• Background and requirements
• Deadlines
• State status
• Q&A - Meeting UST operator training requirements
• Association of State and Territorial Solid Waste Management Officials (ASTSWMO) resources
• Grant guidelines

Background and Requirements

Title XV, Section B of the Energy Policy Act of 2005 amends Subtitle I of the Solid Waste Disposal Act, the original legislation that created the underground storage tank (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 EPA, in coordination with states, must develop training guidelines for three distinct classes of operators who operate and maintain federally regulated underground storage tank systems.

States receiving funding under Subtitle I shall develop state-specific training requirements consistent with EPA's guidelines. The state-specific training requirements must:

• Be developed in cooperation with tank owners and operators;
• Take into consideration training programs implemented by owners and operators; and
• Be appropriately communicated to tank owners and operators.

Operator Training – Minimum Training Requirements and Options
In 2015, EPA revised the underground storage tank (UST) regulations which includes minimum training requirements for owners and operators of UST systems.

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Deadlines

By August 8, 2009, states receiving money under Subtitle I of the Solid Waste Disposal Act were required to develop state-specific training requirements consistent with EPA's guidelines. By August 8, 2012, states were required to ensure all three classes of operators are trained according to state-specific training requirements.

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State Status

As of 2015, two states and one territory are working toward meeting EPA's operator training grant guidelines. The remaining 45 states and the District of Columbia have developed state-specific training requirements consistent with EPA's guidelines.

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Q&A - Meeting UST Operator Training Requirements

• What is underground storage tank operator training?
• When must designated operators of UST systems meet operator training requirements?
• Who must be trained and what must the training cover?
• Must operators repeat training?
• What documentation will owners and operators need to maintain?
• EPA proposed adding operator training requirements to the federal UST regulation.  How will the federal operator training requirements, if changed as proposed, affect federally regulated USTs in the United States?

1. What is underground storage tank operator training?
   
   The Energy Policy Act of 2005 required EPA to publish guidelines that specify training requirements for three classes of UST system operators. State and territorial UST programs (states) receiving money from the federal Leaking Underground Storage Tank Trust Fund are required to develop state-specific operator training requirements that meet EPA’s grant guidelines.  Per EPA’s guidelines, states will require UST systems have designated UST system operators (designated operators).
    
2. When must designated operators of UST systems meet operator training requirements?
   
   Designated operators must be trained according to individual state requirements. While EPA required an August 8, 2012 deadline on states, the only deadline that is currently relevant to UST system owners and operators is the regulatory compliance deadline established by their state.  Some states established earlier training deadlines. Many states adopted the August 8, 2012 deadline. Some states still need to finalize their requirements and will have later compliance dates. In those states without final requirements, operators do not need to meet training requirements until their state issues final requirements. Owners and operators should check with the state where their USTs are located to determine the date of compliance.
    
3. Who must be trained and what must the training cover?
   
   According to EPA’s guidelines, states must identify three classes of operators and minimum requirements for each class. The three operator classes and objectives of training described below are based on EPA’s guidelines. Owners and operators should check with the state where their USTs are located to determine state-specific operator class descriptions and applicable training requirements.
   • Class A operators - have primary responsibility to operate and maintain the UST system and typically manage resources and personnel to achieve and maintain compliance.  Training for Class A operators should allow the operator to make informed decisions regarding compliance with regulatory requirements.
      
   • Class B operators - have daily responsibility for on-site operation and maintenance of UST systems.  Training for Class B operators should provide an in-depth understanding of operation and maintenance aspects of UST systems.
      
   • Class C operators - are daily on-site employees who are generally the first line of response to events indicating emergency conditions.  Training should allow the Class C operator to take appropriate action in response to UST related emergencies or alarms caused by spills or releases from an UST system.
      
4. Must operators repeat training?
   
   EPA required states specify retraining requirements for designated operators. States have addressed this differently. Some states require periodic refresher training, while others require targeted specific retraining on those areas where a compliance violation is identified. Owners and operators should check with the state where their USTs are located to determine the state’s retraining requirements.
    
5. What documentation will owners and operators need to maintain?
   
   Depending on a state’s operator training requirements, legally responsible UST system owners and operators may be required to identify appropriately designated operators, as well as verify training in line with state requirements.  Owners and operators should check with the state where their USTs are located for state-specific requirements. 
    
6. EPA proposed adding operator training requirements to the federal UST regulation.  How will the federal operator training requirements, if changed as proposed, affect federally regulated USTs in the United States?
   
   The federal operator training requirements, if changed as proposed, will primarily apply to UST systems on tribal lands. In the event a state fails to meet EPA’s operator training grant guidelines or get state program approval, the federal operator training requirements would apply to all UST operators in that state. In those states that meet all requirements of EPA’s operator training grant guidelines, EPA’s proposed implementation dates of the federal operator training requirements do not supersede individual state operator training deadlines. Owners and operators should check with the state where their USTs are located to determine the date of compliance required for completing training requirements established by the state.

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Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Resources

The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) UST Task Force developed the Operator Training Resource Guide (PDF) Exit(83 pp, 1.9 MB, About PDF) which provides information on how states are implementing their operator training program. ASTSWMO also developed a spreadsheet (PDF) Exit(12 pp, 430 K, About PDF) outlining key decisions states made in implementing their program.

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Grant Guidelines

On August 8, 2007, EPA published final grant guidelines for operator training. For more information, contact Tim Smith at smith.timr@epa.gov or (202) 564-0643.

For assistance with accessibility for the PDF, please email Sharon Fredericks (fredericks.sharon@epa.gov).

• Grant Guidelines to States for Implementing the Operator Training Provision of the Energy Policy Act of 2005, EPA-510-R-07-005, August 2007 (PDF)(14 pp, 100 K)