Air Transportation Industry Sector Notebook Project 

EPA/310-R-97-001

EPA Office of Compliance Sector Notebook Project 

Air Transportation Industry 

October 1998

Office of Compliance

Office of Enforcement and Compliance Assurance

U.S. Environmental Protection Agency

401 M St., SW (MC 2221-A)

Washington, DC 20460

Sector Notebook Project February 1998 
Air Transportation Industry Sector Notebook Project 

This report is one in a series of volumes published by the U.S. Environmental Protection Agency 

(EPA) to provide information of general interest regarding environmental issues associated with 

specific industrial sectors. The documents were developed under contract by Abt Associates 

(Cambridge, MA), Science Applications International Corporation (McLean, VA), and Booz-Allen 

& Hamilton, Inc. (McLean, VA). This publication may be purchased from the Superintendent of 

Documents, U.S. Government Printing Office. A listing of available Sector Notebooks and 

document numbers is included on the following page. 

All telephone orders should be directed to: 

Superintendent of Documents 

U.S. Government Printing Office 

Washington, DC 20402 

(202) 512-1800 

FAX (202) 512-2250 

8:00 a.m. to 4:30 p.m., EST, M-F 

Using the form provided at the end of this document, all mail orders should be directed to: 

U.S. Government Printing Office 

P.O. Box 371954 

Pittsburgh, PA 15250-7954 

Complimentary volumes are available to certain groups or subscribers, such as public and 

academic libraries, Federal, State, and local governments, and the media from EPA’s National 

Center for Environmental Publications and Information at (800) 490-9198. For further 

information, and for answers to questions pertaining to these documents, please refer to the 

contact names and numbers provided within this volume. 

Electronic versions of all Sector Notebooks are available free of charge at the following web 

address: www.epa.gov/oeca/sector. Direct technical questions to the “Feedback” button at the 

bottom of the web page. 

Sector Notebook Project February 1998 
Air Transportation Industry Sector Notebook Project 

Sector Notebook Contacts 

The Sector Notebooks were developed by the EPA’s Office of Compliance. Questions relating to the 

Sector Notebook Project can be directed to: 

Seth Heminway, Coordinator, Sector Notebook Project

US EPA Office of Compliance

401 M St., SW (2223-A)

Washington, DC 20460

(202) 564-7017

Questions and comments regarding the individual documents can be directed to the appropriate specialists 

listed below. 

Document Number 

EPA/310-R-95-001.

EPA/310-R-95-002.

EPA/310-R-95-003.

EPA/310-R-95-004.

EPA/310-R-95-005.

EPA/310-R-95-006.

EPA/310-R-95-007.

EPA/310-R-95-008.

EPA/310-R-95-009.

EPA/310-R-95-010.

EPA/310-R-95-011.

EPA/310-R-95-012.

EPA/310-R-95-013.

EPA/310-R-95-014.

EPA/310-R-95-015.

EPA/310-R-95-016.

EPA/310-R-95-017.

EPA/310-R-95-018.

EPA/310-R-97-001.

EPA/310-R-97-002.

EPA/310-R-97-003.

EPA/310-R-97-004.

EPA/310-R-97-005.

EPA/310-R-97-006.

EPA/310-R-97-007.

EPA/310-R-97-008.

EPA/310-R-97-009.

EPA/310-R-97-010.

EPA/310-R-98-001.

EPA/310-R-98-002.

EPA/310-R-98-003.

EPA/310-R-98-004.

EPA/310-R-98-005.

EPA/310-R-98-008.

Industry 

Dry Cleaning Industry 

Electronics and Computer Industry* 

Wood Furniture and Fixtures Industry 

Inorganic Chemical Industry* 

Iron and Steel Industry 

Lumber and Wood Products Industry 

Fabricated Metal Products Industry* 

Metal Mining Industry 

Motor Vehicle Assembly Industry 

Nonferrous Metals Industry 

Non-Fuel, Non-Metal Mining Industry 

Organic Chemical Industry* 

Petroleum Refining Industry 

Printing Industry 

Pulp and Paper Industry 

Rubber and Plastic Industry 

Stone, Clay, Glass, and Concrete Industry 

Transportation Equipment Cleaning Ind. 

Air Transportation Industry 

Ground Transportation Industry 

Water Transportation Industry 

Metal Casting Industry 

Pharmaceuticals Industry 

Plastic Resin and Man-made Fiber Ind. 

Fossil Fuel Electric Power Generation Ind. 

Shipbuilding and Repair Industry 

Textile Industry 

Sector Notebook Data Refresh-1997 

Aerospace Industry 

Agricultural Chemical, Pesticide, and 

Fertilizer Industry 

Agricultural Crop Production Industry 

Agricultural Livestock Production Ind. 

Oil and Gas Exploration and Production 

Industry 

Local Government Operations 

Contact Phone (202) 

Joyce Chandler 564-7073 

Steve Hoover 564-7007 

Bob Marshall 564-7021 

Walter DeRieux 564-7067 

Maria Malave 564-7027 

Seth Heminway 564-7017 

Scott Throwe 564-7013 

Jane Engert 564-5021 

Anthony Raia 564-6045 

Jane Engert 564-5021 

Rob Lischinsky 564-2628 

Walter DeRieux 564-7067 

Tom Ripp 564-7003 

Ginger Gotliffe 564-7072 

Seth Heminway 564-7017 

Maria Malave 564-7027 

Scott Throwe 564-7013 

Virginia Lathrop 564-7057 

Virginia Lathrop 564-7057 

Virginia Lathrop 564-7057 

Virginia Lathrop 564-7057 

Jane Engert 564-5021 

Emily Chow 564-7071 

Sally Sasnett 564-7074 

Rafael Sanchez 564-7028 

Anthony Raia 564-6045 

Belinda Breidenbach 564-7022 

Seth Heminway 564-7017 

Anthony Raia 564-6045 

Amy Porter 564-4149 

Ginah Mortensen (913)551-7864 

Ginah Mortensen (913)551-7864 

Dan Chadwick 564-7054 

John Dombrowski 564-7036 

*Spanish translations available. 

Sector Notebook Project February 1998 
Air Transportation Industry Sector Notebook Project 

AIR TRANSPORTATION INDUSTRY 

TABLE OF CONTENTS 

LIST OF EXHIBITS ........................................................ iv

LIST OF ACRONYMS ....................................................... v

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT ..................... 1

A. Summary of the Sector Notebook Project ................................. 1

B. Additional Information ............................................... 2

II. INTRODUCTION TO THE AIR TRANSPORTATION INDUSTRY ................. 3

A. Introduction, Background, and Scope of the Notebook ...................... 3

B. Characterization of the Air Transportation Industry ......................... 4

1. Industry Characterization ........................................ 4

1.1. Types of Aircraft and Airports ............................. 4

1.2. Requirements Pertaining to the Aviation Industry .............. 7

1.3. International Aviation ................................... 8

2. Industry Size and Geographic Distribution ........................... 9

3. Economic Trends ............................................. 13

III. DESCRIPTION OF OPERATIONS ......................................... 16

A. Aircraft Operations and Associated Environmental Aspects .................. 16

1. Aircraft and Aviation-Support Vehicle Maintenance .................. 16

2. Fueling .................................................... 22

3. Aircraft Cleaning ............................................ 23

4. Aircraft Deicing and Anti-Icing .................................. 24

5. General Aircraft Operational Activities ............................ 25

B. Airport Operations ................................................. 29

1. Runway Deicing ............................................. 29

2. General Airport Operations ..................................... 29

IV. POLLUTION PREVENTION OPPORTUNITIES .............................. 31

A. Air Transportation Operations ........................................ 32

1. Maintenance and Refurbishing Operations ......................... 32

2. Fueling .................................................... 38

3. Aircraft and Vehicle Exterior Cleaning ............................ 40

4. Aircraft Deicing ............................................. 41

5. General Aircraft Operations .................................... 43

B. Airport Operations ................................................. 44

1. Runway Deicing ............................................. 44

2. General Airport Operations ..................................... 44

Sector Notebook Project i February 1998 
Air Transportation Industry Sector Notebook Project 

V. SUMMARY OF FEDERAL STATUTES AND REGULATIONS ................... 47

A. General Description of Major Statutes .................................. 47

B. Industry Specific Requirements........................................ 58

C. Pending and Proposed Regulatory Requirements .......................... 64

VI. COMPLIANCE AND ENFORCEMENT HISTORY ............................ 67

A. Air Transportation Industry Compliance History ........................... 71

B. Comparison of Enforcement Activity Between Selected Industries ............. 73

C. Review of Major Legal Cases/Supplemental Environmental Projects ............ 78

1. Review of Major Cases ........................................ 78

2. Supplementary Environmental Projects (SEPs) ...................... 80

VII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES ................ 81

A. Sector-Related Environmental Programs and Activities ..................... 81

1. EPA Voluntary Activities ...................................... 81

2. Trade Association/Industry Sponsored Activities .................... 84

B. Summary of Trade Associations ....................................... 84

VIII. RESOURCE MATERIALS/BIBLIOGRAPHY ............................... 90

Sector Notebook Project ii February 1998 
Air Transportation Industry Sector Notebook Project 

LIST OF EXHIBITS

Exhibit 1: Market Size Analysis of Air Transportation Industry ...................... 9

Exhibit 2: Distribution of Establishments by Sector ............................... 9

Exhibit 3: Activity at the 10 Busiest Airports (1996) ............................. 10

Exhibit 4: Top Ten Airlines of Scheduled Service (1996) ......................... 10

Exhibit 5: Number of Businesses by Company Size .............................. 11

Exhibit 6: Top Five States with Air Transportation Establishments .................. 12

Exhibit 7: Top Five States with Air Transportation Industry Employees .............. 12

Exhibit 8: Top Five States with Highest Air Transportation Sales .................. 13

Exhibit 9: Summary of Domestic Passenger Traffic .............................. 13

Exhibit 10: Forecast for U.S. Commercial Carriers and Regionals/Communters

FY1998 - 2009 ................................................. 14

Exhibit 11: Maintenance and Refurbishing Operations: Activities and Potential

Environmental Impacts ........................................... 18

Exhibit 12: Annual Air Pollutant Releases by Industry Sector (tons/year) .............. 28

Exhibit 13: Five-Year Enforcement and Compliance Summary for the

Air Transportation Industry ....................................... 72

Exhibit 14: Five-Year Enforcement and Compliance Summary for Selected Industries .... 74

Exhibit 15: One-Year Enforcement and Compliance Summary for Selected Industries .... 75

Exhibit 16: Five-Year Inspection and Enforcement Summary by Statute

for Selected Industries ........................................... 76

Exhibit 17: One-Year Inspection and Enforcement Summary by Statute

for Selected Industries ........................................... 77

Sector Notebook Project iii February 1998 
Air Transportation Industry Sector Notebook Project 

LIST OF ACRONYMS

AFS AIRS Facility Subsystem (CAA database)

AIRS Aerometric Information Retrieval System (CAA database)

BIFs Boilers and Industrial Furnaces (RCRA)

BOD Biochemical Oxygen Demand

CAA Clean Air Act

CAAA Clean Air Act Amendments of 1990

CATC Clean Air Technology Center

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CERCLIS CERCLA Information System

CFCs Chlorofluorocarbons

CO Carbon Monoxide

COD Chemical Oxygen Demand

CSI Common Sense Initiative

CWA Clean Water Act

D&B Dun and Bradstreet Marketing Index

DOT U.S. Department of Transportation

ELP Environmental Leadership Program

EMS Environmental Management System

EPA United States Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act

FAA Federal Aviation Administration

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FINDS Facility Indexing System

FWPCA Federal Water Pollution Control Act

HAP Hazardous Air Pollutant (CAA)

HSDB Hazardous Substances Data Bank

HSWA Hazardous and Solid Waste Amendments

ICAO International Civil Aviation Organization

IDEA Integrated Data for Enforcement Analysis

LDR Land Disposal Restriction (RCRA)

LEPC Local Emergency Planning Committee 

MACT Maximum Achievable Control Technology (CAA)

MCLG Maximum Contaminant Level Goal

MCL Maximum Contaminant Level 

MEK Methyl Ethyl Ketone

MSDS Material Safety Data Sheet

NAAQS National Ambient Air Quality Standards (CAA)

NAFTA North American Free Trade Agreement

NAICS North American Industrial Classification System

NCDB National Compliance Database (for TSCA, FIFRA, EPCRA)

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NEIC National Enforcement Investigation Center

NESHAP National Emission Standards for Hazardous Air Pollutants

Sector Notebook Project iv February 1998 
Air Transportation Industry Sector Notebook Project 

NO2 Nitrogen Dioxide

NOI Notice of Intent

NOV Notice of Violation

NOX Nitrogen Oxide 

NPDES National Pollutant Discharge Elimination System (CWA)

NPL National Priorities List

NRC National Response Center

NSPS New Source Performance Standards (CAA)

OAR Office of Air and Radiation

OECA Office of Enforcement and Compliance Assurance

OPA Oil Pollution Act

OPPTS Office of Prevention, Pesticides, and Toxic Substances

OSHA Occupational Safety and Health Administration

OSW Office of Solid Waste

OSWER Office of Solid Waste and Emergency Response

OW Office of Water

P2 Pollution Prevention

PCS Permit Compliance System (CWA Database)

PM10 Particulate matter of 10 microns or less

PMN Premanufacture Notice

POTW Publicly Owned Treatments Works

PT Total Particulates

RACT Reasonably Available Control Technology

RCRA Resource Conservation and Recovery Act

RCRIS RCRA Information System

SARA Superfund Amendments and Reauthorization Act

SDWA Safe Drinking Water Act

SEP Supplemental Environmental Project

SERC State Emergency Response Commission

SIC Standard Industrial Classification

SIP State Implementation Plan

SO2 Sulfur Dioxide

SOX Sulfur Oxide

SPCC Spill Prevention Control and Countermeasures

TOC Total Organic Carbon

TRI Toxic Release Inventory

TRIS Toxic Release Inventory System

TSCA Toxic Substances Control Act

TSD Treatment, storage, and disposal

TSS Total Suspended Solids

UIC Underground Injection Control (SDWA)

UST Underground Storage Tank (RCRA)

VOC Volatile Organic Compound

Sector Notebook Project v February 1998 
Air Transportation Industry Sector Notebook Project 

AIR TRANSPORTATION INDUSTRY

(SIC 45)

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 

I.A. Summary of the Sector Notebook Project 

Integrated environmental policies based upon comprehensive analysis of air, 

water, and land pollution are a logical supplement to traditional single-media 

approaches to environmental protection. Environmental regulatory agencies 

are beginning to embrace comprehensive, multi-statute solutions to facility 

permitting, enforcement and compliance assurance, education/outreach, 

research, and regulatory development issues. The centralconcepts driving the 

new policy direction are that pollutant releases to each environmental medium 

(air, water, and land) affect each other, and that environmental strategies must 

actively identify and address these inter-relationships bydesigning policies for 

the “�����” facility. One way to achieve a whole facility focus is to design 

environmental policies for similar industrial facilities. By doing so, 

environmental concerns that are common to the manufacturing of similar 

products can be addressed in a comprehensive manner. Recognition of the 

need to develop the industrial “sector-based” approach within the EPA Office 

of Compliance led to the creation of this document. 

The Sector Notebook Project was originally initiated by the Office of 

Compliance within the Office of Enforcement and Compliance Assurance 

(OECA) to provide its staff and managers with summary information onmajor 

industrial sectors. As other EPA offices, states, the regulated community, 

environmental groups, and the public became interested in this project, the 

scope of the original project was expanded to its current form. The ability to 

design comprehensive, common sense environmental protection measures for 

specific industries is dependent on knowledge of several inter-related topics. 

For the purposes of this project, the key elements chosen for inclusion are: 

general industry information (economic and geographic); a description of 

industrial processes; pollution outputs; pollution prevention opportunities; 

Federal statutory and regulatory framework; compliance history; and a 

description of partnerships that have been formed between regulatory 

agencies, the regulated community and the public. 

For any given industry, each topic listed above could alone be the subject of 

a lengthy volume. However, in order to produce a manageable document, this 

project focuses on providing summary information for each topic. This 

format provides the reader with a synopsis of each issue, and references where 

more in-depth information is available. Text within each profile was 

researched from a variety of sources, and was usually condensed from more 

detailed sources pertaining to specific topics. This approach allows for a wide 

coverage of activities that can be further explored based upon the citations 

Sector Notebook Project 1 February 1998 
Air Transportation Industry Sector Notebook Project 

and references listed at the end of this profile. As a check on the information 

included, each notebook went through an external review process. The Office 

of Compliance appreciates the efforts of all those that participated in this 

process who enabled us to develop more complete, accurate and up-to-date 

summaries. 

I.B. Additional Information 

Providing Comments 

OECA’s Office of Compliance plans to periodically review and update the 

notebooks and will make these updates available both in hard copy and 

electronically. If you have any comments on the existing notebook, or if you 

would like to provide additional information, please send a hard copy and 

computer disk to the EPA Office of Compliance, Sector Notebook Project, 

401 M St., SW (2223-A), Washington, DC 20460. 

Adapting Notebooks to Particular Needs 

The scope of the industry sector described in this notebook approximates the 

national occurrence of facility types within the sector. In many instances, 

industries within specific geographic regions or states may have unique 

characteristics that are not fully captured in these profiles. The Office of 

Compliance encourages state and local environmental agencies and other 

groups to supplement or re-package the information included in this notebook 

to include more specific industrial and regulatory information that may be 

available. Additionally, interested states may want to supplement the 

“Summary of Applicable Federal Statutes and Regulations” section with state 

and local requirements. Compliance or technical assistance providers may 

also want to develop the “Pollution Prevention” section in more detail. Please 

contact the appropriate specialist listed on the opening page of this notebook 

if your office is interested in assisting us in the further development of the 

information or policies addressed within this volume. If you are interested in 

assisting in the development of new notebooks for sectors not covered in the 

original eighteen, please contact the Office of Compliance at (202) 564-2395. 

Sector Notebook Project 2 February 1998 
Air Transportation Industry Introduction, Background, and Scope 

II. INTRODUCTION TO THE AIR TRANSPORTATION INDUSTRY 

This section provides background information on the size, geographic 

distribution, employment, production, sales, and economic condition ofthe air 

transportation industry. Facilities described within this document are 

described in terms of their Standard Industrial Classification (SIC) codes. 

II.A. Introduction, Background, and Scope of the Notebook 

This notebook pertains to the transportation industry as classified within SIC 

code 45 (Transportation by Air). (Please note that this section provides both 

the SIC code and the new North American Industrial Classification System 

(NAICS) code, which went into effect January 1, 1997. While the NAICS 

code is identified in this section, the remainder of the document will refer to 

the SIC codes for specific air transportation activities.) 

The transportation industry includes other modes of transport, such as 

trucking, railroad, pipeline, and water, which make up an important portion 

of overall transportation activity in the United States. These modes are 

addressed in two sector notebooks. Trucking, railroad, and pipeline 

transportation are addressed in Ground Transportation Industry [EPA/310-R97-002], and water transportation is addressed in Water Transportation 

Industry [EPA/310-R-97-003]. 

The air transportation industry (SIC 45) includes establishments engaged in 

furnishing domestic and foreign transportation by air and also operating 

airports and flying fields and furnishing terminal services. Specifically, this 

notebook includes the following groups: 

SIC 4512 - Air Transportation, Scheduled (NAICS 481111 and 481112). 

This sector includes establishments primarily engaged in furnishing air 

transportation over regular routes and on regular schedules. This industry 

includes Alaskan carriers operating over regular or irregular routes. 

SIC 4513 - Air Courier Services (NAICS 49211). This sector includes 

establishments primarily engaged in furnishing air delivery of individually 

addressed letters, parcels, and packages(generally under 100 pounds), except 

by the U.S. Postal Service. Separate establishments of air courier companies 

which provide pick-up and delivery only, “drop-off points,” or distribution 

centers are all classified in this industry. 

SIC 4522 - Air Transportation, Nonscheduled (NAICS 481211, 481212, 

48799, 62191). This sector includes establishments engaged in furnishing 

nonscheduled air transportation. Also included in this industry are 

establishments primarily engaged in furnishing airplane sightseeing services, 

Sector Notebook Project 3 February 1998 
Air Transportation Industry Introduction, Background, and Scope 

air taxi services, and helicopter passenger transportation services to, from, or 

between local airports, whether scheduled or not scheduled. 

SIC 4581 - Airports, Flying Fields, and Airport Terminal Services (NAICS 

488111, 488119, 56172, 48819). This sector includes establishments 

primarily engaged in operating and maintaining airports and flying fields; in 

servicing, repairing (except on a factory basis), maintaining, and storing 

aircraft; and in furnishing coordinated handling services for airfreight or 

passengers at airports. This industry also include private establishments 

primarily engaged in air traffic control operations (except government). 

II.B. Characterization of the Air Transportation Industry 

II.B.1. Industry Characterization 

��� �������������� �������� ������� ������ ����� ��������� ������ �������

��� ��������� �� ��������� ���� ��� ����� �� �������� �������� ����� ���

�������� ������ ��� �������� �� ������� �� � ���������������������� ����

���������������� ����� �� ��� �������� ������� �� ������������ ��������� ��

��� ��� �������������� ����������� ��� ��� ���������������������� �����������

����� �������������� ������������ �� ��� ���� ��������� ��� ���� ������� ��

��� ����� �������� ������� �� �����

The airline industry in particular provides transportation of passengers, cargo, 

mail and perishable goods. American citizens have come to rely on domestic 

and international air transportation more and more every year. Airline travel 

in the United States has been getting safer over the years and is the safest in 

the world. The National Safety Council’s latest fatality totals for 1995 show 

175 deaths caused by United States airline accidents. By contrast, five times 

as many people died in boating accidents and accidents involving bicycles and 

tricycles. 

II.B.1.1. Types of Aircrafts and Airports 

Generally, the air transportation sector can be broken down into two 

categories: (1) facilities providing scheduled, non-scheduled, and air courier 

services using aircraft, and (2) airports and airport operations. It is these two 

major topics (i.e., aircraft facilities and airports) and the activities and 

operations that occur within each of these areas that are the primary focus of 

this notebook. 

Categories of Aircraft 

Sector Notebook Project 4 February 1998 
Air Transportation Industry Introduction, Background, and Scope 

There are five types of aircraft that compose the aviation industry: 

commercial, air taxi operations, commuter, general, and military. 

Commercial aircraft encompass air carriers and air taxi flights. Air carriers 

are airlines holding a certificate issued of public convenience and necessity 

under Section 401 of the Federal Aviation Act of 1958 authorizing them to 

perform passenger and cargo services. Air carriers operate aircraft designed 

to have a maximum seating capacity of more than 60 seats, to have a 

maximum payload capacity of more than 18,000 pounds, or to conduct 

international operations. The four different types of air carriers (and their 

annual operating revenues) are: 

� Majors (greater than $1 billion) 

� Nationals ($100 million to $1 billion) 

� Large regionals ($20 million to $100 million) 

� Medium regionals (Up to $20 million). 

Air taxi operations are those in which departure time, departure location, and 

arrival location are specifically negotiated with the customer or by the 

customer’s representative and are conducted with airplanes or rotorcraft 

having a seating configuration of 30 or fewer seats. 

Commuter aircraft are noncertified small regionals who perform scheduled 

service to smaller cities and serve as feeders to the major hub airports. They 

generally carry 60 or fewer passengers. 

General aviation is all aviation that is not commercial or military. General 

aviation is the segment of civil aviation that encompasses all facets of aviation 

except air carriers and commuters. General aviation includes corporateexecutive transportation, instruction, rental, aerial application, aerial 

observation, business, pleasure, and other special uses. 

Military refers to the operators of all military (e.g., Air Force, Army, Navy, 

U.S. Coast Guard, Air National Guard, and military reserve organizations) 

aircraft using civil airports. 

Classification of Airports 

The system of airports in the U.S. is the largest and most complex in the 

world. As of 1990, there were 17,451 civil landing areas (e.g., airports, 

heliports, seaplane bases, etc.) in the U.S. The activity and services at 

individual airports vary greatly. Regardless of size, many activities occur at 

airports including fueling, aircraft maintenance, aircraft washing, and deicing. 

In addition, two primary activities at most airports are enplaning passengers 

and enplaning air cargo. Enplaning passengers is defined as the total number 

Sector Notebook Project 5 February 1998 
Air Transportation Industry Introduction, Background, and Scope 

of passengers departing on aircraft at the airport. Enplaning air cargo includes 

the total tonnage of priority, nonpriority, and foreign mail, express, and freight 

(property other than baggage accompanying passengers) departing on aircraft 

at an airport. 

Airport Ownership. Public airportsin the U.S. are owned and operated under 

a variety of organizational and jurisdictional arrangements. Commercial 

airports might be owned and operated by a city, county, or State; or by more 

than one jurisdiction. Additionally, some airports may be operated by a 

separate public body, such as an airport authority. Regardless of ownership, 

legal responsibility for day-to-day operations can be vested in any of five kinds 

of governmental or public entities: 

� Municipal or county government. Municipally operated airports are 

city owned and run as a department of the city. 

� A multipurpose port authority. Port authorities are legally chartered 

institutions with the status of public corporations. 

� An airport authority. 

� State government. 

Classification of airports with scheduled services. Airports with scheduled 

passenger service have several classifications: 

� Commercial service airports are those airports receiving passenger 

service and having 2,500 or more annual enplanements. 

� Primary airports are commercial service airports having 10,000 or 

more enplanements. 

� Hub airports are airports that serve as a transfer point for passengers 

changing flights. Commercial service airports are classified as large, 

medium, or small hub airports or non-hub airports, depending on the 

percentage of total national enplanements for which they account. 

� General aviation airports encompass the bulk of civil aircraft 

operations. The general aviation system includes 98% of all registered 

civil aircraft and 95% of all airports. 

� Reliever airports are a special category of general aviation airports. 

Located in the vicinity of major air carrier airports and classified by 

the Federal Aviation Administration as a reliever, these airports are 

designed to provide relief to congested major airports. 

