Effluent Limitation Guidelines and New Source Performance Standards for the Airport Deicing Category

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Text

Part V

Environmental Protection Agency

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40 CFR Part 449

Effluent Limitation Guidelines and New Source Performance Standards for

the Airport Deicing Category; Proposed Rule

Proposed Rules

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ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 449

[EPA-HQ-OW-2004-0038 FRL-8948-2]

RIN 2040-AE69

Effluent Limitation Guidelines and New Source Performance

Standards for the Airport Deicing Category

AGENCY: Environmental Protection Agency (EPA).

ACTION: Proposed rule.

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SUMMARY: EPA is proposing technology-based effluent limitation

guidelines (ELGs) and new source performance standards (NSPS) under the

Clean Water Act (CWA) for discharges from airport deicing operations.

The requirements generally would apply to wastewater associated with

the deicing of aircraft and airfield pavement at primary commercial

airports. The ELGs would be incorporated into the NPDES permits issued

by EPA, states or tribes. EPA expects compliance with this regulation

to reduce the discharge of deicing-related pollutants by at least 44.6

million pounds per year. EPA estimates the annual cost of the rule

would be $91.3 million.

DATES: Comments must be received on or before December 28, 2009. Under

the Paperwork Reduction Act, comments on the information collection

provisions must be received by the Office of Management and Budget on

or before September 28, 2009.

uce the discharge of deicing-related pollutants by at least 44.6

million pounds per year. EPA estimates the annual cost of the rule

would be $91.3 million.

DATES: Comments must be received on or before December 28, 2009. Under

the Paperwork Reduction Act, comments on the information collection

provisions must be received by the Office of Management and Budget on

or before September 28, 2009.

ADDRESSES: Submit your comments, identified by Docket No. EPA-HQ-OW-

2004-0038 by one of the following methods:

http:www.regulations.gov: Follow the on-line instructions

for submitting comments.

E-mail: [email protected], Attention Docket ID No. EPA-HQ-

OW-2004-0038.

Mail: Water Docket, U.S. Environmental Protection Agency,

Mail Code: 4203M, 1200 Pennsylvania Ave., NW., Washington, DC 20460.

Attention Docket ID No. EPA-HQ-OW-2004-0038. Please include a total of

3 copies. In addition, please mail a copy of your comments on the

information collection provisions to the Office of Information and

Regulatory Affairs, Office of Management and Budget (OMB), Attn: Desk

Officer for EPA, 725 17th St., NW., Washington, DC 20503.

Hand Delivery: Water Docket, EPA Docket Center, EPA West

Building Room 3334, 1301 Constitution Ave., NW., Washington, DC,

Attention Docket ID No. EPA-HQ-OW-2004-0038. Such deliveries are only

accepted during the Docket's normal hours of operation, and special

arrangements should be made for deliveries of boxed information by

calling 202-566-2426.

Instructions: Direct your comments to Docket No EPA-HQ-OW-2004-

0038. EPA's policy is that all comments received will be included in

the public docket without change and may be made available online at

http://www.regulations.gov, including any personal information

provided, unless the comment includes information claimed to be

Confidential Business Information (CBI) or other information whose

disclosure is restricted by statute

o Docket No EPA-HQ-OW-2004-

0038. EPA's policy is that all comments received will be included in

the public docket without change and may be made available online at

http://www.regulations.gov, including any personal information

provided, unless the comment includes information claimed to be

Confidential Business Information (CBI) or other information whose

disclosure is restricted by statute. Do not submit information that you

consider to be CBI or otherwise protected through www.regulations.gov

or e-mail. The www.regulations.gov Web site is an ``anonymous access''

system, which means EPA will not know your identity or contact

information unless you provide it in the body of your comment. If you

send an e-mail comment directly to EPA without going through http://www.regulations.gov your e-mail address will be automatically captured

and included as part of the comment that is placed in the public docket

and made available on the Internet. If you submit an electronic

comment, EPA recommends that you include your name and other contact

information in the body of your comment and with any disk or CD-ROM you

submit. If EPA cannot read your comment due to technical difficulties

and cannot contact you for clarification, EPA may not be able to

consider your comment. Electronic files should avoid the use of special

characters, any form of encryption, and be free of any defects or

viruses.

Docket: All documents in the docket are listed in the http://www.regulations.gov index. A detailed record index, organized by

subject, is available on EPA's Web site at http://epa.gov/guide/airport. Although listed in the index, some information is not publicly

available, e.g., CBI or other information whose disclosure is

restricted by statute. Certain other material, such as copyrighted

material, will be publicly available only in hard copy

the http://www.regulations.gov index. A detailed record index, organized by

subject, is available on EPA's Web site at http://epa.gov/guide/airport. Although listed in the index, some information is not publicly

available, e.g., CBI or other information whose disclosure is

restricted by statute. Certain other material, such as copyrighted

material, will be publicly available only in hard copy. Publicly

available docket materials are available either electronically in

http://www.regulations.gov or in hard copy at the Water Docket in the

EPA Docket Center, EPA/DC, EPA West, Room 3334, 1301 Constitution Ave.,

NW., Washington, DC. The Public Reading Room is open from 8:30 a.m. to

4:30 p.m., Monday through Friday, excluding legal holidays. The

telephone number for the Public Reading Room is 202-566-1744, and the

telephone number for the Water Docket is 202-566-2426.

FOR FURTHER INFORMATION CONTACT: Eric Strassler, Engineering and

Analysis Division, telephone: 202-566-1026; e-mail:

[email protected] or Brian D'Amico, Engineering and Analysis

Division, telephone: 202-566-1069; e-mail: [email protected].

SUPPLEMENTARY INFORMATION:

Regulated Entities

Entities potentially regulated by this action include:

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North American

Example of regulated Industry

Category entity Classification

System Code

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Industry....................... Primary airports with 481, 4881

over 1,000 annual jet

departures that

conduct deicing

operations.

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North American

Example of regulated Industry

Category entity Classification

System Code

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Industry....................... Primary airports with 481, 4881

over 1,000 annual jet

departures that

conduct deicing

operations.

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This section is not intended to be exhaustive, but rather provides

a guide for readers regarding entities likely to be regulated by this

action. Other types of entities that do not meet the above criteria

could also be regulated. To determine whether your facility is

regulated by this action, you should carefully examine the

applicability criteria listed in Sec. 449.01 and the definitions in

Sec. 449.02 of the rule and detailed further in Section IV of this

preamble. If you still have questions regarding the applicability of

this action to a particular entity, consult one of the persons listed

for technical information in the preceding FOR FURTHER INFORMATION

CONTACT section.

How To Submit Comments

The public may submit comments in written or electronic form. (See

the ADDRESSES section above.) Electronic comments must be identified by

the docket no. EPA-HQ-OW-2004-0038 and must be submitted as a

WordPerfect, MS Word or ASCII text file, avoiding the use of special

characters and any form of encryption. EPA requests that any graphics

included in electronic comments also be provided in hard-copy form. EPA

also will accept comments and data on disks in the aforementioned file

formats. Electronic comments received on this notice may be filed

online at many Federal Depository Libraries. No confidential business

information (CBI) should be sent by e-mail.

Supporting Documentation

of encryption. EPA requests that any graphics

included in electronic comments also be provided in hard-copy form. EPA

also will accept comments and data on disks in the aforementioned file

formats. Electronic comments received on this notice may be filed

online at many Federal Depository Libraries. No confidential business

information (CBI) should be sent by e-mail.

Supporting Documentation

The rule proposed today is supported by a number of documents

including:

Technical Development Document for Proposed Effluent

Limitation Guidelines and Standards for the Airport Deicing Category

(TDD), Document No. EPA-821-R-09-004;

Economic Analysis for Proposed Effluent Limitation

Guidelines and Standards for the Airport Deicing Category (EA),

Document No. EPA-821-R-09-005;

Environmental Impact and Benefit Assessment for Proposed

Effluent Limitation Guidelines and Standards for the Airport Deicing

Category (EIB), Document No. EPA-821-R-09-003.

These documents are available in the public record for this rule and on

EPA's Web site at http://epa.gov/guide/airport. They are available in

hard copy from the National Service Center for Environmental

Publications (NSCEP), U.S. EPA/NSCEP, P.O. Box 42419, Cincinnati, Ohio

45242-2419, telephone 800-490-9198, http://epa.gov/ncepihom.

Overview

The preamble describes the terms, acronyms, and abbreviations used

in this notice; the background documents that support these proposed

regulations; the legal authority of these rules; a summary of the

proposal; background information; and the technical and economic

methodologies used by the Agency to develop these regulations. This

preamble also solicits comment and data on specific areas of interest.

Table of Contents

rms, acronyms, and abbreviations used

in this notice; the background documents that support these proposed

regulations; the legal authority of these rules; a summary of the

proposal; background information; and the technical and economic

methodologies used by the Agency to develop these regulations. This

preamble also solicits comment and data on specific areas of interest.

Table of Contents

I. Legal Authority

II. Purpose and Summary of Proposed Rule

III. Background

IV. Scope/Applicability of Proposed Rule

V. Industry Profile

VI. Summary of Data Collection

VII. Technology Options, Costs, Wastewater Characteristics, and

Pollutant Reductions

VIII. Economic Analysis for Airports

IX. Airline Impacts

X. Environmental Assessment

XI. Non-Water Quality Environmental Impacts

XII. Regulatory Implementation

XIII. Statutory and Executive Order Reviews

XIV. Solicitation of Data and Comments

XV. Guidelines for Submission of Analytical Data

Appendix A: Abbreviations and Definitions Used in This Document

I. Legal Authority

EPA is proposing this regulation under the authorities of sections

301, 304, 306, 308, 402 and 501 of the Clean Water Act (CWA), 33 U.S.C.

1311, 1314, 1316, 1318, 1342 and 1361 and pursuant to the Pollution

Prevention Act of 1990, 42 U.S.C. 13101 et seq.

II. Purpose and Summary of Proposed Rule

Section 304(m) of the CWA, added by the Water Quality Act of 1987,

requires EPA to establish schedules for (1) reviewing and revising

existing effluent limitation guidelines and standards (``effluent

guidelines'') and (2) promulgating new effluent guidelines. On

September 2, 2004, EPA published an Effluent Guidelines Plan (69 FR

53705) that established schedules for developing new and revised

effluent guidelines for several industry categories. One of the

industries for which the Agency established a schedule was the Airport

Deicing Category. Today EPA proposes to set national standards for

control of wastewater discharges from deicing operations at airports

r 2, 2004, EPA published an Effluent Guidelines Plan (69 FR

53705) that established schedules for developing new and revised

effluent guidelines for several industry categories. One of the

industries for which the Agency established a schedule was the Airport

Deicing Category. Today EPA proposes to set national standards for

control of wastewater discharges from deicing operations at airports.

Deicing operations include removal of ice from aircraft, application of

chemicals to prevent initial icing or further icing (anti-icing), and

removal of (and preventing) ice from airfield pavement (runways,

taxiways, aprons and ramps).

Commercial airports and air carriers conduct deicing operations as

required by the Federal Aviation Administration (FAA). Airport

discharges from deicing operations may affect water quality, including

reductions in dissolved oxygen, fish kills, reduced organism abundance

and species diversity, contamination of drinking water sources (both

surface and groundwater), creation of noxious odors and discolored

water in residential areas and parkland, and other effects.

The proposed effluent guidelines and standards address both the

wastewater collection practices used by airports, and the treatment of

those wastes. Airports within the scope of this proposed rule would be

required to collect spent aircraft deicing fluid (ADF) and treat the

associated wastewater. Additionally, airports performing airfield

pavement deicing would be required to use non-urea-based deicers. The

requirements would be implemented in CWA discharge permits.

III. Background

A. Clean Water Act

, and the treatment of

those wastes. Airports within the scope of this proposed rule would be

required to collect spent aircraft deicing fluid (ADF) and treat the

associated wastewater. Additionally, airports performing airfield

pavement deicing would be required to use non-urea-based deicers. The

requirements would be implemented in CWA discharge permits.

III. Background

A. Clean Water Act

Congress passed the Federal Water Pollution Control Act Amendments

of 1972, also known as the Clean Water Act (CWA), to ``restore and

maintain the chemical, physical, and biological integrity of the

nation's waters.'' (33 U.S.C. 1251(a)). The CWA establishes a

comprehensive program for protecting our nation's waters. Among its

core provisions, the CWA prohibits the discharge of pollutants from a

point source to waters of the U.S. except as authorized under the CWA.

Under section 402 of the CWA, EPA authorizes discharges by a National

Pollutant Discharge Elimination System (NPDES) permit. The CWA also

authorizes EPA to establish national technology-based effluent

limitation guidelines and standards (effluent guidelines or ELGs) for

discharges from different categories of point sources, such as

industrial, commercial and public sources.

Congress recognized that regulating only those sources that

discharge effluent directly into the nation's waters would not be

sufficient to achieve the CWA's goals. Consequently, the CWA requires

EPA to promulgate nationally applicable pretreatment standards that

restrict pollutant discharges from facilities that discharge wastewater

indirectly through sewers flowing to publicly owned treatment works

(POTWs). See section 307(b) and (c), 33 U.S.C. 1317(b) and (c).

National pretreatment standards are established for those pollutants in

wastewater from indirect dischargers that may pass through, interfere

with or are otherwise incompatible with POTW operations

ct pollutant discharges from facilities that discharge wastewater

indirectly through sewers flowing to publicly owned treatment works

(POTWs). See section 307(b) and (c), 33 U.S.C. 1317(b) and (c).

National pretreatment standards are established for those pollutants in

wastewater from indirect dischargers that may pass through, interfere

with or are otherwise incompatible with POTW operations. Generally,

pretreatment standards are designed to ensure that wastewaters from

direct and indirect industrial dischargers are subject to similar

levels of treatment. In addition, POTWs are required to implement local

treatment limits applicable to their industrial indirect dischargers to

satisfy any local requirements. See 40 CFR 403.5.

Direct dischargers must comply with effluent limitations in NPDES

permits. Indirect dischargers, who discharge through POTWs, must comply

with pretreatment standards. Technology-based effluent limitations in

NPDES

permits are derived from effluent limitation guidelines (CWA sections

301 and 304) and new source performance standards (sec. 306)

promulgated by EPA, or based on best professional judgment where EPA

has not promulgated an applicable effluent guideline or new source

performance standard. Additional limitations based on water quality

standards (sec. 303) may also be included in the permit in certain

circumstances. The ELGs are established by regulation for categories of

industrial dischargers and are based on the degree of control that can

be achieved using various levels of pollution control technology

gated an applicable effluent guideline or new source

performance standard. Additional limitations based on water quality

standards (sec. 303) may also be included in the permit in certain

circumstances. The ELGs are established by regulation for categories of

industrial dischargers and are based on the degree of control that can

be achieved using various levels of pollution control technology.

EPA promulgates national effluent limitation guidelines and

standards of performance for major industrial categories for three

classes of pollutants: (1) Conventional pollutants (i.e., total

suspended solids, oil and grease, biochemical oxygen demand, fecal

coliform, and pH); (2) toxic pollutants (e.g., toxic metals such as

chromium, lead, nickel, and zinc; toxic organic pollutants such as

benzene, benzo-a-pyrene, phenol, and naphthalene); and (3) non-

conventional pollutants (e.g., ammonia-N, formaldehyde, and

phosphorus).

B. NPDES Permits

Section 402 of the CWA requires permits for discharges of

pollutants to waters of the United States. In most states, the permits

are issued by a state agency that has been authorized by EPA. Currently

46 states and 1 U.S. territory are authorized to issue NPDES permits.

In the other states and territories, EPA issues the permits.

