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1989 DETRIMENTAL
IMPACT STUDY OF AIRCRAFT FUEL SAMPLING And YEAR
2000 FOLLOWUP ADDENDUM BIBLIOGRAPHY This
original study was done in 1990 to identify the potential dangers inherent
in the practice of throwing fuel samples on the ground by pilots
conducting preflight checks on piston powered aircraft. It does not include inadvertently
spilled AVGAS, nor does it include anything involving jet fuel. The statistics used throughout the
original part of this paper are from 1989 and derived from figures
publicly available then from the FAA,
(Federal Aviation Administration) the AOPA, (Airplane Owners and Pilots Association)
and NTSB (National Transportation
and Safety Board). PROBLEM
DEFINITION The
problem is pollution of soil, air, and ground water with petroleum
distillates and organic lead because of preflight sampling leaded AViation
GASoline by pilots of gasoline engine powered aircraft. The first thing
that must be done is determine the scope and magnitude of the problem that
exists, because it seems insignificant when taken as a single and
individual act. Each
time pilots prepare to fly an aircraft, as part of the preflight checks,
they remove fuel samples from each of the fuel tanks, and other low points
in the fuel system. Because they
may extract fuel contaminants during this check, they throw the samples on
the ground instead of putting the fuel back into the aircraft fuel tank,
from which they came. Each time
they perform this check they discard from 6 to 12 ounces of AVGAS. The most common grade of AVGAS is
100LL. 100 designates the octane
rating and LL designates it as Low Lead.
The Low Lead designation is in reference, and comparison to a
previous grade of AVGAS, which contained a much higher lead content. On a broader comparison, 100LL AVGAS
still contains roughly four times the lead that was found in regular
leaded automotive fuel before it was banned. The lead additive used in AVGAS is an
organic tetraethyl lead, the same one used previously in automotive
gasoline. This form of lead
additive is highly, and aggressively toxic to all complex forms of
life. To
appreciate the dangers created by this practice, it is necessary to
determine how much of these toxic substances are introduced into the soil,
air, and wastewater eco systems immediately surrounding airport
facilities. The following will
determine how much of this highly toxic leaded fuel is deliberately
discarded within the contiguous 48 United States on a yearly basis as a
result of pilot preflight operations.
The following statistics do not reflect inadvertent, or accidental
fuel discharges, which can be substantial during summer
months. AVIATION
SECTOR BREAKDOWN The
aviation industry is divided into two major
categories: (1) Air
Carrier - Comprised of scheduled
and unscheduled operations conducted under parts 121 and 135 of the
Federal Aviation Regulations. Which are primarily Commercial Airlines and
Air Cargo operators. Consequently,
those aircraft are primarily jet engine powered and are not considered as
part of this analysis because jet fuel does not contain the lead
anti-knock additives, and no definitive statistics are easily
available. (2)
General Aviation - Comprised of private aviators either for personal or
business purposes. The main
concern of this report is the private aircraft with a piston engine(s)
using aviation gasoline (AVGAS) either single or twin engine. Therefore,
all results will be confined to that portion of the General Aviation
category. NUMERICAL
BASIS STATEMENTS (All numbers are 1989 statistics) Of the
total aircraft registered and active in the United States which number:
225,179 97% are
General Aviation category: 219,401. Of the
total General Aviation aircraft: 88% are
piston engine planes: 193,479 Of the
total General Aviation, piston engine planes: 88% are
single engine planes: 170,035 12% are
multiengine planes: 23,331
Conservatively,
the fuel quantity drained from an airplane for each preflight is 8 ounces
for a single engine plane. This is
based on a 4 second (equaling 4
ounces) purge of the fuel line to the engine, (per most manufacturers recommendations)
Also, a 2 ounce sample taken from the wing tanks, of which there are two,
or 8 ounces from a single sump at he lowest point in the fuel system. These figures assume only two fuel
tanks, and one additional fuel line extraction point. Some aircraft have more tanks, and more
fuel lines checkpoints as found with the most recent Cessna model 172,
which has a total of 13 such checkpoints, all of which are required to be
checked before every flight by extracting at least 2 ounces per
checkpoint. 4 oz.
from the engine.
4
oz. 2 oz. from each of two wing
tanks. 8 oz.
total The
amount of fuel drained as a sample from a twin-engine plane is 12 Ounces,
or 8 ounces from a single, common drain. 8 oz.
4 oz. from each of two engines.
