A/B/C Operator Information

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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 Wis. Admin. Code §​ ATCP 93 Subchapter VIII. The following information pertains to requirements under the ATCP 93 Flammable, Combustible, and Hazardous Liquids Code, enforced by the Department of Agriculture, Trade and Consumer Protection (DATCP)​. Regulatory oversight of the operator training requirement will be via annual inspections and the Permit-To-Operate process.​ See also 40 CFR 280 (Federal EPA UST Rule)​.


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How to Obtain the Req​​uired Train​​ing 

Class A and B operators must obtain a certificate from a DATCP-approved training program. Class C operators may be trained by the​ accredited Class A or Class B facility operator where the Class C operator is employed or may obtain a certificate from a DATCP-approved training program. Approved training programs are listed below.

Class A and/or B Training & Testing Vendors
 Class C ​Training & Testing Vendors 

ANTEA Group (formerly API)
(888) 951-3456

Petro Classroom/Williams & Company 
(844) 303-6752

PASS 
(765) 281-5588

UST Training 
Ben Thomas​
(866) 301-8265

​eSpec Software, LLC 
(800) 274-4437


1st Choice Gassy Tanks
(844) 602-1555​

ANTEA Group (formerly API)
(888) 951-3456

eSpe​c Software, LLC​ 
(800) 274-4437

JMM Management Group, LLC
(​847) 888-0276

Petro Classroom/Williams & Company
(844) 303-6752

PASS
(765) 281-5588

​Titan Management Group
U.S. Interactive
(800) 505-5095

UST Training
Ben Thomas
(866) 301-8265

Department of Commerce Training for ​Emergency Generator, Used Oil & Chemical Tank Operators Only

Note: Ensure that pop-ups are enabled in your web browser before beginning this training. Certifications cannot be recovered. You must re-take the exam if your certification does not print. ​

​Documenta​​tion ​and Training Deadlines 

To report an A or B operator, please send a copy of the new A/B Operator certificate including the facility ID and/or address to:

DATCP Bureau of Weights and Measures
PO Box 7837
Madison, WI 53707-7837

Alternatively, email: DATC​PStorageTanks@wisconsin.gov.         

To report multiple operators, you may use the A/B Operator Designation​ form. 

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. ​​ 

Class C operators who are trained by the accredited Class A or Class B facility operator where the Class C operator is employed may use DATCP's Class C UST Operator Certificatio​n form to document the training and certification.


Reco​rdkee​p​ing

The owner or operator must maintain operator documentation at the attended fueling system facility and have it immediately available for inspection by an authorized agent or the department. Wis. Admin. Code § 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."

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 retraining. Certificates verifying completion of training or retraining must be maintained in paper or electronic form by the owner or operator.

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


Responsibilities of Oper​​ato​​​rs

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 and maintain the UST system in accordance with applicable requirements. The Class B operator typically implements in-field aspects of operation, maintenance, and recordkeeping 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, recordkeeping, and reporting are met.
  • Requirements for leak or release prevention equipment, recordkeeping, and reporting are met. 
  • All relevant equipment complies with performance standards. 
  • Monthly periodic inspections required under PEI RP 500 and RP 900 per Wis. Admin. Code §§​ ATCP 93.500(8) and ATCP 93.605(1) are performed or reviewed monthly by a Class B operator. 
  • Appropriate individuals are trained to respond properly to emergencies or alarms relating to spills, leaks, or releases from the underground storage tank system. 

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.
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 Wis. Admin. Code § 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.
    • Note: Wis. Admin. Code § 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 Wis. Admin. Code § 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.

How to Obtain Appr​​oval of an Operator Trainin​​g Program

Operator training must include evaluation and accreditation of the operator's knowledge of the applicable requirements in §§ ATCP 93.840 to 93.842. Training programs must be approved by DATCP. Request for training approval must be submitted to DATCP on form TR-WM-159 which is available on our forms page. There is no fee for training approval. Training programs may request approval to offer training to the public, for internal personnel only, or both. For questions regarding approval of operator training programs, please contact our Compliance U​nit at (608) 224-4942, option 4, or by email at datcpwmcompliance@wisconsin.gov. ​

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Requirements for O​​perat​​or Tra​​​ining​

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 recordkeeping requirements and standards of this chapter regarding all of the following: 
    • Spill prevention. 
    • Overfill prevention. 
    • Leak and release detection. 
    • Corrosion protection. 
    • Emergency response. 
    • Product compatibility.
  • Tank registration and permitting requirements.
  • Financial responsibility documentation requirements.
  • Notification 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

Training for a Class B operator must provide a more in-depth understanding of operation and maintenance aspects but may cover a narrower range 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:

  • The purposes, methods, and function of: 
    • Components of underground storage tank systems. 
    • Materials of underground storage tank system components. 
    • Methods of leak and release detection, and leak and release prevention applied to underground storage tank system components. 
  • Operation and maintenance requirements of this chapter which apply to underground storage tank systems and which address each of the following: 
    • Spill prevention. 
    • Overfill prevention. 
    • Leak and release detection. 
    • Corrosion protection. 
    • Emergency response.
    • Product compatibility.
    • ​Reporting and record​keeping requirements. 
    • Class C operator training requirements.

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.


Ret​​raining

If DATCP​ 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​ online.

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