Section 402(p) of the Act, added by the Water Quality Act of 1987

(Pub. L. 100-4, February 4, 1987), requires stormwater dischargers

``associated with industrial activity'' to be covered under an NPDES

permit. In its initial stormwater permit regulations, called the

``Phase I'' stormwater regulations (55 FR 47990, November 16, 1990),

EPA designated air transportation facilities, including both airlines

and airports, which have vehicle maintenance shops (including vehicle

rehabilitation, mechanical repairs, painting, fueling, and

lubrication), equipment cleaning operations, or airport deicing

operations as subject to NPDES stormwater permitting requirements. See

40 CFR 122.26(b)(14)(viii)

(55 FR 47990, November 16, 1990),

EPA designated air transportation facilities, including both airlines

and airports, which have vehicle maintenance shops (including vehicle

rehabilitation, mechanical repairs, painting, fueling, and

lubrication), equipment cleaning operations, or airport deicing

operations as subject to NPDES stormwater permitting requirements. See

40 CFR 122.26(b)(14)(viii).

Airport stormwater discharges may be controlled under a general

NPDES permit, which covers multiple facilities with similar types of

operations and/or wastestreams, or by an individual permit. (An airport

may have additional NPDES permits for non-stormwater discharges, such

as from equipment repair and maintenance facilities. The following

discussion pertains only to stormwater permits.)

1. General Permits

Currently most airport deicing discharges are covered by a general

permit issued either by EPA or by an NPDES-authorized state agency. In

most areas where EPA is the permit authority, the Multi-Sector General

Permit (MSGP) covers airport deicing discharges (73 FR 56572, September

29, 2008). Many NPDES-authorized state agencies have issued general

permits in their respective jurisdictions with requirements similar to

the MSGP. An airport seeking coverage under a general permit submits a

Notice of Intent (NOI) to the permit authority rather than a detailed

permit application. By submitting an NOI, the permittee is agreeing to

comply with the conditions in the published permit

08). Many NPDES-authorized state agencies have issued general

permits in their respective jurisdictions with requirements similar to

the MSGP. An airport seeking coverage under a general permit submits a

Notice of Intent (NOI) to the permit authority rather than a detailed

permit application. By submitting an NOI, the permittee is agreeing to

comply with the conditions in the published permit.

For airports, the major requirements of the MSGP are:

Develop a stormwater pollution prevention plan (SWPPP),

including a drainage area site map, documentation of measures used for

management of runoff, an evaluation of runway and aircraft deicing

operations, and implementation of a program to control or manage

contaminated runoff, including consideration of various listed control

practices;

Implement deicing source reduction measures, including

minimizing or eliminating the use of urea and glycol-based deicing

chemicals; minimizing contamination of stormwater runoff from runway

and aircraft deicing operations; evaluating whether over-application of

deicing chemicals occurs; and consider use of various listed source

control measures;

For airports using over 100,000 gal. of glycol based

deicing chemicals and/or 100 tons or more of urea annually, monitor

discharges quarterly for the first four quarters of the permit cycle,

for the following pollutants: biochemical oxygen demand

(BOD5), chemical oxygen demand (COD), ammonia and pH;

If the average of the four monitoring values for any

parameter exceeds its benchmark, implement additional control measures

where feasible, and continue monitoring;

Conduct an annual site inspection during the deicing

season, and during periods of actual deicing operations if possible;

and routine facility inspections at least monthly during the deicing

season.

2. Individual Permits

Some EPA and state NPDES-permitting authorities have required

certain airports to obtain individual permits

tional control measures

where feasible, and continue monitoring;

Conduct an annual site inspection during the deicing

season, and during periods of actual deicing operations if possible;

and routine facility inspections at least monthly during the deicing

season.

2. Individual Permits

Some EPA and state NPDES-permitting authorities have required

certain airports to obtain individual permits. In these situations, an

airport must submit a detailed application and the permit authority

develops specific requirements for the facility.

Some individual permits contain specialized requirements for

monitoring and/or best management practices. Some of these permits also

contain numeric water quality-based effluent limitations (WQBELs).

Information on water quality-based permitting is available on EPA's Web

site at http://cfpub.epa.gov/npdes/generalissues/watertechnology.cfm.

C. Effluent Guidelines and Standards Program

Effluent guidelines and new source performance standards are

technology-based regulations that are developed by EPA for a category

of dischargers. These regulations are based on the performance of

control and treatment technologies. The legislative history of CWA

section 304(b), which is the heart of the effluent guidelines program,

describes the need to press toward higher levels of control through

research and development of new processes, modifications, replacement

of obsolete plans and processes, and other improvements in technology,

taking into account the cost of controls. Congress also directed that

EPA not consider water quality impacts on individual water bodies as

the guidelines are developed. See Statement of Senator Muskie (Oct. 4,

1972), reprinted in Legislative History of the Water Pollution Control

Act Amendments of 1972, at 170. (U.S. Senate, Committee on Public

Works, Serial No

other factors as the Administrator deems appropriate. See CWA sec.

304(b)(1)(B). If, however, existing performance is uniformly

inadequate, EPA may establish limitations based on higher levels of

control than currently in place in an industrial category when based on

an Agency determination that the technology is available in another

category or subcategory, and can be practically applied.

2. Best Conventional Pollutant Control Technology (BCT)

The 1977 amendments to the CWA required EPA to identify additional

levels of effluent reduction for conventional pollutants associated

with BCT technology for discharges from existing industrial point

sources. In addition to other factors specified in section

304(b)(4)(B), the CWA requires that EPA establish BCT limitations after

consideration of a two part ``cost-reasonableness'' test. EPA explained

its methodology for the development of BCT limitations in July 1986 (51

FR 24974). Section 304(a)(4) designates the following as conventional

pollutants: biochemical oxygen demand measured over five days

(BOD5), total suspended solids (TSS), fecal coliform, pH,

and any additional pollutants defined by the Administrator as

conventional. The Administrator designated oil and grease as an

additional conventional pollutant on July 30, 1979 (44 FR 44501; 40 CFR

401.16).

3. Best Available Technology Economically Achievable (BAT)

BAT represents the second level of stringency for controlling

direct discharge of toxic and nonconventional pollutants. In general,

BAT effluent limitation guidelines represent the best economically

achievable performance of facilities in the industrial subcategory or

category. The factors considered in assessing BAT include the cost of

achieving BAT effluent reductions, the age of equipment and facilities

involved, the process employed, potential process changes, and non-

water quality environmental impacts including energy requirements, and

such other factors as the Administrator deems appropriate

performance of facilities in the industrial subcategory or

category. The factors considered in assessing BAT include the cost of

achieving BAT effluent reductions, the age of equipment and facilities

involved, the process employed, potential process changes, and non-

water quality environmental impacts including energy requirements, and

such other factors as the Administrator deems appropriate. The Agency

retains considerable discretion in assigning the weight to be accorded

these factors. An additional statutory factor considered in setting BAT

is economic achievability. Generally, EPA determines economic

achievability on the basis of total costs to the industry and the

effect of compliance with BAT limitations on overall industry and

subcategory financial conditions. As with BPT, where existing

performance is uniformly inadequate, BAT may reflect a higher level of

performance than is currently being achieved based on technology

transferred from a different subcategory or category. BAT may be based

upon process changes or internal controls, even when these technologies

are not common industry practice.

4. New Source Performance Standards (NSPS)

New Source Performance Standards reflect effluent reductions that

are achievable based on the best available demonstrated control

technology. Owners of new facilities have the opportunity to install

the best and most efficient production processes and wastewater

treatment technologies. As a result, NSPS should represent the most

stringent controls attainable through the application of the best

available demonstrated control technology for all pollutants (that is,

conventional, nonconventional, and priority pollutants). In

establishing NSPS, EPA is directed to take into consideration the cost

of achieving the effluent reduction and any non-water quality

environmental impacts and energy requirements.

5

resent the most

stringent controls attainable through the application of the best

available demonstrated control technology for all pollutants (that is,

conventional, nonconventional, and priority pollutants). In

establishing NSPS, EPA is directed to take into consideration the cost

of achieving the effluent reduction and any non-water quality

environmental impacts and energy requirements.

5. Pretreatment Standards for Existing Sources (PSES)

Pretreatment standards apply to discharges of pollutants to

publicly owned treatment works (POTW) rather than to discharges to

waters of the United States. Pretreatment Standards for Existing

Sources are designed to prevent the discharge of pollutants that pass

through, interfere with, or are otherwise incompatible with the

operation of POTWs. Categorical pretreatment standards are technology-

based and are analogous to BAT effluent limitation guidelines. The

General Pretreatment Regulations, which set forth the framework for the

implementation of categorical pretreatment standards, are found at 40

CFR part 403. These regulations establish pretreatment standards that

apply to all non-domestic dischargers. See 52 FR 1586 (Jan. 14, 1987).

6. Pretreatment Standards for New Sources (PSNS)

Section 307(c) of the Act calls for EPA to promulgate pretreatment

standards for new sources at the same time it promulgates new source

performance standards. Such pretreatment standards must prevent the

discharge of any pollutant into a POTW that may interfere with, pass

through, or may otherwise be incompatible with the POTW. EPA

promulgates categorical pretreatment standards for existing sources

based principally on BAT technology for existing sources. EPA

promulgates pretreatment standards for new sources based on best

available demonstrated technology for new sources. New indirect

dischargers have the opportunity to incorporate into their facilities

the best available demonstrated technologies

e with the POTW. EPA

promulgates categorical pretreatment standards for existing sources

based principally on BAT technology for existing sources. EPA

promulgates pretreatment standards for new sources based on best

available demonstrated technology for new sources. New indirect

dischargers have the opportunity to incorporate into their facilities

the best available demonstrated technologies. The Agency typically

considers the same factors in promulgating PSNS as it considers in

promulgating NSPS.

IV. Scope/Applicability of Proposed Rule

EPA solicits comments on various issues specifically identified in

this preamble as well as any other issues related to this rule that are

not specifically addressed in today's notice.

A. Facilities Subject to 40 CFR Part 449

EPA is proposing to establish effluent limitation guidelines and

standards for primary commercial airports that conduct deicing

operations and have more than 1,000 annual departures of scheduled

commercial jet aircraft. Further information on the rationale for the

proposed scope is provided in Section VII.D.1 of this preamble and in

both the TDD and the EA.

B. Overview of Technology Requirements

The proposed rule would require an airport subject to this Part to:

Collect at least a specified proportion (either 20 or 60

percent) of available ADF after it is sprayed on aircraft;

Meet a specified numeric effluent limit for ADF wastewater

collected and discharged on site; and

Certify that it uses airfield pavement deicers that do not

contain urea.

All references to ADF in today's proposed rule are for normalized ADF,

which is ADF less any water added by the manufacturer or customer

before ADF application.

The technologies that serve as the basis for the proposed ELGs are

summarized in Table IV-1 and Figure IV-1. These provisions are

explained in Section VII of this preamble.

t uses airfield pavement deicers that do not

contain urea.

All references to ADF in today's proposed rule are for normalized ADF,

which is ADF less any water added by the manufacturer or customer

before ADF application.

The technologies that serve as the basis for the proposed ELGs are

summarized in Table IV-1 and Figure IV-1. These provisions are

explained in Section VII of this preamble.

Table IV-1--Summary of Proposed Airport Deicing Effluent Limitation Guidelines and Standards

----------------------------------------------------------------------------------------------------------------

Technical components

-------------------------------------------------------------

Regulatory level Technology basis Airports > 1,000 annual jet Airports > 1,000 annual jet

departures and >= 10,000 departures and = based pavement deicers or

460,000 gal. ADF usage) or Meet effluent limit for

capture 20% (for airports http://www.airweb.faa.gov.

C. Description of Deicing Operations

A major concern for the safety of passengers is the clearing of ice

and snow buildup on runways, taxiways, roadways, gate areas, and

aircraft. Two basic types of deicing/anti-icing operations are

generally performed at an airport: the deicing/anti-icing of aircraft,

and the deicing/anti-icing of paved areas, including runways, taxiways,

roadways, and gate areas. The most common technique for the deicing/

anti-icing of aircraft is the application of chemical deicing/anti-

icing agents. Deicing of runways, taxiways, and roadways is most

commonly performed using mechanical means, but may also be performed

using chemical agents. The anti-icing of paved areas is typically

conducted with anti-icing chemicals.

1. Aircraft Deicing

Aircraft deicing involves the removal of frost, snow, or ice from

an aircraft. Aircraft anti-icing generally refers to the prevention of

the accumulation of frost, snow, or ice

ays, and roadways is most

commonly performed using mechanical means, but may also be performed

using chemical agents. The anti-icing of paved areas is typically

conducted with anti-icing chemicals.

1. Aircraft Deicing

Aircraft deicing involves the removal of frost, snow, or ice from

an aircraft. Aircraft anti-icing generally refers to the prevention of

the accumulation of frost, snow, or ice. The responsibility for

performing deicing/anti-icing varies between airports, but it is

usually performed by a combination of individual airlines and support

contractors, commonly called fixed-base operators (FBOs) or ground

service providers. Airlines typically select procedures for deicing/

anti-icing their aircraft, which are then approved by the FAA.

a. Chemical Deicing Practices

In the deicing/anti-icing process, aircraft are usually sprayed

with deicing/anti-icing fluids (ADF) that contain chemical deicing

agents; however, non-chemical methods are also performed. Deicing/anti-

icing occurs when the weather conditions are such that ice or snow

accumulates on an aircraft. During snowstorms, freezing rain, or cold

weather that causes frost to accumulate on aircraft surfaces including

the wings, deicing is necessary to ensure the safe operation of

aircraft. Studies have concluded that even a small amount of ice, if

located on critical aircraft surfaces (e.g., leading edge of the wing),

can cause significant decreases in lift.

The typical deicing season runs from October through April for most

airports in the northern U.S. In colder areas, the deicing season may

extend over a longer period. In warmer climates, the deicing season may

be shorter or deicing may rarely occur. However, it is important to

note that deicing may be needed in hot, humid areas at any time. Some

aircraft may experience frost build-up after landing at an airport in a

hot, humid area

ber through April for most

airports in the northern U.S. In colder areas, the deicing season may

extend over a longer period. In warmer climates, the deicing season may

be shorter or deicing may rarely occur. However, it is important to

note that deicing may be needed in hot, humid areas at any time. Some

aircraft may experience frost build-up after landing at an airport in a

hot, humid area. (The phenomenon is similar to frost forming on a cold

glass of water exposed to hot, humid air and occurs for the same reason

that the cold glass developed frost. Fuel chills when a plane operates

at high altitudes where the temperature is very cold. When the plane

lands in a hot, humid area, the cold fuel chills the fuel tank. If the

tank is very close to the surface of the wing, it causes frost to form

on the wing.)

ADF works by adhering to aircraft surfaces to remove and/or prevent

snow and ice accumulation. Non-chemical methods include the use of

mechanical or thermal means (e.g., infrared heating) to prevent,

remove, or melt ice and snow. Two types of deicing are performed: Wet-

weather and dry-weather deicing, depending on a number of climatic and

operational factors. Wet-weather deicing is performed during storm

events that include precipitation such as snow, sleet, or freezing

rain. Dry-weather deicing is performed when changes in the ambient

temperature cause frost or ice to form on aircraft but no precipitation

is present. Dry-weather deicing may also be performed on some types of

aircraft whose fuel tanks become super-cooled during high-altitude

flight, resulting in ice formation at lower altitudes and after

landing. Dry-weather deicing may occur at temperatures up to 55[deg]

Fahrenheit (F), but generally requires a significantly smaller volume

of deicing fluid than wet-weather deicing.

During typical wet-weather conditions, 150 to 1,000 gallons of ADF

may be used on a single commercial jet, while as little as 10 gallons

may be used on a small corporate jet

formation at lower altitudes and after

landing. Dry-weather deicing may occur at temperatures up to 55[deg]

Fahrenheit (F), but generally requires a significantly smaller volume

of deicing fluid than wet-weather deicing.

