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UST - Module 1

Operator Training Introduction

QuestionAnswer
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
Created by: Mtorres732
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