Quick Guide to Compliance
HAZARDOUS MATERIALS BUSINESS PLAN PROGRAM
I NEED TO SUBMIT A HAZARDOUS MATERIALS BUSINESS PLAN (HMBP)
You may use either of the e-reporting systems below. Please visit the sites for additional information and instructions.
I NEED TO FIX MY SITE MAP
A template map can be found here. Alternately, you can design your own map, but it must include ALL of the following features: North orientation, loading areas, internal roads, adjacent streets, storm and sewer drains, access and exit points, emergency shutoffs, evacuation staging areas, hazardous material/waste handling, and storage areas, and emergency response equipment (Ex. first aid kit, fire extinguisher, spill kit, and fire control equipment). If anything on this list does not apply to your facility, please make a note in the map’s margin, such as “no storm drains located on the property.” The map must also include a legend describing any symbols used on the map.
I NEED TO NOTIFY MY PROPERTY OWNER
A template letter can be found here: HMBP Property Owner Notification Letter. Complete the letter and mail or e-mail a copy to your property owner. Keep a copy for your records and send a copy to your inspector.
I NEED TO CERTIFY MY HAZARDOUS MATERIALS BUSINESS PLAN
If you have an account in CERS (California Electronic Reporting System), you must log on to the system and certify your Business Plan.
- Select “Start/Edit Submittal”
- If there are no changes, select “Create All HMBP Submittal Elements.” If you need to make changes, select the element that needs updating, and make the necessary changes. Be sure to submit all elements of the Business Plan to have a compliant submission.
- Select “Submit Selected Elements”
If you require additional assistance, you may contact firstname.lastname@example.org for a business training PowerPoint.
If you have an account on the San Mateo County Portal, you must log on to the system and certify your Business Plan.
- Select the “HMBP” link under “Annual Certification.”
- A summary of your HMBP will be displayed. At the bottom, you can select “submit with no changes” or you can select “amend prior to submission.” If there are no changes, select “submit with no changes. If you need to update any portion of the plan, select “amend prior to submission.” If you need assistance amending your submission, please review the portal instructions.
I NEED TO TRAIN MY EMPLOYEES AND/OR PROVIDE DOCUMENTATION
At a minimum, you must review the contents of the HMBP with your employees, particularly the chemical hazard and emergency response portions. This training must be documented and the documentation kept for three years. A template form for this training record is provided: Training – Record for HMBP.
HAZARDOUS WASTE GENERATOR PROGRAM
I NEED TO APPLY FOR A NEW EPA ID NUMBER
Complete the DTSC application to obtain an EPA ID number.
MY EPA ID NUMBER IS INACTIVE
I NEED TO LABEL MY HAZARDOUS WASTE CONTAINERS
A hazardous waste container must mark with the following information: name and address of the generator, accumulation start date, the words, “Hazardous Waste”, composition, physical state, and hazardous properties of the waste. The label must always be visible. A template is provided here.
I NEED TO DISPOSE OF MY HAZARDOUS WASTE
- For businesses that generate less than 27 gallons of hazardous waste per month, visit the County’s Very Small Quantity Generator Program. Self transportation is allowed.
- For any business that generates hazardous waste, find a list of registered waste haulers.
- For used oil, visit CalRecycle’s Certified Collection Centers.
- For latex or oil-based paint, visit paintcare.org.
- For disposal of universal waste (I.e. fluorescent bulbs, small batteries, etc.): smchealth.org/fluorescentlights.
I NEED TO POST EMERGENCY INFORMATION
Complete this form and post it by the phone or by the hazardous waste storage area at your facility.
I NEED TO PROVIDE HAZARDOUS WASTE TRAINING FOR MY EMPLOYEES
- For Small Quantity Generators: employees must be familiar with hazardous waste requirements and emergency response procedures. Free training classes available.
- You will have to provide emergency response training in house. Training Documentation Form.
- For Large Quantity Generators: business must have a training plan and provide additional information on the training document, including the employee’s title and job description: Training Documentation Form.
- Basics of hazardous waste video.
If you need additional assistance, you can hire an environmental consultant or an outside vendor who can provide you with training.
I NEED A TANK ASSESSMENT
Large Quantity Generators that have a tank system used to accumulate hazardous waste need to contact a Professional Engineer to conduct an assessment of the tank prior to installation and every five years thereafter. In addition, the facility needs to conduct a daily documented inspection. Hazardous Waste Tank Management Guidance.
