United States
Environmental Protection
Agency
Enforcement And ;
Compliance Assurance
:(2223A) ;
Profile Of The
Air Transportation Industry
SECTOR
NOTEBOOKS
EPA Office Of Compliance Sector Notebook Project
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
f8 1997
THE ADMINISTRATOR
Message from the Administrator
Since EPA's founding over 25 years ago, our nation has made tremendous progress in protecting
public health and our environment while promoting economic prosperity. Businesses as large as
iron and steel plants and those as small as the dry cleaner on the corner have worked with EPA to
find ways to operate cleaner, cheaper and smarter. As a result, we no longer have rivers catching
fire. Our skies are clearer. American environmental technology and expertise are in demand
around the world.
The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.
The Environmental Protection Agency has undertaken its Sector Notebook Project to compile,
for major industries, information about environmental problems and solutions, case studies and
tips about complying with regulations. We called on industry leaders, state regulators, and EPA
Staff with many years of experience in these industries and with their unique environmental issues.
Together with an extensive series covering other industries, the notebook you holdin your hand is
the result.
These notebooks will help business managers to understand better their regulatory requirements,
and learn more about how others in their industry have achieved regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.
I encourage you to use this notebook to evaluate and improve the way that we together achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that in industry after industry, community after community
environmental protection and economic prosperity go hajrtin hand.
R*cyc!«dfftecycl«bte Printod wHh Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
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Air Transportation Industry
Sector Notebook Project
EPA/310-R-97-001
EPA Office of Compliance Sector Notebook Project
Air Transportation Industry
February 1998
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M St., SW (MC 2221-A)
Washington, DC 20460
Sector Notebook Project
February 1998
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Air Transportation Industry
Sector Notebook Project
This report is one in a series of volumes published by the U.S. Environmental Protection Agency
(EPA) to provide information of general interest regarding environmental issues associated with
specific industrial sectors. The documents were developed under contract by Abt Associates
(Cambridge, MA), Science Applications International Corporation (McLean, VA), and Booz-
Allen & Hamilton, Inc. (McLean, VA). This publication may be purchased from the
Superintendent of Documents, U.S. Government Printing Office. A listing of available Sector
Notebooks and document numbers is included at the end of this document.
AH telephone orders should be directed to:
Superintendent of Documents .
U.S. Government Printing Office
Washington, DC 20402
(202)512-1800
FAX (202) 512-2250
8:00 a.m. to 4:30 p.m., EST, M-F
Using the form provided at the end of this document, all mail orders should be directed to:
U.S. Government Printing Office
P.O. Box 371954
Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and
academic libraries, Federal, State, and local governments, and the media from EPA's National
Center for Environmental Publications and Information at(800) 490-9198. For further
information, and for answers to questions pertaining to these documents, please refer to the
contact names and numbers provided within this volume.
Electronic versions of all Sector Notebooks are available via Internet on the Enviro$en$e World
Wide Web. Downloading procedures are described in Appendix A of this document.
Cover photograph by Stephen Delaney, EPA
Sector Notebook Project
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Air Transportation Industry
Sector Notebook Proj ect
Sector Notebook Contacts
The Sector Notebooks were developed by the EPA's Office of Compliance. Questions relating
to the Sector Notebook Project can be directed to:
Seth Heminway, Coordinator, Sector Notebook Project
US EPA Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7017
Questions and comments regarding the individual documents can be directed to the appropriate
specialists listed below.
Document Number
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310'
EPA/310.
EPA/310.
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
-R-95-001.
-R-95-002.
R-95-003.
R-95-004.
R-95-005.
R-95-006.
R-95-007.
-R-95-008.
-R-95-009.
-R-95-010.
-R-95-011.
-R-95-012.
-R-95-013.
-R-95-014.
-R-95-015.
-R-95-016.
-R-95-017.
-R-95-018.
-R-97-001.
R-97-002.
R-97-003.
-R-97-004.
R-97-005.
R-97-006.
R-97-007.
R-97-008.
R-97-009.
R-97-010.
