### 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 Deic ing Operations Point Source rule. Specifically, EPA is costing selected airports to assess ADF u sage from their tenants, perform an engineering review of airport operations to determine and document compliance with the percent ADF collection standard, perform annual aircraft de icing fluid (ADF) collection equipment/system inspections, and perform chemical oxygen dema nd (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 presen ts the subset of airports that would be assumed to conduct these activities as part of their compliance with the final rule.

1.0 A SSESSING ADF U SAGE FROM A IRPORT T ENANTS

EPA has assumed that airports using significant amounts of ADF during typical winter seasons will need to collect and compile ADF usage info rmation 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 coll ected for six months of the year on average.

The costs associated with assessi ng 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 equa tion above is calculated based on an average reported labor rate of $33/hour obtained from the 2004 airport questio nnaire and an escalation rate of 7 percent to adjust costs to a 2006 basis 1 . The adjustment of the labor rate was done so that the labor costs for the compliance activity will be on a similar y ear basis as the other costs assessed by EPA.

1 From Bureau of Labor Statistics, Producer Price Index industry data fo r the airport industry. Increase

from 2004 to 2006.

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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 D ETERMINATION OF ADF S TORMWATER C OLLECTION P ERCENT

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 engineerin g consultant or firm to evaluate the airport’s ADF usage data to calculate the estimated av ailable normalized ADF at the airport. The engineering consultant will also evaluate in formation on the airport’s deicing stormwater collection and control operations a nd 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 air port-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 Develo p 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 A NNUAL ADF C OLLECTION E QUIPMENT /S YSTEM I NSPECTIONS

As part of the final rule, airports may docume nt annual compliance with the 40 percent collection standard by demonstrating that their selecte d Best Available Technology (BAT) system is properly maintained and operated. The BAT syst em may include plug-and-pump or drainage system diversion collection of ADF contaminat ed 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

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documenting that the equipment is being ma intained 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 a nd will include the following types of activities:

 Inspection of GCVs to ensure that they ar e 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 hour s total) are required to perform these activities

on an annual basis.

The costs associated with performing the annua l 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 aver age 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 basis 1

.

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 P ERFORMING COD M ONITORING FROM ON -S ITE T REATMENT S YSTEM

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

ADF stormwater collection and control will tr eat 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 curre ntly being in compliance with EPA’s collection

standard send collected ADF stormwater to a P ublic 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 ai rport treatment system such as an AFB reactor, EPA assumed the following:

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 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 continu ously for 26 weeks per year (6 months);

 Approximately 1 hour of labor is require d 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/sample 3 and includes the cost of the sample container.

Using the assumptions above, ERG calculated the a nnual 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 collecti on 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 op tions 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 efflue nt 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 airpor t survey that are required to meet the collection standard either discharge collected ADF stormwat er to a POTW, to off-site recycle/recovery, or are zero discharge.

2 Average labor costs from the airport deici ng questionnaire escalated to 2006 year basis.

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