UST Operator Training: Minimum Requirements

By Nancy W. Teolis, J.D., BLR Legal Editor-Environmental
nteolis@blr.com

What is UST Operator Training?

UST operator training means any program that meets EPA’s Grant Guidelines to States for Implementing the Operator Training Provision of the Energy Policy Act of 2005.

EPA UST Operator Training Guidelines describe the minimum requirements a state’s underground storage tank program must contain, including a description of the classes of operators, required training for each class of operator, deadlines when operator training is required, and examples of acceptable state approaches to operator training.

Resource: EPA Guidelines
http://enviro.blr.com/environmental-guidance/hazmat-and-chemicals/underground-storage-tanks-USTs/USTCA-Operator-Training-Guidelines/

How Does a State Implement These Guidelines?
A state implements these guidelines by:

• Requiring operator training for all operators in each class
• Developing state-specific operator training requirements consistent with EPA’s Guidelines
• Establishing a procedure to identify individuals who are required to be trained under the operator training requirements specified in EPA’s Guidelines
• Ensuring all operators are trained in accordance with the Guidelines

 

States may choose to be more stringent than these minimum requirements.

Three Classes of Operators
Each UST facility must designate and train three classes of operators identified as Class A, Class B, and Class C. Separate individuals may be designated for each class of operator or an individual may be designated to more than one of the operator classes.  An individual who is designated to more than one operator class must be trained in each class.

Minimum Training — Class A Operator

A Class A operator has primary responsibility to operate and maintain the UST system. The Class A operator’s responsibilities include managing resources and personnel, such as establishing work assignments, to achieve and maintain compliance with regulatory requirements. At a minimum, the Class A operator must be trained in the following:

• A general knowledge of UST system requirements so he or she can make informed decisions regarding compliance and ensure appropriate individuals are fulfilling operation, maintenance, and recordkeeping requirements and federal and state UST program requirements and standards regarding:

— Spill and overfill prevention
–Release detection
–Corrosion protection
–Emergency response
— Product compatibility

• Financial responsibility documentation requirements
• Notification requirements
• Release and suspected release reporting
• Temporary and permanent closure requirements
• Operator training requirements

Minimum Training — Class B Operator

A Class B operator implements applicable UST regulatory requirements at the facility. This individual implements day-to-day aspects of operating, maintaining, and recordkeeping for USTs at one or more facilities.

States may require either site-specific Class B operator training or broader training regarding regulatory requirements that, at a minimum include the following:

• Components of UST systems
• Materials of UST system components
• Methods of release detection and release prevention applied to UST components
• Federal and state operation and maintenance requirements including:

— Spill and overfill prevention
–Release detection
–Corrosion protection
–Emergency response
— Product compatibility

• Reporting and recordkeeping requirements
• Class C operator training requirements

Minimum Training — Class C Operator

A Class C operator is an employee that is generally responsible for emergency response. This individual is responsible for responding to alarms or other indications of emergencies caused by spills or releases from UST systems. This individual notifies the Class B or Class A operator and appropriate emergency responders when necessary.  Not all employees at the facility are necessarily Class C operators.

At a minimum, the Class C operator must be trained to take action in response to emergencies or alarms caused by spills or releases from an UST system.

Resource: BLR Class C Operator Training Program (TrainingToday.BLR.com)
http://trainingtoday.blr.com/employee-training-course/class-c-ust-operator-training

BLR has developed a customizable Class C UST Operator Training Program as part of BLR’s Training Today website at TrainingToday.BLR.com. The program is designed for use by certified Class A and B operators and has been approved in most states. Contact BLR at 800-727-5257 for more information.
When Must 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. Check with your state for stricter state training requirements.

Nancy W. Teolis, J.D., has been a Legal Editor for BLR’s environmental law publications since 1993, focusing primarily on underground storage tanks, pesticides, and hazardous waste-related requirements. Before joining BLR, she worked for the law firm Rudman & Winchell in Bangor, Maine, with an emphasis on asbestos exposure litigation.  She received her law degree from Western New England University School of Law in Springfield, Massachusetts, and is a member of the Connecticut bar.