Q. What are the operator training requirements for USTs?

A. The Energy Policy Act of 2005 required states receiving federal funding to develop operator training. The 2015 UST revisions codify these requirements. All owners and operators of UST systems must ensure they have designated Class A, Class B, and Class C operators.

Operator designation

UST owners and operators must designate at least one Class A and one Class B operator for each UST or group of USTs at a facility. In addition, each individual who meets the definition of a Class C operator at the facility must be designated as such.

Class A operators must participate in an appropriate training program or pass an examination covering comparable topics as a training program. The training program must evaluate Class A operators to determine if individuals have the knowledge and skills to make informed decisions regarding compliance and can fulfill the operation, maintenance, and recordkeeping requirements. The following minimum topics, including the purpose, methods, and functions of each, must be taught:

• Spill and overfill prevention;
• Release detection;
• Corrosion protection;
• Emergency response;
• Product and equipment compatibility and demonstration;
• Financial responsibility;
• Notification and storage tank registration;
• Temporary and permanent closure;
• Reporting, recordkeeping, testing, and inspections;
• Environmental and regulatory consequences of releases; and
• Training requirements of Class B and Class C operators.

Class B operators have two training options. A Class B operator may participate in a training program that covers the general requirements that encompass all regulatory requirements and typical equipment used at UST facilities or may receive training on site-specific requirements that address only the regulatory requirements and equipment specific to the facility. A Class B operator may pass a test in lieu of either training program if the examination is comparable. The following minimum topics, including the purpose, methods, and functions of each, must be taught:

• Operation and maintenance;
• Spill and overfill prevention;
• Release detection and related reporting;
• Corrosion protection;
• Emergency response;
• Product and equipment compatibility and demonstration;
• Reporting, recordkeeping, testing, and inspections;
• Environmental and regulatory consequences of releases; and
• Training requirements of Class C operators.

Class C operators must either be trained by a Class A or Class B operator, complete a training program, or pass a test comparable to the training. The training program must teach Class C operators how to take appropriate actions, including notifying appropriate authorities, in response to emergencies or alarms caused by spills or releases. The training must evaluate whether the individuals have the knowledge and skills necessary to be designated as a Class C operator.

Retraining

Operators at UST systems determined to be out of compliance by the implementing agency must complete a training program or comparable examination. The training program must be developed or administered by an independent organization, the implementing agency, or a recognized authority.

The training must cover areas determined to be out of compliance. Retraining must occur within 30 days the facility is determined to be out of compliance unless:

• Class A and Class B operators take annual refresher training.
• The retraining requirement is waived by the implementing agency.

Recordkeeping

Owners and operators must maintain a list of designated Class A, Class B, and Class C operators and maintain records verifying training has been completed. The records must be kept for as long as the operators are designated.

The list must:

• Identify all currently designated Class A, B, and C operators.
• Include the names, class of operator trained, date duties were assumed, date of each completed training, and any retraining.

The records verifying training can be in either paper or electronic form. At a minimum, the records must:

• Identify the name of the trainee.
• State the date trained.
• Identify the operator training class completed.
• Identify the name of the trainer or examiner.
• Identify the training company name, address, and telephone.
• Show the certification was signed by the trainer or examiner, if a classroom or field training program.
• Indicate the name of the training program and Web address if Internet-based.
• Identify areas where retraining occurred.