Operator Training Requirements for Operators of Federally Regulated Underground Tanks
The Federal Energy Policy Act of 2005 required states to develop training requirements for individuals who operate and maintain federally-regulated underground storage tank systems. Operators are owners or owners' representatives (Class A), the actual persons charged with supervising day-to-day operations (Class B) and on-site employees (Class C).
The Energy Policy Act of 2005 was codified in
ATCP 93 Subchapter VIII. The following information pertains to requirements under the ATCP 93 Flammable, Combustible and Hazardous Liquids Code. Regulatory oversight of the operator training requirement will be via annual inspections and the Permit-To-Operate process.
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Acceptable Training and Certification Processes
Operator training must include evaluation and accreditation of the operator's knowledge of the applicable requirements in ss.
ATCP 93.840 to
93.842. Training programs must be approved by DATCP.
Class A and B operators must obtain a certificate from a DATCP approved training program. Class C operators may obtain a certificate from a DATCP approved training program or from the accredited Class A or Class B facility operator where the Class C operator is employed indicating the Class C operator has successfully completed training for the facility.
All Class A, Class B, and Class C operators must obtain the training and certification required before assuming their responsibilities except that existing, compliant facilities that experience a personnel change have 30 days to have a new class A or B operator trained. Facilities must notify DATCP of A or B operator changes within 15 days of the new operator completing the training program.
Responsibilities of Operators
Class A Operators - The Class A operator is the individual who has primary responsibility to operate and maintain the UST system in accordance with applicable requirements. The Class A operator typically manages resources and personnel, such as establishing work assignments to achieve and maintain compliance with regulations. The Class A operator is responsible for all of the following:
Compliance with tank system registration and permit to operate requirements.
Managing resources and personnel, such as establishing work assignments, to achieve and maintain compliance with regulatory requirements.
Ensuring that appropriate individuals do all of the following:
Properly operate and maintain the underground storage tank system.
Maintain appropriate records.
Receive training to operate and maintain the underground storage tank system and keep records.
Properly respond to emergencies or alarms relating to spills, leaks or releases from the underground storage tank system.
Make financial responsibility documents available to the authorized agent or the department as required.
Class B Operators - The Class B operator is the individual who has day-to-day responsibility to operate a maintain the UST system in accordance with applicable requirements. The Class B operator typically implements in-field aspects of operation, maintenance, and record keeping for the UST system. The Class B operator is responsible for ensuring that all of the following occur:
Requirements for leak or release detection methods, record keeping, and reporting are met.
Requirements for leak or release prevention equipment, record keeping, and reporting are met.
All relevant equipment complies with performance standards.
Monthly periodic inspections required under PEI RP 500 and RP 900 per ss.
ATCP 93.500 (8) and
ATCP 93.605 (1) are performed or reviewed monthly by a Class B operator.
Appropriate individuals are trained to properly respond to emergencies or alarms relating to spills, leaks or releases from the underground storage tank system.
All Class C operators are provided with training and written instructions that include all of the following:
Emergency response procedures, including all of the following:
Procedures for overfill protection during delivery of regulated substances.
Operation of emergency shut-off systems.
Appropriate responses to all alarms.
Reporting of leaks, spills and releases.
Any site-specific emergency procedures.
The name and other information needed for contacting appropriate parties if a leak, spill, release, or alarm occurs.
A Class C operator is present during all operating hours of the underground storage tank system, except:
For fueling facilities which are attended as specified in s.
ATCP 93.605 (5) (a) and which include hours of operation when no attendant is on duty, a sign shall be posted in a conspicuous place, stating the emergency shutoff procedures and the name and telephone number of the Class B operator, along with the name and telephone number of the local emergency responders, including 911 personnel.
ATCP 93.605 (5) (a) reads as follows: To be considered as being an attended fueling facility, there shall be at least one attendant regularly on duty on a daily basis, but not necessarily during all hours of operation, to supervise, observe, and control the actual dispensing of fuel.
For fueling facilities that are not attended as specified in s.
ATCP 93.605 (5) (a), signage shall be posted as indicated above.
For facilities which are not addressed above and which typically are unmanned, such as emergency generators, signage shall be posted in accordance with the location and information requirements listed above.
Class C Operators - The Class C operator is the individual responsible for initially addressing emergencies presented by a spill or release from a UST system. The Class C operator typically controls or monitors the dispensing or sale of regulated substances. The Class C operator is responsible for all of the following:
Initially responding to alarms, spills, leaks, or releases.
Notifying the Class B or Class A operator and appropriate emergency responders, including 911 personnel, when necessary.
Controlling or monitoring the dispensing or sale of regulated substances
Requirements of Operator Training
Class A Operators
Each Class A operator shall attend department-approved training in all of the following:
Basic underground storage tank system requirements, so that the operator can make informed decisions regarding compliance and ensure appropriate individuals are fulfilling operation, maintenance, and record keeping requirements and standards of this chapter regarding all of the following:
Tank registration and permitting requirements.
Financial responsibility documentation requirements.
Requirements for reporting obvious and suspected releases.
Requirements for permanently closing a tank system and for placing a tank system temporarily out of service.
Operator training requirements.
Class B Operators - Compared with training for a Class A operator, training for a Class B operator must provide a more in-depth understanding of operation and maintenance aspects, but may cover a more narrow breadth of applicable regulatory requirements.
Class B operators must attend department-approved training which covers either site-specific training that is focused only on regulatory requirements and equipment specific to the operator's UST system facility, or general training that encompasses all regulatory requirements and typical equipment used in UST facilities. At minimum, Class B operator training must include all of the following:
Class C Operators - Class C operators must be trained to take appropriate action in response to emergencies, including situations that pose an immediate danger or threat to the public or to the environment, and in response to alarms caused by spills, leaks or releases from an underground storage tank system. Class C operators must be trained to understand site-specific emergency procedures and instructions.
The owner or operator must maintain operator documentation at the underground storage tank system site and have it immediately available for inspection by an authorized agent or the department. Records must identify all Class A, Class B, and Class C operators currently designated for the facility. This includes the names, class of operator trained, date of assumed duties, date of each completed initial training, and any retaining. Certificates verifying completion of training or retraining must be maintained in paper or electronic form by the owner or operator. Fueling facilities that are not attended as specified in section ATCP 93.605 (5) (a). At facilities that typically are unmanned, such as emergency generators, the owner or operator must maintain the documentation at a readily available site and provide it for inspection upon request. In addition, the Department is using a reporting system to identify those who must be listed by each company as the Class A and Class B operators. The database will also track which training and test each individual completed.
Note: ATCP 93.605 (5) (a) reads as follows: "To be considered as being an attended fueling facility, there shall be at least 1 attendant regularly on duty on a daily basis, but not necessarily during all hours of operation, to supervise, observe and control the actual dispensing of fuel."
If the Department determines that an underground storage tank system is not in compliance with release prevention and release detection requirements or exhibits a continuing pattern of non-compliance with Wis. Admin. Code § ATCP 93, the Department may require that the Class A, Class B, or Class C operators be retrained within 30 days.
Note: Significant operational compliance performance measures for release prevention and release detection, as developed by the U.S. Environmental Protection Agency, are available at
Approved Operator Training Programs