Terminal Facilities. The terminal and associated landside facilities such as 

the parking areas and access roads provide the transition zone for passengers 

Sector Notebook Project 6 February 1998 
Air Transportation Industry Introduction, Background, and Scope 

between surface and air transportation. Landside facilities are long-term 

installations and are largely independent of activities that occur airside. 

Concession and food service operations provide food and materials goods for 

passengers. 

II.B.1.2. Requirements Pertaining to the Aviation Industry 

The Federal Aviation Administration’s (FAA’s) major responsibilities include 

overseeing aircraft safety and the competency of pilots and mechanics. The 

FAA does this by providing mandatory safety rules, conducting safety 

inspections, and setting high standards for civil aviation. 

Noise Abatement. In addition to safety, the FAA also addresses issues such 

as noise abatement. As a result of complaints against aircraft noise, which 

increased dramatically with the introduction of jet aircraft, the Federal 

Aviation Act of 1958 was amended to include noise abatement regulations 

designed to establish noise levels which aircraft manufacturers cannot exceed 

in the development of new aircraft. In 1979, the Aviation Safety and Noise 

Abatement Act authorized the FAA to help airport operators develop noise 

mitigation abatement programs. 

The Airport Noise and Capacity Act of 1990 authorized DOT/FAA to reduce 

aircraft engine noise by requiring an aircraft fleet replacement program. The 

estimated effect of the phase out of larger, noisier aircraft is estimated to 

reduce the number of people exposed to significant noise levels of aircraft 

noise in the U.S. from 2.7 million in 1990 to 400,000 by the year 2000, when 

the phaseout is complete. The law also limited airport operators’ abilities to 

place noise or access restrictions on airports in the interest of avoiding an 

overly burdensome patchwork of individual operating limitations across the 

United States. 

Standards for Aircraft Design. The FAA works closely with aircraft 

manufacturers while examining designs for new planes. The FAA sets very 

high standards for aircraft designs. Once the design has been thoroughly 

examined and the first model has completed a grueling series of flight tests 

and evaluations, the model is certificated for production by the FAA 

(http://www.faa.gov/publicinfo.htm). 

Monitoring and Maintenance of Existing Aircraft. Once the aircraft has 

been certified and put into service, the FAA continues to monitor its 

performance. When necessary, the FAA will issue repair notices known as 

“Airworthiness Directives” to the manufacturers and airlines when problems 

are spotted. The FAA issues several hundred notices a year. In addition, 

manufacturers often issue Service Bulletins to advise aircraft carriers of safety 

improvements or procedures that will enhance safety. 

Sector Notebook Project 7 February 1998 
Air Transportation Industry Introduction, Background, and Scope 

FAA airworthiness requirements specify materials to be used during 

maintenance or other technical specifications and standards (e.g., cleaning, 

deicing) that limit the airlines’ ability to change materials, procedures, or 

processes. 

Flight Personnel. The FAA sets standards for training, health, experience, 

number of hours worked, and qualifications for pilots and other flight 

personnel. Because pilots play such a vital role in maintaining aircraft 

operations safety, they are especially heavily regulated by the FAA. Pilots 

must have their health examined every six months. They must pass special 

examinations and flight tests, and those serving as captains are required to 

possess hundreds of hours of additional flying time. FAA tests their flying 

skills on a regular basis. DOT and FAA safety policies and rules expressly 

place the ultimate legal authority for aircraft operation fully and solely on the 

pilot in command of the aircraft (14 CFR §91.3(a)). 

Air Traffic Control Operations. FAA is responsible for developing, 

maintaining, and operating the nation’s Air Traffic Control System, which is 

in charge of ensuring the safe separation of aircraft during flight and 

sequencing aircraft for taxiing, takeoff, and landing. 

Maintenance Personnel. Airline mechanics and technicians must be certified 

by the FAA. In addition, repair stations must obtain an FAA operating 

certificate and are subject to regular inspection by the agency. 

For more information about FAA airworthiness requirements, see the FAA 

website at http://www.faa.gov/publicinfo.htm. 

II.B.1.3. International Aviation 

After 1945, commercial air transportation began to transcend domestic 

markets into the international arena, therefore, the standardization of 

operational practices for international services, such as navigational aids and 

weather reporting systems, became essential. There were also many political 

and technical problems that needed to be solved. For example, there was the 

issue of commercial rights: what arrangements were needed for the airlines of 

one country to fly into and through territories of another? For more 

information relating to International Civil Aviation Organization (ICAO) and 

other international milestones, refer to Memorandum on ICAO, January 1994. 

Sector Notebook Project 8 February 1998 
Air Transportation Industry Introduction, Background, and Scope

Sector Notebook Project 9 February 1998

Air Transportation Sectors

Air Transport - Scheduled

Air Transport - Nonscheduled

Air Courier Services

Airport Terminals

22.4%

20.4%

13.8%

43.4%

������� ��� � ���������� ������������ �������� ���� ������������������������

II.B.2. Industry Size and Geographic Distribution

Industry Size

According to Dun & Bradstreet, there were an estimated 16,282 air

transportation establishmentsin the U.S. as of April 1997. Exhibit 1 provides

information on each of the SIC codes in the air transportation industry,

including total number of establishments and employees, and total annual

sales.

Exhibit 1. Market Size Analysis of Air Transportation Industry

SIC Code No. of

Establishments

No. of

Employees

Annual Sales

(millions)

4512 3,638 320,837 147,858.6

4513 2,252 75,493 15,172.9

4522 3,321 39,253 7,019.0

4581 7,071 220,986 15,616.8

Total 16,282 656,569 185,667.3

Source: Dun & Bradstreet Marketplace (www.dnb.imarketinc.com), December 1997

������� � �������� ��� ����������� �� �������������� ��� ��� ��������������

������ ��������� ������

Exhibit 2: Distribution of Establishments by Sector
Air Transportation Industry Introduction, Background, and Scope 

Exhibit 3 lists the busiest airports in terms of the total passengers and cargo. 

Keep in mind that 99% of the nation’s airports are much smaller than these 

airports, but conduct the same activities to a lessor extent or volume. 

Exhibit 3. Activity at the 10 Busiest Airports (1996) 

Leading Airports in Passengers 

Arriving & Departing (Millions) 

Leading Airport in Cargo Tons 

Enplaned & Deplaned (Thousands) 

Chicago O’Hare 69.2 Memphis 1934 

Atlanta 63.3 Los Angeles 1719 

Dallas/Ft. Worth 58 Miami 1710 

Los Angeles 57.9 New York Kennedy 1636 

San Francisco 39.3 Louisville 1369 

Miami 33.5 Anchorage 1269 

Denver 32.3 Chicago O’Hare 1259 

New York Kennedy 31.2 Newark 958 

Detroit 30.6 Atlanta 800 

Las Vegas 30.5 Dallas/Ft. Worth 774 

������� ���� ��� ��������� ����������� ������ ������

The activity and services of the aviation industry vary greatly. Exhibit 4 

presents the top 10 airlines of scheduled service in the U.S. 

Exhibit 4. Top 10 Airlines of Scheduled Service (1996) 

Airline Passengers (millions) 

Delta 97.2 

United 81.9 

American 79.3 

US Airways 56.6 

Southwest 55.3 

Northwest 52.7 

Continental 35.7 

Trans World 23.3 

America West 18.1 

Alaska 11.8 

������� ���� ��� ��������� ����������� ������ ������

Sector Notebook Project 10 February 1998 
Air Transportation Industry Introduction, Background, and Scope 

Company size varies greatly among air transportation facilities. Exhibit 5 

presents an analysis of the number of businesses compared to the number of 

employees per air transportation sector. The distribution of establishments 

with a specific employee size varies from one SIC code to another. 

������� �� ������ �� ���������� �� ������� ����

��� ��

���������

������ �� ����������

��������� ������������ ��� ������� ��������

� ��� ��� ��� ���

� �� � ��� ���� ��� ����

� �� � ��� ��� ��� ����

�� �� �� ��� ��� ��� ���

�� �� �� ��� ��� ��� ���

�� �� �� ��� �� ��� ���

��� �� ��� ��� �� ��� ���

��� �� ��� �� � � ��

��� �� ��� �� � � ��

����� �� �� � � ��

�������� � � �

������� ���� �� ��� ����

������ ���� ���� ���� ����

������� ��� � ���������� ������������ �������� ���� ������������������������

���������� ������������

��� ��� �������������� �������� �� ������ ���������� �� ��� ����� �� ������

���� �������������� �� ��� ��� �������������� ��������� ���� ��� ������� ��

����������� ������ �������� ��������� ��� ��� ����� �������� � ��� �

�������� ��� ���� ������ ���� ��� ���� �������������� ��� ��������� �� ���

�������������� ��� �����

Sector Notebook Project 11 February 1998 
Air Transportation Industry Introduction, Background, and Scope 

Exhibit 6. Top Five States with Air Transportation Establishments 

SIC Code States 

(Number of Establishments) 

Air transportation, 

scheduled (SIC 4512) 

CA 

(426) 

FL 

(369) 

NY 

(321) 

TX 

(258) 

IL 

(200) 

Air transportation, 

nonscheduled (SIC 4522) 

CA 

(348) 

FL 

(314) 

TX 

(236) 

NY 

(151) 

AK 

(146) 

Air courier services 

(SIC 4513) 

CA 

(328) 

NY 

(308) 

FL 

(208) 

TX 

(194) 

IL 

(91) 

Airports, flying fields, & 

services (SIC 4581) 

CA 

(747) 

TX 

(641) 

FL 

(551) 

NY 

(304) 

IL 

(264) 

Source: Dun & Bradstreet Marketplace, December 1997 (www.dnb.imarketinc.com) 

Exhibit 7. Top Five States with Air Transportation Industry Employees 

SIC Code States 

(Number of Employees) 

Air transportation, 

scheduled 

(SIC 4512) 

TX 

(37,691) 

CA 

(31,396) 

MN 

(31,363) 

GA 

(30,484) 

NY 

(18,111) 

Air transportation, 

nonscheduled 

(SIC 4522) 

FL 

(3,662) 

CA 

(3,580) 

MN 

(2,546) 

IN 

(2,437) 

MI 

(2,428) 

Air courier 

services 

(SIC 4513) 

TN 

(20,374) 

CA 

(6,299) 

OH 

(6,299) 

NY 

(5,762) 

TX 

(5,143) 

Airports, flying 

fields, & services 

(SIC 4581) 

FL 

(36,414) 

CA 

(35,225) 

TX 

(15,755) 

NY 

(15,702) 

IL 

(15,762) 

Source: Dun & Bradstreet Marketplace, December 1997 (www.dnb.imarketinc.com) 

Exhibit 8 presents the top five states for each SIC code with the highest total 

sales in millions of dollars. California, Florida, New York, and Texas are 

consistently among the top five for these sectors. 

Sector Notebook Project 12 February 1998 
Air Transportation Industry Introduction, Background, and Scope 

Exhibit 8. Top Five States with Highest Air Transportation Sales 

SIC Code States 

(Total sales in millions) 

Air transportation, 

scheduled (SIC 4512) 

TX 

(41,080.5 

) 

IL 

(36,807) 

MN 

(27,512) 

VA 

(13,859) 

GA 

(13,109.7 

) 

Air transportation, 

nonscheduled 

(SIC 4522) 

IN 

(1,019.9) 

OR 

(776.7) 

FL 

(516.2) 

CA 

(534.70) 

NY 

(506.1) 

Air courier services 

(SIC 4513) 

TX 

(8,867.3) 

CA 

(2,793.6) 

WA 

(1,976) 

OH 

(602.1) 

NY 

(353.9) 

Airports, flying 

fields, & services 

(SIC 4581) 

FL 

(3,426.5) 

NY 

(2,544.7) 

TX 

(1,762.8) 

VA 

(1,639) 

CA 

(596.4) 

Source: Dun & Bradstreet Marketplace, December 1997 (www.dnb.imarketinc.com) 

II.B.3. Economic Trends 

Aviation Trends and Forecasts 

The aviation industry has been growing steadily and is expected to continue. 

U.S. commercial air carrier passenger enplanements, which had averaged less 

than 1.0 percent growth between 1990 and 1993, grew at an annual rate of 

6.2 percent over the last 3 years. In 1996, the large U.S. air carriers increased 

their system capacity by only 2.9 percent, while passenger demand increased 

by 6.1 percent. Exhibit 9 presents the trends for U.S. scheduled airlines in 

passengers enplaned and domestic cargo from 1960 to 1996. 

Sector Notebook Project 13 February 1998 
Air Transportation Industry Introduction, Background, and Scope 

Exhibit 9: ������� �� �������� ���������

�������

Sector Notebook Project 14 February 1998 
Air Transportation Industry Introduction, Background, and Scope

Sector Notebook Project 15 February 1998

������� ��� ������� ������� ����� ���������

��� ��� �������� ���� �������� ���������� ��� ���������� �������� ����

�������� ���� ��� �� ���� �� ��� ������� �� ����� ������� �� ��������

���������� ��� ��������� ��� ��� �������� ���������

������� ��� �������� ��� ���� ���������� �������� ���

������������������� ������ � ����

����

����������

���������� �

�������

��������� �����

���������� �

���

���������

��������

����������

�����������

���� ����� ����� ����� ����

���� ����� ����� ����� ����

���� ����� ����� ����� ����

���� ����� ����� ����� ����

���� ����� ����� ����� ����

���� ����� ����� ����� ����

���� ����� ����� ����� ����

���� ����� ����� ����� ����

���� ����� ����� ����� ����

���� ����� ����� ����� ����

���� ����� ������� ����� ����

���� ����� ������� ����� ����
Air Transportation Industry Introduction, Background, and Scope 

������� ������� �������� ���������������

� ���� ���������� ��� �������� ��� �������������������� �������� ����

��������������

� ���������� ��� ���������

� �������� ��� �������� �� ��� �������� ��� ��� �������������� �� ��� ���

�������� ����� ���������

������� �� ������������

������ ����� ��� ������ ������ ������� ������� ��� ������� ��������� �� ���

������� ����������� �������� ��� �� ���������� �� ���� �������� ���

������� �������� ���� ���������� ���������� ��� ���������� ��� ������ ��

��� ������� ��������� ��� ������������ ��� �� ���� ��� ������� ����� �����

������� ��������� ������ ���� ������������� ��� ������� ���������

����� ��������� �� ��������� �������� �� ����� ��� ����� ��� �����������

� ���� ������ ��� ��������� ��������� ������������ ��� ����������� ���

�������� ������� ��� ��� ������� �� ��� ����� ��������� ��� ������������ ���

������� ������� �������� ��� ���� ����� ��� ���� ��������� ���������

������������ ���� ������� �������� ��������� �������� ��� ��� ������ ������

��� ����������� ������ ��� ���� ���� �� ��� �������� �������� ���� ��� ����

�������

Increase of Total Revenue Sales. Total sales revenues for the industry as a 

whole (in adjusted dollars) have increased each consecutive year except for 

a brief decline from 1989 through 1991. This brief decline can be explained 

largelyby two factors: (1) Northwest Air Lines was private during those same 

years, so its revenues were not included in the industry data, and (2) Eastern 

Air Lines experienced a major labor strike that began in March 1989. As 

indicated by its financial data from 1989 to 1991, Eastern was able to continue 

Sector Notebook Project 16 February 1998 
Air Transportation Industry Description of Operations 

operation, in spite of the labor strike, by charging fares below its costs. 

Eastern’s unusually low fares may have caused other airlines to reduce fares 

in a similar fashion, and this reduced the total revenue earned by the industry 

as a whole. Current projections are that industry revenues will continue to 

rise due to the strengthened economy and a predicted 5% increase in airline 

traffic. 

Increased number of airlines. Following deregulation in 1978, the number 

of companies increased dramatically from about 36 carriers in 1978 to a total 

of 123 such carriers in 1984. This initial increase resulted from the market 

becoming more accessible to new companies that sought to operate below the 

costs of older, established airlines with higher cost structures. However, a 

clear decline in the number of air carriers in the late 1980s followed this initial 

increase due to weaker airlines being forced out of business or being taken 

over by the stronger companies. Then by 1993, the numbers increased again 

as numerous small airlines emerged, offering direct, low cost, no-frills service. 

To compete with these lower cost airlines, many of the larger airlines are 

initiating their own low cost divisions. The Brookings 1986 Report estimated 

that the traveling public was saving $5.7 billion a year (measured in 1977 

d o ll a rs) a s a r e s u lt of d e r e g u l a t i o n ( www. a ir ­

transport.org/handbk/chaptr02.htm). 

Expanded market. A major development since deregulation was the creation 

of hub and spoke networks. The hubs are strategically located airports used 

as transfer points for passengers traveling from one location to another. The 

hub and spoke systems were developed in order to enable airlines to serve far 

more markets, with the same size fleet, than the traditional direct, point-topoint service. 

Deregulation also sparked marketing innovations used by most major airlines 

and many smaller airlines that equate to fare discounts, such as the frequent 

flyer program that is designed to reward repeat customers with free tickets 

and other benefits. 

The appearance of new airlines, combined with the rapid expansion into new 

markets by many of the established airlines, resulted in unprecedented 

popularity and competition in the airline industry. In 1977, the last full year 

of government regulation of the airline industry, the US airlines carried 240 

million passengers. By 1993 they were carrying nearly 490 million. A study 

by the Department of Transportation a decade after deregulation found that 

well over 90% of airline passengers had a choice of carriers compared to only 

two-thirds in 1978 (www.air-transport.org/handbk/chaptr02.htm) 

III. DESCRIPTION OF OPERATIONS 

Sector Notebook Project 17 February 1998 
Air Transportation Industry Description of Operations 

This section describes the major operations and maintenance activities within 

the air transportation industry. The section is designed for those interested in 

gaining a general understanding of the industry, and for those interested in the 

relationship between the industrial process associated with air transportation, 

and the associated environmental aspects and potential impacts of the 

processes. This section is not exhaustive; the operations and maintenance 

activities discussed are intended to represent the air transportation practices 

and activities with potentially significant environmental impacts. These 

activities are presented in two categories: 

(1) Aircraft operations, including maintenance, cleaning, fueling, and 

deicing; and 

(2) Airport operations, including terminal activities, loading and off 

loading. 

This section does not attempt to replicate published engineering information 

that is available for this industry. Refer to Section VIII for a list of resource 

materials that are available. 

III.A. Aircraft Operations and Associated Environmental Aspects 

III.A.1. Aircraft and Aviation-Support Vehicle Maintenance 

Aircraft maintenance activities include scheduled preventive maintenance, 

repairs required as a result of inspections, and aircraft refurbishing. When an 

aircraft is built, the manufacturer creates a maintenance program for the 

operator of the plane. Representatives from the manufacturer, the Federal 

Aviation Administration (FAA), subcontractors, and the airline that purchases 

the aircraft form a review board that develops minimum requirements of a 

maintenance program. This maintenance program is then documented and 

followed throughout the aircraft’s life. 

Together, scheduled maintenance and day-to-day preventive activities are 

necessary to keep the aircraft safe and reliable. In general, aircraft 

maintenance is the function of three factors: (1) hours of flight time, (2) 

number of landing and take off cycles, and (3) calendar length of time from 

prior maintenance. Aircraft preventive maintenance starts with daily 

inspections of items such as tires, brakes, and fluid levels. The aircraft then 

continues to receive many levels of maintenance that include fluid and filter 

changes, detailed testing, inspections for cracks and corrosion, and after many 

hours of flying (usually over 100,000), complete refurbishing of the aircraft 

to return the plane to its original condition. 

Sector Notebook Project 18 February 1998 
Air Transportation Industry Description of Operations 

Aviation-support vehicles undergo a similar, yet less rigorous schedule of 

inspections, testing, and maintenance that includes oil and fluid changes, 

battery replacement, and repairs including metal machining. 

Environmental Aspects and Potential Impacts of Aircraft Maintenance 

Environmental aspects of aircraft maintenance include the use and disposal of 

aircraft and vehicle fluids such as: 

� Wastewater from parts cleaning, metal finishing, or coating 

applications 

� Generation of hazardous wastes consisting of flammable and metalscontaminated solvents, used hand-wipes, and sludges collected during 

all maintenance operations 

� Hazardous air pollutant (HAP) emissions from solvent-based cleaners 

and coatings used in all activities. 

Wastes generated as a result of aircraft and aviation-support vehicle 

maintenance and repair activities can include used oil, spent fluids, batteries, 

metal machining wastes, organic solvents, and tires. Some of these wastes 

can be toxic or otherwise hazardous, and uncontrolled releases can 

contaminate surface water, groundwater, and soils. Typical materials used in 

each operation and the potential impacts of use and disposal of these materials 

are identified in Exhibit 11. A description of these operations and associated 

environmental impacts appear below. 

Lubrication and Fluid Changes. Lubrication and fluid changes are part of 

the aircraft standard maintenance program. These activities occur at regular 

intervals, and as inspections indicate they are necessary. In conducting 

aircraft lubrication and fluid changes, these operations may generate waste oil 

and greases. These materials have the potential to contaminate water supplies 

and soil if not properly stored. By storing these materials in secure containers 

or tanks with secondary containment, the potential for releases to impact the 

environment is significantly reduced. 

Exhibit 11. Maintenance and Refurbishing Operations: Activities and 

Potential Environmental Impacts 

Operation Activities Environmental Aspects and 

Potential Impacts 

Lubrication and 

Fluid Changes 

Storage, transfer, 

and disposal of 

petroleum products 

Potential to contaminate soil, 

groundwater, and surface waters, if 

spilled or allowed to enter storm drains 

Sector Notebook Project 19 February 1998 
Air Transportation Industry Description of Operations 

Exhibit 11. Maintenance and Refurbishing Operations: Activities and 

Potential Environmental Impacts 

Operation Activities Environmental Aspects and 

Potential Impacts 

Battery repair and 

replacement 

Storage of batteries 

containing sulfuric 

acid 

Potential to contaminate soil, 

groundwater, and surface waters with 

hazardous material, if not contained 

and covered from weather 

Chemical Milling 

Maskant 

Application and 

Chemical Milling 

Use and disposal of 

maskants containing 

either toluene/xylene 

mixture or 

perchloroethylene 

Air pollution from organic HAP 

emissions, waste maskant 

Parts Cleaning Aqueous, semiaqueous, and 

solvent-based cleaner 

use and disposal 

Water pollution from wastewater 

containing cleaners, waste solvents; 

metals, oil, and grease 

Air pollution from organic HAP 

emissions 

Metal Finishing Use and disposal of 

processing solutions, 

cyanide, heavy metal 

baths 

Air pollution from HAP emissions; 

contaminated wastewater including 

cyanide solutions, corrosive acid and 

alkali solutions; heavy metal sludges 

Coating 

Application 

Primer and topcoats 

application and 

disposal 

Air pollution from organic HAP 

emissions; waste paint; waste solvent 

thinner 

Depainting Chemical or blast 

depainting agents 

use and disposal 

Contaminated sludge (stripper solution 

and paint residue); air contamination 

from VOC emissions from paints; 

solid waste containing paint chips and 

spent blasting media. 

Painting Paint use, storage, 

and disposal 

Soil or water contamination from 

disposal of waste paint, thinners, 

solvents, resins; air contamination by 

VOC emissions. 

Battery repair and replacement. Battery repair and replacement involve 

removing, repairing, and recharging aircraft and vehicle batteries. These 

operations have the potential to impact the environment if sulfuric acid in the 

batteries is released. Acid has the potential to contaminate soil and 

groundwater supplies, and to cause personnel injury if used batteries are not 

properly handled. By using proper safety equipment during handling, and 

storing batteries in a contained and covered area that is not exposed to rain 

water, batteries are less likely to cause a significant impact. 

Sector Notebook Project 20 February 1998 
Air Transportation Industry Description of Operations 

Chemical Milling Maskant Application and Chemical Milling. This 

operation uses etchant solutions to reduce the thickness of selected areas of 

metal parts in order to reduce weight. Chemical milling maskants are typically 

rubber- or polymeric-based coatings applied to an entire part or subassembly 

by brushing, dipping, spraying, or flow coating. After the chemical milling 

maskant is cured, it is removed from selected areas of the part where metal is 

to be removed during the chemical milling process. 

Chemical milling maskants typically contain either a toluene/xylene mixture 

or perchloroethylene as solvent constituents. These chemical solvents 

vaporize when exposed to air, and if not stored in tightly sealed containers, 

become a source of hazardous air pollutants (HAPs). These organic HAP 

emissions also occur as the solvent evaporates as the chemical milling maskant 

is applied and cured. 

Parts Cleaning. Aircraft components are cleaned frequently to remove 

contaminants such as dirt, grease, and oil. Cleaning is performed using a wide 

variety of cleaning materials, including aqueous, semi-aqueous, or, in some 

cases, solvent-based cleaners. Recently, many aircraft maintenance facilities 

have substituted solvent-based cleaners with water-based cleaning materials. 

Many components are cleaned with soap and water. 

Parts cleaning operations can include immersion, flush, spray gun cleaning, or 

hand wiping of aircraft components. For most parts, cleaning is typically 

performed by a hand wiping process. However, parts that are either too large 

or too intricate to hand wipe are cleaned by immersion in large solvent baths 

or parts cleaning machines. Assemblies and parts with concealed or 

inaccessible areas may be cleaned by pouring the cleaning material over or 

into the part. The cleaning material is then drained from the part and the 

procedure is repeated as many times as necessary to ensure the required 

cleanliness. 

The potential environmental impact of parts cleaning operations is dependent 

on the type of cleaning solution used. Halogenated, solvent-based cleaning 

materials potentially have the most significant impact. These solvents can 

generate organic HAP emissions from the evaporation of solvents during the 

cleaning process, including: (1) evaporation of solvent from open containers 

and solvent-soaked cloth and paper, and (2) emissions from storage tanks 

used to store cleaning solvents. In addition, solvent spills have the potential 

to contaminate soil, groundwater, or surface water. Contamination can be 

caused by hazardous constituents found in solvents themselves, as well as in 

metals, oils, and other potential contaminants found in the parts being cleaned. 

Spent hazardous solvents must be managed as hazardous wastes. Typically, 

they are reclaimed by a RCRA permitted hazardous waste recycler. 