During typical wet-weather conditions, 150 to 1,000 gallons of ADF

may be used on a single commercial jet, while as little as 10 gallons

may be used on a small corporate jet. An estimated 1,000 to 4,000

gallons may be needed to deice a larger commercial jet during severe

weather conditions. Aircraft anti-icing fluids are applied in much

smaller volumes than their deicing counterparts are. A commercial jet

requires approximately 35 gallons of fluid for anti-icing after

deicing. Generally, dry-weather deicing requires 20 to 50 gallons of

deicing fluid, depending on the size of the aircraft.

Chemical aircraft deicers are categorized into four classes. Not

all types are currently used. Fluid types vary by composition and

allowed holdover time (the estimated time for which deicing/anti-icing

fluid will prevent the formation of frost or ice and the accumulation

of snow on the treated surfaces of an aircraft). Type I is the most

commonly used fluid and is used primarily for aircraft deicing. These

types of fluids typically contain glycol as the active ingredient

(usually ethylene glycol or propylene glycol), along with water and

additives, and remove accumulated ice and snow from aircraft surfaces.

Types II, III, and IV were developed for anti-icing. These fluids form

a protective anti-icing film on aircraft surfaces to prevent the

accumulation of ice and snow. Anti-icing fluids are composed of either

ethylene glycol or propylene glycol, a small amount of thickener,

water, and additives. The additives in aircraft

nd

additives, and remove accumulated ice and snow from aircraft surfaces.

Types II, III, and IV were developed for anti-icing. These fluids form

a protective anti-icing film on aircraft surfaces to prevent the

accumulation of ice and snow. Anti-icing fluids are composed of either

ethylene glycol or propylene glycol, a small amount of thickener,

water, and additives. The additives in aircraft

deicing and anti-icing fluids may include corrosion inhibitors, flame

retardants, wetting agents, identifying dyes, and foam suppressors.

Type IV fluids can provide up to a 70 minute holdover time, depending

on atmospheric conditions. (Holdover time is the amount of time a given

aircraft treatment by ground anti-icing fluid remains effective.

Holdover time effectively runs out when frozen deposits start to form

or accumulate on treated aircraft surfaces.) Most large airlines use

both Type I and Type IV fluids.

Aircraft deicing and anti-icing operations usually occur at

terminal gates, gate aprons, taxiways, or centralized deicing pads.

Centralized deicing pads may be located near terminals and gates, along

taxiways serving departure runways, or near the departure end of

runways. Each airport may use only one or a combination of all of these

locations for deicing/anti-icing. The amount and type of deicing

performed at each location may vary. For example, an airport with

deicing pads may allow air carriers to perform minimal deicing at

gates, at a level sufficient to move the aircraft safely, and require

all other deicing operations to be conducted at a pad.

If deicing is not conducted at the gate, then, prior to takeoff, an

aircraft will taxi to an airport-approved deicing/anti-icing location.

Depending on the deicing location design, several aircraft may be

deiced simultaneously on a single deicing pad. Deicing trucks and/or

spray equipment mounted on fixed booms apply the appropriate ADF

all other deicing operations to be conducted at a pad.

If deicing is not conducted at the gate, then, prior to takeoff, an

aircraft will taxi to an airport-approved deicing/anti-icing location.

Depending on the deicing location design, several aircraft may be

deiced simultaneously on a single deicing pad. Deicing trucks and/or

spray equipment mounted on fixed booms apply the appropriate ADF. One

to four deicer trucks may be used for deicing a single aircraft,

depending on its size and weather conditions. When holdover times are

exceeded prior to takeoff, secondary deicing/anti-icing is necessary.

If an aircraft must return to the gate or another designated location

for secondary deicing/anti-icing, its departure may be substantially

delayed. The need for secondary deicing will likely decrease as more

airlines use Type IV fluids to extend the allowable holdover time.

While the FAA has issued regulations and guidance on conducting

deicing/anti-icing operations, the aircraft pilot is ultimately

responsible for determining whether the deicing performed is adequate.

The pilot may inspect the aircraft after deicing and order additional

deicing or anti-icing.

Dry-weather deicing, also referred to as clear ice deicing, may be

performed whenever ambient temperatures are cold enough to form ice on

aircraft wings (below 55[deg] F). Dry-weather deicing is also used to

defrost windshields and wingtips on commuter planes and is usually

conducted throughout the entire deicing/anti-icing season.

b. Non-Chemical Deicing Practices

Non-chemical deicing methods involve mechanical or thermal means to

remove ice and snow from aircraft surfaces. Dry, powdery snow can be

swept from aircraft using brooms or brushes. Hot air blowers can also

be used to remove snow mechanically with forced air and to melt ice and

snow. In addition, some smaller aircraft are equipped with inflatable

pneumatic or hydraulic boots that can expand to break ice off the

leading edges of wings and elevators

l means to

remove ice and snow from aircraft surfaces. Dry, powdery snow can be

swept from aircraft using brooms or brushes. Hot air blowers can also

be used to remove snow mechanically with forced air and to melt ice and

snow. In addition, some smaller aircraft are equipped with inflatable

pneumatic or hydraulic boots that can expand to break ice off the

leading edges of wings and elevators.

Mechanical snow removal methods (e.g., using nylon brooms and ropes

to remove snow from parked aircraft) are typically only used in the

early morning because they are time-intensive and labor-intensive, and

would be too disruptive to airline schedules during the day. Mechanical

methods are typically also used in conjunction with fluid application

and are dependent on climate and operational variables. Personnel must

be properly trained and provided with appropriate equipment so as not

to damage navigational equipment mounted on aircraft. Airlines

typically use brooms to remove as much snow and ice as possible before

applying conventional aircraft deicing fluids.

Other non-chemical deicing practices--infrared heating, forced air

and hot air systems--are being used at several airports throughout the

U.S. These technologies are described in Section VII.B.3, Pollution

Prevention Technologies.

2. Airfield Pavement Deicing

Pavement snow removal and deicing/anti-icing removes or prevents

the accumulation of frost, snow, or ice on runways, taxiways, aprons,

gates, and ramps. A combination of mechanical methods and chemical

deicing/anti-icing agents is used for pavement deicing at airports.

Runway deicing/anti-icing is typically performed by airport personnel

or a contractor hired by the authority. Some ramp, apron, gate, and

taxiway deicing/anti-icing may be performed by other entities, such as

airlines and FBOs that operate on those areas. Pavement deicing

typically occurs during the same season as aircraft deicing, but may be

shorter or longer than the aircraft deicing season.

a

way deicing/anti-icing is typically performed by airport personnel

or a contractor hired by the authority. Some ramp, apron, gate, and

taxiway deicing/anti-icing may be performed by other entities, such as

airlines and FBOs that operate on those areas. Pavement deicing

typically occurs during the same season as aircraft deicing, but may be

shorter or longer than the aircraft deicing season.

a. Mechanical Methods

Mechanical methods, such as plows, brushes, blowers, and shovels

for snow removal, are the most common form of runway deicing, and may

be used in combination with chemical methods. Airports generally own

multiple pieces of snow removal equipment and have employees trained to

operate them. Sand may be used to increase the friction of icy paved

areas. Because winter storm events can be unpredictable, personnel

trained in pavement deicing/anti-icing may be available at an airport

24 hours a day during the winter season.

b. Chemical Methods

Because ice, sleet, and snow may be difficult to remove by

mechanical methods alone, most airports use a combination of mechanical

methods and chemical deicing agents. Common pavement deicing and anti-

icing agents include potassium acetate, sodium acetate, urea, ethylene

glycol-based fluids, propylene glycol-based fluids, and sodium formate.

Road salt (i.e., sodium chloride or potassium chloride) may be used to

deice/anti-ice paved areas that are not used by aircraft (e.g.,

automobile roadways and parking areas) but are not considered suitable

for deicing/anti-icing taxiways, runways, aprons, and ramps because of

their corrosive effects on aircraft.

Many airports perform deicing of heavy accumulations of snow and

ice using mechanical equipment followed by chemical applications.

Pavement anti-icing may be performed based on predicted weather

conditions and pavement temperature. Deicing and anti-icing solutions

are applied using either truck-mounted spray equipment or manual

methods.

3. Estimates of Deicing Activity

a

effects on aircraft.

Many airports perform deicing of heavy accumulations of snow and

ice using mechanical equipment followed by chemical applications.

Pavement anti-icing may be performed based on predicted weather

conditions and pavement temperature. Deicing and anti-icing solutions

are applied using either truck-mounted spray equipment or manual

methods.

3. Estimates of Deicing Activity

a. Aircraft Deicing Chemical Usage

Airlines use approximately 25 million gallons of ADF annually,

consisting of 22.1 million gallons of propylene glycol-based deicers

and almost 3 million gallons of ethylene glycol-based deicers. EPA

estimates that approximately 320 primary airports conduct deicing

operations annually and that approximately 85 percent of this ADF (21.6

million gallons) is used at 110 of the 320 airports.

b. Airfield Pavement Deicing Chemical Usage

Primary airports use approximately 71 million pounds of chemical

deicers on airfield pavement (runways, taxiways and ramps) annually.

The six most frequently used deicers, with estimated percentages by

weight, are as follows: potassium acetate (63 percent); urea (12

percent); propylene glycol-based fluids (11 percent); sodium acetate (9

percent);

sodium formate (3 percent); and ethylene glycol-based fluids (2

percent).

VI. Summary of Data Collection

A. Previous EPA Data Collection Activities

1. 1993 Screener Questionnaire

In 1992, EPA began developing effluent guidelines and standards for

the Transportation Equipment Cleaning (TEC) category (40 CFR Part 442).

The scope of the TEC regulation at that time included facilities that

clean the interiors of tank trucks, rail tank cars, and tank barges;

facilities that clean aircraft exteriors; and facilities that deice/

anti-ice aircraft and/or airport pavement. Initial data collection

efforts for this project related to airport deicing operations included

development and administration of a ``screener'' questionnaire that was

administered in 1993

included facilities that

clean the interiors of tank trucks, rail tank cars, and tank barges;

facilities that clean aircraft exteriors; and facilities that deice/

anti-ice aircraft and/or airport pavement. Initial data collection

efforts for this project related to airport deicing operations included

development and administration of a ``screener'' questionnaire that was

administered in 1993. The screener questionnaire was developed, in

part, to enable EPA to: (1) Identify facilities that perform TEC

aircraft operations; (2) evaluate facilities based on wastewater,

economic, and operational characteristics; and (3) develop technical

and economic profiles of the industry. Subsequent to distribution of

the screener questionnaire, EPA decided not to include the aircraft

segment as part of the TEC effluent guidelines that were promulgated in

2000 (65 FR 49665, August 14, 2000). The Agency indicated that its

recently-issued stormwater regulations and permits under the NPDES

program imposed new requirements for airport discharges, and that

aircraft cleaning and airport deicing operations were significantly

different from other portions of the TEC category.

EPA mailed the screener questionnaire to 760 entities that

potentially perform aircraft exterior cleaning and/or aircraft or

pavement deicing/anti-icing operations. Following the screener

questionnaire mail-out and analyses of responses, EPA estimated that,

in 1993, there were 588 entities (i.e., airlines and FBOs) that perform

deicing/anti-icing operations.

2. 1998-99 Preliminary Data Summary

EPA conducted a study of airport deicing practices in 1998-99 and

published a report in 2000. (Preliminary Data Summary: Airport Deicing

Operations (Revised), Document No. 821-R-00-016, August 2000). The

study described deicing operations in the industry, wastewater

characteristics and procedures for its collection and treatment. The

study was conducted to comply with CWA sec

ry Data Summary

EPA conducted a study of airport deicing practices in 1998-99 and

published a report in 2000. (Preliminary Data Summary: Airport Deicing

Operations (Revised), Document No. 821-R-00-016, August 2000). The

study described deicing operations in the industry, wastewater

characteristics and procedures for its collection and treatment. The

study was conducted to comply with CWA sec. 304(m), which requires the

Agency to publish a biennial Effluent Guidelines Plan, and a consent

decree in Natural Resources Defense Council and Public Citizen, Inc. v.

Browner (D.D.C. 89-2980, as modified February 4, 1997). As part of the

study, EPA distributed short questionnaires to several aviation

sectors, including those involved in deicing; conducted site visits to

airports; and conducted wastewater sampling episodes.

a. Questionnaires

In 1999, EPA sent questionnaires to airports, an airline industry

association, equipment vendors, and publicly owned treatment works

(POTW), and requested data about the 1998-99 deicing season. The

Airport Questionnaire was sent to nine airports and asked for

information on aircraft and airfield deicing activities; wastewater

handling and treatment; and airport structure, finances and operations.

A questionnaire requesting financial data was sent to an airline

industry association, which provided information about the deicing

operations of 12 of its members, and eight regional airlines also

received questionnaires. The Vendor Questionnaire was sent to nine

businesses and requested information about equipment used to collect,

control, recycle/recover, treat or reduce the generation of glycol-

contaminated wastewater from aircraft and airfield deicing operations.

The POTW Questionnaire was sent to nine facilities and requested

information about potential pollutants in wastewater discharges from

airports, and the potential environmental impacts stemming from POTWs'

acceptance of these wastes.

b

ment used to collect,

control, recycle/recover, treat or reduce the generation of glycol-

contaminated wastewater from aircraft and airfield deicing operations.

The POTW Questionnaire was sent to nine facilities and requested

information about potential pollutants in wastewater discharges from

airports, and the potential environmental impacts stemming from POTWs'

acceptance of these wastes.

b. Wastewater Sampling

EPA conducted six sampling episodes for the study. Two of these

episodes obtained data on ADF, and four episodes obtained data on ADF-

contaminated wastewater and final effluent data from airports with

various collection and treatment systems.

c. Airport Site Visits

EPA visited 16 airports between 1997 and 1999 (including one visit

before the formal commencement of the study). Information gathered

included deicing operations, names and quantities of deicing chemical

products used, wastewater characterization, treatment technologies and

costs, and financial data. The Agency obtained effluent self-monitoring

data from some of the airports that were visited.

d. Other Data Sources

EPA collected data on NPDES permits and from the Toxic Release

Inventory database, which have wastewater discharge information. EPA

also collected data from state, local, and other federal agencies,

including the FAA, Department of Transportation and the United States

Geological Survey (USGS); and Canadian federal agencies involved with

airport environmental issues. These included interviews conducted

during site visits, airport effluent monitoring data, airline

operations data (i.e., departures and enplanement statistics), and

economic and financial information about the industry. All of the

collected data are available in the record for this proposed rule.

B. 2006-07 Industry Surveys

anadian federal agencies involved with

airport environmental issues. These included interviews conducted

during site visits, airport effluent monitoring data, airline

operations data (i.e., departures and enplanement statistics), and

economic and financial information about the industry. All of the

collected data are available in the record for this proposed rule.

B. 2006-07 Industry Surveys

For this proposed rule, EPA developed a series of survey

questionnaires to compile a complete profile of the industry with

regard to type and amounts of deicing chemicals used, collection

systems, and wastewater treatment systems. These questionnaires

expanded on the Agency's earlier survey efforts by the design of a

scientific national statistical sample of airports and development of a

reasonable national estimate of deicing activity by major airlines. A

comprehensive set of questions and data tables was also developed. In

designing the questionnaires, EPA consulted with airport and airline

industry representatives, including the American Association of Airport

Executives (AAAE), Airports Council International--North America (ACI-

NA) and the Air Transport Association (ATA). The Office of Management

and Budget (OMB) approved the questionnaires on January 13, 2006, and

EPA distributed the questionnaires during 2006 and 2007.

1. Airline Screener

EPA designed a short ``screener'' questionnaire to obtain basic

information from air carriers on which organizations actually performed

deicing services for a particular carrier, at specified airport

locations (i.e., the airline conducted its own deicing, it contracted

with another airline, or it used an FBO). EPA used the results of this

questionnaire to select respondents for the Detailed Airline

Questionnaire. The screener was distributed to 72 airlines and

requested information on deicing activities at 149 airports. EPA

distributed the screener to the industry in April 2006.

