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Please note: This summary is provided to help you understand the regulations. Consult the references provided for links to the full text of the regulations.

aircraft engine emissionsAircraft Refueling

Road Rail Air Water

This section provides information about environmental rules that effect entities involved with refueling of commercial and general aviation aircraft.

Related topics:

Who is covered by the regulations?

Any facility that refuels commercial or general aviation aircraft is subject to environmental regulations that are mandated by the US Environmental Protection Agency (EPA).

What is the purpose of the regulations?

Aviation fuels are mixtures of petroleum hydrocarbons that pose human health threats in drinking water wells if they percolate into the ground water. Also, aviation fuels can kill aquatic life and wildlife if spills reach surface water through a storm sewer. The regulations exist to minimize the potential for a release to the environment; to contain releases, if they occur; and to properly respond to spills in a way that minimize environmental damage.

At small airports, aviation fuel is often pumped into aircraft form a tanker (bowser). These vehicles are driven up to parked aircraft, their fuel hoses plugged into the fuel inlet valves of aircraft, and the fuel is pumped into the aircraft under pressure. However, some small airports have pumps that aircraft must taxi up to, similar to gas stations for road vehicles. At major airports, underground fuel pipes allow refueling without the need for tank trucks; the aircraft are serviced by personnel with fuel trucks that carry the necessary hoses and pressure apparatus. All of these refueling operations, regardless of size, have the potential to release fuel and pollute the environment. Implementing required safeguards and being prepared for spills greatly reduces the potential for environmental damage.


The primary environmental regulations affecting refueling include:

  • Industrial stormwater regulations, and
  • Spill Prevention, Control and Countermeasures (SPCC) Rule

Each of these are discussed below.

Industrial Stormwater. The Clean Water Act authorizes EPA and states, which are delegated the authority by EPA, to regulate "point sources" that discharge pollutants into waters of the United States through the National Pollutant Discharge Elimination System (NPDES) permit program. So-called "point sources" are generated from a variety of municipal and industrial operations, including treated wastewater, process water, cooling water, and stormwater runoff. The NPDES Storm Water Program, in place since 1990, regulates discharges from municipal separate storm sewer systems (MS4s), construction activities, and certain industrial activities, including transportation.

For transportation activities (SIC Code 45), the stormwater regulations require that a facility obtain coverage under an industrial stormwater permit (40 CFR 122.26(b)(14)(i)-(xi)) for their vehicle maintenance activities, which specifically includes refueling. Further, the regulations require that a facility Stormwater Pollution Prevention Plan (SWPPP) be prepared and implemented to minimize the impacts of stormwater discharges. For more information on industrial stormwater regulations, see TERC's Stormwater Regulations section.

Throughout most of the nation, EPA has delegated the stormwater program to the states to administer as they deem appropriate, so long as minimum federal requirements are met. Therefore, in most states you will apply for an industrial stormwater permit to your state environmental agency.

However, some states do not yet have the authority to administer this program. For the following states, you will probably need to submit your permit application to your Regional EPA office: Alaska, Idaho, Massachusetts, New Hampshire Texas, Florida, Maine, and Arizona. If your facility is in one of these states, we suggest contacting both your Regional EPA office and state agency to find out where to submit your paperwork.

For more information on state rules regarding industrial stormwater discharges use the Industrial Stormwater Resource Locator.

Spill Prevention, Control and Countermeasure (SPCC) rule. The SPCC rule (40 CFR 112), is a federal regulation that applies to facilities that store, use and consume oil and oil products. Examples of oil storage potentially covered by the SPCC rules include aircraft fuel tanks, mobile refuelers, drums of lubricating or hydraulic fluid, and transformers containing dielectric fluid. The SPCC rules date back to 1973. The rules were promulgated under Section 311 of the Clean Water Act, which provides the authority for a program to prevent, prepare for, and respond to discharges of oil from facilities and mandates regulations establishing procedures, methods, and equipment.