Sector Notebook Project 21 February 1998 
Air Transportation Industry Description of Operations 

Facilities that use aqueous or semi-aqueous cleaning materials have a much 

less significant potential environmental impact because they do not generate 

hazardous air emissions. They do, however, generate metals, oil, and grease 

in the aqueous system that have the potential to contaminate water supplies. 

Wastewater from these cleaning processes is required to be treated onsite in 

accordance with the facility’s wastewater discharge permit (known as a 

National Pollutant Discharge Elimination System or NPDES permit) or 

according to standards set by any local pretreatment programs. 

Metal Finishing. Metal finishing processes are used to prepare the surface 

of a part for better adhesion, improved surface hardness, and improved 

corrosion resistance. Typical metal finishing operations include chemical 

conversion coating, anodizing, electroplating, and any operation that 

chemically affects the surface layer of a part. Each of these metal finishing 

operations has the potential to significantly impact the environment by 

discharging metals, cyanides, phosphates, acids, and other contaminants to 

waterways, soil, or groundwater. 

HAP emissions and contaminated wastewater are the most significant 

environmental aspects of metal finishing operations. As the organic chemicals 

in the processing solutions evaporate, they generate hazardous vapors and 

emissions. Evaporation of solution also occurs from refurbished parts as they 

are removed from the processing tanks. Wastewater from these operations 

includes cyanide solutions, corrosive acid, and alkali solutions. This water is 

typically treated prior to discharge, in accordance with a facility’s NPDES 

permit or applicable pretreatment requirements. For more details on metal 

finishing processes and the associated environmental aspects, see EPA’s 

Sector notebook titled Profile Of The Fabricated Metal Products Industry 

(EPA 310-R-95-007). 

Coating Application. A coating is a material that is applied to the surface of 

a part to form a decorative or functional solid film. The most common 

coatings are primers and topcoats. Coatings are applied to aircraft 

components using several methods of application. The methods most 

commonly used are spraying, brushing, rolling, flow coating, and dipping. 

Nearly all coatings contain a mixture of organic solvents. Spray guns and 

other components of coating units must be cleaned when switching from one 

coating to another. The cleaning of spray guns involves disassembling the gun 

and placing the parts in a vat containing an appropriate solvent. The residual 

coating is brushed or wiped off the parts. 

Organic HAP emissions from coating application are generated from 

evaporation of solvents during mixing, application, and fromoverspray, which 

is exhausted from spray booths or hangars. Coating operations also 

Sector Notebook Project 22 February 1998 
Air Transportation Industry Description of Operations 

produce waste paint and waste solvent thinner that are typically drummed and 

shipped offsite as RCRA hazardous waste. 

Depainting. Depainting involves the removal of coatings from the outer 

surface of aircraft. Two methods are chemical stripping and blast depainting. 

During chemical stripping, stripping agents are applied to the aircraft, allowed 

to degrade the coating, and then scraped or washed off with the coating 

residue. Blast depainting methods use a media such as plastic, wheat starch, 

carbon dioxide, or high pressure water to remove coatings by physically 

abrading the coatings from the surface of the aircraft. Depainting operations 

can produce either a liquid or solid waste stream, depending on the type of 

process used. 

Air pollution and soil or water contamination are potential impacts from 

depainting. Chemical depainting generates organic HAPs from evaporation 

of the solvents in the stripping solution, while particulate emissions occur 

from the blasting media. Depainting operations can produce either a liquid or 

solid waste stream, depending on the type of process. Chemical depainting 

processes produce a liquid sludge that consists of the stripper solution and 

paint residue. Blast depainting processes produce a solid waste stream that 

consists of paint chips and spent blasting media. These wastes are required 

to be characterized as hazardous or nonhazardous and disposed of 

appropriately. 

Painting. Aircraft painting generally occurs in an enclosed area to minimize 

potential environmental and human health impacts. High pressure, low 

volume, and electrostatic painting systems can reduce the amount of paint 

needed for a job. 

Aspects of painting with potential environmental impacts include management 

of unused paints, spray paint booth air filters, and spent paint thinner, and 

emissions of volatile organic compounds (VOCs) from thinners and solvents. 

Spent paint filters often must be handled as hazardous waste because of the 

presence of wet paint or paint containing lead or chromium. Through proper 

training of employees and the use of high efficiency equipment, painting 

operations have been able to reduce paint waste, minimize air emissions, and 

protect the health of employees. 

Sector Notebook Project 23 February 1998 
Air Transportation Industry Description of Operations 

III.A.2. Fueling 

An essential part of any airport operation is the fueling of aircraft. Fueling is 

conducted either by tank trucks or a central underground fueling system. In 

both operations, fueling involves the transfer of a potentially hazardous liquid 

to the aircraft. Aviation fuels are broken down into two classes. The 

reciprocating engines use various grades of aviation gasoline, while the jet 

class, which includes gas turbines, utilizes jet fuels. There are grades of 

aviation gasoline that are readily identified by the color-coded dyes added to 

them. The color-coded system aids maintenance personnel in finding fuel 

leaks when they occur and prevents fueling mixups. 

For jet fuel, there are two basic grades of jet fuel, Jet-A and Jet-B. Jet-A fuel, 

a narrow cut kerosene product, is the standard commercial and general 

aviation grade available in the United States. It usually contains no additives 

but may be additized with an anti-icing chemical. Jet-A1 is identical to Jet-A 

except that it has a lower freeze point. It is used outside the United States 

and is the fuel of choice for long haul flights where the fuel temperature may 

fall to near the freeze point. It often contains a static dissipator additive. 

Jet-B fuel is a wide cut kerosene with lighter gasoline-type naphtha 

components. It is not used by the commercial air transportation sector, 

however, it is used by the military. 

Fuel tanks are generally located in the wings of light aircraft. However, 

depending on the make and model of the aircraft, it is also common to find 

fuel tanks in the main fuselage. Fuel lines range in diameter from 1/8 of an 

inch to as large as 4 inches on very large aircraft. Fuel lines of aircraft using 

wing tanks are located back from the leading edge of the wing. With fuselage 

tank model twin-engine aircraft, the fuel lines run from the fuselage tanks out 

through the wing structure along the wing spar into the engine compartment. 

On single-engine aircraft, the fuel lines are routed from the fuel tank to the 

firewall, and then to the engine. 

Environmental Aspects and Potential Impacts of Fueling 

The major environmental aspect of fueling operations is managing the fuel so 

that it is not released to the environment, either to the air, water, or soil. 

Leaking pipes or improper connections between fueling lines and the aircraft 

can allow fuel vapors to be released to the air, causing air contamination. 

Leaks, improper connections, and improperly monitored storage tanks ����

can lead to fuel spills. As a contingency measure, many airports and airlines 

employ vacuum sweeper trucks as well as hand operated sweeper units for 

spill response. Vacuum sweepers allow the spilled material to be removed 

������� from the site while minimizing the spill’s potential to impact the 

environment. If spills are not contained or diverted to an established 

Sector Notebook Project 24 February 1998 
Air Transportation Industry Description of Operations 

treatment system, they may end up being discharged to soil and groundwater 

either directly through storm drains, or as sheet runoff during rain events. 

Underground fueling systems that are not maintained properly can leak into 

the surrounding soils and eventually contaminate groundwater. EPA 

regulations for underground storage tanks require tanks to be upgraded and 

monitored to reduce the probability of leaks to groundwater. 

By conducting activities to prevent releases such as maintaining fuel tanks, 

lines, and fueling systems, and by assuring proper training of employees, the 

possibility of leaking tanks, equipment leaks, or accidental spillage is reduced 

�������������. 

III.A.3. Aircraft Cleaning 

Exterior cleaning of aircraft typically consists of washing with detergent 

solutions and a water rinse. Small aircraft cleaning is carried out using hand 

held spray nozzles, hoses and brushes. For larger aircraft, wet cleaning 

������� is limited to wheel wells and landing gear and is conducted to facilitate 

inspections. In addition, wet cleaning ��������� is performed on wing 

structure and flap-sequencing carriage areas for overhaul and inspection 

processes and on the lower aircraft fuselage for removal of accumulations of 

oil and grease. 

Because it can be more economical (e.g., lower water costs) to dry polish 

aircraft fuselages rather than wash them with water and cleaning solutions, 

aircraft are cleaned using dry methods whenever possible. 

Environmental Aspects and Potential Impacts of Cleaning 

The primary environmental aspect of aircraft cleaning is the generation and 

disposal of wastewater from cleaning aircraft exteriors. If high pressure steam 

cleaners are used, water use may range from 10-20 gallons for washing small 

aircraft, and between 100 and 200 gallons for large aircraft.

2 Wastewater 

from cleaning activities may contain diluted cleaning chemicals, low 

concentrations of metals, oil and grease, solvents, dirt and grit, or other 

materials that are used as detergents, or are found in the aircraft itself. If not 

treated, the washwater has the potential to pollute the soil, groundwater, and 

surface waters. 

2 A Boeing 727 is an example of a narrow-body aircraft, while MD-11's, Boeing 747's and 767's are examples of 

wide-body aircraft. 

Sector Notebook Project 25 February 1998 
Air Transportation Industry Description of Operations 

To prevent such contamination, wastewater from cleaning operations usually 

drains to catch basins where it is mixed with other airport wastewater and 

discharged at an onsite treatment facility prior to discharge in accordance with 

the facility’s NPDES permit. Prior to discharge, the wastewater may also 

pass through a holding tank where metals, dirt, and grit settle to the bottom, 

oil and grease are skimmed off the water surface, and the remaining water is 

discharged. If the washwater is not treated onsite, it may be discharged to a 

publicly owned treatment works (POTW), where it is treated prior to 

discharge. Washwater discharged to the POTW may be subject to 

pretreatment requirements established by EPA and the POTW. 

III.A.4. Aircraft Deicing and Anti-Icing 

As noted earlier, FAA regulations govern every aspect of airline and airport 

operations, including procedures and standards for aircraft maintenance and 

airworthiness, including aircraft deicing. Aircraft deicing and anti-icing are 

key components in assuring cold weather aircraft safety. Deicing and antiicing remove from and inhibit for a period of time the formation of ice and 

snow on wings, fuselages, and other parts of the airplane that provide lift 

during takeoff. Common practice is to deice (remove accumulation) then 

anti-ice (protect from further accumulation) aircraft before takeoff. These 

processes use glycol-based materials, including ethylene glycol, diethylene 

glycol, or propylene glycol. 

Aircraft deicing is carried out either at the departure gate area or at a central 

or remote facility in the vicinity of the runway to minimize the amount of time 

between treatment and takeoff. Central and remote deicing areas facilitate 

collection of deicing fluids for recycling and treatment. 

Deicing is almost performed exclusively using hand held nozzles and hoses. 

Automatic deicer spray machines, called “������� ��������”, have been 

developed in recent years. However, there are some limitations on the 

practicality of such equipment and the associated capital investment. 

Environmental Aspects and Potential Impacts of Deicing 

Deicing operations generate spent deicer fluids. These fluids drain from the 

aircraft surfaces or from the runway surfaces to drains that direct the fluids to 

onsite water treatment facilities, to storm drains, or simply to paved surfaces 

where they may be discharged to local waterways or groundwater as sheet 

runoff. In some cases, deicing fluids may be released directly to the 

environment through runoff to surface waters or infiltration to groundwater. 

Glycol-based fluids deplete oxygen from the waters in which they are disposed 

and have toxic effects on life forms in those waters (Aviation Week and Space 

Technology, January 1995). 

Sector Notebook Project 26 February 1998 
Air Transportation Industry Description of Operations 

In general, each airport has its own distinct characteristics and drainage 

systems and collecting deicing fluid for reuse or recycling may not be 

practical. However, some airports have constructed deicing fluid collection 

systems that prevent discharge to storm water sewers and segregate spent 

deicer from other wastewater for reclamation, recycling, onsite treatment, or 

disposal offsite. FAA allows the reuse of deicing fluids that are reformulated 

and re-certified to meet appropriate aircraft deicing fluid specifications. 

However, at this time, the aviation industry has not recycled glycols for reuse 

on aircraft or runways due to cost. Some reclaimed deicing fluids may be sold 

in secondary markets (e.g., windshield deicers for automobiles). In 

compliance with Clean Water Act requirements, spent deicing fluids are 

treated ������ in the facility wastewater treatment system, discharged to 

publicly owned wastewater treatment plants, or discharged directly to surface 

waters in accordance with permit conditions. 

III.A.5. General Aircraft Operational Activities 

As discussed earlier, the FAA has jurisdiction over all aircraft operations and 

prohibits states and local governments from regulating in the areas of aircraft 

operations and airspace management. In addition, the exclusive jurisdiction 

also extends to environmental statutes as they relate to the aviation industry. 

For example, Section 233 of the Clean Air Act specifically prohibits states 

from regulating air pollution from aircraft engines. 

Aircraft Operation. The mode of operation of the aircraft can be broken 

down into five stages: idling at gate and runway; engine power up; taxiing; 

takeoff and climb out; and approach and landing. Depending on the type of 

engine and aircraft, these activities can consume varying amounts of resources 

and produce various pollutants. Because fuel is the airline industry’s second 

largest expense, increasing fuel efficiency of aircraft engines has been a top 

priority of U.S. airlines. Over the past two decades, U.S. airlines have 

increased fuel efficiency nearly 50% by lowering cruising speeds, using 

computers to determine optimum fuel loads and to select altitudes and routes 

that minimize fuel burn; and keeping aircraft exteriors trimmed (i.e., stowed) 

to minimize aerodynamic drag.

3 

The environmental aspects of aircraft operation are related to the use and 

burning of fuel. Fuelhas the potential to cause varying environmental impacts 

depending on the type of fuel, the efficiency of burning, and the manner in 

which excess fuel is discarded. During aircraft operations, engines emit 

hydrocarbons, carbon monoxide, and nitrogen oxides (NOx). Hydrocarbon 

and carbon monoxide emissions result from incomplete combustion at the 

lower power settings for descent, or when idling or taxiing on the ground. 

3 The Airline Handbook, Chapter 9: Airlines and the Environment from the Air Transport Association, 1997. 

Sector Notebook Project 27 February 1998 
Air Transportation Industry Description of Operations 

NOx, the result of combustion products mixing with nitrogen in the air, is 

produced when engines are at their hottest, such as during takeoffs and, to a 

lesser extent, during cruise when jet engines also produce carbon dioxide and 

water vapor. 

Aircraft loading and off loading. Aircraft loading and off loading includes 

all activities associated with the movement of materials, items, and people in 

and out of airplanes. Regardless of the type of airport, aircraft loading and off 

loading occur an infinite number of times daily throughout the U.S. Aircraft 

cargo loads consist of several different items, including but not limited to 

passengers, baggage, mail, live animals, dangerous goods (including 

hazardous materials), and wet cargo (e.g., fresh fish, seafood, meat, casings, 

etc.). 

The primary loading and off loading activity with a potentially significant 

impact on human health and the environmental is the loading and off loading 

of hazardous materials. Though a rare occurrence, these loading activities 

have the potential to contaminate soil, groundwater, or surface water in the 

event of a spill or release. Facilities minimize and control these impacts 

through development and implementation of spill prevention control and 

countermeasures plans, storm water pollution prevention plants, and other 

emergency response programs. 

If hazardous materials are transported by aircraft, the materials are subject to 

U.S. Department of Transportation (DOT) requirements that regulate aircraft 

inspections, placement of materials, packaging, and shipping papers (e.g., 

waybills, manifests). If hazardous materials are loaded onto an airplane, 

containers should be inspected for proper labeling/placarding, any signs of 

leakage, and compatibility with other hazardous materials. If damage or 

spillage of a package containing hazardous materials is observed on board an 

aircraft or during loading/off loading, immediate action must be taken in 

accordance with company or airport procedures. 

Transportation of Dangerous Goods. Once hazardous materials are loaded 

onto aircraft, they are transported to their destination. In preparation for 

transport, they are stored, segregated and secured to assure safety during the 

transportation process. If improperly stored and secured, dangerous goods 

have the potential to not only impact the health of workers and passengers, 

but also to impact the safety of the aircraft itself. 

To assure that these goods are transported in a safe manner, regulations have 

been established by DOT and the International Civil Aviation Organization 

(ICAO) Dangerous Goods Panel. These standards regulate the types of 

materials that can be transported, and the types of aircraft in which they can 

be transported. The ICAO Dangerous Goods regulations include a detailed 

Sector Notebook Project 28 February 1998 
Air Transportation Industry Description of Operations 

list of individual articles and substances specifying the United Nations 

classification of each article or substance, their acceptability for air transport, 

and the conditions for their transport. 

According to the regulations, dangerous goods may be transported in one of 

the following ways: they may not be carried on any aircraft under any 

circumstances; they are forbidden under normal circumstances, but may be 

carried with specific approvals from the States concerned; they may be carried 

only on cargo aircraft; or they may be safely carried on passenger aircraft, 

provided certain requirements are met. It should be noted that most 

dangerous goods fall into the latter transport category. 

The ICAO Dangerous Goods regulations also provide packing instructions 

for all dangerous goods acceptable for air transport with a wide range of 

options for inner, outer, and single packaging. In addition, all individuals 

involved in the preparation or transport of dangerous goods must be properly 

trained to carry out their responsibilities. Information on the goods must be 

conveyed by the pilot to air traffic services to aid in the response to any 

aircraft incident or accident. Finally, dangerous goods accidents or incidents 

must be reported, so that an investigation by the relevant authorities can 

establish the cause and take corrective action. 

Aircraft Noise. Another type of pollution generated from the operation of 

aircraft is noise pollution. Noise from airports is a significant negative impact 

for many people in the airport vicinity. Federal noise regulations require all 

large aircraft to meet noise standards. FAR Part 150 regulations address the 

issue of aircraft noise and provide a comprehensive scheme for planning and 

mitigation measures funded by aviation trust funds intended to reduce noise 

impacts on the public (US EPA Office of Federal Activities, Pollution 

Prevention/Environmental Impact Reduction Checklist for Airports)�

Air Pollutants from Transportation 

The EPA Office of Air Quality Planning and Standards has compiled air 

pollutant emission factors for determining the total air emissions of priority 

pollutants (e.g., total hydrocarbons, SOx, NOx, CO, particulates, etc.) from 

many transportation sources. The Aerometric Information Retrieval System 

(AIRS) contains a wide range of information related to stationary sources of 

air pollution, including the emissions of a number of air pollutants which may 

be of concern within a particular industry. Exhibit 12 summarizes annual 

releases (from the industries for which a Sector Notebook Profile was 

prepared) of carbon monoxide (CO), nitrogen dioxide (NO2), particulate 

matter of 10 microns or less (PM10), total particulates (PT), sulfur dioxide 

(SO2), and volatile organic compounds (VOCs). 

Sector Notebook Project 29 February 1998 
Air Transportation Industry Description of Operations 

Exhibit 12. Annual Air Pollutant Releases by Industry Sector (tons/year) 

Industry Sector CO NO2 PM10 PT SO2 VOC TOTALS 

Power Generation 366,208 5,986,757 140,760 464,542 13,827,511 57,384 20,843,162 

Petroleum Refining 734,630 355,852 27,497 36,141 619,775 313,982 2,087,877 

Iron and Steel 1,386,461 153,607 83,938 87,939 232,347 83,882 2,028,174 

Pulp and Paper 566,883 358,675 35,030 111,210 493,313 127,809 1,692,920 

Stone, Clay, and Concrete 105,059 340,639 192,962 662,233 308,534 34,337 1,643,764 

Transportation* 128,625 550,551 2,569 5,489 8,417 104,824 800,475 

Organic Chemicals 112,410 187,400 14,596 16,053 176,115 180,350 686,924 

Inorganic Chemicals 153,294 106,522 6,703 34,664 194,153 65,427 560,763 

Nonferrous Metals 214,243 31,136 10,403 24,654 253,538 11,058 545,032 

Lumber and Wood Production 122,061 38,042 20,456 64,650 9,401 55,983 310,593 

Metal Mining 4,670 39,849 63,541 173,566 17,690 915 300,231 

Nonmetal Mining 25,922 22,881 40,199 128,661 18,000 4,002 239,665 

Plastic Resins and Synthetic 

Fibers 

16,388 41,771 2,218 7,546 67,546 74,138 209,607 

Metal Casting 116,538 11,911 10,995 20,973 6,513 19,031 185,961 

Rubber and Misc. Plastics 2,200 9,955 2,618 5,182 21,720 132,945 174,620 

Motor Vehicles, Bodies, Parts 

and Accessories 

15,109 27,355 1,048 3,699 20,378 96,338 163,927 

Textiles 8,177 34,523 2,028 9,479 43,050 27,768 125,025 

Printing 8,755 3,542 405 1,198 1,684 103,018 118,602 

Fabricated Metals 4,925 11,104 1,019 2,790 3,169 86,472 109,479 

Pharmaceuticals 6,586 19,088 1,576 4,425 21,311 37,214 90,200 

Furniture and Fixtures 2,754 1,872 2,502 4,827 1,538 67,604 81,097 

Ship Building and Repair 105 862 638 943 3,051 3,967 9,566 

Electronics and Computers 356 1,501 224 385 741 4,866 8,073 

Dry Cleaning 102 184 3 27 155 7,441 7,912 

* “Transportation” includes air, water, railroad, trucking, and pipeline categories and SIC codes, and as such, 

represents a very broad range of industries. This represents stationary source air emissions only, not mobile 

sources. 

Source: U.S. EPA Office of Air and Radiation, AIRS Database, 1997. 

Sector Notebook Project 30 February 1998 
Air Transportation Industry Description of Operations 

III.B. Airport Operations 

Airport operations include all activities related to operating and maintaining 

the airport. These activities include operation and maintenance of runways, 

control towers, maintenance facilities, aircraft gates, baggage handling 

facilities, and general airport operations. This section focuses on two of these 

activities: runway deicing and general operations. 

III.B.1. Runway Deicing 

Airport runways, taxiways, and gate areas are sprayed with deicer and antiicer to remove and prevent the buildup of ice and snow that would inhibit 

taxing, takeoff, and landing. Pavement deicing/anti-icing breaks the bond 

holding ice and compacted snow to the surfaces of runways and taxiways, 

facilitating mechanical ice and snow removal, and allowing aircraft to maintain 

adequate friction between aircraft tires and the runway. Runway and ramp 

deicing is usually done with one or more substances (e.g., glycol, urea, sodium 

formate, and/or potassium acetate). Sand is usually reserved to prevent 

slippage at the gate area, but not on taxiways and runways due to potential 

engine ingestion hazards. 

Environmental Aspects and Potential Impacts of Runway Deicing 

Deicing mixtures have the potential to contaminate groundwater and surface 

water supplies as they flow from airport runways to storm drains or to 

waterways as sheet runoff. Sand has the potential to clog storm water drains 

and contaminate water bodies through increased erosion and sediment 

buildup. Deicing chemicals that mix with storm water discharges must be 

managed according to the facility’s NPDES storm water permit. In an effort 

to control water contamination, many facilities direct storm water to an onsite 

treatment facility prior to discharge. 

III.B.2. General Airport Operations 

General airport operations encompass manyactivities including passenger and 

vehicle traffic, ticketing, baggage handling, passenger security, and 

concessions and food services. Airports, like other administrative offices, can 

generate large quantities of waste paper and consume large amounts of energy 

from lighting, heating and cooling systems, and computers. Concession shops 

and food service operations can generate significant quantities of solid waste, 

such as corrugated cardboard, paperboard, office paper, newspapers, 

magazines, wooden pallets, aluminum, plastic, and glass containers, as well 

as leftover food. Groundskeeping and landscaping activities can generate 

waste pesticides and herbicides. Airport traffic congestion can generate 

significant air emissions. 

Sector Notebook Project 31 February 1998 
Air Transportation Industry Description of Operations 

Environmental Aspects and Potential Impacts of General Operations 

The operation of airports can have a variety of impacts on the environment. 

These impacts include erosion, sedimentation, soil compaction, noise 

pollution, chemical pollution resulting from aircraft maintenance and deicing, 

aircraft emissions, contaminated runway and grounds runoff, generation of 

waste construction materials, and litter and other debris from administrative 

and food service operations. 

In regards to wildlife, there is typically no significant destruction of wildlife 

habitat. FAA is, however, aware of the problem that certain species (e.g., 

large waterfowl, birds that flock, deer) cause aviation. As a result, FAA 

encourages, and in some cases requires, airport sponsors to work with wildlife 

agencies to manage the habitat attracting these species. Such measures are 

needed to reduce the number of collisions between these species and aircraft 

to protect human and wildlife populations. 

Sector Notebook Project 32 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

IV. POLLUTION PREVENTION OPPORTUNITIES 

The best way to reduce pollution is to prevent it in the first place. Some 

companies have creatively implemented pollution prevention techniques that 

improve efficiency and increase profits while at the same time minimizing 

environmental impacts. Airlines and airports are reducing material inputs, reengineering processes to reuse by-products, improving management practices, 

and employing substitution of toxic chemicals. Some operations are able to 

actually get below regulatory thresholds just by reducing pollutant releases 

through aggressive pollution prevention policies. While implementing 

pollution prevention techniques, it is important that the facility assure that 

the techniques are conducted in accordance with FAA safety regulations 

and airworthiness requirements. FAA’s Advisory Circular entitled, 

“Management of Airport Industrial Waste”(AC#150/5320-15), provides 

guidance on managing industrial wastes that airport operations generate. 

The Pollution Prevention Act of 1990 established a national policy of 

managing waste through source reduction, which means preventing the 

generation of waste. The Pollution Prevention Act also established as national 

policy a hierarchy of waste management options for situations in which source 

reduction cannot be implemented feasibly. In the waste management 

hierarchy, if source reduction is not feasible, the next alternative is recycling 

of wastes, followed by energy recovery, and �� � ���� ������������ waste 

treatment. 

In order to encourage these approaches, this section provides both general 

and company-specific descriptions ofsome pollution prevention advances that 

have been implemented within the air transportation industry. While the list 

is not exhaustive, it does provide core information that can be used as the 

starting point for facilities interested in beginning their own pollution 

prevention projects. This section provides summary information from 

activities that may be or are being implemented by this sector. When possible, 

information is provided that gives the context in which the technique can be 

used effectively. 

