UST Operator Training FAQs
Why is Operator Training being required?
Federal law mandates operator training requirements.
Who must be trained?
All individuals who operate, maintain, or are responsible for addressing emergencies presented by spills or releases from Underground Storage Tanks (USTs) must receive training based on their duties and level of responsibility for USTs. This requirement includes owner/operators of all regulated USTs including emergency generator USTs.
What are the levels of training?
Each underground storage tank system at a facility must have a certified Class A, Class B, and Class C Operator designated. An individual can be certified for all three classes as long as they are trained in all three.
When must Operators be trained?
Class A and Class B Operators must be trained within 30 days of assuming operation and maintenance responsibilities for the UST system. Class C Operators must be trained before assuming responsibility for responding to emergencies.
Is the Class A, B, & C Operator training the same thing as the WV Certified Worker Program which has Classes A, B, C, D, and E Certified Workers?
No. The Operator training is for owner and operators. The certified worker program is for those who want to install, remove, repair, test, and/or repair UST systems.
How do I know which level of training I need to take?
The following are definitions of the different operator classifications. Owners must determine who best fits this role at their facilities.
Class A Operators are responsible for the broader aspects of compliance and are typically in management positions. They are at the highest level of responsibility. In smaller operations this will likely be the tank Owner/Operator and within a larger company this may be an Environmental Manager. The Class A operator’s responsibilities include managing resources and personnel, such as establishing work assignments, to achieve and maintain compliance with regulatory requirements.
Class B Operators implement the regulatory requirements on a daily basis at one or more facilities. Class B Operators must have a more in depth understanding of operation and maintenance aspects but will have a narrower area of responsibility than a Class A Operator. For a large corporation this could be a district manager, maintenance supervisor, or a site manager, for a smaller company it may be the owner or operator. This individual implements day-to-day aspects of operating, maintaining, and recordkeeping for USTs.
Class C Operators are the first line of response to an emergency event. In most instances this will be the clerk or store manager. The Class C Operator controls the dispensing of fuel and is responsible for initial response to alarms or releases. This individual notifies the Class A and Class B operator and appropriate emergency responders when necessary. An Operator with at least a Class C certification must be on site during fueling operations at all facilities, unless the facility has been designated as an unmanned facility.
Do the Class A and/or B operator have to be on site all the time?
No. The Class A and/or B do not have be on site at all times; however, there must be a Class C operator on site during all hours of operation unless the facility has been designated as an unmanned facility. However, in the case of an unmanned facility, a Class C Operator must be available at all times to respond immediately to calls from the facility and must be capable of reaching the facility within 60 minutes.
I have multiple facilities. Can I designate one person as my Class A Operator for all of the facilities?
Yes. Every owner must have one person that is a certified Class A Operator, however if the owner should have multiple locations they would be able to designate one person to be over all of their facilities. WVDEP would caution against putting one person over so many facilities that it may inhibit their ability to fully perform their duties as a Class A Operator. This person or persons must be someone within the organization that the owner has designated as their Class A Operator. The role of the Class A operator cannot be filled by an outside contractor/consultant.
I have multiple facilities. Can I designate one person as my Class B Operator for all of the facilities?
Yes. Every owner must have one person that is a certified Class B Operator, however if the owner should have multiple locations they would be able to designate one person to be over all of their facilities. WVDEP would caution against putting one person over so many facilities that it may inhibit their ability to fully perform their duties as a Class B Operator. WVDEP will give consideration to allowing the Class B Operator role to be performed by a contractor/consultant when formally requested and approved by WVDEP.
Can a facility have multiple individuals in each classification?
Can a facility have one person in all three Operator classifications?
Yes. One person can serve as a Class A, Class B, and Class C Operator. However, multiple Class C Operators will likely be necessary at most facilities because a Class C Operator must be on site during fueling operations.
Can a contractor/consultant serve as the Class A Operator for my facility?
No. The Class A Operator role is fulfilled by the owner/operator and cannot be contracted out.
Can a contractor/consultant serve as the Class B Operator for my facility?
Yes. WVDEP will give consideration to allowing the Class B Operator role to be fulfilled by a contracted individual when formally requested and approved by WVDEP.
Do I have to have to keep proof of my training?
Yes. Each Class A and Class B Operator must carry proof of training during duty hours, and each Class C Operator must have proof of training present at the location where the Class C Operator is on duty. The certified operator (Class A, B, & C) must have personal photo identification available that will enable WVDEP to verify that certified operator's identity.
Can a Class A or Class B Operator train the Class C Operator?
Yes, beginning October 13, 2018 the Class A or Class B operator can train the Class C operator. This is consistent with the newly adopted federal regulations.
Is annual Operator refresher training required?
