CUPA Evaluation Process
Background
In accordance with Health and Safety Code, division 20, chapter 6.11 (HSC 6.11), Section 25404.4 and California Code of Regulations, title 27, division 1, subdivision 4, section 15330, the Secretary for the California Environmental Protection Agency (CalEPA) periodically reviews the ability of each Certified Unified Program Agency (CUPA) to continuously meet the intent of the law: coordination, consolidation, and consistency by implementation and enforcement of all Unified Program elements.
The CUPA Performance Evaluation is conducted by staff from each state agency with Unified Program responsibilities, including the State Water Resources Control Board (State Water Board). State Water Board staff use a wide spectrum of performance measures, criteria, and data when assessing a CUPA's Underground Storage Tank (UST) Program. To improve consistency and efficiency of the evaluation process, the State Water Board is providing several guidance documents and references. These documents may be used to prepare for a CUPA Performance Evaluation, a Self-Audit Report, or when a CUPA evaluates a Participating Agency.
The evaluation process and resource documents provided are considered living and will be amended occasionally. Any updates or modifications will be announced through the State Water Board UST Program Monthly Updates page.
Evaluation Process
Notice Letter: A letter that is sent out by CalEPA to the CUPA notifying them of the date on which the performance evaluation is scheduled to begin (includes a list of facility files the evaluation team has chosen to review).
Kickoff Meeting: Introduction of CUPA and evaluation team (CalEPA, DTSC, OSFM, SWRCB) to each other.
Facility Files Upload: CUPA provides requested facility files to CalEPA. Each member of the evaluation team verifies that all documents have been provided and the CUPA is notified of any missing documents.
Oversight Inspection: A member from the evaluation team schedules a time with the CUPA to witness a UST inspection.
Preliminary Summary of Findings (PSOF): The Preliminary Summary of Findings is the initial report provided to the CUPA that includes accomplishments/examples of outstanding implementation/challenges, deficiencies requiring correction, incidental findings requiring resolution, and observations with recommendations.
Q&A Meeting: The CUPA provides feedback on the PSOF,which then the evaluation team will take into consideration on making any edits.
Exit Briefing: The CUPA and the evaluation team finalizing the PSOF to ensure all edits and updates have been included.
Final Summary of Findings (FSOF): The Final Summary of Findings is provided to the CUPA along with their evaluation results.
Progress Reports: If needed, the CUPA will be placed on a schedule to provide CalEPA with progress reports on deficiencies and/or incidental findings.
Guidance Documents and Templates
- What starts with the Notice Letter?
- Date range of information evaluated
- Kickoff Meeting
- Preparing for Kickoff Meeting - Supplemental Questionnaire
- Facility File Review
- UST Permit Review
- UST Permit to Operate Template
- Previous Evaluations Carry Overs
- CERS Quality Assurance Review
- CME Data Review
- Enforcement (Red Tags, AEO, and Referrals)
- Inspection Frequency
- I&E Plan Requirements
- Technical Compliance Rate
- Return to Compliance
- Inspection Quality Review
- Abandoned Tanks Guidance Document
- What is SWRCB reviewing now?
- What changes in 2026
- H&SC 6.7, section 25299.4 requirements
Evaluation Links
Statutes, Regulations, and Local Guidance Letters
Contact Us
Have a question? Contact the Program
Michelle Suh, Environmental Scientist, MPH.
UST Leak Prevention Unit
Michelle.Suh@waterboards.ca.gov
Phone: (916) 323-0878
Tom Henderson, Supervisor
UST Leak Prevention Unit
Tom.Henderson@waterboards.ca.gov
Phone: (916) 319-9128