Please note that the activities described in this section do not necessarily apply 

to all facilities that fall within this sector. Facility-specific conditions must be 

considered ��������� when pollution prevention options are evaluated, and the 

full impacts of each option must be evaluated for its effects on air, land, and 

water pollutant releases. 

Waste minimization generally encompasses any source reduction or recycling 

that results in either the reduction of total volume or the toxicity of hazardous 

waste. Source reduction is a reduction of waste generation at the source, 

Sector Notebook Project 33 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

usuallywithin a process. Source reduction can include processmodifications, 

feedstock (raw material) substitution, housekeeping and management 

processes, and increases in efficiency of machinery and equipment. Source 

reduction includes any activity that reduces the amount of waste that exits a 

process. Recycling refers to the use or reuse of a waste as an effective 

substitute for a commercial product or as an ingredient or feedstock in an 

industrial process. 

IV.A. Air Transportation Operations 

Pollution prevention/waste minimization opportunities in the air transportation 

industry are available for many operations including aircraft and vehicle 

maintenance and repair, washing and cleaning, deicing, fueling, aircraft 

modification, and airport layout and operations. These areas are addressed 

in the following sections. 

IV.A.1. Maintenance and Refurbishing Operations 

Aircraft maintenance activities generate wastes that are of great environmental 

concern to the air transportation industry. The major wastestreams from 

aircraft maintenance and refurbishing are lubricants, batteries, scrap metal, 

parts cleaning wastes (e.g., solvents), depainting wastes (e.g., chemical paint 

stripping wastes, abrasive blast and surface preparation wastes), and 

painting/painting equipment cleaning wastes. Source reduction is the best 

pollution prevention approach for reducing the amount of wastes produced. 

Source reduction can be achieved through material substitution, process or 

equipment modification, recycling, or better operating practices. Note: Such 

modifications must be made in accordance with FAA requirements, as well 

as the extraordinarily specific maintenance practices recommended by 

airframe and engine manufacturers. The following material presents 

pollution prevention/waste minimization opportunities for each type of waste. 

Used Oil and Lubricants. Most airline maintenance facilities recycle used oil. 

Recycling used oil requires equipment like a drip table with a used oil 

collection bucket to collect oil dripping off parts. Drip pans can be placed 

under aviation-support vehicles awaiting repairsin case they are leaking fluids. 

Some facilities use absorbent materials (e.g., “pigs” or “quick dry”) to catch 

drips or spills during activities where oil drips may occur. While absorbents 

prevent oil from impacting the environment, they actually create more solid 

and potentially hazardous waste in the form of contaminated absorbent 

materials. Preventing small spills in the first place, using drip pans, or cleaning 

spills with rags, soap and water can prevent the generation of additional 

waste. Recycling used oil by sending it to a commercial recycling facility 

saves money and protects the environment. 

Sector Notebook Project 34 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

To encourage recycling, the publication How To Set Up A Local Program To 

Recycle Used Oil is available at no cost from the RCRA/Superfund Hotline 

at 1-800-424-9346 or (703) 412-9810. 

Spent petroleum-based fluids and solids should be sent to a recycling center 

whenever possible. Solvents that are hazardous waste must not be mixed with 

used oil. If they are mixed, the entire mixture may be considered hazardous 

waste, and thus subject to more stringent regulation. Non-listed hazardous 

wastes will be mixed with waste oil, and as long as the resulting mixture is not 

hazardous, can be handled as waste oil. All used drip pans and containers 

should be labeled ��������. 

Fluids. Aircraft and aviation-support vehicles require regular changing of 

fluids, including oil, coolant, and others. To minimize releases to the 

environment, these fluids should be drained and replaced in areas where there 

are no connections to storm drains or municipal sewers. Minor spills should 

be cleaned prior to reaching drains. Used fluid should be collected and stored 

in separate containers. Fluids can often be recycled. For example, brake fluid, 

transmission gear, and gear oil are recyclable. Some liquids are able to be 

legally mixed with used motor oil which, in turn, can be reclaimed. 

During the process of engine maintenance, spills of fluids are likely to occur. 

The “dryshop” principle encourages spills to be cleaned immediately, without 

waiting for the spilled fluids to evaporate into the air, to transmit to land, or 

to contaminate other surfaces. The following techniques help prevent spills: 

� Collect leaking or dripping fluids in designated drip pans or 

containers. Keep all fluids separated so they may be properly 

recycled. 

� Keep a designated drip pan under the vehicle while unclipping hoses, 

unscrewing filters, or removing other parts. The drip pan prevents 

splattering of fluids and keeps chemicals from penetrating the shop 

floor or outside area where the maintenance is occurring. 

� Immediately transfer used fluids to proper containers. Never leave 

drip pans or other open containers unattended. 

Radiator fluids from aviation-support vehicles are often acceptable to 

antifreeze recyclers. This includes fluids used to flush out radiators during 

cleaning. Reusing the flushing fluid minimizes waste discharges. If a licensed 

recycler does not accept the spent flushing fluids, consider changing to 

another brand of fluid that can be recycled. Many maintenance facilities have 

purchased antifreeze recycling systems that connect directly to a vehicle so 

Sector Notebook Project 35 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

that the antifreeze is taken from the vehicle, cleaned, and then put back into 

the same vehicle. 

If the maintenance facility services air conditioners in aviation-support 

vehicles, special equipment must be used to collect the freon or other 

refrigerant because it is not permissible to vent the refrigerant to the 

atmosphere. Air conditioner maintenance activities require employee training, 

specifically for handling refrigerants. Reusing refrigerants onsite is less costly 

than the only other legal alternative, sending the refrigerant to an offsite 

recycler. 

Batteries. Facilities have many battery disposal options: recycling onsite, 

recycling through a supplier, or direct disposal. Facilities should explore all 

options to find one that is right for the facility. Many waste batteries must be 

handled as hazardous waste. Lead acid batteries are not considered hazardous 

waste as long as they are recycled. In general, recycling batteries may reduce 

the amount of hazardous waste stored at a facility, and thus the facility’s 

responsibilities under RCRA. The following best management practices are 

recommended when sorting used batteries: 

� Place on pallets in a contained area, and label by battery type (e.g., 

lead-acid, nickel, and cadmium). 

� Protect them from the weather with a tarp, roof, or other means. 

� Store them on an open rack or in a watertight, secondary containment 

unit to prevent leaks. 

� Inspect them for cracks and leaks as they are removed from the 

vehicle or aircraft. If a battery is dropped, treat it as if it is cracked. 

Acid residue from cracked or leaking batteries is likely to be 

hazardous waste under RCRA because it is likely to exhibit the 

characteristic of corrosivity, and may contain lead and other metals. 

� Avoid skin contact with leaking or damaged batteries. 

� Neutralize acid spills and dispose of the resulting waste as hazardous 

if it still exhibits a characteristic of a hazardous waste. 

Machine Shop Wastes. The major hazardous wastes from metal machining 

are waste cutting oils, spent machine coolant, and degreasing solvents. 

However, scrap metal also can be a component of hazardous waste produced 

at a machine shop. Material substitution and recycling are the two best means 

to reduce the volume of these wastes. 

Sector Notebook Project 36 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

The preferred method of reducing the amount of waste cutting oils and 

degreasing solvents is to substitute them with water-soluble cutting oils. 

Recycling of waste cutting oils also is possible if nonwater-soluble oils must 

be used. Machine coolant can be recycled, and a number of proprietary 

systems are available to recycle the coolant. Coolant recycling is implemented 

���� ������ when a standardized type of coolant is used throughout the shop. 

Reuse and recycling of solvents also are achieved ������, as mentioned above. 

Most shops collect scrap metals from machining operations and sell these to 

metal recyclers. Metal chips which have been removed from the coolant by 

filtration should be drained and included in the scrap metal collection. Wastes 

should be segregated ��������� to facilitate reuse and recycling. 

Small Parts Cleaning. Solvents are commonly used for small parts cleaning. 

Spent solvents are often toxic and/or hazardous and should be disposed of in 

an environmentally safe manner. Spent solvent, if hazardous, must be treated 

and disposed of as hazardous waste, unless recycled properly. There are 

several options for reducing the amount and/or toxicity of spent solvents: 

� Switch to non-hazardous substances. Switch from hazardous, 

organic-based to non-hazardous, aqueous-based solvents. In addition, 

certain aqueous parts washers can use detergents instead of solvents. 

Whilewater-based parts washers may be more expensive thansolventbased parts washers (costs range from $1,000 to $3,000 for waterbased washers capable of washing small parts), the cost of the parts 

washer can be quickly recovered as the cost of disposing or recycling 

of hazardous solvent as well as the cost of any required training for 

workers handling the solvent are eliminated. This will reduce the 

amount of hazardous waste generated from cleaning operations. 

� Keep lids closed when not in use. For solvents that contain volatile 

organic compounds, keeping containers closed except when parts 

�������� are being cleaned reduces solvent emissions to the 

atmosphere, improves worker safety, and allows the solvent to be 

used longer, rather than simply to evaporate. 

� Reuse. Solvents can be reused �� ������� ������������ ��� ��� and 

until their effectiveness is compromised, and then they can be 

recovered and recycled. 

� Recycle. Solvent recycling ���� can decrease hazardous waste 

production from small parts cleaning. Spent solvents can be cleaned 

and recycled with a solvent still. Processes for recycling solvents are 

well established and widely used in many industrial sectors. Solvents 

should not be poured down sewer drains, mixed with used oil, or 

Sector Notebook Project 37 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

stored in open containers to allow them to evaporate. Solvent stills 

(e.g., distillation units) may only be installed in appropriately fire rated 

areas. 

� Use good housekeeping practices. To minimize solvent waste 

generation, facilities should use good housekeeping practices 

including labeling of all chemicals and wastes to avoid misuse and 

potential injury or contamination; keeping containers of hazardous 

solvents closed to prevent air emissions; providing storage area leak 

control and containment; and making improvements in drum location, 

product transfer leak collection, and drum transport procedures. If 

solvents are used, care should be taken to wear protective safety gear 

and follow good housekeeping practices. 

Depainting 

Chemical Stripping Wastes. Chemical stripping operations must be 

conducted according to the appropriate and relevant requirements associated 

with the original equipment manufacturers’ specifications. Chemicalstripping 

wastes consist primarily of stripping agent and paint sludges. Methylene 

chloride is the most commonly used paint stripping agent, although the 

industry increasingly is using less toxic agents such as dibasic esters, semiaqueous, terpene-based products, aqueous solutions of caustic soda, and 

detergent-based strippers that currently are available on the market. In order 

to reduce compliance costs, many facilities are replacing methylene chloride 

with nonhalogenated strippers. 

The Aerospace National Emission Standards for Hazardous Air Pollutants 

(NESHAP) (effective September 1998) places stringent limitations on the use 

of chemical strippers containing hazardous air pollutants. (See discussion in 

Section V.C Pending and Proposed Regulatory Requirements.) 

Storing and reusing or recycling used strippers also are effective waste 

minimization techniques. Solvent strippers, particularly stripping baths, 

��������� can be reused several times before their effectiveness is diminished. 

Both spent caustic and organic stripping solutions can be treated to remove 

contaminants. Segregating the spent stripping wastes from other waste 

streams will help facilitate cost-efficient reuse and recycling of contaminated 

strippers. 

Abrasive Blasting and Surface Preparation Wastes. Abrasive blasting is 

being used as an alternative for chemical paint stripping. Although blasting 

does not require disposal of chemical strippers, it does create a large amount 

of water runoff and air pollution, and the presence of paint chips containing 

Sector Notebook Project 38 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

hazardous metals and organometallic biocides can make abrasive blasting 

wastes potentially hazardous. Research and testing are underway on a 

number of innovative alternative paint removal and surface preparation 

techniques including: plastic media blasting, steel shot slingers, water jet 

stripping, thermalstripping, dryice pellets, laser paint stripping, and cryogenic 

stripping. However, an alternative as economically viable and easy as 

chemical paint stripping has not been found. 

� Plastic media blasting has had mixed results. The same types and 

quantities of solid wastes are generated as with grit blasting, but the 

plastic media tend to be more easily recyclable through the use of 

pneumatic media classifiers that are part of the stripping equipment. 

The abrasion eventually turns the plastic media to dust, making the 

waste paint the main waste to be disposed. However, it will not work 

on epoxy or urethane paints. In addition, the blasting equipment is 

more expensive and requires more highly trained operators. 

� Cavitating water jet stripping systems remove most paints, separate 

the paint chips from the water, and treat the water to eliminate 

dissolved toxic materials. Although relatively little hazardous waste 

is generated by this process, it is not as efficient as grit blasting, and 

the equipment has higher capital and operating costs. 

� The thermal stripping process softens the paint so it can be peeled 

relatively easily. Although it generates only one waste stream (waste 

paint), it is more labor-intensive than other stripping methods and can 

only be used on non-heat-sensitive surfaces. 

� Carbon dioxide pellets can be used as a blast medium leaving only 

paint chips that can be swept up and placed in containers for disposal 

(the dry ice evaporates). However, the cost of the dry ice, storage, 

and handling equipment can be substantial. 

� A pulsed carbon dioxide laser controlled by an industrial robot to 

remove paint produces no residue. However, the method is complex, 

capital intensive, and requires highly skilled operators. 

� Cryogenic stripping using liquid nitrogen baths followed by gentle 

abrasion or plastic shot blasting is useful for small parts or objects, but 

requires special equipment for handling the liquid nitrogen. 

Blasting cannot be used as a paint stripping method on certain substrate 

because the abrasive media will cause damage, especially to composite 

materials. 

Sector Notebook Project 39 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

Painting and Painting Equipment Cleanup Wastes. Methods for 

minimizing paint and painting equipment cleanup wastes include tight 

inventory control, material substitution, and minimization of fugitive 

oversprays. Tight inventory control techniques such as monitoring employee 

operations or limiting access to raw materials storage areas force employees 

to stretch the use of the raw materials. Use of less toxic types of paints can 

reduce the amount of hazardous paint waste as well as painting equipment 

cleanup waste (i.e., solvent wastes). Also, the use of powder coatings based 

on finely pulverized plastics that are baked on at 400�F has been tried as a 

substitute for paint for some industrial applications. 

Minimizing overspray has benefits in terms of both inventory control and 

elimination of surface water runoff. For inventory control, overspray can be 

minimized by using air-assisted, airless, high volume, low pressure turbine, 

air-atomized electrostatic, and airless electrostatic application techniques. In 

addition, overspray can be minimized by maintaining a fixed distance from the 

surface while triggering the paint gun, and releasing the trigger when the gun 

is not aimed at the target. Overspray control for minimizing runoff can be 

achieved by using plastic sheeting under and around the aircraft being painted, 

or using a paint booth for smaller parts. 

To reduce the amount of wastes created by painting operations, all paint 

should be used until containers are completely empty. Containers that are 

considered empty under the Resource Conservation and Recovery Act 

(RCRA) may be disposed of as solid waste (40 CFR 265). However, they 

may face requirements under DOT regulations depending on the amount of 

hazardous waste remaining in the container. Used containers of paint may 

need to be disposed of as hazardous wastes if they are not completely empty. 

Also, paint may be purchased in recyclable and/or returnable containers to 

reduce disposal costs. 

IV.A.2. Fueling 

Pollution prevention opportunities for aircraft and vehicle refueling operations 

primarily focus on the prevention of fuel spillage and the associated air, water, 

and hazardous waste pollution. Fuel tank monitoring and automatic shutoff 

devices are key spill prevention measures. Although not permitted for jet fuel, 

using color-coded dyes to identify fuel grades of aviation fuel is commonly 

used to prevent mixtures of fuel and to find fuel leaks. One technique to 

prevent fuel spills is to install catchment basins, including containment at 

hydrant pits. All leaking pipe joints, nozzle connections, and any damage to 

the fueling hose (e.g., kinks, crushing, breaks in the carcass, bulges, blistering, 

soft spots at the coupling, deep cracks or cuts, spots wet with fuel, or 

excessive wear) should be reported immediately to reduce their potential 

Sector Notebook Project 40 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

impact on the environment. Using dry cleanup methods for the fuel area 

reduces water runoff and associated contamination of groundwater and 

surface water supplies. 

Pollution prevention techniques for aircraft fueling include: 

� Inspect fueling equipment daily to ensure that all components are in 

satisfactory condition. 

� Employ proper grounding and bonding techniques for a safe fueling 

operation. 

� If fueling of an airplane occurs at night, assure it is carried out it in 

well lit areas. 

� Where possible, avoid fueling an aircraft during aircraft maintenance 

activities that might provide a source of ignition to fuel vapors. 

Similarly, assure that all radio and radar equipment is off during the 

refueling process. 

� While fueling, check for leaks and assuring that the fueling operator 

has a clear view of control panel. 

� Never leave the nozzle unattended during overwing fueling, or wedge 

or tie the nozzle trigger in the open position. 

� Discourage topping off of fuel tanks, except when required for 

compliance with FAA safety regulations. 

� Sump of hydrant pits. 

Vehicle fueling. Self-locking fueling nozzles minimize the risk of both fuel 

spillage and air pollution by ensuring a secure seal between the fuel source and 

tank. 

Fuel in vehicle operations. Use of battery-operated or alternative fuel 

vehicles provides two ways to reduce emissions from aviation-support 

vehicles. Natural gas vehicles, for example, are a viable alternative to 

gasoline- and diesel-powered transportation. Almost any gasoline-powered 

vehicle can be converted to run on natural gas by installing a natural gas fuel 

system and storage tanks without removing any existing equipment. Diesel 

conversions are somewhat more complicated because they also involve 

reducing compression and adding a sparked-ignition system. Other fuels 

suitable for vehicles include methanol, ethanol, and propane. 

Sector Notebook Project 41 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

In 1997, there were alternative fuel vehicle programs at virtually every major 

airport in the United States. The alternative vehicle usage at airports runs the 

gamut from taxis, shuttle buses, passenger busses, transport busses, minivans, 

trucks, cars, tugs, tractors, belt loaders, and ground power units, to catering 

vehicles. The use of natural gas vehicles is being driven by both cost 

effectiveness and regulation. Many states require companies with fleets of 

twenty or more vehicles to phase in alternative fuel vehicles. The 1990 Clean 

Air Act also contains incentives to encourage the use of alternative fuels. 

Federal (and in some areas, State) tax deductions for “alternative fuel 

vehicles” and related refueling equipment are available. The maximum tax 

deductions range from $2,000 to $50,000 for each alternative fuel vehicle and 

up to $100,000 on refueling stations. 

IV.A.3. Aircraft and Vehicle Exterior Cleaning 

Pollution prevention opportunities for aircraft and aviation-support vehicle 

cleaning focus on the reduction of wastewater discharges. 

� Aircraft Cleaning. For washing aircraft, 

it is best to utilize a designated cleaning Note: Air worthiness 

area, recycle washwater (if possible), and requirements may 

use phosphate-free detergents. dictate the quantity of 

Washwater should be contained and an water used in certain 

oil/water separator should be used. 

Washwater can be captured, filtered, and 

reused in aircraft washing and other activities. If the washwater is 

reused for washing aircraft, it must meet the manufacturer's 

specifications for washwater. ���������� ���������� ������������

��� ������ �� ��������� �� ����������� �������� �������� ������

Another water reduction tool, a flow restrictor, can be used to control 

the amount of water being used to wash aircraft. A reduction in water 

usage will translate into a reduction in the volume of generated 

wastewaters. (Note that technologies for water reduction are only 

suggestions and should be evaluated individually to address the 

circumstances appropriate to each site.) 

� Vehicle Washing. Vehicle washing has become a major 

environmental compliance issue for most companies that operate a 

fleet of vehicles. While pollutants from vehicle washing are generally 

controlled by routing the water through an oil and water separator, 

many techniques are available that prevent the water from being 

generated at all. The following pollution prevention activities will 

help ensure that a facility is addressing potential sources of pollution: 

Sector Notebook Project 42 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

�

�

�

IV.A.4. Aircraft Deicing 

Wastewater discharge can be prevented by dry washing 

vehicles using a chemical cleaning and waxing agent, rather 

than detergent and water. The dry washing chemical is 

sprayed on and wiped off with rags. No wastewater is 

generated. Dry washing is labor intensive and creates solid 

waste that must be disposed of properly. 

Wastewater can be contained by washing at a low point of the 

facility, blocking drains from the facility using a containment 

dike or blanket, or washing on a built-in or portable 

containment pad. 

Wastewater can be disposed of by evaporation from a 

containment area, or by discharging the wastewater to a 

sanitary sewer system. Permission must be obtained from the 

POTW before washwater can be drained, pumped, or 

vacuumed to a sanitary sewer connection. 

As noted earlier, FAA regulations and advisory circulars govern in detail 

virtually every aspect of airline and airport operations, particularly with 

respect to procedures and standards for aircraft maintenance and 

airworthiness, including aircraft deicing. Potential pollution prevention 

opportunities for aircraft deicing operations include (1) providing the 

appropriate training on the use of glycol products to ensure they are efficiently 

applied to reduce polluting airport runoff and (2) collecting deicing fluid to 

prevent direct discharges to surrounding surface water and groundwater along 

with facility storm water. Appropriate liquid aircraft deicers include ethylene 

glycol, propylene glycol, and di-ethylene glycol. 

��������� ������� ������ �� �������� ��� ����� �� ������� ����� �� ��������

�� ����������� ��� ������� ���������� ��� �� ������� ������� ��� ��� ����

������ ���������� ���� ������� ��� ���������� �������� ��������� �������

����� �� � ������ �������� �� ���� �������� ��� �������� �� ��������

������� ����� ��� �� ���� ��� ����������� ������������� ����� ��� ��� ����

��������� ���� �� ������� ������� ������ ��� ����� ������� �������� ���������

��������� ������ �������������� ��� �������� ������ ��� ���� ����������� ���

����� �� ����� � ������ ������ ��������������

��� ������ ������� ���� ������� ������� �������� ���������� �� �������

������ �� ���������������� ������ ������ ����� �� ������������� �� ����� ��

���� ��������� ��������� ��� ������������ ��������� �� �� ��������� �� �������

�������������� ���� ������� ���� ���� ��� ������� ������������� �� �����

Sector Notebook Project 43 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

���������� ���� ��� ���� �� �������� ������ ��������� �� ���������� �����

�� ���� �� �� �������� �������� ����� ������� ��� ��������� �� ������

��������� ��� �������� �� ��������� ������ ������� �������� �� ��� ���� ��

������� �������� �� ��� ������� ���� ��� ������ ��� ������� �������� ���� ���

����� �������

The most widespread collection method involves the collection of deicer 

through separate drainage areas around aircraft deicing operations, which 

minimizes the mixing of storm water and deicing fluid. The collection systems 

can be located ������ at the gate area or at a remote deicing area. Deicer fluid 

at gate area surfaces can be collected using vacuum sweeping machines, 

sponge rollers, and pumps. 

Alternative deicing methods. Additional technology-based, alternative 

deicing methods ��������� are being developed by industry. While some of 

these have yet to be proven cost effective, they do present viable alternatives 

as technology is improved. 

� FAA has approved site-specific procedures for infra-red equipment 

designed to de-ice aircraft. 

� Deicing truck with a cab. This type of enclosure for the operator 

reduces overspray since the operator can get closer to the job. 

However, minimum safe distances must be maintained to avoid 

accidents and damage to aircraft or personnel. Customers of such a 

system have reported up to 30% reductions in consumption of glycolbased and other anti-deicing fluids. 

� More advanced computerized ice detection protection systems. For 

example, a system that takes electronic measurements from a wingmounted sensor disc to identify the type and thickness of ice 

contamination has been developed. The system also can tell when the 

deicing fluid is in a transition stage and about to fail as a protective 

coat. Such a mechanism would be useful in determining when and 

where the aircraft needs to be deiced. 

����������� �� ������������� ���������� ����������� ��� �� �� ���������

��������� ���� ����� ���� ��� ������� ����������� ������� �� ���������

�������������� �� ���� ������ ���������� ������� ��� �� ������� ����

����������� ��� ������������ �� ���� ��� ���������� ���� ����� �������

����� �� ��� ������� ��� ���� ������ �� ���������� ������ ������������

���������� �������� ���� ���������� �������� ��� ���������� �������

���������� ��������������������� � �������� ��������� ������ ������ ������

�������� ��� �� ���������� �� ������ ��� ������ �� ���������� ���������

Sector Notebook Project 44 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

������� ��������� ������ ���������� ��������� ��� ���� �� �������� ��

������ ������ �� �������� ���������� ��������� �������� ���������� �������

���� �� ���������� ���������� �������� �������������� ����������� ���

��������� ��� ������ ����������� ������� ������ ������������� ���

��������� ����� ������� ������� ������ ����������� �������� �� ������ ���

������� ��� ����������� �� ���� ������ ��������� ������� �� �����������

������������� ���������� ��� ������� ��� ����������� ��������� �� ����

���������� ������� ������ ����������� ����������� ������ �� ����������

�� � ��������� ����������� �� � ��� �� �������� �������� ���� �� ��� ��

������������ �� � ���������� ������

IV.A.5. General Aircraft Operations 

Modifications. Pollution prevention opportunities for aircraft modification 

primarily focus on improving the efficiency of the engine. Engine 

manufacturers are being encouraged or required to research and develop 

cleaner, quieter, and more fuel-efficient aircraft. Air pollution is a function of 

both the type of aircraft engine and the mode of operation of the aircraft, 

which can be broken down into the following stages: idling at gate and 

runway; engine power up; taxiing; takeoff and climb out; and approach and 

landing. With respect to the type of engine, one mechanism that can improve 

air quality in and around airports is for airlines and associated personnel to 

encourage and support aviation research that would reduce aircraft emissions. 

In the meantime, airlines have the option of buying and leasing aircraft that 

meet or exceed the strictest requirements while retiring, replacing, or 

retrofitting older equipment as rapidly as possible to reduce both the amount 

of air and noise pollution. 