2

irport

locations (i.e., the airline conducted its own deicing, it contracted

with another airline, or it used an FBO). EPA used the results of this

questionnaire to select respondents for the Detailed Airline

Questionnaire. The screener was distributed to 72 airlines and

requested information on deicing activities at 149 airports. EPA

distributed the screener to the industry in April 2006.

2. Airport Questionnaire

EPA designed the Airport Deicing Questionnaire to serve as the

Agency's primary data source for airport-specific

information. The questionnaire requested information on a number of

topics including, general airport information, deicing operations,

deicing stormwater collection and conveyance, deicing stormwater

treatment, sampling data, pollution prevention, receiving waters, and

airport financial information.

EPA distributed the Airport Deicing Questionnaire to the industry

in April 2006. The questionnaire was sent to 153 airports, including a

census of all large and medium hub airports, as well as a sample survey

of all Small and Non-Hub Airports. (General aviation airports were not

included in the survey, except for a few with large cargo operations,

because these airports are used mainly by small private airplanes that

typically do not fly during icing conditions, and therefore are sites

where little or no ADF use occurs.)

3. Detailed Airline Questionnaire

EPA designed the Detailed Airline Questionnaire in order to learn

more about the airlines' role in deicing operations, as well as to get

information that is more precise on ADF usage. This questionnaire was

EPA's primary data source for airline-specific information. The

questionnaire asked questions on topics including deicing operations,

ADF purchase and usage, pollution prevention practices, and operational

costs. The questionnaire was sent in March 2007 to 58 air carriers,

covering deicing operations at 57 airports

to get

information that is more precise on ADF usage. This questionnaire was

EPA's primary data source for airline-specific information. The

questionnaire asked questions on topics including deicing operations,

ADF purchase and usage, pollution prevention practices, and operational

costs. The questionnaire was sent in March 2007 to 58 air carriers,

covering deicing operations at 57 airports. This questionnaire

requested information on a number of topics including: General airline

information, airline deicing practices, pollution prevention practices

and deicing costs.

C. Site Visits

In order to become familiar with the day-to-day operations at

airports, as well as learn some of the more site-specific issues that

arise with deicing, EPA conducted site visits at more than 20 airports.

EPA visited airports that had specific treatment technologies in place,

in order to learn more about these technologies. Some of the airports

included were Denver, Pittsburgh and General Mitchell (Milwaukee). All

site visits were documented with Site Visit Reports (SVRs), which are

in the record for today's proposed rule (Record Index, Section 2.3).

D. Wastewater Sampling Episodes

EPA collected several wastewater samples for chemical analysis

during sampling episodes at six airports to characterize pollutants

found in ADF-contaminated runoff, and to assess the performance of

treatment systems. The Agency conducted episodes at these six airports

in 2005 and 2006: Minneapolis/St. Paul International Airport, Detroit

Metropolitan Wayne County International Airport, Albany International

Airport, Denver International Airport, Greater Rockford (Illinois)

Airport, and Pittsburgh International Airport. At the first two

airports, EPA conducted one-day sampling episodes, to provide a general

characterization of wastewater from deicing operations. The subsequent

four events were multiple-day performance sampling episodes, which were

designed to document the performance of wastewater treatment systems

ernational Airport, Greater Rockford (Illinois)

Airport, and Pittsburgh International Airport. At the first two

airports, EPA conducted one-day sampling episodes, to provide a general

characterization of wastewater from deicing operations. The subsequent

four events were multiple-day performance sampling episodes, which were

designed to document the performance of wastewater treatment systems.

For each analytical chemical class or parameter, EPA collected 24-

hour composite samples when possible, in order to capture the

variability in the waste streams containing ADF generated throughout

the day. EPA used the data from the laboratory analyses of these

samples to develop a list of pollutants of concern, and characterize

the raw wastewater at airports. EPA used the data collected from the

influent, intermediate, and effluent points to analyze the efficacy of

treatment at the facilities, and to develop current discharge

concentrations, loadings, and the treatment technology options for the

Airport Deicing effluent guideline. EPA used effluent data, along with

data provided by industry in the questionnaires and other sources, to

calculate the long-term averages and limitations for each of the

proposed regulatory options. During each sampling episode, EPA

collected flow rate data corresponding to each sample collected and

production information from each associated production system for use

in calculating pollutant loadings. EPA has included in the public

record all information collected for which a facility has not asserted

a claim of Confidential Business Information (CBI) or which would

indirectly reveal information claimed to be CBI.

After conducting the sampling episodes, EPA prepared sampling

episode reports for each facility. These reports included descriptions

of the wastewater treatment processes, sampling procedures, and

analytical results. EPA documented all data collected during sampling

episodes in the sampling episode report for each sampled site

) or which would

indirectly reveal information claimed to be CBI.

After conducting the sampling episodes, EPA prepared sampling

episode reports for each facility. These reports included descriptions

of the wastewater treatment processes, sampling procedures, and

analytical results. EPA documented all data collected during sampling

episodes in the sampling episode report for each sampled site. Non-

confidential business information from these reports is available in

the public record for this proposal. For detailed information on

sampling and preservation procedures, analytical methods, and quality

assurance/quality control procedures see the Quality Assurance Project

Plans and the Sampling and Analysis Plans (Record Index, Section 2.4).

E. Other Data Collection

EPA collected other information from various other data sources

including: National Pollutant Discharge Elimination System (NPDES)

permits for information on current permit requirements; industry

correspondence on technology costs and long-term wastewater monitoring

data; and searches of technical and scientific literature, covering

current deicing practices and treatment technologies, current airport

deicing runoff data, chemical information and environmental impact

studies, and current stormwater regulations in the United States and

other countries.

F. Summary of Public Participation

EPA has met or corresponded with many airport and airline

representatives, citizen and environmental groups, vendors of deicing

chemicals and equipment, state permit agencies, other Federal agencies

and engineering consulting firms. The Agency has attended conferences

on airport deicing and has given presentations at several of those

conferences. Correspondence from these organizations about the proposed

rule is in the Record for the proposed rule.

VII. Technology Options, Costs, Wastewater Characteristics, and

Pollutant Reductions

A. Wastewater Sources and Wastewater Characteristics

s

and engineering consulting firms. The Agency has attended conferences

on airport deicing and has given presentations at several of those

conferences. Correspondence from these organizations about the proposed

rule is in the Record for the proposed rule.

VII. Technology Options, Costs, Wastewater Characteristics, and

Pollutant Reductions

A. Wastewater Sources and Wastewater Characteristics

1. Aircraft Deicing

Most ADF is applied to aircraft through pressurized spraying

systems, mounted either on trucks that move around an aircraft, or on

large fixed boom devices located at a pad dedicated to deicing.

Airlines typically purchase ADF in concentrated form (normalized) and

dilute it with water prior to spraying.

Most of the aircraft deicing fluid is Type I fluid, which is not

designed to adhere to aircraft surfaces. Consequently the majority of

Type I ADF is available for discharge due to dripping, overspraying,

tires rolling through or sprayed with fluid, and shearing during

takeoff. Once the ADF has reached the ground, it will then mix with

precipitation, as well as other chemicals found on airport pavements.

(These chemicals typically include aircraft fuel, lubricants and

solvents, and metals from aircraft, ground support and utility

vehicles.) Water containing these substances enters an airport's storm

drain system. At many airports, the

storm drains discharge directly to waters of the United States with no

treatment.

Type IV fluid, an anti-icing chemical, is designed to adhere to the

aircraft. Because of this adherence characteristic, EPA estimated that

the majority of Type IV fluid is not available for discharge.

For the purposes of this proposed rule, the pollutant loadings are

discussed in terms of applied ADF and how much of that is expected to

be discharged. A more detailed discussion of loadings estimates is

presented later in this section

designed to adhere to the

aircraft. Because of this adherence characteristic, EPA estimated that

the majority of Type IV fluid is not available for discharge.

For the purposes of this proposed rule, the pollutant loadings are

discussed in terms of applied ADF and how much of that is expected to

be discharged. A more detailed discussion of loadings estimates is

presented later in this section. Given the highly variable nature of

storm events, it is difficult to estimate flows or concentrations of

ADF-contaminated stormwater generated at an airport. Those factors are

greatly dependent on the size of the storm event associated with the

discharge, drainage characteristics, ADF collection systems (if

present), and airport operations. Additionally, due to the design of

drainage systems at some airports, their discharges may occur well

after a storm event has completed.

2. Airfield Pavement Deicing

Most solid airfield deicing chemical products are composed of an

active deicing ingredient (e.g., potassium acetate, sodium acetate) and

a small amount of additives (e.g., corrosion inhibitors). Liquid

airfield deicing chemical products are composed of an active ingredient

(e.g., potassium acetate, propylene glycol), water, and minimal

additives. The airfield deicing products that include salts (i.e.,

potassium acetate, sodium acetate, and sodium formate) will all ionize

in water, creating positive salt ions (K\+\, Na\+\), BOD5

and COD load as the acetate or formate ion degrades into carbon dioxide

(CO2) and water. Pavement deicers containing urea will

degrade to ammonia, and generate BOD5 and COD load as well.

Most of EPA's sampling data does not include airfield pavement

deicers. However, EPA collected samples from a few locations at Detroit

Metro Airport that contain airfield deicing stormwater. Large hub

airports, both Detroit Metro and Pittsburgh, provided sampling data

associated with stormwater contaminated by airfield pavement deicers

grade to ammonia, and generate BOD5 and COD load as well.

Most of EPA's sampling data does not include airfield pavement

deicers. However, EPA collected samples from a few locations at Detroit

Metro Airport that contain airfield deicing stormwater. Large hub

airports, both Detroit Metro and Pittsburgh, provided sampling data

associated with stormwater contaminated by airfield pavement deicers.

More information on these sampling activities is provided in the TDD.

As with the aircraft deicers, the variablity of storm events and

drainage systems make it difficult to estimate flows or concentrations

of pavement deicing waste streams generated at an airport.

B. Control and Treatment Technologies in the Aviation Industry

The ADF application process has presented a challenge for airports

attempting to manage their contaminated stormwater streams. The

airlines' process of applying ADF to aircraft through high pressure

spraying, combined with their typical practices of spraying the

aircraft outdoors in multiple, large unconfined (but usually

designated) spaces, results in pollutants being dispersed over a wide

area and entering storm drains at multiple locations. This process

contrasts sharply with many other industries where pollutants are

generated in confined areas, managed through a piping system, and not

commingled with precipitation.

EPA has identified several technologies that are available to

collect and manage portions of the ADF wastestream. Some of these

collection technologies are more effective than others; however, EPA

has not identified any single technology that is capable of collecting

all applied ADF. Typically, ADF that is not captured becomes available

for discharge, either through an airport's drainage system, or from

shearing off the aircraft during takeoff.

Once the ADF wastestream is collected, it can be treated, and this

process is similar to many other industries that generate wastewater.

EPA identified four technologies available for treating ADF wastewater

cting

all applied ADF. Typically, ADF that is not captured becomes available

for discharge, either through an airport's drainage system, or from

shearing off the aircraft during takeoff.

Once the ADF wastestream is collected, it can be treated, and this

process is similar to many other industries that generate wastewater.

EPA identified four technologies available for treating ADF wastewater.

EPA also examined pollution prevention technologies, which can

reduce or eliminate use of ADF chemicals and urea for pavement deicing.

1. Aircraft Deicing Fluid Collection Technologies

a. Glycol Recovery Vehicle

A glycol recovery vehicle (GRV) is a truck that utilizes a vacuum

mechanism to gather stormwater contaminated with ADF resulting from

deicing operations. A GRV is a modular technology, in that collection

capacity can be increased by using additional units, without the

complicating factors of in-ground construction associated with some

other technologies. An airport may increase its overall ADF collection

capacity by purchasing or leasing larger units and/or additional units.

GRV trucks are typically stationed near the ADF spraying trucks and

are deployed either during aircraft deicing activities or, after the

aircraft deicing activity has completed. The truck then transports the

ADF-contaminated stormwater to an on-site storage facility, after which

the material is either treated at the airport or sent off site for

treatment. EPA estimates that GRVs typically capture approximately 20

percent of the available ADF when properly operated and maintained.

b. Plug and Pump

The plug-and-pump collection system involves simple alterations to

an airport's existing storm drain system, typically the insertion of

blocking plugs or similar devices in storm drains, combined with use of

GRVs, to contain and collect ADF-contaminated stormwater

that GRVs typically capture approximately 20

percent of the available ADF when properly operated and maintained.

b. Plug and Pump

The plug-and-pump collection system involves simple alterations to

an airport's existing storm drain system, typically the insertion of

blocking plugs or similar devices in storm drains, combined with use of

GRVs, to contain and collect ADF-contaminated stormwater. Drainage

system modifications involve the placement of temporary blocking

devices at storm drain inlets, and/or installation of shutoff valves at

one or more points in the storm sewer system. Before a deicing event

begins, airport personnel activate the blocking devices, which trap the

ADF-contaminated stormwater in the collection system. After the deicing

activity ceases, the vacuum trucks pump the contaminated stormwater

from the storm sewer system and transport the liquid to on-site storage

and subsequent treatment. EPA estimates that plug-and-pump systems,

which incorporate GRVs, may capture approximately 40 percent of the

available ADF when properly operated and maintained.

c. Centralized Deicing Pads

A centralized deicing pad is a facility on an airfield built

specifically for aircraft deicing operations. It is typically a paved

area adjacent to a gate area, taxiway, or runway, and constructed with

a drainage system separate from the airport's main storm drain system.

It is usually constructed of concrete with sealed joints to prevent the

loss of sprayed ADF through the joints. The pad's collection system is

typically connected to a wastewater storage facility, which then may

send the wastewater to an on-site or off-site treatment facility.

Some airports use GRVs in combination with centralized deicing pads

in order to maximize collection and containment of ADF-contaminated

stormwater

oncrete with sealed joints to prevent the

loss of sprayed ADF through the joints. The pad's collection system is

typically connected to a wastewater storage facility, which then may

send the wastewater to an on-site or off-site treatment facility.

Some airports use GRVs in combination with centralized deicing pads

in order to maximize collection and containment of ADF-contaminated

stormwater. Airports typically locate the pads near the gate areas or

at the threshold of a runway to minimize delays in aircraft takeoff and

to enhance the effectiveness of the ADF applied by limiting time

between application and takeoff.

Centralized deicing pads reduce the volume of deicing wastewater by

restricting deicing to very small areas, and managing the captured

wastewater through a dedicated drain system. EPA estimates that central

deicing pads allow airports to capture about 60 percent of the

available ADF.

In addition, although the name implies a small collection area,

central pads designed to accommodate more than one commercial aircraft

generally encompass several acres. A deicing pad is specially graded

and designed to capture highly contaminated runoff, which can then be

sent to storage ponds, tanks or directly to treatment. By capturing

high concentrations of spent ADF, the feasibility of recycling

increases. Recovered glycol is typically sold to chemical manufacturers

for use in a variety of products, including coatings, paints, plastics

and polyester fibers.

d. Summary of ADF Collection Technology Usage

EPA estimates the number of airports that use each of the above

collection technologies in Table VII-1. Some airports use more than one

technology, and some of the airports in the estimate use the technology

for only a portion of their ADF-contaminated stormwater.

in a variety of products, including coatings, paints, plastics

and polyester fibers.

d. Summary of ADF Collection Technology Usage

EPA estimates the number of airports that use each of the above

collection technologies in Table VII-1. Some airports use more than one

technology, and some of the airports in the estimate use the technology

for only a portion of their ADF-contaminated stormwater.

Table VII-1--Estimated Totals of ADF Collection Technologies Used by

Airports

------------------------------------------------------------------------

Number of

Collection technology airports

------------------------------------------------------------------------

Glycol Recovery Vehicle.................................... 53

Plug and Pump.............................................. 29

Centralized Deicing Pad.................................... 66

------------------------------------------------------------------------

See the Technical Development Document for further explanation of

EPA's estimates of the ADF capture rates for the fluid collection

technologies.

