Mark R. Twombly is a writer and editor who has been flying for 35 years. He lives in Florida.
Habits can be difficult to break, but there's one that I have to work on. You too, probably. For the past 35 years I've been sumping — draining fuel from airplanes to check for water, debris, and other contaminants. I've also been dumping — disposing of the samples by pouring the fuel onto the ramp. The problem is that fuel is toxic, flammable, and corrosive, and pouring even a small sump sample on the ground constitutes illegal disposal of hazardous waste in some places.
Most, but not all, of a dumped avgas sample evaporates — dissipating, not disappearing, into thin air. The pollutants left on the ramp, including the tetraethyl lead additive, are subject to runoff into soil and surface water. At my airport, even the soap used to wash aircraft must be biodegradable.
Sumping and dumping has been general aviation's uncomfortable little secret for as long as we've been familiar with the term hazardous waste. But no one with enforcement power has put much effort into commanding a change in the practice. Until now, that is.
At the most recent meeting of the airport users group at my home field, airport Manager Coleen Baker distributed a small brochure and a four-minute, 40-second videotape titled, respectively, "Preflight Fuel Dumping" and Aviation Environmental Responsibility. The operative sentence in the brochure reads: "As a pilot, fixed-base operator, or aviation maintenance technician, you are required by law to dispose of your 'sumped' fuel properly." The brochure and the video detail those "proper" procedures.
They were produced because of an unusual partnership between Embry-Riddle Aeronautical University (ERAU) and the Florida Department of Environmental Protection, Hazardous Waste Section. The partnership is a consequence of an enforcement action last year. The Department of Environmental Protection cited ERAU's Daytona Beach, Florida, campus for improper disposal of fuel samples taken from the university's large fleet of training aircraft.
Florida's environmental cops targeted ERAU because of a complaint lodged with the National Response Center, described on its Web site as "the sole point of federal contact for reporting oil and chemical spills." According to Janine Kraemer, an environmental specialist with the Florida Department of Environmental Regulation, the complainant fingered both Embry-Riddle campuses, in Prescott, Arizona, and Daytona Beach, for sumping and dumping.
(The National Response Center reports that it received an average of 222 aircraft-related spill reports in each of the 11 years from 1991 through 2001. The only categories with fewer reported spills are "Unknown" and, since 1998, something called "Terrorist Non-Release.")
Arizona environmental officials paid a visit to the Prescott campus, according to Kraemer, and told university officials that they were in violation of laws requiring proper disposal of waste fuel.
Florida took a more aggressive position. Kraemer went to Embry-Riddle's main campus in Daytona Beach and found that, despite the earlier inspection and warning from Arizona officials, the university had not changed its sump-dumping ways. Florida decided to pursue enforcement.
ERAU was cited with failure to adhere to Florida statute 403.727, which requires people and institutions to maintain their facilities in a way that would ensure that no release of hazardous waste material occurs. The state fined the university, but the amount was reduced from the maximum $50,000 a day allowed by law. The reduction in the fine was based on Embry-Riddle's agreement to partner with the state in an educational campaign aimed at changing pilots' habits regarding the dumping of fuel samples. AOPA President Phil Boyer met with Kraemer last fall to help make sure the campaign didn't turn into onerous regulations.
The brochure and video are the opening salvos in that campaign. In them, Embry-Riddle explains that, instead of dumping fuel samples, its students and instructors now use a special sump device called a GATS (gasoline analysis test separator) Jar. The plastic container features a fine-mesh screen that separates non-petroleum contaminants from aviation fuel, allowing the purified fuel to be poured back into the aircraft fuel tank.
Embry-Riddle returns sumped fuel to the tank only if no contaminants are present in the GATS Jar sample. If the fuel is ?ontaminated, the sample is poured into a waste-fuel container.
Waste fuel containers also are used by Sporty's at Clermont County Airport in Batavia, Ohio. According to Sporty's President Hal Shevers, several of the commercially available five-gallon cans are positioned in high-traffic areas including Sporty's Academy flight school and the visitor parking ramp at Sporty's Pilot Shop. The waste fuel is collected and used to power the airport's fuel trucks. Meanwhile, Kraemer is visiting Florida FBOs, airport managers, and flight schools to distribute copies of the brochure and video, and ask for their cooperation in complying with waste-fuel handling restrictions. "Then we're going back and checking," she adds.
Disposing of sumped fuel is not the only issue on the mind of environmental regulators. Kraemer said she was at an airport one hot day when she noticed something pouring out the bottom of a wing onto the ramp. She asked about it, and was told that the sun had heated the fuel in the full tank, causing it to expand and escape through the vent line.
That observation led to Embry-Riddle's adopting a new policy of slightly underfilling the tanks in its flight-training aircraft to preclude expansion and the venting of fuel onto the ramp.
The primary target of Florida's educational campaign is flight schools. If new pilots can be taught to handle sumped fuel without dumping, and to avoid filling fuel tanks to the brim if there is potential for venting, eventually everyone will be in compliance, Kraemer says.
She recognizes that the tougher problem in the short term is convincing individual pilots and aircraft owners, especially at smaller airports, to stop dumping their sumped fuel. The state has joined with aviation interests in a task force charged with coming up with ideas to encourage compliance on the individual level.
I wish them luck. Pilots can be pretty hidebound about changing entrenched habits, even bad ones. On this issue, however, there are legitimate concerns. Reusing sumped fuel takes a leap of faith. If any undetected contaminants go back into the fuel tank, they would declare their presence at about the time the airplane is lifting off.
The GATS Jar, which is designed to filter out all contaminants, addresses that concern. But even though the device has been on the market for years (Sporty's has been selling an average of about 150 a year for at least a decade), it will take time for the general pilot population to develop trust in it and similar products. The fact that ERAU is now using it daily should help speed acceptance by more pilots.
The caution against topping off tanks also requires a change in long-established thinking, even among manufacturers. My airplane is equipped with four rubber fuel bladders, and the handbook says this about filling them: "The cells should be kept full of fuel during storage of the airplane to prevent accumulation of moisture and deterioration of the cells." An alternative to underfilling is to position a catch pan under the vent tube to contain any overflow, says Kraemer.
The estimated 3 million gallons of aviation fuel that is sumped and dumped each year (I question that figure, but Embry-Riddle concedes that it used to pour an estimated 40 drums of avgas on the ramp annually) is a sobering figure. But it must be a mere puddle in comparison to oceans of spilled automotive gas and diesel fuel. Think of the drips and dribbles that follow the fueling of millions of vehicles at gas stations around the country every day.
The best way to encourage widespread compliance with a no-dumping policy in aviation is to make it easy to comply. How? By having waste-fuel containers positioned everywhere on airports, and tended regularly. Pilots can choose to use a device like the GATS Jar to return pure fuel to the tank if they wish, but having waste-fuel containers handy to every airplane on the airport is the surest way to end the longstanding practice of dumping sumped fuel.
