LAFD CUPA UST Program - Response to COVID - 19 The LAFD CUPA recognizes that during this time of crises involving COVID-19, the operational ability of both the CUPA and the facilities we regulate are under substantial stress, and may not be able to conduct business as usual. Under the current situation facility inspection services by the CUPA have been significantly reduced. For all regulated facilities, we encourage you, where possible, to maintain compliance with your regulatory and local ordinance responsibilities, while also fully adhering to all federal, state, and local public health and safety orders, as they pertain to COVID-19. Please also note our offices are currently closed to the public. We continue to provide the following services:
Public Records Requests Billing, Online Payments and Permitting Plan Check Soils Report Review and Site Assessment Limited Service Requests CERS Reviews and support Receiving and Processing Hazardous Materials Spill Notifications Compliance assessment and technical support of our regulated facilities Limited inspections
We are doing our best to modify the way we operate to continue providing essential services where possible. The CUPA Program is considered an essential service during COVID -19 and as such inspections will be on a limited basis to protect the health and safety of our residents and protect our environment. Please monitor our web page for changes in the LAFD CUPA Program services and activities. https://www.lafd.org/fire-prevention/
Underground Storage Tank Inspections, Testing, Repairs and Operations All normally required maintenance, monitoring, testing and repairs, as well as annual permitting, monthly DO inspections, record keeping (including CERS entries), etc. shall continue where possible. In those circumstances where it is not possible to maintain regulatory compliance, UST owners and operators must minimize the risk of a hazardous materials release by ensuring critical UST leak detection, monitoring, and cathodic protection equipment remain on and monitored. In addition, leak detection and monitoring alarms should be responded to appropriately. UST owners and operators who cannot maintain regulatory compliance must document that all critical UST leak detection, monitoring, and cathodic protection equipment remain operational and all leak detection and monitoring alarms have been responded to appropriately. Further documentation and operational requirements that will be enforced by LAFD CUPA are explained in detail in the following letter from State Water Resources Control Board: https://www.waterboards.ca.gov/water_issues/programs/ust/docs/covid_letter.pdf
All UST owners shall continue to notify LAFD CUPA of scheduled testing through our notification system, however be aware that an inspector may not be available for testing. As most notifications will not receive a reply, you are encouraged to proceed with your requested testing date. All test reports shall be submitted to LAFD CUPA for review. There may be a delay before your inspector can review and respond to the test results. Plan Check: UST Plan check and permits shall continue to be processed as we are able, but permit inspections are limited at this time, and may not be available under certain circumstances. Those maintenance and repair activities that normally require a plan check and permit shall be allowed to proceed without inspection. The permit package shall be retained, along with applicable documentation (notes, photos, etc.) until such time as the inspection can be provided. Unfortunately, we have very limited ability to provide inspections for large projects such as tank pulls, new installs, major retrofits, etc. Please do not undertake any major work where an inspector is required to be present without first calling the office to discuss your needs. We are looking at new technologies and capabilities that may allow for some limited inspections of this type moving forward. Unattended UST Facilities: Some gas station facilities in the City of Los Angeles have expressed concern that they may not be able to continue to operate if their employees become ill, and inquired about the possibility of operating as unattended self-service motor fuel-dispensing facilities. The LA Fire Code speaks to the requirements for such operation as below: 2304.3 Unattended self-service motor fuel-dispensing facilities. Unattended self-service motor fuel-dispensing facilities shall comply with Sections 2304.3.1 through 2304.3.7. 2304.3.1 General. Where approved, unattended self-service motor fuel-dispensing facilities are allowed. As a condition of approval, the owner or operator shall provide, and be accountable for, daily site visits, regular equipment inspection and maintenance. 2304.3.2 Dispensers. Dispensing devices shall comply with Section 2306.7. Dispensing devices operated by the insertion of coins or currency shall not be used unless approved. 2304.3.3 Emergency controls. (ESO Switch) Approved emergency controls shall be provided in accordance with Section 2303.2. Emergency controls shall be of a type that is only manually resettable and accessible to the public. 2304.3.4 Operating instructions. Dispenser operating instructions shall be conspicuously posted in approved locations on every dispenser and shall indicate the location of the emergency controls required by Section 2304.3.3. 2304.3.5 Emergency procedures. An approved emergency procedures sign, in addition to the signs required by Section 2305.6, shall be posted in a conspicuous location and shall read:
,1 &$6( 2) ),5( 63,// 25 5(/($6( 86( (0(5*(1&< 3803 6+872)) 5(3257 7+( ,1&,'(17 ),5( '(3$570(17 3+21( FACILITY ADDRESS ________________________ 2304.3.6 Communications. A telephone not requiring a coin to operate or other approved, clearly identified means to notify the fire department shall be provided on the site in a location approved by the fire code official. 2304.3.7 Quantity limits. Dispensing equipment used at unsupervised locations shall comply with one of the following: 1. Dispensing devices shall be programmed or set to limit uninterrupted fuel delivery to 25 gallons (95 L) and require a manual action to resume delivery. 2. The amount of fuel being dispensed shall be limited in quantity by a preprogrammed card as approved.
Additionally, the practice of keeping the required fire extinguishers in the store must be discontinued. Two 2A:20BC extinguishers must be placed in cabinets available to the public. For the duration of the COVID-19 impact on our operations, gas stations shall be allowed the TEMPORARY option of conducting business as an unattended facility. Additionally, the requirements of 2304.3.6 and 2304.3.7 shall be waived on the same temporary basis. However, such facilities must be capable of offsite monitoring for leak detection. This can be as simple as utilizing a central station alarm company, or as complex as installing available remote monitoring equipment and software from the system manufacturer. A permit shall not be required for such alteration. Unfortunately, those stations that currently have mechanical line leak detectors, or shallow Bravo UDCs utilizing float and chain technology, are not capable of fully monitoring remotely. ESO switches must be accessible to the public. CERS shall be updated, and the district inspector notified should a facility choose to operate unattended. Changes to the monitoring plan and the emergency response plan shall be updated in CERS. Should you have any questions please feel to contact us at 213 978 3720 or by email at LAFDCUPA@LACITY.ORG