1 From: John Mee <jmee@inlandgroup.ca> To: Brian Damico/DC/USEPA/US@EPA Cc: msvedruzic@inlandgroup.ca, 'Roger Langille' <rlangille@inlandgroup.ca> Date: 03/29/2011 09:16 AM Subject: Inland comments

Dear Mr. Damico;

Further to your recent discussions with my colleague, Mike Svedruzic, please find attached Inland's comments. We hope you find these helpful in your analysis and we would be pl eased to answer any further questions you may have or to clarify any of our remarks in this submission.

Mike is travelling this week, so I'll invite you to contact myself or Roger Langille for any questions that come up this week. Once Mike is back next week he will also be available for any questions.

Thank You John

John Mee Senior Director, Business Development Inland Technologies 902-895-6346, ext 323 (See attached file: Inland T echnologies- EPA Information Mar 29 2011.docx)

Inland Technologies International Limited

Response to EPA Request for Additional Information Regarding “Plug and Pump” Technologies

Inland appreciates this opportunity to prov ide the EPA additional information regarding “Plug and Pump” technologies and active re covery operations.As a service provider whose core business is the collection, management and treatment of spent Aircraft Deicing Fluid (ADF) we will provide information and a perspective based on twenty years of experience. This includes expertise acquired from over twenty airports in North America with both the impl ementation and operation of both passive and active collection methodologies.

Understanding Active Glycol Recovery

When we are approached by new clients to im plement spent glycol recovery programs we understand that every airport is unique. We conduct a detailed on-site analysis and develop a program to meet specific needs. While the tools we employ to accomplish active recovery are similar from airport to airport the actual approa ch at each airport is customized based on individual requirements. A number of factors have to be evaluated and ultimately these influence the componen ts of the spent ADF management program.

Here are some of the issues we consider when developing the program:2 1. Defining the environmental objectives

 Are there prescribed regulatory wate r quality metrics to be adhered to?

o Defined as “end of pipe” discharge water quality?

o Defined as the capture of a tar get percentage of applied glycol?

 Will there be a Pilot program implem ented to determine feasible long-term requirements?

 What is the compliance timeframe to m eet overall program goals? Typically with each year of active recovery, colle ction rates improv e with operational experience.

 Are there specific short term objecti ves that graduate to achieve an overall milestone?3 2. Evaluate existing infrastructure, f light operations, weather patterns and deicing practices

 The timing and frequency of deicing, m agnitude of deicing events, flight schedules and number of locations where dei cing occurs will impact the amount and type of equipment and recovery methods used.

 Generally, existing infrastructure can be adapted to be suitable for recovery operations. At a minimum, this usually means installation of drain blocking devices.

 Are there inherent space and infrastructure limitations at the ai rport that must be considered when planning/designing new applications to handle deicing runoff?

 Both active and passive glycol recove ry methodologies may be able to be employed or only one may be feasible.

 Can recovery goals be achieved through on-gate deicing or must deicing take place at designated areas?

 Can strategic areas of the existing ta rmac be converted to deicing pads during winter weather events?

 Weather conditions affect the recovery rate of active collection operations. Climates where typical events include a hi gh percentage of freezing rain and wet snow will dictate different recovery ta ctics than areas where events are often characterized by dry snow. The same type of equipment can be used, but the operation of the equipment and the amount of equipment will be adjusted to the nature of the climate.

3. How quickly can a spent ADF coll ection and management program be implemented?

 Can any of the collection approaches be implemented quickly to achieve some measure of environm ental protection?

 Typically, block and pump recovery operations can be implemented much more quickly than the time it takes to c onstruct new containment systems and/or change permanent drainage infrastructure.

 This can give flexibility to airports to make long term capital improvements.4 4. Implement an effective collecti on and management program for ADF impacted storm water while minimi zing impact on airport operations.

 All airport stakeholders must under stand that the spent ADF collection program is as important as any other integral winter operation such as deicing and snow removal therefore it must be incorporated in to the overall operating plan.

 All airport stakeholders must work c ooperatively and coordinate to maximize efficiency.

5. How to maximize efficiency wh ile understanding potential limitations

 What limitations or restrictions may potentially affect collection objectives? Funding, budget implications, equipment availability, coordination and integration, etc.

 Who will actively manage the recovery program? Airport staf f, airlines, subcontracted services?

 Who will assume responsibility for performance?

 How will performance be measured?

