Spcc Rule: Do Airports Need To Comply?

The Spill Prevention, Control, and Countermeasure (SPCC) rule is a federal regulation that applies to facilities storing, using, and consuming oil and oil products. Airports, with their aviation fuel tanks, mobile refuelers, and drums of lubricating fluids, fall under the SPCC rule's jurisdiction. The rule's purpose is to prevent oil spills and mitigate their environmental impact, mandating procedures, methods, and equipment to manage spills effectively. While transportation-related facilities, including highway vehicles and railroad cars, are generally exempt, airports are considered non-transportation facilities regulated by the Environmental Protection Agency (EPA). This distinction is crucial as transportation facilities fall under the United States Department of Transportation's (DOT) authority. The SPCC rule's application to airports has sparked debates and clarifications, with the EPA requiring secondary containment for refueler trucks, which has significant financial implications for the aviation industry.

Airports and Spill Prevention, Control and Countermeasures (SPCC)

The Spill Prevention, Control, and Countermeasure (SPCC) rule was originally published in 1973 under the authority of §311 of the Clean Water Act. The SPCC rule requires non-transportation-related facilities that store, transfer, use, or consume oil or oil products to develop, maintain, and implement an oil spill prevention plan, known as an SPCC Plan. The purpose of the SPCC rule is to help prevent oil spills and protect public health and the environment. Airports are subject to the SPCC rule, as they store and transfer large amounts of oil and fuel for aircraft.

The SPCC rule applies to facilities that store more than 1,320 U.S. gallons in total of all above-ground containers or more than 42,000 gallons in completely buried containers. Airports typically store large quantities of fuel and oil, exceeding these thresholds, and are, therefore, subject to the SPCC regulations.

The SPCC rule requires airport operators to develop and implement an SPCC Plan, which outlines how the airport will prevent oil spills and fuel transfers to aircraft and how they will respond in the event of a spill. This includes the positioning of mobile or portable oil storage containers and the use of secondary containment, such as dikes or catchment basins, to prevent discharges into navigable waters or adjoining shorelines.

In 2005, the US Environmental Protection Agency (EPA) clarified that aviation refueler trucks are considered "mobile or portable oil storage containers" and are subject to the SPCC rule's secondary containment requirements. This has had a significant financial impact on the aviation industry, as airlines and fuel suppliers work to install secondary containment in refueler truck parking areas. However, the EPA has emphasized the flexibility in engineering solutions for secondary containment, and airports have been working to comply with these requirements to prevent oil spills.

Overall, airports are subject to the SPCC rule due to the large volume of oil and fuel they store and transfer. By developing and implementing SPCC Plans, airports can help prevent oil spills and protect the environment and public health. The SPCC rule provides a framework for airports to manage their fuel and oil operations safely and responsibly.

SPCC rule and oil spill prevention

The US Environmental Protection Agency's (EPA) Spill Prevention, Control, and Countermeasure (SPCC) rule helps facilities with large oil storage capacity to prevent the discharge of oil into navigable waters or adjoining shorelines. The rule requires these facilities to develop, maintain, and implement an oil spill prevention plan, called an SPCC Plan.

The SPCC rule applies to facilities that store, transfer, use, or consume oil or oil products and have a total oil storage capacity of more than 1,320 US gallons in above-ground containers or more than 42,000 gallons in completely buried containers. Additionally, the facility must be in a location where it could reasonably be expected to discharge oil into navigable waters or adjoining shorelines, such as lakes, rivers, and streams.

The SPCC rule has been amended over the years to streamline requirements for certain facilities and provide flexibility in engineering solutions for secondary containment. For example, in 2006, the EPA amended the SPCC rule to exempt mobile refuelers at non-transportation-related facilities from providing sized secondary containment systems. However, general secondary containment requirements still apply to these vehicles.

Airports, airlines, and fuel providers are considered transportation service providers and may be subject to the SPCC rule. While there have been debates and clarifications around the inclusion of aviation refueler trucks under the SPCC rule, the EPA has maintained that these vehicles are "mobile or portable storage containers" and require secondary containment to prevent oil spills.

To comply with the SPCC rule, facilities must prepare and implement an SPCC Plan, which outlines how the facility will prevent oil spills and respond to any discharges. The plan must be maintained at the location of the facility and be available for inspection. Facilities with an oil storage capacity of over 10,000 gallons will need a professional engineer to certify their plan.

SPCC rule and oil spill response

The US Environmental Protection Agency (EPA) has a set of Spill Prevention, Control, and Countermeasure (SPCC) rules, which are designed to help facilities prevent a discharge of oil into navigable waters or adjoining shorelines. The SPCC rule requires facilities to develop, maintain, and implement an oil spill prevention plan, called an SPCC Plan. These plans help facilities prevent oil spills and control spills should they occur.