Tanks that hold used antifreeze or used oil can receive a three-year exemption if they meet the exemption requirements. The exemption needs to be approved by the CUPA and the Fire Agency. Facilities must use this form.
UNDERGROUND STORAGE TANK PROGRAM
I NEED TO FIX MY TANK PAGE OR MONITORING PLAN
I NEED TO SUBMIT AN UPDATED DESIGNATED OPERATOR FORM
I NEED TO SUBMIT AN OWNER STATEMENT OF UNDERSTANDING AND COMPLIANCE
HOW DO I CORRECTLY COMPLETE THE OWNER’S PORTION OF THE DESIGNATED OPERATOR (DO) MONTHLY REPORT?
Complete guidance can be found here, however, the key piece is that the owner must sign each DO report and indicate all corrective actions taken. The DO inspections must occur every 30 days, and it is the responsibility of the UST owner/operator to ensure this is done.
WHEN MUST I TEST MY UST OVERFILL SYSTEM AGAIN?
Regardless of when the overfill system was initially tested, it must be retested by October 13, 2021.
The water board provided a guidance document about overfill here: Overfill guidance document.
ABOVEGROUND STORAGE TANK PROGRAM
HOW DO I COMPLETE AN SPCC PLAN?
If you have a petroleum storage capacity of 10,000 gallons or less, and the largest container is 5,000 gallons or less, you can self-certify using this Template for Tier I facilities (EPA). Be sure to complete all applicable sections. Alternately, you can have a Professional Engineer certified plan.
If you have a petroleum storage capacity of 10,000 gallons or less, and the largest container is greater than 5,000 gallons, you can self-certify using the Tier II Template from CAL-CUPA. Be sure to complete all applicable sections. Alternately, you can have a Professional Engineer certified plan.
If you have a petroleum storage capacity greater than 10,000 gallons, you must have a Professional Engineer (PE) certify your plan. Contact your inspector if you need assistance finding a PE.
SPCC plans must be reviewed every 5 years or if there are significant changes to storage volume or containers/tanks.
I NEED TO DO SPCC TANK AND CONTAINER INSPECTIONS
The APSA Template for Tier I facilities provides information about minimum tank inspection requirements on page 17 and a sample log on page 16. This template can be used for any SPCC facility type. A more in-depth inspection checklist, SP001, is also available here- Monthly / Annual Inspection record for tanks (EPA, SP001).
If you have a tank in an underground area (TIUGA), you can use this form.
Keep records of inspection for 3 years
I NEED TO DOCUMENT TRAINING OR ANNUAL BRIEFINGS
Training for newly hired oil-handling employees must cover:
- Operation and maintenance of equipment to prevent discharges;
- discharge procedure protocols;
- applicable pollution control laws, rules, and regulations;
- general facility operations; and,
Annual Briefings assure adequate understanding by including a review of past reportable discharges or failures, malfunctioning components, and any recently developed precautionary measures.
The template also has a page to document this. Template for Tier I facilities, P.19, attachment 3.4.
If you prefer to combine this training with annual HMBP training, you can record it on the HMBP training log, but you must provide a description of the training topics covered on the form Training – Record for HMBP . Log this on the pages mentioned above if you use a Tier I or Tier II SPCC plan.
I NEED TO DOCUMENT A 5 YEAR REVIEW OF MY SPCC OR MAKE CHANGES
The 5-year review log is used to document when the plan was reviewed (and amended if applicable). A review must be documented every 5 years, at minimum.
The technical amendments log can and must be updated att any time to include amendments to the plan. The amendments must be added within 6 months of a change at the facility and must be implemented no later than 6 months from the amendment date.
CALIFORNIA ACCIDENTAL RELEASE PROGRAM
I NEED TO SUBMIT AN RISK MANAGEMENT PLAN (RMP)
Who does this apply to?
An owner or operator of a business that has more than a threshold quantity of a regulated substance (listed in Tables 1-3, Title 19 § 2770.5) in a process may need to submit an RMP.
What is required as part of this plan?
- Permit registration (form here) and submission of the RMP
- 45-day public comment period on RMP
- Proper storage and handling of regulated substances
- Training staff
- Operating and maintaining process equipment
- Hazard Review
- Emergency response to an accidental release