 What will be the primary focus when co llecting? Glycol concentration, focus on largest deicing sprayer, allow collection in taxiways, etc.

 What percentage of glycol wi ll you collect down to bef ore the effort produces diminishing returns? The lower the conc entration of glycol in the spent ADF, the larger volume of water that will be collected. This has storage and treatment cost implications.

 Typically, with active collection t he more money spent on equipment, storage and overall effort the better the collection rate that can be achieved. There is a point however where regar dless of the money allocated towards a recovery program that there is poi nt where diminishing returns will occur due to inherent airport infrastructure limit ations and/or coordination issues

 All airport stakeholders must work c ooperatively and coordinate to maximize efficiency.5 Tools that are utilized as part of an Active Spent ADF Collection Program

The following will highlight key collection te chnologies that minimize infrastructure changes at airports:

a. Collection Vehicles

Glycol recovery vehicles and vacuum trucks are a primary component of any active spent ADF recovery program. These vehicles are utilized as described in Section VII, Section B 1 (a) and (b) of the EPA’s Proposed Rule for Effluent Limitation Guidelines and New Source Performanc e Standards for the Airport Deicing Category.

It is important to note, that both glycol recovery vehicles and vacuum trucks are currently in use at many airports in Nort h America and are an int egral part of deicing operations. These vehicles can be oper ated safely and do not impede airport or aircraft operations with proper coordinati on and training. In most cases these vehicles are essential for winter operat ions much the same as snow removal equipment and other deicing equipment. At airports where environmental compliancy related to glycol recovery is critical, airport st akeholders and tenants understand that glycol collecti on efforts must be integrated into the overall winter operations plan.

Typically the implementation of operations using these types of vehicles can occur quickly to provide an airport the immediate ability to capture contaminated storm water. The specialized recovery vehicles are manufactured by multiple vendors and typically can be delivered wit h three months lead time.

Both vacuum trucks and glycol recovery vehicles can be purchased, leased or provided as part of a service contract.

Glycol recovery vehicle collection operati ons virtually always combine the use of drain blocks as part of operations. Most Gl ycol Recovery Vehicle operations employ some sort of device in the storm sewer inlets to contain deicing runoff on the apron surface until it can be collected.

Glycol recovery units can be used for on- gate collection or at dedicated deicing areas. Vacuum trucks typically are not us ed for on-gate collection but can be used to recover from blocked sumps and drains associated with deicing operations.

Training, operations plans and safety are ab solutely crucial to employing use of vacuum trucks and glycol recovery vehicles at airports.6 In regards to references to the limitati ons of glycol recovery vehicles and the potential operational issues experienced during deicing prec ipitation events involving snow, these issues can be minimized. Collection of snow and slush in the vehicles can occur but it really is dependent on the snow removal operations. As much as practical, snow should be removed from deicing areas prior to deicing taking place and is an integral part of a well managed glycol containment and collection program. If the snow is removed prior to deicing on areas such as central deicing pads than snow collection in the glycol recovery vehi cles is minimized. If snow removal does not occur and snow is collected by the re covery vehicle then most machines are equipped with a “tilt and dump” feature whic h allows the operator to quickly evacuate the built up material in a designated “pink snow” dump area and return to collection operations. Operator training is also important in this process to avoid collecting excessive amounts of snow. Typically glycol impacted snow is collected and sent to a “pink snow” area by the snow removal co ntractors so the residual glycol can be
recovered as needed.

Glycol concentration ranges of influent can va ry greatly as the material is collected by glycol recovery vehicles .A range of 0.5 to 30 % concentration is not uncommon but many factors influence this. The type of deicing or storm event has a significant effect on glycol concentrations in recove red fluid along with many other variables .From our experience, with aggressive collection during snow precipitation deicing events we can collect fluid as high as 15 to 20% in glycol concentration assuming there is no significant waiting period for the vehicles to mo ve into the area and begin recovery operations. The highest glycol conc entration is seen from frost recovery but very small volumes are recovered. Duri ng mixed precipitation and freezing rain events it is not uncommon to collect spent ADF in concentrations from 1 to 6% glycol concentration since so much dilution is occurring with the runoff.

Based on our experience, by washing the pavement with clean water after initial glycol collection this can significantly enhance collection performance. Most glycol recovery vehicles are equipped with an onbo ard freshwater tank and spray heads to accomplish this process. This can only be accomplished when outside temperatures are above freezing and weather conditions a llow. In the past, chemical emulsifiers were commonly used in this process, but experience has shown that the emulsifier agents don’t really enhance co llection performance compared to clean water alone. Thus, they are no longer used.

