Who needs to be trained? EPA’s UST training guidelines established 3 classes of operators—A,B, and, C. See if you can identify these guys in your facility.
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.
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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.
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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.
Minimum training requirements. Nancy Teolis, BLR’s UST legal editor, wrote a pretty in-depth blog post for the Environmental Daily Advisor recently on the minimum requirements for facilities. Remember your state will most likely have specific training requirements, so check with them too.
There’s still time! See tomorrow’s Advisor for details on EPA-approved training approaches to this UST operator training.