2. Wastewater Treatment and Recycling Technologies

EPA identified four potential BAT wastewater technologies. Two of

these technologies are biological in that they use microorganisms to

break down the glycol. The other two technologies are mechanical and

produce two wastestreams, one a high concentrated glycol stream, and

one that is primarily water for discharge. The high glycol stream can,

in some instances, be recycled and used for a variety of products.

There have been limited instances in the U.S. of recycled glycol used

for ADF formulation.

a. Anaerobic Fluidized Bed

An Anaerobic Fluidized Bed (AFB) treatment system uses a vertical,

cylindrical tank in which the ADF-contaminated stormwater is pumped

upwards through a bed of granular activated carbon at a velocity

sufficient to fluidize, or suspend, the media

sed for a variety of products.

There have been limited instances in the U.S. of recycled glycol used

for ADF formulation.

a. Anaerobic Fluidized Bed

An Anaerobic Fluidized Bed (AFB) treatment system uses a vertical,

cylindrical tank in which the ADF-contaminated stormwater is pumped

upwards through a bed of granular activated carbon at a velocity

sufficient to fluidize, or suspend, the media. A thin film of

microorganisms grows on and coats each granular activated carbon

particle, providing a vast surface area for biological growth. These

microorganisms provide treatment of the ADF-contaminated stormwater.

Byproducts from the AFB treatment system include methane, carbon

dioxide and new biomass (animal material, e.g. bacteria).

Treating wastes using an anaerobic biological system as compared to

an aerobic system offers several advantages. The anaerobic system

requires much less energy since aeration is not required and the

anaerobic system produces less than 10 percent of the sludge of an

aerobic process. In addition, because the biological process is

contained in a sealed reactor, odors are eliminated. Based on EPA

sampling results, the AFB treatment system successfully removed over 98

percent of BOD5, over 97 percent of COD, and over 99 percent

of propylene glycol from the wastestream. This reduced the

BOD5 and COD loads discharged to receiving waters by over 98

and 97 percent, respectively. Two airports in the United States use the

AFB technology: Albany County Airport in Albany, New York, and Akron-

Canton Regional Airport, Akron, Ohio.

b. Ultrafiltration/Reverse Osmosis

Ultrafiltration/Reverse Osmosis (UF/RO) technology filters ADF-

contaminated stormwater at a high temperature (75 [deg]C) using an

ultrafiltration membrane as its first stage. Next, the deicing fluid

(filtrate) can be dewatered using a reverse osmosis membrane as a

second stage. Since the ultrafiltration membrane is effective at

removing contaminants, the RO stage is used for dewatering and glycol

separation

Reverse Osmosis (UF/RO) technology filters ADF-

contaminated stormwater at a high temperature (75 [deg]C) using an

ultrafiltration membrane as its first stage. Next, the deicing fluid

(filtrate) can be dewatered using a reverse osmosis membrane as a

second stage. Since the ultrafiltration membrane is effective at

removing contaminants, the RO stage is used for dewatering and glycol

separation. This process produces a glycol-laden stream that can be

distilled in an additional stage to increase its glycol concentration.

Concentrated glycol streams can be recycled as a feedstock in chemical

manufacturing. The effluent from the UF/RO system contains small

amounts of glycol, carbonaceous BOD (cBOD) and COD, and can either be

discharged to surface water, or sent to a POTW for further treatment.

Based on EPA sampling results, the RO treatment system successfully

removed over 99 percent of BOD5, over 99 percent of COD, and

over 99 percent of propylene glycol. UF/RO technology is used at

Pittsburgh International Airport.

c. Mechanical Vapor Recompression and Distillation

Mechanical Vapor Recompression (MVR) followed by distillation is

typically used when glycol concentrations in ADF-contaminated

stormwater are greater than 5 percent. This type of a system is not

generally practical for lower concentration glycol contaminated

stormwater, which would typically be discharged directly to a POTW for

treatment. The MVR/distillation technology generates a concentrated

glycol stream (containing greater than 99 percent glycol) that can be

sold as a chemical feedstock. The effluent from the MVR/distillation

system contains propylene glycol, cBOD and COD and it must be

discharged to a POTW for further treatment.

MVR and distillation is used at Denver International Airport for

recycle and recovery of spent ADF. The system first treats ADF-

contaminated stormwater using the MVRs, which increase the glycol

concentration to approximately 40 percent

al feedstock. The effluent from the MVR/distillation

system contains propylene glycol, cBOD and COD and it must be

discharged to a POTW for further treatment.

MVR and distillation is used at Denver International Airport for

recycle and recovery of spent ADF. The system first treats ADF-

contaminated stormwater using the MVRs, which increase the glycol

concentration to approximately 40 percent. Effluent from the MVRs is

then treated by distillation to increase the glycol concentration to

approximately 99 percent. The glycol product is passed through

polishing filters to remove residual contaminants allowing for resale

of the product as a chemical feedstock. Overheads (distillate) from

both the MVRs and distillation columns contain propylene glycol and

they are sent to a POTW for additional treatment.

Based on EPA sampling results, the MVR/Distillation treatment

system successfully removed over 93 percent of BOD5, over 97

percent of COD, and over 98 percent of propylene glycol.

d. Aerated Pond

An aerated pond uses mechanical aerators either to inject air into

the wastewater or to cause violent agitation of wastewater and air in

order to achieve oxygen transfer to the wastewater. Bacteria are

suspended in the wastewater, and aid in the biodegradation of glycol.

Contaminated stormwater is retained in the detention pond during the

deicing season and discharged later, after microorganisms present in

the pond have biodegraded the glycols. The detention pond is monitored

and nutrients are added, pH is adjusted, and anti-foaming agents are

added as needed. The biodegradation of glycol is temperature-dependant

and predominantly occurs during the spring and early summer months when

ambient temperatures are higher. When the BOD5 concentration

has been sufficiently reduced, the volume is discharged to surface

waters.

Based on EPA sampling results, the aerated pond treatment system

successfully removed 100 percent of BOD5, and over 93

percent of COD. An aerated pond system is currently in use

pendant

and predominantly occurs during the spring and early summer months when

ambient temperatures are higher. When the BOD5 concentration

has been sufficiently reduced, the volume is discharged to surface

waters.

Based on EPA sampling results, the aerated pond treatment system

successfully removed 100 percent of BOD5, and over 93

percent of COD. An aerated pond system is currently in use

at Greater Rockford Airport, in Rockford, Illinois.

3. Pollution Prevention Technologies

EPA has identified several technologies that reduce ADF usage to

some extent while safely deicing aircraft, and one applicable to

airfield pavement deicing, that are in use at airports across the

United States. However, there are limited data on the actual pollutant

reductions that these technologies may achieve. While the effectiveness

or cost-effectiveness of these technologies has not been documented,

these technologies can reduce the amount of deicing chemicals required

to deicing aircraft and airfields. The reduction of chemicals will not

only have a positive environmental effect, but may also be cost-

effective, as the decrease in costs of purchased deicing chemicals may

offset the cost of the technology itself.

a. Infrared Deicing Systems

A few U.S. airports have used infrared (IR) heating systems for

several years. The systems have been demonstrated to deice aircraft

effectively, which substantially reduces ADF usage. One type of IR

system consists of an open-ended hangar-type structure with IR

generators mounted inside, suspended from the ceiling. The IR equipment

is designed to use specific wavelengths that heat ice and snow, and

minimize heating of aircraft components. The IR energy level and

wavelength may be adjusted to suit the type of aircraft. Although the

system can deice an aircraft, it cannot provide aircraft with anti-

icing protection. Consequently, when the ambient temperature is below

freezing, anti-icing fluid is typically applied to the aircraft after

it leaves the hangar

ths that heat ice and snow, and

minimize heating of aircraft components. The IR energy level and

wavelength may be adjusted to suit the type of aircraft. Although the

system can deice an aircraft, it cannot provide aircraft with anti-

icing protection. Consequently, when the ambient temperature is below

freezing, anti-icing fluid is typically applied to the aircraft after

it leaves the hangar. Since the aircraft surfaces are dry, the volume

of anti-icing fluid required is less than for typical anti-icing

operations. In addition, a small amount of deicing fluid may be

required for deicing areas of the aircraft not reached by the IR

radiation, such as the flap tracks and elevators. The system,

therefore, does not completely replace glycol-based fluids, but greatly

reduces the volume required.

Documents provided by a vendor describe use of an IR system that

reduces the amount of Type I ADF required by up to 90 percent. Two

large hub airports, Newark Liberty International, Newark, New Jersey,

and John F. Kennedy International Airport, New York, use IR systems for

some of their flights. If this technology can be applied widely, it may

prove to be a highly effective means of reducing ADF pollution.

EPA has not obtained substantial data documenting the amount of

reduced glycol usage from use of IR systems, nor information on the

availability of the technology for broader or industry-wide

installation. EPA is interested in receiving any available data on

those topics to documenting IR costs including (e.g., the capital costs

of installing an IR facility, operating and maintenance costs,

especially energy costs, glycol used during deicing and siting/sizing

requirements for an IR facility). Because IR is not widely available or

used, EPA does not propose to identify IR as an available technology

for purposes of establishing ELGs. However, the Agency may reconsider

this technology, if sufficient data support a conclusion that this

technology is available

and maintenance costs,

especially energy costs, glycol used during deicing and siting/sizing

requirements for an IR facility). Because IR is not widely available or

used, EPA does not propose to identify IR as an available technology

for purposes of establishing ELGs. However, the Agency may reconsider

this technology, if sufficient data support a conclusion that this

technology is available. Specifically, EPA would require information

proving that IR is an available technology for a sufficient percentage

of an airports total deicing activity, as well as information on the

amount of time required for deicing, as well as any sizing and siting

requirements for placing an IR facility.

b. Forced Air/Hot Air Deicing Systems

Forced air/hot air deicing systems are currently in operation at a

few U.S. airports. These systems use forced air to blow snow and ice

from aircraft surfaces. Some systems allow deicing fluids to be added

to the forced air stream at different flow settings (e.g., 9 and 20

gpm), while other systems require separate application of deicing

fluid. Several vendors are currently developing self-contained, truck-

mounted versions of these forced-air systems, and most systems can be

retrofitted onto existing deicing trucks.

A similar method to truck-mounted forced-air systems is the double

gantry forced-air spray system. The gantries support a set of high- and

low-pressure nozzles, which blast the aircraft surfaces with heated air

at a pressure of 40 to 500 pounds per square inch. When weather

conditions are severe, a small volume of water and glycol may be added

to the air stream to remove dense coverings of snow and ice. Airfield

use of the gantry system has been limited perhaps because it is a

permanently mounted system that has been known to cause delays in

aircraft departures.

c. Product Substitution

Another solution to environmental problems associated with deicing

chemicals is to replace chemical deicers with more environment-friendly

products

to the air stream to remove dense coverings of snow and ice. Airfield

use of the gantry system has been limited perhaps because it is a

permanently mounted system that has been known to cause delays in

aircraft departures.

c. Product Substitution

Another solution to environmental problems associated with deicing

chemicals is to replace chemical deicers with more environment-friendly

products. In the ADF products category, initially the predominant

deicers were based on ethylene glycol, whereas in recent years

propylene glycol-based deicers, which are less toxic to mammals, have

become more widely used. Chemical manufacturers, the aviation industry

and the U.S. Air Force are continuing to explore development of deicers

that could generate lower levels of pollutants compared to the glycol-

based products.

In the field of airfield pavement deicers, several types of

products are available as alternatives to glycol-based and urea-based

deicers, such as potassium acetate, sodium formate and sodium acetate.

d. Transportation Research Board Report

The Transportation Research Board (TRB), a division of the National

Academies of Science, established a research panel to develop fact

sheets on deicing practices to assist airports in reducing their

deicing chemical usage and discharges. A report was prepared in 2009

under TRB's Airport Cooperative Research Program (ACRP), titled

``Deicing Planning Guidelines and Practices for Stormwater Management

Systems.'' This report (DCN AD01191) and the fact sheets (DCN AD01192)

are in the docket for today's proposed rule.

C. Pollutants of Concern

ing practices to assist airports in reducing their

deicing chemical usage and discharges. A report was prepared in 2009

under TRB's Airport Cooperative Research Program (ACRP), titled

``Deicing Planning Guidelines and Practices for Stormwater Management

Systems.'' This report (DCN AD01191) and the fact sheets (DCN AD01192)

are in the docket for today's proposed rule.

C. Pollutants of Concern

Airport deicing stormwater is generated when airfield and aircraft

deicing/anti-icing chemicals mix with snow, freezing precipitation or

rainwater. In addition, other airport-related activities, including

aircraft fueling and maintenance activities, may contribute pollutants

to stormwater. Because of the difficulties in characterizing airport

deicing stormwater, EPA evaluated pollutants detected in the

stormwater, pollutants present in source water (i.e., prior to

contamination with ADF), and pollutants that are present in ADF prior

to use to determine which pollutants are present in deicing stormwater.

The primary source of information used to identify potential pollutants

of concern from deicing stormwater was EPA's sampling episodes,

detailed in Section VI, as well as information presented in available

NPDES permits and the Airport Questionnaire.

1. Aircraft Deicers

EPA, through its review of sampling data, discussions with experts

in the field of chemical deicers, and review of NPDES permits,

identified over 90 pollutants associated with ADF-contaminated

stormwater.

EPA shortened the list of pollutants to those that were directly

associated with aircraft deicing. This was done by reviewing

information provided by

ort Questionnaire.

1. Aircraft Deicers

EPA, through its review of sampling data, discussions with experts

in the field of chemical deicers, and review of NPDES permits,

identified over 90 pollutants associated with ADF-contaminated

stormwater.

EPA shortened the list of pollutants to those that were directly

associated with aircraft deicing. This was done by reviewing

information provided by

experts and excluding pollutants that were thought to be associated

with one of the following sources; source water, aircraft and vehicle

fueling operations, maintenance-related operations, or runoff from

building roofs.

Having identified pollutants that are present in airport deicing

stormwater, the Agency next needed to consider which pollutants should

be controlled. EPA did not consider a pollutant as a potential

pollutant of concern if it possesses the following characteristics:

The pollutant is present in the deicing stormwater from a

source other than deicing chemical use;

The pollutant is discharged in relatively small amounts

and is neither causing nor likely to cause toxic effects;

The pollutant is detected in the effluent from only a

small number of airports and is uniquely related to those facilities;

or

The pollutant cannot be analyzed by EPA-approved or other

established methods.

2. Airfield Deicers

While field information on the constituents of airfield deicing and

anti-icing chemicals is scarce, EPA determined which chemicals are

commonly used based on the Airport Questionnaire responses. EPA did not

identify an available technology to collect and treat pavement deicing

pollutants, and therefore did not collect wastewater samples from

pavement deicing discharges. Some of the most common airfield deicing

and anti-icing chemicals include potassium acetate, sodium acetate,

urea, sodium formate, and glycols.

3. Summary

After reviewing these criteria, EPA identified 21 chemicals or

parameters as pollutants of concern

hnology to collect and treat pavement deicing

pollutants, and therefore did not collect wastewater samples from

pavement deicing discharges. Some of the most common airfield deicing

and anti-icing chemicals include potassium acetate, sodium acetate,

urea, sodium formate, and glycols.

3. Summary

After reviewing these criteria, EPA identified 21 chemicals or

parameters as pollutants of concern. Based on our knowledge of usage

volumes, and known effects, EPA focused on the glycols in ADF fluids,

and the ammonia in urea-based pavement deicers. Section VII.D.2 below

discusses how EPA determined which of these pollutants of concern

should become regulated pollutants in today's proposed rule. See the

TDD and the EIB for further discussion of pollutants of concern.

