1

MEMORANDUM | 30 December 2008

TO Cho-Yi Kwan and Timothy Roberts, U.S. EPA

FROM Cynthia Manson and Aaron Kamholtz, Industrial Economics, Inc.

SUBJECT

Draft Methodology for Assessing Cost-Effectiveness of Operator Training Options

WA 1-19, Task 4

The Environmental Protection Agency's (EPA's) Office of Underground Storage Tanks 

(OUST) is currently exploring options related to federal rulemaking action(s) associated 

with implementing provisions of Title XV, Subtitle B of the Energy Policy Act of 2005 

(entitled the Underground Storage Tank Compliance Act of 2005). The Energy Policy 

Act expands eligible uses of the Leaking Underground Storage Tank (LUST) Trust Fund 

and includes provisions regarding inspections, operator training, delivery prohibition, 

secondary containment and financial responsibility, and cleanup of releases that contain 

oxygenated fuel additives.

In addressing operator training, EPA in August 2007 developed and published “Grant 

Guidelines to States for Implementing the Operator Training Provision of the Energy 

Policy Act of 2005.” These guidelines explain how states receiving Subtitle I funding 

must implement the operator training provisions in Section 9010 of the Solid Waste 

Disposal Act. The guidelines outline different levels of training required for three classes 

of operators, and provide information on topics such as retraining.

EPA is currently considering options for establishing regulations related to training for 

operators of underground storage tanks (USTs). To assist EPA in this process, Industrial 

Economics, Incorporated (IEc) has developed an initial comparative overview of the 

relative cost-effectiveness of different operator training mechanisms. This initial 

overview considers a range of variables including the type of operator being trained, 

options for live and remote instruction, verification techniques, and program design and 

implementation costs.

The memorandum first generally discusses cost-effectiveness in the context of operator 

training, and briefly discusses the link between an effective operator training scheme and 

changes in human health and ecological risk. We then frame the analysis with a brief 

overview of the scope of EPA’s operator training requirements, and a summary of the 

variables that are most important in measuring program costs and effectiveness. 

BACKGROUND AND 

INTRODUCTION 
2

The memorandum next provides an overview of training options and preliminary cost 

estimates, including both unit costs for operators to obtain training and a brief discussion 

of costs associated with curriculum design and implementation. The training options and 

associated costs are presented in graphic form for each class to provide initial insights 

into cost-effectiveness and implementation issues. Finally, the memorandum presents 

initial qualitative conclusions about the relative cost-effectiveness of different program 

options, with a brief discussion of limitations and areas for additional examination. 

Although this memorandum contains preliminary information on both unit (per capita and 

per class) costs of obtaining training and also on course and test design costs, our 

assessment generally represents a qualitative comparison of different options, in part 

because we have been unable to identify state data that tracks the impacts of existing 

operator training options. As a result, the methodology and data presented here should be 

considered a preliminary screen, and not a conclusive cost-effectiveness assessment.

The first step in a complete assessment of operator training options is to define “costeffectiveness” in the context of operator training. Ideally, a cost-effective operator 

training program would be designed to ensure the following operational improvements:

A more rapid response to emergencies limiting the severity of potential leaks 

and resulting in potentially less environmental damage.

An improved understanding of statutory and regulatory requirements helping to 

reduce the number of violations.

Improved long-term compliance due to fewer human errors resulting in fewer

avoidable compliance violations. 

These achievements, in turn, improve environmental quality (i.e., reductions in human 

health and ecological risk) by decreasing the number and length of the non-compliance 

incidents that are associated with a higher risk of spills, and by effectively responding to

spills that occur. A cost-effective operator training program is one that will ensure an 

optimal degree of “knowledge regarding operating and maintaining underground storage 

tank systems.”1 Typically, cost-effectiveness is measured in terms of achievement per 

dollar. The option with the highest level of achievement (e.g., the greatest reduction in 

non-compliance incidents) at the lowest cost is the most cost-effective option.

NOTE ON ENVIRONMENTAL IMPACTS ASSOCIATED WITH OPERATOR TRAINING

Because operator training programs are compliance tools designed to support existing 

regulations, they do not provide unique human health or ecological benefits that would 

not occur if all facilities maintained full compliance with existing regulations. As a 

result, their impacts are not incremental to the potential total benefits of the existing 

technical standards under RCRA Subtitle I.2

 

1

“Grant Guidelines to States for Implementing the Operator Training Provision of the Energy Policy Act of 2005.” EPA, August 

2007.

2

 Regulatory impact analyses commonly assume full compliance in assessing the prospective benefits and costs of new or 

revised regulations. 

COSTEFFECTIVENESS AND 

OPERATOR TRAINING
3

However, to the extent that operator training increases actual compliance, training can 

provide measurable benefits related to reduced risk of releases and associated damage. It 

is important, however, to avoid double-counting other benefits estimates in measuring 

operator training benefits. For this reason, at this time we constrain our consideration of 

effectiveness to changes in compliance behavior and do not attempt to estimate changes 

in human health or environmental risk.

EPA’s operator training regulatory requirements are not yet final, but will be designed to 

ensure appropriate training for all employees who are involved in compliance and 

operations at facilities with USTs that are primarily in Tribal Lands and in states that do 

not comply with EPA’s operator training guidelines or chose to not accept Subtitle I 

funding. Consistent with the current guidelines, EPA’s regulation will likely specify

training for three different types of operators. At this time, however, EPA has not yet 

decided who fits into each operator type:

Class A Operator – at least one per company. For each organization that 

owns/operates USTs, EPA will require that at least one operator be trained to 

understand and implement all regulatory requirements, including, for example, 

permitting, financial assurance, facility design and equipment standards, and 

recordkeeping and reporting requirements. 

Class B Operator – at least one per facility. For each facility, EPA will require 

that at least one operator be trained to manage all activities associated with 

operating the UST, including technical standards, filling and dispensing 

procedures and equipment, alarms, and reporting and response protocols.

Class C Employee – varies by facility. EPA will require at least that all 

employees whose work involves UST operations (e.g., cashiers at a gas station

who monitor or run the pumps) be trained in emergency response procedures and 

other basic operations, such as filling and dispensing procedures, as needed.3

Consistent with provisions of the 2005 Energy Policy Act, EPA’s Grant Guidelines 

anticipate that all facilities will provide initial training for employees by 2012. Following 

that date, Class A and Class B operators must be trained within 30 days of hire or within 

a reasonable time frame established by the implementing agency. Class C employees

must be trained before assuming their duties.

4

 

EPA’s Grant Guidelines do not specify the specific content or delivery mechanism (i.e., 

in-person or remote training). 

 

3

Employees who have no role in the sale of gasoline (e.g., staff who work specifically at a co-located deli) do not typically 

require training. 

4 The specific time frame for initial training has yet to be established for EPA’s operator training regularity requirements, but 

we assume that it will be similar in structure to the content of the Grant Guidelines in this regard. Note that regardless of 

when Class A and Class B operators are trained, the owner/operator assumes liability for operations at the time of 

purchase, ensuring an unbroken chain of liability.