Operations. Pollution prevention opportunities for aircraft operations at the 

airport include the following: 

� Utilize more efficient aircraft. By operating more efficient aircraft, 

airlines have been able to reduce fuel consumption and decrease the 

cost of operations. Since 1976, the introduction of more fuel efficient 

aircraft has reduced fuel consumption per passenger mile by 

approximately 50%.

4 

� Retrofit gate facilities to centralized ground power in order to reduce 

aircraft engine running and prevent extraneous air emissions 

associated with engine and auxiliary power unit usage. 

4 Airline Fuel Consumption, The Boeing Company, 1997. 

Sector Notebook Project 45 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

� Reduce holdover time from deicing to takeoff to eliminate the need 

for a plane to require deicing more than once. 

� Checking cargo prior to loading for leaking or otherwise damaged 

shipments will prevent the leakage of wastes. This is of particular 

importance for loading dangerous goods, wet cargo, live animals, or 

other cargo prone to leakage. After unloading, it is useful to check 

the cargo compartments to ensure that all of the load for a given 

station has been removed. Inspecting any traces of leakage at once 

will enable the operator to establish the source of such leakage. 

IV.B. Airport Operations 

IV.B.1. Runway Deicing 

In addition to collection and recycling of deicing fluids, pollution prevention 

opportunities include the use of alternative, less polluting deicers such as 

magnesium acetate and potassium acetate. These fluids have been approved 

by FAA on both safety and environmental grounds, and have no significant 

impact on water quality. It should be noted that although they have received 

FAA approval, magnesium acetate and potassium acetate have caused safety 

problems by damaging aircraft lighting systems. As in all cases where 

alternative technologies are used to minimize environmental impacts, aircraft 

safety is a major concern and must be addressed. 

IV.B.2. General Airport Operations 

Pollution prevention opportunities for airports focus primarily on alleviating 

air and noise pollution by implementing layout modifications and changes in 

airport operations. These improved practices can reduce the amount of air 

and noise pollution generated by aircraft and associated airport activities. 

� For existing airports, engage in comprehensive noise mitigation 

planning and implement feasible measures to reduce noise impacts on 

densely populated regions. For new airports, if possible, choose an 

optimal site for the airport that is away from large communities. 

� Use proper land use planning, which is a local government 

responsibility, for the areas affected by airport noise. For examples, 

airports may choose to purchase land surrounding the airport for 

airport use or acquire land as aviation easements. Airports may also 

work with local zoning boards and encourage them to zone land near 

airports for airport compatible uses. In particular, FAA is concerned 

about sanitary landfill locations near airports because landfills attract 

Sector Notebook Project 46 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

certain bird species that are hazards to aviation due to their size and/or 

flocking behavior. 

Additional Airport Activities Impacting Air Quality. Air pollution resulting 

from airport operations is dependent on both mobile sources of pollution such 

as airplanes, ground-service vehicles, and automobiles accessing the airport 

as well as point sources of pollution such as power plants, fueling systems, 

fuel storage facilities, aircraft maintenance facilities, and deicing facilities. 

Airport Traffic. Air quality in and around the airport vicinity is related not 

only to aircraft using the airport but to travelers and employees accessing the 

airport and maintenance vehicles that service the airport. Automobiles and 

busses used by motorists that enter and leave airports create a large source of 

air pollution through automobile exhaust. To reduce emissions from private 

vehicles, airports can link or improve public transport access, provide express 

bus services, and institute bus/high occupancy vehicle lanes on access roads. 

Employee Programs. Initiating employee programs can reduce air pollution 

in and around the airport. For instance, modifying airport employee work 

weeks to a revised schedule that limits trips made by employees will decrease 

air emission (e.g., an airport may implement a 9 day/80 hour two-week 

schedule). Other options are voluntary employee Rideshare Programs or day 

care services to prevent employees from having to travel unnecessary miles, 

which in turn reduces the quantity of auto emissions associated with airport 

operations. 

Recycling solid waste. Recycling all paper, cardboard, plastics, metal, and 

airport-specific items such as wood and film plastic will prevent pollution. In 

addition, distributing recycling literature and educational materials to 

employees and travelers will encourage more recycling of these materials. 

Pest Management. Food waste from the large number of concessionaires at 

major airports create pest management problems at airports. Various 

pesticides, fumigants, and other pest management techniques are used at 

airports to control pests. 

Landscaping. Airport erosion control projects should use environmentally 

and economically beneficial landscaping methods. Any plantings near 

runways should avoid attracting hazardous wildlife (e.g., geese, gulls, large 

mammals, or prey species that attract large mammals). However, careful 

planting can reduce the use of pesticides, herbicides insecticides, and 

rodenticides; control erosion; reduce water usage; reduce energy usage; 

Sector Notebook Project 47 February 1998 
Air Transportation Industry Pollution Prevention Opportunities 

reduce runoff and air emissions from mowers; and associated exposure to 

workers and the public. 

Sector Notebook Project 48 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

V. SUMMARY OF FEDERAL STATUTES AND REGULATIONS 

This section discusses the Federal regulations that may apply to this sector. 

The purpose of this section is to highlight and briefly describe the applicable 

Federal requirements, and to provide citations for more detailed information. 

The three following sections are included: 

� Section V.A. contains a general overview of major statutes 

� Section V.B. contains a list of regulations specific to this industry 

� Section V.C. contains a list of pending and proposed regulations 

The descriptions within Section V are intended solely for general information. 

Depending upon the nature or scope of the activities at a particular facility, 

these summaries may or may not necessarily describe all applicable 

environmental requirements. Moreover, they do not constitute formal 

interpretations or clarifications of the statutes and regulations. For further 

information, readers should consult the Code of Federal Regulations and other 

state or local regulatory agencies. EPA Hotline contacts are also provided for 

each major statute. 

V.A. General Description of Major Statutes 

Resource Conservation and Recovery Act 

The Resource Conservation And Recovery Act (RCRA) of 1976 which 

amended the Solid Waste Disposal Act, addresses solid (Subtitle D) and 

hazardous (Subtitle C) waste management activities. The Hazardous and 

Solid Waste Amendments (HSWA) of 1984 strengthened RCRA’s waste 

management provisions and added Subtitle I, which governs underground 

storage tanks (USTs). 

Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts 

260-299) establish a “cradle-to-grave” system governing hazardous waste 

from the point of generation to disposal. RCRA hazardous wastes include the 

specific materials listed in the regulations (commercial chemical products, 

designated with the code “�” or “�”; hazardous wastes from specific 

industries/sources, designated with the code “K”; or hazardous wastes from 

non-specific sources, designated with the code “F”) or materials which exhibit 

a hazardous waste characteristic (ignitability, corrosivity, reactivity, or 

toxicity, and designated with the code “D”). 

Regulated entities that generate hazardous waste are subject to waste 

accumulation, manifesting, and recordkeeping standards. Facilities must 

generally obtain a permit either from EPA or from a State agency which EPA 

has authorized to implement the permitting program if they store hazardous 

Sector Notebook Project 49 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

wastes for more than 90 days (or 180 or 270 days depending on the amount 

of waste generated and the distance the waste will be transported) before 

treatment or disposal. Facilities may treat hazardous wastes stored in lessthan-ninety-day tanks or containers without a permit. Subtitle C permits 

contain general facility standards such as contingency plans, emergency 

procedures, recordkeeping and reporting requirements, financial assurance 

mechanisms, and unit-specific standards. RCRA also contains provisions (40 

CFR Part 264 Subpart S and §264.101) for conducting corrective actions 

which govern the cleanup of releases of hazardous waste or constituents from 

solid waste management units at RCRA treatment, storage, and disposal 

facilities. 

Although RCRA is a Federal statute, many States implement the RCRA 

program. Currently, EPA has delegated its authority to implement various 

provisions of RCRA to 47 of the 50 States and two U.S. territories. 

Delegation has not been given to Alaska, Hawaii, or Iowa. 

Most RCRA requirements are not industry specific but apply to any company 

that generates, transports, treats, stores, or disposes of hazardous waste. 

Here are some important RCRA regulatory requirements: 

� Identification of Solid and Hazardous Wastes (40 CFR Part 261 

and 262) provides definitions and lays out the procedure every 

generator must follow to determine whether the material in question 

is considered a hazardous waste or solid waste, or is exempted from 

regulation. 

� Standards for Generators of Hazardous Waste (40 CFR Part 262) 

establish the responsibilities of hazardous waste generators including 

obtaining an EPA ID number, preparing a manifest, ensuring proper 

packaging and labeling, meeting standards for waste accumulation 

units, and recordkeeping and reporting requirements. Providing they 

meet additional requirements described in 40 CFR 262.34, generators 

may accumulate hazardous waste for up to 90 days (or 180 or 270 

days depending on the amount of waste generated and the distance the 

waste will be transported) without obtaining a permit. 

� Land Disposal Restrictions (LDRs) (40 CFR Part 268) are 

regulations prohibiting the disposal of hazardous waste on land 

without prior treatment. Under the LDRs program, materials must 

meet LDR treatment standards prior to placement in a RCRA land 

disposal unit (landfill, land treatment unit, waste pile, or surface 

impoundment). Virtually all hazardous wastes are subject to LDR 

requirements. Generators of waste subject to the LDRs must provide 

Sector Notebook Project 50 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

notification of such to the designated treatment, storage, and disposal 

facility to ensure proper treatment prior to disposal. 

� Used Oil Management Standards (40 CFR Part 279) impose 

management requirements affecting the storage, transportation, 

burning, processing, and re-refining of the used oil. For parties that 

merely generate used oil, regulations establish storage standards. For 

a party considered a used oil processor, re-refiner, burner, or marketer 

(one who generates and sells off-specification used oil directly to a 

used oilburner), additional tracking and paperwork requirements must 

be satisfied. 

� RCRA contains unit-specific standards for all units used to store, 

treat, or dispose of hazardous waste, including Tanks and 

Containers. Tanks and containers used to store hazardous waste 

with a high volatile organic concentration must meet emission 

standards under RCRA. Regulations (40 CFR Part 264-265, Subpart 

CC) require generators to test the waste to determine the 

concentration of the waste, to satisfy tank and container emissions 

standards, and to inspect and monitor regulated units. These 

regulations apply to all facilities that store such waste, including large 

quantity generators accumulating waste prior to shipment off-site. 

� Underground Storage Tanks (USTs) containing petroleum and 

hazardous substances are regulated under Subtitle I of RCRA. 

Subtitle I regulations (40 CFR Part 280) contain tank design and 

release detection requirements, as well as financial responsibility and 

corrective action standards for USTs. The UST program also 

includes upgrade requirements for existing tanks that must be met by 

December 22, 1998. 

� Boilers and Industrial Furnaces (BIFs) that use or burn fuel 

containing hazardous waste must comply with design and operating 

standards. BIF regulations (40 CFR Part 266, Subpart H) address 

unit design, provide performance standards, require emissions 

monitoring, and restrict the type of waste that may be burned. 

EPA's RCRA, Superfund and EPCRA Hotline at 1-800-424-9346 responds 

to questions and distributes guidance regarding all RCRA regulations. The 

RCRA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST, 

excluding Federal holidays. 

Comprehensive Environmental Response, Compensation, and Liability Act 

Sector Notebook Project 51 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

The Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA), a 1980 law known commonly as Superfund, authorizes EPA 

to respond to releases, or threatened releases, of hazardous substances that 

may endanger public health, welfare, or the environment. CERCLA also 

enables EPA to force parties responsible for environmental contamination to 

clean it up or to reimburse the Superfund for response costs (including 

remediation costs) incurred by EPA. The Superfund Amendments and 

Reauthorization Act (SARA) of 1986 revised various sections of CERCLA, 

extended the taxing authority for the Superfund, and created a free-standing 

law, SARA Title III, also known as the Emergency Planning and Community 

Right-to-Know Act (EPCRA). 

The CERCLA hazardous substance release reporting regulations (40 CFR 

Part 302) direct the person in charge of a facility to report to the National 

Response Center (NRC) any environmental release of a hazardous substance 

which equals or exceeds a reportable quantity. Reportable quantities are listed 

in 40 CFR §302.4. A release report may trigger a response by EPA, or by one 

or more Federal or State emergency response authorities. 

EPA implements hazardous substance responses according to procedures 

outlined in the National Oil and Hazardous Substances Pollution Contingency 

Plan (NCP) (40 CFR Part 300). The NCP includes provisions for permanent 

cleanups, known as remedial actions, and other cleanups referred to as 

removals. EPA generally takes remedial actions only at sites on the National 

Priorities List (NPL), which currently includes approximately 1300 sites. 

Both EPA and states can act at sites; however, EPA provides responsible 

parties the opportunity to conduct removal and remedial actions and 

encourages community involvement throughout the Superfund response 

process. 

EPA's RCRA, Superfund and EPCRA Hotline at 1-800-424-9346 answers 

questions and references guidance pertaining to the Superfund program. 

The CERCLA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST, 

excluding Federal holidays. 

Emergency Planning And Community Right-To-Know Act 

The Superfund Amendments and Reauthorization Act (SARA) of 1986 

created the Emergency Planning and Community Right-to-Know Act 

(EPCRA, also known as SARA Title III), a statute designed to improve 

community access to information about chemical hazards and to facilitate the 

development of chemical emergency response plans by State and local 

governments. EPCRA required the establishment of State emergency 

response commissions (SERCs), responsible for coordinating certain 

Sector Notebook Project 52 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

emergency response activities and for appointing local emergency planning 

committees (LEPCs). 

EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four 

types of reporting obligations for facilities which store or manage specified 

chemicals: 

� EPCRA §302 requires facilities to notify the SERC and LEPC of the 

presence of any extremely hazardous substance (the list of such 

substances is in 40 CFR Part 355, Appendices A and B) if it has such 

substance in excess ofthe substance's threshold planning quantity, and 

directs the facility to appoint an emergency response coordinator. 

� EPCRA §304 requires the facility to notify the SERC and the LEPC 

in the event of a release equal to or exceeding the reportable quantity 

of a CERCLA hazardous substance or an EPCRA extremely 

hazardous substance. 

� EPCRA §311 and §312 require a facility at which a hazardous 

chemical, as defined by the Occupational Safety and Health Act, is 

present in an amount exceeding a specified threshold to submit to the 

SERC, LEPC and local fire department material safety data sheets 

(MSDSs) or lists of MSDSs and hazardous chemical inventory forms 

(also known as Tier I and II forms). This information helps the local 

government respond in the event of a spill or release of the chemical. 

� EPCRA §313 requires manufacturing facilities included in SIC codes 

20 through 39, which have ten or more employees, and which 

manufacture, process, or use specified chemicals in amounts greater 

than threshold quantities, to submit an annual toxic chemical release 

report. This report, known commonly as the Form R, covers releases 

and transfers of toxic chemicals to various facilities and environmental 

media, and allows EPA to compile the national Toxic Release 

Inventory (TRI) database. 

All information submitted pursuant to EPCRA regulations is publicly 

accessible, unless protected by a trade secret claim. 

EPA's RCRA, Superfund and EPCRA Hotline at 1-800-424-9346 answers 

questions and distributes guidance regarding the emergency planning and 

community right-to-know regulations. The EPCRA Hotline operates 

weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding Federal holidays. 

Sector Notebook Project 53 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

Clean Water Act 

The primary objective of the Federal Water Pollution Control Act, commonly 

referred to as the Clean Water Act (CWA), is to restore and maintain the 

chemical, physical, and biological integrity of the nation's surface waters. 

Pollutants regulated under the CWA include “priority” pollutants, including 

various toxic pollutants; “conventional” pollutants, such as biochemical 

oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and 

grease, and pH; and “non-conventional” pollutants, including any pollutant 

not identified as either conventional or priority. 

The CWA regulates both direct and indirect discharges. The National 

Pollutant Discharge Elimination System (NPDES) program (CWA §502) 

controls direct discharges into navigable waters. Direct discharges or “point 

source” discharges are from sources such as pipes and sewers. NPDES 

permits, issued by either EPA or an authorized State (EPA has authorized 42 

States to administer the NPDES program), contain industry-specific, 

technology-based and/or water quality-based limits, and establish pollutant 

monitoring requirements. A facility that intends to discharge into the nation's 

waters must obtain a permit prior to initiating its discharge. A permit 

applicant must provide quantitative analytical data identifying the types of 

pollutants present in the facility's effluent. The permit will then set the 

conditions and effluent limitations on the facility discharges. 

A NPDES permit may also include discharge limits based on Federal or State 

water quality criteria or standards, that were designed to protect designated 

uses of surface waters, such as supporting aquatic life or recreation. These 

standards, unlike the technological standards, generally do not take into 

account technologicalfeasibility or costs. Water quality criteria and standards 

vary from State to State, and site to site, depending on the use classification 

of the receiving body of water. Most States follow EPA guidelines which 

propose aquatic life and human health criteria for many of the 126 priority 

pollutants. 

Storm Water Discharges 

In 1987 the CWA was amended to require EPA to establish a program to 

address storm water discharges. In response, EPA promulgated the NPDES 

storm water permit application regulations. These regulations require that 

facilities with the following storm water discharges apply for an NPDES 

permit: (1) a discharge associated with industrial activity; (2) a discharge from 

a large or medium municipal storm sewer system; or (3) a discharge which 

EPA or the State determines to contribute to a violation of a water quality 

standard or is a significant contributor of pollutants to waters of the United 

States. 

Sector Notebook Project 54 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

The term “storm water discharge associated with industrial activity” means 

a storm water discharge from one of 11 categories of industrial activity 

defined at 40 CFR 122.26. Six of the categories are defined by SIC codes 

while the other five are identified through narrative descriptions of the 

regulated industrial activity. If the primary SIC code of the facility is one of 

those identified in the regulations, the facility is subject to the storm water 

permit application requirements. If any activity at a facility is covered by one 

of the five narrative categories, storm water discharges from those areas 

where the activities occur are subject to storm water discharge permit 

application requirements. 

Those facilities/activities that are subject to storm water discharge permit 

application requirements are identified below. To determine whether a 

particular facility falls within one of these categories, consult the regulation. 

Category I: Facilities subject to storm water effluent guidelines, new source 

performance standards, or toxic pollutant effluent standards. 

Category ii: Facilities classified as SIC 24-lumber and wood products 

(except wood kitchen cabinets); SIC 26-paper and allied products (except 

paperboard containers and products); SIC 28-chemicals and allied products 

(except drugs and paints); SIC 291-petroleum refining; SIC 311-leather 

tanning and finishing; SIC 32 (except 323)-stone, clay, glass and concrete; 

SIC 33-primary metals; SIC 3441-fabricated structural metal; and SIC 373-

ship and boat building and repairing. 

Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal 

mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral 

mining. 

Category iv: Hazardous waste treatment, storage, or disposal facilities. 

Category v: Landfills, land application sites, and open dumps that receive or 

have received industrial wastes. 

Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and 

SIC 5093-automotive scrap and waste material recycling facilities. 

Category vii: Steam electric power generating facilities. 

Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41-

local passenger transportation; SIC 42-trucking and warehousing (except 

public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water 

transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk 

storage stations and terminals. 

Sector Notebook Project 55 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

Category ix: Sewage treatment works. 

Category x: Construction activities except operations that result in the 

disturbance of less than five acres of total land area. 

Category xi: Facilities classified as SIC 20-food and kindred products; SIC 

21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related 

products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture 

and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted 

paper and paperboard products; SIC 27-printing, publishing, and allied 

industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and 

allied products; SIC 30-rubber and plastics; SIC 31-leather and leather 

products (except leather tanning and finishing); SIC 323-glass products; SIC 

34-fabricated metal products (except fabricated structural metal); SIC 35-

industrial and commercial machinery and computer equipment; SIC 36-

electronic and other electrical equipment and components; SIC 37-

transportation equipment (except ship and boat building and repairing); SIC 

38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous 

manufacturing industries; and SIC 4221-4225-public warehousing and 

storage. 

Pretreatment Program 

Another type of discharge that is regulated by the CWA is one that goes to 

a publicly owned treatment works (POTWs). The national pretreatment 

program (CWA §307(b)) controls the indirect discharge of pollutants to 

POTWs by “industrial users.” Facilities regulated under §307(b) must meet 

certain pretreatment standards. The goal of the pretreatment program is to 

protect municipal wastewater treatment plants from damage that may occur 

when hazardous, toxic, or other wastes are discharged into a sewer system 

and to protect the quality of sludge generated by these plants. Discharges to 

a POTW are regulated primarily by the POTW itself, rather than the State or 

EPA. 

EPA has developed technology-based standards for industrial users of 

POTWs. Different standards apply to existing and new sources within each 

category. “Categorical” pretreatment standards applicable to an industry on 

a nationwide basis are developed by EPA. In addition, another kind of 

pretreatment standard, “local limits,” are developed by the POTW in order to 

assist the POTW in achieving the effluent limitations in its NPDES permit. 

Regardless of whether a State is authorized to implement either the NPDES 

or the pretreatment program, if the State develops its own program, it may 

enforce requirements more stringent than Federal standards. 

Sector Notebook Project 56 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

Spill Prevention Control and Countermeasure Plans 

The 1990 Oil Pollution Act requires that facilities that could reasonably be 

expected to discharge oil in harmful quantities prepare and implement more 

rigorous Spill Prevention Control and Countermeasure (SPCC) Plan required 

under the CWA (40 CFR §112.7). There are also criminal and civil penalties 

for deliberate or negligent spills of oil. Regulations covering response to oil 

discharges and contingency plans (40 CFR Part 300), and Facility Response 

Plans to oil discharges (40 CFR §112.20) and for polychlorinated biphenyl 

(PCB) transformers and PCB-containing items were revised and finalized in 

1995. 

EPA’s Office of Water, at (202) 260-5700, will direct callers with questions 

about the CWA to the appropriate EPA office. EPA also maintains a 

bibliographic database of Office of Water publications which can be 

accessed through the Groundwater and Drinking Water Resource Center, at 

(202) 260-7786. 

Safe Drinking Water Act 

The Safe Drinking Water Act (SDWA) mandates that EPA establish 

regulations to protect human health from contaminants in drinking water. 

The law authorizes EPA to develop national drinking water standards and to 

create a joint Federal-State system to ensure compliance with these standards. 

The SDWA also directs EPA to protect underground sources of drinking 

water through the control of underground injection of liquid wastes. 

EPA has developed primaryand secondary drinking water standards under its 

SDWA authority. EPA and authorized States enforce the primary drinking 

water standards, which are, contaminant-specific concentration limits that 

apply to certain public drinking water supplies. Primary drinking water 

standards consist of maximum contaminant level goals (MCLGs), which are 

non-enforceable, health-based goals, and maximum contaminant levels 

(MCLs), which are enforceable limits set as close to MCLGs as possible, 

considering cost and feasibility of attainment. 

The SDWA Underground Injection Control (UIC) program (40 CFR Parts 

144-148) is a permit program which protects underground sources of drinking 

water by regulating five classes of injection wells. UIC permits include 

design, operating, inspection, and monitoring requirements. Wells used to 

inject hazardous wastes must also comply with RCRA corrective action 

standards in order to be granted a RCRA permit, and must meet applicable 

RCRA land disposal restrictions standards. The UIC permit program is 

primarily State-enforced, since EPA has authorized all but a few States to 

administer the program. 

Sector Notebook Project 57 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

The SDWA also provides for a Federally-implemented Sole Source Aquifer 

program, which prohibits Federal funds from being expended on projects that 

may contaminate the sole or principal source of drinking water for a given 

area, and for a State-implemented Wellhead Protection program, designed to 

protect drinking water wells and drinking water recharge areas. 

EPA’s Safe Drinking Water Hotline, at 1-800-426-4791, answers questions 

and distributes guidance pertaining to SDWA standards. The Hotline 

operates from 9:00 a.m. through 5:30 p.m., EST, excluding Federal 

holidays. 

Toxic Substances Control Act 

The Toxic Substances Control Act (TSCA) granted EPA authority to create 

a regulatory framework to collect data on chemicals in order to evaluate, 

assess, mitigate, and control risks which may be posed by their manufacture, 

processing, and use. TSCA provides a variety of control methods to prevent 

chemicals from posing unreasonable risk. 

TSCA standards may apply at any point during a chemical’s life cycle. Under 

TSCA §5, EPA has established an inventory of chemical substances. If a 

chemical is not already on the inventory, and has not been excluded by TSCA, 

a premanufacture notice (PMN) must be submitted to EPA prior to 

manufacture or import. The PMN must identify the chemical and provide 

available information on health and environmental effects. If available data 

are not sufficient to evaluate the chemicals effects, EPA can impose 

restrictions pending the development of information on its health and 

environmental effects. EPA can also restrict significant new uses of chemicals 

based upon factors such as the projected volume and use of the chemical. 

Under TSCA §6, EPA can ban the manufacture or distribution in commerce, 

limit the use, require labeling, or place other restrictions on chemicals that 

pose unreasonable risks. Among the chemicals EPA regulates under §6 

authority are asbestos, chlorofluorocarbons (CFCs), and PCBs. 

EPA’s TSCA Assistance Information Service, at (202) 554-1404, answers 

questions and distributes guidance pertaining to Toxic Substances Control 

Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST, 

excluding Federal holidays. 

Clean Air Act 

The Clean Air Act (CAA) and its amendments, including the Clean Air Act 

Amendments (CAAA) of 1990, are designed to “protect and enhance the 

nation's air resources so as to promote the public health and welfare and the 

productive capacity of the population.” The CAA consists of six sections, 

Sector Notebook Project 58 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

known as Titles, which direct EPA to establish national standards for ambient 

air quality and for EPA and the States to implement, maintain, and enforce 

these standards through a variety of mechanisms. 

Under the CAAA, many facilities will be required to obtain permits for the 

first time. State and local governments oversee, manage, and enforce many 

of the requirements of the CAAA. CAA regulations appear at 40 CFR Parts 

50-99. 

