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UST Program - Leak Prevention - Frequently Asked Question #8

UST Program - Leak Prevention - Frequently Asked Question #8

Question: Who is a “facility employee” and therefore needs to be trained? Who provides the “facility employee” training? What tasks is a “facility employee” required to perform? How is the “facility employee” training requirement implemented at an underground storage tank (UST) facility that is not routinely staffed (“unmanned”)?

Answer: Not all employees at a particular facility are necessarily “facility employees.” As defined in the regulations, a “facility employee” is an individual who is employed on-site at an UST facility, and who may be called upon to respond to spills, overfills, or other problems associated with the operation of the UST system. In short, the “facility employee” is any person who is both involved with the day-to-day operation of the UST facility (e.g., facility manager ) and has a role related to the operation of the USTs (i.e., responding to spills, overfills, etc.). . All “facility employees” as defined in the regulations on-site must be trained, and at least one of the “facility employees” present during operating hours at staffed facilities is required to have current training.

For example, Gasoline Station X has several underground storage tanks and an associated convenience store. A cashier, whose responsibilities include responding to alarms, spills, and other associated problems outlined in the facility’s monitoring and response plans, runs the convenience store during its operating hours, from 9 AM to 5 PM. However, gasoline is for sale at the dispenser islands 24 hours a day. In this case, during the hours of 9 AM to 5 PM, this cashier serves as the “facility employee” for the UST facility. However, when the convenience store is closed and the cashier is not present, the UST facility has been permitted by the local agency to operate as an unstaffed facility. The requirement to provide “facility employee” training does not require UST facility to change existing staffing or hire additional personnel. Instead, it requires any “facility employees” who are working on-site to be trained.

The Designated UST Operator is the only individual who can provide on-the-job training to “facility employees.” “Facility employee” training is required every twelve months and the first training must be completed by July 1, 2005. Employees hired on or after July 1, 2005 must be trained within 30 days of their date of hire. This training cannot be delegated. The training for each “facility employee” must include, but is not limited to: 1) the operation of the UST system in a manner consistent with the facility’s best management practices (BMPs); 2) the “facility employee’s” role with regard to the monitoring equipment as specified in the facility’s monitoring plan; 3) the “facility employee’s” role with regard to spills and overfills as specified in the facility’s response plan; 4) the name of the contact person(s) for emergencies and monitoring equipment alarms. Examples of BMPs are available at on-line at: http://www.waterboards.ca.gov/water_issues/programs/ust/training/disclaimer_bmp.shtml.

For facilities that are not routinely staffed (i.e., an “unmanned” facility), the Designated UST Operator must implement a facility employee-training program approved by the local agency. This training should be based on the spill, overfill, alarm, and emergency response procedures in place at the facility. An example of an unmanned UST facility is a remotely located emergency generator UST facility or a “Cardlock-style UST fueling facility.”

This facility employee-training requirement does not change the day-to-day operation of an UST facility. If there are no “facility employees”, there is no need to hire a new individual to hold the “facility employee” title and be trained.

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