Training Requirements for Operators
of Federally Regulated Underground Tanks
Energy Policy Act of 2005
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
The Energy Policy Act of 2005 was
codified in SPS 310
Subchapter VIII. The following information pertains to
requirements under the SPS 310 Flammable, Combustible and Hazardous
Liquids Code. Regulatory oversight of the operator training requirement
will be via annual inspections and the Permit-To-Operate process.
Acceptable Training and Certification Processes
Operator training includes evaluation of an operator's knowledge of
applicable requirements. Methods for meeting the requirements of Class
A and B include having either of the following: (1) certificate issued
by the International Code Council® showing an
individual has passed the Wisconsin underground storage tank operator
examination; or (2) written proof of successful completion of an
equivalent, alternate operator training and testing program that has
received prior approval from the Wisconsin Department of Safety and
Professional Services (DSPS). Alternate programs will include an
evaluation of operator knowledge through testing, practical
demonstration or other tools that the Department determines are
Class C operators must obtain training
and a certificate 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.
Each new or
existing facility with an underground storage tank system must have a
Class A, a Class B and a Class C operator designated by January
1, 2012. For an entity that demonstrates it meets the
definition of a small business in section 227.114 (1), Stats., the date
for having accredited operators is August 8, 2012.
Responsibilities of Operators
Class A Operators
- Manage resources and personnel, such as establishing work
assignments, to achieve and maintain compliance with regulations.
Ensure 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 tank
system and keep records. Properly respond to emergencies or alarms
relating to spills, leaks or releases from the underground storage tank
system and make financial responsibility documents available.
Class B Operators - Ensure that
all requirements for leak or release detection methods, leak or release
prevention equipment, record keeping and reporting are met. Ensure that
all relevant equipment complies with performance standards and
appropriate individuals are trained to properly respond to emergencies
or alarms relating to spills, leaks or releases from the underground
storage tank system.
Class B operators provide
Class C operators with written instructions that include emergency
response procedures, 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 and any site-specific emergency procedures. Give name and
other information needed for contacting appropriate parties if a leak,
spill, release or alarm occurs.
For fueling facilities which are attended and which include hours of
operation when no attendant is on duty, a sign must be posted in a
conspicuous place, stating the emergency shut-off procedures and the
name, address and telephone number of the Class B operator, along with
the name and telephone number of the local emergency responders,
including 911 personnel.
& B Contracting Options - A facility owner may
contract with a service company to fulfill the requirements of the
Class A or Class B operator. The facility owner must list with the
Department the individual(s) from the service company performing the
operator requirements and keep the appropriate certificate(s) on site
or readily available for inspection.
C Operators - Furnish initial response to alarms,
spills, leaks or releases, notify the Class B or Class A operator and
appropriate emergency responders, including 911 personnel, when
necessary and control or monitor the dispensing or sale of regulated
A Operators - Class A operators must be trained and
tested in basic underground storage tank system requirements, to make
informed decisions regarding compliance and ensure appropriate
individuals are fulfilling operation, maintenance, and record keeping
requirements and standards regarding all of the following: spill
prevention, overfill prevention, leak and release detection, corrosion
protection, emergency response, product compatibility, 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, and operator training and testing
Class B Operators
- Training and testing for a Class B operator provides 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 receive either site-specific operator training that is
focused only on equipment used at the operator's underground storage
tank system facility or broader training regarding regulatory
requirements that encompass all components of underground storage tank
systems, materials of tank system components, methods of leak and
release detection and prevention, operation, and applicable maintenance
requirements. Training and testing must address spill prevention,
overfill prevention, leak and release detection, corrosion protection,
emergency response, product compatibility, reporting and record keeping
requirements plus Class C operator training requirements.
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
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, except for
fueling facilities that are not attended as specified in section SPS
310.605 (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.
SPS 310.605 (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 significant compliance, the Class B operator must be retrained
within 60 days or another time period prescribed by the Department, in
the areas that are determined to not be in compliance, except both the
Class A and Class B operators must be retrained if so directed by the
operational compliance performance measures for release prevention and
release detection, as developed by the U.S. Environmental Protection
Agency, are available at www.epa.gov/oust/cmplastc/soc.htm.
Operator Training / Testing Grants
Grants are available through the Wisconsin Department of
Safety and Professional Services (DSPS) to help offset the cost of
training and examinations required for persons who must be certified to
operate federally regulated underground storage tanks.
The grant can be used to pay the Wisconsin ICC test fee or can be
applied toward the cost of tuition for a state approved Class A, Class
B or Class A/B test or training course. Only one grant will be awarded
per person to Wisconsin tank operators on a first come basis, subject
to available funds. DSPS will give priority to small business owners,
civic organizations or government agencies. Operators for large
businesses will also be considered for grants, depending on funding
availability. (Note: Section 227.114 (1) Wis Stats, reads in part: "
'Small business' means a business entity, including its affiliates,
which is independently owned and operated and not dominant in its
field, and which employs 25 or fewer full-time employees or which has
gross annual sales of less than $5,000,000."
Applicants MUST indicate which test or
training course will be chosen. Grants are specific to the test or
training course; it is IMPORTANT that applicants RESEARCH the test or
training course best suited for their needs BEFORE applying for grant.
An owner or operator who wishes to submit an application for a
grant must apply
on-line. After a receiving a grant, a code will be sent to
the applicant to use for payment of fees when registering for the test
or training course.
Operator Training and Testing Vendors
Vendors or organizations seeking training or test approval must contact
Mike Fehrenbach (contact information below).
Class A and/or Class B Operator
& Testing Vendors
Class C Operator
& Testing Vendors
Generator, Used Oil & Chemical Tank Operator Web Training
& Testing (online)
Testers, LLC - Robert
Safety Solutions (online)
Training by Petroleum Training Solutions - Ben Thomas (Webinar)
International Code Council Test
registration instructions below for WICC:
Reservation when using
grant for payment:
for a grant (voucher) to pay the test fee.
- Call Pearson Vue
test center at (800) 275-8301 to Request an Exam
Select test code, test site
location, date/time and give demographic information.
WA-WI Class A UST
System OP (Class A)
Class B UST System OP (Class B)
wants to be Class A and B operators, it is only necessary to take and
pass the Class B test).
method is the voucher number (grant code) sent to the
Reservation when NOT
using grant for payment:
to "UST/AST Certification" at bottom of Pearson
Vue ICC web page, click on "Request an Exam
Registration", follow instructions, select test code,
test site location, date/time and give demographic information, make
WA-WI Class A UST System OP (Class A)
WB-WI Class B UST System OP (Class B)
(If operator wants to be Class A and B operators, it is only necessary
to take and pass the Class B test).
method is Credit Card.
& Company (online)
American Safety Solutions
Training by Petroleum Training Solutions
questions to Mike Fehrenbach at email@example.com