ANALYTIC 

FRAMEWORK: KEY 

VARIABLES AND 

ASSUMPTIONS
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With this general framework for the operator training requirements as a basis, this section 

first provides a summary of the key variables that are likely to drive the effectiveness and 

costs of operator training programs. Second, it outlines the main challenges to address 

when choosing an optimal operator training program, and the assumptions we use to help 

reach a conclusion.

VARIABLES AFFECTING TRAINING EFFECTIVENESS AND COST

We first present a general description of the key variables that are likely to drive the 

effectiveness of training by ensuring that useful information is conveyed to training 

participants. The list of variables below has been constructed from several interviews 

with professional trainers who provide training for UST facilities, and State and Tribal 

representatives responsible for implementing training at regulated facilities. The section 

then documents the main variables driving the costs of training options, based on a 

review of the same sources.

Key Effectiveness Variables

The program features of an effective operator training program should have many of the 

following characteristics:

Initial Transfer of Information (i.e., delivery of training course)

A clear, well-focused curriculum. An effective operator training program will 

provide the appropriate material to the target operators and employees. EPA’s 

current guidelines consider a distinct three-tiered structure, with: at least one 

Class A operator per company who must know regulatory and compliance 

requirements; at least one Class B operator per facility who must understand 

equipment function, operational compliance, and response procedures for any 

operational problem; and any number of Class C employees who must 

understand emergency procedures and general operations. The appropriate 

curricula and training approaches will likely differ significantly for each of these 

classes of operator.

High quality instructors. High quality instruction is central to the effectiveness 

of training options. In-person training, which can be highly effective because of 

the opportunity to interact with trainees, is also dependent on the quality of the 

instruction. The extent to which EPA instructors are licensed or certified may 

affect both the cost and effectiveness of training programs. In the absence of 

instructor certification, standardized courses such as those offered on-line by the 

International Code Council could potentially represent a cost-effective option 

because the quality of the instruction is consistent, though interaction is limited.

Opportunity to ask questions. Training for UST operators involves complex 

regulatory requirements and comprehensive understanding of facility operations. 

As a result, the ability of operators to ask questions of instructors will likely 

measurably affect the effectiveness of training. Live instruction provides a 

significant advantage in this respect; to a lesser extent, some remote options may 
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provide opportunities for question and answer. These options include a Webinar 

format or the availability of a helpline for employees and operators. A Webinar 

would allow for a certain degree of interaction between trainer and operator 

during the online course. 

Hands-on training for site-specific information. Since there are many different 

types of equipment in use across the country, when the training required is 

specifically related to the equipment used on site, operators are likely to better 

understand operational requirements if they are able to physically conduct the 

actions and repeat the steps they are learning about.

Verification of Learning

Ensuring Attendance and Testing. An effective training program will include

steps to verify that operators have attended and successfully learned the content 

of the course. A number of methods for verifying identity and testing is

potentially effective, but formal verification is particularly important for remote 

training options where interaction with instructors is limited. 

Retention of Knowledge

Accessible “refresher” training opportunities. The retention of knowledge 

from training over time is imperfect, and in some cases new technologies and 

regulatory practices emerge. Therefore, accessible and regular re-training is 

likely to improve the long-term knowledge and overall performance of operators. 

Key Cost Variables

The costs of a training program include both the costs to the operators to obtain the 

training, and program design and implementation costs (e.g., curriculum development, 

trainer certification). Below, we summarize the key variables that are likely to have the 

biggest impact on the total cost of the operator training program:

Features that Affect Operator Costs

In-Person Instruction: Obtaining in-person instruction, whether on-site training 

provided by a certified trainer or a Class A operator, off-site classroom-based 

training, or “remote” training through a Webinar or similar interface, is typically 

the more expensive option for operators than accessing remote training options 

such as computer- or on-line training without live instruction. Costs for 

obtaining in-person instruction include time away from work, the cost of 

instruction itself, and the cost and time associated with any necessary travel 

(either for the participants or for bringing a trainer on-site). These costs increase 

for more remote facilities and facilities that are very small or sole proprietorships.
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Length of Training Course. Training programs can range in length from less 

than an hour for Class C employees to several days for some comprehensive 

courses offered in recent years. Longer training curricula require more employee 

time away from work and in some cases, more travel costs. Again, these costs 

are likely higher for remote facilities and sole proprietorships. 

Retraining requirements. EPA’s current guidelines require that operators be 

retrained only after a documented compliance issue at a facility. If additional 

retraining or training updates are required (e.g., at fixed intervals), then total 

training costs will increase.

Factors that Affect Program Development and Implementation Costs

Certification of Instructors: An effective system for certifying instructors, 

including EPA staff, professional “third-party” instructors, and company 

representatives (including Class A operators) who can train other employees in 

their organizations, requires the development and implementation of clear 

requirements, methods for ensuring that certified instructors meet those 

requirements, and potentially the costs associated with maintaining a database of 

certified instructors.

Development of Remote Curricula: Development of high quality curricula for 

remote training options (on-line or computer) includes content development, 

programming, beta-testing, material distribution and support, and periodic 

content and programming updates. 

Development and Implementation of Verification Procedures: Particularly 

for remote training, development of a rigorous means of ensuring that operators 

have successfully completed training includes design of tests and verification 

procedures, distribution of materials and support, and, depending on test design, 

maintenance of database information on testing.

CHALLENGES TO ASSESSING COST-EFFECTIVENESS

The variables that affect the costs and effectiveness of training programs are generally 

clear. However, a number of challenges prevent the development of a clear, general costeffectiveness ranking of different program options. One difficulty lies in defining the 

specific options for curriculum design, instructor certification, and retraining and 

ensuring that both curricula and instructors are of high quality. Even assuming that a 

range of well-focused and delivered training options are available to each facility, 

however, other variables affect the specific training options that would be the most costeffective. These include:

Location- Specific Considerations

Facility location may drive up the cost of obtaining training if it is difficult for operators 

to reach testing centers, and too costly to bring trainers out for on-site instruction. 

Unfortunately, remote locations may also have limited access to high-speed Internet 
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which limits some lower-cost options. In contrast, operators in urban areas may have a 

range of low-cost options. In both cases, on-site training by company representatives or 

regulators could provide an attractive option if it is available.

Operator-Level Considerations

Each of the three operator classes specified in EPA’s guidelines requires a different type

of training, suggesting that different training approaches may be most effective for each. 

Specifically, Class A operators required to understand regulatory and compliance 

requirements may benefit most from a classroom environment with opportunities to learn 

from peers. In contrast, Class B operators required to understand operations would most 

likely benefit from on-site, hands-on instruction on the specific equipment that they will 

manage. Finally, Class C employees, though also likely to benefit from hands-on 

instruction, are likely to benefit most from training by a fellow employee (e.g., a Class A 

or B operator) who will also be available for follow-up training and daily operations.

Initial Facility Training and New Operator Training

The most cost-effective options for the initial implementation of training requirements 

may differ from the options that a facility employs for new hires. For example, it may be 

cost-effective to bring a professional trainer on-site to provide initial training to all 

employees at a larger facility. This option is not likely to be cost effective for individual 

employees, particularly high-turnover Class C employees with limited training needs.