Industry
Dry Cleaning Industry
Electronics and Computer Industry
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Industry
Air Transportation Industry
Ground Transportation Industry
Water Transportation Industry
Metal Casting Industry
Pharmaceuticals Industry
Plastic Resin and Manmade Fiber Industry
Fossil Fuel Electric Power Generation Industry
Shipbuilding and Repair Industry
Textile Industry
Sector Notebook Data Refresh, 1997
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Jane Engert
Anthony Raia
Jane Engert
Robert Lischinsky
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Seth Heminway
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Anthony Raia
Belinda Breidenbach
Seth Heminway
Phone (202)
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-5021
564-6045
564-5021
564-2628
564-7067
564-7003
564-7072
564-7017
564-7027
564-7013
564-7057
564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-6045
564-7022
564-7017
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AIR TRANSPORTATION INDUSTRY
TABLE OF CONTENTS
LIST OF EXHIBITS iv
LIST OF ACRONYMS v
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
A. Summary of the Sector Notebook Project 1
B. Additional Information 2
H. INTRODUCTION TO THE AIR TRANSPORTATION INDUSTRY 3
A. Introduction, Background, and Scope of the Notebook 3
B. Characterization of the Air Transportation Industry 4
1. Industry Characterization 4
1.1. Types of Aircraft and Airports 4
1.2. Requirements Pertaining to the Aviation Industry 7
1.3. International Aviation 8
2. Industry Size and Geographic Distribution 9
3. Economic Trends 13
m. DESCRIPTION OF OPERATIONS 16
A. Aircraft Operations and Associated Environmental Aspects 16
1. Aircraft and Aviation-Support Vehicle Maintenance 16
2. Fueling 22
3. Aircraft Cleaning 23
4. Aircraft Deicing and Anti-Icing 24
5. General Aircraft Operational Activities 25
B. Airport Operations 29
1. Runway Deicing 29
2. General Airport Operations 29
IV. POLLUTION PREVENTION OPPORTUNITIES 31
A. Air Transportation Operations 32
1. Maintenance and Refurbishing Operations 32
2. Fueling 38
3. Aircraft and Vehicle Exterior Cleaning 40
4. Aircraft Deicing 41
5. General Aircraft Operations 43
B. Airport Operations 44
1. Runway Deicing 44
2. General Airport Operations 44
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V. SUMMARY OF FEDERAL STATUTES AND REGULATIONS 47
A. General Description of Major Statutes 47
B. Industry Specific Requirements 58
C. Pending and Proposed Regulatory Requirements 64
VI. COMPLIANCE AND ENFORCEMENT HISTORY 67
A. Air Transportation Industry Compliance History 71
B. Comparison of Enforcement Activity Between Selected Industries 73
C. Review of Major Legal Cases/Supplemental Environmental Projects 78
1. Review of Major Cases 78
2. Supplementary Environmental Projects (SEPs) 80
VE. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES 81
A. Sector-Related Environmental Programs and Activities 81
1. EPA Voluntary Activities 81
2. Trade Association/Industry Sponsored Activities 84
B. Summary of Trade Associations 84
Vffl. RESOURCE MATERIALS/BIBLIOGRAPHY 90
Appendix A - Instructions for downloading this notebook
Sector Notebook Project
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LIST OF EXHIBITS
Exhibit 1: Market Size Analysis of Air Transportation Industry 9
Exhibit 2: Distribution of Establishments by Sector 9
Exhibit 3: Activity at the 10 Busiest Airports (1996) 10
Exhibit 4: Top Ten Airlines of Scheduled Service (1996) 10
Exhibit 5: Number of Businesses by Company Size 11
Exhibit 6: Top Five States with Air Transportation Establishments 12
Exhibit 7: Top Five States with Air Transportation Industry Employees 12
Exhibit 8: Top Five States with Highest Air Transportation Sales 13
Exhibit 9: Summary of Domestic Passenger Traffic 13
Exhibit 10: Forecast for U.S. Commercial Carriers and Regionals/Communters
FY1998 - 2009 14
Exhibit 11: Maintenance and Refurbishing Operations: Activities and Potential
Environmental Impacts 18
Exhibit 12: Annual Air Pollutant Releases by Industry Sector (tons/year) 28
Exhibit 13: Five-Year Enforcement and Compliance Summary for the
Air Transportation Industry 72
Exhibit 14: Five-Year Enforcement and Compliance Summary for Selected Industries 74
Exhibit 15: One-Year Enforcement and Compliance Summary for Selected Industries 75
Exhibit 16: Five-Year Inspection and Enforcement Summary by Statute
for Selected Industries 76
Exhibit 17: One-Year Inspection and Enforcement Summary by Statute
for Selected Industries 77
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LIST OF ACRONYMS
AFS AIRS Facility Subsystem (CAA database)
AIRS Aerometric Information Retrieval System (CAA database)
BIFs . Boilers and Industrial Furnaces (RCRA)
