CUPA Programs Fee... · • Trained Inspectors (Steel Tank Institute SP001 Certified) •...

September 13, 2016

Environmental Management Department

CUPA

Programs2020 Fee Proposal

Marie Woodin, Director

Michael Meyer, Division Chief

Robert Duncan, Deputy Chief

The mission of the Sacramento County


(EMD) is to protect public health and the

environment by ensuring compliance with

environmental regulations.

2


September 13, 2016


34 Environmental

Programs

Special Fund Department

100% fee supported

FY 2018/2019: 29,462

inspections countywide

124 FTE specifically

trained Environmental

Specialists and support staff

4


Environmental

Compliance

Division

Michael Meyer, Chief

Environmental Compliance

Cross Connection

Control Program

Toxic Site Clean Up

Abandoned Wells Program

Solid Waste Facilities

Land Use Evaluation

Wells

Medical Waste

Multi Family Recycling

Small Water Systems

Business Recycling/ Organics Recycling

Liquid Waste/Septic

Systems

Above Ground Storage Tanks

Hazardous Waste Storage and Generation

Hazardous Materials Business Plans and Storage

Underground Storage Tanks

Recycled Water

CAL Accidental Release

Prevention Program

Incident Response

Certified Unified Program Agency (CUPA)The Environmental Compliance Division has been certified

by the California Environmental Protection Agency (Cal-EPA)

as the CUPA for Sacramento County. As the CUPA, EMD is

responsible for the implementation of six statewide

environmental programs for Sacramento County:

• Aboveground Petroleum Storage Act (ASPA)

• California Accidental Release Prevention (CalARP)

• Hazardous Material Business Plan Program (HMP)

• Hazardous Waste Management (HW)

• Underground Storage Tanks (UST)

• Tiered Permitting

5


Certified Unified Program Agency (CUPA)

• Authorities:

– APSA (H&S Code*, § 25270.5, subd. (a));

– CalARP (H&S Code, § 25534.5);

– HMP (H&S Code, § 25508, subd. (a));

– HW (H&S Code, § 25185, subd. (a)); and

– UST (H&S Code, § 25289).

*California Health & Safety Code

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The implementation of these programs

involve:• A single fee system and consolidated permit for all

Unified Program elements

• Inspection of regulated facilities

• Education of regulated businesses on requirements,

laws, and regulations

• Investigations of complaints, spills, unauthorized

releases, etc.

• Enforcement against facilities that have violated

applicable laws and regulations

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Specialized Programs = Specialized Staff

Aboveground Petroleum Storage Act (ASPA)H&SC Chapter 6.67 pursuant to 40 CFR 112.7

• Facilities storing petroleum in quantities greater than 1,320 gallons

• In-depth review of the Spill Prevention Control and Countermeasures

Plan (SPCC) and compliance with industry standards

• Trained Inspectors (Steel Tank Institute SP001 Certified)

• Facilities inspected/verified every three years

8


California Accidental Release Prevention

(CalARP)H&SC Chapter 6.95 & Title 19 CCR

• Facilities storing more that the threshold quantity of

regulated substances that pose the greatest risk of

immediate harm to the public and environment (i.e.: chlorine

gas, ammonia gas)

• High potential for offsite impacts

• Review Risk Management Plans for completeness/technical

adequacy

• Extensive regulatory requirements

• Inspectors require highly specialized training

• Inspected every three years

Specialized Programs = Specialized Staff9


Hazardous Material Business Plan Program

(HMP)H&SC Chapter 6.95 & Title 19 CCR

• Facilities storing reportable quantities of Hazardous Materials

• Dedicated business plan review team


• Biweekly HMP workshops

– Call to schedule (916) 875-8550

• CA Environmental Reporting System (CERS) Hotline 916-875-2377



Hazardous Waste Management (HW) & Tiered

Permitting

H&SC Chapter 6.5 & Title 22 CCR pursuant to 40 CFR part 262

• Facilities that generate/treat hazardous waste onsite

• Activity specific, risk based permitting program

• Complex regulations

• Extensive document review




Underground Storage Tanks (UST)

Specialized Programs = Specialized Staff

H&SC Chapter 6.7, Title 23 CCR

• Facilities that store hazardous materials

in underground tanks

• International Code Council (ICC)

Certified - Continuous education

• Construction- New installation, repairs

& upgrades

• Removal- Initial and ongoing monitoring

• Annual inspection

• Biweekly UST workshops

– Call to schedule (916) 875-8550

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Why is a Fee Adjustment Needed?

• Our fees have not increased since 2010

• EMD receives no General Funds (100% fee funded)

• Required fee accountability program per Title 27 of CCR

– § 15220. Fee Accountability Program.

(a) Each CUPA shall implement a fee accountability program designed

to encourage efficient and cost-effective operation of the program for

which the single fee and surcharge are assessed.