Facilities that meet the criteria (i.e., exceed a threshold oil storage capacity, and could reasonably discharge to navigable waters or adjoining shorelines) must comply with the SPCC regulations. These regulations require the facility owner/operator to prepare and implement an SPCC plan for their facility. This plan must be well thought out and prepared in accordance with good engineering practices. It must document the location of storage vessels, types of containment, dangers associated with a major release of material from the tanks, types of emergency equipment available at each site, and procedures for notifying the appropriate regulatory and emergency agencies. More detailed information on SPCC threshold capacities and other general aspects of the rule can be found on TERC's SPCC page.

Various aspects of the SPCC rule changed in 2006, when amendments were finalized. The 2006 rule somewhat streamlined SPCC requirements for mobile refuelers, which under the old rule had to be parked in an area that provides a sized secondary containment for the trucks, which included the entire volume of the largest truck plus sufficient freeboard for precipitation. Refueler trucks still must meet a “general secondary containment rule” and provide some form of secondary containment.

This means that you must provide some mechanism of capturing a spill in the area the truck is parked, whether it is in the form of curbs, dikes, oil/water separators, or other diversion device. The EPA also allows the use of an “active containment system,” which typically includes use of a facility spill kit that can be deployed in the event of a spill. The engineer that certifies your SPCC Plan will provide the best engineering solution to your site-specific arrangement.

It is important to note that the 2006 SPCC Amendments differentiate between transportation and non-transportation facilities (and combinations of the two, which are referred to as "complex"). Aircraft refueling generally falls under the non-transportation category. This is an important distinction because transportation facilities come under the jurisdiction of the US Department of Transportation (DOT), while non-transportation facilities are regulated by EPA. [Transportation-related facilities include onshore and offshore terminal facilities, equipment appurtenant to a non-transportation-related facility used to transfer oil in bulk to or from a vessel, interstate and intrastate onshore and offshore pipeline systems, highway vehicles and railroad cars that are used for the transport of oil, equipment used for the fueling of locomotive units, as well as the rights-of-way on which they operate.] In 2013 EPA published SPCC Guidance for Regional Inspectors, which provides specific guidance for refueling operations (see section 2.5). As stated in this document, a tank truck or mobile refueler that fuels exclusively at one site, such as at an airport, would be subject to the SPCC rule and under EPA jurisdiction. However, if the tank truck or refueler only distributed fuel to multiple off-site facilities and did not perform fueling activities at the home base, the vehicle would be transportation-related, and regulated by DOT.

Best Management Practices

The Federal Aviation Administration (FAA) has published the following two guidance documents covering aircraft fueling, including best management practices with regard to stormwater pollution prevention:

  • Aircraft Fuel Storage, Handling, Training, and Dispensing on Airports (FAA). This 2012 advisory circular (AC) contains specifications and guidance for the storage, handling, and dispensing of aviation fuel on airports. Additionally, this AC provides standards and guidance for the training of personnel who conduct these activities.

  • Management of Airport Industrial Waste. This 2008 advisory circular (AC) provides basic information on the characteristics, management, and regulations of industrial wastes generated at airport and guidance for the development of a Storm Water Pollution Prevention Plan (SWPPP) that applies best management practices to eliminate, prevent, or reduce pollutants in storm water runoff associated with particular airport industrial activities.

More Resources

NATA Refueling and Quality Control Procedures for Airport Service and Support Operations. The National Air Transportation Association’s (NATA’s) refueling and quality control guidebook provides information and detailed procedures on the safe handling and delivery of aviation fuels.

National Fire Prevention Association (NFPA) 407. The FAA uses the standards contained in the most recent edition NFPA 407, which provides a standard for the storage and delivery of aviation fuel in an airport environment.

Industrial Stormwater Fact Sheet: Sector S: Vehicle Maintenance Areas, Equipment Cleaning Areas, or Deicing Areas at Air Transportation Facilities. This fact sheet specifically discusses stormwater discharges from airports, airport terminals, airline carriers, and establishments as defined by Standard Industrial Classification (SIC) Major Group 45.

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