My last article, in August, seemed to be a stretch from the concerns of that day – winter operations. Now, it doesn’t seem so very far off, and some of you are well into your de-icing operations for the season. As a follow up to my last installment, on August 28th, the U.S. EPA issued their Proposed Effluent Limitation Guidelines Rule for Airport Deicing Operations. Specifically, the affect to airport facilities (classified by U.S. EPA under the National Pollutant Discharge Elimination System (NPDES) program as industrial) would be a greatly-reduced threshold for untreated discharge of de-icing agents from airport facilities.
Currently, the American Association of Airport Executives (AAAE) and Airports Council International-North America (ACI-NA) are soliciting comments to instill an industry perspective in an attempt to build continuity. The group comment period has passed, but comments will be accepted on the proposed rule changes through December 28, 2009. The summary document and comment submittal format can be found at the following link: http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480a16b99 .
I was surprised to find out that several airports within my local area have no facilities in-place to collect de-icing run-off from discharging with storm water. One airport in particular has made no accommodations for surface water collection in the de-icing area, as well as, not having a designated snow dump area to handle snow contaminated with de-icing agents. On the opposite end of the spectrum, as an example of either good planning or the right decisions coming together at the right time (along with a little luck), the Grand Canyon National (GCN) Airport, located in north central Arizona, at the gateway to the South Rim of the Grand Canyon, has employed a fully contained catchment system for de-icing operations.
Now, most people don’t realize that such a small airport would support such large volumes of passenger traffic, but with the draw of the Grand Canyon, along with five resident air tour providers, this facility is the third busiest airport in the State of Arizona. Along with the high numbers associated with this passenger volume, the high elevation (6,700 feet) climate around the South Rim of the Grand Canyon has been known to produce snow any month of the year, resulting in the needto support winter de-icing operations. The Grand Canyon is typically the coldest weather reading in the state, with record lows dipping below -20°F.
The GCN has an additional benefit of being covered under an individual storm water permit issued to the Arizona Department of Transportation by Arizona Department of Environmental Quality (ADEQ) under the NPDES (delegated to ADEQ as AZPDES). Now the nature of the airport (Category Eight (viii): Transportation facilities that have vehicle maintenance, equipment cleaning, or airport deicing operations) requires classification as an industrial facility, which imposes an individual Storm water Pollution Prevention Plan (SWPPP), as well as, additional conditions and monitoring requirements. Along with the development of this site-specific SWPPP, many of the new facilities are incorporating “Green” practices. The Aircraft Rescue and Fire Fighting (ARFF) building, that is nearing completion, is headed toward Gold Status in the LEED Certification process. As with many LEED certified buildings in the arid southwest, the new facility will retain gray water for landscaping purposes.
The current de-icing operations at GCN includes a full containment apron, sloped to a single drain, which is plumbed to a holding tank. A manual switch operated prior to application of de-icing fluids diverts all captured drainage to a holding tank. Once switched back, all storm water run-off is diverted to the community sanitary sewer system for general treatment. The current treatment process allows the operator of the treatment plant to accept a controlled release of glycol products in the sanitary sewage system. This release within the system is controlled at the storage tank to ensure consistent distribution.
Certainly the installation of a holding tank and drainage infrastructure is not an easily implemented, long term objective. However, with proposed changes, the airport operator’s exposure through NPDES (or state equivalent) must be monitored to prove compliance.