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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Monday,January 13,2020 8:32 AM To: 'Rincon,Carlos' Cc: Cox, Devin Subject: RE: Changes to Hazardous Materials Business Plan Submittal Requirements AB1429 Attachments: AB1429 CalOES guidance.pdf Hi Carlos, I have sat down with the CUPA Program Coordinator(manager)and the Hazardous Materials Lead Senior(supervisor) and we had a discussion about AB1429. They is what I have been told: San Joaquin county will still require annual submittals of at least the inventory portion of CERS. CERS will by default,for now,require the facility information to be resubmitted.The annual inventory submittal is required by San Joaquin County Ordinance 4-8006-DUE DATE FOR BIANNUAL PLAN REVIEWS AND ANNUAL INVENTORIES. Which states the following Annual inventories are due on January 15th of every year. Biannual hazardous materials management plan reviews by a business which are due in a given year will be due on January 15th of that year regardless of date of the original plan submittal. Also,based on the Health and Safety Code(HSC) interpretation and the guidance provided by CalOES on the AB 1429, they yearly submittal may still apply. HSC section 25508.2 states the following 25508.2. On or before the due date established pursuant to paragraph(2)of subdivision (a) of Section 25508,the business owner, business operator,or officially designated representative of the business shall annually review and certify that the information in the statewide information management system is complete,accurate,and in compliance with Section 11022 of Title 42 of the United States Code.An electronic submittal to the statewide information management system that meets the requirements of paragraph(1)of subdivision(a)of Section 25508 satisfies the certification requirement of this section. Per the guidance document attached, Section I.Annual Certification Requirements - "Effective January 1, 2020, all handlers of hazardous material,whether subject or not to EPCRA or APSA,are still required to annually review and certify that their information in California Environmental Reporting System (CERS) is complete, ..... "The process depicted at the end of this document provides guidance to handlers on how they can meet the certification requirement in CERS." The process shown at the end of the of the guidance document is the same process used to submit the Hazardous Materials Business Plan and all other elements when there are no changes. Given that this is the process that CalOES describes as a certification and the regulations require an annual certification by all facilities and an this process described by CalOES guidance is the equivalent to a submittal, San Joaquin County will verify annual certification by the process described by CalOES until further guidance is released by CaIOES. 1