Ben Thomas of UST Training has spent the last year traveling around the US providing UST operator training at systems previously deferred by State and Federal UST rules. These included airport hydrant systems and field constructed USTs which are now–or may be–subject to Federal regulation under 40 CFR 280 Subpart K).
More astute readers may realize that these “Subpart K” tanks are only regulated by EPA at the moment (state rules are coming) and operator training is technically not required until October of 2018. However, a number of UST operators have elected to start training now and not wait.
Creating a UST operator training course for Class A/B and C operators was indeed a challenge but here at UST Training we like to stay ahead of the curve so create we did. Over the last year, we’ve trained hundreds of operators at over a dozen sites where these Subpart K tanks either exist or may quality for inclusion as regulated USTs by 2018. We’ve developed a training program, that, like always, is relevant and useful for operations as well as foward thinking for pending state reg changes.
And we just learned EPA has published the document Requirements for Field-Constructed Tanks and Airport Hydrant Systems (EPA 510-K-16-002). April 2016 (PDF)(43 pp, 2 MB). This will help answer some questions you might have about Subpart K USTs.
If you have questions about developing a Class A/B or C UST operator training course that can be customized to these unique UST system, please contact Ben Thomas.