DES, Inc.

Environmental assessments and audits at aviation facilities

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Courtesy of DES, Inc.

Environmentalists are all about “green”, but there is another type of green that is associated with being environmentally compliant – money. There are primarily two types of environmental assessments that are performed at aviation facilities that can affect a company’s bottom line: Phase I/II Environmental Site Assessments (ESA) and General Facility Audits. The ESAs are also referred to as due diligence and are performed to strict federal government standards set by the “All Appropriate Inquiry” rule. A General Facility Audit is a more inclusive walkover of a facility but also performed to professional standards.

Phase I and II ESAs are generally performed for a potential buyer of commercial property. The ESA must meet the requirements as defined by the EPA for “innocent land owner defense.” Most lending agencies require an ESA to ensure that there is no environmental contamination on the property prior to purchase. If a buyer were to forego this assessment, cleanup of any existing contamination that is discovered after the purchase would be the responsibility of the buyer and/or the lending agency.

A Phase I ESA requires a thorough investigation of the history of the use of the property. Extensive searches of government records are conducted as well as interviews with the property owner and surrounding property owners. By government regulation, this type of assessment must be conducted under the direction of a qualified professional such as a Professional Engineer or a Professional Geologist.

If any soil or ground water contamination is suspected or discovered, and the buyer does not cancel the purchase at that time, a Phase II ESA must be performed. The Phase II ESA involves an in-depth investigation which usually involves soil and/or ground water sampling and analyses to determine the extent and type of contamination. If after the Phase II ESA is complete and the potential buyer still wants to purchase the property, there can be two different choices: the seller can take full responsibility for the cleanup, or the buyer and seller can negotiate the purchase price and the buyer accepts the cleanup responsibility. In most cases, if contamination is discovered, the sale is cancelled.

A General Facility Audit is another type of assessment that investigates numerous issues such as fire codes, environmental violations, previous regulatory fines, OHSA problems, etc. This type of audit can also offer preventive measures to ensure that such problems do not recur. Such audits help to keep a facility in compliance with regulations and make the property more saleable.

The following are just a few of the environmental issues that aviation facilities must be aware of:

• Most aviation facilities that have fuel storage tanks must have a federally required Spill Prevention Control and Countermeasure Plan (SPCC) which is certified by a registered Professional Engineer. Requirements of an SPCC plan include, but are not limited to, having proper secondary containment for fuel tanks, a tank testing program, a regular inspection program, employee training programs, general containment measures, and a contract with an emergency response provider.
• Nearly all aviation facilities must have a National Pollution Discharge Elimination System (NPDES) storm water discharge permit and a Storm Water Pollution Prevention Plan (SWPPP). Many owners believe that they are covered under their airport’s permit and SWPPP. This is generally not the case. All facilities must have their own permit and most are not covered in their airport’s SWPPP.
• Most facilities must submit a Tier I report to state and local authorities initially and a Tier II report yearly.

A General Facility Audit can accomplish three objectives.

• It can identify non-compliance issues and offer solutions that could prevent potential regulatory fines and penalties
• It can identify ways to prevent environmental contamination and code violations.
• It can identify unknown contamination issues that might be discovered by a future Phase I ESA.

An excellent method to keep your facility in compliance with the regulations and ready for a potential buyer to inspect is to have a qualified specialist conduct a General Facility Audit every six months or at least annually. The audits are relatively inexpensive and can provide the owner with a prioritized list of all “out-of-compliance” regulatory items.

Every aviation facility operator should be aware of the government regulated Environmental Site Assessments (Phase I & II) and the General Facility Audit. Don’t wait until a crisis to develop a good working relationship with an environmental/regulatory professional. It can save you time, negative publicity, and money.

Katherine Mitchell is a regulatory specialist and Project Coordinator at Diversified Engineering Sciences. She has six years experience with the company and has developed a working knowledge of federal and state regulations that pertain to the aviation industry.

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