{A0137730.1 } 

# Draft Site Visit Report for Logan International Airport Boston, MA

Prepared for:



## U.S. Environmental Protection Agency

Engineering and Analysis Division
Office of Water 1200 Pennsylvania Avenue, NW Washington, D.C. 20460

Prepared by:

Eastern Research Group, Inc. 14555 Avion Parkway
Suite 200 Chantilly, VA 20151

August 2011

EPA Contract No. 68-CO2-095 Work Assignment 8-15{A0137730.1 } 2 Draft

Site Visit Report for Logan International Airport Boston, MA

1.0 P LACE AND D ATE

Massachusetts Port Authority

One Harborside Drive
East Boston, MA 02128

March 21, 2011

2.0 A TTENDEES

Logan International Airport Catherine Wetherell, Deputy Director, Capital Programs and Environmental Affairs (617) 568-3501 Vincent Cardillo, Deputy Director of Aviation Operations (617) 561-1936 Patricia Haederle, Assistant Director, Capital Programs

and Environmental Affairs Ira Wallach, Chief Aviation Counsel (617) 568-3151 Flavio Leo, Manager of Av iation Planning (617) 568-3528

Anderson & Kreiger LLP William Lahey, Attorney (617) 621-6550 Elizabeth Mason, Attorney (617) 621-6534

U.S. Environmental Protection Agency Brian D’Amico, Project Engineer (202) 566-1069 Newton Tedder, EPA Region 1 NPDES Permitting (617) 918-1038

Eastern Research Group, Inc. (technical contractor to U.S. EPA) Calvin Franz, ERG Economic Task Assignment Manager (781) 674-7383

3.0 B ACKGROUND AND O BJECTIVES

The U.S. Environmental Protection Agency (EPA) conducted a site visit at Logan International Airport (BOS), Boston, MA (Logan) on March 21, 2011. EPA conducted this site visit to collect

information to inform the Effluent Limitation Gu idelines rulemaking for discharges from airport deicing operations. EPA visited Logan to bett er understand its operati ons and constraints, including the significant land c onstraints described by Massachuse tts Port Authority (Massport) in its February 26, 2010 comments on the proposed Effluent Limitation Guidelines and New Source Performance Standards for the Airport Deicing Category published in the Federal Register on August 28, 2009 (Proposed Rule).{A0137730.1 } 3 4.0 O VERVIEW

Logan is owned and operated by Massport, an indepe ndent state authority that is also responsible for the Hanscom Field and Worcester Regional air ports, the Port of Bost on, and additional real estate holdings. It is the largest and busiest commercial airport in New England and one of the busiest (top 25) airports in the United States.

In 2010, Logan had approximately 353,000 aircra ft operations (takeoffs and landings) and handled approximately 27.4 million passenge rs, roughly 3.7 million of whom were on international flights. Its carriers include major airlines, regional and commuter airlines, foreignflagged air carriers and car go carriers. Airlines operat ing from Logan include:

 Major airlines: AirTran Airways, American Airlines, Continental, Delta, JetBlue Airways, Southwest Airlines, United Airlin es, and US Airways, which account for 85 percent of passenger enplanemen ts. (Alaska Airlines and Frontier Airlines also operate from Logan, but account for a very small percentage of passenger enplanements.)

 Regional/commuter airlines: American Eagle, Ca pe Air, Porter Airlines, Spirit Airlines, Sun Country, United Express, US Airways Express/Shuttle, Virgin America.

 Foreign air carriers: Aer Li ngus, Air Canada, Air France, Alitalia, British Airways, Iberia, Icelandair, Lufthansa, SATA (Azore s Express), Swiss International Air Lines, TACV (Cabo Verde Airlines), Virgin Atlantic Airways.

 Cargo carriers: ABX Air, Asta r Air Cargo, Air Transport In ternational, DHL Airways, Federal Express, and UPS Airlines.

There is no single dominant carrier at Logan; Am erican, US Airways, Delta and JetBlue account for approximately 14 percent to 18 percent of enplanements each.

