Fixed-Base Operator

Accidental releases from underground or aboveground storage tanks (UST/AST) used to hold jet fuel, AVGAS (aviation gasoline used in spark ignition piston engines), and other aircraft fluids can contaminate soil and groundwater and lead to costly investigations and cleanups. Fumes or vapors from leaking ASTs/USTs can lead to bodily injury claims from third parties. Releases can occur from many different circumstances, including leaking pipes or hoses from tanks and fueling dispensers or during fuel loading from the transport to the fuel tank.

Aircraft de-icing fluid (ADF), aircraft anti-icing fluid, and airfield pavement de-icer formulations consist of chemicals and, in many formulations, various additives. De-icing chemicals commonly used include urea, sodium formate, propylene glycol, and ethylene glycol. De-icing effluent is highly toxic to humans, wildlife, and aquatic populations. Without proper discharge controls, de-icing agents can contaminate stormwater run-off, accumulate on unpaved areas, and infiltrate soil and groundwater during snow melt.

Fueling vehicles are subject to accidents, upset, and overturns, which could result in a release of cargo, including jet fuel, AVGAS, or aircraft lubricants. FBOs may have transportation exposure on and off the airport location.

Vehicles and powered equipment, such as fuel trucks, service trucks, ground power units, lifts, aircraft pushback tractors, and cargo loaders, can leak fuel, oil, and other fluids during use or while parked at the site, which can infiltrate into soil and groundwater.

The exposure of airport property to weather elements creates a significant risk for stormwater run-off to collect fuels, chemicals, and spilled or leaked wastes. Contaminated run-off can discharge into water systems and lead to human health hazards and natural resource damage.

Cleaning, maintenance, and repair activities involve using and storing various materials that contain hazardous chemicals and solvents, such as oils and hydraulic fluids, additives, cleaners, paints, and paint strippers. Improper handling and storage can result in an accidental release. Wastewater generated from cleaning activities may contain hazardous substances and must be properly handled.

FBOs that operate restaurant services have exposure to generated grease waste. Improper maintenance of grease traps or containment of grease waste can result in a release that contaminates soil or groundwater, clogs drain or sewer lines causes natural resource damage, and exposes bacteria and infectious diseases to third parties that come in contact with it. Storm drains and sewer pipes may directly lead to local water systems without treatment. Grease that enters sewer and storm drains can also cause a clog and result in a buildup of poisonous hydrogen sulfide gas or a sewage backup spill.

Restaurant operations can carry additional environmental liability from using and storing dry chemical fire suppression systems, cleaning chemicals such as ammonia, bleach, degreasers, and pesticides and rodenticides.

Mishandling of lavatory waste or failures in hoses, valves, and equipment can result in a release contaminated with biohazards and disinfecting chemicals. Improper spill response can pose significant risks to human health and natural resources. Lavatory trucks and equipment should only be cleaned in approved areas with appropriate wastewater containment.

FBOs may generate hazardous wastes that require special disposal procedures. Spent solvents, waste oil, antifreeze, de-icing chemicals, wastewater, and restaurant grease may all fall under hazardous waste. The waste generator must determine whether a waste is hazardous and follow proper storage, labeling, and disposal procedures. Improper disposal could lead to cleanup and third-party liability, and there may be legal consequences for violating RCRA hazardous waste requirements.