Memorandum 

November 17, 2010 

Page 1 

MEMORANDUM 

TO: Airport Deicing Administrative Record 

FROM: Mary Willett, ERG

DATE: November 17, 2010 

SUBJECT: Estimated Compliance-Related Costs for the Final Airport Deicing 

Rulemaking 

This memorandum provides the estimated costs for airports to perform specific compliancerelated activities analyzed for final Airport Deicing Operations Point Source rule. Specifically, 

EPA is costing selected airports to assess ADF usage from their tenants, perform an engineering 

review of airport operations to determine and document compliance with the percent ADF 

collection standard, perform annual aircraft deicing fluid (ADF) collection equipment/system 

inspections, and perform chemical oxygen demand (COD) monitoring from an on-site treatment 

system (such as anaerobic fluidized bed (AFB) treatment) to demonstrate compliance with the 

final rule COD standards. Each section below outlines the methodology and assumptions used to 

develop costs for each of these activities and presents the subset of airports that would be 

assumed to conduct these activities as part of their compliance with the final rule. 

1.0 ASSESSING ADF USAGE FROM AIRPORT TENANTS

EPA has assumed that airports using significant amounts of ADF during typical winter seasons 

will need to collect and compile ADF usage information from airline tenants. This ADF usage 

cut-off determines whether an airport will need to comply with the Collection Percentage 

Standard under the final rule. 

Methodology

EPA is assuming that airport personnel will collect ADF usage data monthly from airport tenants 

and will collate that data into a spreadsheet which can be totaled each season to assess an annual 

ADF usage for the entire airport. EPA is assuming that 8 hours per month will be required for 

this activity and that ADF usage data is collected for six months of the year on average. 

The costs associated with assessing ADF usage will therefore be: 

8 hours/month x 6 deicing months/yr x $35/hour labor rate = $1,680/year 

The labor rate shown in the equation above is calculated based on an average reported labor rate 

of $33/hour obtained from the 2004 airport questionnaire and an escalation rate of 7 percent to 

adjust costs to a 2006 basis1

. The adjustment of the labor rate was done so that the labor costs for 

the compliance activity will be on a similar year basis as the other costs assessed by EPA.

 

1

 From Bureau of Labor Statistics, Producer Price Index industry data for the airport industry. Increase 

from 2004 to 2006. 
Memorandum 

November 17, 2010 

Page 2 

Airports Assessing ADF Usage

EPA is assuming that those airports that use less than 80,000 gallons of normalized ADF per year 

will need to collect and assess total airport annual ADF usage. 

2.0 DETERMINATION OF ADF STORMWATER COLLECTION PERCENT 

For options requiring collection and treatment of spent ADF, EPA assumes that airports will need 

to evaluate their ADF stormwater collection system. 

Methodology

EPA is assuming that airports will hire an engineering consultant or firm to evaluate the airport’s 

ADF usage data to calculate the estimated available normalized ADF at the airport. The 

engineering consultant will also evaluate information on the airport’s deicing stormwater 

collection and control operations and current deicing stormwater loads to storage and/or indirect 

discharge to calculate and document the airport’s percent ADF capture. 

Table 1 summarizes EPA’s estimate of the hours and total costs for a consulting firm to develop 

and document an engineering assessment using airport-specific data. EPA developed the project 

elements and estimated the average hourly rate for consulting engineers at $85/hour based on best 

professional judgment. 

Table 1. Estimated Cost to Develop an Airport Engineering Assessment 

Project Element Labor Hours Labor Rate Total Cost 

Project Management 40 $85/hr $3,400 

Data Analysis and Drawings 120 $85/hr $10,200 

Calculation of Percent ADF 

Capture 

40 $85/hr $3,400 

Report Preparation and Revisions 80 $85/hr $6,800 

Client Meetings 24 $85/hr $2,040 

Subtotals: 264 $25,840 

Overhead Charges 10% Subtotal $2,584 

Total Cost $28,424 

EPA is estimating a total project cost of $28,424 per airport as shown in Table 1, where this cost 

is assumed to occur once each permit cycle (i.e., once every five years). 

 

Airports Performing Collection Percent Analysis

EPA assumes that some airports will be required to perform an analysis of the airport’s ADF 

collection percent. 

3.0 ANNUAL ADF COLLECTION EQUIPMENT/SYSTEM INSPECTIONS

As part of the final rule, airports may document annual compliance with the 40 percent collection 

standard by demonstrating that their selected Best Available Technology (BAT) system is 

properly maintained and operated. The BAT system may include plug-and-pump or drainage 

system diversion collection of ADF contaminated stormwater and may be supplemented with 

Glycol Collection Vehicle (GCV) use. Airports can demonstrate that those technologies are 

being used properly by performing an annual inspection of the collection equipment and 
Memorandum 

November 17, 2010 

Page 3 

documenting that the equipment is being maintained and used per the manufacturer’s 

specifications. 