As a major airport in the nati onal airspace system, Logan can e xperience significant delays and in fact is ranked as among the most congested airports in the United St ates (18th in 2009). Logan experiences minimal delays in good weather – when it can utilize three runways – but in poor weather (including low visi bility, strong winds and/or heavy rain, snow or other precipitation), it typically loses the use of at leas t one runway, with the result that capacity drops and delays increase. Another source of delay is Logan’s location in the Northeast next to the heavily congested airspace of New York/New Jersey/Pennsylvania and Washington DC. Aircraft travelling to and from Logan need to be metered through this airspace. Moreover, because Logan is primarily an “origin and dest ination” airport (meaning that most passengers either begin or end their air tr avel itinerary at Boston, as oppos ed to “hub” airports at which passengers connect with other flig hts to reach their ultimate des tination), aircraft serving Logan are more susceptible to air carrier network-related delays.{A0137730.1 } 4 5.0 F ACILITY D ESCRIPTION

Logan occupies approximately 1,750 acres of land in East Boston and Winthrop, immediately to the east of the densely populated urban nei ghborhood of East Boston, and is surrounded on its other three sides by, respectiv ely, Boston Harbor, Boston Inne r Harbor and Winthrop Bay. Moreover, almost all of the available space at Loga n is already occupied by existing airfield or landside activities. Approximately 80 percent of the site is us ed for runways, taxiways and related safety areas, aprons, and other aircraft op erational purposes; the re mainder is occupied by passenger and cargo terminals, access roads, and support infrastructure. A map of the airport showing these constraints is presented as Figure 1.

Logan has six runways, although one of these (15L/33R) is less than 2,560 feet long and accounts for a minimal percentage of total runway usage (it is used primarily by general aviation (GA) aircraft). Of the remaining runways:

 Runway 4L/22R is 7,861 feet long and accounts for 5.4 percent of arrivals and 31.5 percent of departures;

 Runway 4R/22L is 10,005 feet long and acc ounts for 45.6 percent of arrivals and 6.1 percent of departures.

 Runway 9/27 is 7,000 feet long and accounts fo r 31.9 percent of arrivals and 38.8 percent of departures.

 Runway 15R/33L is a 10,083 foot runway that accounts for 15.7 percen t of arrivals and 23.7 percent of departures.

 Runway 14/32 is 5,000 feet long and accounts fo r 1.4 percent of arrivals and 0.0 percent of departures.

6.0 F LIGHT O PERATIONS AT L OGAN A IRPORT

According to Massport, a combination of weathe r patterns and space cons traints at Logan make operations challenging, even dur ing good weather. Due to the airport’s coastal location, wind direction is highly variable:

 Winds most frequently blow from the northwest, about 37 percent of the time;

 Winds from the southwest o ccur 28 percent of the time;

 Winds from the northeast o ccur 18 percent of the time

 Winds blow least frequently from the s outheast, about 17 percent of the time.

This necessitates a more complex airfield layout at Logan than at airports with less variable winds, because the runways at Logan cannot be constructed to operate primarily in a single{A0137730.1 } 5 prevailing wind pattern; they must be oriented to provide significant capacit y in essentially every

direction.

The fact that Logan’s land area is relatively small and limited to a peninsula, in combination with this weather-driven requirement to build runway s that can operate in multiple wind patterns, has resulted in runways and taxiways that cross each other in many locations, as depicted in the Airport Diagram (Figure 2):

 With the wind from the northwest, Logan uses Runways 27 and 33L for both departures and arrivals, and Runway 32 for arrivals. Runways 27 and 33L cross each other, and Runway 32 crosses through the safety zone for Runway 27.

 With the wind from the southeast, Logan uses Runway 15R for both departures and arrivals, and Runways 9 and 14 for departur es. Runways 15R and 9 cross each other.

 With the wind from the southwest, Logan uses Runways 22R and 22L for departures, and Runways 22L and 27 for arrivals. Runways 22L and R 27 cross each other, and aircraft using those runways must cross Runway 22R (or its safety zone) going to or from

terminals.

 With the wind from the northeast, Logan uses Runways 4L and 4R for both departures and arrivals, and Runway 9 for departures. Again, Runways 4R and 9 cross, and aircraft using these runways must cross Runway 22R goi ng to or from terminals. This operational pattern is particularly relevant to deic ing operations since th e wind comes from the northeast for many New E ngland winter storms.

