Underground Storage Tank Program Grant Guidelines Operator Training 

_________________________________________________________________________________________________ 

Grant Guidelines To States 

For Implementing The 

Operator Training Provision 

Of The Energy Policy Act Of 2005 

U.S. Environmental Protection Agency 

Office of Underground Storage Tanks 

Washington, D.C. 20460 

www.epa.gov/oust 

August 2007 

EPA-510-R-07-005 
Underground Storage Tank Program Grant Guidelines Operator Training 

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Contents 

 

Overview Of Operator Training Grant Guidelines ..................................1

Why Is EPA Issuing These Guidelines? ......................................................................1

What Is In These Guidelines?...................................................................................... 2

When Do These Guidelines Take Effect?.................................................................... 2 

Operator Training Requirements........................................................................ 3

What Is Operator Training? ......................................................................................... 3

What Underground Storage Tank Systems Do These Guidelines Apply To?.............. 3 

How Does A State Implement These Guidelines?....................................................... 3

Who Is Subject To Operator Training Requirements And What Are 

 The Requirements? ................................................................................................ 3

When Must Operators Be Trained? ............................................................................. 7

What Training Approaches Would Meet The Operator Training Requirements?......... 8

How May States Ensure All Operators Are Trained In Accordance With 

 These Guidelines? ..................................................................................9 

What Enforcement Authority Must States Have For Operator Training? ..................... 9

How Will States Demonstrate Compliance With These Guidelines? ........................... 9

How Will EPA Enforce States' Compliance With The Requirements In These 

 Guidelines?........................................................................................................... 10 

For More Information About The Operator Training 

Grant Guidelines..................................................................................................... 11

Background About The Energy Policy Act Of 2005 ................................................... 11

Appendix: The Three Operator Classes At A Glance........................................A-1

 

 
Underground Storage Tank Program Grant Guidelines Operator Training 

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Overview Of Operator Training Grant Guidelines

Why Is EPA Issuing These Guidelines? 

 The U.S. Environmental Protection Agency (EPA), in consultation with states, 

developed these grant guidelines as required by the operator training provision in 

Section 9010(a) of the Solid Waste Disposal Act (SWDA), enacted by the Underground 

Storage Tank Compliance Act, part of the Energy Policy Act of 2005 signed by 

President Bush on August 8, 2005. 

 Section 1524 of the Energy Policy Act amends Subtitle I of the Solid Waste 

Disposal Act by adding Section 9010. Section 9010 requires EPA to publish guidelines 

that specify training requirements for three classes of operators: 

 

• Persons having primary responsibility for on-site operation and maintenance 

of underground storage tank systems. 

• Persons having daily on-site responsibility for the operation and maintenance 

of underground storage tank systems. 

• Daily, on-site employees having primary responsibility for addressing 

emergencies presented by a spill or release from an underground storage 

tank system. 

Section 9010(a)(2) requires EPA to consider: 

• State training programs in existence when the guidelines are published. 

• Training programs that are being used by tank owners and operators as of 

August 8, 2005. 

• The high turnover rate of tank operators and other personnel. 

• The frequency of improvement in underground storage tank equipment 

technology. 

• The business in which tank operators are engaged. 

• The substantial differences in the scope and length of training needed for the 

three classes of operators. 

• Such other factors as EPA finds necessary to carry out Section 9010. 

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Section 9010(b)(2) also requires each state receiving Subtitle I funding (hereafter 

referred to as “state”), to develop state-specific training requirements that: 

• Are consistent with EPA’s guidelines. 

• Are developed in cooperation with tank owners and operators. 

• Consider training programs implemented by tank owners and operators. 

• Are appropriately communicated to tank owners and operators. 

In addition, Section 9010(c) requires that all persons who are subject to the 

operator training requirements specified in these guidelines must: 

• Meet the state-specific training requirements. 

• Repeat applicable requirements if the tank for which they have primary daily 

on-site management responsibilities is determined to be out of compliance 

with a requirement or standard of 40 CFR 280 or a requirement or standard of 

a state program approved under Section 9004. 

EPA’s Office of Underground Storage Tanks (OUST) is issuing these grant 

guidelines to establish the minimum requirements a state receiving Subtitle I funding 

must meet in order to comply with the operator training provisions of the Energy Policy 

Act. 

What Is In These Guidelines? 

 These guidelines describe the minimum requirements a state’s underground 

storage tank (UST) program must contain in order for a state to comply with the Section 

9010 requirements for Subtitle I funding. These guidelines include: a description of the 

classes of operators; required training for each class of operator; deadlines when 

operator training is required; and examples of acceptable state approaches to operator 

training. 