4
oz. 2 oz from each of two wing
tanks. 12 oz.
total The
average fuel sample quantity based on number of single and twin planes is
as follows: Single
engine: 88% @ 8 oz. Multi-engine:
12% @ 12 oz. 8.5 oz. average
sample. Some of
the figures that will be used herein must be derived, from the reference
statistics given on the AOPA fact sheet, and are based on some basic
assumptions. It should be observed that there is a high degree of
correlation between all of the given and derived figures despite using
different data sets and approaches used to arrive at the results. Every
correlation will not be specifically explained, but are self-evident to
those familiar with the subject matter. The
first derived figure sought, which will be used in following calculations,
is the average number of miles flown between departures. The basic
assumption is that the aircraft will undergo a preflight inspection before
each departure, as required by FAA regulations. Because of the average
miles between departures it is assumed that there would probably be a
refueling operation to top the tanks after each operation. This would be
true even if the plane were going to sit waiting to be flown again, since
it is a common practice to fill the idle fuel tanks after a flight to
avoid condensation, or the formation of water in a large air
cavity. Total
annual General Aviation miles flown.. 4,557,800,000. miles Piston
engine factor... 88% Total
piston engine miles flown... 4,010,864,000. miles Total
General Aviation departures... 40,200,000. Piston
engine factor... 88% Total
piston engine plane departures... 35,376,000.departures Factored
miles flown.. 4,010,864,000.
miles Factored
departures... / 35,376,000. departures
Miles
flown per departure... 113.4
Miles/departure The next
figure to be determined is the average number of gallons used, and
therefore necessarily replaced in a refueling operation per departure,
thus identifying a different interval between preflight checks and
consequently, each fuel sampling operation. Total
factored piston engine miles flown... 4,010,864,000. miles Average
miles flown per departure... x 113.4
miles Annual
number of preflight operations or refuels.. 35,369,171. Total
annual gallons of AVGAS consumed... 377,000,000. gallons Annual
number of preflight operations or refuels... /35,369,171. refueling
operations Average
gallons per refuel operation...
10.7 gallons To
validate this figure, it can also be arrived at another
way. Total
annual gallons of AVGAS consumed... 377,000,000. gallons Total
factored piston engine departures... /35,376,000. departures Average
gallons per preflight operation... 10.7 gallons METHODOLOGY
STATEMENT In an
effort to extrapolate a meaningful figure regarding the total amount of
fuel being poured out onto the ground, four different sets of data will be
resolved and then averaged to try to render a number that is a high
confidence expression or at least fair in it’s
representation. DERIVATION
#1 Based on annual number of departures… Total
annual General Aviation departures... 40,200,000. Piston
engine factor... 88% 35,376,000 One
preflight inspection with fuel sampled
x8.5 oz. per
departure… 300,696,000. oz.
128
ounces per gallon... /128 oz. AMOUNT OF
FUEL POURED ONTO THE GROUND 2,349,188. Gallons
ANNUALLY
WITHIN THE UNITED STATES. DERIVATION
#2 Based on annual fuel consumed. Total
annual gallons of AVGAS consumed...
377,000,000. Gals.
Average
estimated refueling quantity...
/10.7
Gals. (assume a
fuel test following refueling
operations, 35,233,645. Refuels or before
next flight after refueling) Average Sample Quantity... X
8.5 oz. Total
ounces... 299,485,931. oz. 128
ounces per gallon... /128 oz. GALLONS
OF FUEL POURED ONTO THE GROUND... 2,339,734.
Gallons DERIVATION
#3 Based on annual miles flown. Total
annual General Aviation miles flown...
4,557,800,000. miles
Piston
engine factor... 88% Total
piston engine miles flown...
4,010,364,000miles Number
of preflight operations/refuels...
35,369,171intervals GALLONS
OF FUEL ANNUALLY POURED ONTO THE GROUND...
2,348,734. Gallons. It may
be argued that a preflight inspection and consequently fuel sampling is
only done once a day per flying aircraft. Therefore, the following
approach may prove enlightening. DERIVATION
#4 Based on one preflight per day per flying
aircraft. Annual
factored departures... 35,376,000. departures
Number
of General Aviation piston planes...
193,366.
aircraft Number
of departures/plane/yr... 182.9 Number
of days in a year... /365
days/year Number
of departures or preflight operations/plane/day... 0.5 This
factor could represent that half of the category planes fly each day, or
half a preflight sample is taken each day for each plane. Numerically it
makes no difference to the outcome. Number
of General Aviation piston planes...
193,366 aircraft
Factored
preflight fuel sample quantity...
x4.25 ounces Number
of ounces of fuel poured out/day
821,806. ounces/day
128
ounces per gallon... /128 oz. Gallons
per day... 6,420. gallons Days in
a year... x365 days/year TOTAL
ANNUAL AMOUNT OF FUEL BEING DUMPED... 2,343,431.
