MEMORANDUM 

TO: Airport Deicing Administrative Record 

FROM: Mark Briggs and Mary Willett, ERG

DATE: October 2010

SUBJECT: Estimated Capital and Operating Costs for Storage Tanks 

This memorandum estimates both the capital and annual operating and maintenance (O&M) 

costs for an airport to install storage tanks for stormwater impacted by aircraft deicing and antiicing fluid (ADF). Costs have been developed for tanks that are used to store ADF impacted 

stormwater prior to discharging to a Publicly Owned Treatment Plant (POTW) or to an on-site 

treatment system. The tank costs described in the following paragraphs have taken into 

consideration comments received on the proposed rule. First, EPA agrees with the comment that 

normalizing tank volume to the number of airline departures as was done at proposal is not the 

preferred method of calculating the necessary tank volume. Therefore, EPA has normalized tank 

storage volume requirements to annual ADF use. EPA believes ADF use will account for 

variables such as dilution caused by variable size storm events in different regions of the United 

States. Next, EPA agrees with the comment that all data should be used to estimate tank volume 

requirements and associated costs, and therefore tank volumes for both Akron and Denver are 

included in the analysis. By including all tanks designed to contain the variety of precipitation 

events occurring at a particular airport during the course of a deicing season, the likelihood of 

underestimating tank size and ultimately tank costs have been reduced. Lastly, EPA agrees with 

the comment that all tanks considered for this analysis should be above-ground permanent 

storage tanks, and therefore the following analysis does not include either underground storage 

tanks or temporary “frac” tanks. 

Costing Approach 

Storage tanks are used at airports to provide either flow and/or concentration equalization of 

aircraft deicing and anti-icing fluid (ADF) contaminated stormwater prior to POTW discharge or 

to an on-site treatment system. The actual size of the storage tanks depends primarily on the 

amount of ADF impacted stormwater generated during precipitation events, the area from which 

deicing stormwater is collected, and the rate the tanks can be discharged to either the POTW or 

the on-site treatment system. 

For EPA’s airport deicing operations effluent guidelines program, ERG obtained storage tank 

volumes from five airports: Denver1

, Cincinnati2, Pittsburgh3, Portland4 and Akron5. ERG was 

also able to obtained installed capital costs for the storage tanks at Denver, Cincinnati and 

 

1

 USEPA Engineering Site Visit Report for Denver International Airport, August 2006. 

2

 USEPA Engineering Site Visit Report for Cincinnati/Northern Kentucky International Airport, Sept. 2007. 3

 USEPA Engineering Site Visit Report for Pittsburgh International Airport, August 2006. 4

 USEPA Engineering Site Visit Report for Portland, Oregon International Airport, August 2006. 5

 McQueen, R., and Arendt, T., Development of a Deicer System for Akron-Canton Airport. 
Memorandum 

October 2010 

Page 2 

Akron. Using normalized ADF usage data for each of these airports, ERG normalized tank 

volumes and costs to the annual ADF use per year to provide an equation that could be used to 

estimate storage tank sizes and costs at other airports. EPA’s normalized ADF usage amounts 

represent ADF amounts without any water dilution. ERG chose ADF usage as the costing basis 

for tank storage since the amount of tank storage needed is directly related to the amount of ADF 

applied for aircraft deicing, and ADF applied is a function of the frequency, duration, and 

intensity of precipitation events occurring at a particular airport during the course of a deicing 

season. In addition, the storage tanks at each of these airports are used to contain ADF impacted 

stormwater from deicing pads, gates and apron areas prior to discharge to a POTW and/or on-site 

treatment, and therefore the hydraulic capacity has likely been designed with specific discharge 

requirements (e.g., maximum flow and equalized pollutant concentrations) in mind. 

Capital and Operating Costs for Storage Tanks 

ADF usage information, storage tanks volumes, costs and normalized tank volumes and costs are 

provided in Table 1. The data in Table 1 indicates the volume of storage tanks at the five airports 

range between 1.5 million gallons and 8 million gallons, with the average being approximately 

4.6 million gallons. The average unit cost for storage tanks calculated from the data in Table 1 

is $1.67/gallon. The normalized storage tank volume, calculated from the data provided in Table 

1 is 13.1 gal/gal ADF use/yr. 