BOD Biochemical Oxygen Demand
CAA Clean Air Act
CAAA Clean Air Act Amendments of 1990
CATC . Clean Air Technology Center
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS CERCLA Information System
CFCs Chlorofluorocarbons
CO Carbon Monoxide
COD Chemical Oxygen Demand
CSI Common Sense Initiative
CWA Clean Water Act
D&B Dun and Bradstreet Marketing Index
DOT U.S. Department of Transportation
ELP Environmental Leadership Program
EMS Environmental Management System
EPA United States Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
FAA Federal Aviation Administration
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FINDS Facility Indexing System
FWPCA Federal Water Pollution Control Act
HAP Hazardous Air Pollutant (CAA)
HSDB Hazardous Substances Data Bank
HSWA Hazardous and Solid Waste Amendments
ICAO International Civil Aviation Organization
IDEA Integrated Data for Enforcement Analysis
LDR Land Disposal Restriction (RCRA)
LEPC Local Emergency Planning Committee
MACT Maximum Achievable Control Technology (CAA)
MCLG Maximum Contaminant Level Goal
MCL Maximum Contaminant Level
MEK Methyl Ethyl Ketone
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards (CAA)
NAFTA North American Free Trade Agreement
NAICS North American Industrial Classification System
NCDB National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NEIC National Enforcement Investigation Center
NESHAP National Emission Standards for Hazardous Air Pollutants
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NO2 Nitrogen Dioxide
NOI Notice of Intent
NOV Notice of Violation
NOX Nitrogen Oxide
NPDES National Pollutant Discharge Elimination System (CWA)
NPL National Priorities List
NRC National Response Center
NSPS New Source Performance Standards (CAA)
OAR Office of Air and Radiation
OECA Office of Enforcement and Compliance Assurance
OPA Oil Pollution Act
OPPTS Office of Prevention, Pesticides, and Toxic Substances
OSHA Occupational Safety and Health Administration
OSW Office of Solid Waste
OSWER Office of Solid Waste and Emergency Response
OW Office of Water
P2 Pollution Prevention
PCS Permit Compliance System (CWA Database)
PMjQ Particulate matter of 10 microns or less
PMN Premanufacture Notice
POTW Publicly Owned Treatments Works
PT Total Particulates
RACT Reasonably Available Control Technology
RCRA Resource Conservation and Recovery Act
RCRIS RCRA Information System
SARA Superfund Amendments and Reauthorization Act
SDWA Safe Drinking Water Act
SEP Supplemental Environmental Project
SERC State Emergency Response Commission
SIC Standard Industrial Classification
SIP State Implementation Plan
SO2 Sulfur Dioxide
SOX Sulfur Oxide
SPCC Spill Prevention Control and Countermeasures
TOC Total Organic Carbon
TRI Toxic Release Inventory
TRIS Toxic Release Inventory System
TSCA Toxic Substances Control Act
TSD Treatment, storage, and disposal
TSS Total Suspended Solids
UIC Underground Injection Control (SDWA)
UST Underground Storage Tank (RCRA)
VOC Volatile Organic Compound
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AIR TRANSPORTATION INDUSTRY
(SIC 45)
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
I.A. Summary of the Sector Notebook Project
Integrated environmental policies based upon comprehensive analysis of air,
water, and land pollution are a logical supplement to traditional single-media
approaches to environmental protection. Environmental regulatory agencies
are beginning" to embrace comprehensive, multi-statute solutions to facility
permitting, enforcement and compliance assurance, education/outreach,
research, and regulatory development issues. The central concepts driving
the new policy direction are that pollutant releases to each environmental
medium (air, water, and land) affect each other, and that environmental
strategies must actively identify and address these inter-relationships by
designing policies for the "whole" facility. One way to achieve a whole
facility focus is to design environmental policies for similar industrial
facilities. By doing so, environmental concerns that are common to the
manufacturing of similar products can be addressed in a comprehensive
manner. Recognition of the need to develop the industrial "sector-based"
approach within the EPA Office of Compliance led to the creation of this
document.
The Sector Notebook Project was originally initiated by the Office of
Compliance within the Office of Enforcement and Compliance Assurance
(OECA) to provide its staff and managers with summary information on
major industrial sectors. As other EPA offices, states, the regulated
community, environmental groups, and the public became interested in this
project, the scope of the original project was expanded to its current form.