The use of glycol recovery vehicle water spray systems can also reduce the costs of glycol treatment.By washing down glycol impacted pavement after deicing occurs, the glycol recovery vehicles can reclaim mo st of the residual glycol that would otherwise wash away with future precipitatio n events. For airports that have stringent guidelines for the release of storm water, by actively reclaiming this additional7 material this can reduce volumes of spent ADF to be treated to meet storm water
criteria.

Operation and maintenance costs for glycol recovery vehicles vary based on the frequency of use. This is related to the specific collection r equirements of each airport and the amount of deicing events which require the glycol recovery equipment to be operated.

Key questions to address when determining costs associated with Glycol Recovery
Vehicles:

 Are the glycol recovery vehicles the pr imary and only means of collection or are they used as a secondary method of reco very for frost or deicing pad operations?

 Where are the units being operated? For ex ample, cold dry c limate with typical deicing events consisting of dry snow, or northeast climate with frequent ice events and wet snow?

 What type of glycol collection vehicl e is being operated? Tow-behind unit or single chassis unit?

In general, the costs for repair and main tenance vary depending on the type of recovery vehicle. Based on our experienc e, the repair and maintenance costs (not including fuel and labor) per deicing season range from $3,000 to $10,000 per vehicle. Fuel costs can be calculated using the specifications provided by the vehicle manufacturer and is dependent on the frequ ency of use. Labor costs can be calculated on a case-by-case basis depending on a variety of airport specific factors including whether the operati on of the vehicle is performed by airport staff or
subcontracted to other vendors.

The typical lifespan of a Glycol Recovery V ehicle varies based on frequency of use and type of recovery. Key questions to address:

 Are the glycol recovery vehicles the pr imary and only means of collection or are they used as a secondary method of reco very for frost or deicing pad operations?

 Depending on the type of use, frequency of use and based on our experience, a glycol recovery vehicle’s lifespan can range from 8 to 15 years.8 b. “Plug and Pump” Technologies

Inland is currently managing glycol recovery programs at many airports in North America. Most of these ai rports employ some method of “plug and pump” or “block and pump” technologies for the recovery of glycol. This has proven to be a very effective approach in meeti ng environmental goals. Low cost drain blockers are installed with minimal effort at the begi nning of each season or permanently and can be used for the duration of the season with minimal effort to maintain and operate
the devices.

Ultimately, installation and use of these types of devices require minor infrastructure changes. The benefits of utilizing this tec hnology are that airports can quickly change and use the existing drainage infr astructure in the near term to accommodate deicing without major constructi on or capital projects. These devices
allow immediate containment while long term improvement projects such as the construction of deicing pads and other containment systems are being developed.

Drain blocking devices include drain inserts, drain plugs, and drain bladders. Fact Sheet 33 in the ACRP Report #14 describes these devices and how they are used. Single sewer grates are typically blocked by inserts for surface recovery by glycol recovery vehicles and trench drains or subsurface drainage systems are usually blocked by plugs or bladders for recovery by vacuum trucks.

Issues related to potential “ponding of deici ng stormwater” where drains are blocked are in most cases related to drain management and cannot be assumed to be directly related to glycol recovery vehi cle performance. Many times “ponding” can be associated to drainage infrastructure iss ues or coordination issues. With proper procedures and active management, issues related to “ponding” can be minimized as to not impede airport operations. It is also important to note that the type of winter precipitation events may influence these types of ramp conditions.

c. Portable or Temporary Storage Tanks

Adequate storage and location of storage tanks is an integral part of any spent ADF recovery program. Temporary storage tanks su ch as “frac” tanks are strategically located near areas of deici ng to maximize recovery efficiency. These tanks can be rented monthly instead of annually to reduce operating expenses.9 d. Operational Changes and Coordination

In order for a spent ADF co llection program to be succe ssful, airport stakeholders
and tenants must understand that glycol collection efforts must be incorporated into the overall winter operations plan. Airlines, airport staff, tenants and sub-contractors must properly plan and coordinat e for the recovery of deic ing fluids. Development of Standardized Operating Procedures (SOP ), training, communication and cooperation are essential par ts of the overall program. Typically, the longer the program is in place effici ency will improve with each deici ng season as experience is gained.