D. Options Considered for Proposal

Current airport deicing operations involve application of chemicals

to both aircraft and airfield pavement. ADF may be dispersed over a

large area due to the high-pressure spraying process used with aircraft

as well as shearing during aircraft taxiing and takeoff. Pavement

chemicals, while not sprayed at high pressure, are nonetheless

similarly dispersed over a large area, namely runways, taxiways and

aprons. The deicing chemicals mix with stormwater and are conveyed

through a combination of overland flow and conveyance structures

(ditches and pipes). At some airports, the contaminated stormwater is

discharged untreated directly to waters of the United States. At other

airports, the wastewater is treated before discharge, sent to a POTW or

off-site waste contractor, and/or discharged to groundwater.

In order to reduce discharges of untreated ADF wastewater for this

industry, EPA concluded that the best available technology would need

to include two basic components. The first component is a requirement

to capture (collect) a certain percentage of available ADF. The second

component is a requirement to treat the collected ADF to meet specified

end-of-pipe discharge limitations

oundwater.

In order to reduce discharges of untreated ADF wastewater for this

industry, EPA concluded that the best available technology would need

to include two basic components. The first component is a requirement

to capture (collect) a certain percentage of available ADF. The second

component is a requirement to treat the collected ADF to meet specified

end-of-pipe discharge limitations. In many other industrial sectors,

wastewater is typically generated and handled in confined systems such

as reactors, pipes and pumps. Wastewater flows are carefully managed in

these systems, and under normal operations all wastewater is directed

to the facility's treatment system or to a POTW. In aircraft deicing

operations, the chemicals are sprayed outdoors in a comparatively

unconfined, usually designated setting, and there is a high likelihood

that some pollutants will bypass the treatment system. Setting a

minimum collection rate in the proposed rule, based on available

technology, will require an airport to reduce significantly its level

of uncontrolled discharges in an economically achievable manner.

1. Regulated Facilities

Early in the regulatory development process, EPA focused on deicing

activities at primary airports, particularly those with extensive jet

traffic. Operators of general aviation aircraft, as well as smaller

commercial non-jet aircraft, typically suspend flights during icing

conditions, whereas commercial airlines operating at primary airports

are much more likely to deice their jets in order to meet customer

demands.

Based on the survey results, EPA estimated that 320 primary

commercial airports conduct deicing operations. Any effluent guidelines

that EPA might develop for these airports must be ``economically

achievable'' as required by the CWA, so the Agency proceeded to analyze

various industry characteristics that would be an indicator of

affordability for the candidate control and treatment technologies

ed on the survey results, EPA estimated that 320 primary

commercial airports conduct deicing operations. Any effluent guidelines

that EPA might develop for these airports must be ``economically

achievable'' as required by the CWA, so the Agency proceeded to analyze

various industry characteristics that would be an indicator of

affordability for the candidate control and treatment technologies.

This included a review of the relative sizes of various airports (based

on annual departures), the levels of deicing activity, traffic

characteristics (i.e., passenger vs. cargo operations), the extent of

pollution controls and treatment in place, and the costs of various

technologies. EPA further classified airports based on the number of

annual jet departures. EPA found that there were some primary airports,

typically smaller airports, with high percentages of non-jet traffic,

and so it excluded airports with 1,000 or fewer annual jet departures

from the scope of the proposed rule. These airports have a higher

proportion of propeller-aircraft flights, which are typically delayed

or cancelled during icing conditions (i.e., far less deicing takes

place at these airports, and far less deicing fluid is used, than at

airports serving more jets). The Agency estimated that the remaining

218 largest primary airports account for approximately 85 percent of

the deicing fluid used nationally, and including these airports in the

scope of today's proposed rule is economically achievable. Moreover,

not applying the 1,000 annual jet departure cutoff would only increase

the volume of deicing fluid that is within the scope of today's

proposed rule by 1 to 2 percent yet would potentially result in high

costs to smaller airports that have minimal pollutant contributions.

Accordingly, it is appropriate to establish this exclusion because it

avoids projected significant adverse economic impacts on this segment

of the industry without excluding from the national standards a

significant pollutant load.

2

n the scope of today's

proposed rule by 1 to 2 percent yet would potentially result in high

costs to smaller airports that have minimal pollutant contributions.

Accordingly, it is appropriate to establish this exclusion because it

avoids projected significant adverse economic impacts on this segment

of the industry without excluding from the national standards a

significant pollutant load.

2. Regulated Pollutants

As described in Section VII.C, EPA identified 21 pollutants of

concern that stem directly from airport deicing operations. EPA

estimates, however, that many of these pollutants, such as metals, are

generally present in airport stormwater discharges irrespective of

deicing activities that are taking place. These pollutants would be

also present in discharges at airports where no deicing takes place and

as such are beyond the scope of today's proposed rule.

EPA determined that pollutants directly associated with aircraft

deicing chemicals could be associated with an indicator pollutant.

Initially, both COD and BOD5 were identified as possible

indicator parameters. The Agency determined that COD is the best

indicator for the following reasons:

COD captures the oxygen demand from nitrogen and other

organic components of the contaminated

stormwater that may not be represented in a BOD5 analytical

result.

Toxic aircraft deicing fluid additive compounds in deicing

stormwater may have a negative and variable impact on the acclimation

of the active cultures used in BOD5 analysis, making that

method less accurate than a COD analysis.

COD analyses are simple to conduct and can be measured in

real time, compared to the 5-day test required by the BOD5

analytical method.

The COD analytical method does not require measurement of

the receiving water temperature.

Further discussion of analytical methods is provided in a memorandum,

``Regulation of COD for Airport Deicing Operations'' (DCN AD00845) in

the docket for today's proposed rule.

s are simple to conduct and can be measured in

real time, compared to the 5-day test required by the BOD5

analytical method.

The COD analytical method does not require measurement of

the receiving water temperature.

Further discussion of analytical methods is provided in a memorandum,

``Regulation of COD for Airport Deicing Operations'' (DCN AD00845) in

the docket for today's proposed rule.

While EPA has an understanding generally of ADF composition--i.e.,

each product is a glycol-based compound with several additives--deicing

fluid manufacturers did not provide us with information on specific ADF

formulations. These manufacturers declined several requests to provide

information on formulations, citing concerns about confidential

business information. EPA has learned about a number of the additives,

but not necessarily their concentration, from other sources. Because of

incomplete information on these ADF additives, EPA is not proposing

numeric effluent limits for any of these additives.

Ammonia is the principal pollutant generated by urea-based pavement

deicers, and EPA determined that ammonia is an appropriate indicator

pollutant for urea-based airfield pavement deicers.

See the TDD and EIB for further information on regulated

pollutants.

3. Technology Options Considered for Basis of Regulation

The effluent limitations that EPA is proposing to establish today

are based on well-designed, well-operated collection and treatment

systems. Below is a summary of the technology basis for the proposed

limitations and the alternative options considered by the Agency. As is

the case for any effluent guideline containing numeric effluent

limitations, a facility would be able to use any combination of

wastewater treatment technologies and pollution prevention strategies

at the facility to meet effluent limitations.

a

eatment

systems. Below is a summary of the technology basis for the proposed

limitations and the alternative options considered by the Agency. As is

the case for any effluent guideline containing numeric effluent

limitations, a facility would be able to use any combination of

wastewater treatment technologies and pollution prevention strategies

at the facility to meet effluent limitations.

a. Subcategorization

EPA may divide a point source category into groupings called

``subcategories'' to provide a method for addressing variations among

products, processes, and other factors, which result in distinctly

different effluent characteristics. See Texas Oil & Gas Ass'n. v. US

EPA, 161 F.3d 923, 939-40 (5th Cir. 1998). Regulation of a category by

subcategories provides that each subcategory has a uniform set of

effluent limitations that take into account technological achievability

and economic impacts unique to that subcategory. In some cases,

effluent limitations within a subcategory may be different based on

consideration of these same factors, which are identified in CWA

section 304(b)(2)(B). The CWA requires EPA, in developing effluent

guidelines, to consider a number of different factors, which are also

relevant for subcategorization. The CWA also authorizes EPA to take

into account other factors that the Agency deems appropriate.

In developing the proposed rule, EPA considered whether

subcategorizing the aviation industry was warranted. EPA evaluated a

number of factors and potential subcategorization approaches, including

the presence of an on-site glycol reclamation facility, amount of ADF

applied, number of departures, availability of land to install

collection systems, and FAA airport classifications

appropriate.

In developing the proposed rule, EPA considered whether

subcategorizing the aviation industry was warranted. EPA evaluated a

number of factors and potential subcategorization approaches, including

the presence of an on-site glycol reclamation facility, amount of ADF

applied, number of departures, availability of land to install

collection systems, and FAA airport classifications.

Establishing formal subcategories is not necessary for the Airport

Deicing category because the proposed rule is structured to address the

relevant factors (i.e., amount of ADF applied and number of departures)

and establish a set of requirements that encompasses the range of

situations that an airport may encounter during deicing operations.

Both the aircraft deicing and pavement deicing requirements include an

airport size threshold, which excludes smaller facilities. The use of a

performance standard, as compared to a technology specification,

provides flexibility for airports in meeting the requirements. EPA is

proposing to establish a set of effluent limitations that take into

account the factors that EPA determined are relevant for

subcategorizing this point source category.

b. Aircraft Deicing

EPA is proposing capture and treatment requirements for spent ADF.

EPA is not aware of an available and economically achievable technology

that is capable of capturing 100 percent of the spent ADF, and

therefore the Agency is focusing on collection technologies and their

efficacy.

i. ADF Collection

The available technologies for collecting ADF--glycol recovery

vehicles, plug-and-pump equipment, and deicing pads--are described

above. EPA evaluated various different combinations of these collection

technologies for different-sized airports. See Table VII-2. These

various options were developed to represent a wide range of collection

requirements and corresponding costs

i. ADF Collection

The available technologies for collecting ADF--glycol recovery

vehicles, plug-and-pump equipment, and deicing pads--are described

above. EPA evaluated various different combinations of these collection

technologies for different-sized airports. See Table VII-2. These

various options were developed to represent a wide range of collection

requirements and corresponding costs. EPA's objective was to find a

combination of requirements that would result in the greatest level of

pollutant removals while still being economically achievable.

Specifically, EPA finds that the number of aircraft departures is

an appropriate criterion for grouping airports by size and applying

different collection requirements to the various size groups. EPA's

review of airline and airport deicing practices revealed that the

amount of ADF required to deice a single aircraft varies widely. This

is primarily due to the type of weather conditions to which an aircraft

is exposed, or aircraft size. However, the Agency has concluded that an

airport's overall ADF usage level directly correlates to the amount of

wastewater generated and pollutant loadings. Because direct ADF usage

data were not available for every airport, EPA determined that the

annual number of aircraft departures at an airport, considered

simultaneously with precipitation data, is a reliable predictor of ADF

usage, based on extrapolations of data provided in the questionnaires.

Based on the available technologies, EPA developed four ADF

collection options as listed in Table VII-2 below as candidates for

identification as best available technology for the collection of ADF.

umber of aircraft departures at an airport, considered

simultaneously with precipitation data, is a reliable predictor of ADF

usage, based on extrapolations of data provided in the questionnaires.

Based on the available technologies, EPA developed four ADF

collection options as listed in Table VII-2 below as candidates for

identification as best available technology for the collection of ADF.

Table VII-2--ADF Collection Technology Options Considered for BAT

------------------------------------------------------------------------

Requirement (applies

to primary airports Estimated

Option with more than 1,000 airports in Technology basis

annual jet departures) scope

------------------------------------------------------------------------

1........... 20% ADF Capture 110............. Glycol recovery

(Airports w/10,000 or vehicle (GRV).

more annual

departures).

2........... 40% ADF Capture 110............. Plug & Pump.

(Airports w/10,000 or

more annual

departures).

3........... 60% ADF Capture 110 (14 @ 60% + Centralized

(Airports w/460,000 96 @ 20%). Deicing Pad +

gals. or more annual GRV.

ADF usage and 10,000

or more departures) +

20% ADF Capture

(Airports w/10,000 or

more annual

departures and less

than 460,000 gals.

annual ADF usage).

4........... 60% ADF Capture 218 (14 @ 60% + Centralized

(Airports w/460,000 204 @ 20%). Deicing Pad +

gals. or more ADF GRV.

usage) + 20% ADF

Capture (Airports w/

1,000 or more jet

departures).

------------------------------------------------------------------------

Note: All references to ADF are for normalized ADF, which is ADF less

any water added by the manufacturer or customer before ADF

application.

ADF Capture 218 (14 @ 60% + Centralized

(Airports w/460,000 204 @ 20%). Deicing Pad +

gals. or more ADF GRV.

usage) + 20% ADF

Capture (Airports w/

1,000 or more jet

departures).

------------------------------------------------------------------------

Note: All references to ADF are for normalized ADF, which is ADF less

any water added by the manufacturer or customer before ADF

application.

Not all airports estimated to be in the scope of this proposed rule

would incur ADF collection costs under it, because many of these

airports already have ADF collection systems in place (Section VIII.C

below). For example, of the estimated 14 airports that would have to

meet the 60 percent ADF collection requirement in this proposal, seven

already have installed deicing pads that would capture at least 60

percent of the ADF.

ii. Treatment

All airports subject to the ADF collection requirement would also

be required to treat their ADF wastewater prior to discharge, unless

they send this wastewater to a POTW or commercial treatment/recycle

facility. EPA examined the four wastewater treatment technologies

described above in Section VII.B.2 as candidates for the model BAT

technology.

Under this proposal, the collected ADF wastewater would need to be

treated to a specified numeric effluent limit for COD. This limit would

be based on the long-term averages of effluent from the treatment

system identified at BAT (see Section VII.E.2 below).

Further discussion of other ADF treatment technologies that EPA

considered can be found in the TDD.

c. Airfield Pavement Deicing

In general, airports discharge airfield pavement deicing chemicals

without treatment due to the difficulty and expense required in

collecting and treating the large volumes of contaminated stormwater

generated on paved airfield surfaces. EPA is not aware of an available,

economically achievable means for controlling these pollutants through

collection and use of a conventional, end-of-pipe treatment system

rports discharge airfield pavement deicing chemicals

without treatment due to the difficulty and expense required in

collecting and treating the large volumes of contaminated stormwater

generated on paved airfield surfaces. EPA is not aware of an available,

economically achievable means for controlling these pollutants through

collection and use of a conventional, end-of-pipe treatment system. It

may be possible, however, to reduce or eliminate certain pollutants by

modifying deicing practices, such as using alternative chemical deicing

products. In particular, EPA has identified ammonia as the primary

pollutant of concern from airfield deicing, while COD from airfield

deicing is also a pollutant of concern, and both of these pollutants

are a byproduct of urea-based pavement deicers.

Accordingly, to address discharges of ammonia from airfield

pavement, EPA identified one candidate for best available technology,

namely, discontinuing the use of urea-based pavement deicers and using

alternative pavement deicers instead. EPA researched product

substitution for urea-based deicers and found that airfield pavement

deicers other than urea are widely available in the market and that

these alternate deicers do not produce ammonia. Eighty-nine percent of

primary airports currently use airfield pavement deicers that do not

contain urea. The most widely used substitute product, potassium

acetate, accounts for 64 percent (by weight) of the annual airfield

pavement deicer usage in the U.S. Urea stood out as an airfield deicer

that was not predominantly used in the industry to begin with. Where it

is still used, one of the main reasons for its use appears to be low

cost compared to other products. Alternatives to urea are available

that are equally effective and safe, and would greatly reduce

discharges of ammonia from airfield deicing. These alternative airfield

deicers include potassium acetate, sodium formate and sodium acetate

dominantly used in the industry to begin with. Where it

is still used, one of the main reasons for its use appears to be low

cost compared to other products. Alternatives to urea are available

that are equally effective and safe, and would greatly reduce

discharges of ammonia from airfield deicing. These alternative airfield

deicers include potassium acetate, sodium formate and sodium acetate.

In suggesting these alternative deicers, EPA considered environmental

impacts and safety issues. The Agency solicits specific data on those

issues. EPA has also determined that the use of substitute airfield

deicers would be economically achievable in the industry (see Section

VIII below).