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27 CCR § 15220

Fee Accountability Program

The fee accountability program shall include at a minimum the

following elements:

• Fee schedule, amount billed, and revenue collected

• Staff work hours required to implement the program

• Direct & indirect program expenses (disposable equipment

or administrative functions)

• Number of regulated facilities in each program element

within the jurisdiction

• Quantity and range of services provided

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Sacramento County by the Numbers

In 2018

• 7,057 total permits issued

• Over 3,000 inspections conducted

• 3,762 business plans reviewed

• 947 public records act requests: over 78,000 documents

• 471 UST inspections

• 159 UST Removals, Installations, Upgrades, and/or Repairs

• 521 incident response calls

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Services Provided • Complaint response

• On-call technical specialists

• Plan/Document review

• HMP/UST workshops

• Online resources

• Incident response team

• Social media outreach

• New/Existing Business Assistance

– Business Environmental Resource Center (BERC)

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Meet the Needs of the Customer

• Staff availability to provide assistance

• Streamline processes

• Reduce turnaround time

• Maintain highly trained and dedicated staff

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Proposed Fee Schedule

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• 3-5 year phased-in approach

• Fees will be effective July 2020

• < 50% of all CUPA program subcategories

will be affected by the fee increase (37 out

of 75)

ABOVEGROUND PETROLEUM

STORAGE ACT (APSA)

Fee Breakdown by CUPA Program

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Sacramento County CUPA (APSA)Fee Comparison & Percent Increase –

Three Year Phase-In Plan

PE

CodeProgram Element Description

2010 – 2019

Fee

Increase per

year for 3 years

Percent

Increase/

Year

5441Aboveground Petroleum Storage ≥1,320 and

<10,000 Gallons$73 +$49 +67%

20

Program DescriptionCurrent

Fee

Effective

July 2020

Effective

July 2021

Effective

July 2022

AST 1,320 gallons <

10,000 gallons $73 $122 $171 $220

Only fee categories that will change are shown. If not shown in

this table, that fee category will remain unchanged.

Statewide CUPA Program Fee

Comparison Chart (APSA)

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CALIFORNIA ACCIDENTAL

RELEASE PREVENTION

PROGRAM (CALARP)


22

Sacramento County CUPA (CalARP)Fee Comparison & Percent Increase – Old vs. New

PE


2010 – 2019

Fee

Increase per

year for 3

years

Percent

Increase/

Year

5911CalARP Program Level 1 Annual

Program Activity Fee$1,017 $286 +28%





5921CalARP Additional Covered Process

Fee$261 $506 +193%

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Sacramento County CUPA (CalARP)Three Year Phase-In Plan

PE


Current

FeeEffective

July 2020

Effective

July 2021

Effective

July 2022


Program Activity Fee$1,017 $1,303 $1,588 $1,874





5921CalARP Additional Covered Process

Fee$261 $767 $1,272 $1,778

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Comparison Chart (CalARP)

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HAZARDOUS MATERIALS

BUSINESS PLAN (HMP)


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Sacramento County CUPA (HMP)

PE Code Program Element Description Current FeeIncrease per

year

Percent

Increase

5203Hazardous Materials Disclosure Fee 1-3

Materials$552 $28 5%

5214Hazardous Materials Disclosure Fee, Waste

Only$0 $79 79%

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Fee Comparison & Percent Increase – One or Five Year Phase In Plan


Fee

Effective

July 2020

Effective

July 2021

Effective

July 2022

Effective

July 2023

Effective

July 2024

Hazardous Materials

Disclosure Fee 1-3

Materials

$552 $580 N/A N/A N/A N/A

Hazardous Materials

Disclosure Fee,

Waste Only

$0 $79 $158 $237 $316 $395

Only fee categories that will change are shown. If not shown in these

tables, that fee category will remain unchanged.


Comparison Chart (HMP)

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HAZARDOUS WASTE (HW) &

TIERED PERMITTING


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Sacramento County CUPA (HW)Fee Comparison & Percent Increase –

Three Year Phase-In

PE


2010 –

2019 FeeIncrease per

year for 3 years

Percent

Increase/

Year

5304 Hazardous Waste Generator Fee <55 gallons $123 $81 +65%

30


Fee

Effective

July 2020

Effective

July 2021

Effective

July 2022

Hazardous Waste

Generator Fee <55

gallons

$123 $204 $285 $366


these tables, that fee category will remain unchanged.

