Important environmental issues at aviation facilities, Part II
Many people think of risk management as having adequate insurance to cover potential disasters. A better approach is preventing or minimizing disaster in the first place. The dictionary definition of risk management is the technique or profession of assessing, minimizing, and preventing accidental loss to a business, as through the use of insurance, safety measures, etc. In the last issue, we covered several environmental issues that impact safety at an FBO facility including Spill Prevention Control and Countermeasure (SPCC) Plans and fuel spills. When a company plans ahead, disasters can be minimized or avoided completely. Following are other environmental issues that should be addressed to minimize risk.
Storm Water Pollution Prevention Plans (SWPPPs) – The SWPPP regulation is a federal program delegated to the state level and; in the case of FBOs, some corporate facilities, and small airports; applies to facilities storing fuel or conducting aircraft maintenance. Certain stored products at a given facility will place that facility within the SWPPP regulation. Many FBO operators believe that they are covered under the airport SWPPP. This is generally not the case. Although some airports possess and maintain a valid permit and a SWPPP, individual tenants are generally not covered under the airport’s permit and most are not covered by the SWPPP unless that plan meets specific requirements. Just because a facility is named in the airport’s plan as a tenant does not mean they are covered under the airport’s SWPPP. The airport must document vital information such as the tenant’s exact operating procedures for certain tasks, quantity and location of stored petroleum products, emergency contacts, etc. In most cases, airports will not cover tenants under their own SWPPP, placing this requirement on the individual businesses. Facilities are at risk for heavy fines if storm water contaminated with petroleum products reaches navigable waterways or municipal storm sewers.
Sump Fuel in Ground Support Equipment – In some states, the use of sumped jet fuel in non-DOT vehicles is an acceptable practice, however, in certain states, such as Florida, this practice in a violation of state air quality regulations and can bring about severe penalties. Understandably, sump fuel presents a significant financial issue to most FBOs and airports providing fuel. Systems exist to recover sump fuel which may then be placed back into the tanks (where allowable under FAA, ATA, and fuel supplier guidelines). For commercial aircraft fueling operations, this is not an option, but sump fuel recovery for general aviation fueling can constitute a dramatic savings over time, easily offsetting costs for the additional equipment. It is important that FBO operators be familiar with all Federal, State and local regulations concerning sump fuel. Facilities are at risk for fines and lawsuits if sump fuel is used, transferred or stored improperly.
Tier II – FBOs that store threshold quantities of fuel or other chemicals are subject to Tier II reporting. The purpose of a Tier II report is to prepare local first responders such as the airport fire department to safely respond to a spill or fire involving hazardous chemicals. Imagine if you were responding to a disaster. You would want to know where volatile chemicals were located so you would be as safe as possible while doing your job. General Aviation facilities involved in painting aircraft are also subject to this reporting if they have hazardous chemicals over threshold levels. A facility that has not submitted a Tier II report is at risk for fines especially if responders are hurt because they were not aware of hazardous chemicals on site.
Training – Proper employee training is one of the best risk management tools. A SWPPP or SPCC Plan is useless if employees are unfamiliar with emergency procedures and safety measures contained in these plans. SPCC regulations require annual training of all employees who are involved in the fueling process. SWPPP Best Management Practices include training of employees to minimize leaks and spills that might migrate into navigable waters or municipal storm sewers. A trained employee is a safe employee. Proper training prevents on the job injuries and potential disasters.
Planning ahead with environmental issues decreases risk to employees and to a facility’s physical structure. Compliance with environmental regulations protects a company against government penalties and fines. This also protects a company from bad publicity due to an environmental disaster such as an oil spill or severe injuries to workers due to inadequate training or mismanagement of hazardous substances. Because government regulations are often complex and difficult to understand, many companies ignore them and hope they don’t get caught. Hiring an environmental consultant to make sure you are compliant with these regulations is money well spent.
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.