Facility File Review

The State Water Board Evaluation staff will review inspection reports, testing documents, permit copies, and other submissions from the CUPA to assess the quality of inspections conducted. The evaluation staff will verify the accuracy of information entered into CERS. The facility file review process may identify various issues, such as incomplete inspection records, discrepancies in testing documents and reports, and inaccuracies in CERS submissions.

Common issues found during the facility file review process:

Non-compliance was observed during compliance inspection, but no violation was issued in CERS and inspection report

  • Description: During the compliance inspection, the inspector identifies a violation that is not documented in CERS and/or the inspection report. Inspectors must document all instances of non-compliance, even if immediately corrected, in both the inspection report and in CERS. Violations of the TCR performance measures are particularly critical since the State Water Board is required to report these performance measures to the USEPA.
  • Examples:
    • Violation is issued on the inspection report and not recorded in CERS
    • Violation is noted in the comment section of the inspection report but not issued on the inspection report or recorded in CERS
    • The incorrect Unified Program Violation type number is issued on the inspection report and recorded in CERS

Non-compliance was not observed, and no violation was issued in CERS and inspection report

  • Description: The testing documents identify non-compliance during the inspection, but this is not documented in the inspection report or CERS. The inspector must ensure that all instances of non-compliance are documented as violations in the inspection report and reported in CERS, even if they are promptly corrected.
  • Examples:
    • Monitoring System Certification form noted a failed sensor, and no violation is issued in CERS
    • Secondary Containment Testing form noted a failed component, and no violation is issued in CERS
    • Annual Monitoring System Certification is late, and no violation was issued

Incomplete or inaccurate information on test results

  • Description: The testing documents reveal missing or inaccurate information (e.g., blank sections). The inspector must ensure that the inspection process includes verifying the accurate completion of all testing documents
  • Examples:
    • Monitoring System Certification form is missing information (e.g., section left blank)
    • Overfill Prevention Inspection Report is missing the UST service technician signature
    • The in-tank gauging testing section is completed on the Monitoring System Certification form when facility has double-walled tanks

UST construction and inspection discrepancies

  • Description: Discrepancies in CERS and accepted testing documents emphasize the need for a thorough review during compliance inspections. CERS must accurately reflect the UST construction at the facility, and the inspector must reject submissions with inaccuracies. Additionally, submitted testing documents must correspond exactly with the information recorded in CERS.
  • Examples:
    • Overfill Prevention Inspection Report cites a method that is conflicting with information on CERS
    • Secondary Containment Testing Report form notes a different tank manufacturer from CERS
    • Monitoring System Certification lists sensors that is different from the sensors disclosed on CERS

Using outdated or unofficial forms

  • Description: The inspector must accept only current UST reporting and inspection forms that the State Water Board has officially released and approved. Reject any forms that are modified or outdated. The CUPAs can find all UST reporting and inspection forms at Underground Storage Tank Forms
  • Examples:
    • CUPA is accepting outdated UST testing documents (e.g., pre-2020 October)
    • CUPA is accepting unofficial UST testing documents that have been altered by the UST service technician

Missing or expired certification/training for the technician

  • Description: Ensure that the ICC number and expiration date (Section 2), as well as the manufacturer and test equipment training certifications (Section 3), are listed on the testing documents and report. The inspector must verify that expiration dates are later than the inspection dates.
  • Examples:
    • Monitoring System Certification form completed by a technician with no training or certification provided
    • Monitoring System Certification form completed by a technician with no training or certification provided for the line leak detector test
    • Overfill Prevention Inspection Report with no training or certification provided

Missing closure documents

  • Information on how the evaluation staff reviews closure documents can be found on the UST Closure page.

Permit is inconsistent with UST Regulations and H&SC

  • Information on how the evaluation staff reviews permits can be found on the UST Permit Review page.

NOTE: This does not include all potential issues identified during the facility file review.