ASSUMPTIONS FOR THIS ANALYSIS

While EPA has not yet finalized the parameters of its training requirements, we make the 

following general assumptions in order to frame the discussion of cost-effectiveness.

Individual Training by Operator Class

We assume that EPA will require separate, non-overlapping training for the three classes 

of operator. Class A operators must understand regulatory compliance issues such as 

financial assurance, notification, and facility design and equipment standards. Class B 

operators (who at small facilities may also be Class A operators) will be responsible for 

general operations, and Class C employees are front-line employees (their role is limited 

to initial response to emergency situations).

Preservation of Training Options

Consistent with the Grant Guidelines, our analysis assumes that operators will be able to 

choose from a range of training options; we therefore do not eliminate discussion of 

options that are not universally available (e.g., on-line training). We also assume that 

state programs consistent with current guidance will not require significant revision to be 

compliant with final regulations.
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Geographic Range

In general, we consider training options without specifically assessing geographic 

dynamics; specific options will be more or less attractive based on location. However, 

we do specifically consider issues related to the application of training options on Tribal 

lands.

First-Party and EPA Trainer Options

We assume that all Class A operators must receive training from a professional trainer 

(i.e., third-party training). However, for Class B operators and Class C employees, we 

consider the option that a qualified employee (i.e., a first-party trainer) could provide onsite training. For example, a first-party trainer could be a Class A operator with extensive 

experience and appropriate Class B operator training. We also consider the option that 

EPA inspectors provide training to all classes. We assume that the fully-loaded cost of a 

GS11 inspector would be $117,000 ($56 per hour, $448 per day).5

EPA’s operator training guidelines includes a range of training options for each operator 

class; each option has different features and costs. We briefly outline the different 

options for delivering operator training, and provide preliminary estimates of costs.

To inform our assessment of the cost-effectiveness of existing operator training efforts, 

we reviewed a range of literature and relevant course information, and also spoke with 

several people involved with UST operator training, including professional trainers, state 

personnel involved with implementing and tracking training programs, and Tribal 

representatives involved with training implementation.6

TRAINING OPTIONS 

Exhibit 1 below outlines the range of possible training options currently available for all 

classes of operator; some of these options are more appropriate for specific categories 

than others. We then describe each of these options in more detail, and briefly 

summarize its effectiveness in different contexts.

 

5 Costs calculated based on the 2007 Bureau of Labor Statistics salary for a GS-11 employee, with an applied overhead rate of 

150% to reflect all overhead costs, including benefits, technology and support, and office space). Data available at: 

http://www.bls.gov/oco/cg/cgs041.htm#earnings

6

 Mitch Scheel, OR, personal communication, June 26, 2008; Andrea Zajac, MI, personal communication, June 18, 2008; Ken 

McBride, personal communication, October 8, 2008; Chuck Tillman, personal communication, September 30, 2008; Robert 

Largent, personal communication, October 9, 2008; Ben Thomas, Ben Thomas Associates, Inc. Personal Communication, May 

27, 2008; Klatt, Bruce, The Ultimate Training Workshop Handbook, 1999. McGraw-Hill; and International Code Council, 

“2008 UST/AST Examination Information Bulletin,” Revised May 14, 2008. Accessible at: 

http://www.iccsafe.org/certification/ust-ast/

OVERVIEW OF 

TRAINING OPTION

FEATURES AND 

COSTS
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EXHIBIT 1. AVAILABLE TYPES OF OPERATOR TRAINING

TYPE OF TRAINING GENERAL DESCRIPTION

Hands-On Training: On-site 

(3rd party)

An independent trainer is paid to provide training services to the employees at the location 

on which they work.

Hands-On Training: On-site 

(1st party)

Training provided at the facility by a trained/certified employee within the company for 

other employees.

Hands-On Training: On-site 

(EPA Trainer)

Training is provided on-site by certified EPA personnel. The trainer could be an EPA UST 

inspector with training certification. 

On-site Training: 

Posted notice combined with 

1

st party training

A Class A or B operator posts instructions for Class C operators in an easily visible location 

inside the facility reinforcing materials taught in training course.

Off-site Training:

Classroom

Operators receive training at a location other than the facility at which they work, provided 

by a paid, independent instructor. 

Remote Training: Self-taught

(typically with a test) 

Operators independently use standard materials (hard copy or electronic) to learn 

requirements. Method may include a test providing certification to operate. 

Remote Training: On-line 

(typically with a test)

Employees login to a website and complete an on-line course. Method may include a test 

providing certification to operate.

Opt-Out Test Experienced employees complete a comprehensive test on-line to demonstrate that they do 

not require additional training.

To optimize training effectiveness, EPA could require a specific level (or levels) of 

certification for both third-party and first-party instructors, to ensure that they are familiar 

with the regulations and with the range of existing technologies on site at facilities. Both 

of the first-party and third-party training options have the potential to be highly effective 

given a capable trainer and the appropriate curriculum. 

EFFECTIVENESS OF TRAINING OPTIONS

The appropriateness of training options varies with operator class, because each class has 

different operational requirements. Below we discuss the relative effectiveness of each 

type of training for specific operator classes:

On-site (3rd party): On-site training provided by an independent trainer would

be highly effective for all operator classes. On-site training is likely to include 

both standard materials and site-specific, hands-on instruction. The combination 

of live instructor and relevant hands-on training provides an opportunity for 

participants to ask questions and “practice” skills learning in the training. The 

hands-on aspect of this training may be less critical for Class A operators than for 

other operator classes.

On-site (1st party): On-site training provided by a 1st party trainer is most likely 

to be effective for Class C employees, who require limited, site-specific operating 

information that could be provided by a Class B operator. This is particularly 

reasonable because 1st party trainers are best positioned to train new employees 

in high-turnover positions. In limited cases (e.g., larger companies or Tribal 

organizations with multiple facilities), a 1st party trainer may be able to develop 
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the expertise to provide on-site technical training to Class A or Class B operators

as well as Class C employees. However, in many cases Class B and Class A 

operators could benefit from an external trainer with updated information on both 

regulations and on a range of technologies in use at UST facilities.7

On-site (EPA Trainer): An EPA trainer could be an UST inspector who has 

passed a required training certification. Additionally, it could be a staff person 

who does not have inspector experience, but rather has obtained EPA’s required 

certification. This option is potentially highly efficient because EPA will be able 

to verify the trainer has the knowledge needed to provide effective training, and 

can coordinate training with scheduled inspections. 

On-site training - Posted notices: While ineffective for Class A and Bs, a 

posted list of instructions, phone numbers, and other important information may 

be effective for Class C employees, when combined with 1st party training. A 

posted summary of required knowledge ensures that information is easily 

accessible when needed, and reduces the need for retraining. 

