By Jay Collert, CHMM, CET
For owners of underground storage tanks (UST), a new training requirement is sure to cause some pain for those who wait too long to comply with it. While the Energy Policy Act of 2005 dispensed lots of tax credits for energy efficiency, it also created many new requirements for owners of USTs. The training requirement section may prove to be the one that hurts the most.
Simply, the Act requires all owners of USTs to have individuals trained to one or more of three levels (Class A, B, and C) depending on their responsibilities. Class A individuals generally focus on statutory and regulatory requirements related to operating and maintaining the underground storage tank system. Class B personnel are responsible for field implementation of applicable underground storage tank regulatory requirements and implements day-to-day aspects of operating, maintaining, and recordkeeping for USTs at one or more facilities. Class C folks are the first line of response to events indicating emergency conditions or responding to alarms.
Deadlines set by the EPA for the training are as follows:
- Aug. 8, 2007: EPA must issue and make available to the public the operator training guidelines.
- Aug. 8, 2009: States receiving funding under Subtitle I of the Solid Waste Disposal Act must develop state-specific training requirements consistent with EPA’s guidelines.
- Aug. 8, 2012: States ensure all three classes of operators are trained according to state-specific training requirements.
To further complicate matters, some states are only allowing state-certified or state-recognized organizations to provide compliant training. New Mexico is an example of a state that requires training providers to apply for status. To read New Mexico’s requirements, go to: www.nmenv.state.nm.us/ust/documents/OperatorTrainingRequirementsforPetroleumStorageTankSystems.pdf.
To read more about the EPA guidelines, go to: www.epa.gov/OUST/fedlaws/otgg_final080807.pdf. You’ll need to contact your individual state to determine what its requirements will be and to ensure you meet the deadline.
About the Author: Jay Collert is a nationally recognized environmental trainer and consultant with the Aarcher Institute of Environmental Training LLC, based in Houston, TX. Since 1994, he has focused on helping companies understand and comply with the complexities of environmental regulations. Contact: 281-256-9044, [email protected] or www.aarcherinstitute.com