The ability to design comprehensive, common sense environmental
protection measures for specific industries is dependent on knowledge of
several inter-related topics. For the purposes of this project, the key elements
chosen for inclusion are: general industry information (economic and
geographic); a description of industrial processes; pollution outputs; pollution
prevention opportunities; Federal statutory and regulatory framework;
compliance history; and a description of partnerships that have been formed
between regulatory agencies, the regulated community and the public.
For any given industry, each topic listed above could alone be the subject of
a lengthy volume. However, in order to produce a manageable document,
this project focuses on providing summary information for each topic. This
format provides the reader with a synopsis of each issue, and references
where more in-depth information is available. Text within each profile was
researched from a variety of sources, and was usually condensed from more
detailed sources pertaining to specific topics. This approach allows for a
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wide coverage of activities that can be further explored based upon the
citations and references listed at the end of this profile. As a check on the
information included, each notebook went through an external review
process. The Office of Compliance appreciates the efforts of all those that
participated in this process who enabled us to develop more complete,
accurate and up-to-date summaries.
I.B. Additional Information
Providing Comments
OECA's Office of Compliance plans to periodically review and update the
notebooks and will make these updates available both in hard copy and
electronically. If you have any comments on the existing notebook, or if you
would like to provide additional information, please send a hard copy and
computer disk to the EPA Office of Compliance, Sector Notebook Project,
401 M St., SW (2223-A), Washington, DC 20460.
Adapting Notebooks to Particular Needs
The scope of the industry sector described in this notebook approximates the
national occurrence of facility types within the sector. In many instances,
industries within specific geographic regions or states may have unique
characteristics that are not fully captured in these profiles. The Office of
Compliance encourages state and local environmental agencies and other
groups to supplement or re-package the information included in this notebook
to include more specific industrial and regulatory information that may be
available. Additionally, interested states, may want to supplement the
"Summary of Applicable Federal Statutes and Regulations" section with state
and local requirements. Compliance or technical assistance providers may
also want to develop the "Pollution Prevention" section in more detail.
Please contact the appropriate specialist listed on the opening page of this
notebook if your office is interested in assisting us in the further development
of the information or policies addressed within this volume. If you are
interested in assisting in the development of new notebooks for sectors not
covered in the original eighteen, please contact the Office of Compliance at
(202) 564-2395.
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Air Transportation Industry
Introduction, Background, and Scope
II. INTRODUCTION TO THE AIR TRANSPORTATION INDUSTRY
This section provides background information on the size, geographic
distribution, employment, production, sales, and economic condition of the
air transportation industry. Facilities described within this document are
described in terms of their Standard Industrial Classification (SIC) codes.
II.A. Introduction, Background, and Scope of the Notebook
This notebook pertains to the transportation industry as classified within SIC
code 45 (Transportation by Air). (Please note that this section provides both
the SIC code and the new North American Industrial Classification System
(NAICS) code, which went into effect January 1, 1997. While the NAICS
code is identified in this section, the remainder of the document will refer to
« , the SIC codes for specific air transportation activities.)
The transportation industry includes other modes of transport, such as
trucking, railroad, pipeline, and water, which make up an important portion
of overall transportation activity in the United States. These modes are
addressed in two sector notebooks. Trucking, railroad, and pipeline
transportation are addressed in Ground Transportation Industry [EPA/310-R-
97-002], and water transportation is addressed in Water Transportation
Industry [EPA/310-R-97-003].
The air transportation industry (SIC 45) includes establishments engaged in
furnishing domestic and foreign transportation by air and also operating
airports and flying fields and furnishing terminal services. Specifically, this
notebook includes the following groups:
SIC 4512 - Air Transportation, Scheduled (NAICS 481111 and 481112).
This sector includes establishments primarily engaged in furnishing air
transportation over regular routes and on regular schedules. This industry
includes Alaskan carriers operating over regular or irregular routes.
SIC 4513 - Air Courier Services (NAICS 49211). This sector includes
establishments primarily engaged in furnishing air delivery of individually
addressed letters, parcels, and packages (generally under 100 pounds), except
by the U.S. Postal Service. Separate establishments of air courier companies
which provide pick-up and delivery only, "drop-off points," or distribution
centers are all classified in this industry.
