EPA Training Requirements for Petroleum Storage Tanks: UST vs. AST

The United States’ regulatory framework for oil storage and spill prevention has evolved over decades, shaped by landmark environmental laws. The origins of aboveground storage tank (AST) regulation in 40 CFR Part 112 trace back to the Federal Water Pollution Control Act of 1949, which was later amended and strengthened by the Clean Water Act (CWA) of 1972. In 1973, the Environmental Protection Agency (EPA) issued the first Spill Prevention, Control, and Countermeasure (SPCC) regulations under the authority of Section 311 of the CWA to address the risks of oil discharges into navigable waters from fixed facilities. These regulations formed the backbone of the training and operational requirements for personnel involved in AST facilities.

In contrast, the regulatory framework for underground storage tanks (USTs) developed later, primarily in response to growing concerns during the late 1970s and 1980s about leaking tanks contaminating soil and groundwater. The Resource Conservation and Recovery Act (RCRA), as amended in 1984 by the Hazardous and Solid Waste Amendments, authorized the EPA to establish a comprehensive program for USTs. By the late 1980s, the EPA promulgated 40 CFR Part 280 to govern UST system installation, operation, leak detection, spill prevention, and training. These two regulatory frameworks—SPCC for ASTs and Part 280 for USTs—reflect different environmental priorities: protection of surface waters in the former, and protection of subsurface soil and groundwater in the latter.

Understanding the differences in training requirements between these two programs highlights how regulatory approaches evolved to address distinct risks associated with different types of storage systems.

1. Overview of Training Goals for AST and UST Operators

Training requirements under 40 CFR 112 focus primarily on preventing discharges of oil into navigable waters and minimizing the environmental impact of spills at aboveground storage facilities. Personnel designated as 'oil-handling personnel' are trained to understand facility SPCC plans, operate and maintain equipment, and respond to discharges to protect surface waters.

Training under 40 CFR 280 aims to ensure that UST operators and designated personnel (Class A, B, and C operators) understand the operational requirements for leak detection, spill prevention, and emergency response. This training is tailored to preventing releases to the subsurface environment, protecting soil and groundwater from contamination. The different focus areas reflect the primary environmental concerns of each program.

2. Historical Evolution of Training Requirements

The SPCC regulations for ASTs emerged in the early 1970s as part of the first wave of national water pollution prevention measures under the Clean Water Act. At that time, the focus was on large spills of oil into rivers, lakes, and oceans, typically from industrial facilities or transportation hubs. Training for oil-handling personnel was included in §112.7(f) to ensure that facility staff could prevent, control, and respond to spills effectively.

By the 1980s, as environmental regulators recognized the widespread problem of leaking underground storage tanks, new legislation under RCRA drove the development of a parallel regulatory program. The establishment of operator classes—A, B, and C—was a hallmark of the UST program. These designations allowed for tiered responsibilities and targeted training: Class A operators for overall compliance, Class B for day-to-day operations and maintenance, and Class C for frontline emergency response.

This distinction between the historically surface-water-focused SPCC regulations and the groundwater-focused UST regulations explains why training for AST facilities emphasizes equipment operation, maintenance, and spill response, while UST training places more emphasis on leak detection, alarms, and emergency response procedures.

3. Enforcement of Training Requirements: Federal vs. State

While the EPA establishes the federal framework for both AST (SPCC) and UST training requirements, the enforcement mechanisms differ. Under the SPCC program in 40 CFR 112, enforcement remains primarily a federal EPA responsibility, although EPA often coordinates with state agencies during inspections, particularly in states that have parallel or complementary oil spill prevention regulations.

For USTs under 40 CFR 280, Congress directed EPA to approve state programs to implement and enforce UST requirements. Today, most states have primary enforcement authority for UST regulations, including operator training. EPA retains oversight and enforcement authority in Indian Country and in states without approved UST programs. This division reflects the localized nature of UST installations and the importance of state-level implementation to address diverse environmental and operational contexts.

4. Mandatory Training and Requirements

The training provisions in 40 CFR 112 and 40 CFR 280 differ in scope and in structure, timing, and assessment requirements. The table below summarizes these differences and illustrates how the regulatory expectations for UST and AST facilities diverge.

Aspect	40 CFR 280 – UST (Class C)	40 CFR 112 – Oil-Handling Personnel
Statutory training requirement	Yes — § 280.242 mandates training (or examination) for Class C (and Class A, B) operators.	Yes — § 112.7(f) requires that oil-handling personnel be trained.
Timing / when training must occur	Class C operators must be trained before assuming duties as Class C.	Training must occur at a minimum annually, and whenever there are significant changes to equipment or procedures. (§ 112.7(f)(1))
Training content scope	For Class C, the training must enable them “to take appropriate actions (including notifying appropriate authorities) in response to emergencies or alarms caused by spills or releases resulting from operation of the UST system.” (§ 280.242(c)(1))	More expansive: Oil-handling personnel must be trained in operation & maintenance of equipment to prevent discharges; discharge procedure protocols; relevant pollution control laws; general facility operations; and the contents of the facility’s SPCC Plan. (§ 112.7(f)(1))
Evaluation / assessment	Training must include evaluation (testing, practical demonstration, or other method acceptable to implementing agency) per § 280.242(d) / (e).	The regulation does not explicitly require a specific evaluation mechanism in § 112.7(f)(1), although in practice training programs often include assessment.
Retraining / refresher	For Class C, there is no explicit periodic retraining requirement in § 280.242, but Class A and B operators must be retrained if the system is out of compliance.	Part 112 expressly calls for training “at least once a year” and whenever significant changes occur. (§ 112.7(f)(1))
Recordkeeping of training	Part 280 requires owners/operators to maintain records verifying training (and retraining) for all designated operators (§ 280.245).	Part 112 requires that training records be maintained (in the inspection/test records, etc.) under § 112.7(e) and (f) (e.g. inspection and test records for 3 years).

