EPA Proposes Airport Deicing Effluent Guidelines

EPA Administrator signed a Notice on August 17, 2009, proposing Airport Deicing Effluent Guidelines. In that Notice, EPA is proposing “technology-based effluent standards for discharges from airport deicing operations.” Effluent guidelines and new source performance standards are technology-based regulations that are developed by EPA for a category of dischargers. In this case, the deicing effluent guidelines are based on the performance of control and treatment technologies.

In general, the regulations would apply to “wastewater associated with the deicing of aircraft and airfield pavement at primary commercial airports.”  (Although various industry groups have objected to using the term “wastewater” to describe the deicing effluent, since that is the term that the EPA uses in the proposed rule, that is the term used in this article).  The proposed regulations would affect airports that

  1. conduct aircraft deicing operations,
  2. have 1,000 or more annual jet departures, and
  3. 10,000 or more total annual departures.

Such airports would be required to collect spent aircraft deicing fluid (ADF) and treat the wastewater. They may either treat the wastewater on-site or send it to an off-site treatment contractor or publicly owned treatment works. Some airports would be required to reduce the amount of ammonia discharged from urea-based airfield pavement deicers or use more environmentally friendly airfield deicers that do not contain urea.

Summary of Proposed Airport Deicing Effluent Limitation Guidelines and Standards
Regulatory Level Technology Basis Technical Components
Airports >1,000 Annual Jet Departures and >=10,000 Annual Departures Airports >1,000 Annual Jet Departures and <10,000 Annual Departures
Best Available Technology Economically Achievable (BAT) 1. 60% or 20% Aircraft Deicing Fluid (ADF) capture
2. Biological treatment
3. Pavement deicer product substitution
1. Capture 60% of available ADF (for airports having >=460,00 gal. ADF usage) or capture 20% (for airports <460,000 gal. ADF usage)
2. Treat wastewater to meet effluent limit for chemical oxygen demand (COD)
3. Certify use of non-urea-based pavement deicers
or
Meet effluent limit for ammonia
1. Certify use of non-urea-based pavement deicers
or
Meet effluent limit for ammonia
New Source Performance Standards (NSPS) 1. 60% ADF capture
2. Biological treatment
3. Pavement deicer product substitution
1. Capture 60% of available ADF
2. Treat wastewater to meet effluent limit for chemical oxygen demand (COD)
3. Certify use of non-urea-based pavement deicers
or
Meet effluent limit for ammonia
1. Certify use of non-urea-based pavement deicers
or
Meet effluent limit for ammonia
Note: All references to ADF are for normalized ADF, which is ADF less any water added by the manufacturer or customer before ADF application

Although EPA Administrator signed the notice on August 17, 2009, it has not yet been published in the Federal Register.  The public comment period on the regulations will run for 120 days after publication in the Federal Register.

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