Spilled Fuel

Air Safety Week, March 21, 2005

On-airport mobile refuelers are "mobile or portable" storage containers that require secondary containment as a guard against spillage, according to a letter the Aviation Coalition received March 9 from the Environmental Protection Agency (EPA). The members of the coalition are the Air Transport Association, the National Air Transport Association, Airports Council International - North America, and the National Air Transportation Association.

In a March 14 letter to its members, the coalition expressed its disappointment with the ruling. "EPA generally believes secondary containment is 'practical' (and therefore required) when mobile refuelers are parked for some length of time," the coalition said, adding, "You should be aware that EPA takes the position that on-airport mobile refuelers are subject to the secondary containment requirements and recently has been undertaking enforcement actions under this interpretation."

Extracts of the EPA letter show that the agency believes a way will be found to provide secondary containment.

No Slack

The EPA's position regarding secondary containment for mobile refuelers (extracts):

"It appears that some in the aviation industry erroneously believe that ... rules do not apply to mobile refuelers and/or that EPA would modify the requirements to exempt mobile refueling from coverage."

"At this time, we are not considering any deregulatory amendments ... with respect to mobile/portable containers."

"We recognize that when mobile refuelers are fueling, staged in operating locations so that they may initiate fueling, or traveling to and from aircraft, it may be impracticable for some facilities to meet the sized secondary containment requirement. We are aware of facilities that have successfully met this requirement using National Fire Protection Association (NFPA) design guidelines and/or good engineering design solutions under certain circumstances. Further, that there are facilities that have developed good and reasonable engineering design solutions to provide secondary containment for when mobile fuelers are not fueling, not staged, or not involved in fueling activity."

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