Next Steps in the Implementation Process

Based on the evaluation criteria and consideration of key fact ors, a complete spent ADF or contaminated storm water management pl an must be developed before recovery operations can begin. The over all program may consist of many but not all of the aforementioned considerations. Th is is developed specifically in response to what is feasible for the airport.

Typical Performance and Expected Results

A detailed plan, specialized equipment and properly trained sta ff are a vital part of an effective recovery operation. A great deal of consideration and coordination must be put into the implementation and management of the program.
In many cases aggressive glycol recovery operations coupled with plug and pump may be more feasible and cost effective in t he immediate term than central deicing pads constructed specifically for glycol cont ainment. Again, an analysis of the above mentioned factors must take place to deci de which approach(s) are best suited for a specific airport.

Based on our experiences providing glycol re covery services at airports in North America, with the proper allocation of re sources, equipment, labor, detailed operating plans and proper coordinat ion of all airport st akeholders, a 20% recovery rate (based on the EPA methodology of available ADF) is feas ible at most airports within one year of implementation and without major infrastructu re changes to accommodate deicing. This assumes however that an experienced servic e provider is contracted to perform services and the spent ADF collection require ment is incorporated into an airport’s winter operating procedures. With regards to the question raised whether we effectively10 meet the 20% collection standar d with glycol recovery vehicles, we meet and exceed this requirement at all of t he airports that we currently operate glycol recovery vehicles. To achieve this rate however, we also requi re drain blockers to be used in conjunction with the recovery vehicles. Obviously all of the above mentioned factors have to be considered and incorporated for this to hold true.

In terms of achieving a 40% collection rate (based on the EPA methodology of available ADF) at airports, this goal is also feasib le. Generally after two to three years of operation and modification to our spent ADF recovery programs we are able to achieve this performance level. This always requi res installation and operation of “plug and pump” technologies including drain blockers, glycol recovery vehicles, vacuum trucks, supervisory vehicles, dedicated managem ent, adequate storage, detailed operating protocols, airport wide cooperation and coordinati on, and ongoing process improvements. This too can be achieved wit hout major infrastructure changes assuming the airport does not have inheren t limitations that would obscure glycol recovery efforts. There is usually a larger allocation of re sources required than the 20% capture rate and a higher cost. Under the 40% collection scenar io it is absolutely crucial to have a dedicated staff for glycol recovery, critical that specific deicing procedures are developed with spent ADF contai nment in mind and usually a co mbination of both active and passive collection methodologies are employ ed to meet this level of performance.

To accomplish a 60% recovery rate (based on the EPA methodology of available ADF) typically infrastructure and operational changes are required. This includes construction of deicing pads or use of dedicated deicing areas, specialized containment systems and adequate storage for spent ADF. We do achiev e 60% recovery rates with “plug and pump technologies ” and also most commonl y with a combination of both active and passive collection approaches. However this was achieved after infr astructure changes, many years of experience at that particular airport, by significant operational procedural changes for deicing were incorporated as th e program expanded, dedicated resources for the management program and complete c oordination/cooperation of stakeholders.

Please note that glycol collection rates will vary from event to event during the course of any deicing season. The aforementioned co llection rates were based on the average recovery rate recognized afte r a final mass balance is calcul ated at the end of a deicing season. In dry non-precipitati on events the amount of ADF t hat can be recovered from the tarmac is high. The ADF recovered also tends to have a very high concentration. In freezing rain and wet snow events, active glycol recovery operations can be much more challenging. The fluid recovered from the tarm ac and drains can be more dilute. A larger volume of fluid is also collected under thes e conditions since there is a greater volume of water that is captured. For example, east coast airpor ts have a wetter climate and typically lower average concentrations and higher volumes of dilute spent ADF. Recovery rates typically decrease with freez ing rain and mixed precipitation events11 because of how quickly the deicing fluid dilu tes with runoff. Also the concentration of collected ADF depends on whether it is possibl e to recover while deicing is occurring and how quickly the fluid can be recovered after the plane moves. It also depends on whether the glycol recovery vehicle has to wait for multiple aircraft to be deiced before it cleans the area. These factors tend to give variability in the recovery rate, event by event, throughout the course of a winter season.

