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September 08, 2014
The ABCs of EPA's proposed changes to UST operator training requirements

"In the next few months the Environmental Protection Agency (EPA) is expected to publish a final rule containing revisions to the 1988 underground storage tank (UST) regulations, including UST operator training requirements. Yesterday we looked at some of the primary changes to UST training requirements and today we will review specific aspects of training programs."

Proposed UST Operator Training Program Elements

EPA's proposed UST regulatory revisions encompass many aspects of UST systems, including extensive changes to the requirements for UST operator training, as we discussed yesterday.

Although EPA's intention is to require operator training that is consistent with the grant guidelines for states under the Energy Policy Act, the Agency is building in flexibility by issuing only minimum requirements. This will allow for site-specific training needs, while ensuring a level of standardized training for all covered UST operators.

Training programs for Class A and B operators must, at a minimum, teach and evaluate knowledge on the purpose, methods, and functions of the following items:

Class A operator:

  • Spill and overfill prevention;
  • Release detection;
  • Corrosion protection;
  • Emergency response;
  • Product and equipment compatibility;
  • Financial responsibility;
  • Notification and storage tank registration;
  • Temporary and permanent closure;
  • Related reporting and recordkeeping;
  • Environmental and regulatory consequences of releases;
  • Training requirements for Class B and C operators; and
  • Training for Class A operators, at a minimum, must provide general knowledge on all listed areas.

Class B operator:

  • Operation and maintenance;
  • Spill and overfill prevention;
  • Release detection and related reporting;
  • Corrosion protection and related testing;
  • Emergency response;
  • Product and equipment compatibility;
  • Reporting and recordkeeping;
  • Environmental and regulatory consequences of releases; and
  • Training requirements for Class C operator.
  • Training for Class B operators may be general or specific to a Class B operator's site.

Training programs for Class C operators must, at a minimum, teach and evaluate knowledge of the following items:

Class C operator:

  • Appropriate action to take in response to emergencies (including situations posing an immediate danger or threat to the public or environment and that require immediate action) or alarms caused by spills or releases from a UST system.
  • Training for Class C operators may be general or specific to a Class C operator's site.

Training also requires an evaluation component that must be developed and administered by an independent organization, the implementing authority, or a delegated authority. This component must evaluate knowledge through a test, practical demonstration, or another approach that is acceptable to the implementing agency.

However, in lieu of an actual training program, operators in all three classes of training must pass comparable examinations that assess their knowledge of the minimum requirements for their class or classes.

To ensure training is completed in a timely way and is aligned with the age of the UST systems, the EPA proposed a phased-in system specifying the deadline for training.

  • For facilities with one or more USTs that were installed on or before 12/22/1988, the deadline for training is 1 year after the effective date of the rule.
  • For sites with no USTs installed before 12/22/1988 but at least one UST installed on or before 12/22/1998, the deadline is 2 years after the effective date of the final rule.
  • For facilities with all USTs installed after 12/22/1998, the deadline is 3 years after the effective date of the rule.
  • After the last deadline for training, Class A and B operators must be trained within 30 days of assuming duties and Class C operators must be trained before assuming duties.

Retraining may also be required when a UST system is found to be out of compliance. This training must include, at a minimum, those areas deemed to be out of compliance by the implementing agency and must be completed within 30 days of the final determination of noncompliance. The EPA is proposing to allow annual refresher training in lieu of retraining; however, refresher training must have been in place at the time of the determination of noncompliance.

In addition, the EPA is proposing to allow implementing agencies to waive retraining, preferably in writing. The proposed training requirements will be added to CFR Part 280 in a new subpart, Subpart J, and are anticipated in late 2014.

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