Environmental Management at Airports Its Not a Game

1
Environmental Management at Airports Its Not a
Game

• Presented by
• Janell Barrilleaux, C.P.G. Director of
  Environmental Programs City and County of
  Denver Department of Aviation

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Test Your Knowledge

• CDPHE
• CWA
• EIS
• FONSI
• OPA
• SPCC
• DOLE
• FRP

• OPS
• COGCC
• LUST
• FAA
• USACE
• NOV
• AST
• CYA

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Whats The Big Deal About Airports?

• Every regulatory requirement/program applies.
• Complex facility.
• Diverse activities conducted all over the airport
• Numerous tenants conduct activities at the site.

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Current Climate

• Increased emphasis on safety/security
• Economic woes
• Short term forecasts uncertain
• Long-term growth expected

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Regulated Airport Activities

• Aircraft Deicing
• Pavement Deicing
• Fueling
• Maintenance
• Aircraft Lavatory Service
• Washing Aircraft and Vehicles
• Development/ Construction

• Building and Grounds Maintenance
• Chemical, Materials, and Fuel Storage/Handling
• Equipment Cleaning
• Sweeping/Washing
• Fire Fighting
• Painting/Stripping
• Incineration

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So, what do you manage?

• Your activities that have the greatest risk
• To the environment
• To your reputation
• To your finances
• To your freedom
• To your project schedules/development

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Here are the biggees!

• Stormwater
• SPCC
• Storage Tanks
• Waste Management
• Spills
• FAA approvals - NEPA

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Potential Inspections

• DIA is subject to numerous audits/inspections by
  various agencies
• DEH (as agent to CDPHE)
• DEH Environmental Protection
• CDPHE SWD incinerator
• CDPHE HMWMD
• CDPHE AQPD
• DOLE/OPS storage tanks
• EPA hazardous waste
• EPA MS4
• CDPHE WQCD stormwater
• Metro Annual compliance inspection

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What is the Key to Compliance?

• Say what you are going to do
• AND
• Do what you say (and prove it!).

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Environmental Compliance Based on Cycles
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QUESTION

• What do you think is the activity conducted at
  most airports that is considered to have the
  biggest potential impact on water quality?

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Aircraft Deicing

• FAA, airlines, manufacturers, airports
• Glycol/ADF
• Management of spent fluids

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How is it regulated?

• Industrial stormwater permit
• SWMP/BMPs
• Inspections
• Training
• Records
• Storage
• MS4 or industrial permit
• Spills CDPHE SWD

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How to COMPLY!

• Read and follow your Permit AND SWMP
• Document training and communications
• Reporting follow the requirements know when
  you have to NOTIFY!
• Inspect your TENANTS!

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STORAGE TANK REQUIREMENTS
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SPCC WHAT NOW?

• New regulations effective 8/02
• 1,320 gallons new trigger
• 55 gallon containers vs. 660 gallon tanks
• Equipment with oil
• Mobile fueling
• 280/281 review to determine jurisdiction
• Lawsuits pending
• Different interpretation of regulations EPA vs.
  industry
• Deadlines extended and will be again!
• 8/04 for plans
• 2/05 for implementation

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Petroleum - How Hard Can It Be?

• Oil and gas production
• Transmission lines
• Fuel farm
• Pipelines to hydrant system
• Hydrant system
• Hydrant to truck
• Truck to plane
• Storage tanks and dispensers
• Tanker trucks
• Oil storage

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Who Regulates What?

• OPS jurisdiction (USTs and ASTs of certain sizes)
  7CCR 1101-14
• CDPHE SWD (USTs and ASTs that OPS does not
  regulate)
• EPA (SPCC part of ASTs FRPs)
• CDPHE or OPS (hydrant systems depending on the
  feed tanks)
• DOT (mobile fuelers/traffic accidents)
• Oil and Pipeline Safety (fuel transmission lines)

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Who Regulates What?

• Who does the inspections of the compliance of the
  tanks that are not within OPS jurisdiction?