Pursuant to Title I of the CAA, EPA has established national ambient air 

quality standards (NAAQSs) to limit levels of “criteria pollutants,” including 

carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, sulfur 

dioxide, and volatile organic compounds (VOCs). Geographic areas that 

meet NAAQSs for a given pollutant are classified as attainment areas; those 

that do not meet NAAQSs are classified as non-attainment areas. Under 

Section 110 of the CAA, each State must develop a State Implementation 

Plan (SIP) to identify sources of air pollution and to determine what 

reductions are required to meet Federal air quality standards. Revised 

NAAQSs for particulates and ozone were proposed in 1996 and may go into 

effect as early as late 1997. 

Title I also authorizes EPA to establish New Source Performance Standards 

(NSPSs), which are nationally uniform emission standards for new stationary 

sources falling within particular industrial categories. NSPSs are based on the 

pollution control technology available to that category of industrial source. 

Under Title III, EPA establishes and enforces National Emission Standards 

for Hazardous Air Pollutants (NESHAPs), nationally uniform standards 

oriented towards controlling particular hazardous air pollutants (HAPs). Title 

I, section 112(c) of the CAA further directed EPA to develop a list of 

sources that emit any of 189 HAPs, and to develop regulations for these 

categories of sources. To date EPA has listed 174 categories and developed 

a schedule for the establishment of emission standards. The emission 

standards will be developed for both new and existing sources based on 

“maximum achievable control technology” (MACT). The MACT is defined 

as the control technology achieving the maximum degree of reduction in the 

emission of the HAPs, taking into account cost and other factors. 

Title II of the CAA pertains to mobile sources, such as cars, trucks, buses, 

and planes. Reformulated gasoline, automobile pollution control devices, and 

vapor recovery nozzles on gas pumps are a few of the mechanisms EPA uses 

to regulate mobile air emission sources. 

Title IV of the CAA establishes a sulfur dioxide and nitrogen oxide emissions 

program designed to reduce the formation of acid rain. Reduction of sulfur 

Sector Notebook Project 59 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

dioxide releases will be obtained by granting to certain sources limited 

emissions allowances, which, beginning in 1995, will be set below previous 

levels of sulfur dioxide releases. 

Title V of the CAA of 1990 created a permit program for all “major sources” 

(and certain other sources) regulated under the CAA. One purpose of the 

operating permit is to include in a single document all air emissions 

requirements that apply to a given facility. States are developing the permit 

programs in accordance with guidance and regulations from EPA. Once a 

State program is approved by EPA, permits will be issued and monitored by 

that State. 

Title VI of the CAA is intended to protect stratospheric ozone by phasing out 

the manufacture of ozone-depleting chemicals and restrict their use and 

distribution. Production of Class I substances, including 15 kinds of 

chlorofluorocarbons (CFCs) and chloroform, were phased out (except for 

essential uses) in 1996. 

EPA's Clean Air Technology Center, at (919) 541-0800, provides general 

assistance and information on CAA standards. The Stratospheric Ozone 

Information Hotline, at 1-800-296-1996, provides general information about 

regulations promulgated under Title VI of the CAA, and EPA's EPCRA 

Hotline, at 1-800-535-0202, answers questions about accidental release 

prevention under CAA §112(r). In addition, the Clean Air Technology 

Center’ s website includes recent CAA rules, EPA guidance documents, and 

updates of EPA activities (www.epa.gov/ttn then select Directory and then 

CATC). 

V.B. Industry Specific Requirements 

�� ����� �������� ������� ���������� �������� �������� ��������

�������������� �������� ��� ��� �������������� �������� �� ��������� ��

������� ��������� �������� ������ ��� ����� ��������� ��� ��� ��������������

�������� �� ��������� �� ����� ������� ���������� ������� ��������

�������������� ������ ��� ��� ��� ������������� ����������� ��������

��������� ���� ��� ��� �������� �� ����� �� ����� �����

��� ��� ������������� ������ �� ���������� �� ������ �� ���� �������������

���������� �� ���� ����� ������� ������ �� ��� ������� ���� �� �������

������� ����������� ���������� ���� ��� �������� �� ������ ���� ����

��������� ���� ������ ��� ��������� ����� ������������ ���� ��� �������

������� ������������� ���� �������� ���� ��� ������� �� ������� �����

���������� ��� ������ ���������� �������� ������� ���� ��� ��������� ����

������ ��� ��� �������������� ���������

Sector Notebook Project 60 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

����� ����� ���

����� ������������� ���������� ���� ��� �������������� ����������

����������� �� ������� ������ �� ��������� ����� ��� ������� �����

��������� ������� ��� �������� �������� ��������� ��������� �����������

������ ������� ������� ���� �� �������� �� ��������� ���������� ����

��������� ������� ��� ������� �� ������� ���������� ��� ������������ ���

���������� ������� ��� ���������� ��������� ��� ��� ���������� ������� ���

��� ���� �������� ��������� �������� �������� �� ���� ������ ��� �������

�� ��� ��������� ��� ��� ������� ��� ��� �������������� �� ��� ����� �� �

��������� �������� � ������ ��� �� � ������������ ������������ ����������

�� �� ��������� ��������� ��� �� ������� �� ������ �� ��� ���� �� ��� �������

�� ���������� ����� ������

�� �������� �� ������� ������ �� ���� ��� �� ���������� ��������

���������� ���������� ��� ������� ���������� ���������� ���������� ����

����������� �� ���� ����� ����� ��� �� �������� ���������� ����������

����������� ������������ ��� �������� ����������� �������� ����� ����������

��������� ������������ ��� ������ ��� �������� �������� �����������

���������� ��� ����� ��������� ��������� ����� �� ������� ���������� ����

���� �������� ������� �� ��������� ��� �� �� ��� ������� �� ������������

�������� ���������� ���������� ��� ��� �������������� ��������� ���������

����� ���� ������� ���������� ���� �� �������� ��������� ����� ����������

��� ��������� �� �� ����������� �� ����� ��������� ���� �������� �� ���

�������� ������ �� ������ ����� �������� ��� ����� ���������

��������������

����� ����� ������������� �� ��������� ����� ��� ������� ����������� ��

��� ����� ����� ���� ��� ��������� ����� ����� ����������� �� ��������

��� ����� ����� ������� ������� ����������� �� ����� ����� �� ������ �� ���

���� �� ����� ��� ����� �������� ��������� �� ��� ����� ����� ����������

���� � ������ ����� ��������� ���������� ���� ���������� ����������� ���

�������� �� ����� ��� � ����� ����� ������� ��� ���� ������ ����

�������������� ���������� ���������� �� ��� �� ������� ��� ��� ���� �����

���� ������� ����������� ������ ��������� �������� ����������� �� �������

������� ���������� ��� ���������� �� ���� � ����� ����� ���������

���������� ���� ���������� ��������� �������� ���� ����� �������� �� ���

�������� ���� ��� ������ �������� �� ������� ����������� ���������� �������

������������� ���������� �������� ��������� �������� ��� �������������

��������� �������� ����������� ������� ������� ����������� �� ����� ���

��������� ���������� ����� ���������� ��������������� �� ������� ������ ���

���������� �� �� ���������� ���� ���������� ��������� �� �� ���� ��������� ��

���� ������������ ���������� �� ��������� �� ����������� �� � ��������

�������������� ������������ ��� �������� ����� ����� ��� ����

Sector Notebook Project 61 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

���������� ������� �� ���� ���� ���� ������ ��� �� ��� ��������� ������

�������������

� ���������� ������ ������������

� ����� ������ ������������ � ����� ������ ����������� ��� �� �����

�� ���������� ���� ���� ���������� ��� ����������� �� ����� � �����

����� ����� ������ ����������� ���� ������� �������� ��� ����� ��

��� �������� ����������� �� ������� ���������� ��� ��� �������

�������� ��� ����������� ����������� �� ��� ������������

�������� ���� ���������� �� ��� ��������� ��� ��� ������� �� ���

���������� ����� ������

� ������ �� ������ ��� ������� ������ ���������

����� ��� ��� �������� ���������� �� ������� ����� ���������� �������

��� �������������� ������ ����� ��� ��������� ��������� ���� �� ��� ��

��� ���������� ���� ����� � ����� �� ������ �� ���� ��� ������ �� �����

���������� �� � ���������� ����� ��� ���� ������� �������� ��������� ������

�� ��������� ������ ��� ��� ����������� �� ����������� ����� ���� ���� ��

���� ������� ���� ����� �������� ��� �������� �� ������� �������� �����

�� ������������ ������� ���������� ���� � ����� ������� �� �������� ����

��� ������ ����� �� ��������� ��������� ��������� �� ���� ����� ���

���������� ��� ��������� ��� ����������� ���������� ��� ���������

��������� �� ���� ���� �� ���������� �������� ����� �� ��� ���� ��������

CPF EGTVKHKGF D[ C TGIKUVGTGF 2TQHGUUKQPCN 'PIKPGGT

�������� ������������ ��� �������� ���

��� �������������� ���������� �������� � ������� �� �������������� ������

�� ��� ������ �� ������ ���������� ��� ������� ����������� ������� �����

��� ���� �������� �������� ����������� ������� ������� ���� ������� ����

���� �������� ���� ��� ���� �� ������� ��� ������������ �������� �� ��

��������� ��� ����� �� �� ��� �������� �������� ������������ ���

����������� ���������� �������� ��������� ������ ���� �� ������� �����

�������� ��� ��������� ��� ������ ��� ����� �������� ���������� ������

��������� ���� �������� ����������� ���������� ���� ��� �� ���������

��������

� ������������ �������������� ��������� ��� ��������� ����� �������

���������

� ������� ����������� ������

� ����������� ����� �����

� ������ �� ������ ��������� ��������� ����� �������� ���������

��� ������� ��� ��������� ���������� ����� ������ ������ ����������

��������� ����� �� ����� ������ ������� �� ���������

� ����� ��������

Sector Notebook Project 62 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

� ���������� ����� ���� ��� ����� ����

� ����� ��������� ��������

���� ���� ��������� �������� ��� �������������������� ������ ������ �����

���� ������������ ����� �� ���� ����� �������� ������� ��� ������������

�������� ���� ���� ������������ ������ ���� ������� ��� �� ��� ���������

����� ��������������� ����� ������ ���� ��� �������������� ����������

������� �� ��������� ����� ���������� ����� ���� ���� ����� ����� ��

�� ��� ���������� �������������� �� ��������� ������� � ����� �� ����������

� ���� �� ��� ��������� ������ ��� �� ����� �� �� ��� ����������������

������ ��� ���� ��������� �� ���� ������� � �������������� ��������� �� ��

��� ���������������� ���� ������ ��� ������� �� ��� ��������� �����

����������� �� �� ��� ����� ���� �������� �������� ��� ���� ���� ���

��� ���� ��� ������� �� ��������� ������

��� ��������� ���

��� ���� ��� ��������� ��� ����� ����������� ������� ����� ��� �������

��������� ������� ���������� ���� ��������� ��� �� ����� ���� � �����������

������ �� ����������� ��� �� ��������� ���������� ��� �������

����������� �������� ��� ��������� ������������ �� ������� ���������� ����

��� ������� ������� ����������� ������ ����� ������������ ��� ������

���� ��� �������������� ����������� ��������������� ����������� ��������

�������� �� ��� ���������� ��� ����������� ����� ��� ��� ���� ����� ���

�������� �������� ����� �� ��� ���������� ��� ��� ���� ���� ���� �������

��� ��������� �� �����

������������� ������������� ��������� ������������� ��� ��������� ���

� ������ �� ������ ��������� ���� ��� ��� �������������� ������������ ���

����������� ��������� ������� ������ �������������������� ����������

���� ������ ��� ������� �������� �� ���� ���������� ��� ������� ��������

�������� ������� ����� ����������

��������� �������� ��� ��������� ������������� ���

������������ ��������� ������� ������������� ��� ������ �� ������

�� � �������� �� �������� �� ����������� ������ ��� ����� ��� ����� ������

�� �� �������� �� ����� �� � ������� ���� ��� ����������������������

��������� ���� ������� ��� ���������� �������� ��� ���� ����������

���������� ������� �� ���� ����������� ������� ����� �� ��� ���� ��

���������� ��������� ����������� ��� ��� ���� ���� �� ���� �� ���� ����

��� ��������� ���������� ������� �� ��� ��������� ������������

������������ ����� ������ ������� ������ ��� ��� ������� �������

Sector Notebook Project 63 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

Many materials commonly used in the aviation industry fall into this category 

of CERCLA hazardous substances, including many solvents, ethylene glycol, 

methanol, methylene chloride, and 1,1,1-trichloroethane. ���� ������ �� ���

���������� �� ������ �������� �� �������� ������ ����� ���� ��� ��������

������� �� ��������� ��� ���������� ��� ������� ��� ����� �������� ��� �������

��� �������� �� ����� ��� ������ �� �������� �� ��� ������ �������� ��� ������

�� ������ �� ��� ���������� ���� ������ � ������� ���� ��� ����������� ��

����� ������ �� ���� �� �������� ������ �� ��� ������� ������ �����

������

Federally Permitted Release Exemption. CERCLA Section 103(a) exempts 

those persons in charge of facilities from reporting releases that are federally 

permitted. On February 4, 1992, EPA issued OSWER Directive 9360.4-12 

regarding CERCLA Reporting Requirements for Releases of Ethylene Glycol 

From Airplane Deicing Operations. This Interpretative Memorandum and 

OSWER Directive allows the airline industry to classify releases of the 

ethylene glycol as nonreportable (or exempt) discharges if a facility (1) has an 

NPDES permit covering ethylene glycol, (2) has applied for an NPDES 

permit, or (3) discharges to a publicly-owned treatment works (POTW) 

meeting the applicable pretreatment standards. Since most if not all fluid 

discharges resulting from aircraft deicing operations usually fit into one of the 

permitted release exemptionsfound in CERCLA Section 101(10), most water 

discharges of ethylene glycol-based deicing fluids will not result in a reporting 

requirement. (EPA, 1992) 

Emergency Planning. Under EPCRA, a facility must notify authorities if it 

has onsite at any time a listed hazardous substance in an amount over the 

substance’s threshold planning quantity. Extremely hazardous substances that 

may be present in aviation-related facilities include nitric acid, sulfuric acid, 

phenol and ammonia (EEA, 1996). 

Clean Air Act 

Sections 231-234 of the Clean Air Act gives exclusive jurisdiction to the 

federal government and preempts any state or local regulation with respect to 

emissions of any air pollutant from any aircraft or engine. 

Air Quality Standards - Ozone Non-Attainment Areas. The most important 

pollutant affected by air quality standards is ozone. In attainment areas, a 

major source emits or has the potential to emit more than 100 tons per year 

of any criteria pollutant or 10 tons per year of any hazardous air pollutant or 

25 tons per year of any combination of hazardous air pollutants (emission 

thresholds differ for various categories of nonattainment areas). Large 

aircraft maintenance facilities performing aircraft painting or using large 

amounts of solvents may exceed these limits. Emission rates are dependent 

Sector Notebook Project 64 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

on the types of chemicals and methods used and the types of air emission 

control equipment used. Some regulations apply to substances (e.g., solvent 

degreasers) regardless of the size of the source. These regulations are 

designed to reduce emissions from solvent evaporation (EEA, 1996). 

To assist State and local agencies in establishing regulations that reduce VOC 

emissions from the air transportation industry, EPA developed a control 

technique guideline. This guideline offers an incentive of reduced 

recordkeeping requirements for facilities that use only approved cleaning 

agents, and requires vapor pressure limits for non-listed cleaning agents. 

Additionally, the guideline requires unused cleaning agent and solvent-laden 

rags to be stored in containers to prevent evaporation. (EEA, 1996) Airports 

located in ozone non-attainment areas may be subject to restrictions 

applicable to motor vehicles. These restrictions may affect the type and use 

of both airside and landside vehicles. 

NESHAPs/MACT Standard. National emission standards for hazardous air 

pollutants (NESHAP) attempt to control several hundred compounds, the 

most notable for airports being asbestos. Airports must comply with the 

NESHAP requirements for asbestos when demolishing, or significantly 

remodeling, a building containing asbestos. Asbestos is commonly found in 

ceiling tile, floor tile, boiler room insulation, and sprayed-on insulation 

installed more than 20 years ago. 

As stated earlier, MACT is the control technology achieving the maximum 

reduction in the emission of the hazardous air pollutants, taking into account 

cost and other factors. A MACT standard for coating operations conducted 

by aerospace manufacturing and reworking facilities was finalized by EPA in 

1996. The emission limit from primers is 2.9 pounds per gallon and the 

topcoat emission limit is 3.5 pounds per gallon. Generally, HAP emissions 

are not permitted during paint removal operations (except during spot 

stripping and decalremoval) (EEA, 1996). However, a number of exceptions 

may apply which permit such emissions under circumstances addressed in the 

NESHAP. According to the aerospace NESHAP, the provisions restricting 

HAP emissions during paint removal do not apply to the removal of paint 

from parts or units normally removed from the plane. 

New Source Performance Standards (NSPS). Some facilities subject to 

NSPS may be found at airports, including industrial and utility boilers, vehicle 

maintenance facilities, and fuel storage and delivery facilities. 

State Implementation Plans (SIPs). SIPs regulate stationary sources, such 

as buildings and other permanent installations, and mobile sources, such as 

automobiles. Typical airport facilities and activities which may be subject to 

stationary source regulations include heating and refrigeration plants; fueling 

Sector Notebook Project 65 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

systems; fuel storage facilities; aircraft maintenance facilities; deicing; 

roadways, garages, and parking lots; landside development; building 

demolition; and building construction. SIPs may also control mobile sources 

such as fleet vehicles and other vehicles using the airport. Airports are large 

parking areas for automobiles, trucks, and aircraft. SIPs may have to limit 

motor vehicle emissions through “transportation control measures.” These 

measures are designed to reduce congestion and the number of vehicle miles 

traveled in a region. Measures which affect airports include improved public 

transit, measures to encourage uses of buses and other high occupancy 

vehicles, mandatory trip reduction, and traffic flow improvements. 

Where applicable, SIPs must address the requirements of general air 

conformity (40 CFR Part 93). In addition, FAA is required to ensure 

compliance with general air conformity requirements for federal airport 

actions planned for nonattainment or maintenance areas. 

Ozone-Depleting Substances. The amended CAA is phasing out the 

production and restricting the use and distribution of ozone-depleting 

chemicals. One ozone-depleting chemical widelyused inthe air transportation 

industryforfire suppression is halon. Halon production has ceased and future 

purchases must be from recycled stock. For consistency with these 

regulations, FAA has revised its policy and no longer requires halon use 

during firefighting drills conducted under FAR 121.417 and FAR 135.331 

(EEA, 1996). 

Additionally, EPA has established requirements for servicing and disposal of 

air conditioning and refrigeration equipment containing regulated ozonedepleting refrigerants. Certified, self-contained recovery equipment must be 

available during refrigeration equipment servicing. Additional recordkeeping 

and reporting requirements apply for appliance owners/operators and 

technicians. Facilities with refrigeration equipment containing ozonedepleting chemicals must comply with 40 CFR Part 82 (EEA, 1996). 

Federal Insecticide, Fungicide, and Rodenticide Act 

FIFRA regulations are applicable to air transportation facilities and operations 

where herbicides are used to control weeds and brush, or when pesticides and 

rodenticides are used for pest control in buildings. Air transportation 

operations should only apply herbicides, both general and restricted use, 

according to label instructions. Certification is required for use of restricted 

use herbicides. 

V.C. Pending and Proposed Regulatory Requirements 

Sector Notebook Project 66 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

����� ����� ���

���������� ����� ��� �� �������� ����������� ���������� �������� �� ��� ���

�������������� ��������� �������� ���������� ��� ��������� ����� ���������

��� ���� �������� ��������� ��������� �������� ��������� �� ��� ������ ��

������ ����� ���������� ��� �� �� �������� �� ������� ���� ��� ������ ��

����� �� �������� ���� ��������� ���� �������� �� ��� �������� ������

�� ������ ����� �������� ��� ����� ��������� ��������������

�� ������� ��� ����� ��� �������� � ������� �� ���������� �����������

��������� �������� ����������� �� ��� �������� ���������� ���� ��� ����� �� �

���� ������� ������� ��� ����� �������� ��� ��������� ��������

����������� ����� ��� ���������� �� ������� ����������� ��� ������������

����������� ��� �������� ������������� ����� ����� ��� �� ������� ���

������� ��������� ��������� ����������� ������� ���� ��� �����������

�������� ��������� ���������� ��� ��� �������� ���� �� ��������� �� ��

��������� �� �������� �����

The modified consent decree also targets airport deicing operations. ���

������� ������ ������� ��� �� ������ ������� ���������� ���� ��� �����

�� ��� ����������� ����������� ��� ������� initiate a study of water pollution 

problems associated with airport deicing operations and storm water runoff. 

Recently issued FAA guidelines on aircraft deicing and the recent EPA storm 

water rules are likely to have a significant effect on airport deicing operations. 

In addition, the EPA Office of Water will also work with the Department of 

Defense to study deicing operations at military installations. Depending on 

the results of this study, guidelines specific to deicing at military installations 

may be developed. 

EPA’s five-year-old baseline general permit for industrial storm water 

dischargers expired on September 30, 1997. EPA suggests that industries 

covered by the baseline permit should explore their permit options. Most 

State five-year industrial permits expired along with the EPA Baseline 

General Permit on September 30, 1997. Most permits contain a provision 

stating that the expired permit remains effective and enforceable until 

replaced. However, the permits also contain a provision requiring permittees 

to submit a new Notice of Intent (NOI) prior to permit expiration to remain 

covered. Once an airport is without a permit, it generally cannot reapply for 

coverage under the expired permit. 

Emergency Planning and Community Right-to-Know Act 

Under EPCRA 313, Toxic Release Inventory (TRI) reporting is required by 

manufacturing and certain other facilities. Air transportation facilities are 

Sector Notebook Project 67 February 1998 
Air Transportation Industry Federal Statutes and Regulations 

currently not subject to TRI reporting requirements. EPA recently expanded 

the TRI program and did not include airports (62 FR 23834), however, they 

may be added in the future. 

Clean Air Act 

EPA has completed its final amendments to the Aerospace NESHAP under 

the CAA which will be implemented September 1, 1998. The Aerospace 

NESHAP establishes work practice, equipment, and pollution control 

standards for maintenance procedures. 

EPA will issue its final Control Techniques Guidelines document for the 

aerospace industry addressing reasonably available control technology 

(RACT) for volatile organic compounds (VOC) emissions, whichwill address 

the maintenance issues discussed in the document. 

����� ����� ��� ���������� ������� �� ����� ��������� �������� �������

���������� ��� ����������� �� ��� ���������� �� ��������� ��� ����� ���

���������� ������� � ������� �������� ������ ��� ����� ��� ��� ��������

��������� ���������������� ���� ������ ��������� ��� ���� ������

Sector Notebook Project 68 February 1998 
Air Transportation Industry Compliance and Enforcement History 

VI. COMPLIANCE AND ENFORCEMENT HISTORY 

Background 

Until recently, EPA has focused much of its attention on measuring 

compliance with specific environmental statutes. This approach allows the 

Agency to track compliance with the Clean Air Act, the Resource 

Conservation and Recovery Act, the Clean Water Act, and other 

environmental statutes. Within the last several years, the Agency has begun 

to supplement single-media compliance indicators with facility-specific, 

multimedia indicators of compliance. In doing so, EPA is in a better position 

to track compliance with all statutes at the facility level, and within specific 

industrial sectors. 

A major step in building the capacity to compile multimedia data for industrial 

sectors was the creation of EPA's Integrated Data for Enforcement Analysis 

(IDEA) system. IDEA has the capacity to “read into” the Agency's singlemedia databases, extract compliance records, and match the records to 

individual facilities. The IDEA system can match Air, Water, Waste, 

Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given 

facility, and generate a list of historical permit, inspection, and enforcement 

activity. IDEA also has the capability to analyze data by geographic area and 

corporate holder. As the capacity to generate multimedia compliance data 

improves, EPA will make available more in-depth compliance and 

enforcement information. Additionally, sector-specific measures of success 

for compliance assistance efforts are under development. 

Compliance and Enforcement Profile Description 

Using inspection, violation and enforcement data from the IDEA system, this 

section provides information regarding the historical compliance and 

enforcement activity of this sector. With this decision, the selection criteria 

are consistent across sectors with certain exceptions. For the sectors that do 

not normally report to the TRI program, data have been provided from EPA's 

Facility Indexing System (FINDS) which tracks facilities in all media 

databases. Please note, in this section, EPA does not attempt to define the 

actual number of facilities that fall within each sector. Instead, the section 

portrays the records of a subset of facilities within the sector that are well 

defined within EPA databases. 

As a check on the relative size of the full sector universe, most notebooks 

contain an estimated number of facilities within the sector according to the 

Bureau of Census (see Section II). With sectors dominated by small 

businesses, such as metal finishers and printers, the reporting universe within 

the EPA databases may be small in comparison to Census data. However, 

Sector Notebook Project 69 February 1998 
Air Transportation Industry Compliance and Enforcement History 

the group selected for inclusion in this data analysis section should be 

consistent with this sector's general make-up. 

Following this introduction is a list defining each data column presented 

within this section. These values represent a retrospective summary of 

inspections and enforcement actions, and reflect solely EPA, State, and local 

compliance assurance activities that have been entered into EPA databases. 

To identify any changes in trends, the EPA ran two data queries, one for the 

past five calendar years (April 1, 1992 to March 31, 1997) and the other for 

the most recent twelve-month period (April 1, 1996 to March 31, 1997). The 

five-year analysis gives an average level of activity for that period for 

comparison to the more recent activity. 

Because most inspections focus on single-media requirements, the data 

queries presented in this section are taken from single media databases. These 

databases do not provide data on whether inspections are state/local or EPAled. However, the table breaking down the universe of violations does give 

the reader a crude measurement of the EPA's and States' efforts within each 

media program. The presented data illustrate the variations across EPA 

Regions for certain sectors.5 This variation may be attributable to state/local 

data entry variations, specific geographic concentrations, proximity to 

population centers, sensitive ecosystems, highly toxic chemicals used in 

production, or historical noncompliance. Hence, the exhibited data do not 

rank regional performance or necessarily reflect which regions may have the 

most compliance problems. 

