May 30, 2012
On May 16, 2012, the United States Environmental Protection Agency (EPA) issued the final rule for Effluent Limitation Guidelines and New Source Performance Standards for the Airport Deicing Category, effective June 15, 2012. The ruling was welcome news to airport industry leaders who were successful in their diligent efforts to persuade the EPA to consider the site-specific needs and individual operational and land constraints of the nation’s airports. This document is intended to provide a brief summary of the new regulations. For the entire text of the ruling in the Federal Register, fact sheet, background, and other related information, please visit the EPA website at http://water.epa.gov/scitech/wastetech/guide/airport/index.cfm.
Scope and Applicability
The new EPA regulations will affect deicing operations for both aircraft and airfield pavements. The effluent guidelines, while intended to reduce pollutants discharged to surface waters and publicly owned treatment works, do not set receiving water quality standards. Instead they are based on “best available technologies” (BAT) with regard to treatment and control of potential pollutants.
With regard to aircraft deicing operations, there are no uniform requirements for aircraft deicing fluid (ADF) discharges at existing airports mandated in this rule. Only new airports with 10,000 annual departures located in certain cold climate zones will be required to install BAT collection facilities for ADFs. In existing facilities, the National Pollution Discharge Elimination System (NPDES) permitting process for industrial storm water will continue to be the primary means to control ADF discharges on a site-specific basis.
The new ruling does, however, make an important change regarding airfield pavement deicing:
“Existing and new primary airports with 1,000 or more annual jet departures ("non-propeller aircraft") that generate wastewater associated with airfield pavement deicing are to use non-urea-containing deicers, or alternatively, meet a numeric effluent limitation for ammonia1.”
The EPA expects that most airports will choose product substitution to meet this requirement. For example, Cryotech E36®, liquid potassium acetate, Cryotech BX36®, liquid bio-based, and Cryotech NAAC®, solid sodium acetate, are certified pavement deicers that do not contain urea or other ammonia-producing compounds, and may safely be substituted. It will be extremely difficult for airports subject to this new rule to continue to use urea containing deicers. Regarding the alternative effluent limitation option:
“An airport that chooses this alternative is required to perform an analysis for ammonia in airfield pavement discharges at all locations where pavement deicing with deicers containing urea is occurring and must achieve the numeric limitations for ammonia prior to any dilution or commingling with other non-deicing discharges.”
The final ruling was very favorable to the aviation industry and reflected the EPA’s recognition of the voluntary commitment to pollution prevention already underway by the major airline and airport industry associations, A4A (formerly, ATA) and ACI-NA. It was noted that several major airports have voluntarily made great strides in pollution prevention, such as ADF collection technologies. Cryotech applauds these accomplishments and looks forward to working with customers in continued efforts to develop state-of-the-art, high-performance products that also protect the environment.
For further information, please contact us.
1 Ammonia is the principle pollutant generated by urea-based pavement deicers.