Sacramento County CUPA

(Tiered Permitting)Program Current Fee & Proposed Increases

PE


2010 –

2019 Fee

Increase per

year for 5

years

Percent

Increase/

Year

5551Conditionally Exempt <55 gallons per

month$106 $43 41%

5552Conditionally Authorized >55 gallons per

month$424 $107 25%

5553 Permit by Rule $424 $107 25%

5554Household Hazardous Waste CF –

Permanent$1,166 $121 10%

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Sacramento County CUPA

(Tiered Permitting)

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Program Element

Description

Current

FeeEffective July

2020

Effective

July 2021

Effective

July 2022

Effective

July 2023

Effective

July 2024

Conditionally Exempt

<55 gallons per month$106 $149 $191 $234 $277 $320

Conditionally Authorized

>55 gallons per month$424 $531 $638 $745 $852 $959

Permit by Rule $424 $531 $638 $745 $852 $959

Household Hazardous

Waste CF – Permanent$1,166 $1,287 $1,409 $1,530 $1,651 $1,773




Comparison Chart (HW)

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UNDERGROUND STORAGE

TANKS (UST)


34

Sacramento County CUPA (UST)Fee Comparison & Percent Increase

PE


2010 –

2019 Fee

Increase per

year for 3

years

Percent

Increase/

Year

5411 Underground Storage Tank Fee – 1 Tank $1,103 $90 8.2%

5412 Underground Storage Tank Fee – 2 Tanks $1,325 $62 4.7%



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Sacramento County CUPA (UST)Three Year Phase-In Plan

36

Program Element Description2010 –

2019 Fee

Effective

July 2020

Effective

July 2021

Effective

July 2022

Underground Storage Tank Fee – 1 Tank $1,103 $1,193 $1,283 $1,373

Underground Storage Tank Fee – 2 Tanks $1,325 $1,387 $1,449 $1,512




37


2019 Fee

Effective

July 2020

Effective

July 2021

Effective

July 2022

Underground Storage Tank Installation – 1

Tank$3,408 $4,309 $5,209 $6,110


Tanks$3,834 $4,657 $5,480 $6,303


Tanks$4,260 $5,011 $5,262 $6,513


Tanks$4,686 $5,357 $6,027 $6,698


Tanks $5,112 $5,737 $6,362 $6,987


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2019 Fee

Effective

July 2020

Effective

July 2021

Effective

July 2022

UST Repair: Tank, Piping or Monitoring

System$1,065 $1,209 $1,352 $1,496

UST: Spill Containment $746 $817 $888 $959

UST Closure – 1 Tank $1,491 $1,495 $1,498 $1,502

UST Temporary Closure – 1 Year $746 $828 $911 $993


these tables, that fee category will remain unchanged.


Comparison Chart (UST)

39

Sacramento County Stormwater

Program

40

Program Element Description2010 – 2019

Fee

Effective July

2020

Auto Body Shops $166 $150

Auto Repair Shops $166 $150

Restaurants $83 $91

Retail Gas Outlets $72 $65

General Permit Under 10 Acres $238 $215



EXAMPLES

Fee Comparison Charts, Graphs and Business Types

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Example Business Type

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• CESQG (Conditionally Exempt Small Quantity

Generators <55 gallons):

– PE’s 5214, 5304 and CUPA SurchargePast Fees from 2010 – 2019 Proposed Fees FY 2020

5214: Hazardous

Materials Disclosure

Fee, Waste Only

$0 5214: Hazardous


Fee 1-3 Materials,

Waste Only

$79

5304: Hazardous

Waste Generator Fee

<55 gallons

$123 5304: Hazardous

Waste Generator Fee

<55 gallons

$204

CUPA Surcharge $49 CUPA Surcharge $49

TOTAL $172 TOTAL $332

Percent Increase 93 %

Example Business Type

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• Auto Shop:

– PE’s 5203, 5305 and

CUPA Surcharge

Past Fees from 2010 – 2019 Proposed Fees FY 2020

5203: Hazardous


Fee 1-3 Materials



Fee 1-3 Materials

$580

5305: Hazardous

Waste Generator Fee

55 – 500 gallons


Waste Generator Fee

55 – 500 gallons

$524


TOTAL $1,125 TOTAL $1,153

Percent Increase 2.5 %

CUPA Comparison Graph

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*Note this reflects the following fees: PE 5203, 5305 and CUPA Surcharge

Retail Gas

Station Example

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Past Fees from 2010 – 2019 Proposed Fees FY 2020

5203: Hazardous

Materials Disclosure Fee

1-3 Materials


Materials Disclosure Fee

1-3 Materials

$580

5304: Hazardous Waste

Generator Fee <55

gallons

$123 5304: Hazardous Waste

Generator Fee <55

gallons

$204

5413: Underground

Storage Tanks – 3 Tanks

$1,531 5413: Underground

Storage Tanks – 3 Tanks

$1,565


TOTAL $2,255 TOTAL $2,398

Percent Increase 6.3 %

Gas Station:

• PE’s 5203, 5413, 5304

• Hazardous Materials (1-3), USTs (3), Hazardous Waste Generator

CUPA Comparison Graph

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*Note this reflects the following fees: PE 5203, 5304, 5314 and CUPA Surcharge

Summary

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• Phased in approach for ease in fee adjustments

• Ten years since last fee assessment

• Stay up to date with future outreach or

compliance tools available to you:

www.emd.saccounty.net

http://www.emd.saccounty.net/

Questions

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https://emd.saccounty.net/

mailto:[email protected]

mailto:[email protected]

https://emd.saccounty.net/

SURVEY

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