DEQ to Begin Enforcement of UST Facility Class A, Class B, and Class C Operators on January 2, 2013

by GGTM Law on September 24, 2012

Based upon mandates from the federal government, Michigan amended its underground storage tank (UST) rules to require that each UST facility have Class A, Class B, and Class C operators. These Michigan rules became effective on May 8, 2012, with a deadline for operator certification of August 8, 2012. The categories of operators are as follows:

  • Class A: This person has primary responsibility to operate and maintain the underground storage tank system. For a typical gas station, it is the owner of the station or his designee. For large corporations, it is the manager or designee responsible for tank operations. The Class A operator can also be designated as a Class B operator as long as he/she has passed the Class B operator exam. A broad knowledge base is required for a Class A operator.
  • Class B: This individual implements the day-to-day aspects of operating, maintaining, and record keeping for underground storage tank systems at one or more facilities. For a typical gas station, it is the owner or the person/company contracted by the owner to maintain the tanks. For large corporations, it is the employee, person/company contracted by the corporation to maintain the tanks. The Class B operator must have in-depth knowledge of tank system operation and maintenance.
  • Class C: This individual is responsible for responding to alarms or other indications of emergencies caused by spills, releases, or overfills associated with an underground storage tank system. For a typical gas station, this is the cashier. A test is not required, however this person must be trained in responding to releases, alarms, and emergency conditions. Training can be performed by Class A or Class B operators, or by third-party vendors. Class C operator training must be documented.

Beginning August 9, 2012, DEQ inspectors (Hazardous Materials Storage Tank Inspectors) have been checking for compliance with this new certification requirement as a part of their UST facility inspections. Due to the compressed timeframe for training and testing, the DEQ has stated that enforcement actions will not be taken until January 2, 2013.

Class A and B operators must be properly trained and pass a written test in order to be certified. Class C operators must be properly trained, but are not required to take a test. For more detailed information, click on the following link: http://www.michigan.gov/deq/0,4561,7-135-3311_4115_4238-287280–,00.html.

 

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