The PASS Training Marketplace

Class A/B and C Operator Training
PASS’ UST Owner/Operator Training (for Class A/B Operators) and Class C Operator Training may be used to train operators at UST facilities located on tribal lands. These are national courses which are designed to meet or exceed the requirements of the Energy Policy Act of 2005 and the Environmental Protection Agency’s (EPA’s) UST regulations (40 CFR 280). Remember that revisions to 40 CFR 280 are being finalized, and once they go into effect all UST operators in Indian Country will require training. See our August 2013 issue of PASSing Notes for more information.

All of PASS’ UST operator training courses meet and exceed the federal requirements for UST operator training and are offered through our in-house designed and built Learning Management System (LMS). PASS’ state-specific A/B training courses are custom tailored to meet state requirements, and are accepted by more states than any other training provider. Our courses are available on demand, 24/7 and are accessible from any internet-connected computer, tablet, or phone. The student can complete an entire course in a single session or take the course in segments. The training may be stopped and restarted, allowing for maximum schedule flexibility. PASS also does not impose time restrictions on course access, so students may take as much time as they need to complete their training. Once training is completed a certificate is available to save and print.

Release Reporting

If a leak takes place in Indian Country, then the EPA’s Regional UST program should be contacted.

Release Detection

Release Detection Methods for Tanks

Automatic tank gauging (ATG)
Interstitial monitoring
Secondary containment with interstitial monitoring
Statistical Inventory Reconciliation (SIR)
Manual tank gauging
Vapor monitoring
Groundwater monitoring
Tank tightness testing

Financial Responsibility

Owners/operators may use any of the following financial responsibility mechanisms.

Obtain Insurance
Use a Financial test
Obtain a corporate guarantee
Obtain a letter of credit
Obtain a surety bond
Rely on a state fund

Delivery Prohibition/Non-Compliance Enforcement

Delivery prohibition programs prohibit product delivery to underground storage tanks that have one or more compliance violations, as determined by a state or territory. States and territories generally use one of two methods for identifying the delivery eligibility status of USTs:

Red Tag Program
Delivery prohibition programs that physically identify USTs that are ineligible to receive product. The mechanisms are usually red tags, but the mechanisms and their colors can vary by state. The mechanisms are generally attached to the fill pipes of ineligible tanks. If an UST does not have a red tag, then the deliverer can assume that the tank is compliant and eligible for delivery.
Green Tag Program
Delivery prohibition programs that physically identify USTs that are eligible to receive product. The mechanisms are usually green tags or permits, but the mechanisms and their colors can vary by state. The mechanisms are generally conspicuously displayed at the UST facility. If a green tag or permit is present, then the deliverer can assume the tank is compliant and eligible for delivery. The absence of a green tag or permit prohibits deliveries to the UST.

Temporary & Permanent Closure

Closing Temporarily

You may temporarily close your UST for up to 12 months by following these requirements:

Continue to maintain and monitor any corrosion protection systems
Continue to maintain financial responsibility
Beginning on October 13, 2018 your operators must be trained
If your temporarily closed UST is not empty, you must also:
- Continue to monitor for leaks by performing release detection
- Perform monthly walkthrough inspections for your release detection beginning on October 13, 2018
- Perform annual inspections and testing of release detection equipment beginning on October 13, 2018
- Perform three year containment sump testing if using the containment sump for interstitial monitoring of the piping beginning on October 13, 2018
If a release is discovered, quickly stop the release, notify your regulatory authority, and take appropriate action to clean up the site.
If the UST remains temporarily closed for more than 3 months, leave vent lines open, but cap and secure all other lines, pumps, manways, and ancillary equipment.

USTs in temporary closure are not required to meet the following requirements:

Spill testing
Overfill Inspections
Empty USTs do not require:
- Release detection
- Annual release detection testing and inspections
- Monthly walkthrough inspections
- Three year containment sump testing

An UST is considered empty if no more than one inch of residue is present or not more than 0.3 percent by weight of the total capacity of the UST system remains in the system.

After 12 months of temporary closure, you have three options:

You must permanently close your UST if it doesn't meet the applicable requirements for new or upgraded USTs (except for spill and overfill).
You can ask your implementing agency for an extension beyond 12 months, if you provide an assessment that determines whether contamination is present at your site.
Your UST can remain temporarily closed without needing an extension granted by the implementing agency if the UST meets the applicable requirements for new or upgraded USTs (except for spill and overfill) and the requirements noted above for temporary closure.

Closing Permanently

If you decide to close your UST permanently, follow these requirements for permanent closure:

Notify the implementing agency at least 30 days before you close your UST.
Determine if contamination from your UST is present in the surrounding environment. If there is contamination, you may have to take corrective action. For at least 3 years, keep a record of the actions you take to determine if contamination is present at the site (or you can mail this record to your implementing agency).
Either remove the UST from the ground or leave it in the ground. In both cases, the tank must be emptied and cleaned by removing all liquids, dangerous vapor levels, and accumulated sludge. These potentially very hazardous actions need to be carried out carefully by trained professionals who follow standard safety practices. If you leave the UST in the ground, have it filled with a harmless, chemically inactive solid, like sand, or close it in place in a manner approved by the implementing agency.

Don't forget to check with your implementing agency for their closure requirements.

Recordkeeping

You will have to keep records of leak detection performance and maintenance:
- The last year's monitoring results, and the most recent tightness test.
- Copies of performance claims provided by leak detection manufacturers must be kept for five years.
- Records of recent maintenance, repair, and calibration of on-site leak detection equipment.
- 2015 Requirement: Beginning on October 13, 2018 keep records of annual release detection equipment operations tests for three years.
- 2015 Requirement: Beginning on October 13, 2018 keep records of site assessments for groundwater and vapor monitoring methods for as long as the methods are used.
- 2015 Requirement: Beginning on October 13, 2018 keep the most recent tank tightness test, piping tightness test and vapor monitoring result using a tracer compound for airport hydrant systems and field-constructed tanks.
You will have to keep records of the last three 60 day rectifier inspections and the last two three year tests of your corrosion protection system.
If corrosion protection equipment is not used for metal tanks and piping, you must keep a record of the corrosion expert’s analysis of the site corrosion potential for the life of the UST system.
You must keep records showing that a repaired or upgraded UST system was properly repaired or upgraded until the UST system is permanently closed or undergoes a change-in-service.
For at least 3 years after closing an UST, you must keep records of the site assessment results required for permanent closure. (These results show what impact your UST has had on the surrounding area.)
You must keep records that document your financial responsibility, as explained in EPA's booklet, Dollars And Sense.
2015 Requirement: Beginning on October 13, 2015 keep records demonstrating compliance with the compatibility requirement if storing regulated substances containing greater than 10 percent ethanol, greater than 20 percent biodiesel or any other regulated substance identified by the implementing agency, for as long as the UST system is used to store the regulated substance.
2015 Requirement: Beginning on October 13, 2018 keep records of spill bucket testing, containment sump testing, and overfill inspections for three years. If spill bucket or containment sump testing is not conducted, keep documentation showing the equipment is double walled and the integrity of both walls is periodically monitored for as long as testing is not conducted.
2015 Requirement: Beginning on October 13, 2018 keep records of walkthrough inspections for one year.
2015 Requirement: Beginning on October 13, 2018 keep records of demonstrating compliance with the operator training requirements.

The preceding discussion is summarized from the regulatory language in 40 CFR Part 280.34.