More Mobile Refueler SPCC Confusion

Important Information for Aerial Firefighters

Posted on Friday, March 28, 2008

A number of HAI members under contract to the U.S. Forest Service (USFS) and the Department of the Interior (DOI) for aerial firefighting have expressed concern over new contractor environmental responsibilities and compliance with 40 CFR Part 112, oil pollution prevention, spill prevention, control and countermeasure plan requirements (SPCC).

New contract language requires an SPCC plan for each mobile fueler used on USFS and DOI contracts, regardless of bulk storage container (tank) size. HAI staff has been in contact with USFS and DOI officials at the National Interagency Fire Center (NIFC) to discuss this matter. An Example SPCC Plan provided to NIFC personnel by the Idaho EPA inspector should be of assistance to HAI members who must comply with this requirement. All operators are strongly encouraged to familiarize themselves with the example plan.

40 CFR Part 112 addresses fuel truck operators while the vehicle is stationary, and NIFC officials have acknowledged the need for operators to carry secondary containment when near a waterway if the fuel has potential to access the waterway. According to information provided to HAI, it is the vendor’s responsibility to judge whether or not the fuel could reach the waterway. NIFC has indicated to HAI that every effort will be made in the field to reduce that possibility. However, when this is not possible, secondary containment may be necessary. If operators are performing aerial firefighting under government contract, a helicopter manager will be ordered and it is anticipated that local officials will provide assistance with the deployment of the containment system.