Compliance and Enforcement Data Definitions 

General Definitions 

Facility Indexing System (FINDS) -- this system assigns a common facility 

number to EPA single-media permit records. The FINDS identification 

number allows EPA to compile and review all permit, compliance, 

enforcement and pollutant release data for any given regulated facility. 

Integrated Data for Enforcement Analysis (IDEA) -- is a data integration 

system that can retrieve information from the major EPA program office 

databases. IDEA uses the FINDS identification number to link separate data 

records from EPA’s databases. This allows retrieval of records from across 

media or statutes for any given facility, thus creating a “master list” of 

5 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD, 

PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK, 

TX); VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X 

(AK, ID, OR, WA). 

Sector Notebook Project 70 February 1998 
--

Air Transportation Industry Compliance and Enforcement History 

records for that facility. Some of the data systems accessible through IDEA 

are: AIRS (Air Facility Indexing and Retrieval System, Office of Air and 

Radiation), PCS (Permit Compliance System, Office of Water), RCRIS 

(Resource Conservation and Recovery Information System, Office of Solid 

Waste), NCDB (National Compliance Data Base, Office of Prevention, 

Pesticides, and Toxic Substances), CERCLIS (Comprehensive Environmental 

and Liability Information System, Superfund), and TRIS (Toxic Release 

Inventory System). IDEA also contains information from outside sources 

such as Dun and Bradstreet and the Occupational Safety and Health 

Administration (OSHA). Most data queries displayed in notebook sections 

IV and VII were conducted using IDEA. 

Data Table Column Heading Definitions 

Facilities in Search -- are based on the universe of TRI reporters within the 

listed SIC code range. For industries not covered under TRI reporting 

requirements (metal mining, nonmetallic mineral mining, electric power 

generation, ground transportation, water transportation, and dry cleaning), or 

industries in which only a very small fraction of facilities report to TRI (e.g., 

printing), the notebook uses the FINDS universe for executing data queries. 

The SIC code range selected for each search is defined by each notebook's 

selected SIC code coverage described in Section II. 

Facilities Inspected indicates the level of EPA and state agency 

inspections for the facilities in this data search. These values show what 

percentage of the facility universe is inspected in a one-year or five-year 

period. 

Number of Inspections -- measures the total number of inspections 

conducted in this sector. An inspection event is counted each time it is 

entered into a single media database. 

Average Time Between Inspections -- provides an average length of time, 

expressed in months, between compliance inspections at a facility within the 

defined universe. 

Facilities with One or More Enforcement Actions -- expresses the number 

of facilities that were the subject of at least one enforcement action within the 

defined time period. This category is broken down further into federal and 

state actions. Data are obtained for administrative, civil/judicial, and criminal 

enforcement actions. Administrative actions include Notices of Violation 

(NOVs). A facility with multiple enforcement actions is only counted once 

in this column, e.g., a facility with 3 enforcement actions counts as 1 facility. 

Sector Notebook Project 71 February 1998 
--

Air Transportation Industry Compliance and Enforcement History 

Total Enforcement Actions -- describes the total number of enforcement 

actions identified for an industrial sector across all environmental statutes. A 

facility with multiple enforcement actions is counted multiple times, e.g., a 

facility with 3 enforcement actions counts as 3. 

State Lead Actions shows what percentage of the total enforcement 

actions are taken by state and local environmental agencies. Varying levels 

of use by states of EPA data systems may limit the volume of actions 

recorded as state enforcement activity. Some states extensively report 

enforcement activities into EPA data systems, while other states may use their 

own data systems. 

Federal Lead Actions -- shows what percentage of the total enforcement 

actions are taken by the United States Environmental Protection Agency. 

This value includes referrals fromstate agencies. Many of these actions result 

from coordinated or joint state/federal efforts. 

Enforcement to Inspection Rate -- is a ratio of enforcement actions to 

inspections, and is presented for comparative purposes only. This ratio is a 

rough indicator of the relationship between inspections and enforcement. It 

relates the number of enforcement actions and the number of inspections that 

occurred within the one-year or five-year period. This ratio includes the 

inspections and enforcement actions reported under the Clean Water Act 

(CWA), the Clean Air Act (CAA) and the Resource Conservation and 

Recovery Act (RCRA). Inspections and actions from the TSCA/FIFRA/ 

EPCRA database are not factored into this ratio because most of the actions 

taken under these programs are not the result of facility inspections. Also, 

this ratio does not account for enforcement actions arising from noninspection compliance monitoring activities (e.g., self-reported water 

discharges) that can result in enforcement action within the CAA, CWA, and 

RCRA. 

Facilities with One or More Violations Identified -- indicates the 

percentage of inspected facilities having a violation identified in one of the 

following data categories: In Violation or Significant Violation Status 

(CAA); Reportable Noncompliance, Current Year Noncompliance, Significant 

Noncompliance (CWA); Noncompliance and Significant Noncompliance 

(FIFRA, TSCA, and EPCRA); and Unresolved Violation and Unresolved 

High Priority Violation (RCRA). The values presented for this column reflect 

the extent of noncompliance within the measured time frame, but do not 

distinguish between the severity of the noncompliance. 

Violation status may be a precursor to an enforcement action, but does not 

necessarily indicate that an enforcement action will occur. 

Sector Notebook Project 72 February 1998 
Air Transportation Industry Compliance and Enforcement History 

Media Breakdown of Enforcement Actions and Inspections -- four 

columns identify the proportion of total inspections and enforcement actions 

within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each 

column is a percentage of either the “Total Inspections” or the “Total 

Actions” column. 

VI.A. Air Transportation Industry Compliance History 

Exhibit 13 provides an overview of the reported compliance and enforcement 

data for the air transportation industry over the past five years (April 1992 to 

April 1997). These data are also broken out by EPA Regions thereby 

permitting geographical comparisons. A few points evident from the data are 

listed below. 

As shown, there were 444 facilities identified through IDEA with air 

transportation SIC codes. Of these, 52 percent (231) were inspected in the 

last 5 years. 

� Over the 5 years, 973 inspections were conducted at those 231 

facilities. On average, each facility was inspected between 4 and 5 

times, or about once a year. 

� The 973 inspections resulted in 48 facilities having enforcement 

actions taken against them. At those 48 facilities, there were a total 

of 97 enforcement actions, meaning each facility averaged 

approximately 2 enforcement actions over the past 5 years. 

� The average enforcement to inspection rate is 0.10. This average rate 

means that for every 10 inspections conducted, there is 1 resulting 

enforcement action taken. Across the regions, this rate ranged from 

0.03 to 0.30. 

Sector Notebook Project 73 February 1998 
Air Transportation Industry Compliance and Enforcement History 

E

xhibit 13. Five-Y

e

a

r E

nfo

r

c

e

m

e

nt and C

o

m

plianc

e Sum

m

a

r

y fo

r the Air T

rans

portation Industry 

J 

E

nforcement 

to Inspection 

Rate 

0.22 0.30 

0.03 0.09 

0.09 

0.11 0.03 

0.29 0.10 0.11 0.10 

I 

Percent Federal 

Lead 

Acti

o

ns 

50% 12% 

0% 0% 

50% 

0% 

100% 

0% 0% 

29% 12% 

H 

Percent 

State Lead 

Acti

o

ns 

50% 88% 

100% 100% 

50% 

100% 

0% 

100% 100% 

71% 88% 

G 

Total 

E

nforcement 

Acti

o

ns 

4 

17 

4 

37 

8 

6 2 

4 8 7 

97 

F 

F

acilities with 

1 or More 

E

nforcement 

Acti

o

ns 

3 5 

3 

16 

4 

5 1 

2 5 4 

48 

E 

A

verage 

M

onths 

Between 

Inspections 

77 20 

20 20 

16 

42 32 

90 20 80 27 

D 

N

u

m

ber of 

Inspections 

18 56 

137 402 

89 

53 58 

14 82 64 

973 

C 

F

acilities 

Inspecte 

d 

4 

13 25 95 15 

17 13 

9 

14 26 

231 

B 

F

acilities 

in Search 

23 19 46 

132 

23 

37 31 

21 27 85 

444 

A 

Region 

I II III IV V VI VII VIII IX X T

O

T

AL 

V I . B . 

Comparison of 

E n f o r cem e n t 

Activity Between 

S e l e c t ed 

Industries 

Exhibits 14 and 15 

a llo w t h e 

compliance history 

o f t h e a i r 

tr ans p o rt a t io n 

sector to be 

compared to the 

other industries 

covered by the 

industry sector 

n o t e b o o k s . 

C o m p a r is o n s 

between Exhibits 

14 and 15 permit 

the identification 

o f trends in 

compliance and 

e n f o r cem e n t 

records of the 

various industries 

by comparing data 

covering the last 

five years (April 

1992 to April 

1997) to that of 

the past year 

(April 1996 to 

Ap ril 1997) . 

S o me p o in ts 

evident from the 

data are listed 

below. 

�

Overall, the air 

tr a ns p o rt a t io n 

sector enforcement 

Sector Notebook Project 74 February 1998 
Air Transportation Industry Compliance and Enforcement History 

numbers are mostly consistent, on a percentage basis, with the other sectors. 

� As shown in Exhibit 14, the air transportation enforcement-toinspection rate is 0.10 over the past 5 years. Over the last year, as 

shown in Exhibit 15, the air transportation enforcement-to-inspection 

rate is 0.08. 

Exhibits 16 and 17 provide a more in-depth comparison between the air 

transportation industry and other sectors by breaking out the compliance and 

enforcement data by environmental statute. As in the previous exhibits, the 

data cover the last five years (Exhibit 16) and the last year (Exhibit 17) to 

facilitate the identification of recent trends. A few points evident from the 

data are listed below. 

� As shown, over the past 5 years, nearly half of all inspections 

conducted and resulting in enforcement actions at air transportation 

facilities have been under RCRA. 

� Over the past year, while RCRA accounted for more than half of all 

inspections, only 25 percent of the enforcement actions were under 

RCRA. 

Sector Notebook Project 75 February 1998 
Sector Notebook Project February 1998 76

Exhibit 14: Five-Year E

nforcement and Com

pliance Sum

mary for Selected Industries

A

C

D

E F G

H 

Industry Sector Facilities

in Search

Facilities

Inspected

Number of

Inspections

Average

Months

Between

Inspections

Facilities with

1 or more

Enforcement

Actions

Total

Enforcement

Actions

Percent

State

 Lead

Actions

PeFe

L

Ac

Metal Mining 1,232 378 1,600 46 63 111 53% 

Coal Mining 3,256 741 3,748 52 88 132 89% 

Oil and Gas Extraction 4,676 1,902 6,071 46 149 309 79% Non-Metallic Mineral Mining 5,256 2,803 12,826 25 385 622 77% 

Textiles 355 267 1,465 15 53 83 90% 

Lumber and Wood 712 473 2,767 15 134 265 70% 

Furniture 499 386 2,379 13 65 91 81% 

Pulp and Paper 484 430 4,630 6 150 478 80% 

Printing 5,862 2,092 7,691 46 238 428 88% 

Inorganic Chemicals 441 286 3,087 9 89 235 74% 

Resins and Manmade Fibers 329 263 2,430 8 93 219 76% 

Phar

maceuticals 164 129 1,201 8 35 122 80% 

Organic Chemicals 425 355 4,294 6 153 468 65% 

Agricultural Chemicals 263 164 1,293 12 47 102 74% 

Petroleum Refining 156 148 3,081 3 124 763 68% 

Rubber and Plastic 1,818 981 4,383 25 178 276 82% Stone, Clay, Glass and Concrete 615 388 3,474 11 97 277 75% 

Iron and Steel 349 275 4,476 5 121 305 71% 

Metal Castings 669 424 2,535 16 113 191 71% 

Nonferrous Metals 203 161 1,640 7 68 174 78% 

Fabricated Metal Products 2,906 1,858 7,914 22 365 600 75% 

Electronics 1,250 863 4,500 17 150 251 80% 

Automobile Assembly 1,260 927 5,912 13 253 413 82% 

Shipbuilding and Repair 44 37 243 9 20 32 84% 

Ground Transportation 7,786 3,263 12,904 36 375 774 84% 

Water Transportation 514 192 816 38 36 70 61% 

Air Transportation 444 231 973 27 48 97 88% 

Fossil Fuel Electric Power 3,270 2,166 14,210 14 403 789 76% 

Dry Cleaning 6,063 2,360 3,813 95 55 66 95% 

Exhibit 15: O

neYear E

nforcement and Com

pliance Sum

mary for Selected Industries

A

C

D

E

F

G

Industry Sector Facilities in

Search

Facilities

Inspected

Number of

Inspections

Facilities with 1 or More

Violations

Facilities with 1 or more

Enforcement Actions

Total

Enforcemen

Actions

Number

Percent* Number

Percent*

Metal Mining 1,232 142 211 102 72% 9 6% 1

Coal Mining 3,256 362 765 90 25% 20 6% 2Oil and Gas Extraction 4,676 874 1,173 127 15% 26 3% 3

Non-Metallic Mineral Mining 5,256 1,481 2,451 384 26% 73 5% 9

Textiles 355 172 295 96 56% 10 6% 1

Lumber and Wood 712 279 507 192 69% 44 16% 5

Furniture 499 254 459 136 54% 9 4% 1

Pulp and Paper 484 317 788 248 78% 43 14% 7

Printing 5,862 892 1,363 577 65% 28 3% 5

Inorganic Chemicals 441 200 548 155 78% 19 10% 3

Resins and Madmade Fibers 329 173 419 152 88% 26 15% 3

Phar

maceuticals 164 80 209 84 105% 8 10% 1

Organic Chemicals 425 259 837 243 94% 42 16% 5

Agricultural Chemicals 263 105 206 102 97% 5 5% 1

Petroleum Refining 156 132 565 129 98% 58 44% 13

Rubber and Plastic 1,818 466 791 389 83% 33 7% 4Stone, Clay, Glass and Concrete 615 255 678 151 59% 19 7% 2

Iron and Steel 349 197 866 174 88% 22 11% 3

Metal Castings 669 234 433 240 103% 24 10% 2

Nonferrous Metals 203 108 310 98 91% 17 16% 2

Fabricated Metal 2,906 849 1,377 796 94% 63 7% 8

Electronics 1,250 420 780 402 96% 27 6% 4

Automobile Assembly 1,260 507 1,058 431 85% 35 7% 4

Shipbuilding and Repair 44 22 51 19 86% 3 14% 

Ground Transportation 7,786 1,585 2,499 681 43% 85 5% 10

Water Transportation 514 84 141 53 63% 10 12% 1Air Transportation 444 96 151 69 72% 8 8% 1

Fossil Fuel Electric Power 3,270 1,318 2,430 804 61% 100 8% 13Dry Cleaning 6,063 1,234 1,436 314 25% 12 1% 1

BB
Air Transportation Industry Compliance and Enforcement History 

Exhibit 16: Five-Year I

nspection and E

nforcement Sum

mary by Statute for Selected Industries 

FIFR

A/TS

C

A/ 

EPCRA/Other 

% of Total 

Actions 

17% 

1% 

3% 

3% 

6% 

16% 

14% 

4% 

4% 

5% 

6% 

5% 

6% 

11% 

7% 

11% 

4% 

8% 

14% 

10% 

13% 

7% 

9% 

3% 

3% 

4% 0% 

5% 

0% 

% of Total 

Inspections 

1% 

1% 

0% 

0% 

2% 

1% 

1% 

2% 

1% 

1% 

4% 

5% 

4% 5% 

2% 

2% 

1% 

1% 

2% 

1% 

2% 

2% 

2% 

5% 

1% 

1% 0% 

1% 

0% 

RCRA 

% of Total 

Actions 

12% 

8% 

18% 

4% 

14% 

31% 

43% 

10% 

29% 

30% 

23% 

20% 

28% 30% 

21% 

34% 

30% 

31% 31% 

31% 

43% 

50% 

43% 

47% 

45% 

33% 48% 

10% 

71% 

% of Total 

Inspections 

8% 

4% 

8% 

3% 

18% 

44% 

34% 

15% 

35% 

34% 

38% 

45% 

44% 28% 

36% 

35% 

31% 

28% 

32% 

33% 

45% 

47% 

43% 

42% 

29% 

37% 48% 

11% 

41% 

Clean Water Act 

% of Total 

Actions 

52% 

28% 

14% 

13% 

25% 

6% 

0% 

28% 

3% 

21% 

28% 

25% 

25% 20% 

13% 

11% 

9% 

26% 10% 

17% 

11% 

11% 

9% 

25% 

11% 

34% 20% 

26% 

6% 

% of Total 

Inspections 

52% 

38% 

16% 

14% 

22% 

6% 

3% 

32% 

5% 

27% 

23% 

15% 

16% 24% 

20% 

12% 

13% 

26% 

11% 

18% 

12% 

13% 

8% 

14% 

12% 

23% 27% 

32% 

3% 

Clean Air Act 

% of Total 

Actions 

19% 

64% 

65% 

81% 

54% 

47% 

42% 

59% 

64% 

44% 

43% 

49% 

42% 39% 

59% 

44% 

57% 

35% 44% 

43% 

33% 

32% 

39% 

25% 

41% 

29% 32% 

59% 

23% 

% of Total 

Inspections 

39% 

57% 

75% 

83% 

58% 

49% 

62% 

51% 

60% 

38% 

35% 

35% 

37% 43% 

42% 

51% 

56% 

45% 55% 

48% 

40% 

38% 

47% 

39% 

59% 

39% 25% 

57% 

56% 

Total 

Enforcement 

Actions 

111 

132 

309 

622 

83 

265 

91 

478 

428 

235 

219 

122 

468 102 

763 

276 

277 

305 

191 

174 

600 

251 

413 

32 

774 

70 97 

789 

66 

Total 

Inspections 

1,600 

3,748 

6,071 

12,826 

1,465 

2,767 

2,379 

4,630 

7,691 

3,087 

2,430 

1,201 

4,294 1,293 

3,081 

4,383 

3,474 

4,476 

2,535 

1,640 

7,914 

4,500 

5,912 

243 

12,904 

816 973 

14,210 

3,813 

Facilities 

Inspected 

378 

741 

1,902 

2,803 

267 

473 

386 

430 

2,092 

286 

263 

129 

355 164 

148 

981 

388 

275 424 

161 

1,858 

863 

927 

37 

3,263 

192 231 

2,166 

2,360 

Industry Sector 

Metal Mining Coal Mining Oil and Gas Extraction Non-Metallic Mineral Mining Textiles Lumber and Wood Furniture Pulp and Paper Printing Inorganic Chemicals Resins and Manmade Fibers Phar

maceuticals 

Organic Chemicals Agricultural Chemicals Petroleum Refining Rubber and Plastic Stone, Clay, Glass and Concrete Iron and Steel Metal Castings Nonferrous Metals Fabricated Metal Electronics Automobile Assembly Shipbuilding and Repair Ground Transportation Water Transportation Air Transportation Fossil Fuel Electric Power Dry Cleaning 

Sector Notebook Project 77 February 1998 
Air Transportation Industry Compliance and Enforcement History 

Exhibit 17: O

neYear I

nspection and E

nforcement Sum

mary by Statute for Selected Industries 

FIFR

A/TS

C

A/ 

EPCRA/Other 

% of 

Total 

Actions 

30% 

0% 

0% 

0% 

0% 

40% 

9% 

1% 

0% 

6% 

5% 

0% 

0% 

9% 

10% 

0% 

0% 

0% 

0% 

7% 

0% 

5% 

0% 

0% 

1% 

9% 0% 

0% 

0% 

% of 

Total 

Inspections 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 0% 

0% 

0% 

RCRA 

% of 

Total 

Actions 

30% 

5% 

24% 

2% 

8% 

25% 

45% 

7% 

23% 

25% 

5% 

14% 

34% 

36% 

15% 

23% 

30% 

24% 

35% 

30% 

57% 

53% 

47% 

50% 

44% 

45% 25% 

5% 

38% 

% of 

Total 

Inspections 

8% 

4% 

9% 

3% 

17% 

44% 

32% 

14% 

33% 

39% 

38% 

45% 

47% 

30% 

34% 

35% 

28% 

26% 30% 

41% 

43% 

43% 

41% 

35% 

26% 

38% 57% 

9% 

30% 

Clean Water Act 

% of 

Total 

Actions 

40% 

14% 

9% 

9% 

17% 

5% 

0% 

19% 

0% 

9% 

38% 

14% 

13% 

0% 

8% 

13% 

7% 

29% 

8% 

20% 

2% 

5% 

6% 

50% 

10% 

36% 42% 

21% 

6% 

% of 

Total 

Inspections 

40% 

40% 

10% 

10% 

17% 

6% 

2% 

32% 

4% 

26% 

24% 

11% 

13% 

22% 

17% 

10% 

10% 

23% 

10% 

15% 

11% 

14% 

7% 

11% 

11% 

24% 15% 

32% 

1% 

Clean Air Act 

% of 

Total 

Actions 

0% 

82% 

68% 

89% 

75% 

30% 

45% 

73% 

77% 

59% 

51% 

71% 

54% 

55% 

67% 

64% 

63% 

47% 

58% 

43% 

41% 

37% 

47% 

0% 

46% 

9% 

33% 

73% 

56% 

% of 

Total 

Inspections 

52% 

56% 

82% 

87% 

66% 

51% 

66% 

54% 

63% 

35% 

38% 

43% 

40% 

48% 

49% 

55% 

62% 

52% 

60% 

44% 

46% 

44% 

53% 

54% 

64% 

38% 28% 

59% 

69% 

Total 

Enforcement 

Actions 

10 

22 

34 

91 

12 

52 

11 

74 

53 

31 

36 

14 

56 

11 

132 

41 

27 

34 

26 

28 

83 

43 

47 

4 

103 

11 12 

135 

16 

Total 

Inspections 

211 

765 

1,173 

2,451 

295 

507 

459 

788 

1,363 

548 

419 

209 

837 

206 

565 

791 

678 

866 

433 

310 

1,377 

780 

1,058 

51 

2,499 

141 151 

2,430 

1,436 

Facilities 

Inspected 

142 

362 

874 

1,481 

172 

279 

254 

317 

892 

200 

173 

80 

259 

105 

132 

466 

255 

197 

234 

108 

849 

420 

507 

22 

1,585 

84 96 

1,318 

1,234 

Industry Sector 

Metal Mining Coal Mining Oil and Gas Extraction Non-Metallic Mineral Mining Textiles Lumber and Wood Furniture Pulp and Paper Printing Inorganic Chemicals Resins and Manmade Fibers Phar

maceuticals 

Organic Chemicals Agricultural Chemicals Petroleum Refining Rubber and Plastic Stone, Clay, Glass and Concrete Iron and Steel Metal Castings Nonferrous Metals Fabricated Metal Electronics Automobile Assembly Shipbuilding and Repair Ground Transportation Water Transportation Air Transportation Fossil Fuel Electric Power Dry Cleaning 

Sector Notebook Project 78 February 1998 
Air Transportation Industry Compliance and Enforcement History 

VI.C. Review of Major Cases/Supplemental Environmental Projects 

This section provides summary information about major cases that have 

affected this sector, and a list of Supplemental Environmental Projects 

(SEPs). 

VI.C.1. Review of Major Cases 

As shown in the previous tables, there have been only 97 enforcement actions 

taken against air transportation industries over the past 5 years. Stemming 

from those 97 actions are at least 34 cases, some of which are discussed in 

more detail below. The 34 cases can be categorized as follows: 

� 1 Clean Air Act case (new source performance standards)

� 2 Clean Water Act cases (pretreatment and NPDES permit violations)

� 21 RCRA (USTs, unpermitted storage units, etc.)

� 5 CERCLA

� 4 TSCA (PCBs)

� 1 EPCRA (release reporting).

Of these 34 cases, 16 were against federal facilities and 2 were criminal cases. 

Supplemental environmental projects were negotiated in 3 of the cases. 

(These are discussed in more detail in the following section.) The following 

cases are examples of EPA’s enforcement against air transportation industries. 

� Pacific Southwest Airmotive, Inc. (PSA) owned and operated a jet 

engine overhaul facility in San Diego, California. EPA brought an 

enforcement action against PSA (and ultimately its new owner U.S. 

Air) under the Clean Water Act for violations of the pretreatment 

standard for metal finishing operations. During operations, PSA 

discharged an average of 73,000 gallons per day of regulated 

industrial wastewater through the sewers to San Diego’s Point Loma 

wastewater treatment plant. The court entered a civil consent decree 

in which U.S. Air agreed to pay $335,000 in civil penalties. 

� Grumman St. Augustine Corporation strips, paints, and refurbishes 

aircraft at its St. Augustine, Florida, facility. EPA brought an 

enforcement action against Grumman in 1991 as part of the RCRA 

Land Disposal Restrictions Initiative. A consent decree in 1993 

settled the enforcement action. The decree calls for a civil penalty of 

$2.5 million, of which Grumman will initially pay $1.5 million in cash. 

The penalty would be reduced by $1 million if Grumman completed 

several innovative pollution prevention projects. 

Sector Notebook Project 79 February 1998 
Air Transportation Industry Compliance and Enforcement History 

The pollution prevention provisions would substantially reduce or eliminate 

several highly toxic waste streams, including a paint stripper, methylene 

chloride, and ozone-depleting chemicals (e.g., CFCs). EPA estimated that up 

to 240,000 pounds of hazardous emissions per year will be eliminated and 

toxic sludge will be reduced if Grumman complied with RCRA. Furthermore, 

if compliance with RCRA is achieved, approximately 2.4 million gallons of 

potable water will be conserved. 

� As a result of an imminent and substantial endangerment situation, 

EPA issued Reese Air Force Base in Lubbock, Texas, an 

administrative order under RCRA Section 7003. In March 1993, 

EPA learned that Reese had detected trichloroethylene above safe 

drinking water standards in some privately-owned drinking water 

wells near the base. After confirming the data, EPA issued the 

administrative order. The order requires the base to conduct the 

following activities: 

(1) Collect samples from wells in a 36-square-mile area (within 

a 2-mile perimeter of the base) to determine the extent of the 

contamination 

(2) Notify the owners of any contamination 

(3) Supply an alternate source of drinking water to the residents 

with contaminated wells 

(4) Monitor the ground water in and adjacent to the plume. 

