DES, Inc.

Important environmental issues at aviation facilities, Part I

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Courtesy of Courtesy of DES, Inc.

There are numerous federal, state, and local environmental regulations that apply to aviation facilities. The requirements are continually expanding due to new and revised regulations. There has recently been a significant increase in inspection frequency and official letters of non-compliance. FBO facilities are the most often targeted. Since fuel storage is usually the greatest environmental concern for aviation facilities, we have listed below the primary items of concern:

Spill Prevention Control and Countermeasure (SPCC) Plans – Chapter 40, Part 112 of the Code of Federal Regulations (SPCC Rule) requires that most facilities storing more than 1,300 gallons of fuel aboveground or 42,000 gallons underground have a valid SPCC Plan. The Plan must be sealed by a registered Professional Engineer. This program is regulated by the U.S. Environmental Protection Agency and has existed since 1973. A new version of the rule will be implemented in July 2009, but all facilities must meet the existing regulation. The Rule provides general and specific guidelines for the storage of petroleum products including tank specifications, spill pad requirements, training, best management practices, and spill reporting requirements. The rule is complicated and lengthy, and therefore is a source of much confusion for facilities that store and provide fuel. A good SPCC Plan is an essential part of any regulated facility’s operating procedures. The Plan must address the rule in its entirety, provide the facility with a valuable resource in preventing and cleaning up spills, and satisfy all regulatory requirements on all levels.

Aboveground Storage Tank Containment – If a facility falls within the jurisdiction of the SPCC Rule, all containers holding 55 gallons or more that are used to store a petroleum product are subject to the regulation and must be kept in some form of secondary containment. For large tanks (i.e., 12,000 gal., 20,000 gal., etc.); concrete secondary containment areas, double wall tanks, and dike tanks can be used to satisfy this requirement. Containers that are often overlooked include 55 gallon drums, used oil tanks, sump fuel tanks, and other mobile tanks. In accordance with the SPCC Rule, all containers over 55 gallons must be stored in a structure capable of containing the contents as well as sufficient freeboard for rainfall with a variance for airport refuelers.

Loading/Offloading Spill Pads – One requirement in the SPCC Rule is that all facilities involved in the loading and offloading of petroleum products must have the ability to capture and contain the contents of the largest fuel compartment of the vehicles transferring fuel. EPA documents state that a spill pad is required at a loading and unloading rack, which is defined as an area in which multiple connections exist, and fuel is both loaded and offloaded. In the case of many FBOs and airports, this occurs when delivery trucks offload to fuel farm storage tanks and airport mobile refueling trucks (refuelers) are filled from the fuel farm. It is important that FBOs and airports have a spill pad designed and constructed in accordance with the SPCC Rule. In some cases, regardless of environmental regulations; local fire codes may dictate that a spill pad be required for all fuel tanks.

Fuel Spills – The consequences of a major spill are obvious, but one of the most prevalent causes of contamination at fuel storage facilities is the repeated release of small amounts of fuel over an extended period of time. The most common fuel spills are from overfilling of tanks. Overfills from single wall tanks are captured within the required secondary containment area, but overfills from double wall tanks can flow directly onto the adjacent soil. Leaking fittings, flanges, and couplings should be repaired immediately. Regular inspections of all fueling equipment must be performed. Personnel should be encouraged to report all fuel spills immediately, no matter how minor. Spills that are addressed immediately are often considerably less expensive to clean up than the cumulative effects of spills which go unreported for years.

These are only a few of the environmental issues related to operating an aviation facility. Other issues related to risk management will be addressed in next month’s FATA newsletter.

Ronald Lynch is a registered professional geologist and president of Diversified Engineering Sciences. He has over 30 years experience working with environmental and engineering issues at aviation facilities throughout the United States.

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