Mandatory Training for UST Operators- One State Down, 49 to Go. Observations from the Oregon Front Line
By Ben Thomas
An ambitious deadline. A new series of requirements. A constant barrage of reminders. A limited number of service providers. Confused tank owners. And thousands of tanks at stake. Is it the 1998 upgrade deadline? Not exactly, but close.
On March 1, 2004, Oregon became the first state to have achieved a regulatory deadline for training underground storage tank (UST) operators. By that date, every owner of fuel dispensing UST systems in Oregon must have designated a person as the official “operator” and have proven that the operator received formal training on all of Oregon’s UST rules. They had nine months to do it. No problem.
Oregon met the challenge in a unique way that didn’t require a significant resource burden on the Department of Environmental Quality. In fact there was virtually no burden; they relied on private enterprise to deliver the whole thing. First, they created guidance to qualify training vendors. Then they created guidance for would-be instructors to follow. Then they invited the instructors to post their contact information and training dates on the state’s web site. Then the DEQ broadcast letters statewide alerting operators that training options were now available. Later DEQ would audit classes to make sure the trainers were doing the right thing.
As a listed vendor, I personally trained over 25%** of all Oregon operators from June 2003 to April 2004. That’s over 500 people in 30 classes in nine months. Students had to take my eight-hour class on UST regulations, including lessons in administrative rules, financial responsibility, enforcement, leak detection, spill and overfill prevention, corrosion protection, suspected releases, and other applicable codes. Eight hours bought them a full day lecture, a reference guide, two quizzes, multiple classroom exercises, and a certificate of completion.
When a large number of people are forced to take a class in a topic many of them have been working in for years, you learn some interesting things. Some thought they knew enough to get by. Some didn’t know where to begin. Some simply don’t want to burn up eight hours in a classroom. One day last summer at a class, an older gentleman crossed his arms and said loudly “I’ve been pumping gas for 45 years and I’ll be damned if I’m gonna sit here and let some pissant kid tell me how to pump gas.” Needless to say, he needed some convincing on the value of the day that lay ahead.
Provided below are my personal observations of the great Oregon UST Operator Training Experiment. It’s nothing scientific but it is based on talking to hundreds of operators, fielding over a thousand questions, chatting with area service providers, and reading several hundred class quizzes and feedback forms. Because it is the only training summary of its kind to date, I thought the readers might find these reflections useful if they decide to bring a comprehensive training package to other states.
□ Needing to upgrade the operator. Nearly everyone had an automatic tank gauge, and a number of operators knew it did a test, but the average Joe didn’t know much more. Items like keeping the tank full enough to get a valid test, 12 months of record history, responding to invalid tests, proving third party certification, and periodic maintenance and calibration seemed like novel topics of discussions.
□ Tanks 101: C+. That being said, I found the average attendee had a fundamental grasp on tank system basics. They knew they had certain alarm capabilities. They knew they had a tank “computer” that did something or another. They generally knew whether they had steel or fiberglass systems. What they didn’t know was how to organize all these rules into one manageable bundle. One student commented “I wish this class was available years ago.”
□ Did they know? Virtually everyone with pressurized line has line leak detectors (or so they claimed). A decent number of operators knew they needed an annual line tightness test and line leak detector function test, but I wasn’t so sure these tests were widely done each and every year. Many with double-wall pipes didn’t know about the importance of keeping containment sumps clean and free of liquid. When asked what certain alarms meant, I was met with plenty of blank stares.
□ Old news to some. A few large companies already had progressive record keeping and training programs in place. ConocoPhillips in particular has an excellent record tracking system for which they require all their dealers to adhere. These students tended to understand the more in-depth requirements and asked more complex compliance questions during class.
□ A pleasant surprise. When surveyed, the majority of students found the class relevant and useful. That surprised me, given that nearly everyone who took the class did so against their will. For a population of students who have a grasp on tank system basics, that tells me there is still much to learn, and much that can be learned (especially when they have to take a class).
□ Side effects. I haven’t been able to quantity it, but I think I created a lot of work for service providers doing testing and maintenance in the Northwest. The main grumble I heard at the end of the day was “Boy, am I due for a checkup.” One thing I really encourage operators to do is to set up an annual “tank physical” so their system can be given a top-to-bottom inspection on a routine basis.
□ Value. Operators overwhelmingly felt like they were now better prepared for a compliance inspection after taking an eight-hour course. I spoke with a few operators who were inspected shortly after the class. They all said me they passed with flying colors. They told me they now understood the equipment, what the inspectors wanted, and how to get into compliance based on what they were doing wrong when they first came to class.
□ Did they learn anything? I gave all students a 10-question multiple choice quiz on basic UST rules before each class. The average score coming into the class cold was 50%. I gave the same quiz at the end of the day. The average score jumped up to 90%. That tells me people were paying attention and showed improvement on their comprehension of basic UST rules.
DEQ inspectors have told me they have seen a noticeable increase in preparedness for compliance inspections. That might be an obvious conclusion, since the owner must now by law designate an operator to handle UST matters, but the inspectors are thrilled nonetheless. The more ready an operator is, the quicker the compliance inspection and, hopefully, the fewer the violations to follow up on.
So now that the deadline has passed, what’s the compliance rate for training? Not bad. DEQ estimates that over 80% of the UST systems in Oregon now have designated, trained operators. Officials says it might be more like 90% because they are still receiving verifications around the state. That’s impressive given the state didn’t enforce the requirement but rather encouraged people to get trained using the state’s normal outreach channels.
And what about the cranky old fellow who didn’t want me telling him what to do? Over the course of the day, a slow transformation occurred. He eventually quit glaring at me, uncrossed his arms, picked up his pen, and started taking notes. Soon he was asking questions. By the end of the day he was smiling and joking. As he was leaving, he approached me and agreed, almost seemingly against his better judgment that the course has been worth his while. He said he had to get back to the station to make himself a record keeping binder for the next inspection.
Ben Thomas ran the Alaska UST leak prevention program from 1995 to 2002. He now has a consulting and training business in Washington State.
(** Note, after 9 years that number has grown to over 80+%)