Off-site training - Classroom: Classroom training off-site can be an effective 

training method for all operator classes, because it can be tailored to employees’ 

needs and learning styles by allowing for questions and providing the opportunity 

for illustration of certain site-specific issues. Hands-on training can also be 

incorporated into classrooms, though on-site training for technical issues is likely 

to be better targeted (e.g., to specific equipment used by participants). This 

method may be most effective for Class A operators, who are likely to benefit 

from the ability to interact with both instructors and peers as they address 

complex issues. Classroom training may be more difficult to adapt for retraining, 

where operators may need only targeted “refreshers.”8

Remote: Self-taught: This type of training involves an employee working 

independently through a curriculum (either hard copy or electronic), and typically 

involves taking a test. This approach requires varying curricula and tests for each 

operator class. It is more likely to be effective for non-site-specific topics such as 

regulatory compliance, and less likely to be effective in providing technical 

information about site equipment, though a modular approach can target certain 

types of equipment based on information provided by the user. While this 

represents the most accessible and flexible training option, a key limitation of this

training is the inability of a participant to ask questions or seek clarification on 

complex topics. 

 

7 Chuck Tillman, personal communication, September 30, 2008. The Choctaw Nation in Oklahoma owns multiple travel 

plazas and Chuck Tillman’s role is in part to ensure that all employees at each facility understand the operating and 

response requirements.

8 One issue that does not appear to significantly affect the implementation of training is “cheating.” Particularly in “live” 

on-site or classroom training, state officials and Ben Thomas agree that students are typically motivated to make use of the 

training opportunity, assuming that the curriculum is appropriate. On-line classes could potentially be subject to 

“substituting” one test-taker for another, but verification procedures, follow-on training, and the incentive to avoid noncompliance appear to limit the incidence of this type of behavior as well.
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Remote: On-line: An on-line class, generally with a final test, could be effective 

for each operator class. However, similar to the self-administered training, online learning is more likely to be effective for non-site specific topics such as 

regulatory compliance, and less likely to be effective in providing technical 

information about site equipment, where hands-on training is particularly useful. 

Similarly, this option limits the opportunities for students to interact with 

instructors and seek clarification on complex topics. While this option is flexible 

and generally accessible, it may also be impractical in areas without high-speed 

Internet service (e.g., some Tribal lands and rural areas). Retraining using this 

method could potentially be effective, however, because those with Internet 

access could easily login and retake a course and final exam. 

On-line training options can also include a wide spectrum of more “interactive” 

features, from simple e-mail question forums to “live” instructions through 

Webinars with audio and even video support. Webinar and video-conferencing 

options can improve the quality of the training itself by providing access to 

instructors for questions and interactive exercises and tests; costs can also be 

higher – even similar to live training. At this time “live” remote options are not 

readily available to UST facility operators, and are likely to face technology 

constraints similar to or more significant than those associated with on-line 

training – lack of service in remote areas and lack of appropriate software and 

hardware at smaller facilities. We therefore consider these options briefly but do 

not attempt to specify a specific “live” on-line approach.

Opt-Out Test: This training option is a limited application option where current 

employees can bypass training requirements if they demonstrate knowledge by 

passing a comprehensive test. The most important factor in ensuring 

effectiveness of this option is the design of an appropriate test.

In addition to the options laid out above, some “hybrid” options such as annual testing 

update requirements may be useful in improving the effectiveness of remote options. In 

the case of annual testing or compliance demonstration, retention is likely improved, and 

operators can also have access to updated materials as technologies evolve. California 

currently employs a system where ICC testing is supplemented by annual compliance 

reporting requirements. 

COST ASSESSMENT – UNIT COSTS TO AN OPERATOR FOR OBTAINING TRAINING

Exhibit 2 below shows each of the training types and a preliminary estimate of their 

respective unit costs to an operator. The values in this table assume that operators make 

use of existing professional training services (e.g., ICC, Ben Thomas). Please note, 

however, that these costs are based only on a few sources and competing companies 

offering similar services may have differing cost structures. 
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EXHIBIT 2. TRAINING METHOD COSTS TO OPERATORS

TYPE OF TRAINING ESTIMATED COST

Hands-On Training: On-site (3rd party)

$1,000-$3,000 per classa

Per employee costs depend on class size; most efficient 

for large facilities or multiple local facilities

Hands-On Training: On-site (1st party) Unknown, but generally less expensive than 3rd partyb

Hands-On Training: On-site (EPA Trainer) $448 per day, per trainer

On-site Training: 

Posted notice combined with 1st party 

training

$0.50 for noticec; costs for 1st party training vary but 

likely 1-2 hours of staff time, and includes other general 

facility training

Off-site Training:

Classroom $200-$400 per person, per classa

Remote Training: Self-taught

(typically with a test) $45-$75 per employeeb 

Remote Training: On-line

(typically with a test)e $5-$20 per employeea

Opt-Out test $45-$75 per employeeb

Notes:

a. Ben Thomas, Ben Thomas Associates, Inc. Personal Communication, May 27, 2008.

b. This cost is likely to vary significantly within each company and also may be confidential information.

c. The $0.50 cost is attributable to printing a notice and affixing it to a highly-visible location. 

d. International Code Council, “2008 UST/AST Examination Information Bulletin,” Revised May 14, 2008. 

Accessible at: http://www.iccsafe.org/certification/ust-ast/

e. Remote training can include live trainer options such as Webinars. Per-employee costs associated with 

Webinar training can be similar to costs associated with classroom training because they require a similar 

amount of preparation time from two staff members (a trainer and a technical support person).

While unit cost information informs the comparison of specific training options, it is 

important to note that most of these costs are highly sensitive to location. Travel costs 

can have a significant impact on the relative costs of each of these options. It may in 

some cases be cost-effective to bring instructors into a remote region for one or a series of 

on-site training sessions. In densely populated areas, classroom training may be a viable 

option. The cost of on-line training or remote self-instruction is typically lowest in all 

cases, but can be less effective (as noted above). Hybrid options such as Webinar 

training can be more effective in providing access to instructors, but can also have cost 

structures similar to live training options.

9

 In addition, all on-line training is limited to 

areas with effective Internet access. 

COST ASSESSMENT – PROGRAM DEVELOPMENT AND IMPLEMENTATION COSTS

In addition to the costs to operators of accessing training options, EPA’s operator training 

regulations will likely include significant “start-up” and implementation costs. Note that 

costs in this section are “straw-man” estimates based on our professional judgment and 

experience developing and conducting similar courses. Therefore, they are highly 

 

9 IEc has information on Webinar-based training for EPA enforcement staff. This training is similar in cost to live training, 

because it requires two staff members (a trainer and a technical support person) and roughly 30 to 60 minutes preparation

per participant to ensure scheduling, electronic connection, and distribution of materials. In addition, enrollment in the 

course is typically capped at 10 to ensure that participants have ample access to instruction. As a result, the per-person cost 

of the Webinar option in this example is similar to the attending an off-site live training course.
13

uncertain, and depend on the specific course content, delivery system, and existing 

materials that EPA chooses to employ. Significant program development and 

implementation costs include:

Development of a System for Certifying Trainers: A key aspect of 

implementing a training requirement is identifying appropriate trainers. A range 

of certification systems are possible. For example, certification can be 

“outsourced” to an external company, and would-be trainers would be required to 

obtain certification. This approach would likely require a competitive 

contracting effort to identify the best certification company and effort to finalize 

a certification curriculum, but would not involve significant implementation costs 

after inception. Other options include providing certification through EPA 

courses, certifying EPA instructors, or adopting certification approaches used by 

one or more states. The costs associated with each of these options are highly 

variable; more research on current approaches in other agencies or states might 

be useful in identifying costs, but it is also necessary to clarify the options EPA 

would consider for certification.