Methodology

EPA is assuming that annual inspection of ADF stormwater collection equipment/systems will 

occur prior to the normal airport deicing season and will include the following types of activities: 

 Inspection of GCVs to ensure that they are maintained and ready for use along with any 

inspection of the vehicle vacuum system recommended by the manufacturer (e.g., 

inspection of the vacuum pressure and/or nozzles); and 

 Inspection of the plug-and-pump or drainage diversion system to ensure that system 

components are in good condition and working order (e.g., inspection and exercising of 

shut off values, inspection of balloon inserts etc.). 

EPA is assuming that two weeks of labor (80 hours total) are required to perform these activities 

on an annual basis. 

The costs associated with performing the annual ADF collection equipment/system inspections 

will therefore be: 

80 hours/season x $35/hour labor rate = $2,800/year 

The labor rate is calculated based on an average reported labor rate of $33/hour from the 2004 

airport questionnaire data and an escalation rate of 7 percent to adjust costs to a 2006 year basis1

. 

Airports Performing Collection Equipment/Systems Inspections

EPA assumes that a subset of airports will be required to comply with analyzed collection 

standards and will perform annual inspections. 

4.0 PERFORMING COD MONITORING FROM ON-SITE TREATMENT SYSTEM

For purposes of the national costing effort, EPA has assumed that airports requiring additional 

ADF stormwater collection and control will treat the stormwater through an on-site AFB 

treatment system. In addition, airports that are already achieving compliance with the collection 

standard that employ on-site treatment prior to direct discharge need to demonstrate compliance 

with the COD treatment standards at the effluent discharge point from the on-site treatment 

system. Most of the airports assessed as currently being in compliance with EPA’s collection 

standard send collected ADF stormwater to a Public Owned Treatment Works (POTW) or to offsite glycol recovery. However, EPA did not assume either POTW discharge or transfer to an offsite glycol recovery facility would be a viable option for those airports requiring additional 

collection and control. For purposes of assessing national costs, EPA is assuming that airports 

requiring additional collection and control will need to conduct on-going monitoring of the 

effluent discharge point of the on-site treatment system to ensure permit compliance. Costs for 

on-going effluent COD monitoring do not apply to airports that have limited ADF usage and 

demonstrate that they are below the 60,000 gallons/year normalized ADF usage cut-off. 

Methodology

To develop on-going monitoring costs for an airport treatment system such as an AFB reactor, 

EPA assumed the following: 
Memorandum 

November 17, 2010 

Page 4 

 Airports would collect a daily 24-hour composite sample of treatment system effluent for 

analysis of COD for each day the treatment system is operating; 

 Treatment systems would be operated continuously for 26 weeks per year (6 months); 

 Approximately 1 hour of labor is required for sample collection and delivery of the 

sample to the laboratory; 

 Labor costs for sample collection are $35/hr;2

 and 

 Costs for COD analysis by the laboratory is $22/sample3

 and includes the cost of the 

sample container. 

Using the assumptions above, ERG calculated the annual cost for monitoring the effluent from an 

airport treatment system to be $10,374/year. The equations below show the method used to 

calculate the annual treatment system monitoring cost. 

Sample Analysis Cost ($/yr): 1 sample/day x 7 days/wk x 26 wks/yr x $22/sample = $4,004 

Labor Cost ($/yr): 1 hr/day x 7 days/wk x 26 wks/yr x $35/hr = $6,370 

Total Cost ($/yr): $4,004 + $6,370 = $10,374 

Airports Conducting Effluent COD Monitoring

For options requiring collection and treatment of spent ADF, EPA assessed costs for all airports 

which have been costed for additional collection and on-site treatment of ADF stormwater, to 

monitor for COD at the effluent discharge point from the on-site treatment system. In addition, 

EPA evaluated all of the other airports (included in EPA’s airport survey) that currently comply 

with the collection requirements in the analyzed options to determine which of those airports treat 

ADF stormwater on-site and discharge the effluent directly to U.S. surface waters. Those 

airports would also require monitoring of effluent COD to meet the final rule standards and 

include: 

 Washington Dulles International Airport; 

 Denver International Airport; 

 Albany International Airport; and 

 Nashville International Airport. 

All of the other airports included in EPA’s airport survey that are required to meet the collection 

standard either discharge collected ADF stormwater to a POTW, to off-site recycle/recovery, or 

are zero discharge. 

 

2

 Average labor costs from the airport deicing questionnaire escalated to 2006 year basis. 3

 Sample analysis costs obtained from EPA for analysis of COD samples by contract laboratory.