 

When Do These Guidelines Take Effect? 

 These guidelines are effective August 8, 2007. 

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Operator Training Requirements 

What Is Operator Training? 

Underground storage tank operator training means any program that meets the 

requirements of these guidelines. Such a program is designed to ensure knowledge 

regarding operating and maintaining underground storage tank systems. 

What Underground Storage Tank Systems Do These Guidelines Apply To? 

These guidelines apply to underground storage tank systems regulated under 

Subtitle I, except those excluded by regulation at 40 CFR Part 280.10(b) and those 

deferred by regulation at 40 CFR 280.10(c). 

How Does A State Implement These Guidelines? 

A state implements these guidelines by: 

• Requiring operator training for all operators in each class. 

• Developing state-specific operator training requirements consistent with 

EPA’s guidelines by August 8, 2009. State-specific operator training 

requirements must: 

 Be developed in cooperation with tank owners and operators; 

 Take into consideration training programs implemented by tank owners 

and tank operators; and 

 Be appropriately communicated to tank owners and operators. 

• Establishing a procedure to identify individuals who are required to be trained 

under the operator training requirements specified in these guidelines. 

• Ensuring all operators are trained in accordance with these guidelines. 

States may choose to be more stringent than these minimum requirements. 

Who Is Subject To Operator Training Requirements And What Are The 

Requirements? 

For purposes of implementing the operator training requirements, these 

guidelines establish three classes of operators identified as Class A, Class B, and Class 

C. Each underground storage tank system or group of underground storage tank 

systems at a facility must have a Class A, Class B, and Class C operator designated. 

All individuals designated as a Class A, B, or C operator must, at a minimum, be trained 

according to these guidelines. Separate individuals may be designated for each class 

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of operator described above or an individual may be designated to more than one of the 

above operator classes. An individual who is designated to more than one operator 

class must be trained in each operator class for which he or she is designated. 

Because an individual may be designated for more than one operator class, states may 

allow a training approach that encompasses training for more than one operator class. 

States must establish a procedure to identify individuals who are required to 

meet the operator training requirements specified in these guidelines. For example, a 

state may accomplish this by requiring that underground storage tank system owners or 

operators identify, for each underground storage tank system or group of underground 

storage tank systems at a facility, at least one name for each class of operator outlined 

in these guidelines. 

These guidelines in no way relieve the owner or operator, as defined in 40 CFR 

280, from any legal responsibility mandated by the federal underground storage tank 

regulations or requirements of a state underground storage tank program approved by 

EPA under SWDA Section 9004. 

There may be occasions when a Class A, Class B, or Class C operator will not 

be present at the facility. For example, operators are frequently not present at 

unmanned facilities, such as emergency generators at telecommunication towers and 

card lock/card access facilities. However, these operators are still responsible for 

operation and maintenance activities or responding to emergencies and must be trained 

according to these guidelines. 

 

To assist states in identifying responsible individuals to be trained pursuant to 

these guidelines, the following sections characterize, in general terms, each class of 

operator. These sections also identify general training requirements pertaining to 

operating and maintaining underground storage tank systems. See Appendix (The 

Three Operator Classes At A Glance) which describes the operator classes and the 

objectives of training requirements. States must further specify training for each 

individual class of operator by developing state-specific training requirements. 

Class A Operator 

 A Class A operator has primary responsibility to operate and maintain the 

underground storage tank system. The Class A operator’s responsibilities include 

managing resources and personnel, such as establishing work assignments, to achieve 

and maintain compliance with regulatory requirements. 

In general, this individual focuses on the broader aspects of the statutory and 

regulatory requirements and standards necessary to operate and maintain the 

underground storage tank system (i.e., 40 CFR 280 or requirements of a state 

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underground storage tank program approved by EPA under SWDA Section 9004). For 

example, this individual typically ensures that appropriate individual(s): 

• Properly operate and maintain the underground storage tank system. 

• Maintain appropriate records. 

• Are trained to operate and maintain the underground storage tank system and 

keep records. 

• Properly respond to emergencies caused by releases or spills from 

underground storage tank systems at the facility. 

• Make financial responsibility documents available to the underground storage 

tank implementing agency as required. 

At a minimum, the Class A operator must be trained in the following: 

• A general knowledge of underground storage tank system requirements so he 

or she can make informed decisions regarding compliance and ensure 

appropriate individuals are fulfilling operation, maintenance, and 

recordkeeping requirements and standards of 40 CFR 280 or requirements 

and standards of a state underground storage tank program approved by 

EPA under SWDA Section 9004 regarding: 

 Spill prevention 

 Overfill prevention 

 Release detection 

 Corrosion protection 

 Emergency response 

 Product compatibility 

• Financial responsibility documentation requirements. 

