MEMORANDUM TO: Brian D’Amico, USEPA/OW/OST/EAD FROM: Cortney Itle, ERG DATE: July 12, 2010 SUBJECT: Summary of Alaskan Airports Comments

In 2009, the U.S. Environmental Protection Agency proposed technology-based effluent standards for discharges from airport deicing operations. The Ag ency received multiple comments about Alaska (AK) airports and airlines; these comments were received from:

 State of Alaska Department of Transportation and Public Facilities;

 State of Alaska Department of Environmental Conservation, Division of Water, Wastewater Discharge Authorization Program;

 Ted Stevens Anchorage International Airport; and

 Alaska Airlines and Horizon Air. The purpose of this memorandum is to review and su mmarize comment issues that are specific to Alaskan airports and airlines. The main topics presented in each of the comments are summarized below. State of Alaska Department of Transporta tion and Public Facilities (EPA-HQ-OW-2004-0038- 1225.1)

 AK airports have relatively high numbers of comme rcial aircraft departures. However, they use small amounts of aircraft deicing fluids ( ADF) due to dry and cold climatic conditions. Therefore the aircraft departure thresholds in the rule will impact costs for small remote airports but will result in minimal environmental benefits.

 Because of the remote nature of AK airports, th ey are generally preppe d for individual flights and not continuous operations. Because of th is, AK airports rely heavily on mechanical methods for runway deicing.

 Some AK airports do not have airport traffi c towers and do not track the number of departures. The threshold of 1000 jet departur es per year should be raised to 2000 to avoid causing increased costs to small rural airports.

 During some conditions, E-36 (potassium acetat e) is used, although its effectiveness is limited by arctic temperatures.

 EPA’s cost estimate of switching to alterna tives to urea is underestimated, because of the need for large storage tanks, application vehicl es, and transportation. Heated storage tanks with circulation capabilities are needed. Shipments may be required to travel by barge, which can only occur in summer months so storage tanks would need to hold a whole winter’s supply of potassium acetate. Airports in Kotzebue (OTZ) and Nome (OME) currently use some potassium acetate because of their milder temperatures.

 One AK airport currently holds an 8 year supply of urea.

 FAA funds have been used to build urea processing plants at AK airports. State of Alaska Department of Environmental Conservation, Division of Water, Wastewater Discharge Authorization Program (EPA-HQ-OW-2004-0038-1230.1)

 As noted in the comments from State of Alask a Department of Transportation and Public Facilities, the jet departure threshold should be adjusted to 2000 jet departures per year to reflect the conditions at rural airports.

 At Ted Stevens Anchorage International Airpor t (ANC), the airlines apply and collect the ADF. The airlines should be permitted as well as the airport.

 EPA should investigate the effectiveness and cost of alternative deicers in the arctic climate.

 General comments on the rule were provided, including: o Available ADF should be defined. o EPA should study the chemicals and their toxicities in formulations of ADF. o The threshold of 460,000 gallons s hould be lowered to 400,000 gallons. o There should be a specific prohibition of discharge of ADF to the land. o Guidance is needed for military facilities. o For GRVs, requirements are needed for the d escription of operational coverage of the facility, a percentage of the time during deici ng days that GRVs must be operated, and a requirement that all collected ADF is disposed of in a treatment facility. o EPA should consider a phased implementation of the rule. o EPA should develop guidance for the states on the environmental impacts or safety issues associated with alternative pavement deicers. o The rule should account for local safety and climatic conditions in determining the 25 gallons per aircraft safety exemption. o EPA should consider limiting BOD and glycol. o The weekly average effluent limitation is better than the monthly average effluent limitation. o Runways should not be considered new sour ces, it would be difficult to enforce by the permitting authority. o The airports should be allowed to choose whet her to have single or multiple deicing pads.

Ted Stevens Anchorage International Airport (EPA-HQ-OW-2004-0038-1212.1)

 The ban of urea will not necessarily reduce COD load because increased levels of potassium acetate are needed to maintain the same level of deicing that urea delivers.

