submitting a complete HMBP fulfills all of the same federal EPCRA requirements.
HMBPs are submitted through the California Environmental Reporting System (CERS). While the HMBP does collect information about a facility's hazardous materials inventory (similar to other Tier II reports), it additionally collects other information, such as about aboveground storage tanks, underground storage tanks, releases, hazardous wastes, and recyclable materials.
What is a CUPA?
A CUPA (Certified Unified Program Agency) is the equivalent of a Local Emergency Planning Committee (LEPC) in other states. CalEPA functions as the State Emergency Response Commission (SERC) and delegates the responsibility of implementing the HMBP program at the local level to the CUPAs. Much the same as LEPCs, each facility in California is in the jurisdiction of one (and only one) CUPA.
What are the HMBP reporting thresholds?
For the hazardous materials inventory portion of the HMBP, it is important to note that the reporting thresholds are lower than the federal thresholds (and in many other states). The thresholds are as follows:
- 55 gallons or more of a liquid
- 500 pounds or more of a solid
- 200 cubic feet or more of a gas
- For Extremely Hazardous Substances, 500 pounds or the Threshold Planning Quantity, whichever is lower
In California, hazardous wastes at a facility are also required to be included on the HMBP. The hazardous waste reporting threshold at most CUPAs is the same for a standard hazardous material (55 gallons for liquids, 500 pounds for solids).
Are there any other nuances to be aware of?
Moreso than LEPCs in any other state, many CUPAs have their own reporting requirements. This includes (but is not limited to) things like:
- A different reporting deadline than March 1 (the typical Tier II deadline)
- Some CUPAs prefer their facilities to submit their reports by the anniversary of their first HMBP submittal
- Some CUPAs enforce a deadline of December 31 or August 31
- Specific requirements for site maps
- A requirement to include any quantity of hazardous materials
- A requirement to include any quantity of hazardous waste
- Particular requirements about how to submit common materials, such as Lead-Acid Batteries
Encamp is aware of and supports submissions that account for all these nuances. For additional information specific to a facility, reach out to your Customer Success Manager.
Last Modified 10/28/22