Reese has completed the initial sampling of about 950 wells, provided 

carbon filters for all the impacted water wells, and connected some of 

the users to the City of Lubbock’s water system. The city is in the 

process of connecting its water lines to the residents that live within 

the city limits. The residents living outside the city limits may use the 

water from the wells after it has been carbon filtered. 

� Region II conducted a major consolidated multimedia inspection of 

Kennedy International Airport in New York City, which is operated 

by the Port Authority of New York and New Jersey. A number of 

violations were documented, both at facilities operated by the Port 

Authority itself, as well as at some facilities operated by airline or 

service companies. In 1993 a complaint was issued to the Port 

Authority citing it for TSCA violations and proposing a penalty of 

$289,000. On June 28, 1994, Region II issued three additional 

administrative complaints to OgdenAviation Services, Inc., citing that 

company for violations of the federal underground storage tank 

regulations, and proposing penalties totaling $109,125. 

VI.C.2. Supplementary Environmental Projects (SEPs) 

Sector Notebook Project 80 February 1998 
Air Transportation Industry Activities and Initiatives 

SEPs are compliance agreements that reduce a facility's non-compliance 

penalty in return for an environmental project that exceeds the value of the 

reduction. Often, these projects fund pollution prevention activities that can 

reduce the future pollutant loadings of a facility. Information on SEP cases 

can be accessed via the Internet at EPA’s Enviro$en$e website: 

http://es.inel.gov/sep. 

The following are examples of three SEPs negotiated with air transportation 

facilities. 

� In response to violations of EPCRA Section 304 and CERCLA 

Section 103 at the Memphis/Shelby County Airport (Tennessee), the 

County Airport Authority agreed to implement a $475,000 pollution 

prevention SEP. The SEP involves the purchase of equipment that 

will assist in the deicing of runways. The use of this equipment will 

reduce the amount of deicing fluid required, which results in a 

substantial reduction in the use of ethylene glycol. In addition, the 

Authority agreed to pay a $9,000 penalty to resolve its past violations. 

� EPA achieved a comprehensive settlement of a TSCA administrative 

complaint against the Port Authority of New York and New Jersey, 

which is a joint State agency that operates Kennedy and LaGuardia 

Airports in New York City. The Region had cited the Authority for 

multiple violations of PCB regulations at the airports. The settlement 

provides that the port authority will pay a civil penalty of $19,500 and 

conduct two SEPs. One SEP consists of a 3-year fluorescent bulb 

recycling program for all Port Authority facilities in the New York 

metropolitan area. The total cost to implement the SEP is $130,000. 

The second SEP is a storm water management training program that 

will be conducted at the airports over a 2-year period. This SEP will 

cost $90,000. 

� American Airlines, Inc. was charged with violations of the RCRA land 

disposal restrictions for discharging degreasing solvents, which are 

hazardous waste, into their onsite injection wells. A consent order 

was filed against American Airlines, in which it agreed to pay a cash 

penalty of $20,000, take affirmative actions to prevent further 

injection of restricted wastes, and conduct a SEP in the amount of 

$385,235. The SEP reduces chrome wastes by subjecting them to a 

chrome waste recovery system. The system reduces the waste by 98 

percent or, in this case, 6,969 pounds per year. In addition, this 

system results in the elimination of 26 million gallons of wastewater 

annually into injection wells. 

VII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES 

Sector Notebook Project 81 February 1998 
Air Transportation Industry Activities and Initiatives 

This section highlights the activities undertaken by this industry sector and 

public agencies to voluntarily improve the sector's environmental 

performance. These activities include those initiated independently by 

industrial trade associations. In this section, the notebook also contains a 

listing and description of national and regional trade associations. 

VII.A. Sector-Related Environmental Programs and Activities 

VII.A.1. EPA Voluntary Programs 

Environmental Leadership Program 

The Environmental Leadership Program (ELP) is a national initiative 

developed by EPA that focuses on improving environmental performance, 

encouraging voluntary compliance, and building working relationships with 

stakeholders. EPA initiated a one year pilot program in 1995 by selecting 12 

projects at industrial facilities and federal installations that demonstrate the 

principles of the ELP program. These principles include: environmental 

management systems, multimedia compliance assurance, third-party 

verification of compliance, public measures of accountability, pollution 

prevention, community involvement, and mentor programs. In return for 

participating, pilot participants received public recognition and were given a 

period of time to correct any violations discovered during these experimental 

projects. 

EPA is making plans to launch its full-scale Environmental Leadership 

Program in 1998. The full-scale program will be facility-based with a 6-year 

participation cycle. Facilities that meet certain requirements will be eligible 

to participate, such as having a community outreach/employee involvement 

programs and an environmental management system (EMS) in place for 2 

years. (Contact: http://es.inel.gov/elp or Debby Thomas, ELP Deputy 

Director, at (202) 564-5041) 

Project XL 

Project XL was initiated in March 1995 as a part of President Clinton’s 

Reinventing Environmental Regulation initiative. The projects seek to 

achieve cost effective environmental benefits by providing participants 

regulatory flexibility on the conditionthat they produce greater environmental 

benefits. EPA and program participants will negotiate and sign a Final Project 

Agreement, detailing specific environmental objectives that the regulated 

entity shall satisfy. EPA will provide regulatory flexibility as an incentive for 

the participants’ superior environmental performance. Participants are 

encouraged to seek stakeholder support from local governments, businesses, 

and environmental groups. EPA hopes to implement fifty pilot projects in 

four categories, including industrial facilities, communities, and government 

Sector Notebook Project 82 February 1998 
Air Transportation Industry Activities and Initiatives 

facilities regulated by EPA. Applications will be accepted on a rolling basis. 

For additional information regarding XL projects, including application 

procedures and criteria, see the April 23, 1997 Federal Register Notice. 

(Contact: Fax-on-Demand Hotline (202) 260-8590, Web: 

http://www.epa.gov/ProjectXL, or Christopher Knopes at EPA’s Office of 

Policy, Planning and Evaluation at (202) 260-9298.) 

Climate Wise Program 

EPA’s ENERGY STAR Buildings Program is a voluntary, profit-based program 

designed to improve the energy-efficiency in commercial and industrial 

buildings. Expanding the successful Green Lights Program, ENERGY STAR 

Buildings was launched in 1995. This program relies on a 5-stage strategy 

designed to maximize energy savings thereby lowering energybills, improving 

occupant comfort, and preventing pollution—all at the same time. If 

implemented in every commercial and industrial building in the United States, 

ENERGY STAR Buildings could cut the nation’s energy bill by up to $25 billion 

and prevent up to 35% of carbon dioxide emissions. (This is equivalent to 

taking 60 million cars of the road). ENERGY STAR Buildings participants 

include corporations; small and medium sized businesses; local, federal and 

state governments; non-profit groups; schools; universities; and health care 

facilities. EPA provides technical and non-technical support including 

software, workshops, manuals, communication tools, and an information 

hotline. EPA’s Office of Air and Radiation manages the operation of the 

ENERGY STAR Buildings Program. (Contact: Green Light/Energy Star 

Hotline at 1-888-STAR-YES orMaria Tikoff Vargas, EPA Program Director 

at (202) 233-9178 or visit the ENERGY STAR Buildings Program website at 

http://www.epa.gov/appdstar/buildings/) 

Green Lights Program 

EPA’s Green Lights program was initiated in 1991 and has the goal of 

preventing pollution by encouraging U.S. institutions to use energy-efficient 

lighting technologies. The program saves money for businesses and 

organizations and creates a cleaner environment by reducing pollutants 

released into the atmosphere. The programhas over 2,345 participants which 

include major corporations, small and medium sized businesses, federal, state 

and local governments, non-profit groups, schools, universities, and health 

care facilities. Each participant is required to survey their facilities and 

upgrade lighting wherever it is profitable. As of March 1997, participants had 

lowered their electric bills by $289 million annually. EPA provides technical 

assistance to the participants through a decision support software package, 

workshops and manuals, and an information hotline. EPA’s Office of Air and 

Radiation is responsible for operating the Green Lights Program. (Contact: 

Green Light/Energy Star Hotline at 1-888-STAR-YES or Maria Tikoff 

Vargar, EPA Program Director, at (202) 233-9178.) 

Sector Notebook Project 83 February 1998 
Air Transportation Industry Activities and Initiatives 

WasteWi$e Program 

The WasteWi$e Program was started in 1994 byEPA’s Office of Solid Waste 

and Emergency Response. The program is aimed at reducing municipal solid 

wastes by promoting waste prevention, recycling collection and the 

manufacturing and purchase of recycled products. As of 1997, the program 

had about 500 companies as members, one third of whom are Fortune 1000 

corporations. Members agree to identify and implement actions to reduce 

their solid wastes setting waste reduction goals and providing EPA with 

yearly progress reports. To member companies, EPA, in turn, provides 

technical assistance, publications, networking opportunities, and national and 

regional recognition. (Contact: WasteWi$e Hotline at 1-800-372-9473 or 

Joanne Oxley, EPA Program Manager, (703) 308-0199.) 

NICE3 

The U.S. Department of Energy is administering a grant program called The 

National Industrial Competitiveness through Energy, Environment, and 

Economics (NICE3). By providing grants of up to 45 percent of the total 

project cost, the program encourages industry to reduce industrial waste at 

its source and become more energy-efficient and cost-competitive through 

waste minimization efforts. Grants are used by industry to design, test, and 

demonstrate new processes and/or equipment with the potential to reduce 

pollution and increase energy efficiency. The program is open to all 

industries; however, priority is given to proposals from participants in the 

forest products, chemicals, petroleumrefining,steel, aluminum, metal casting 

and glass manufacturing sectors. (Contact: Chris Sifri, DOE at 

(303) 275-4723 or Eric Hass, DOE at (303) 275-4728 or 

http//www.oit.doe.gov/access/nice3.) 

Design for the Environment (DfE) 

DfE is working with several industries to identify cost-effective pollution 

prevention strategies that reduce risks to workers and the environment. DfE 

helps businesses compare and evaluate the performance, cost, pollution 

prevention benefits, and human health and environmental risks associated with 

existing and alternative technologies. The goal of these projects is to 

encourage businesses to consider and use cleaner products, processes, and 

technologies. For more information about the DfE Program, call (202) 260-

1678. To obtain copies of DfE materials or for general information about 

DfE, contact EPA’s Pollution Prevention Information Clearinghouse at (202) 

260-1023 or visit the DfE Website at http://es.inel.gov/dfe. 

VII.A.2. Trade Association/Industry Sponsored Activity 

Industry Working Group on Deicing 

Sector Notebook Project 84 February 1998 
Air Transportation Industry Activities and Initiatives 

A deicing working group was formed by the American Association of Airport 

Executives and the Airports Council International - North America to (1) 

study the use of deicing chemicals on aircraft; (2) study the feasibility of 

locating deicing facilities away from airport gates; and (3) provide information 

to both industry members and the federal government on ways in which 

deicing operations can be improved upon. As part of their investigation, the 

working group sent out surveys to the major airports to determine which 

deicing procedures and chemicals are being used by the industry. Some of the 

survey questions relate to environmental effects of deicing and recovery, 

reuse, and recycling of waste deicer. The results of the survey indicated that 

a number of air carriers are using alternative chemicals, and have constructed 

remote deicing facilities with deicer recovery systems. (Contact: Carter 

Morris, American Association of Airport Executives, (703) 824-0500.) 

ISO 14000 

ISO 14000 is a series of internationally-accepted standards for environmental 

management. The series includes standards for environmental management 

systems (EMS), guidelines on conducting EMS audits, standards for auditor 

qualifications, and standards and guidance for conducting product lifecycle 

analysis. Standards for auditing and EMS were adopted in September 1996, 

while other elements of the ISO 14000 series are currently in draft form. 

While regulations and levels of environmental control vary from country to 

country, ISO 14000 attempts to provide a common standard for 

environmental management. The governing body for ISO 14000 is the 

International Organization for Standardization (ISO), a worldwide federation 

of 110+ country members based in Geneva, Switzerland. The American 

National Standards Institute (ANSI) is the United States representative to 

ISO. 

VII.B. Summary of Trade Associations 

American Association of Airport Executives 

4212 King Street 

Alexandria, VA 22302 

Phone: (703) 824-0500 

Fax: (703) 820-1395 

The American Association of Airport Executives (AAAE) is comprised of 

airport management personnel and representatives of companies serving the 

civil airport industry. The AAAE sponsors educational seminars, conducts 

examinations, and maintains a speakers' bureau. AAAE has an Environmental 

Service/Environmental Affairs Committee that provides assistance on 

complying with environmental regulations (e.g., regulation interpretations, 

training seminars, and manuals). Environmental compliance assistance is 

focused on the storm water rules. Publications are the bimonthly Airport 

Sector Notebook Project 85 February 1998 
Air Transportation Industry Activities and Initiatives 

Executive Magazine and the Airport Report Newsletter. Separate yearly 

conferences are held on topics such as national airports, legislative issues 

(semiannual), international facilities, and general annual issues. 

Airports Association Council International 

1220 19th Street NW, Suite 200 

Washington, D.C. 20036 

Phone: (202) 293-8500 

Fax: (202) 331-1362 

The Airports Association Council International (AACI) is comprised of 

operators of public airport facilities. The group also includes government 

bodies that own and operate major airports. The association provides 

compliance assistance to members through seminars, meetings, conferences, 

regulation interpretations, and manuals. One day conferences are frequently 

held on environmental management and auditing techniques. Committees 

include planning and environmental,safety and security, and U.S. government 

affairs. Publications are the weekly Airport Highlights, the annual Worldwide 

Airport Traffic Report, and the Airport Environmental Management 

Handbook. The AACI holds an annual meeting in September or October. 

National Air Transportation Association 

4226 King Street 

Alexandria, VA 22302 

Phone: (703) 845-9000 

Fax: (703) 845-8176 

The National Air Transportation Association (NATA) representsthe interests 

of aviation services companies such as fixed-based operators and on-demand 

air taxis. NATA provides compliance assistance to members in the form of 

guidelines, explanations of regulations, and seminars. Most of NATA's work 

relates to Federal Aviation Administration regulations; however, 

environmental services are also provided. Environmental aspects of deicing 

and aircraft cleaning are not a major focus, because the membership does not 

include the carrier companies, however, some fixed-based operators carry out 

deicing operations. Publications include an annual membership directory, an 

annual report, and the monthly ATAnews. 

Sector Notebook Project 86 February 1998 
Air Transportation Industry Activities and Initiatives 

Airports Council International - North America 

1775 K Street, NW Suite 500 

Washington, D.C. 20006 

Phone: (202) 293-8500 

Fax: (202) 331-1362 

Airports Council International - North America (ACI-NA) is the “voice of 

airports” representing local, regional, state, and national governing bodies 

that own and operate commercial airports in the U.S. ACI-NA member 

airports enplane more the 90 percent of the domestic and virtually all of the 

international airliner passenger and cargo traffic in North America. 

Aerospace Industries Association 

1250 Eye Street, NW 

Washington, D.C. 20005 

Phone: (202) 371-8400 

Member companies of Aerospace Industries Association (AIA) represent 

the primary manufacturers of military and large commercial aircraft, 

engines, accessories, rockets, spacecraft, and related items. 

General Aviation Manufacturers Association 

1400 K Street, NW Suite 801 

Washington, D.C. 20005 

Phone: (202) 393-1500 

The General Aviation Manufacturers Association (GAMA) is a national 

trade association, headquartered in Washington, D.C., representing 53 

manufacturers of fixed-wing aircraft, engines, avionics, and components. 

In addition to building nearly all U.S. general aviation aircraft, GAMA 

member companies also operate aircraft fleets, airport fixed-based 

operations, pilot schools, and training facilities. 

Air Transport Association of America 

1709 New York Ave., NW 

Washington, D.C. 20006 

Phone: (202) 626-4000 

Fax: (202) 626-4181 

The Air Transport Association of America (ATA) represents 22 major 

scheduled airlines in the U.S. engaged in transporting persons, goods, or 

mail by aircraft. ATA serves its membership by providing aviation safety, 

advocating industry positions, conducting designated industry-wide 

programs and monitoring public understanding. ATA publishes annually 

Air Transport as well as fact sheets, press releases, studies, speeches, and 

references pertaining to air transport. The ATA holds quarterly meetings. 

Sector Notebook Project 87 February 1998 
Air Transportation Industry Activities and Initiatives 

Air Line Pilots Association 

535 Herndon Parkway 

P.O. Box 1169 

Herndon, VA 20170 

Phone: (703) 689-2270 

Fax: (703) 689-4370 

The Air Line Pilots Association (ALPA) is a union representing 46,000 

airline pilots at 45 U.S. airlines. ALPA provides lobbying of airline pilot 

views to Congress and government agencies, and devotes approximately 

20 percent of its dues income to support aviation safety. 

Regional Airline Association 

1200 19th Street, N.W. Suite 300

Washington, D.C. 20036

Phone: (202) 857-1170

Fax: (202) 429-5113

The Regional Airline Association (RAA) represents regional air carriers

and suppliers of products and services that support the industry before the

Congress, Federal Aviation Administration, Department of Transportation

and other federal and state agencies. RAA member airlines transport

between 90-95 percent of all regional airline passengers. RAA developed

an Environmental Compliance Handbook addressing compliance issues.

Aircraft Owners & Pilots Association 

421 Aviation Way 

Frederick, MD 21701 

Phone: (301) 695-2000 

With over 270,000 members, the Aircraft Owners & Pilots Association 

(AOPA) represents the interests of general aviation pilots. It provides 

insurance plans, flight planning, and other services, and sponsors large flyin meetings. 

Helicopter Association International 

1619 Duke Street 

Alexandria, VA 22314 

Phone: (703) 683-4646 

Fax: (703) 683-4745 

The members of Helicopter Association International (HAI) represent 

rotocraft operators and manufacturers. 

Sector Notebook Project 88 February 1998 
Air Transportation Industry Activities and Initiatives 

National Association of State Aviation Officials 

8401 Colesville Road, Suite 505 

Silver Spring, MD 20910 

Phone: (301) 588-0587 

Fax: (301) 585-1803 

The National Association of State Aviation Officials (NASAO) represents 

departments of transportation and state aviation departments and 

commissions from 49 states, Puerto Rico, and Guam. 

National Business Aircraft Association 

1200 18th Street, NW, Room 200

Washington, D.C. 20036

Phone: (202) 783-9000

The National Business Aircraft Association (NBAA) represents 361

companies that own and operate aircraft flown for corporate purposes.

NBAA is affiliated with the International Business Aircraft Council.

Flight Safety Foundation 

2200 Wilson Boulevard 

Arlington, VA 22201 

Phone: (703) 739-6700 

Fax: (703) 739-6708 

The Flight Safety Foundation (FSF) promotes air transport safety. Its 

members include airport and airline executives and consultants. 

Experimental Aircraft Association 

EAA Aviation Center 

Oshkosh, WI 54903 

Phone: (414) 426-4800 

The Experimental Aircraft Association (EAA), with over 700 local 

chapters, promotes the interests of home-built and sport aircraft owners. 

Aviation Distributors & Manufacturers Association 

1900 Arch Street 

Philadelphia, PA 19103 

Phone: (215) 564-3484 

Fax: (215) 564-3484 

The Aviation Distributors & Manufacturers Association (ADMA) 

represents the interests of a wide variety of aviation firms including FBOs 

and component parts manufacturers. 

Sector Notebook Project 89 February 1998 
Air Transportation Industry Activities and Initiatives 

International Air Transport Association 

2000 Peel Street

Montreal, PQ, Canada H3A2R4

Phone: (514) 844-6311

Fax: (514) 844-5286

The International Air Transport Association (IATA) is an association of

105 international air carriers whose main functions include coordination of

fares and operations.

Cargo Airline Association 

1220 19th Street, N.W. Suite 400

Washington, D.C. 20036

Phone: (202) 293-1030

Fax: (202) 293-4377

The Cargo Airline Association (CAA) is a nationwide trade organization

with members made up of all segments of the air cargo community. The

Association is responsible for promoting the use of air freight services;

monitoring regulatory activity; representing the industry before Congress,

various agencies, and courts; providing educational programs; and keeping

members up-to-date on all issues affecting air cargo.

Sector Notebook Project 90 February 1998 
Air Transportation Industry References/Bibliography 

VIII. RESOURCE MATERIALS/BIBLIOGRAPHY 

Section II: Introduction to the Air Transportation Industry 

��� ������� ��������� ������������������������������������ ��� ��������� ������������

Dun & Bradstreet Market Place Webpage, http://www.dnb.imarketinc.com 

Federal Aviation Administration home page, http://www.faa.gov and 

http://www.faa.gov/publichinfo.htm 

Standard Industrial Classification Manual, Office of Management and Budget, 1987. 

1992 Census of Transportation, Communications, and Utilities: U.S. Summary, U.S. Department 

of Commerce. 

Encyclopedia of American Business History and Biography: The Airline Industry, A. Bruccoli 

Clark Layman, Inc., and Facts On File, Inc., 1992. 

Air Environmental Management Handbook, M. Schneiderman and T. Devine, 1993. 

Memorandum on ICAO, January 1994. 

Transportation in America, Eno Transportation Foundation, Inc., 1994. 

Air Transport Association Annual Report, 1997. Air Transport Association. 

Airports and the Environment: A Study of Air Transport, Alan H. Stratford. 

Section III: Operations Description 

Hazardous Materials Shipments: Classification, Identification, and Procedures. Keller & 

Associates, 1977. 

Planning & Design of Airports, 3rd Edition, Robert Horonjeff and Francis McKelvey. McGrawHill Book Co. 1983. 

Airport Planning & Management, 2nd Edition, Alexander Wells, TAB Books, 1992. 

Report of the American Association of Airport Executives - AD HOC Working Group on 

Deicing, American Association of Airport Executives, Alexandria, Virginia, 1993. (Contact: 

David Jeffrey, American Association of Airport Executives, (703) 824-0500 ext.136.) 

Sector Notebook Project 91 February 1998 
Air Transportation Industry References/Bibliography 

Aviation Week and Space Technology, January 1995. 

U.S. EPA Office of Air and Radiation, AIRS Database, 1997. 

AHM 640-Aircraft Loading and Off-Loading Precautions. International Air Transport 

Association (IATA). 

Pollution Prevention/Environmental Impact Reduction Checklist for Airports, U.S. EPA Office 

of Federal Activities. 

Section IV: Pollution Prevention Opportunities 

Fact Sheet - FCAD-1. California, Plus Fact Sheet - Minnesota and Michigan FM10-2-9. Office 

of Research and Development, 1990. 

Guides to Pollution Prevention - The Mechanical Equipment Repair Industry, Office of Research 

and Development, EPA/625/R-92/008. September, 1992. 

Guide to Cleaner Technologies - Cleaning and Degreasing Process Changes, Office of Research 

and Development, EPA/625/R-93/017, February 1994. 

Guide to Cleaner Technologies - Alternatives to Chlorinated Solvents for Cleaning and 

Degreasing, Office of Research and Development, EPA/625/R-93/016, February 1994. 

Project Summary - Onsite Solvent Recovery, Office of Research and Development, EPA/600/SR94/026, March 1994. 

Guide to Cleaner Technologies - Organic Coating Replacements, Office of Research and 

Development, EPA/600/R-94/006, September 1994. 

Guide to Cleaner Technologies - Alternative Metal Finishes, Office of Research and 

Development, EPA/625/R-94/007, September 1994. 

Project Summary - Pollution Prevention Opportunity Assessment, U.S. Coast Guard Aviation 

Training Center, Mobile, AL. Office of Research and Development, EPA/600/SR-94/156, 

September 1994. 

Project Report - NASA Langley Research Center and Tidewater Interagency Pollution 

Prevention Project Program. Office of Research and Development, EPA/600//R-94/171, 

September 1994. 

Project Summary - Pollution Prevention Opportunities Assessment, U.S. Naval Base, Norfolk 

Naval Air Station, Office of Research and Development, EPA-600/SR-95/135, September 1995. 

Sector Notebook Project 92 February 1998 
Air Transportation Industry References/Bibliography 

Environmental Research Brief - Pollution Prevention Assessment of Manufacturing of Aircraft 

Landing Gear. Office of Research and Development, EPA 600-S-95/032, August 1995. 

Program Summary - Parts Washing Alternatives Study, U.S. Coast Guard, Office of Research 

and Development. EPA-600-SR-95/006, February 1995. 

Demonstration of Alternative Cleaning Systems, Office of Research and Development, 

EPA/600/R-95-120, August 1995. 

Airline Fuel Consumption, The Boeing Company, 1997. 

Section V: Summary of Applicable Federal Statutes and Regulations 

Environmental Regulatory Compliance Handbook. Prepared for Regional Airline Association, 

Prepared by Energy and Environmental Analyses, Inc., 1996. 

Overview of the Storm Water Program, Office of Water, U.S. Environmental Protection Agency, 

June 1996. EPA 833-R-96-008. 

New Technology Plays Key Role in Deicing Gear, Aviation Week & Space Technology, January 

9, 1995, pp. 40-41. 

Airports and the Environment: A Study of Air Transport. Stratford, A.H. 

Flying Off Course: Environmental Impacts of America’s Airports, Natural Resources Defense 

Council, October 1996. 

Section VII: Compliance Activities and Initiatives 

Enforcement Accomplishments Report, FY 1992, U.S. EPA, Office of Enforcement (EPA/230-

R93-001), April 1993. 

Enforcement Accomplishments Report, FY 1993, U.S. EPA, Office of Enforcement (EPA/300-

R94-003), April 1994. 

Enforcement Accomplishments Report, FY 1994, U.S. EPA, Office of Enforcement (EPA/300-

R95-004), May 1995. 

Enforcement Accomplishments Report, FY 1995, U.S. EPA, Office of Enforcement (EPA/300-

R96-006), July 1996. 

Enforcement Accomplishments Report, FY 1996, U.S. EPA, Office of Enforcement (EPA/300-

R97-003), May 1997. 

Sector Notebook Project 93 February 1998