Thus, even in the best conditions, runway operati ons at Logan are highly complex with varying traffic patterns depending on weather conditions.

Furthermore, Logan is considered is delay pron e when weather conditions deteriorate and result in loss of available runways due to visibility or winds. When the weather is good and three runways can be used for operations, capacity is adequate and airlines will experience minimal delays. However, when weather deteriorates Logan generally loses the use of one runway; capacity decreases and delays incr ease rapidly if this occurs.

7.0 C URRENT A IRCRAFT D EICING /A NTI -I CING O PERATIONS

Two types of deicing operations are conducted at Logan from October or November through March or April: deicing of aircra ft, and deicing of paved areas, including the runways, taxiways and ramp areas. Aircraft deicing occurs appr oximately 112 days per y ear during the typical deicing season, and weather condi tions requiring deicing are not limited to snow, sleet and freezing rain events – deicing is very often require d on cold, clear mornings to remove frost that has built up on aircraft overnight, in the absence of any precipita tion. Deicing may be required if the air temperature is below approximately 38 to 40 degrees Fahrenheit, and might continue for

several hours after a storm ends.{A0137730.1 } 6 Aircraft deicing is the responsibility of the indi vidual airlines and is conducted by the airline (or its contractors) or Logan’s sole fixed-base operator. The majority of aircraft deicing operations at Logan are performed at the gate by the airlines. In general, ope rations in the gate area require four to six vehicles per aircraft , including catering, baggage, fuel a nd lavatory services vehicles. Airlines performing gate deicing typically use two deicing trucks per aircra ft (one on each side of the aircraft). As a result, deicing weather usually adds two mo re large vehicles to an already

constrained work area.

One airline, American Airlines, uses a glycol collection vehicle (GCV ) during frost deicing events to collect ADF-containing stormwater, but does not typically use it during storm events. Massport itself does not own or operate GCVs. The airlines use Best Management Practices (BMPs) to reduce the amount of ADF sprayed on airc raft. Delta, for example, uses steam mixed

with ADF.

Some aircraft deicing is perfor med at an off-gate location, Julie t “Pad.” Juliet Pad is a paved area, adjacent to taxiway J at the western end of R 14/32, designed to be us ed for aircraft parking when Runway 14/32 is not in use. Developmen t of Juliet Pad was initiated by US Airways to avoid gate constraints during poor weather/deicing conditions.. Th e area that is now Juliet Pad was paved when Massport built Runway 14/32; Mass port anticipated that the area might be used for parking aircraft and therefore increased its pavement thickness. Two airlines use Juliet Pad for deicing, US Airways and Jet Blue. When po ssible, 100 percent of JetBlue’s deicing is done at Juliet Pad, although the wind direction in some storms precl udes use of the pad for deicing. US Airways performs a variable percentage of deicing at Juliet Pad; in some storms, up to 80 percent of its deicing may be pe rformed at the pad. There is no co llection in place at Juliet Pad and deicing runoff from the pad dr ains directly in to Boston Har bor. Juliet Pad cannot be used when Runway 14/32 is in use.

Logan currently discharges stormwater – includ ing stormwater containi ng deicing runoff – to Boston Harbor pursuant to a 2007 NPDES permit issued by EPA Region 1 to Massport and certain airlines as co-permittees. This perm it required the development of a Storm Water Pollution Prevention Plan, including the design and implementation of BMPs aimed at the

reduction of deicer use and deic ing runoff discharges at Loga n. The airline co-permittees developed responsive BMPs, and Massport su bmitted these BMPs to EPA along with a certification of permit compliance (which is done annually). Nota bly, nearly fifteen years of Boston Harbor water quality testing has f ound no evidence of water quality falling below established water quality standard s during any deicing season fo r pollutants associated with deicer use (i.e., dissolved oxygen) . These findings were most re cently confirmed by the water quality study mandated by EPA in the current NPDES permit.