• Notification requirements. 

• Release and suspected release reporting. 

• Temporary and permanent closure requirements. 

• Operator training requirements. 

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Class B Operator 

A Class B operator implements applicable underground storage tank regulatory 

requirements and standards (i.e., 40 CFR 280 or requirements of a state underground 

storage tank program approved by EPA under SWDA Section 9004) in the field. This 

individual implements day-to-day aspects of operating, maintaining, and recordkeeping 

for underground storage tanks at one or more facilities. For example, this individual 

typically monitors, maintains, and ensures: 

• Release detection method, recordkeeping, and reporting requirements are 

met. 

• Release prevention equipment, recordkeeping, and reporting requirements 

are met. 

• All relevant equipment complies with performance standards. 

• Appropriate individuals are trained to properly respond to emergencies 

caused by releases or spills from underground storage tank systems at the 

facility. 

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. 

States may require either site-specific operator training, which is focused only on 

equipment used at the underground storage tank facility, or broader training regarding 

regulatory requirements that, at a minimum, encompass the following: 

• Components of underground storage tank systems. 

• Materials of underground storage tank system components. 

• Methods of release detection and release prevention applied to underground 

storage tank components. 

• Operation and maintenance requirements of 40 CFR 280 or requirements of a 

state underground storage tank program approved by EPA under SWDA 

Section 9004 that apply to underground storage tank systems and include: 

 Spill prevention 

 Overfill prevention 

 Release detection 

 Corrosion protection 

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 Emergency response 

 Product compatibility 

• Reporting and recordkeeping requirements. 

• Class C operator training requirements. 

Class C Operator 

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. This individual notifies the Class B or Class A 

operator and appropriate emergency responders when necessary. Not all employees of 

the facility are necessarily Class C operators. This individual typically: 

 

• Controls or monitors the dispensing or sale of regulated substances, or 

• Is responsible for initial response to alarms or releases. 

At a minimum, the Class C operator must be trained to: 

• Take action in response to emergencies (such as, situations posing an 

immediate danger or threat to the public or to the environment and that 

require immediate action) or alarms caused by spills or releases from an 

underground storage tank system. 

 

When Must Operators Be Trained? 

 States must ensure that Class A, Class B, and Class C operators are trained 

according to state-specific training requirements by August 8, 2012, which is three years 

after the date states are required to develop state-specific training requirements. A 

state may want to establish a schedule for phasing in the training over this time. 

After August 8, 2012, states must require operators be trained as follows: 

• Class A and Class B operators must be trained within 30 days or another 

reasonable period specified by the state, after assuming operation and 

maintenance responsibilities at the underground storage tank system. 

 

• Class C operators must be trained before assuming responsibility for 

responding to emergencies. 

If a state determines an underground storage tank system is out of compliance, 

appropriate operator(s) must be retrained. States may determine whether both Class A 

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and Class B operators are retrained, or if only one class of operator (either Class A or 

Class B) is retrained. At a minimum, an underground storage tank system is out of 

compliance if the system: 

• Does not meet EPA’s Significant Operational Compliance requirements for 

release prevention and release detection measures identified at: 

http://www.epa.gov/oust/cmplastc/soc.htm; or 

• Is not in significant compliance with other requirements, such as financial 

responsibility, as determined by the state. 

 

Operators must be retrained within a reasonable time frame established by the 

state. At a minimum, retraining must include training of the areas determined not in 

significant compliance. States requiring at least annual operator training that covers all 

operator class requirements would meet retraining requirements. 

 

What Training Approaches Would Meet The Operator Training Requirements? 

 

 Operator training must evaluate operator knowledge of the minimum training 

requirements described for each class of operator in these guidelines. 

 The following is a list of acceptable approaches to meet training requirements 

stated in these guidelines: 

• An operator training program conducted or developed by the state or by a 

third party that has received prior state1 approval. The program may include 

in-class, on-line, or hands-on training. Such a program must include an 

evaluation of operator knowledge. Examples include testing, practical 

demonstration, or other tools determined as acceptable by the state. 

 

• An appropriately administered and evaluated verification of operator 

knowledge (i.e., examination). This determination must be accomplished 

through an operator examination designed to measure operator knowledge as 

required in these guidelines. The state or a third party acceptable to the state 

may administer this examination. The examination process must be 

acceptable to the state and reasonably determine the person tested has the 

necessary knowledge and skills to be considered competent to operate 

underground storage tanks. 

• For Class C operator training, the state may accept training conducted by a 

trained Class A or Class B operator. 

