EPA Proposed UST Regs – Part 1

Operator Training:
The operator training requirements of the proposed federal regulations (proposed regs) mandate what has been required since 2007 by the Energy Policy Act of 2005 (Energy Act). Most states have already implemented (or are in the process of implementing) their own regulations that parrot the proposed regulations and Energy Act guidelines in order to receive federal grant money.
Because most states have already enacted their own operator training regulations, the proposed fed regulations should only be a added burden to UST owners and operators with systems on tribal lands and in states that have not implemented their own rule or their rule fails to meet the federal guidelines.
Here’s the quick and dirty of the proposed regs:>
What are the 3 Classes of Operators:
A Operator – An individual with a broad understanding of the UST regulations capable of making informed decisions about personnel and resources necessary to manage the portfolio of UST systems.
B Operator– An individual with a more specific understanding of the UST systems and the associated regulations, maintenance, and testing. Manages the day-to-day compliance and maintenance of one or more UST Systems.
C Operator– An individual capable of responding to emergencies or alarms resulting from the UST systems. At least one C Operator must be present at all times while the UST systems are operational. (There are special requirements for card-lock or unmanned locations).
Where can I get the training:
A/B Operator Training. States have varying requirements for operator certification and testing from 3rd party online and classroom curriculums, to implementing agency provided curriculums, to the International Code Council curriculum.
C Operator Training. C Operators can complete the same curriculums described for A/B operators, and can also be trained by the UST owner/operator’s designated A or B operator.
The proposed reg allows for “designated operator contractors”, which are 3rd party companies like 7G who take on the Operator A and/or B responsibility for a contracted rate. C operators must be employees.
When do I need to have the training completed (if the proposed regs go through):
You should refer to your state’s rule and implementation schedule (or contact 7G). The proposed reg would institute a tiered implementation schedule based on the age of the USTs present at the facility. Once the schedule ran, A/B operators would need to be trained within 30 days of taking on the responsibility. C operators would need training before they could start.
How do I prove that I have completed the trainings?
You must maintain documents to identify all operators by class and demonstrate the training (or retraining) via a list with names, operator class, date of assumed duties, date of training, and date of any retraining. The records must be kept for 3 years.
All in all the Operator Training regulations should not be a surprise to most. However, while most UST owners/operators have certified an A and B operator, they have not fully implemented a proper training and tracking plan for their C Operators. Due to the high turnover rate of the position corresponding to a C Operator, this requirement could pose a significant burden if the regulation goes through and is actually enforced.
For further information and for links to the federal regulations visit the 7G website Here.
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