Massport is responsible for snow removal around the gates and terminals. Snow, which contains an unknown amount of aircraft deicing fluid (ADF) overspray and runoff, is plowed away from the gates, collected and dumped into snow melte rs, which then discharge into the stormwater drainage system. Of the 13 in-ground snow melte rs, seven are on the airf ield, two are for the west garage, four for the central gara ge, and four are for the south garage.{A0137730.1 } 7 7.1 Potential Sites for Pad Deicing/Anti-Icing Operations

7.1.1 EPA-Identified Sites

Massport indicated in its comments on the Proposed Rule that there would be major problems associated with trying to devel op deicing pads within Logan’s ex isting footprint. EPA suggested

that there were three sites that appeared to be potentially usable for pads: (1) Juliet Pad, in an expanded form, (2) Governors Island, and (3) the North Cargo area. These will be discussed in turn, and their locations are appr oximately indicated in Figure 3.

In any event, it is unlikely that even a single deicing pad with sufficient capacity would be adequate to enable Logan’s compliance with both the Proposed Rule a nd applicable Federal Aviation Administration (FAA) requirements. As indicated in Figure 3, wh ile Juliet Pad and/or a pad at Governors Island would be well-sited for operations in nor theasterly winds, they would be poorly sited for operations in a southeasterly or southwesterly wind. Si milarly, a pad in the North Cargo area would pose signi ficant operational difficultie s when winds are from the

southwest or northwest.

7.1.1.1 Juliet Pad

There are a number of potential aviation safety and ope rational constraints that would make the expansion of Juliet Pad unsuitable fo r increased deicing operations.

 Use of Juliet Pad – expanded or not – woul d be limited to times when Runways 14/32

and 9/27 are not in use. Juliet Pad coul d not be used when Runway 14/32 is open because aircraft in deicing positions would violate FAA Runway Safety Area and Runway Object Free Area requirements. In most storms, Runway 14/32 is not in use

because the wind is out of the northeast. Ho wever, as storms move through, wind shifts occur, and Logan may need to start using R unway 14/32 to maintain operational capacity;

Juliet Pad cannot be used for de icing if Runway 14/32 is in use. In addition, vertical objects on an Expanded Juliet Pad would penetr ate FAA “critical airspace surfaces” for Runway 9/27, so the pad could not be used wh en Runway 27 is active or when Runway 9 is being used for arrivals.

 Access to Juliet Pad would either require tw o-way traffic on taxiway J, or the use of Runway 14/32 as a taxiway, both of which create safety issues.

 Because Runway 14/32 is an operational r unway, deicing infrastructure cannot be installed at Juliet Pad; deic ing would have to be perf ormed there using portable equipment only, which would cause substant ial logistical and delay problems.

 Juliet Pad can currently be used for aircraft such as Boeing 737s and Airbus A320s, but not larger aircraft; taxiways do not provide su fficient clearance, nor is the pavement thick enough. Even with expansion, the pad would onl y be able to deice a limited number of larger aircraft; Logan expects only two of nine deicing posi tions at an expanded Juliet Pad would be usable for aircraft larger than FAA Design Group III (e.g., B-737, A320).{A0137730.1 } 8 After the site visit was conducted, Boston Logan i ndicated that even if Juliet Pad were expanded, using it to deice 100 percent of aircraft would result in significant de lays due to capacity limitations. Specifically, based on current Logan departure rates, patterns and fleet mix, deicing all aircraft at an Expanded Ju liet Pad would result in total de lays of 1,076 to 2,616 aircraft hours and 87,191 to 208,025 passenger hours annually. The to tal annual indirect cost of such delays would fall between $4.4 million and $10.5 million. At air traffic levels projected by the FAA for Logan for 2020, deicing all aircraft at an Expanded Juliet Pad would result in total delays of 1,900 to 5,251 aircraft hours and 152,272 to 415,153 passenger hours annually. The annual indirect cost of such delays would be betw een $7.7 million and $21 million. The total indirect cost of these delays over the next ten y ears would be between $65 million and $167 million.

7.1.1.2 Governors Island

Governors Island is located in Logan’s southeast corner, between the approach ends of Runways 4R and 32. Although the potential area availabl e for deicing operations at Governors Island appears sizable on a map, the actual available sp ace is much smaller due to the location of FAA Air Surveillance Radar to the east, Runway 4R/22L to the west, and Runway 32/14 to the south.

Moreover, the use of the Governors Island site fo r deicing operations w ould interfere with the

above-referenced FAA Air Surveillance Radar an d with FAA-protected ground and airspace, and the location of the radar and runways places signifi cant restrictions on the height of anything in the Governors Island area. Nothing in this ar ea can exceed the height of the radar platform, which is about 20 feet off the ground at approximat ely the same elevation as the runways. Thus, it would be impossible to site a deicing pad here because the aircraft tails would exceed the height limit.