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40 CFR 280.90 - UST Financial Assurance
Requirements
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C.R.S. 8-20.5-206 - UST Financial Assurance
Requirements

• Moneys in the PST Fund may be used by owners
  and operators of eligible tanks to demonstrate
  compliance with federal financial responsibility
  requirements.
• Gasoline diesel tanks eligible, so PST Fund
  satisfies CDPHE and EPA financial requirements.
• Owners and operators of ineligible tanks must
  secure independent financial assistance, but may
  use federally approved financial assurance
  mechanism.
• Av Gas and Jet A tanks not eligible, independent
  financial assurance.
• Local governments have some extra options for
  ineligible tanks.

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AST Financial Assurance Requirements

• For ASTs regulated by OPS and eligible
  Financial responsibility is 35,000
• If not regulated by OPS no requirement

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Approved Methods for Local Governments -
Ineligible Tanks

• Self Insurance (Local Government Financial Test)
• Corporate Guarantee (Private 3rd Party Entity)
• Insurance Coverage
• Bond (Local Government Rating Test)
• Letter of Credit
• Trust Fund
• Intergovernmental Guarantee or Dedicated Funds)

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WHAT ABOUT NON-PETROLEUM TANKS?

• Glycol tanks?
• Hazardous materials tanks?

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Airport Wastes
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Non-hazardous Solid Wastes

• Sanitary wastes (garbage)
• Petroleum contaminated media
• Stuff you recycle

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Waste Disposal/Management Questions?

• What is the definition of disposal?
• Is it legal to dispose of solid waste on airport
  property?

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Hazardous Wastes CRADLE TO GRAVE remember!

• Paints and paint solvents
• Spent solvents (parts washers)
• Aerosol cans
• Rags (gasoline/paints)
• Paint filters (paint booths)
• Gasoline filters
• Gasoline-contaminated absorbents
• Used antifreeze (if not recycled)
• Used oil and oil filters (if not recycled)

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What About Universal Wastes?

• Universal wastes are those wastes that are
  subject to widespread use and therefore make
  disposal difficult (such as fluorescent bulbs,
  electronic equipment, etc.).
• The universal waste rule provides an alternative
  and reduced set of management standards that the
  generator can follow in lieu of the rigorous
  hazardous waste requirements.

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How to Comply?

• Segregate your wastes
• Characterize your wastes
• Make your tenants do this as well!
• Notify you of hazardous waste activity!

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QUESTION?

• What is the proper way to handle the following
  items LEGALLY
• Shop rags
• Spill cleanup absorbents
• Used filters
• Electronic equipment

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What does DIA do? Risk Management

• Stormwater Inspections (bi-annual inspections of
  facilities)
• Compliance tracking (pretreatment devices,
  permits, APENs, inspections, SPCC, stormwater,
  training, etc.)
• Training - Environmental awareness, SPCC, waste,
  stormwater
• Compliance assistance for all tenants and
  operators joint workshops with CDPHE/EPA
• Special police authority
• Tenant oversite (development, closeout,
  operations, compliance, remediation)
• Effective communications with Operations,
  Properties, Maintenance and Engineering.
• Environmental Management System (EMS)
• Waste Management Plan
• Notification Handbook

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EMS for DIA

• DIA management supported the development of an
  Environmental Management System (EMS) for DIA to
  enhance our ability to comply with environmental
  requirements and to provide a mechanism for
  continuous improvement.
• We completed the ISO 14001 audit in April 2004
  and are recommended for certification!

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What is an EMS anyway?

• A structured approach towards managing
  environmental assets and liabilities to pursue a
  policy of continual improvement
• Management Systems are an effort to engineer
  human systems

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REGULATORY UPDATE

• SPCC status
• CDPHE WQCD hiring inspector
• OPS evaluating how to get more regulatory
  jurisdiction
• CDPHE SWD looking at requiring additional
  notifications
• CDPHE WQCC groundwater standards
• EPA MS4 inspections (looking at CDPHE)

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Summary

• Airports are faced with a myriad of
  environmental laws and regulations that affect
  their airports. The degree to which airports are
  affected depends on the airports location, type
  of conditions that exist, and the regulatory
  categories. The key to success is knowledge,
  awareness, training, and teamwork!

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Any Questions?
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CLOSING PHOTO