According to federal regulations, three distinct classes of operators who operate and maintain federally regulated underground storage tank (UST) systems must take and pass state-specific UST operator training by Aug. 8. The point of the regulation, which applies to any truckstop or travel plaza that operates a UST, is to ensure UST operators are ready to respond if a UST emergency or spill occurs.
The training requirement was created in the Energy Policy Act of 2005, which was signed by President Bush on Aug. 8, 2005. Title XV, Subtitle B of this act (titled the Underground Storage Tank Compliance Act) contains amendments to Subtitle I of the Solid Waste Disposal Act—the original legislation that created the UST program. The UST provisions of the Energy Policy Act focus on preventing releases and direct EPA to help states comply with new UST requirements.
Section 1524 of 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 UST systems.
While the Energy Policy Act was passed in 2005, the guidelines of the act were not effective until Aug. 8, 2007. Under the guidelines, a state had until Aug. 8, 2009 to develop state-specific training requirements consistent with EPA's guidelines. All three classes of UST operators in every state with completed regulations must be trained according to the state-specific training requirements by Aug. 8, 2012.
State-Specific Training Regulations
It is important to note that the training requirements are written by each individual state and several states have not finished their regulations. Thus, operators are required to complete training only in the states that have adopted operator training regulations. State-specific information can be found here.
Who Must Take the Training by Aug. 8, 2012?
Each UST system or group of UST systems at a facility must have a Class A, Class B and Class C operator designated and all individuals designated as a Class A, B, or C operator must, at a minimum, be trained according to the guidelines.
Separate individuals may be designated for each class of operator described above or an individual may be designated to more than one of the above operator classes. An individual who is designated to more than one operator class must be trained in each operator class for which he or she is designated. Because an individual may be designated for more than one operator class, states may allow a training approach that encompasses training for more than one operator class.
The Class A operator has primary responsibility to operate and maintain the UST system. The Class A operator’s responsibilities include managing resources and personnel, such as establishing work assignments, to achieve and maintain compliance with regulatory requirements. In general, this individual focuses on the broader aspects of the statutory and regulatory requirements and standards necessary to operate and maintain the UST system. Class A operators do not have to be onsite at all times, but they do need to be able to respond to emergency calls and access the site within hours.
The Class B operator implements applicable UST regulatory requirements and standards in the field. This individual implements day-to-day aspects of operating, maintaining and recordkeeping for USTs at one or more facilities. Class B operators do not have to be onsite at all times but they do need to be able to respond to emergency calls and access the site within hours.
The Class C operator is an employee and is, generally, the first line of response to events indicating emergency conditions. This individual is responsible for responding to alarms or other indications of emergencies caused by spills or releases from UST systems. This individual notifies the Class B or Class A operator and appropriate emergency responders when necessary. Not all employees of the facility need to be Class C operators, but a certified Class C UST operator must be on-site at all times in order to be open and operational.
After Aug. 8, 2012, operators be trained as follows:
- Class A and 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.
- Class C operators must be trained before assuming responsibility for responding to emergencies.
How to Get Into Compliance by Aug. 8, 2012
In keeping with NATSO’s fundamental purpose to deliver solutions to members’ challenges,NATSO has partnered with Practical American Safety Solutions (PASS) to offer an online training program that meets the federal and state requirements.
To prepare for the upcoming deadline, you will need to first identify the Class A, B and C operators at your facility. As a reminder, separate individuals may be designated for each class of operator described above or an individual may be designated to more than one of the above operator classes. PASS offers the same training for both Class A and B operators.
Next, instruct your Class A, B and C operators to take the PASS training online. The NATSO/PASS online registration for UST operator training can be found here. Class A/B training can be completed in as little as four hours and Class C operator training can be completed in approximately forty minutes.
Very Important – If you navigate to the PASS testing site through a different link, be sure to select NATSO as your Director.
About the PASS Training Program
PASS was established in 2003 to provide compliance training to the petroleum industry. Its founding partners have been providing construction, maintenance and inspection services to members of the petroleum industry for the past 39 years.
The course provided by PASS is driven by regulatory compliance, but it provides meaningful training for even the most experienced operators. The EPA has compiled a set of minimum guidelines that each state must follow when developing training requirements. We also work closely with state governments to ensure that our program meets or exceeds their standards.
Quick Facts About the PASS Training Program
- Web-based solution, with free tech support
- Available 24/7
- Self-paced allows trainees to start and stop the training at their convenience
- Provides cross training of employees by offering a combines A/B curriculum
- Class A/B Training is approved and accepted in 15 states. Class C is approved and accepted in 30 states.
Class A/B training is $179.99 and Class C training is $12.99.
Questions
Contact Kimberly Roberts, NATSO’s member care specialist, at (703) 739-8573 or kroberts@natso.com with questions.
Subscribe to Updates
NATSO provides a breadth of information created to strengthen travel plazas’ ability to meet the needs of the travelling public in an age of disruption. This includes knowledge filled blog posts, articles and publications. If you would like to receive a digest of blog post and articles directly in your inbox, please provide your name, email and the frequency of the updates you want to receive the email digest.