Case Studies

Inland has been asked to provide commentar y on achievable collection efficiencies based on our industry experience. We are pr oviding general information for two large hub airports where we have acquired severa l years of experience implementing and managing the spent ADF programs. Specifica lly we focused on these two programs because they include the use of Glycol Recovery Vehicl es combined with plug and pump operations to collect spent glycol. We are providing information based on actual data obtained but will not specify the names of each airport.

While there will certainly be some slight variat ion in the collection efficiencies achieved based upon an airports geographic location, type of winter precipitation (i.e. snowfall vs. mixed precipitation) and airpor t infrastructure we can provi de a case history of what we
see as realistic and achievable.

We have an example of one large hub airport with approximately 1,00 0 to 1,500 flight operations per day and another hub airport with approximat ely 500 to 1,000 flight operations per day. Each airport is located in the Mid-Atlantic region and we have been operating at each over the past several years. The larger airport sprays approximately 175,000 gallons to 200,000 gallons of neat deicin g fluid per year while the other airport sprays approximately 80,000 gallons to 120,000 gallons of neat fl uid. Due to the climate in the northeast and Mid-Atlantic region, these airports normally see moderate wet snowfall or moderate mixed pr ecipitation events annually.

At each airport we began by using existing infr astructure to employ a recovery program utilizing Glycol Recovery Vehicles combined with various drain blockers and plug and pump operations using vacuum trucks. We are contracted to provide all of the equipment and labor resources to manage t he glycol recovery program. We have fulltime employees dedicated to providin g the glycol collecti on and management services. In the case of the first large hub airport it has ample room for growth or changes to current infrastructure while t he second large hub airport has more limited options. At the outset neither airport possessed any dedicated infrastructure for collecting glycol contaminated storm water runoff or centralized deicing locations. Deicing operations were per formed primarily on-gate at lo cations with varying drainage12 structures and proximity to the storm drainage inlets and our goal was to collect all spent ADF that was tested to have glycol conc entrations that were 5% concentration or higher. The glycol concentrations tested on apron surfaces less than 5% were not a primary area of focus in an effort to maximize utilization of resources.

At the first large hub location we achieved average annual recovery rates ranging from a minimum of 35% and maximum in the mid 50% range over the first few years. The recovery rate was calculated by taking t he total amount of pure glycol collected and dividing it by the total amount of available ADF. Please see further below for more detailed information on reporting and available ADF. We saw similar collection rates during this time frame at the second large hub airport ranging from a minimum of 32% to a maximum in the mid 50% range. In eac h case we achieved these results using drain blocking methods for the existing infras tructure with no major changes to deicing operations except that the recovery operations were coordinated with airport staff.

Over the last few years with airport infrastr ucture improvements, such as apron areas modified to be deicing pads, increase in equipm ent allocation and labor, and operational changes to deicing practices we have been able to collect spent ADF with glycol
concentrations ൒ 1% and subsequently our average annual recovery rate has increased and consistently been in the upper 40% to lo w 60% range at each location. It is important to note that we s ee varying recovery rates per type of weather event. The lower range is typically attributed to s easons with more frequent freezing rain events while the higher ranges are s een with deicing season with more frequent snow events. Freezing rain and mixed precip itation events typically gener ate a very high volume of dilute fluid which must be collected. Resour ces can become limited while collected very large volumes of dilute spent AD F during short periods of time.

Please note that all recovery rates are reported based on using the EPA methodology of
Available ADF. This means that the total amount applied of Type I fluid was normalized
to remove the water content in the ADF so lution. 80% of the annual volume of Type I was included as available fluid for colle ction. For Type IV the annual amount applied was not normalized (assumed pure by the air port authority) and 10% of the annual Type IV volume applied was included as available fo r collection. The airport authority at each airport requires all deicing fluid users to r eport their usage at a minimum monthly. On the collection side, Inland has a detailed r eporting and an inventory system to track all fluid collected. As fluid is collected and put into each storage tank the fluid is measured and adequately circulated to get an average glycol percentage. Handheld refractometers are used to obtain glycol concentrations. The glycol content is then converted to gallons of pure glycol. Da ily, weekly, monthly and annual reports are tabulated and reported to each airport authority .These volume s and concentrations are verified as the fluid is transferred for recycling operations and a mass balance is also
calculated on all the concentra ted glycol that is produced.13 Conclusion

We hope that this information will be useful to the EPA as it completes the evaluation of plug and pump technologies. Please do not hesitat e to contact us if you require further clarification for any of the material we pr esented or would like to discuss further. Thank you for the opportunity to provide this information.