GALLONS COMBINED
RESULTS In an
effort to derive a meaningful figure, which fairly represents the amount
of fuel deliberately poured out onto the ground by pilots in the
contiguous United States in the period of one year, four different
approaches have been used to determine the final number. Different assumptions have been
made in conjunction with different
sets of data. To be fair and to avoid any exaggerations inherent in the
different sets of data, the four results are averaged. This should result
in a number with a higher degree of confidence and believability.
Averaging is reasonable because all four results are of the same general
magnitude and if anything will render a conservative if not accurate final
result. DERIVATION #1 RESULT… 2,349,188
GALLONS/YR. DERIVATION #2 RESULT… 2,339,734
GALLONS/YR. DERIVATION #3 RESULT… 2,348,734
GALLONS/YR. DERIVATION #4 RESULT… 2,343,431
GALLONS/YR. TOTAL... 9,381,087. GALLONS NUMBER OF
RESULTS / 4 2,345,272.
AVERAGE GALLONS /YEAR APPROXIMATELY
2 MILLION, 345 THOUSAND, 272. GALLONS OF LEADED AVIATION FUEL ARE
BEING POURED ONTO THE GROUND AROUND OUR AIRPORTS
ANNUALLY. These
figures only represent fuel purposefully sampled, and discarded by pilots
performing preflight inspections.
It does not include the fuel that drips, or in many cases run out
of the fuel tank vent tube when a plane is either over-filled with fuel,
or has been topped off in the cool of the evening and then experiences the
heat of the following day, thereby expanding the fuel, which then runs out
of the fuel tank vent tube. These circumstances amount to a significant
quantity of fuel as is attested by the stains on every parking ramp across
the country and could add half again the amount of fuel reaching the
ground. Additionally,
the calculated figure does not include any accidental spills of aviation
fuel, nor does it include any jet fuel. STATISTICAL
CONCLUSION. Amazingly
and unequivocally this one operation of sampling the fuel in an airplane
to detect water and debris contamination and then throwing the sample on
the ground amounts to 2.3 MILLION GALLONS of fuel being deliberately
poured out onto the ground of the United States EACH AND EVERY YEAR. Over
the past decade since the activity levels have remained about the same,
this amounts to a staggering 23 MILLION GALLONS of fuel contaminating our
ground and air with petroleum distillates and highly toxic lead
additives. In terms
of wasted resources, consider the barrels of oil that must be refined to
render this amount of aviation fuel and the money spent for the wasted
fuel. TOXICITY
The damage to the atmospheric air quality, local soil, and wastewater is immeasurable, but based on the significance of the quantities involved; they surely must be significant also. In terms
of biological toxicity and toxic pollution to the soil and ground water
supplies consider this, beyond the obvious contamination of petroleum
distillates, the main additive to aviation fuel is tetraethyl lead. It’s
the same organo-metalic anti-knock compound formerly found in banned
regular leaded automotive gasoline only in much greater concentrations. It
is highly toxic, easily absorbed biologically because it is already
organic in its basic nature, and already in solution form, presenting a
considerable health risk because of the serious physiological effects
possible, which include, but is not limited to brain damage, birth
deformities and eventually premature death. This represents enough of a
hazard that because of this threat alone leaded gasoline has been banned
in automotive use, and the practice of spilling AVGAS should be halted,
especially in light of the quantities with which we are
dealing. Many
studies, and historical evidence show that airborne exposure, and skin
contact to tetra-ethyl lead has caused extremely high incidences of
death. Ingestion of minute
quantities only speed the inevitable results. THE
SOLUTION Now that
an awareness of the problem and its size and gravity exists,
attention can now be turned to the solution. This
problem is easily and quickly solved with the issuance and enforcement of
federal regulations coming out of the EPA and the FAA to be imposed on all
airport authorities, FBO’s, Flight Schools, and
pilots. The
Regulation would specifically stipulate three
things: (1) The
practice of throwing fuel samples on the ground is
prohibited. (2) Fuel
samples must be either returned to the aircraft’s fuel tank, or deposited
in a suitable waste fuel collection container away from the
aircraft. (3) Fuel
tank may not be filled above the fuel tank limit
tabs. As it
stands currently, there are some EPA regulations that can be used to
prohibit the offending activity, but only if the local EPA officials wish
to use them to attack this particular problem. As yet, very little is being done to
discourage the deliberate throwing of AVGAS onto the ground by
pilots. Most state EPA officials,
and state legislators completely ignore this hazardous practice, which
puts the health of all complex life forms in proximity to airports in
jeopardy because of the environmental hazards posed. THE
COMPLIANCE QUESTION Legislation
would solve one problem and create one more. The problem created is
one of compliance. What do the pilots that are now throwing the fuel
samples on the ground do to stop polluting the environment and to comply
with the law? There are
alternatives, some of which are reasonable, and others that are
not. First,
pilots could be required to return all samples taken to the aircraft fuel
tanks from which they came. Pilots and the FAA would consider this an
unsafe practice potentially re-contaminating the plane’s fuel supply, and
negate the purpose of the preflight fuel inspection. Secondly, small
collection containers could be supplied by the airport authority and
stationed adjacent to each aircraft parking space where fuel samples could
be collected. This would contain
some of the heavier additives, but the lighter toxins and lead, which is
bound to the petroleum distillates, would easily evaporate into the
air. This might also necessitate
routine inspections and draining of the numerous collection
canisters. Third, an area
collection container could be employed that would service several
aircraft. The distance from the
aircraft would be great enough to all but the adjacent planes, that it is
unlikely pilots would actually use them.
