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Delivering Training to Class A or Class B Operators - USTs

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. The UST Regulations (20 DCMR, Chapters 55-70) were revised and published on August 21, 2009. The new regulations provide that operators can be trained starting on August 2009, although DDOE will not enforce this requirement until August 2012.

To deliver training to Class A and/or Class B operator who operate in the District of Columbia, you must:

  • Develop a training curriculum and materials that meet the District’s requirements for training Class A and/or B operators (see below for specific requirements).
  • Submit the training curriculum (including method of delivery and assessment tool/exam) to the District Department of the Environment (DDOE) for review. Allow at least 30 days for DDOE review before scheduling course offerings. Note that delivery of operator training prior to obtaining the Director’s approval shall be subject to enforcement action, and/or fines.
  • If the course will be delivered by classroom or hands-on instructors, submit to DDOE a resume or qualification summary for each instructor demonstrating his/her UST experience and proficiency with the new regulatory requirements.
  • Obtain DDOE’s written approval of your training course(s) prior to delivering it to Class A and/or B operators.
  • Administer the approved assessment or written examination after each training, to test knowledge and understanding of operators.
  • Provide signed and dated training certificates to Class A and/or B operators who attain a passing grade of 80%.
  • Maintain records indicating the date, location, names of trainers, names of trainees operating in the District who completed and passed the course by class of operator.
  • Make records available to DDOE, as requested.
  • After the initial training curriculum has been approved, notify DDOE of any major changes you plan to make to the curriculum and resubmit to DDOE for approval.
  • Operators of Emergency Generators are required to be trained on everything, unlike the Federal requirements which only requires training on release detection.

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

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

If you plan to deliver training to Class C operators who operate in the District, you should inform DDOE. Although DDOE does not require a formal training curriculum for Class C Operator training; review and approval process, we are interested in documenting training providers in DC and to hear about what you plan to offer. Class C operator training records must be maintained at the UST facility.

Required training for Class C operators:

Class A or B Operators may provide training for Class C Operators or they may attend training provided by an external training provider. At a minimum, training provided by the Class A or B to a Class C 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).

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