Development of Curricula for Instructor-Led Training Options: EPA may 

opt to design standardized materials to support “live” training options, whether 

on-site or in classrooms, or may simply require that training performed by 

instructors address all regulatory requirements. The development of training 

materials is a one-time cost that would be driven by the materials EPA already 

has in-house, and on the extent to which EPA intends to require standardized 

training. Assuming high-end costs reflect development of all-new, highly 

transferrable materials, the cost for this exercise could be $25,000 - $40,000 for 

each course.

Development and Distribution of Remote Training Materials: If EPA 

decides to develop training curricula for on-line or remote training options, the 

following cost elements are relevant. We use professional judgment based on 

similar scope projects to provide very rough estimates of the scale of potential 

costs for development of one course (e.g., Class B) that can be published to the 

Web and distributed remotely. Note that costs for developing a second course 

would be significantly lower because they would build on the initial 

programming.

o Curriculum Content Development: total cost depends on the extent to 

which existing training materials exist; $40,000 - $80,000, assuming that

significant new material must be drafted, reviewed, and tested. Could be 

much lower if formatted materials exist.

o Programming and Design to produce interactive modular training (e.g., 

training that targets specific technologies based on user input); roughly 

$50,000 - $90,000. This estimate includes the purchase of site licenses, 

programming and formatting of interactive training materials and 

databases, development of randomized testing materials and a 
14

certification process using self-instruction (e.g., not on-line), and review 

and beta-testing of approach. Estimate highly uncertain – could be lower 

or higher depending on the software platform EPA uses; assumes limited 

need for tracking information about trainees. Also includes limited time 

for support; “hotline” or other support system could vary in cost. 

o Distribute Materials: $5,000 - $10,000, including web launch and 

production of CDs for distribution upon request.10

o Update and Republish Curriculum: $5,000 - $10,000, including updates 

in programming and materials. Note that cost could be much higher for 

major revisions.

Development of Procedures to Verify and Track Training Results: Our cost 

estimates outlined above allow for development of a database to store 

information from operators accessing training on-line, but do not assume that 

EPA will be responsible for tracking or verifying training and certification. 

Instead, participants would receive and print out certification for their records 

once training had been successfully completed. If EPA determines that a more 

centralized approach to tracking data on operator training is required, this could 

increase start up and annual management costs substantially. 

Again, these costs are highly uncertain, and are designed only to provide a rough scoping 

estimate of the magnitude of costs associated with establishing a program. Actual design 

and implementation costs could be much lower if based on existing materials and if EPA 

expects a limited role in both delivering “live” training and in managing data on 

certification and training status of trainers and operators, respectively. 

Using the cost estimates and qualitative descriptions of effectiveness outlined above, we 

provide an initial assessment of the potential cost-effectiveness of different training 

options. Exhibit 3 provides a general summary of the cost-effectiveness of each training 

option with notes about its applicability to different operator classes. Exhibits 4, 5, and 

6 provide more detailed graphical descriptions of the costs and potential effectiveness 

associated with Operator Training for Class A operators (Exhibit 4), Class B operators 

(Exhibit 5) and Class C employees (Exhibit 6).

 

10 Note that this cost estimate does not consider the implementation costs associated with conducting Webinars or other 

“live” options. These costs, if not borne by participants, can vary widely depending on course design. Cost elements 

include the live instructor and technical support efforts to ensure that users can connect to the training.

COSTEFFECTIVENESS 

SUMMARY
15

EXHIBIT 3. AVAILABLE TYPES OF OPERATOR TRAINING

TYPE OF 

TRAINING

COST EFFECTIVENESS

COSTEFFECTIVENESS

SPECIFIC NOTES GENERAL NOTES

Hands-On 

Training: On-site 

(3rd party)

$1,000-$3,000 

per class 

Very high, 

particularly for 

Class B operators

Potentially high 

but ranges based 

on travel costs

Trainer travel is very 

expensive to Tribal 

facilities, but hands-on 

approach is valued

Most states will 

likely make the 

operators pay for 

training

Operators may be 

required to retake a 

class if violations 

are found at their 

facilities

In Kansas, training is 

required every 4 

years

Kansas pays for 

training through a 

state pollution fund

In California, 

operators train 

themselves and then 

take a exam (similar 

to the driving permit 

test)

Oregon allows 

instructions for Class 

Cs to be posted at 

the facility when 

combined with 

limited 1st party 

direction

Hands-On 

Training: Onsite (1st party)

Varies –

depends on 

need to certify 

and travel to 

locations

High if instructor 

is certified; small 

companies may 

not have in-house 

capabilities

Potentially high 

but limited 

application

“Cost-effective within 

a company” (Thomas 

2008)

Hands-On 

Training: Onsite (EPA 

Trainer)

$448 per day, 

per trainer

High if instructor 

is certified High

Would require EPA to 

create a trainer 

certification process

On-site Training: 

Posted notice 

combined with 

1

st party training

$0.50 in 

addition to 

cost of 1st

party training 

(e.g., by Class 

B operator on 

site)

Moderate-high for 

Class C only

Potentially high, 

likely most costeffective because 

information is 

always available

Allows for easy 

employee access to 

important information

Off-site Training:

Classroom

$200-$400 per 

person per 

class

Moderate to high, 

particularly for 

Class A

Moderate to high

Travel may be 

expensive for 

rural/Tribal facilities

Remote Training: 

Self-taught

(typically with a 

test) 

$45-75 (ICC)

Moderate – could 

be well targeted 

but no instructor 

interaction.

High

Requires 

verification/testing to 

ensure application

Remote Training: 

On-line

(typically with a 

test)

$5-$20 per 

Class C 

employee; 

other Class 

operators 

likely similar 

to self-taught

Lower; limited 

site-specific 

information, 

limited access to 

instructor

Variable; low for 

Class C employees 

(cost not 

necessary)

“probably the least 

cost-effective option” 

for Class C employees 

(Thomas 2008); more 

cost-effective for other 

operators if curriculum 

is high quality

Opt-Out test $45-75 (ICC) Potentially high High

Similar setup to driving 

permit computer tests; 

could be used for all 

classes.

Notes: 

1. The information in this exhibit on instructor-led training is from Ben Thomas, personal communication, May 23, 2008, and 

verified by communication with program representatives from Oregon and California (Mitch Scheel, OR, personal communication, 

June 26, 2008 and Andrea Zajac, MI, personal communication, June 18, 2008), information from the ICC, and Tribal 

representatives (Ken McBride, personal communication, October 8, 2008, Chuck Tillman, personal communication, September 30, 

2008, and Robert Largent, personal communication, October 9, 2008). Furthermore, in addition to the sources noted above, data 

in this exhibit is also based on IEc professional judgment. Also note that California and Oregon’s programs predate EPA’s Energy 

Policy Act Guidelines. 