The SPCC rule was originally published in 1973 under the authority of Section 311 of the Clean Water Act. In 1990, the Oil Pollution Act amended the Clean Water Act to require some oil storage facilities to prepare Facility Response Plans. The SPCC rule was further amended in 2006 to streamline requirements for facilities with smaller oil storage capacities and specific types of equipment.

The SPCC rule applies to facilities that store, transfer, use, or consume oil or oil products and have a total oil storage capacity of more than 1,320 gallons in above-ground containers or more than 42,000 gallons in completely buried containers. These facilities must also be able to reasonably discharge oil into navigable waters or adjoining shorelines, such as lakes, rivers, and streams.

The aviation industry is subject to the SPCC rule, as it is considered a transportation service provider. This includes airports, airlines, FBOs, and fuel providers. The EPA has clarified that mobile refuelers, such as those used in the aviation industry, are "mobile or portable storage containers" subject to the SPCC rule requirements. This means that these vehicles must have secondary containment, such as a dike or catchment basin, to prevent oil discharges.

To comply with the SPCC rule, facilities must develop and implement an SPCC Plan that outlines how the facility will prevent oil spills and respond to discharges. The plan must be maintained at the location of the facility and be available for inspection. Facilities with an oil storage capacity of less than 10,000 gallons can self-certify their plan and conduct regular self-inspections, while those with a capacity of over 10,000 gallons will need a professional engineer to certify their plan.

SPCC rule and mobile refuelers

The Spill Prevention, Control, and Countermeasure (SPCC) rule is a US Environmental Protection Agency (EPA) regulation that requires facilities storing more than minimal amounts of oil to prepare an SPCC plan. This plan outlines how the facility will prevent oil spills from certain oil tanks and oil-filled equipment. The rule also ensures effective responses to such spills.

In 2005, the EPA issued a response to the aviation industry's requests for clarification on the regulation of aviation refueler trucks under the SPCC rule. The response stated that secondary containment would be required, which would have a significant financial impact on the industry. This was due to the re-definition of mobile refuelers, which are now considered "mobile or portable oil storage containers".

In December 2006, the EPA amended the SPCC rule to streamline requirements for facilities with smaller oil storage capacities and specific types of equipment. This included removing the requirement for sized secondary containment for mobile refuelers at non-transportation-related facilities. However, the general secondary containment requirements still apply to mobile refuelers, as well as containment requirements associated with oil transfers.

The EPA defines a mobile refueler as a "bulk storage container onboard a vehicle or being towed, designed or used solely to store and transport fuel for transfer into or from ground service equipment or other oil storage containers". Mobile refuelers are commonly found at seaport terminals and tank truck home bases.

The SPCC rule's general secondary containment requirements state that the containment system must prevent spilled oil from escaping prior to cleanup and must include appropriate structures or equipment to prevent a discharge into navigable waters or adjoining shorelines. The EPA notes that there is flexibility in engineering solutions for secondary containment, and facilities are not required to use measures such as enclosing the refuelling unit's area of operation with rollover curbs. Instead, having adequate spill kits and sorbent materials on hand, along with conducting regular inspections, should be sufficient for maintaining compliance.

SPCC rule and aviation refueler trucks

The Spill Prevention, Control, and Countermeasure (SPCC) rule is a US Environmental Protection Agency (EPA) regulation that aims to prevent the discharge of oil from oil storage facilities into navigable waters and ensure effective responses to such discharges. The rule requires facilities storing more than minimal amounts of oil (typically more than 1,320 gallons in above-ground storage containers) to prepare an SPCC plan outlining how they will prevent oil spills from certain oil tanks and oil-filled equipment.

In the context of aviation refueler trucks, the application of the SPCC rule has been a subject of debate and clarification. Aviation refueler trucks are unique in that they are used solely to deliver oil to aircraft and are not intended for oil storage. However, in 2001-2002, the EPA began issuing Notices of Violation to aviation fuel providers for failing to install secondary containment around their parked mobile refuelers. This sparked a discussion within the aviation industry, with trade associations arguing that mobile refuelers were not subject to the same secondary containment requirements as stationary storage tanks.

The EPA maintained its position that secondary containment was necessary for "parked" refuelers, while recognising that it might be impracticable during fuelling operations or when the refuelers were on standby. To address this, the aviation industry proposed various solutions, including parking refuelers on ramps or in areas with existing secondary containment, such as loading rack or tank farm areas.

In December 2006, the EPA amended the SPCC rule to streamline the requirements for facilities with smaller oil storage capacities, including mobile refuelers. While the amended rule exempts mobile refuelers from sized secondary containment provisions, they are still subject to the general secondary containment requirements during all periods of operation. This means that appropriate containment structures or equipment must be in place to prevent oil discharges into navigable waters or adjoining shorelines.

The SPCC rule's impact on aviation refueler trucks has had financial implications for the aviation industry, as airlines and fuel suppliers work with airport managers to implement the necessary containment measures or demonstrate their impracticability. The EPA has emphasised the flexibility in engineering solutions for secondary containment and has provided guidance on addressing impracticability in specific situations.

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