UST Operator Training Requirements Under Energy Policy Act

The Energy Policy Act of 2005 required EPA to develop training guidelines for three distinct classes of operators who operate and maintain underground storage tank (UST) systems. States receiving funding under Subtitle I of the Solid Waste Disposal Act are then required to develop state-specific training requirements consistent with EPA's guidelines no later than August 8, 2009.

The EPA guidelines for UST training recognize three classes of operator:

Class A Operator has primary responsibility to operate and maintain the underground storage tank system, including managing resources and personnel to achieve and maintain compliance with regulatory requirements. At a minimum, the Class A operator must be trained and have general knowledge of UST system requirements so he or she can make informed decisions regarding compliance and ensure appropriate individuals are fulfilling operation, maintenance, and recordkeeping requirements and UST standards and regulatory requirements

A 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. Compared with training for the Class A operator, training for the Class B operator will provide a more in-depth understanding of operation and maintenance aspects, but may cover a more narrow breadth of applicable regulatory requirements.

A 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 underground storage tank systems. At a minimum, the Class C operator must be trained to take action in response to emergencies or alarms caused by spills or releases from an underground storage tank system.

All States must ensure all three classes of operators are trained according to state-specific training requirements by August 8, 2012.

Caltha LLP provides training to comply with a number of regulatory programs, including SWPPP Training, SPCC Training, RCRA Training and Hazard Communication Training.

For further information contact Caltha LLP at
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