SIC 4522 - Air Transportation, Nonscheduled (NAICS 481211, 481212,
48799, 62191). This sector includes establishments engaged in furnishing
nonscheduled air transportation. Also included in this industry are
establishments primarily engaged in furnishing airplane sightseeing services,
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Air Transportation Industry
Introduction, Background, and Scope
air taxi services, and helicopter passenger transportation services to, from, or
between local airports, whether scheduled or not scheduled.
SIC 4581 - Airports, Flying Fields, and Airport Terminal Services (NAICS
488111, 488119, 56172, 48819). This sector includes establishments
primarily engaged in operating and maintaining airports and flying fields; in
servicing, repairing (except on a factory basis), maintaining, and storing
aircraft; and in furnishing coordinated handling services for airfreight or
passengers at airports. This industry also include private establishments
primarily engaged in air traffic control operations (except government).
II.B. Characterization of the Air Transportation Industry
H.B.I. Industry Characterization
The transportation industry affects nearly every American. Either through the
necessity of traveling from one place to another, shipping goods and services
around the country, or working in a transportation-related job,
transportation's share of the national economy is significant. According to
the Eno Transportation Foundation, for all transportation-related industries,
total transportation expenditures in the U.S. accounted for 16.1 percent of the
gross national product in 1993.
The airline industry in particular provides transportation of passengers, cargo,
mail and perishable goods. American citizens have come to rely on domestic
and international air transportation more and more every year. Airline travel
in the United States has been getting safer over the years and is the safest in
the world. The National Safety Council's latest fatality totals for 1995 show
175 deaths caused by United States airline accidents. By contrast, five times
as many people died in boating accidents and accidents involving bicycles
and tricycles.
n.B.1.1. Types of Aircrafts and Airports
Generally, the air transportation sector can be broken down into two
categories: (1) facilities providing scheduled, non-scheduled, and air courier
services using aircraft, and (2) airports and airport operations. It is these two
major topics (i.e., aircraft facilities and airports) and the activities and
operations that occur within each of these areas that are the primary focus of
this notebook.
Categories of Aircraft
There are five types of aircraft that compose the aviation industry:
commercial, air taxi operations, commuter, general, and military.
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Air Transportation Industry
Introduction, Background, and Scope
Commercial aircraft encompass air carriers and air taxi flights. Air carriers
are airlines holding a certificate issued of public convenience and necessity
under Section 401 of the Federal Aviation Act of 1958 authorizing them to
perform passenger and cargo services. Air carriers operate aircraft designed
to have a maximum seating capacity of more than 60 seats, to have a
maximum payload capacity of more than 18,000 pounds, or to conduct
international operations. The four different types of air carriers (and their
annual operating revenues) are:
Majors (greater than $1 billion)
Nationals ($100 million to $1 billion)
Large regionals ($20 million to $100 million)
Medium regionals (Up to $20 million).
Air taxi operations are those in which departure time, departure location, and
arrival location are specifically negotiated with the customer or by the
customer's representative and are conducted with airplanes or rotorcraft
having a seating configuration of 30 or fewer seats.
Commuter aircraft are noncertified small regionals who perform scheduled
service to smaller cities and serve as feeders to the major hub airports. They
generally carry 60 or fewer passengers.
General aviation is all aviation that is not commercial or military. General
aviation is the segment of civil aviation that encompasses all facets of
aviation except air carriers and commuters. General aviation includes
corporate-executive transportation, instruction, rental, aerial application,
aerial observation, business, pleasure, and other special uses.
Military refers to the operators of all military (e.g., Air Force, Army, Navy,
U.S. Coast Guard, Air National Guard, and military reserve organizations)
aircraft using civil airports.
Classification of Airports
The system of airports in the U.S. is the largest and most complex in the
world. As of 1990, there were 17,451 civil landing areas (e.g., airports,
heliports, seaplane bases, etc.) in the U.S. The activity and services at
individual airports vary greatly. Regardless of size, many activities occur at
airports including fueling, aircraft maintenance, aircraft washing, and deicing.
In addition, two primary activities at most airports are enplaning passengers
and enplaning air cargo. Enplaning passengers is defined as the total number
1 of passengers departing on aircraft at the airport. Enplaning air cargo
includes the total tonnage of priority, nonpriority, and foreign mail, express,
and freight (property other than baggage accompanying passengers) departing
on aircraft at an airport.
