DDOE: Underground Storage Tanks: Fact Sheet for Owners and Operators

This fact sheet has been developed in accordance with the Federal Energy Policy Act, 40 CFR Part 280, US EPA Operators Training Guidelines and the District of Columbia Municipal Regulations 2009, 20 DCMR Chapters 55-70, particularly §6502.

Key Responsibilities of UST Stakeholders

1. Owners of USTs:

Shall designate at least one Class A, one Class B, and one Class C operator for each active UST facility and provide training for each operator, as provided at 20 DCMR § 6502. Although operators can be trained starting August 2009, DDOE will not enforce this requirement until August 2012. The tank owner or operator shall incur the costs of training.
May not dispense or store a regulated substance from a facility, after August 8, 2012, unless operators have been designated and trained.
Shall maintain the following documentation at the facility for inspection by DDOE :
   o a list of the designated operators,
   o all operator training certificates,
   o instructions for Class C operators, and
   o record of training completed by all Class C Operators, where certificate not available.
Must ensure that the facility is registered with DDOE annually and a current registration certificate is posted onsite, in a visible location.
Shall post the names of Class C Operator and Owner, as well as contact details for same at unmanned UST facilities.

2. Operators of USTs:

Designated operators shall successfully complete required initial training by August 8, 2012.
Trained operators shall be readily available to respond to suspected or confirmed releases, other unusual operating conditions, emergencies and equipment failures (§6502.3).
Operators A and B shall obtain a passing grade on an examination in order to obtain a training certificate from the trainer. A passing grade means 80% or higher.
The training certificate shall remain valid for a lifetime, except in the event of serious violations or changes in future regulatory requirements. In event that a facility is determined to be in serious violation, the operator shall be retained within 60 days of being notified the facility is in violation.

3. Training Providers:

Must develop training curriculum that meets the requirements of DDOE’s regulations for Operators A and B. If training is offered for Class C Operators, this should also be provided to DDOE.
Must obtain the approval of DDOE prior to imparting any training courses.
May offer training in a classroom, online or onsite at UST facilities.
Must provide signed and dated training certificates to operators A or B, who attain a passing grade of 80% or higher only.

4. Delivery Companies:

Shall only deliver fuel to UST Facilities and tanks that have a current registration certificate posted on-site, and that are not on DDOE’s list for delivery prohibition, which is posted on our website (www.green.dc.gov). In addition, if a yellow tag is placed on the UST fill ports, delivery of product shall NOT be made.

5. District of Columbia Department of Environment (DDOE):

Education and Awareness - DDOE will make available to persons who request it, a copy of the UST Regulations, civil infractions schedule, delivery prohibition guidance document and list of approved training providers in DC. These documents will also be posted on our website at www.green.dc.gov.
Approval of the training operators programs offered by Training Providers - approval shall be at the discretion of DDOE’s Director. Delivery of operator training prior to obtaining the Director’s approval shall be subject to enforcement action. The approval letter is an indication that DDOE has approved the provider’s curriculum.
Reciprocity - DDOE may allow completion of Class A and B Operator training from another state if the person requesting reciprocity demonstrates to the satisfaction of DDOE that the operator training requirements and the UST regulations of the host state are at least as stringent as 20 DCMR, Chapter 65 or 40 CFR, Part 280.
Monitoring and Enforcement of Regulations – DDOE shall conduct inspections of facilities and enforce against facilities that are not in compliance. In accordance with the legal provisions set forth at D.C. Code §§ 8-113.01, et. seq., and the regulatory provisions set forth at 20 DCMR Chapters 55-70, DDOE may:
   a. suspend or revoke the approval granted to any training provider;
   b. suspend or revoke an operator’s certification;
   c. implement sanctions against any owner or operator who fails to meet the requirements of the regulations;
   d. implement sanctions against any delivery companies that deliver regulated substances at a facility or tank at which delivery has been prohibited.

Training Requirements for Class A, B or C Operator:

Class A operator - has primary responsibility to operate and maintain the UST system and facility. 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 person focuses on the broader aspects of the statutory and regulatory requirements and standards necessary to properly operate and maintain the UST system and facility (see §6502.8).

Required training for Class A operators includes the following:
(a) Spill and overfill prevention
(b) Release detection and related reporting requirements,
(c) Corrosion protection
(d) Emergency response,
(e) Product and equipment compatibility,
(f) Financial responsibility
(g) Notification and UST registration requirements,
(h) Temporary and permanent UST closure requirements, and
(i) Class A, B, and C operator training requirements

Class B operator - implements applicable UST system regulatory requirements and standards in the field or at the UST facility. This operator oversees and implements the day-to-day aspects of operations, maintenance, and recordkeeping for the USTs at one or more facilities (see §6502.9).

Required training for Class B operators includes the following:
(a) Spill and overfill prevention
(b) Release detection and related reporting requirements,
(c) Corrosion protection
(d) Emergency response,
(e) Product and equipment compatibility,
(f) Report and recordkeeping requirements, and
(g) Class C operator training requirements

Class C operator - is the first line of response to events indicating an emergency condition. This person is responsible for responding to alarms or other indications of emergencies caused by a spill or release from a UST system and equipment failures. The Class C operator notifies the Class A or B operator and appropriate emergency responders when necessary (see §6502.10).

Required training for Class C operators;
Class A or B Operators may provide training to Class C Operators or this may be done by an external training provider. At a minimum, training provided by the Class A or B operator shall enable the Class C operator to take action in response to emergencies or alarms caused by spills or releases from a UST system. Training shall include written instructions or procedures for the Class C operator to follow and to provide notification necessary in the event of emergency conditions. After the initial training, Class C operators shall be briefed by the Class A or B operator, on these instructions or procedures at least annually (every 12 months).