No, there is no requirement for annual refresher training. However, WVDEP reserves the right to require retraining of Operators if it is determined that a UST system at their facility does not meet significant operational compliance. WVDEP will determine whether Class A, Class B, or both classes of operators require retraining based on the compliance issues observed.
Does West Virginia recognize the Operator Training I received from another state?
No. WVDEP does not have reciprocity with other states for the Operator Training Program.
Who are the approved training vendors?
WVDEP approved training vendors are listed on the UST Operator Training web page. As we approve additional vendors, their names and contact information will be added to the web page.
What happens if I fail to meet the training deadline?
Failure to properly train any operator class or comply with the training requirements is a violation of the Code of State Rules Title 33, Series 30 and may result in an enforcement action being taken by WVDEP.
What happens if an ownership change occurs or new people are hired?
If an ownership change occurs, any new Class A and B operators must be designated and trained within 30 days of the change of ownership. If a Class A and/or B operator is replaced at a Facility, the Class A and/or B operator must be trained within 30 days of assuming their job duties. All Class C operators must be trained before beginning their job duties.
What if I don’t sell fuel to the public? Does this make a difference?
No. All facilities having at least 1 active regulated UST must have at least one Class A, Class B, and Class C operator designated for that facility.
If I have an unmanned site, do the requirements for having a Class A, Class B, and Class C Operator still apply to me?
Yes. Every facility, manned or unmanned, must have a Class A, Class B, and Class C Operator designated for the facility.
What is the Operator Training requirement if my facility is manned during the day, but is unmanned at night?
Every facility, manned or unmanned, must have a designated Class A, Class B, and Class C Operator. A Class C Operator must be on site during all hours of operation. If approved by WVDEP as an unmanned facility, a Class C Operator must be available at all times to respond immediately to calls from the facility and must be capable of reaching the facility within 60 minutes.
Do I just declare my site as unmanned or do I have to do something else?
WVDEP will consider written requests from owners for designating certain types of facilities as unmanned on a case by case basis. Requests for unmanned status must be submitted to the Tanks Program Manager.
Are there any criteria for unmanned sites that don’t apply to manned sites?
WVDEP approval is required to be considered for the unmanned site exemption. Information must be provided to WVDEP regarding how the Class C Operator(s) will be notified and how they will respond to emergencies. Unmanned facilities will be required to have at least one Class C Operator available at all times to respond immediately to calls from the facility and they must be capable of reaching the facility within 60 minutes. Owners will have to develop and post emergency procedures for their facilities.
What is an “unmanned” facility?
In general, an "unmanned” facility means a UST facility that does not have an attendant present during all hours of operation. Examples of such UST facilities would include unattended card lock facilities, emergency generator sites, and some government emergency response service providers.
What is an unattended card lock facility?
It is a vehicle fueling facility which uses a mechanical or electronic method of tracking fuel deliveries using an identification card which is generally operated without the presence of an on-site attendant.
Will I meet the requirements for an unmanned facility if I have only one Class C Operator designated for the facility?
Technically, a facility is required to have a minimum of one (1) Class C Operator available; however, as a practical matter, multiple Class C Operators would likely be needed for a facility due to vacations, illnesses and so forth. If an emergency occurs or a UST inspectors shows up at the site, the Class C Operator must be able to be on-site within 60 minutes of a phone call being made to the Class C Operator. If the Class C Operator is not on-site within this time frame then it is a violation of the UST rule.
What do I need to do to get my site approved as “unmanned”?
WVDEP will consider written requests from owners for designating certain types of facilities as unmanned facilities on a case by case basis. Request for designating a facility as “unmanned” should be made by the UST owner to the WVDEP Tanks Program Manager and should include the following information:
- WV Facility Identification number
- Name of Facility
- Location of the Facility
- Reason why the owner believes that the UST system should be designated as an “unmanned facility.”
- If the facility is “manned” for part of the day and the owner is seeking “unmanned” status for part of the day, please provide information on the hours the site will be “manned” and the hours intended for “unmanned” status.
- Information on how the Class C Operator(s) will be notified and what procedures they will follow in responding to emergencies.
- Explanation of the emergency procedures to be utilized for facility.
- A description of how emergency procedures will be prominently posted at the site.
What type of information should be included in the emergency procedures to be posted at unmanned sites?
At a minimum, the written emergency procedures to be posted at an “Unmanned Facility” should include the following information:
- WV identification number and physical address of facility (includes street address, municipality, and county).
- Contact information including phone number that will reach a Class C operator (Note: Unmanned facilities must have at least one Class C Operator available at all times to respond immediately to calls from the facility and who is capable of reaching the site within 60 minutes).
- Emergency phone numbers: police, fire, hazardous response, 911.
- Procedures necessary in response to an alarm associated with the release detection equipment (if applicable).
- Procedures necessary in response to a spill.
- WVDEP emergency spill hotline telephone number 800-642-3074.