Operator Training
“Closing the gap in coverage and ensuring all operators are trained according to their level of responsibility, as designated as Class A, B, or C”.
The proposed federal regulations would require UST owners and operators to designate three operator classes with respective levels of responsibility for maintaining UST system compliance.
However, the Energy Policy Act of 2005 already requires the states to develop state-specific training requirements for UST system operators as a condition of receiving federal grant money. EPA issued grant guidelines that provide minimum requirements for state operator training programs, and most have adopted them verbatim.[i]
Florida is in the final stages of rule development, which requires Operator Training designation according to the federal guidelines by August 6, 2015.[ii]
The federal operator training requirements, if changed as proposed, will primarily apply to UST systems: 1) on tribal lands or 2) where a state fails to meet EPA’s operator training grant guidelines or get state program approval.[iii] In EPA’s words, they are “closing the gap in coverage and ensuring all operators are trained according to their level of responsibility, as designated as Class A, B, or C.”[iv]
Thus, the first place you should look for Operator Training requirements is the regulation in the state(s) where you operate. If you are not familiar with your state’s operator training requirements, feel free to email 7G and we will be happy to discuss them with you.
As mentioned, the EPA Proposed Regulations parrot the Energy Policy Act guidelines, which in turn have been adopted by most states. Here’s a quick Who, When, and How of the proposed regulations.
Who – As the owner or operator of a UST, you must designate an A, B, and C Operator for each tank or facility (group of tanks).
Class A Operator— The buck stops at the Class A Operator.
Responsibilities: He/She must make informed decisions regarding compliance and determine whether appropriate people are fulfilling the operation, maintenance, and recordkeeping requirements for UST systems. He/She typically manages resources and personnel associated with the entire portfolio of regulated facilities, whether there is 1 or there are 1400.
Knowledge/Training: The Class A Operator must be knowledgeable (and trained) in 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, and training requirements for Class B and C operators.
Class B Operator— Think of the Class B Operator as the field general.
Responsibilities: He/She is burdened with the day-to-day responsibility for implementing the applicable regulations like permitting, release detection, testing, recordkeeping, visual inspections, and maintenance for each facility.
Knowledge/Training: The Class B operator must be knowledgeable and trained in the operation and maintenance of a UST system. This includes knowledge regarding 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 but should be specific to a Class B operator’s facility or facilities.
Class C Operator — The Class C Operator represents the boots on the ground first responder.
<strong>Responsibilities: He/She must be able to address emergencies presented by a spill or release from an UST system and respond to alarms indicated by the facility’s ATG or equivalent alarm conditions where no ATG is present.
Knowledge/Training: The Class C Operator must be knowledgeable and trained in the procedures and protocols for emergency response and alarm conditions at a facility. He/She should be able to respond to small spills and releases, know when to hit the emergency stop button, and/or call in support in the event of an emergency. By rule, Class C Operators may be trained generally, but in practice should be trained specifically about their facility so that they can respond appropriately, and even anticipate issues before they become an emergency.
When- In states with an operator training regulation, owners and operators should refer to their state’s existing implementation requirements and deadlines, or contact 7G. If the proposed regulation will be your first exposure to operator training, the following implementation schedule is projected to apply:
| Criteria | Date Required |
| One or more USTs at the facility were installed on or before 12/22/1988 | One year after effective date of rule. |
| No USTs at the facility were installed on or before 12/22/1988 and at least one UST at the facility was installed on or before 12/22/1998 | Two years after effective date of rule. |
Once the implementation schedule above has run, Class A and B operators are trained within 30 days of assuming duties. Designated Class C operators must be trained before assuming their duties.
Retraining— If your facility is determined to be out of compliance by the state or implementing agency, the Class A and B operators have to take and document a retraining within 30 days that, at minimum, must cover the areas deemed out of compliance.
How – The actual training must be approved by the implementing agency and demonstrated through accessible records. There are several ways to accomplish the training.
Types of Training: The proposed regulation is vague as to where and how you can get approved training, except to reference deference to the implementing agency. If the proposed regulation follows the same process as the Energy Policy Act grant guidelines, then one or more of the options will be available.
A & B Operators
- Online: There are multiple providers of online operator training with varying costs.
- Agency provided: Some states require that you take their specific training, which may be online or in a class.
- ICC: Some states require the International Code Council test and curriculum, which requires an in person, multiple-choice exam.
- Classroom: There are multiple states that have approved classroom/lecture style training.
C Operators
- Online: There are multiple providers of online operator training with varying costs.
- Classroom: There are multiple states that have approved classroom/lecture style training.
- In house: A or B Operators can establish training protocol to train and evaluate Class C Operators.
NOTE: Designated Operator Contractor – EPA will allow UST owners and operators to designate contractors as their Class A and B operators as long as they are responsible for all areas required in the training for the class of operator designated.[v]
Demonstration of Training: The proposed regulations will require (like the Energy Policy Act grant guidelines) that UST owners and operators “maintain documents that identify all operators by class and demonstrate that training or retraining, if necessary.” The proposed rule is specific to require the records be kept for three years and as long as the operator is designated, and must include[vi]:
- A list of designated Class A, B, and C operators for each UST facility, including the names, operator class trained, date assumed duties, date completed initial training, and date of any retraining. These records must be maintained for all Class A, B, and C operators at the facility for the previous three years.