Discontinuing the use of urea-based deicers would greatly reduce

ammonia discharges from airfield runoff, but it would not eliminate

them entirely because of the background levels of ammonia present in

the general runoff from airfields. One method of ensuring that airports

discontinue use of urea-based airfield deicers is to require them to

certify that they use an alternative deicer. Alternatively, EPA could

set a numeric BAT limit on ammonia based on no use of urea that

accounts for the remaining sources of ammonia in airport discharges.

Product substitution would also result in significant reductions of COD

discharges. See the further discussion of this issue in the options

selection discussion in the next section below.

E. BAT Options Selection

an alternative deicer. Alternatively, EPA could

set a numeric BAT limit on ammonia based on no use of urea that

accounts for the remaining sources of ammonia in airport discharges.

Product substitution would also result in significant reductions of COD

discharges. See the further discussion of this issue in the options

selection discussion in the next section below.

E. BAT Options Selection

EPA is proposing to identify Best Available Technology Economically

Achievable based on Option 3 in Table VII-2. Specifically, this BAT

option has the following three components: collection of ADF sprayed

onto aircraft based on either GRV or deicing pads (depending on the

amount of ADF used), treatment of the collected ADF, if appropriate,

based on anaerobic fluidized bed technology, and certification of non-

urea-based airfield pavement deicing.

Under Option 3, all primary airports that have over 1,000 annual

jet departures and 10,000 or more annual departures would be required

to collect at least 20 percent of all available spent ADF. This

collection requirement is based on the estimated performance of glycol

recovery vehicles. A subset of this group, those primary airports that

have more than 1,000 annual jet departures, 10,000 or more annual

departures and use 460,000 or more gallons of normalized ADF annually,

would be required to collect at least 60 percent of all available spent

ADF. (As defined at proposed Sec. 449.2, normalized ADF is ADF less

any water added by the manufacturer or customer before ADF

application.) This collection requirement is based on the estimated

performance of centralized deicing pads, which are present at 8 of the

14

e 460,000 or more gallons of normalized ADF annually,

would be required to collect at least 60 percent of all available spent

ADF. (As defined at proposed Sec. 449.2, normalized ADF is ADF less

any water added by the manufacturer or customer before ADF

application.) This collection requirement is based on the estimated

performance of centralized deicing pads, which are present at 8 of the

14

primary airports currently meeting the departure/annualized ADF usage

criteria noted above. Primary airports with less than 10,000 annual

departures would not be required to collect or treat their spent

deicing fluid.

The proposed rule would reduce pollutant discharges by 44.6 million

pounds annually, comprised of 39.9 million pounds of COD (from both ADF

and urea reductions) and 4.7 million pounds of ammonia (from urea

alone). The proposed BAT requirements for ADF would reduce the aviation

industry's discharges of COD associated with ADF by 27.9 million pounds

per year. This represents almost a 22 percent reduction in discharges

of ADF-correlated COD relative to current practices used by airlines

and airports that conduct deicing. Additionally, the proposed BAT

requirements for airfield pavement deicing would reduce discharges of

COD (from urea deicers) by 12.7 million pounds per year, and reduce

discharges of ammonia by 4.7 million pounds per year.

EPA finds that the proposed BAT technologies are generally

available to be installed or used by those in the industry. Further, as

will be discussed in more detail in Section VIII below, EPA has

determined that the proposed BAT technologies are economically

achievable. The Agency also examined the non-water quality

environmental impacts of the rule and found them to be acceptable. The

technology basis for each requirement--ADF collection, treatment of the

collected ADF, and non-urea-based airfield pavement deicing--is

discussed below.

1

in more detail in Section VIII below, EPA has

determined that the proposed BAT technologies are economically

achievable. The Agency also examined the non-water quality

environmental impacts of the rule and found them to be acceptable. The

technology basis for each requirement--ADF collection, treatment of the

collected ADF, and non-urea-based airfield pavement deicing--is

discussed below.

1. ADF Collection

For each of the four options in Table VII-2, EPA finds that the

collection technology is widely available to the industry. See the

summary of collection technologies used by airports in Table VII-1. EPA

finds that for the top fourteen airports in terms of annual ADF usage,

collection of ADF based on the use of deicing pads is technologically

available. EPA's record indicates that at least seven of the fourteen

airports already have installed deicing pads. For the remaining seven,

EPA examined what appeared to be the most land-constrained airports and

using a formula based on number of departures and number of runways,

estimated the amount of land that would be required for installation of

deicing pads. EPA then reviewed airport site plans provided in the

questionnaires and determined that these constrained airports have

sufficient land to install the necessary collection technologies. See

the TDD for further discussion on the estimated land availability for

deicing pads. Therefore, the Agency determined that economic

achievability is the controlling factor in identifying which option

represents BAT for collection of ADF.

EPA rejected Option 2, Plug-and-Pump technology, as a basis for BAT

for ADF collection. Although Plug-and-Pump is estimated to capture 40

percent of spent ADF, as compared to the other options considered, the

equipment has comparatively high operating and maintenance costs

that economic

achievability is the controlling factor in identifying which option

represents BAT for collection of ADF.

EPA rejected Option 2, Plug-and-Pump technology, as a basis for BAT

for ADF collection. Although Plug-and-Pump is estimated to capture 40

percent of spent ADF, as compared to the other options considered, the

equipment has comparatively high operating and maintenance costs. In

many cases, EPA estimated that Plug-and-Pump costs would be higher than

the cost of deicing pads for a comparable airport, yet deicing pads

achieve greater pollutant removals than Plug-and-Pump. Overall, Option

2 achieves lower levels of pollutant removals, and it would impose

higher costs than Option 3. Therefore, EPA finds that Option 2 is not

the best available technology for ADF collection.

Of the remaining options, Options 1 and 3 are economically

achievable while Option 4 is not. Therefore, EPA proposes to identify

Option 3 as BAT because it achieves the greatest level of pollutant

removals among the remaining options and is economically achievable by

the industry. The 60 percent ADF capture and treatment standard for the

14 airports at which the largest ADF usage occurs is expected to result

in approximately a 70 percent increase in pollutant removals compared

to Option 1 (an increase from 26.4 million pounds to 44.6 million

pounds of COD and ammonia removals; see Section 13 of the TDD). Thus,

EPA projects that Option 3 will result in significantly greater

pollutant removals but little increase in the economic impacts of the

rule compared to Option 1. Under Option 3, only two additional airports

would incur costs beyond Option 1 that would exceed 3 percent of

operating revenue. These two airports are among the largest airports in

the U.S. and therefore have the greatest ability to take on these

additional costs without undue financial burden. See Section VIII below

for EPA's analysis of economic achievability

he

rule compared to Option 1. Under Option 3, only two additional airports

would incur costs beyond Option 1 that would exceed 3 percent of

operating revenue. These two airports are among the largest airports in

the U.S. and therefore have the greatest ability to take on these

additional costs without undue financial burden. See Section VIII below

for EPA's analysis of economic achievability.

Although EPA's analysis indicates that airports have sufficient

land to install deicing pads, the Agency invites commenters to provide

site-specific data and documentation on any space limitations that

would affect an airport's ability to install deicing pads, along with

recommendations for alternative ADF collection techniques if deicing

pads are not feasible.

EPA is also proposing to allow credit for facilities that might

adopt new technologies, such as infrared heating, that use less ADF,

but may not change the percent of ADF captured. See proposed Sec.

449.20(b)(2)(i)(C).

2. Treatment

The Agency proposes to identify Anaerobic Fluidized Bed (AFB) as

the best available treatment technology for reductions of COD. EPA

finds this technology to be widely available to the industry. It is

currently in use at two hub airports, Albany International (New York)

and Akron-Canton Regional (Ohio).

The other three wastewater treatment technologies that EPA

considered were less effective at pollutant removal compared to AFB

systems. In addition, treating spent ADF with the mechanical methods,

UF/RO and MVR/DC results in a concentrated waste stream that also must

be disposed of. While these technologies have potential as a part of an

airport's pollutant control strategy, they are not as effective as AFB

when used as stand-alone treatment options, i.e. the pollutant removals

they achieve are not as great as the removals achieved by AFB systems.

The second biological control option, the aerated pond, was not

selected as the technology basis for BAT for mainly logistical reasons

se technologies have potential as a part of an

airport's pollutant control strategy, they are not as effective as AFB

when used as stand-alone treatment options, i.e. the pollutant removals

they achieve are not as great as the removals achieved by AFB systems.

The second biological control option, the aerated pond, was not

selected as the technology basis for BAT for mainly logistical reasons.

The ponds require large areas for installation, and the normal

operations of these systems require treatment for many months after the

end of the annual deicing season, before the wastewater can be

discharged. Additionally, FAA discourages the installation of new

stormwater detention ponds at airports, as they can be a lure for

migratory birds. In those situations, birds and aircraft are safety

hazards to each other. For airports with existing detention ponds,

however, where adequate storage capacity is available, aerated pond

systems may be able to provide efficient treatment that meets the

standard.

EPA has determined that AFB, as the proposed best available

treatment technology for reductions of COD, will also achieve

significant reductions of many of the other known pollutants associated

with ADF, including 97 percent removal of propylene and ethylene

glycol. The AFB treatment system removes over 75 percent of many

phenol-ethoxylate compounds as well. Moreover, choosing to set a

numeric limit on COD provides an approach that is both effective and is

relatively easier and more inexpensive for airports to comply with than

a numeric limit on glycols, the active ingredient of aircraft deicing

fluids, would be. Monitoring costs for COD are modest relative to some

other parameters considered by EPA. Permittees may conduct

late compounds as well. Moreover, choosing to set a

numeric limit on COD provides an approach that is both effective and is

relatively easier and more inexpensive for airports to comply with than

a numeric limit on glycols, the active ingredient of aircraft deicing

fluids, would be. Monitoring costs for COD are modest relative to some

other parameters considered by EPA. Permittees may conduct

monitoring with the use of portable COD meters, which provide

immediate, real-time information on the efficacy of their treatment

systems and facilitate timely adjustments of system operation where

necessary. Overall, EPA's economic analysis shows that the use of AFB

technology for treating spent ADF would be economically achievable in

the industry. See Section VIII below for more information on economic

achievability.

3. Airfield Pavement Deicers

In addition to the requirements that EPA is proposing for ADF

sprayed onto airplanes, EPA is also proposing today to identify BAT for

the control of deicers that are applied directly to airfield pavement

areas. Specifically, as described in Section VIII.D.3, for airfield

pavement deicers, EPA is proposing to identify a BAT of discontinuing

use of urea-based pavement deicers in favor of alternative, less toxic

products that are not harmful to aircraft. Thus, BAT would be based on

product substitution rather than treatment of the wastestream that runs

off from airfield pavements. To demonstrate that they have used only

non-urea based pavement deicers, permittees would be required to submit

a certification to that effect.

EPA considered two possible methods for eliminating discharges of

ammonia associated with the application of urea-based pavement deicers.

One option would be to set a performance-based numeric limit on

discharges of ammonia that could be met by using non-urea-based

deicers. A second option would require airports to certify that they do

not use urea-based airfield deicing products

hat effect.

EPA considered two possible methods for eliminating discharges of

ammonia associated with the application of urea-based pavement deicers.

One option would be to set a performance-based numeric limit on

discharges of ammonia that could be met by using non-urea-based

deicers. A second option would require airports to certify that they do

not use urea-based airfield deicing products. EPA is proposing today to

adopt the certification option. EPA is proposing the certification

because it ensures compliance while minimizing compliance costs.

Certification allows a facility to demonstrate compliance with this

product substitution-based BAT without the expense of conducting

monitoring activities. Collecting and analyzing samples of airfield

runoff would also present significant practical difficulties. Measuring

ammonia discharges from airfield pavement is generally difficult due to

the design of airport drainage systems. Wastestreams from multiple

areas of an airport may be combined into a single pipe, which

complicates the calculation of pollutant concentrations. In addition,

the ``building block'' approach, which has been used to calculate

combined wastestream concentrations for other industrial categories, is

generally very difficult to perform at airports, due to the variability

and unpredictability of the volume of stormwater runoff. Therefore, as

a practical matter, a permittee who wanted to take samples and

demonstrate compliance with a numeric limit for ammonia would need to

show that the ammonia limit is met for all deicing runoff, not just

airfield discharges.

While EPA is proposing to identify product substitution as BAT, in

order to allow flexibility to regulated facilities, the Agency is also

proposing a compliance alternative to the certification requirement.

This provision would accommodate facilities that might wish to continue

using urea-based deicers and install treatment to eliminate urea-based

ammonia discharges instead

field discharges.

While EPA is proposing to identify product substitution as BAT, in

order to allow flexibility to regulated facilities, the Agency is also

proposing a compliance alternative to the certification requirement.

This provision would accommodate facilities that might wish to continue

using urea-based deicers and install treatment to eliminate urea-based

ammonia discharges instead. Facilities that elect to comply using the

compliance alternative would be required to monitor and comply with a

proposed ammonia limit. To establish the proposed compliance

alternative limitation for ammonia, the Agency had to take into account

the ammonia that is a by-product of an AFB wastewater treatment system.

This is because AFB discharges could have higher ammonia concentrations

than that of background levels found in airfield runoff. While this

results in a proposed compliance alternative ammonia effluent limit

higher than concentrations in airfield runoff where AFB technologies

are not used, the Agency estimates that these concentrations are lower

than those from airfield pavement discharges where urea-based deicers

are used. See ``Evaluation of Proposed Compliance Alternative Ammonia

Limitations with Respect to Airport Deicing Stormwater Typical Ammonia

Discharges,'' DCN AD01194, for additional discussion.

Although EPA has developed compliance alternative ammonia effluent

limitations for this proposal, it estimates that the cost associated

with capturing and treating these waste streams would be prohibitively

high for most airports. Therefore, EPA anticipates that most or all

airports would choose the certification option rather than the ammonia

numeric limits option in order to avoid compliance monitoring. EPA

requests comment on implementation challenges associated with and the

extent to which regulated facilities may select the compliance

alternative. To the extent that comments indicate the compliance

alternative would not be utilized, EPA might not include it in the

final rule.

e the certification option rather than the ammonia

numeric limits option in order to avoid compliance monitoring. EPA

requests comment on implementation challenges associated with and the

extent to which regulated facilities may select the compliance

alternative. To the extent that comments indicate the compliance

alternative would not be utilized, EPA might not include it in the

final rule.

F. NSPS

EPA evaluated which technologies should be identified as the ``best

available demonstrated control technologies'' for purposes of setting

new source performance standards under CWA section 306. Among the

collection technologies that EPA considered, deicing pads capture the

greatest level of available ADF and are widely available in the

industry. Among the treatment technologies considered, treatment of the

captured ADF with an anaerobic fluidized bed system represents the

greatest level of removals of the pollutants of concern and is widely

available for use in connection with new airports and new runways at

existing airports. In considering economic impacts, EPA believes that a

standard based on the use of deicing pads for ADF collection followed

by treatment with an AFB system would not represent a barrier to entry

for new sources in this industry. See the economic analysis discussion

in Section VIII. Accordingly, EPA proposes to base NSPS for aircraft

deicing on these technologies. As with the BAT requirement for existing

sources, the proposed NSPS would require dischargers to collect 60

percent of available spent ADF, and treat the collected wastewater to a

specified numeric limit for COD.

Additionally, EPA considered which technology should be considered

the basis for setting NSPS with respect to airfield deicing. EPA

determined that, just as with existing sources, all new sources would

be capable of eliminating the use of urea for airfield deicing in favor

of substitute deicing products

lable spent ADF, and treat the collected wastewater to a

specified numeric limit for COD.

Additionally, EPA considered which technology should be considered

the basis for setting NSPS with respect to airfield deicing. EPA

determined that, just as with existing sources, all new sources would

be capable of eliminating the use of urea for airfield deicing in favor

of substitute deicing products. Product substitution represents the

greatest level of reduction in ammonia among the available technologies

considered and product substitution does not appear to represent a

barrier to entry. See the economic analysis discussion in Section VIII.

