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One of the greatest hazards that underground storage tanks (USTs) pose is leaking petroleum or other hazardous substances into groundwater, which serves as the source of drinking water for nearly half of the United States. The Environmental Protection Agency (EPA) established the first UST regulations in 1988 to minimize the hazards. In 2015, EPA strengthened the regulations with multiple revisions, one of which established minimum training requirements for designated Class A, Class B, and Class C operators.
All owners and operators of UST systems must have at least one Class A and one Class B operator for each UST or group of USTs at a facility.
The federal regulations for USTs apply only to systems storing either petroleum or the hazardous substances defined in Section 101(14) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980, excluding any substance regulated as a hazardous waste under Subtitle C.
All UST owners and operators must, at a minimum, meet the federal 2015 UST regulations. Some states have stricter regulations that UST owners and operators must meet. As of September 2021, all 50 states and the District of Columbia have incorporated the revised 2015 regulations into their UST regulations.
Subtitle I of the Solid Waste Disposal Act allows states to operate UST programs in lieu of the federal UST program through the state program approval (SPA) regulation. UST systems in states that aren’t part of the SPA program must meet the federal regulations.
All underground storage tank (UST) system owners and operators must:
Class A operators must either be trained in or pass a comparable examination of general knowledge about the purpose, methods, and function of:
Class B operators must be trained in or pass a comparable examination of either:
They must know the purpose, methods, and function of:
Class C operators must either:
They must know how to take appropriate actions (including notifying appropriate authorities) in response to emergencies or alarms caused by spills or releases when operating USTs.
Evaluations
UST owners and operators must evaluate operators through:
A comparable examination must, at a minimum, test the knowledge of Class A, Class B, or Class C operators in accordance with the applicable requirements of 40 CFR 280.242.
At a minimum, evaluate each operator to determine whether they have the required knowledge and skills:
Training timelines
Retraining requirements
When the implementing agency determines that UST operators are out of compliance, Class A and Class B operators must be retrained in or take a comparable examination of, at a minimum, the area(s) out of compliance. The training or examination must:
However, if Class A and Class B operators complete annual refresher training, retraining is not required.
Recordkeeping requirements
Owners and operators of UST systems must: