Implementing the EPA's New UST Operator Training Requirements

October 23, 2013

Implementing the EPA's New UST Operator Training Requirements: Class-Specific Responsibilities and State-by-State Requirements

According to the USEPA’s “Annual Report on the Underground Storage Tank Program” for fiscal year (FY) 2010, at the end of FY 2010, there were approximately 597,000 active, federally-regulated USTs at approximately 215,000 sites across the country.

 

With the exception of Florida, all states are now required by the United States Energy Policy Act of 2005 to ensure that three classes of underground storage tank (UST) system operators, defined by the Act, are trained consistent with United States Environmental Protection Agency (USEPA) guidelines. The approaches being taken to comply with the training mandate vary state to state.  

 

Click on the table below to view GeoInsight's outlines of the three classes of operators, their responsibilities, and required training.

 

Screen_Shot_2012-10-23_at_2.30.21_PM.pngState-specific mandates

States must ensure that existing UST operators are trained according to that state's specific training mandates, requiring that operators be trained as follows:

  • Class A and Class B operators must be trained within 30 days or another reasonable period specified by the state, after assuming operation and maintenance responsibilities at the UST system, and
  • Class C operators must be trained before assuming responsibility for responding to emergencies.

In general the regulations being developed by the states are not requiring UST owners to have certified operators be present at unmanned UST locations, such as cellular towers and pump stations.  However, Class A and B operators must still be designated for those locations and may be given responsibility for multiple locations.  Class A and B operators are not required to be employees of the UST owner, but care should be taken to note state-specific requirements regarding the scope of Class A and B operator responsibilities.  For example, some states require monthly inspections of UST facilities by a Class A or B operator or require certified operators for aboveground tanks, while others do not.

The table below outlines some of the notable differences among the northeastern states in the approaches they are taking to comply with the training and certification mandate. 

State_Variations.jpgClick here to visit the USEPA's main UST page or download their complete Operator Training Resource Guide.