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UST - Module 1
Operator Training Introduction
Question | Answer |
---|---|
Class A Operator (Part 1) | Has primary responsibility to operate & maintain UST system. Responsible for managing resources and personnel & establish assignments to achieve compliance w reg'y req'ts. Focus on the broader aspects of the statutory and reg'y req'ts and standards |
Class A Operator (Part 2) | Typically ensures that appropriate individuals properly operate & maintain UST; maintain records; respond to emergencies caused by releases or spills from UST; make financial responsibility documents available to the implementing agency as req’d |
Class B Operator (Part 1) | Implements applicable UST reg'y req'ts & standards (N.J.A.C. 7:14B et seq.) IN THE FIELD. Implements day-to-day aspects of operating, maintaining, & record keeping for UST at one or more facilities |
Class B Operator (Part 2) | Monitors/Ensures: Release detection method is performed for tanks and product piping. Cathodic protection method is functional. Release prevention equipment (overfill and spill protection) is functioning. Record-keeping, & reporting req'ts are met |
Class B Operator (Part 3) | 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 |
Class C Operator (Part 1) | Responsible for responding to alarms or other indications of emergencies caused by spills or releases. Notifies A/B & appropriate emergency responders |
Class C Operators (Part 2) | Typically controls or monitors the dispensing or sale of regulated substances. NOTE: Not all employees of the facility are necessarily C operators |
What is operator training | 3 tiered training program. Ensures that they know how to operate and maintain UST systems properly. Req'd by Fed Law |
What UST systems does this info apply to | All UST systems regulated under 40 CFR Part 280. Regulated under (N.J.S.A. 58:10A-21 et seq.) & regulations implementing N.J.S.A. (N.J.A.C. 7:14B et seq.) |
Who is subject to operator training and what are requirements (Part 1) | EPA guidelines establish 3 classes of operators - A, B, & C. Each UST or group must have a class designated. You can be designated to more than one class as long as he/she is trained in each class. Regulated heating oil tanks deadline 10/18 |
Who is subject to operator training and what are requirements (Part 2) | O/O submit to the Dept, on the NJ UST facility cert questionnaire, names & designated classes for each UST within 30 days. For UST installed prior to 10/13/15 (effective date of 40 CFR Part 280), O/O ensures each class complete training by 10/18. |
Who is subject to operator training and what are requirements (Part 3) | O/O can designate themselves as A/B/C or can designate contractors or employees. O/O still retain liability for all regulatory issues, including each class operator rec'd training and passed exams |
Training the Class C Operator | Owner/Operator determines the method of training C operators, provided the training meets N.J.A.C. 7:14B-5A.2(c) req'ts |
Class C Training (Part 1) | Instruction to appropriately respond to emergencies by spills or releases resulting from UST system that pose immediate danger to the public or environment AND notify appropriate authorities |
Class C Training (Part 2) | Appropriate actions and responses to alarms associated with release detection equipment or the UST system |
Class C Training (Part 3) | Evaluating trainee’s understanding of the role & ability 2 perform response actions 4 spills, releases & alarms associated w/ release detection equip't. Shall demonstrate relevant knowledge & ability be4 being C operator under N.J.A.C. 7:14B-5.14 |
When must operators be trained | By 10/2018. After 10/2018, A/B must be trained W/IN 30 DAYS after assuming responsibility. Class C BEFORE DESIGNATION |
Retraining (Part 1) | Dept will require retraining & retesting of the designated A/ B operators of the UST system in accordance with N.J.A.C. 7:14B-5A.2 if it determines that an UST system is out of compliance with a significant requirement. |
Retraining (Part 2) | Examples of noncompliance. 1. Not having operating leak detection or cathodic protection mechanisms. 2. Failing to respond to alarms, active discharges, or repeatedly violating the same requirements over multiple inspections |
Retraining (Part 3) | Retraining must be completed w/in 30 days from the date the Department advises the facility of significant or repetitive non-compliance, or within an alternate timeframe as agreed to by the Department |
Retraining (Part 4) | Dept may provide an exception if dept determines that the UST system’s non-compliance resulted from unanticipated equip't failure, bad repairs, or factors beyond normal control and diligence of the O/O |
Documentation of Training Requirements (Part 1) | The O/O maintains records for training and retraining for A/B/C operator. All records will maintain for as long as the operator is designated |
Documentation of Training Requirements (Part 2) | Training records will be maintained on paper (on-site) or electronically (off-site), and will be made available for on-site inspection by the Dept upon request |
Documentation of Training Requirements (Part 3) | Training records must identify each A/B/C for the facility: the name, operator training completed, date of initial training or retraining, & trainer’s name & contact info |
Documentation of Training Requirements (Part 4) | Include trainers name and signature for classroom or field training programs (including C operator training provided by the A/B operator) |
Documentation of Training Requirements (Part 5) | Indicate the computer based training program & web address (if internet based); & include the subjects on which the A/B operators completed retraining |
Responsibility For Compliance | Designation of A/B/C operator DOES NOT relieve an owner and operator of responsibility for compliance |
Unmanned Facilities (part 1) | No attendant at location during operating hours. EX: Emergency Generator Tanks. Public Works Yards. Self Serve Company Fleets |
Unmanned Facilities (part 2) | After hour deliveries can either: schedule with the supplier to have a C operator onsite for delivery OR post signs that meet the req'ts for an unmanned facility. |
Sign Information (Part 1) | Clearly visible and weather resistant & list procedures if a leak or discharge of a hazardous substance & include procedures to address alarms associated with release detection equip't |
Sign Information (Part 2) | All signs should include emergency contacts: local fire and health department; DEP Hotline (877-927-6337); & any appropriate local/state agencies. |
Sign Information (Part 3) | Name and phone numbers for the person responsible during an emergency (O/O or A/B operator); UST Contractor; & the Licensed Site Remediation Professional (LSRP) |
When Must Unmanned Facilities Meet These Sign Requirements | Existing UST systems: 1/2019. New UST systems: signs up prior to tank install |
Reciprocity | State by state basis. Approval depends on training requirements of each states program. PA-Yes NY-No DEL-No |