There would be a potential for runway incursions due to the placement of runway and safety area crossings for aircraft and vehicl es traveling to and from a pa d on the Governors Island site., Also, access to the site could be difficult for de icing equipment. To reach the island without crossing any runways, vehicles woul d have to travel the perimeter road that starts in the vicinity of Juliet Pad. Drivers on the perimeter road require a special li cense and training.

After the site visit was conducted, Boston Logan indi cated that this area ha s been used to store spoil from the construction of the “Big Dig” (depression of Boston’s Central Artery) and is already close to the maximum elevation permitted by the radar. To use this area for a purpose such as storage of ADF-containing stormwater, L ogan would first have to remove the Big Dig spoil material.

7.1.1.3 North Cargo Area

The North Cargo Area is located just south of the west end of Runway 15R/33L. As suggested by the name, this area is used for air cargo operations. Buildings marked 8, 9, 13, 16, and 92 on the map (Figure 3) are perimeter hangers for this area, while the building marked 10 is a recently{A0137730.1 } 9 completed long-term parking garage. Under Logan’s latest master plan, this area is intended for significant development; Massport’s plan is to construct multiple hangars in this area, creating a “hanger row” between buildings 16 and 92 on th e map. However, while Logan is currently rehabilitating hangers 8, 9, and 16, it appears th ere are no immediate plans for demolition of existing hangers and expansion of hanger row due to the economic downturn. The large area shaded gray just north of the cargo area and hang er 9 is the safety area for Runway 15R/33L, and therefore is not usable for deicing.

While there appears to be some available space in the area for a potential deicing pad, this area is a cul-de-sac. Aircraft entering for deicing would need to perfor m a 180 degree turn to reach the taxiways and runways or be pushed backwards. In addition, due to noise restrictions, aircraft

movements in this area would re quire a tug, as aircraft are not allowed to move under their own power. In short, the operational difficulties that would be invol ved in maneuvering aircraft to

and from this location make it an unsuitabl e location for a centralized deicing pad.

Additionally, airport staff indicat ed that the entrance to the No rth Cargo Area is too small to allow more than a single aircraft to enter or exit at a time. The entrance width is constrained by

the location of Terminal E on one side and th e safety area for Runway 15R/33L on the other side, and therefore cannot re alistically be increased.

7.1.2 Massport-Identified Si tes for Pad Deicing

After the site visit was conducted, Boston Logan i ndicated that in order to evaluate Logan’s ability to comply with both the Proposed Rule (under which the airport would be expected to collect and treat 60 percent of available spent ADF) and applicable Federal Aviation Administration (FAA) requirements, Massport reta ined a team of engineering consultants to evaluate the feasibility and cost of installing and operating centralized de icing pads at Logan. Specifically, Massport’s team undertook a set of studies to determine the number, size and location of deicing pads that might enable Logan to comply with both EPA and FAA requirements without reducing airport capacity duri ng weather requiring deic ing operations. The team concluded that (1) compliance with both EPA and FAA requirements would require three separate deicing pads, (2) the siting, construc tion and operation of three pads would not be feasible or affordable, and (3) even a one-pad compliance option – Expanded Juliet Pad – would not be feasible due to operational and space constraints.

The location and size of the three theoretical deicing pads are approxi mated on Figure 4. One pad would be the Expanded Juliet Pad discu ssed above and shown on Figure 3. The other two pads would be located, respectively, north of R unway 15R/33L and west of Runway 22R/4L (the “North Pad”), and east of Runway 9/27 and s outh of Runway 15/R/33L (the “East Pad”).

All the limitations described in Section 7.1.1 c oncerning Expanded Juliet Pad apply to this configuration. The problems with the North and East Pads are also apparent in Figure 4. To achieve the size and location necessary to mainta in operations in all we ather conditions, both pads would require filling approximately 160 acre s of Boston Harbor at an estimated cost of $1.57 billion (excluding land purchase, environmental litigation, and permitting). On this basis, Massport concluded that deicing pads are not a feasible option.