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Air Transportation Industry
Introduction, Background, and Scope
Airport Ownership. Public airports in the U.S. are owned and operated under
a variety of organizational and jurisdictional arrangements. Commercial
airports might be owned and operated by a city, county, or State; or by more
than one jurisdiction. Additionally, some airports may be operated by a
separate public body, such as an airport authority. Regardless of ownership,
legal responsibility for day-to-day operations can be vested in any of five
kinds of governmental or public entities:
Municipal or county government. Municipally operated airports are
city owned and run as a department of the city.
A multipurpose port authority. Port authorities are legally chartered
institutions with the status of public corporations.
An airport authority.
State government.
Classification of airports with scheduled services. Airports with scheduled
passenger service have several classifications:
Commercial service airports are those airports receiving passenger
service and having 2,500 or more annual enplanements.
Primary airports are commercial service airports having 10,000 or
more enplanements.
Hub airports are airports that serve as a transfer point for passengers
changing flights. Commercial service airports are classified as large,
medium, or small hub airports or non-hub airports, depending on the
percentage of total national enplanements for which they account.
General aviation airports encompass the bulk of civil aircraft
operations. The general aviation system includes 98% of all
registered civil aircraft and 95% of all airports.
Reliever airports are a special category of general aviation airports.
Located in the vicinity of major air carrier airports and classified by
the Federal Aviation Administration as a reliever, these airports are
designed to provide relief to congested major airports.
Terminal Facilities. The terminal and associated landside facilities such as
the parking areas and access roads provide the transition zone for passengers
between surface and air transportation. Landside facilities are long-term
installations and are largely independent of activities that occur airside.
Concession and food service operations provide food and materials goods for
passengers.
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Introduction, Background, and Scope
II.B.1.2. Requirements Pertaining to the Aviation Industry
The Federal Aviation Administration's (FAA's) major responsibilities
include overseeing aircraft safety and the competency of pilots and
mechanics. The FAA does this by providing mandatory safety rules,
conducting safety inspections, and setting high standards for civil aviation.
Noise Abatement. In addition to safety, the FAA also addresses issues such
as noise abatement. As a result of complaints against aircraft noise, which
increased dramatically with the introduction of jet aircraft, the Federal
Aviation Act of 1958 was amended to include noise abatement regulations
designed to establish noise levels which aircraft manufacturers cannot exceed
in the development of new aircraft. In 1979, the Aviation Safety and Noise
Abatement Act authorized the FAA to help airport operators develop noise
mitigation abatement programs.
The Airport Noise and Capacity Act of 1990 authorized DOT/FAA to reduce
aircraft engine noise by requiring an aircraft fleet replacement program. The
estimated effect of the phase out of larger, noisier aircraft is estimated to
reduce the number of people exposed to significant noise levels of aircraft
noise in the U.S. from 2.7 million in 1990 to 400,000 by the year 2000, when
the phaseout is complete. The law also limited airport operators' abilities to
place noise or access restrictions on airports in the interest of avoiding an
overly burdensome patchwork of individual operating limitations across the
United States.
Standards for Aircraft Design. The FAA works closely with aircraft
manufacturers while examining designs for new planes. The FAA sets very
high standards for aircraft designs. Once the design has been thoroughly
examined and the first model has completed a grueling series of flight tests
and evaluations, the model is certificated for production by the FAA
(http://www.faa.gov/publicinfo.htm).
Monitoring and Maintenance of Existing Aircraft. Once the aircraft has
been certified and put into service, the FAA continues to monitor its
performance. When necessary, the FAA will issue repair notices known as
"Airworthiness Directives" to the manufacturers and airlines when problems
are spotted. The FAA issues several hundred notices a year. In addition,
manufacturers often issue Service Bulletins to advise aircraft carriers of
safety improvements or procedures that will enhance safety.
FAA airworthiness requirements specify materials to be used during
maintenance or other technical specifications and standards (e.g., cleaning,
deicing) that limit the airlines' ability to change materials, procedures, or
processes.
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Air Transportation Industry
Introduction, Background, and Scope
Flight Personnel The FAA sets standards for training, health, experience,
number of hours worked, and qualifications for pilots and other flight
personnel. Because pilots play such a vital role in maintaining aircraft
operations safety, they are especially heavily regulated by the FAA. Pilots
must have their health examined every six months. They must pass special
examinations and flight tests, and those serving as captains are required to
possess hundreds of hours of additional flying time. FAA tests their flying
skills on a regular basis. DOT and FAA safety policies and rules expressly
place the ultimate legal authority for aircraft operation fully and solely on the
pilot in command of the aircraft (14 CFR §91.3(a)).