Table 1. Storage Tank Volumes and Installed Capital Cost for Various Airports Using 

EPA ADF Usage Estimates 

Airport 

ADF Usage 

(gal/yr)* 

Total Storage 

Tank Volume

 (gal) 

Storage Tank 

Volume ADF Use 

(gal/gal/yr) 

Installed 

Capital Cost 

(2006 $) 

Storage Tank 

Capital Cost 

($/gal) 

Denver 1 1,043,138 6,520,000 6.3 $795,000(a) $1.89 

Pittsburgh 2 943,982 5,140,000 5.4 NA NA 

Cincinnati 3 715,836 8,000,000 11.2 $9,440,000 $1.18 

Portland4 112,086 2,000,000 17.8 NA NA 

Akron5 60,246 1,500,000 24.9 $2,890,000 $1.93 

Averages: 13.1 $1.67 

NA – Not available. 

(a) Cost provided for one 420,000 gallon storage tank. 

1 – Includes six 420,000 gallon storage tanks plus one 4 million gallon storage pond (Pond 003A). Includes 2.4 

million gallon tank for Deicing Pads Charlie, Sierra Widebody, C, Cargo, FBO, Military, a 1.3 million gallon tank 

for Deicing Pads Echo, Y-North and Y-South, and a 1.4 million gallon EQ tank for the RO system. 

2 – Includes one 8-million gallon high glycol concentration storage tank for runoff from deicing pads 

3 – Includes one 2-million gallon storage tank for stormwater from gates, taxiways, snow pads and GRVs. 

Stormwater contains BOD5 concentrations greater than 1,000 mg/L. 

4 – Includes two 750,000-gallon equalization tanks for storage of high glycol stormwater from deicing pads. 
Memorandum 

October 2010 

Page 3 

To determine if the unit cost for above-ground storage tanks was reasonable, ERG compared the 

$1.67/gallon unit cost to the cost for permanent storage tanks reported in the ACRP Fact Sheets6 

According to Fact Sheet 30 for aboveground permanent storage tank costs range from $1.25 to 

$1.75/gallon for tanks ranging in size from 500,000 gallons to 1 million gallons. Unit costs for 

storage tanks between 1 million and 2 million gallons range from $1.00 to $1.50/gallon. ERG is 

not providing costs for underground storage tanks due to constraints such as existing 

underground utilities or high groundwater levels. Based on the data in the fact sheets, ERG 

believes the $1.67/gallon unit cost factor should provide a conservative estimate of tank costs for 

airports which are space constrained. 

Using the ADF use, the average tank volume per ADF use, and cost data in Table 1, ERG 

developed the following equation to estimate costs for storage tanks at all airports based on 

annual ADF use. 

Storage Tank Capital Cost ($) =ADF Use gal/yr × 13.1 gal/gal/yr × $1.67/gallon 

Only limited data were available in the airport questionnaire database to determine the annual 

operating and maintenance (O&M) cost for storage tanks. One airport, Buffalo/Niagra reported 

annual maintenance costs for their storage tanks ranged between $50,000 and $100,000. Using 

ADF usage information at the Buffalo/Niagra airport (281,836 gal/yr) and the reported annual 

O&M cost for Buffalo/Niagra ($75,000/yr), ERG calculated the normalized annual O&M cost 

for storage tanks to be $0.27/gal ADF used/year ($75,000/281,836). Using the normalized cost 

factor, ERG developed the following equation to estimate annual O&M costs for storage tanks at 

airports. 

Storage Tank O&M Cost ($/yr) = ADF gal/yr × $0.27/gal/yr ADF 

Summary

The equations included in this memorandum will be used in the airport deicing costs model to 

estimate option costs by airport. The input variable for these costs is the estimated amount of 

ADF use by airport. The estimated storage tank costs will be combined with other costs such as 

glycol collection vehicle and block and pump recovery technologies.

 

6

 Airport Cooperative Research Program, Fact Sheet 30: Permanent Tanks, 2009.