In this Environmental Daily Advisor video, Advisor editor Kelly Lagana talks with Nancy Teolis about EPA’s UST Operator Training Deadline for August 2012. Nancy Teolis is the editor for USTs, Pesticides, TSCA, and other topics for BLR’s environmental compliance content.
http://youtu.be/xIApdUeVERgKL: This is Kelly Lagana for the Environmental Daily Advisor. We’re talking today with Nancy Teolis. She is the legal editor for the UST topic for BLR’s environmental compliance content. Thanks for joining us today.
NT: Thank you.
KL: I wanted to talk to you about the UST Operator Training Deadline. States must ensure that three classes of operators are trained by August 8, 2012. Can you talk a little about EPA’s UST Operator Training requirements and how it affects owners and operators of UST systems?
NT: EPA developed UST operator training guidelines in response to the Energy Policy Act of 2005. EPA’s guidelines require states to adopt state-specific training requirements for 3 classes of operators—Class A, B and C. The guidelines also contain minimum training requirements that states must adopt for each class. The training applies to USTs containing petroleum and hazardous chemicals that are regulated under the Resource Conservation and Recovery Act, known as RCRA.
KL: Could you briefly describe the three classes of operators?
NT: Sure.
The Class A operator has primary responsibility for the operation of the UST facility and must be familiar with the regulatory requirements. This is usually the owner of the facility.
The Class B operator is responsible for the day-to-day operation and maintenance of the facility. The Class B operator is generally the on-site manager of the facility. Some states have combined these two classes as a Class A/B operator. However, states must ensure that Class A/B operators meet the minimum training requirements for both classes.
The Class C operator is an employee that is responsible for responding to emergency situations, such as spills from the UST systems.
Some UST facilities are considered “unmanned” meaning that an operator is not required to be physically present at the facility. However, there must be some signage with staff contact information in the event of an emergency for the benefit of firefighters or other emergency personnel that may be required to respond to the facility site.
KL: How frequently must UST operators be trained?
States must ensure that Class A, B and C operators are trained according to EPA guidelines and state-specific requirements by August 8, 2012. After August 8, 2012, Class A and B operators must be trained within 30 days, or other reasonable time period specified by the state, after assuming responsibilities. Class C operators must be trained before assuming responsibilities. Refresher training is required by most states from annually to 3 years. Operator retraining is also required when a UST is not in compliance.
KL: Now, what’s the status of the August deadline in the states?
NT: State training status varies. Many states have already passed legislation, adopted rules and implemented their UST Operator training programs — some with earlier training deadlines. State environmental agencies have either created their own training programs, adopted other state programs, or have approved third-party training programs and listed these programs on their websites. In most cases, states require specific training for Class A and B operators and leave it up to them to train their Class C operators. Training is site-specific, so if an operator is transferred to another facility, that operator has to be trained again for that particular site.
However, there are some states facing budget challenges or for other reasons have not developed a program. In a few cases, there may not be any state law or regulation requiring training in place. If training is not completed by the August deadline this year, those states may have issues with EPA related to funding.
EPA has proposed extensive UST rules that include operator training that follow the guidelines, but those rules are not expected to be final before the August deadline.
KL: Does the training need to be documented?
NT: EPA guidelines require that owners or operators maintain records documenting the training received for all classes of operators either onsite or at an alternative site readily available for inspection.
In addition, we have developed a customizable Class C training program as part of BLR’s Training Today website at TrainingToday.BLR.com. The program itself is a pretty comprehensive program for use by certified Class A and B operators and has been accepted and approved in most states. It also includes guidance and forms, such as a training log to aid UST facilities in documenting operator training.
KL: Excellent. We’re going to have lots of information coming out on the Environmental Daily Advisor website regarding UST Operator Training, including minimum training requirements, and additional guidance involving UST compliance.
So thank you very much Nancy for joining with this great information, and thanks for watching everyone.
NT: Thanks Kelly.