Ben Thomas of UST Training recently returned from Guam where he taught what is believed to the first agency-approved Class A/B UST Operator Training course that was exclusively designed for operators of airport hydrant systems (AHS) and field constructed tanks (FCT). These unique UST systems were recently added to the federal UST universe (new Subpart K of 40 CFR 280) but Guam started regulating them back in 2013. So while many states are working to identify these tanks for regulatory inclusion, Guam EPA had a pretty good handle on its inventory.
Ben was hired by the Guam EPA to provide this specialty class because of his national expertise in training UST operators plus his experience training at Air Force, Army and Navy bases throughout the US in 2015-16. Some installations had qualifying Subpart K tanks and some where still assessing whether their AHS and FCT systems qualified.
On June 20, 2016 at the Guam EPA office, 11 operators representing one large airport hydrant system and a series of large, million+ gallon steel tanks attended the class along with four Guam EPA employees. Due to the complex and technical nature of these UST systems, combined with the newness of the UST rules, the format of the class was more dialogue than traditional lecture. Ben was familiar with understanding and explaining the new UST rules. The operators were familiar with the complexities of these large scale systems. The goal was to bring these two streams of expertise together and hammer out a road map about what needed to be done, how to do and when to do it. As the trainer Ben helped lead discussions between the agency and the operators The result: we all learned a lot. We shared a lot. We figured out what needed to be done when and by whom. And Ben certified 11 Class A/B operators in the Western Pacific.
For those unfamiliar with the new Subpart K rules, See this new helpful EPA publication https://www.epa.gov/ust/requirements-field-constructed-tanks-and-airport-hydrant-systems
If you have an actual or potentially qualifying Subpart K tank, or if you’re developing rules to meet the Federal version, feel free to contact Ben at 360-321-4776 or ben@USTtraining.com. He’ll be happy to discuss what he learned.