2. The states that have been identified and contacted that are included in this exhibit may not necessarily meet the 

requirements of EPA’s operator training guidelines. 
16

EXHIBIT 4. DETAILED COSTS AND BENEFITS STRUCTURE FO R CLASS A OPERATOR TRAINING

Class A 

Employees

On-site

Off-site

3rd party 

($2,000 per 

class)

1s t Party 

Trainer 

(varies based 

on company)

EPA 

inspector, if 

available 

($448 per day)

Classroom 

($300 per 

class)

Remote

Online 

($45-75 per 

employee)

Electronic media 

(one-time 

distribution cost)

Initial 

training

Training 

attendance N/A N/A

Curriculum Consistent - Targeted around statutory and regulatory requirements

Requires some form of 

verification e.g., a signed 

statement, company oversight 

Testing

Program 

Design Issues 

and Costs

•Certify trainers –

cost varies by # 

trained, reqs.

•Design 

curriculum and 

Program ($110k -

$170k)

•Update 

curriculum ($5k-

$10k/yr)

•Distribute 

materials ($5k-

$10k)

•Test design 

(cost incl. in 

curriculum 

design)

•Track results 

(cost varies)

•Limit cheating 

(cost incl. in 

programming)

•Recordkeeping (no 

cost to EPA)

Test or no test? No 

cost difference to 

participant, may 

improve level of 

understanding

Retention

Retraining

New hires

Flexible if 

available

Very high 

cost

Specific to 

company 

policy 

information 

on new hires

Perfect timing 

(when on-site 

due to a 

violation)

Low cost, but 

not flexible

Flexible, if 

available

Flexible, 

requires 

verification

Flexible

Flexible, low 

cost, requires 

verification

Flexible, low 

cost, 

requires 

verification

•Routine 

retraining 

option?

•Verification 

for remote 

retraining

Low overall 

effectiveness

High overall 

effectiveness

Moderate 

overall 

effectiveness

Legend:

Verification

Less important to perform written test More important to perform written test

Program 

Characteristics Information Transfer

Opt out

Mandatory 

test

N/A

Flexible, low 

cost, 

requires 

verification

N/A

NOTE: Program Design Costs for Class A do not 

reflect cost savings of simultaneous design for all 

employee classes.

Flexible

Flexible, but 

limited 

availability

REQUIRES ON-SITE INSTRUCTION FACILITIES
17

EXHIBIT 5. DETAILED COSTS AND BENEFITS STRUCTURE FO R CLASS B OPERATOR TRAINING

Class B 

Employees

Hands-o n

Hands-off

3rd party 

($2,000 per 

class)

1st party 

trainer 

(varies by 

company)

EPA 

inspector 

($448 per day)

Classroom 

($300 per 

class)

Remote

Online 

($45-75 per 

employee)

Electronic media 

(one-time 

distribution cost)

Initial 

training

Training 

attendance N/A N/A

Targeted with 

possible Q & 

A session

Targeted

Curriculum Equipmentspecific and 

general info

Targeted with 

Q & A, some 

site-specific

Requires some form of 

verification e.g., a signed 

statement, company oversight 

Testing

Program 

Design Issues 

and Costs

Test or no test? No 

cost difference to 

participant, may 

improve level of 

understanding

Retention

Retraining

New hires

Flexible if 

available

Very high 

cost

Flexible, low 

cost

Specific to 

company 

policy 

information 

on new hires

Perfect 

timing (when 

on-site due 

to a 

violation)

Low cost, not 

flexible

Flexible, if 

available

Very high 

cost

Flexible, 

requires 

verification

Flexible

Flexible, low 

cost, requires 

verification

Flexible, low 

cost, 

required 

verification

•Routine 

retraining 

option?

•Verification 

for remote 

retraining

Low overall 

effectiveness

High overall 

effectiveness

Moderate 

overall 

effectiveness

Legend:

Verification

Program 

Characteristics Information Transfer

Opt out

Mandatory 

test

N/A

Flexible, low 

cost, requires 

verification

N/A

•Certify trainers –

cost varies by # 

trained, reqs.

•Design 

curriculum and 

Program ($110k -

$170k)

•Update 

curriculum ($5k-

$10k/yr)

•Distribute 

materials ($5k-

$10k)

•Test design 

(cost incl. in 

curriculum 

design)

•Track results 

(cost varies)

•Limit cheating 

(cost incl. in 

programming)

•Recordkeeping (no 

cost to EPA)

NOTE: Program Design Costs for Class B do not 

reflect cost savings of simultaneous design for all 

employee classes.

Note – can 

train multiple 

employees

Less important to perform written test More important to perform written test
18

EXHIBIT 6. DETAILED COSTS AND BENEFITS STRUCTURE FO R CLASS C OPERATOR TRAINING

Class C 

Employees

Hands-on

Hands-off

3rd party 

($2,000 per 

class)

1s t party/ 

Class A 

trainer

EPA 

inspector 

($448 per day)

Classroom 

($300 per 

class)

Remote

Online 

($45-75 per 

employee)

Electronic or 

printed/posted 

media (minimal)

Initial 

training

Training 

attendance N/A N/A

Targeted with 

possible Q & 

A session

Targeted

Curriculum Equipmentspecific or 

general

Targeted with 

Q & A, some 

site-specific

Requires some form of 

verification e.g., a signed 

statement, company oversight 

Testing

Program 

Design Issues 

and Costs

•Certify 

trainers; 

minimal if 

Class A/B = 

certified.

•Curriculum 

design, 

update, and 

distribution 

costs 

included in 

Class B 

materials.

•Test design 

costs included 

in Class B 

materials.

• Test delivery 

and recordkeeping costs 

minimal if 

owneroperator 

implements

Test or no test? No 

cost difference to 

participant, may 

improve level of 

understanding

Retention

Retraining

New hires Very high 

cost

Flexible, low 

cost

Specific to 

company 

policy 

information 

on new hires

Perfect 

timing (when 

on-site due 

to a 

violation)

Low cost, not 

flexible

Flexible, if 

available

Very high 

cost

Flexible, 

requires 

verification

Flexible

Flexible, low 

cost, requires 

verification

Flexible, low 

cost, 

required 

verification

•Routine 

retraining 

option?

•Verification 

for remote 

retraining

Low overall 

effectiveness

High overall 

effectiveness

Moderate 

overall 

effectiveness

Legend:

Verification

Program 

Characteristics Information Transfer

Opt out

Mandatory 

test

N/A

Flexible, low 

cost, requires 

verification

N/A

Note – can 

train multiple 

employees

Flexible, if 

available

Less important to perform written test More important to perform written test
19

As Exhibits 4 through 6 illustrate, more than one training option may be appropriate for 

operators, depending on the circumstances (e.g., number of employees requiring training, 

access to Internet). In general, hands-on training options are likely to be more effective, 

particularly where site-specific technical information is central (e.g., for Class B 

operators).11 In circumstances where 1st party or EPA trainers are available, the on-site 

training option may even be a low-cost option. For Class A operators, it is possible that 

classroom training will provide the most effective combination of an in-person trainer and 

interaction with colleagues.

In all cases, remote training (either on-line or distributed electronic training) provides a 

flexible, accessible option, but is associated with a greater need for formal verification of 

operator/employee identity and successful training (i.e., through a test); in-person 

training, in contrast, can include relatively informal procedures for testing participants.

