Effluent Guidelines for Airport Deicing Discharges

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1 Effluent Guidelines for Airport Deicing Discharges Airports Council International and Airlines for America s Deicing Management Conference May 23, 2012

2 ELG Background Effluent limitations guidelines and standards (ELGs) are national regulations that control the discharge of pollutants to surface waters and to publicly owned treatment works ELGs are based on the performance of treatment and control technologies Includes an assessment of economic achievability ELGs are implemented in discharge permits issued by states and EPA regional offices under the National Pollutant Discharge Elimination System May 23,

3 Deicing ELG Rulemaking History Data collection included extensive review of literature; questionnaires to both airports and airlines; 20 site visits, 6 wastewater sampling episodes Collaboration with industry and FAA What did we learn about deicing discharges? Two sources: aircraft deicing and airfield pavement deicing Discharges from deicing operations can have impacts on water quality such as reductions in dissolved oxygen, reduced organism abundance and species diversity, and contamination of drinking water sources What did we learn about airfield pavement deicing? Airports generally apply deicing chemicals to airfields and subsequently discharge airfield deicer contaminated stormwater without treatment We did not identify any currently used techniques to control airfield pavement discharges through collection and/or conventional, end-of-pipe treatment systems Primary pollutants are ammonia and COD These pollutants are a byproduct of pavement deicers containing urea Several alternative pavement deicers are used nationwide May 23,

4 Deicing ELG Rulemaking History (Cont.) What did we learn about aircraft deicing? In absence of controls, most sprayed aircraft deicing fluid (ADF) falls off the aircraft, commingles with stormwater, and enters into airport storm drains or drainage ditches and is discharged to surface waters Industry uses three technologies to collect sprayed ADF prior to entering storm drains: glycol collection vehicles (GCVs) can collect 20 percent of available ADF "plug and pump" techniques combined with use of GCVs can collect 40 percent of available ADF deicing pads can collect 60 percent of available ADF Once collected, some airports send the wastewater off-site to a POTW or a commercial treatment/recycling plant. Several airports use on-site treatment systems. Of the technologies identified, we identified anaerobic fluidized bed as the technology that has the greatest reduction in pollutants prior to surface water discharge Industry also employs several pollution prevention technologies that reduce ADF discharges Lack of available quantitative data on the actual pollutant reductions that these technologies may achieve Lack of data correlating minimized ADF application with safe deicing practices Based on the collected information, we published a proposed rulemaking in August

5 Proposed Airport Deicing Rule Proposal would have applied to deicing discharges at primary airports with 1,000 or more jet departures and would have required: Airfield pavement deicing: certification of non-urea containing pavement deicers or ammonia limit based on product substitution (new and existing sources) Aircraft deicing: ADF collection and COD discharge limit based on anaerobic biological treatment for discharges of collected ADF Largest ADF users with 10,000 or more departures and all new sources: 60% ADF collection based on centralized deicing pads Remainder of ADF users with 10,000 or more departures: 20% ADF collection based on glycol collection vehicles (GCVs) Airports with less than 10,000 departures: No ADF collection requirement Also requested comment on 40% ADF collection based on plug and pump with GCVs. New runways at existing airports are new sources Proposal would have reduced pollutant discharges by at least 44 million pounds annually with an associated cost of $92 million annually 1 5

6 Proposed Rulemaking Comments We received comments from airports, airlines, business associations, state agencies, citizen groups, a drinking water utility, the U.S. Geological Survey (USGS) and the FAA Primary concerns from industry comments: Multiple concerns about the proposed identification of deicing pads as BAT Deicing pads are not feasible at existing airports (space, safety, operational, flight delays, financial impact) Requirements for aircraft deicing discharges should continue to be established on a site specific basis as each airport is unique Applicability of aircraft deicing requirements is inappropriately based on departures ADF Collection and treatment technologies are infeasible for defrost deicing New runways are not new sources FAA comments: Requiring deicing pads at crowded northeast airports would be disruptive New runway should not be defined as a new source EPA should emphasize alternative technologies 6

7 What Did We Learn After the Proposal Comment Period? We continued to meet with stakeholders and the FAA following the comment period for the proposed rule Industry continued to express concerns related to feasibility, safety, operation, delays, and financial impact of collection and treatment as the basis for nationally applicable aircraft deicing discharge requirements at existing airports Including plug and pump and GCV technologies Industry stressed the achievements made in reducing ADF discharges in the past 5 years, particularly in the area of pollution credit and adopted a voluntary pollution reduction program that will reduce ADF discharges 7

8 Final Airport Deicing Rule We project the final rule with reduce pollutant discharges by at least 16 million pounds annually at an annual cost of about $3.5 million Applies to direct discharges of wastewater associated with deicing discharges at existing and new primary airports with 1,000 or more non-propeller aircraft departures Airfield pavement deicing discharge requirements (new and existing airports): Certify use of non-urea containing airfield deicers Or meet a numeric effluent limitations for ammonia as Nitrogen Daily max of 14.7 mg/l Aircraft deicing discharge requirements (existing airports): No nationally applicable requirements EPA determined that while ADF collection and treatment technologies may be feasible and economically achievable at existing airports, it can not make such a determination on a national basis Requirements will continue to be established by the permitting authority on a case by case basis using best professional judgement (BPJ) 8

9 Final Airport Deicing Rule (Continued) Aircraft deicing (new airports): National applicable requirements to new airports with 10,000 annual departures located in certain cold climate zones New runways are not new sources Climate zones added because EPA agrees that departures alone are not a good proxy for ADF usage Climate zone cut-off based on ADF usage at existing airports that perform deicing rather than defrost deicing New airports that meet the NSPS applicability are required to collect 60% of ADF Based on centralized deicing pads In consultation with FAA, EPA finds that the space, safety, operational, flight delays, and financial impact concerns that may apply to existing sources do not extend to new sources Various compliance alternatives that allow for credit for pollution prevention and approaches other than centralized deicing pads If collected ADF is discharged directly, must also meet numeric discharge requirements for COD based on anaerobic biological treatment Daily max of 271 mg/l Weekly average of 154 mg/l Sampling protocol for soluble COD 9

10 Voluntary Pollution Prevention Program We applaud all efforts to develop deicing chemicals and approaches that reduce ADF discharges We are aware that many airports successfully use pollution prevention to reduce ADF application (and ultimately discharge)while maintaining safety We fully support your voluntary pollution prevention program and believe it has the potential to significantly reduce aircraft deicing discharges safely and in a cost-effective manner We look forward to the new data that will be developed as part of your pollution prevention program Our expectation is that as pollution prevention continues to be implemented, we will be able to report that ADF discharges have decreased 10

11 Questions? 8/26/2011 EPA Internal/Deliberative 11