Accordingly, EPA proposes to identify elimination of urea followed by

product substitution of non-urea-based airfield deicers as the best

demonstrated available control technology for purposes of all new

sources.

Based on this identified technology, all new sources would be

required to meet the same certification requirement proposed for BAT.

In addition, as proposed today for existing sources, EPA proposes the

same compliance alternative ammonia effluent limitations for new

sources.

For the purpose of this regulation, EPA proposes that a ``New

Source'' would include, first, a new airport. The cost of construction

of even small airports is significantly greater than the costs

associated with collection and/or treatment of spent deicing fluids.

Accordingly, meeting the new source requirements proposed today would

not be a barrier to entry for them

ations for new

sources.

For the purpose of this regulation, EPA proposes that a ``New

Source'' would include, first, a new airport. The cost of construction

of even small airports is significantly greater than the costs

associated with collection and/or treatment of spent deicing fluids.

Accordingly, meeting the new source requirements proposed today would

not be a barrier to entry for them

economically. See further discussion in Section VIII below.

In addition, EPA proposes to specify that a new runway at an

existing airport is also a new source. EPA anticipates that few new

airports will be constructed in the foreseeable future, and that most

of the anticipated increase in airport capacity will be accomplished

through the expansion of existing airports. The term ``new source'' is

defined in EPA regulations at 40 CFR 122.2 and 122.29. EPA proposes to

specify in the final rule that a new runway meets the terms of those

regulations for being defined as a new source, because in EPA's view a

new runway is a ``structure, facility or installation from which there

is or may be a discharge of pollutants'' (Sec. Sec. 122.2 and

122.29(a)(2)) and because a new runway is ``substantially independent

of an existing source at the same site'' (Sec. 122.29(b)(iii)). EPA

does not believe in general that new runways will be significantly

integrated with existing airport facilities in a way that should

prevent them from being identified as new sources (see Sec.

122.29(b)(iii)). In addition, it is possible that permit authorities,

on a case-by-case basis, would be able to deem other types of

construction activity for aircraft movement areas to constitute a new

source as well. For example, a permit authority might deem the

substantial improvement or replacement of an existing runway to be a

new source if that activity is deemed to ``totally replace the process

or production equipment that causes the discharge of pollutants'' (see

Sec. 122.29(b)(ii))

be able to deem other types of

construction activity for aircraft movement areas to constitute a new

source as well. For example, a permit authority might deem the

substantial improvement or replacement of an existing runway to be a

new source if that activity is deemed to ``totally replace the process

or production equipment that causes the discharge of pollutants'' (see

Sec. 122.29(b)(ii)). In all of the situations discussed above, the new

runway or other runway construction activity would be deemed to be a

new source only if it meets all of the criteria in the regulations

cited above for definition as a new source.

G. BPT and BCT

The CWA provides for two increasingly stringent levels of

technology-based controls on discharges of pollutants. See EPA v.

National Crushed Stone Association, 449 U.S. 64 (1980). BPT represents

the first level of control applicable to all pollutants. BCT and BAT

represent the second level of control for conventional and toxic/

nonconventional pollutants, respectively. EPA considered whether in

this rule, it was necessary to establish BPT and BCT limits, given that

ADF and pavement deicing fluid will be controlled at the more stringent

BAT level. Because the BAT controls in this rule also control the same

pollutants as would be controlled by BPT or BCT limits, it is not

necessary for EPA to analyze options and propose BPT and BCT effluent

limitation guidelines for the Airport Deicing Category. EPA recognizes

that it has proposed, in the past, all three levels of control, BPT,

BCT and BAT for various industries even where the same pollutants and

wastestream were at issue. In this rule however, the Agency solicits

comments on this approach because it represents significant resource

savings for EPA in terms of analysis and rulemaking process while not

sacrificing any environmental protection

gnizes

that it has proposed, in the past, all three levels of control, BPT,

BCT and BAT for various industries even where the same pollutants and

wastestream were at issue. In this rule however, the Agency solicits

comments on this approach because it represents significant resource

savings for EPA in terms of analysis and rulemaking process while not

sacrificing any environmental protection. Additionally, EPA is not

establishing BCT limitations for this industry because these

limitations apply only to conventional pollutants such as

BOD5 and total suspended solids and this effluent guideline

regulates only non-conventional pollutants (chiefly COD and ammonia).

H. Pretreatment Standards

Some airports in the U.S. discharge ADF-contaminated runoff to

POTWs. EPA does not have any information indicating that POTWs

currently have problems of pollutant pass-through, interference or

sludge contamination stemming from these discharges. For this reason,

the Agency is not proposing PSES or PSNS. EPA is aware that high

concentration or ``slug'' discharges of deicing wastewater can create

POTW upset, and many of the airports that discharge to POTWs have

airport-specific requirements on allowable BOD5 or COD

discharge loading per day. They may also have requirements for

discharging at various concentration levels over time. Airports usually

meet this requirement by storing deicing stormwater in ponds or tanks

and metering the discharge to meet the POTW permit requirements.

I. Compliance Costs

many of the airports that discharge to POTWs have

airport-specific requirements on allowable BOD5 or COD

discharge loading per day. They may also have requirements for

discharging at various concentration levels over time. Airports usually

meet this requirement by storing deicing stormwater in ponds or tanks

and metering the discharge to meet the POTW permit requirements.

I. Compliance Costs

1. Overview

EPA estimated industry-wide compliance costs for this proposed

rule. This section summarizes EPA's approach for estimating compliance

costs, while the TDD provides detailed information on these estimates.

All final cost estimates are expressed in terms of 2006 dollars and

represent the cost of purchasing and installing equipment and control

technologies, annual operating and maintenance costs, and associated

monitoring and reporting requirements.

EPA estimated compliance costs associated with today's proposal

using data collected through survey responses, site visits, sampling

episodes, specific airport requests and information supplied by

vendors. As applicable, EPA estimated the costs for an airport to

comply with today's proposal initially, as well as maintaining

equipment and performing required monitoring or other activities to

demonstrate ongoing compliance. These costs may include upgrading/

installing and operating a collection system and/or a treatment system,

chemical analysis for compliance as well as the costs associated with

substituting potassium acetate in place of urea as a chemical airfield

deicer. EPA's cost estimates represent the incremental costs for a

facility when its existing practices would not lead to compliance with

today's proposed rule.

EPA calculated costs based on a computerized design and cost model

developed for each of the technology options considered. EPA developed

facility-specific costs for each of the Airport industry questionnaire

respondents (149 facilities), where each facility was treated as a

``model'' airport

for a

facility when its existing practices would not lead to compliance with

today's proposed rule.

EPA calculated costs based on a computerized design and cost model

developed for each of the technology options considered. EPA developed

facility-specific costs for each of the Airport industry questionnaire

respondents (149 facilities), where each facility was treated as a

``model'' airport. Because the questionnaire respondents represent a

subset of the industry, EPA subsequently modeled the national

population by adjusting the costs upward to estimate the entire

affected airport population.

The questionnaire responses provided EPA with information on three

consecutive deicing seasons (2002-2005) for each of the model

facilities. Some portions of EPA's costing effort reflect the airports'

operations as reported for the three seasons. For example, estimates of

applied deicing chemicals were taken as an average of the years for

which the information was reported. In instances where aspects of an

airport's operation changed over the three-year period, EPA used the

most recent information. For example, if an airport installed a deicing

pad in 2005, EPA's costing estimates would reflect any incremental

changes required above the current ADF collection rate, to meet the

collection rate in the proposed rule.

2. Approach for Developing Aircraft Deicing Costs

Under this proposed rule, an airport would be required to collect a

percentage of its sprayed ADF, and treat that wastewater to comply with

numeric effluent limitations. EPA estimated the costs for an airport to

comply with collection and treatment requirements, as well as

performing required monitoring to demonstrate compliance. These costs

include estimates of upgrading airports' current collection systems,

installing the required technology to treat the wastewater, maintaining

equipment and conducting chemical analyses for compliance.

effluent limitations. EPA estimated the costs for an airport to

comply with collection and treatment requirements, as well as

performing required monitoring to demonstrate compliance. These costs

include estimates of upgrading airports' current collection systems,

installing the required technology to treat the wastewater, maintaining

equipment and conducting chemical analyses for compliance.

EPA first established existing conditions for each model airport

based on information and site plans submitted as part of the Airport

Questionnaire. EPA then determined what upgrades, if any, would be

required to comply with today's proposal. In general, when an airport

lacked a comparable collection system to the one used as the basis for

the options considered in today's proposal, EPA included costs for

installation/implementation of one of the following collection

technologies: GRVs, GRVs used in conjunction with plug-and-pump

systems, or deicing pads.

For estimating wastewater treatment costs, EPA assumed costs for

storage of anticipated volumes of collected ADF. Airport-specific costs

were assessed for storage options, including ponds, permanent tanks

(both underground and aboveground), or mobile/temporary fractional

distillation tanks.

EPA based its selection of a particular storage option on an

airport's current storage facilities, and on what would be the easiest

for that airport to implement. The Agency assumed that it is likely

that an airport with a pond already in place would use that for

storage, as opposed to constructing permanent tanks; and assumed that

an airport with limited available land would install an underground

tank.

Based on questionnaire responses and engineering judgment, EPA

assessed the current level of treatment for each model facility that

discharges directly to waters of the U.S

it is likely

that an airport with a pond already in place would use that for

storage, as opposed to constructing permanent tanks; and assumed that

an airport with limited available land would install an underground

tank.

Based on questionnaire responses and engineering judgment, EPA

assessed the current level of treatment for each model facility that

discharges directly to waters of the U.S. Except in limited

circumstances, when a model facility was determined to require

additional treatment, EPA assigned costs associated with installing an

AFB treatment system as the most likely means of compliance.

Of the direct discharging model facilities that were modeled for

treatment costs, EPA assumed that approximately five percent would use

off-site hauling for waste treatment, based on the Agency's estimate

that this percentage will find this choice to be the most cost-

effective alternative. These facilities have relatively limited deicing

operations and off-site hauling is more cost-effective than installing

an on-site biological treatment system. Additionally, an on-site

biological treatment system would require a regular wastestream flow in

order to keep the biological system functioning properly, and an

airport with limited deicing operations may have trouble maintaining a

regular wastestream.

EPA recognizes that an airport may decide to use a POTW rather than

directly discharging its wastewater. While this may be a lower cost

alternative in some cases, EPA did not estimate costs for such a

change, because the Agency does not have enough information about the

capacity of specific POTWs to receive these volumes of wastewater. EPA

also was not able to determine if a specific POTW would be unwilling to

accept the wastewater from a particular airport, and for other reasons,

such as inconsistencies with its future growth plans. For these

reasons, EPA did not include this alternative in its model

use the Agency does not have enough information about the

capacity of specific POTWs to receive these volumes of wastewater. EPA

also was not able to determine if a specific POTW would be unwilling to

accept the wastewater from a particular airport, and for other reasons,

such as inconsistencies with its future growth plans. For these

reasons, EPA did not include this alternative in its model.

An airport that has upgraded its collection and treatment systems

may have additional monitoring costs. While the permit authority

determines the required monitoring frequency for an individual

permittee, EPA estimated the overall costs of the anticipated

monitoring requirements associated with the proposed rule. EPA

estimated the cost per airport for the ADF collection requirement, and

the cost of analyzing COD in the treated effluent. For costing

purposes, EPA assumed that an airport would take a 24-hour composite

sample and analyze that for COD, and perform that analysis five times

per week throughout the deicing season. EPA made a similar assumption

for purposes of computing the proposed weekly average effluent

limitation. As a conservative estimate, EPA assumed a six-month deicing

season for all modeled facilities. Additionally, EPA assumed that the

model facility would perform an assessment of their collection system

once every permit cycle.

3. Approach for Estimating Airfield Pavement Deicing Costs

Under today's proposal, in addition to the requirements set forth

for capture/treatment of aircraft deicing fluid, an airport would be

required to certify it uses non-urea-based airfield deicers. Through

the results of the Airport Questionnaire, EPA learned that 29 model

facilities (a subset of the 149 model facilities referenced above) use

urea for airfield pavement deicing. As detailed in Section VII.D.3, EPA

based its certification requirement on product substitution

reatment of aircraft deicing fluid, an airport would be

required to certify it uses non-urea-based airfield deicers. Through

the results of the Airport Questionnaire, EPA learned that 29 model

facilities (a subset of the 149 model facilities referenced above) use

urea for airfield pavement deicing. As detailed in Section VII.D.3, EPA

based its certification requirement on product substitution. EPA

calculated the cost for these 29 model facilities to substitute the

urea used for deicing with another widely available pavement deicer

that does not produce ammonia in the wastewater. EPA chose to model the

substitution costs on what it would cost to switch to potassium

acetate, specifically because that product accounts for 64 percent of

the applied chemical airfield deicer usage (by weight) in the U.S.

EPA identified 16 airports that used both urea and potassium

acetate for airfield deicing, and 8 of these airports provided usage

data. The Agency calculated that the average cost of urea was $274.24/

ton and the average cost of potassium acetate was $3.16/gallon. The

questionnaire responses indicated that between 2002 and 2005 an average

of over 7 million pounds of urea were used annually, costing an

estimated $1.06 million.

Urea deicers are applied at a different rate to have an efficacy

equivalent to potassium acetate. EPA had to determine what amount of

potassium acetate would be required to replace the estimated 7 million

pounds of urea used annually. EPA could not locate any information on

the relative application rates between potassium acetate and urea

directly; however, we did develop a comparison to sodium acetate,

another solid pavement deicer. Both urea and potassium acetate

application rates vary depending on the weather conditions and the

thickness of the ice layer at the time of application

million

pounds of urea used annually. EPA could not locate any information on

the relative application rates between potassium acetate and urea

directly; however, we did develop a comparison to sodium acetate,

another solid pavement deicer. Both urea and potassium acetate

application rates vary depending on the weather conditions and the

thickness of the ice layer at the time of application. Using the

information available, EPA assessed comparable application rates and

costs between urea and potassium acetate to treat 1,000 ft \2\ of area

for thin ice conditions at 32 [deg]F and 1-inch-thick ice conditions at

less than 10 [deg]F. DCN AD00843 provides additional details about the

calculations on product substitution.

Using the reported urea usage in the Airport Questionnaire, EPA

estimated the airfield area that was annually deiced at each model

facility. Finally, using the estimated model facility airfield area in

conjunction with the estimated $2.32/1,000 ft\2\ cost of potassium

acetate, EPA was able to calculate the cost per model facility to

perform airfield deicing with potassium acetate. This cost was compared

to the questionnaire reported urea costs to determine the incremental

costs of switching chemical airfield deicers.

4. Calculation of National Costs

EPA categorized all of the costs as either capital costs (one-time

costs associated with planning or installation of technologies), or as

operations and maintenance (O&M) costs (costs that occur on a regular

ongoing basis such as monitoring or annual purchases of deicing

materials).

For each model facility, EPA calculated an annualized cost based on

the sum of all the associated O&M costs as well as amortized capital

costs. Capital costs were amortized over the lifespan of the capital

improvement, as reported by the facility. No capital costs were

amortized over more than 20 years, even if an estimated lifespan of an

airport exceeded 20 years. Finally, EPA

materials).

For each model facility, EPA calculated an annualized cost based on

the sum of all the associated O&M costs as well as amortized capital

costs. Capital costs were amortized over the lifespan of the capital

improvement, as reported by the facility. No capital costs were

amortized over more than 20 years, even if an estimated lifespan of an

airport exceeded 20 years. Finally, EPA

combined the amortized costs with the annual O&M to calculate the total

annual cost of the regulation for that model facility.

EPA then utilized statistical weights assigned to each of the 149

model facilities in order to calculate a national estimated cost of

$91.3 million for complying with the proposed rule. Further discussion

of all of the calculations discussed above can be found i

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