Underground Storage Tank Operator Training

The Energy Policy Act of 2005 states that the US Environmental Protection Agency (EPA), in coordination with states, must develop training guidelines for three distinct classes of individuals who operate and maintain federally-regulated underground storage tank systems (UST's.) States receiving federal funding for regulating these systems must develop state-specific training requirements consistent with EPA's guidelines. The Environmental and Regulatory Services Division has developed new rules for this training and has begun to develop the training programs for the three classes of operators.

After August 8, 2012, operators must be trained as follows: Class A operators – who are owners or owners' representatives, and Class B operators – who are the actual persons charged with supervising day-to-day operations must generally be trained before assuming operation and maintenance responsibilities for a UST. Class C operators are employees who must be trained to identify and respond accordingly to UST emergencies, such as spills and other releases. If a State determines that a UST is out of compliance, appropriate operator(s) must be retrained. At a minimum, retraining must include UST training in the areas that are determined to not be in significant compliance. The Division is also developing a reporting system to identify those who are listed by each company as the Class A and Class B operators. The database will also track which training and test each individual completed.

Several ideas have surfaced regarding training and testing opportunities for the three classes of operators. The options range from allowing operators to participate in a training and testing program delivered by a nationally recognized organization, to extending reciprocity and accepting certificates from another state's training programs, to offering an on-line interactive training and testing site. An operator may already be well versed in the operation of a UST that is in use on a property or may have already received sufficient training through company sources, in which case only testing may be necessary.

The Division is applying for an EPA grant to fund a program that would assist owners and operators of small businesses, and owners and operators where a language barrier exists. The plan is to have third-party training companies hold in-person training classes at several locations in the state that the Division and EPA will support financially to minimize the cost to the small business owner. In addition to the small business support, the Division and EPA plan to contract with interpreters to assist training companies during sessions targeted to non-English speaking operators or operators who have a difficulty with the English language. This approach should give access to training to well over 75 percent of the owner and operator constituency. Additional forms of training may include Webinar-based training sessions and approved company-sponsored training programs. For example, a company with many locations and its own in-house environmental and maintenance department could receive approval to train and test its employees.

The goal of the Division is to make as many training opportunities available and to minimize the burden on the industry. The Division plans to communicate ongoing updates about the training program to owners and operators as more information and class schedules become available.

-- Sam Rockweiler, Civil Eng. Adv. and Michael Fehrenbach, Bureau Director, Petroleum Products and Tanks