5. Analysis of Key Differences

The fundamental distinction between the training requirements for AST and UST personnel lies in the risk each program is designed to mitigate. AST-related risks focus on catastrophic spills into surface waters, often requiring personnel to be proficient in containment and recovery techniques as well as familiarity with the SPCC Plan. Training in this context is usually broader and includes ongoing annual refreshers and updates as facilities change.

UST-related risks are typically associated with slow leaks or system failures that may be less visible but pose serious threats to soil and groundwater quality. Consequently, UST operator training focuses more on leak detection equipment, responding to alarms, and understanding specific system components. The tiered training structure (Class A, B, and C) enables targeted instruction for each operational role, a level of granularity absent in the SPCC framework.

Another key difference is the regulatory emphasis on retraining: SPCC explicitly requires annual training and whenever significant operational changes occur, while UST programs focus on initial training and retraining when noncompliance or operational deficiencies are identified. This reflects the preventive and operational nature of SPCC versus the compliance-oriented structure of UST regulation.

6. Conclusion

The differences between EPA’s training requirements for AST and UST systems reflect the distinct environmental challenges posed by aboveground versus underground storage. SPCC regulations emerged from the early efforts to protect surface waters from large oil spills, leading to a comprehensive program for oil-handling personnel focused on prevention and response. UST regulations, developed a decade later, were tailored to the unique risks of subsurface contamination and required a structured approach to operator training based on roles and responsibilities.

By examining these differences, facility owners and operators can better understand not only the regulatory obligations they face but also the underlying environmental rationale for their training requirements. This awareness is essential for maintaining compliance, protecting the environment, and improving the effectiveness of both SPCC and UST management programs.

Petro Classroom: Your Complete Training Partner for Petroleum Storage Tanks

When it comes to ensuring compliance, safety, and operational excellence in the petroleum storage tank industry, Petro Classroom stands alone as the only training provider offering comprehensive programs for both Aboveground Storage Tanks (ASTs) and Underground Storage Tanks (USTs).

Our courses are designed to meet and to exceed federal and state training requirements for all key stakeholders:

• Tank Owners and Operators – Gain a deep understanding of compliance obligations under both 40 CFR 112 (SPCC/AST) and 40 CFR 280 (UST) to reduce risk and avoid penalties.

• Oil-Handling Personnel – Receive training aligned with SPCC requirements to operate and maintain equipment safely and respond effectively to spills and discharges.

• Contractors and Service Providers – Learn the technical and regulatory knowledge required to perform maintenance, installation, and service work on AST and UST systems while maintaining compliance.

With decades of industry expertise through our parent company, Williams & Company Consulting, Inc., Petro Classroom has developed a robust portfolio of specialized courses, including:

• AST Compliance & SPCC Courses covering SPCC plans, fire codes, steel tank standards, and common tank system operations

• UST Class A/B/C Operator Certification Training available both in engaging classroom sessions and convenient online self-paced formats, ensuring flexibility for operators nationwide

Why Choose Petro Classroom

• Comprehensive Expertise: The only provider to cover AST and UST compliance training under one roof.

• Tailored Learning Options: Choose from classroom instruction led by seasoned industry professionals or 24/7 online training that is self-paced and accessible from anywhere.

• Practical and Effective: Courses include real-world scenarios, up-to-date regulatory insights, and tools to help participants confidently address day-to-day compliance and emergencies.

• For All Stakeholders: Our training serves the entire petroleum storage ecosystem—from facility owners and operators to field contractors and oil-handling staff.

Take Action Today

Do not leave compliance to chance—partner with Petro Classroom to ensure your team is trained, certified, and confident. Our comprehensive offerings for both AST and UST systems mean you can standardize your training approach, reduce administrative burden, and improve environmental protection.

Visit www.petroclassroom.com to explore courses and enroll.

Equip your personnel with the knowledge and skills they need to protect the environment, avoid costly violations, and keep your operations running smoothly—with Petro Classroom as your trusted training partner.

Petro Classroom Training

For more information about training programs and to explore the full range of courses available for AST and UST compliance, visit our official website at: www.petroclassroom.com.

Our website provides easy access to:

• Course catalogs and schedules for both AST and UST training.

• Online enrollment for self-paced and instructor-led training.

• Resources for tank owners, operators, oil-handling personnel, and contractors.

• Compliance updates and expert insights to keep your team ahead of changing regulations.

Petro Classroom will be your trusted partner in training and compliance, helping you stay informed and ready to meet both federal and state requirements for petroleum storage tanks.

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