A number of initial insights may be drawn from the information in Exhibits 3 through 6: 

Class B operators and C employees are likely to benefit most from site-specific 

and/or on-site training, because they will need a working knowledge of facility 

equipment and operations. Class A operators, in contrast, may be most flexible 

and able to use options such as on-line training or off-site classroom training, at 

least for the portion of their training that does not require on-site knowledge.

Classroom and on-site 3rd party training are relatively high cost options, but with 

qualified instructors, these are likely to be among the most effective approaches, 

particularly in cases and for operator classes where facility-specific features are 

central to compliance, and may be more cost-effective in situations where 

multiple employees can be trained on-site. 

The lowest-cost approach for Class A and Class B operators, in locations where 

the technology supports it, is on-line training. An advantage to this approach is 

the consistency of the curriculum; a drawback is the limited ability to tailor a 

curriculum to address the specific questions of trainees. The impact of this 

limitation on the effectiveness of training varies with the curriculum, and with the 

specific training needs of the owners/operators. 

For new Class B operators, remote training options are likely to be the most costeffective unless a 1st party on-site option is feasible within the 30-day window for 

obtaining initial training. 

Anecdotal evidence suggests that the low-cost “posted notice” approach may be 

most cost-effective for Class C employees when combined with 1st party on-site 

training (or remote training by CD if 1st party training is unavailable). The high 

turnover and limited training needs of Class C employees are difficult to address 

with classroom training or 3rd party on-site training, and the fees associated with 

currently available on-line training are higher than other remote options. 

 

11 This point is further evidenced by a survey conducted by the Washington State Department of Agriculture on recertification 

training. “Hands-on Training Boosts Students’ Retention,” WSDA PesticideNotes, July 2002. Available at: 

http://agr.wa.gov/PestFert/docs/P10PestNotes2002.pdf.
20

First party training is appropriate for Class C employee training, and may, in 

some cases (e.g., larger companies) be the most cost effective option for the 

technical training of Class B operators. However, ensuring that 1st party trainers 

are certified or otherwise qualified would be an important factor in promoting 

effectiveness.

EPA trainers, if feasible, would provide the most appropriate and cost-effective 

option for post-violation re-training, and could also provide a reliable option for 

fixed-interval re-training that coincides with inspections. This option is likely 

less feasible for training new hires, however.

At this time we cannot derive meaningful quantitative estimates of cost-effectiveness for 

different training approaches, but Exhibits 3 through 6 provide general comparative 

information that provides a starting point for assessment of more specific regulatory 

options. 

From the information outlined above, we can draw several preliminary conclusions. The 

first is that for Class C employees, EPA could select a training option that is not costly, 

since it appears that training options are similar in effectiveness. An approach that 

combines 1st party training with a posted notice may be the most cost-effective training 

for Class C employees. The second conclusion is that on-site training is generally likely 

to be more effective for technical and general operational training than off-site training. 

This is likely true for Class B operators and potentially also Class A operators. The third 

conclusion is that live training in a classroom is potentially the most effective method for 

Class A operators and could also represent the a cost-efficient method for Class B 

operators if the instructor is capable, has a well-designed curriculum, and travel costs are 

modest. The final conclusion is that retraining may be most cost-effective if implemented 

by EPA inspectors at the time of inspection and/or after violations. 

DATA AND METHODOLOGICAL LIMITATIONS

It is important to note that the methodology outlined in this document has several key 

limitations:

Effectiveness Metrics: This memorandum does not include a measurement of 

the direct environmental benefits from increased operator training. In addition, 

we do not present any direct indicator of the environmental benefits resulting 

from each type of training individually as options. The initial literature search 

conducted in support of this analysis did not identify any data or studies that 

directly document changes in compliance related to training, and we have not 

yet been able to identify theoretical literature that provides quantitative or 

ranked comparison of the effectiveness of different training approaches.

Feasibility of Training Options: Our methodology for this document did not 

include collection of data from owners/operators to identify the training options 

that are most useful and feasible. As a result, our information may not reflect 

key limitations relevant to specific circumstances (e.g., Tribal settings, remote 

facilities, cost-constrained operators). Appendix A outlines the relevant 

CONCLUSIONS, 

LIMITATIONS AND 

NEXT STEPS
21

information we were able to collect from the sources we did interview, but a 

detailed assessment of options should consider (perhaps through public 

comment) input from owner/operators. 

An important limitation to establishing effectiveness of operator training is the fact that 

most states’ current operator training programs are too new to have established, well-kept 

data for analysis of long-term program effectiveness. While we received anecdotal 

indications that training has improved compliance rates, and some existing programs may 

be running well and have increased compliance rates, we were unable to collect any 

specific data showing compliance trends. 

NEXT STEPS

Currently, our ability to measure cost-effectiveness is limited in part by a small base of 

information sources (a small number of states and training experts) and a lack of available 

data showing actual changes in compliance linked to training. In addition, with the 

number of variables, the range of costs and impacts associated with each variable (e.g., 

travel requirements that affect cost or instructor qualifications and curricula that affect the 

impact of the program), and the potential for combining more than one option (e.g., 

adding periodic documentation or re-training to a specific operator training program), it is 

not yet possible to clearly rank the options most likely to be cost-effective. To improve 

the assessment of cost-effectiveness, we recommend the following additional analyses:

A concerted effort to assess recent educational research to identify key 

limitations/advantages in different training approaches. Emerging research 

assessing the effectiveness of remote training approaches is likely to be 

available within several months, and focused effort to coordinate with the 

researchers to provide a theory-based ranking of the effectiveness of different 

training options may provide useful information. More detailed access to 

educational literature may also provide insights in how to design specific 

courses to be most effective. This effort is particularly important if EPA 

anticipates selecting or prioritizing a single form of training in its regulations, 

though. 

Development of a mapping tool to assess geographic issues and travel costs. 

Another useful analysis may be use of spatial data locating USTs on Tribal 

Lands to develop a breakeven cost analysis tool that can identify the impacts of 

travel costs on training options. This may help EPA compare the cost of 

sending trainers to facilities to the cost of having employees travel to central 

locations. Depending on data availability, the analysis could also be adapted to 

identify areas that do not have access to high-speed Internet.

Expansion of effort to identify reasonable cost estimates for hybrid options 

and 1st party training options. Analysis of costs associated with training 

options such as Webinars and 1st party training could be expanded using input 

from EPA on the potential structure of the training options and information 

collected from identified 1st party trainers.
A-1

APPENDIX A:

DATA COLLECTED FROM TELEPHONE INTERVIEWS

BEN THOMAS (BEN THOM AS ASSOCIATES, INC., MAY 23, 2008)

Ben Thomas is a private trainer who currently conducts live operator training 

courses. For more information on Mr. Thomas, see http://www.bentanks.com.

Travel is the biggest obstacle for providing live training on Tribal lands.

Ben Thomas was unaware of any fully developed training programs. Most 

facilities had training for business reasons, not for SPCC or other regulatory 

requirements (California and Oregon are the exceptions since they require 

training).

Believes that on-site training is the best method available, but that having 3rd

party training can be very expensive for some facilities. 

