CUPA

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Certified Unified Program Agency (CUPA) The Unified Program is state law that consolidates six environmental permit programs under the authority of one local Certified Unified Program Agency (CUPA). In Union City, the Environmental Programs Division is the CUPA. A part of the Economic & Community Development Department, Environmental Programs was certified by the California Environmental Protection Agency in 2011, taking over from the Fire Department.

The CUPA inspects and issues permits to facilities that: handle or store hazardous materials; generate or treat hazardous waste; own or operate underground storage tanks; have aboveground petroleum storage in excess of 1,320 gallons; and, store chemicals in excess of Threshold Reporting Quantity (TPQ) subject to the California Accidental Release Prevention Program.

The primary goal of the Environmental Programs Division is to protect public health and the environment by promoting and enforcing compliance with hazardous materials, emergency reporting and Clean Water requirements. Through education, complaint investigation, industry outreach, inspection and enforcement, the CUPA Program plays an important role in the City of Union City’s preparedness and prevention efforts. Inspectors in the CUPA Program are skilled and experienced environmental professionals who take part in continuous education to ensure consistency and uniformity in inspection and enforcement.

These inspections determine compliance with the California Health and Safety Code (HSC) Chapters 6.5, 6.67, 6.7 and 6.95; California Code of Regulations (CCR) Titles 19, 22, 23 and 27; and, the Union City Municipal Code.

What to expect at a facility inspection: The Environmental Programs Division conducts inspections that consolidate the six elements of the Unified Program into one inspection. Facilities that have hazardous materials, hazardous waste, underground storage tanks (USTs), aboveground petroleum storage, or Regulated Substances in excess of Reportable Quantities are subject to permitting and inspection. Here are the main components of a typical CUPA facility inspection:

Compliance inspections are conducted on a routine basis and focus on six general areas:

  1. Site Inspection: The inspector will do a walk-through of the facility and will observe buildings, equipment, storage areas and work areas. The purpose of the walk-through is to:

    • Observe hazardous materials and waste management, including secondary containment, storage, labeling, treatment, and waste disposal procedures;
    • Observe the operation and management of underground storage tanks;
    • Review emergency equipment; spill control, and reporting procedures;
    • Review the quantities of hazardous materials that are handled or stored onsite in reportable quantities;
    • Review the current Unified Program Facility Permit, and confirm the facility permit conditions are satisfied.
  1. Employee Training Documentation (if applicable): Review of the written records for the hazardous materials/hazardous waste training program, as described in the facility’s Hazardous Materials Business Plan or Contingency Plan.

  2. Hazardous Materials Business Plan (if applicable): Review information provided in the plan and ensure that hazardous materials inventory, facility site maps, emergency contacts, emergency response procedures, emergency equipment, recordkeeping and employee training plan are adequate and up to date.

  3. Disposal Documentation for hazardous wastes generated onsite (if applicable): Review of uniform hazardous waste manifests, bills of lading and receipts documenting proper disposal of hazardous wastes generated at your facility.

  4. Spill Prevention Control and Countermeasures Plan (if applicable): Review the completeness of the plan required for facilities with aboveground chemical storage in excess of 1,320 gallons.

  5. Underground Storage Tank (UST) records (if applicable): Review to include, at a minimum:

    • Records of testing, certifications and maintenance performed on the UST system equipment and leak detection systems;
    • Monitoring Plan, Emergency Response Plan, and Monitoring Plot Plan;
    • Certification of Financial Responsibility;
    • Owner/Operator agreement (if applicable);
    • UST Operating Permit.
  1. Emergency Reporting telephone posting (if applicable): Verify Emergency Response Posting is placed near a facility telephone where emergency reporting would occur.

  2. Aboveground Petroleum Storage Act (if applicable): Review Stormwater Pollution Prevention Plan, secondary containment, maintenance records and other official documents.

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Electronic reporting for hazardous materials business plans is mandatory. Paper submittals of HMBP information are no longer accepted. Visit the CERS electronic reporting information page for the latest information


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