 General comments on the rule were provided, including: o Airports required to use a centralized pad shoul d be allowed a lower cut off for the size of planes that are required to use it. o New source rule should only apply to new airfields and not to new runways at existing airfields.o Need to better define difference between "deicing fluid" and "anti-icing fluid". o Current rule does little to encourage the use of pollution prevention through alternate technologies. o Need to allow for separate or multiple permits at one airport. o Deicing pads will slow down capacity at ANC. o Estimated costs for ANC are incorrect (some specific operational information is provided). o The length of time after deicing that deicing pa ds be required to keep diversions in place is not specified. o The type of emulsifier is not specified. o GRV collection rates are not representative. o Air quality permits might be needed for treat ment facilities and operating multiple GRVs. o Normalized ADF can be hard to determin e based on information from manufacturer. o Snow removal and GRV operation on deicing pads will cause operational difficulties. o GRV is not defined. o Time frame to install pads must be flexible to allow coordination with other projects. o Potassium acetate may increase wear and oxidation on break pads.

Alaska Airlines and Horizon Air (EPA-HQ-OW-2004-0038-1221.1)

 Purchasing and operating GRVs at Bethel Airport (BET) would cost over $2.0 million dollars. This airport would collect approximately 1,000 gallons of deicing fluid each year in support of just two to three daily flights.

 These requirements would affect other small airports, such as OME and OTZ. The high costs would result in very low amounts of COD reduction at each location and little environmental benefit.

 EPA’s estimates for OTZ show costs less than the cost of one GRV unit. In addition, EPA estimates that Juneau (JNU), BET, and OME would need to purchase one GRV plus a portion of another GRV. GRVs can only be purchased in units of one and in remote locations such as AK, rental of GRVs is not an option.

 The purchase and operation of a GRV at a small ai rport would represent a large percentage of the overall operating budget.

 Many cities in AK do not have a local POTW, so the airports would need to collect and treat the glycol on-site.

 At locations in arctic AK (such as BET), there is no stormwater to collect during the deicing season (October to March) because temperatures are rarely above freezing. Any ADF used becomes encapsulated in the snow and becomes runoff during the spring thaw. GRVs would not be effective in collecting ADF at these airports.

 The collected ADF would need to be stored until a sufficient quantity was collected to treat. The treatment system would only be run occasionally and an AFB system would not be appropriate for these cases. Due to the cost and impracticality of using ADF, AK airports would collect and store the stormwater for treatment in the lower-48 states. The construction of storage facilities and the cost of shipment are expected to be prohibitive.

 EPA should establish a new minimum threshold of facilities that use less than 90,000 gallons of deicing fluid a year (instead of airports with greater than 1,000 jet departures). ATA has evaluated airport and ADF usage data and dete rmined that a new threshold would have little impact on the rule because the Tier Two airports that are required to collect 20% account for only 1.7% of the ADF usage in the U.S. AT A’s arguments for the creation of a new tier would reduce economic a nd operational burden.

 Urea provides benefit as a “back-up” deicer when other products are not available, particularly because of transportation issues in arctic areas. Urea can be shipped and stored more easily than liquid deicers. Closing down AK airports is not an option because they are often the only transportation available during winter months to ship in supplies.

 Urea should be permitted as a “back-up” or severe weather deicer for AK airports to ensure that vital airport operations are not impacted by lack of liquid pavement deicers.

 ANC is not included in the list of Tier One Ai rports, but according to recent airport reports the usage for the last 5 years averaged greater than 460,000 gallons. The costs of a deicing pad and treatment system at ANC would require that the costs would be over 5% of operating revenues, which exceeds the 3% revenue thres hold established for economic achievability. EPA will have to re-evaluate the economic achievability analysis for deicing pads.

 Airlines will be impacted economically by this rule and a Revenue Test or other means of assessing economic impact should be performed to determine if the rule is Economically Achievable. o Although airports will pay for many of th e improvements, the costs will be covered (either directly or indirectly) by the airline carriers. The rule acknowledges this fact but does not consider the impact that these costs will have on airlines. o Alaska Airlines hold their own NPDES permits at each of the airports affected by this regulation and are not simply “co-permittees”. o JNU is owned and operated by the City/Borough of Juneau. Because the city does not have enough economic capacity to absorb the cost of new regulatory requirements, the majority of the costs would be passed to the airlines. o Some airport locations require airlines to own and operate GRVs and dispose of the collected stormwater.

 During the winter months, air transportation is the only means of transportation into and out of many AK towns. Additional economic impacts could occur at the locations where airline service is essential.