 

1 States might need to establish criteria to determine the suitability of any training provider or curriculum of training courses

provided.

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• To address operators responsible for underground storage tank systems in 

multiple states, states may develop a program that accepts operator training 

verification from other states. 

• Any combination of the above listed operator training approaches or 

comparable training approaches recognized by the state. 

How May States Ensure All Operators Are Trained In Accordance With These 

Guidelines? 

States must have a system in place for ensuring all operators are trained in 

accordance with these guidelines. The following are some examples for meeting this 

requirement. 

 

• Require owners or operators maintain records documenting the training 

received for all Class A, Class B, and Class C operators either: at the 

underground storage tank site and immediately available for inspection by 

the implementing agency; or at a readily available alternative site and be 

provided for inspection to the implementing agency upon request. 

• Require owners or operators report Class A, Class B, and Class C operator 

compliance to the implementing agency. 

What Enforcement Authority Must States Have For Operator Training?

At a minimum, states must have comparable enforcement authorities for their 

operator training requirements as they have for current underground storage tank 

requirements. 

How Will States Demonstrate Compliance With These Guidelines? 

After August 8, 2009, and before receiving future grant funding, states must 

provide one of the following to EPA: 

• For a state that has met the requirements for operator training, the state must 

submit a certification indicating that the state meets the requirements in the 

guidelines. 

• For a state that has not yet met the requirements for operator training, the 

state must provide a document that describes the state’s efforts to meet the 

requirements. This document must include: 

 A description of the state’s activities to date to meet the requirements in 

the guidelines; 

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 A description of the state’s planned activities to meet the requirements; 

and 

 The date by which the state expects to meet the requirements. 

EPA may verify state certifications of compliance through site visits, record 

reviews, or audits as authorized by 40 CFR Part 31. 

 

How Will EPA Enforce States’ Compliance With The Requirements In These 

Guidelines? 

As a matter of law, each state that receives funding under Subtitle I, which would 

include a Leaking Underground Storage Tank (LUST) Cooperative Agreement, must 

comply with certain underground storage tank requirements of Subtitle I. The Agency 

will establish terms and conditions on grants and cooperative agreements for 

underground storage tank activities to require compliance with applicable requirements 

as a condition of funding. EPA will address noncompliance with these terms and 

conditions by utilizing EPA's grant enforcement authorities under 40 CFR Part 31.43, as 

necessary and appropriate. 

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For More Information About The 

Operator Training Grant Guidelines 

Visit the EPA Office of Underground Storage Tanks web site at www.epa.gov/oust or call 703-603-9900. 

Background About The Energy Policy Act Of 2005

On August 8, 2005, President Bush signed the Energy Policy Act of 2005. Title XV, Subtitle B of this act 

(titled the Underground Storage Tank Compliance Act) contains amendments to Subtitle I of the Solid Waste Disposal 

Act – the original legislation that created the underground storage tank (UST) program. These amendments 

significantly affect federal and state underground storage tank programs, will require major changes to the programs, 

and are aimed at reducing underground storage tank releases to our environment. 

The amendments focus on preventing releases. Among other things, they expand eligible uses of the 

Leaking Underground Storage Tank (LUST) Trust Fund and include provisions regarding inspections, operator 

training, delivery prohibition, secondary containment and financial responsibility, and cleanup of releases that contain 

oxygenated fuel additives. 

Some of these provisions require implementation by August 2006; others will require implementation in 

subsequent years. To implement the new law, EPA and states will work closely with tribes, other federal agencies, 

tank owners and operators, and other stakeholders to bring about the mandated changes affecting underground 

storage tank facilities. 

To see the full text of this new legislation and for more information about EPA’s work to implement the 

underground storage tank provisions of the law, see: http://www.epa.gov/oust/fedlaws/nrg05_01.htm 

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Appendix: The Three Operator Classes At A Glance 

Class A Operator Class B Operator Class C Operator 

Who fits this class 

of operator? 

The individual who 

generally focuses on 

the statutory and 

regulatory 

requirements related 

to operating and 

maintaining the 

underground storage 

tank system 

The individual who is 

generally 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 

The individual who 

is generally the first 

line of response to 

events indicating 

emergency 

conditions or 

responding to 

alarms 

What is the objective 

of the training 

requirements? 

Ensure broad 

knowledge of 

regulatory 

requirements 

Ensure in-depth

knowledge of 

implementing regulatory 

requirements 

Ensure knowledge 

of actions to take in 

the event of a leak 

or other emergency 

Class B 

Depth of Training 

Breadth of Training 

Class A 

 Class C 

A-1