Why are fueling operations a stormwater issue?

Airport tenants use a considerable amount of fuel – 850,000 gallons of fuel a day at BWI Marshall Airport and 3,500 gallons a day are used by operations at Martin State Airport.

Spills and leaks that occur during vehicle and equipment fueling can contribute hydrocarbons, oil and grease, and heavy metals to stormwater runoff. Proper procedures for fueling, as well as training for and implementing spill response procedures, play an important role in eliminating discharges of fuels into the stormwater system. Currently, fuel arrives at the airports by pipeline or truck and is kept in large aboveground storage tanks.

Tenants are required to prevent or reduce pollutants exposed to or discharged to stormwater from aircraft and ground vehicle fueling. However, there is flexibility in what measures tenants can implement to accomplish this. MAA has developed Stormwater Pollution Prevention Plans (SWPPPs) for both BWI Marshall and Martin State Airport NPDES permits. The plans identify best management practices for both MDOT MAA staff and tenants related to these activities.

BWI Tenant Directive 212.1 (Parking Fueling Vehicles)
BWI Tenant Directive 212.2 (Aircraft Self-Fueling Operations at BWI Marshall Airport)
MTN Tenant Directive 212.1 (Self-Fueling Operational Requirements) provide specific details on tenant responsibilities provide specific detail on tenant responsibilities.

These requirements assure that fueling is being performed in appropriate locations with sufficient facilities to prevent spills or discharges to the storm or sanitary sewer systems.

Some examples of best management practices tenants can adopt in association with aircraft and ground vehicle fueling include:

Good Housekeeping
  • Fuel pumps intended for vehicular use (not aircraft) should be posted with signs stating “No Topping Off” to prevent overflow.
  • Use pigs/mats over catch basins during fueling activity.
  • Place absorptive material beneath aircraft during fueling.
  • Manage the disposal of water that collects in fuel tanks and fueling hydrant sumps according to state and federal regulations.
Physical Site Usage
  • Avoid mobile fueling of equipment wherever feasible; fuel equipment at designated fueling areas.
Structural Controls
  • Cover the fueling area if possible.
  • Divert stormwater runoff away from fueling area through the use of berms or curbing to avoid stormwater contact with contaminated surfaces.
  • Install gate valves at catch basins and close the valves during fueling activity.
  • Employ secondary containment or cover when transferring fuel from a tank truck to a fuel tank.
Equipment
  • Provide appropriate monitoring for tanks containing fuel, such as:
    • Level indicators and gauges.
    • Overfill protection with alarms.
    • Interstitial leak detection for double-walled tanks.
    • Routine inspection/lockout for drainage valves for tank containment areas.
  • Fuel dispensing equipment should be equipped with “breakaway” hose connections that will provide emergency shut-down of flow should the fueling connection be broken through movement.
  • Automatic shut-off mechanisms should be in place on fuel tankers. These valves should remain in the closed position unless manually opened during fueling.
Maintenance
  • Inspect, clean, and maintain sumps and oil/water separators at appropriate intervals.
Contingency Response
  • Develop and implement a Spill Prevention Control and Countermeasure (SPCC) Plan if required under guidelines set forth in 40 CFR, Sections 112.3(a), (b).
  • Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
  • Clean up spills using dry methods (absorptive materials). Prevent spilled fuel from entering storm drains. Use absorbent materials and spot cleaning for small spills; do not hose down the area unless the storm drain is blocked and drainage is collected by vacuum truck and disposed of through a permitted connection to the sanitary sewer.
  • Properly dispose of any material released during fuel spills or leaks. Vacuum equipment/trucks are recommended for collection. Always dispose of materials in an approved manner; use an approved treatment facility through a permitted connection. Never discharge materials to a catch basin or storm drain.
  • Furnish adequate spill response information, equipment and materials on all fueling vehicles.
Inspection and Training
  • Inspect fueling areas and storage tanks regularly. Record all maintenance activities and inspections relating to fueling equipment and containers in a log book.
  • Underground fuel storage tanks should be tested as required by federal and state laws.
  • Provide the appropriate level of spill response training to personnel to address all types of potential spills.

One of the requirements of tenant leases is that tenants must adhere to the requirements of the applicable tenant directives and associated regulations. Not adhering to these requirements can impact the standing of the tenant lease.

Additionally, many of the best management practices identified above are those included in the Stormwater Pollution Prevention Plan, which is applicable to both MDOT MAA and tenants at the airport. Not implementing best management practices in association with tenant activities may result in the contamination of stormwater at the airport. As a result, MDOT MAA and tenants may face civil or criminal penalties (see Part II.C.15 and 16 of the NPDES Permit available on the Resource Documents page for more details”.).

The following provides additional information on this topic: