Underground Storage Tank Operator Training

The Energy Policy Act of 2005 states that the Environmental Protection Agency (EPA), in coordination with states, must develop training guidelines for three distinct classes of operators who operate and maintain federally-regulated underground storage tank systems (USTs). States receiving funding under Subtitle I of the Solid Waste Disposal Act must develop state-specific training requirements consistent with EPA's guidelines. The Department of Commerce's (Commerce), Environmental Regulatory Services Division, Petroleum Products and Tanks Bureau has begun the task of identifying rules and methods of training for all three classes.

After August 8, 2012, states must require operators be trained as follows:

Class A operators - who are owners or owners' representatives and

Class B operators - who are the actual persons charged with day-to-day operations, must generally be trained within 30 days after assuming operation and maintenance responsibilities at an underground storage tank system.

Class C operators are employees that must be trained to identify and respond accordingly to UST emergencies. If a state determines that an underground storage tank system 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.

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 via a Commerce web site. An operator may already be well versed in the operation of an underground storage tank system 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 goal is to extend as many low or no cost opportunities to operators to receive the appropriate training. The deadline for developing the rules for the training programs is August 8, 2009; the department is well on its way to complying with the mandate.

-- Michael Fehrenbach, Bureau Director, Petroleum Products and Tanks