The fourth, and best alternative is the use of fuel testers, which
now are available, that allow pilots to return their fuel samples to the
aircraft fuel tanks by removing any contaminants before the samples are
re-introduced into the aircraft. There
are three reasonable alternatives to throwing AVGAS onto the ground, so
there is no valid excuse to allow this dangerous and detrimental practice
to continue. WHAT CAN
BE DONE Like
most solutions, once the problem is understood the answer is simple. The
solution to this problem requires all citizens of conscience and
intellect, to raise this issue to their legislative representatives, state
EPA officials, and the FAA, requiring them to take the appropriate steps
to halt this deadly, wasteful, and irresponsible
practice. YEAR
2000 ADDENDUM INTRODUCTION Based on
comparison with the statistics in the 1989 report there has been some
interesting changes in the complexion of the aviation field for the year
2000. Although there have been
shifts in the types, and number of active aircraft in the general aviation
category, the number of piston engine aircraft has remained fairly
constant. There has however, been
an increase in the number of the offending preflight operations, and
consequently in the amount of fuel thrown onto the
ground. Active US Aircraft
2000
Of the
total active aircraft in the United States which now number: 233,533 92% are
General Aviation category:
214,388 Of the
total General Aviation aircraft: 93% are
piston engine planes:
199,320 Of the
total General Aviation, piston engine planes: 86.5%
are single engine planes:
172,420 13.5%
are multiengine planes:
26,900 Total
General Aviation departures, and therefore preflight inspections:
48,700,000 METHODOLGY For
comparison purposes, only one derivation will be
shown. DERIVATION
#1 Based on annual number of
departures… Total
annual General Aviation departures…
48,700,000 Piston
engine factor… 93% 45,291,000 One
preflight fuel inspection per departure…
x8.5
oz. Total
ounces sampled and discarded… 384,973,500 128
ounces per gallon… /128 AMOUNT
OF FUEL PURED ON THE GROUND…
3,007,605 GALLONS SUMMARY
STATEMENT This 3
MILLION plus gallons once again represent only the fuel deliberately
extracted from aircraft fuel tanks and then discarded on the ground in a
single year. Aviation gasoline
still contains the same amount of tetraethyl lead. Over 1989 this amounts to an increase in
dangerous pollution of 22% in 11 years.
That amounts to an average increase of 2% per year. Over the years
from 1989 to 2000, a total of over 32 MILLION GALLONS of lead laced
gasoline has been deliberately, and irresponsibly poured onto the ground
by the single act of private pilots sampling fuel during preflight
inspections. In the decade
preceding 1989 an estimated 23 MILLION GALLONS were poured out. Roughly, 55 MILLION GALLONS have
polluted airport soils and waste water resources over the past 21
years. In
recent years there has been some discussion about removing the lead
additive from aviation fuel, but nothing ever seems to be done. Even if the lead additives were removed
from AVGAS there would still be the same amounts of petroleum distillates
being poured onto the ground. What
must happen to solve the total problem is the discontinuation of the
practice of pouring fuel samples onto the ground. The
makeup of the number of piston-powered aircraft has shifted somewhat over
the past decade. There are fewer
production aircraft being sold, but ever increasing numbers of homebuilt
planes, which keeps the small general aviation numbers stable and growing
slightly each year. Another
trend is more closely related to the problem focused on in this report,
and more of a concern. There is a
trend toward maintaining fewer publicly funded airports across the United
States. At the same time there are
more private airports and landing areas being built, which increases the
overall number of aviation facilities.
The most easily supervised and controlled facilities are public
airports. If the practice of not
dumping fuel is not soon incorporated into the habits of pilots, there
will be less control over the contamination of ever increasing real estate
across the nation, with that pollution making its way into more and more
soil and water systems. The time
is long overdue to insist that this practice be stopped.  |
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