Airfield and Aircraft Deicing Fluid
Winter is quickly approaching and many airports are preparing for cold weather operations. This includes a review of procedures and requirements that pertain to airfield pavement and aircraft deicing operations.
The Federal Aviation Administration (FAA) requires airlines and airports that operate during icy conditions to perform deicing and anti-icing of aircraft and airfield pavement. This ensures the safety of passengers and aircraft operations. However, when performed without discharge controls in place, these deicing operations can degrade nearby water bodies.
The Environmental Protection Agency (EPA) promulgated the Airport Deicing Effluent Guidelines in 2012. The requirements generally apply to wastewater runoff associated with the deicing of airfield pavement at commercial service airports. The guideline also established New Source Performance Standards for wastewater discharges associated with aircraft deicing for a subset of new airports. Airports are required to obtain storm water discharge permits under the National Pollutant Discharge Elimination System (NPDES) program and ensure that wastes from deicing operations are properly collected and treated. The NPDES permit program was created in 1972 by the Clean Water Act and addresses water pollution by regulating point sources that discharge pollutants to waters of the United States.
Here is a breakdown of how the Airport Deicing Effluent Guidelines apply to different airports:
Existing airports with less than 1,000 annual jet departures:
- Existing airports that have less than 1,000 annual jet departures do not fall under the scope of the Airport Deicing Effluent Guidelines.
Existing Airports with at least 1,000 annual jet departures:
- Existing airports with at least 1,000 annual jet departures are subject to the Airport Deicing Effluent Guidelines for the following standards:
Aircraft deicing:
- The Airport Deicing Effluent Guidelines do not establish requirements for aircraft deicing discharges at existing airports. Such requirements will continue to be established in general permits, or for individual permits on a site-specific basis.
Airfield pavement deicing:
- The Airport Deicing Effluent Guidelines require existing airports with at least 1,000 annual jet departures that discharge wastewater associated with airfield pavement deicing to use non-urea-containing deicers, or alternatively, meet a daily maximum effluent limitation for ammonia of 14.7 mg/L.
New airports with less than 1,000 annual jet departures:
- New airports that have less than 1,000 annual jet departures do not fall under the scope of the Airport Deicing Effluent Guidelines.
New airports with at least 1,000 annual jet departures:
- New airports with at least 1,000 annual jet departures are subject to the Airport Deicing Effluent Guidelines for the following standards:
Aircraft deicing:
- New airport with less than 10,000 annual departures:
New airports with less than 10,000 annual departures do not fall under the scope of the Airport Deicing Effluent Guidelines for aircraft deicing. Such requirements will continue to be established in general permits, or for individual permits on a site-specific basis.
New airport exceeding 10,000 annual departures:
- New airports that exceed 10,000 annual departures located in certain cold climate zones are required to collect 60 percent of the available aircraft deicing fluid after deicing. Airports that discharge the collected aircraft deicing fluid directly to waters of the U.S. must also meet numeric discharge requirements for chemical oxygen demand.
- Those airports would have to collect the aircraft deicing fluid and treat the waste water. Waste water can be treated on-site or sent to an off-site treatment contractor or publicly-owned treatment works.
Airfield pavement deicing:
- The Airport Deicing Effluent Guidelines require new airports with at least 1,000 annual jet departures that discharge wastewater associated with airfield pavement deicing to use non-urea-containing deicers, or alternatively, meet a daily maximum effluent limitation for ammonia of 14.7 mg/L.
Now is the time to start to think about your airfield pavement and aircraft deicing operations and the steps you have in place to meet the requirements of the EPA.
If you do not have a discharge permit in place with your state, and these guidelines apply, we would encourage you to give us a call to visit about your situation and further explore your options for obtaining compliance with these rules.
If you do have a permit in place, we would encourage you to review the conditions of that permit, and make sure that you are complying with all those conditions.