In CA, operators train themselves and take an on-line exam. In combination 

with a monthly compliance report, this may be the most cost-effective method 

of training. However, an on-line exam without continual reporting duties is 

likely the least expensive and least effective method.

Oregon allows posting instructions on the facility walls however there’s no 

validation it was read.

He has not witnessed any incidents of cheating. 

Limited access to high-speed Internet limits Tribal facilities’ ability to have online training. 

Kansas has training every four years for Class A and B operators, however 

operators have to retake classes if there are violations. 

Most states require the operators to pay for the training. 

OREGON (MITCH SCHEEL, JUNE 26, 2008)

Mitch Scheel is the UST Policy Coordinator for the Oregon Department of 

Environmental Quality.

Have had a training program since 2004 for Class B operators and C 

employees. In 2009 Oregon will include Class A operators in the training 

program. 

Ben Thomas solely provides the training, offering courses every 3 months. 

Classroom training sessions last eight hours and they are not required to be held 

on-site. The 8-hour class costs $300. 

Employees/operators are required to have training one time. 

Operators pay for all training costs. 
A-2

Web-based training is an option, including ICC’s national exam. PEI may 

eventually offer a similar training program. 

The fire marshal requires a posting of the important telephone numbers at the 

facility. 

MICHIGAN (ANDREA ZAJAC, JUNE 18, 2008)

Andrea Zajac is the Head of the Storage Tank Unit at the Michigan Department of 

Environmental Quality.

Created an Operator Training Task Force that selected ICC for conducting its 

testing on-line. 

ICC offers training on-line and the state is working with various associations for 

additional input in creating its training program. 

Michigan and ICC will create a new test based on the new UST regulations that 

will be required when EPA enacts rules for each new provision of the Energy 

Policy Act. 

EPA grant money is their only funding; there is no in-house funding available. 

CHUCK TILLMAN (CHOCTAW NATION, OKLAHOMA, SEPTEMBER 30, 2008)

Unique situation where there is no official reservation land; the Tribal boundaries 

encompass about 10.5 counties.

There are 13 Tribally-owned plazas and he has no jurisdiction over anything else.

Unless there is something easier, he does all the training.

Turnover can be a problem with class C operators (every 3-6 months).

When somebody new is hired, they are required to watch a video that covers 

alcohol and tobacco sales and it could also cover UST topics such as ATG, alarms, 

and phone numbers. The video could be administered by a manager or Chuck. 

Maintenance workers would also watch the video.

These 13 facilities have locked fill caps that the transport drivers need to get 

unlocked. This requires the employee to be out there verifying the procedures and 

checking the sumps and gauges before locking the fill pipe at the end of the 

delivery. 

Chuck does on-site training, and there is a monthly managers meeting during 

which new issues can be raised for discussion.

He suggests leaving training class C workers to the managers, who he thinks 

should have PowerPoint presentations ready for them to view. After viewing the 

presentations, he thinks they should have to answer a couple questions to show 

they retained some information.

Chuck estimates there are between 10 and 30 employees at each of the 13 plazas.

One aspect of training he does involves creating and responding to a mock spill.
A-3

Chuck is the only Class A employee, and he attended one of Carl Jeffries multiday training programs as well as NETI trainings. 

Chuck works off EPA grant funding money.

He also provides one-day training sessions for managers that include 20-30 

questions for them to answer.

Believes that they could institute a PEI internet course costing approximately $75 

that would be available for 30 days to log into. Thinks that internet access in his 

area is not a problem. 

Chuck thought that while there could be cheating with remote (online) training 

options, cheating would likely not be a problem because there would be very little 

benefit from doing so.

He also stated that sole class A operators should be more accountable and be 

required to take a 3 or 4-day training class every year. 

Chuck noted that he does not have a system of tracking the effectiveness of his 

training; however, when he gets calls from facilities, it shows they have a better 

understanding of their requirements than they previously had. 

KEN MCBRIDE (RED LAKE, GRAND PORTAGE, GRAND SIOUX, AND LOWER SIOUX, 

OCTOBER 8, 2008)

Has done some Inter Tribal Council of Arizona (ITCA) training with EPA in the 

past.

Considers himself a compliance assistant.

Onsite training has been the best.

Has done a couple of classroom classes.

For 3 years he has offered compliance assistance.

Did a couple 3-4 day trainings with Carl Jefferies and ITCA that were geared 

towards training inspectors.

Ken calls facilities with violations and offers assistance. Not all accept his offer.

It takes a lot of effort for facilities not at Red Lakes to come into compliance.

He mainly tries to deal with the B operators.

Sole proprietorships can be difficult because it is hard to track down a contact.

He thinks that some facilities have not accepted the penalties they have been 

assessed and think there is still no reason to come into compliance.

It would be difficult to get people to attend a large off-site training session, mainly 

because they have no travel money.

Class B turnover is not an issue, Class C turnover can be.

Thinks trainers have to go to the facilities because the operators are not “booklearners” and would not get much out of a classroom setting.
A-4

Site visits are better because each facility has different attributes that cannot all be 

taught in a larger classroom setting.

He has been putting together 3-ring notebooks with different sections on facility 

attributes to make assistance easier for facilities to know what information they 

have to review.

Recordkeeping is a major problem for Tribal facilities- they just do not seem to 

care about keeping up with it.

He said they used to use contractors for training, but the Tribal employees could 

not relate to the operators so it did not work well.

Does not think many would choose to take online training because they value the 

hands-on experience; however, it should still be an option to choose from.

There are some facilities that do not even know what kinds of systems they have, 

or what kinds of notification and recordkeeping are required.

ROBERT LARGENT (INTER-TRIBAL ENVIRONMENTAL COUNCIL, OCTOBER 9, 2008)

Provides Inter-Tribal Environmental Council (ITEC) training with one other 

person to 41 Tribes.

All trainings are conducted on-site.

Used to provide trainings in big conference rooms; however, they were not 

efficient- too much unnecessary information for operators.

The trainings are mostly for As and Bs; however, some Cs will sit in with the As 

and Bs.

Also provides training to maintenance workers onsite.

Unless on state lands, would follow EPA’s regulations.

Approximately 75 percent of all facilities have had at least one training.

Have started to make DVDs for class C workers targeting turnover problems (also 

includes material for As and Bs).

There are only a couple of individually-owned facilities.

Training has been offered to every facility.

The biggest challenge with the classroom trainings was making sure you have 

their attention and also to only give them necessary information related to their 

facility.

For onsite trainings, in the morning they would go over paperwork requirements 

and record-keeping, and then in the afternoon they would go out and look at the 

equipment.

Traveling can be difficult for the trainers, and some facilities do not have a small 

room that they can even sit down in.

Has found the hands-on training to be very effective and more helpful to the 

operators.
A-5

In the less-structured on-site environment, operators seem to ask more questions.

With the onsite trainings, they get more input from Tribes showing better 

recognition and awareness of the requirements and systems at their facilities.

He has completed some inspector trainings.

They have websites setup up providing useful information to operators.

Did an online training; however, many did not have access to the internet so it did 

not work that well.

Did not have a final test, no incentive for any cheating.

Believes online training is a viable option, provided all targeted operators have 

internet access.