Underground Storage Tank Operator Training Rule Deadline of August 8, 2012 Is Fast Approaching

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The US EPA Established 3 Classes of Training Operators – A, B & C

Class A Operator

A Class A operator has primary responsibility to operate and maintain the UST system. These responsibilities include managing resources and personnel, such as establishing work assignments, to achieve and maintain compliance with regulatory requirements.

In general, this individual focuses on the broader aspects of the statutory and regulatory requirements and standards necessary to operate and maintain the UST system. For example, this individual typically ensures that appropriate individual(s):

Properly operate and maintain the underground storage tank system.
Maintain appropriate records.
Are trained to operate and maintain the underground storage tank system and keep records.
Properly respond to emergencies caused by releases or spills from underground storage tank systems at the facility.
Make financial responsibility documents available to the underground storage tank implementing agency as required.

Class B Operator

A Class B operator implements applicable underground storage tank regulatory requirements and standards in the field. This individual implements day-to-day aspects of operating, maintaining, and recordkeeping for underground storage tanks at one or more facilities.

For example, this individual typically monitors, maintains, and ensures:

Release detection method, recordkeeping, and reporting requirements are met.
Release prevention equipment, recordkeeping, and reporting requirements are met.
All relevant equipment complies with performance standards.
Appropriate individuals are trained to properly respond to emergencies caused by releases or spills from underground storage tank systems at the facility.

Class C Operator

A Class C operator is an employee and is, generally, the first line of response to events indicating emergency conditions. This individual is responsible for responding to alarms or other indications of emergencies caused by spills or releases from underground storage tank systems. This individual notifies the Class B or Class A operator and appropriate emergency responders when necessary. Not all employees of the facility are necessarily Class C operators. This individual typically:

Controls or monitors the dispensing or sale of regulated substances, or
Is responsible for initial response to alarms or releases.

Operator Training

Background And Requirements

Title XV, Section B of the Energy Policy Act of 2005 amends Subtitle I of the Solid Waste Disposal Act, the original legislation that created the underground storage tank (UST) program. The UST provisions of the Energy Policy Act focus on preventing releases and direct EPA to help states comply with new UST requirements.

Section 1524 of the Energy Policy Act of 2005 states that EPA, in coordination with states, must develop training guidelines for three distinct classes of operators who operate and maintain federally regulated underground storage tank systems.

States receiving funding under Subtitle I shall develop state-specific training requirements consistent with EPA’s guidelines. The state-specific training requirements must:

· Be developed in cooperation with tank owners and operators;

· Take into consideration training programs implemented by owners and operators; and

· Be appropriately communicated to tank owners and operators.

Grant Guidelines

On August 8, 2007, EPA published final grant guidelines for operator training in the Federal Register. You can view the grant guidelines in PDF (PDF) (14 pp, 119K, About PDF) or view the grant guidelines in HTML.

Deadlines

August 8, 2009 – States receiving funding under Subtitle I of the Solid Waste Disposal Act must develop state-specific training requirements consistent with EPA’s guidelines.

August 8, 2012 – States ensure all three classes of operators are trained according to state-specific training requirements.

State Status

This map (PDF) (1 pg, 91K, About PDF) shows states’ status toward meeting EPA’s operator training grant guidelines. States with posted requirements do not necessarily meet all requirements of the operator training grant guidelines.

For More Information

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) UST Task Force developed the Operator Training Resource Guide (PDF) (83 pp, 1.9MB, About PDF) which provides information on how states are implementing their operator training program. ASTSWMO also developed a spreadsheet (PDF) (12 pp, 430K, About PDF) outlining key decisions states made in implementing their program.