Air Traffic Control Operations. FAA is responsible for developing,
maintaining, and operating the nation's Air Traffic Control System, which is
in charge of ensuring the safe separation of aircraft during flight and
sequencing aircraft for taxiing, takeoff, and landing.
Maintenance Personnel. Airline mechanics and technicians must be
certified by the FAA. In addition, repair stations must obtain an FAA
operating certificate and are subject to regular inspection by the agency.
For more information about FAA airworthiness requirements, see the FAA
website at http://www.faa.gov/publicinfo.htm.
II.B.1.3. International Aviation
After 1945, commercial air transportation began to transcend domestic
markets into the international arena, therefore, the standardization of
operational practices for international services, such as navigational aids and
weather reporting systems, became essential. There were also many political
and technical problems that needed to be solved. For example, there was the
issue of commercial rights: what arrangements were needed for the airlines
of one country to fly into and through territories of another? For more
information relating to International Civil Aviation Organization (ICAO) and
other international milestones, refer to Memorandum on ICAO, January 1994.
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Air Transportation Industry
Introduction, Background, and Scope
II.B.2. Industry Size and Geographic Distribution
Industry Size
According to Dun & Bradstreet, there were an estimated 16,282 air
transportation establishments in the U.S. as of April 1997. Exhibit 1 provides,
information on each of the SIC codes in the air transportation industry,
including total number of establishments and employees, and total annual
sales.
Exhibit 1. Market Size Analysis of Air Transportation Industry
SIC Code
4512
4513
4522
4581
Total
No. of
Establishments
3,638
2,252
3,321
7,071
16,282
No. of
Employees
320,837
75,493
39,253
220,986
656,569
Annual Sales
(millions)
147,858.6
15,172.9
7,019.0
15,616.8
185,667.3
Source: Dun & Bradstreet Marketplace (www.dnb.imarketinc.com), December 1997
Exhibit 2 displays the percentages of establishments per air transportation
sector discussed above.
Exhibit 2: Distribution of Establishments by Sector
Air Transportation Sectors
H Air Transport - Scheduled
| | Air Transport - Nonscheduled
1H Air Courier Services
H Airport Terminals
Source: Dun & Bradstreet Marketplace, December 1997 (www.dnb.imarketinc.com)
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Air Transportation Industry
Introduction, Background, and Scope
Exhibit 3 lists the busiest airports in terms of the total passengers and cargo.
Keep in mind that 99% of the nation's airports are much smaller than these
airports, but conduct the same activities to a lessor extent or volume.
Exhibits. Activity at the 10 Busiest Airports (1996)
Leading Airports in Passengers
Arriving & Departing (Millions)
Chicago O'Hare
Atlanta
Dallas/Ft. Worth
Los Angeles
San Francisco
Miami
Denver
New York Kennedy
Detroit
Las Vegas
69.2
63.3
58
57.9
39.3
33.5
32.3
31.2
30.6
30.5
Leading Airport in Cargo Tons
Enplaned & Deplaned (Thousands)
Memphis
Los Angeles
Miami
New York Kennedy
Louisville
Anchorage
Chicago O'Hare
Newark
Atlanta
Dallas/Ft. Worth
1934
1719
1710
1636
1369
1269
1259
958
800
774
Source: 1997 Air Transport Association Annual Report
The activity and services of the aviation industry vary greatly. Exhibit 4
presents the top 10 airlines of scheduled service in the U.S.
Exhibit 4. Top 10 Airlines of Scheduled Service (1996)
Airline
Delta
United
American
US Airways
Southwest
Northwest
Continental
Trans World
America West
Alaska
Passengers (millions)
97.2
81.9
79.3
56.6
55.3
52.7
35.7
23.3
18.1
11.8
Source: 1997 Air Transport Association Annual Report
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Air Transportation Industry
Introduction, Background, and Scope
Company size varies greatly among air transportation facilities. Exhibit 5
presents an analysis of the number of businesses compared to the number of
employees per air transportation sector. The distribution of establishments
with a specific employee size varies from one SIC code to another.
Exhibit 5. Number of Businesses by Company Size
No. of
Employees
1
2 to 4
5 to 9
10 to 24
25 to 49
50 to 99
100 to 249
250 to 499
500 to 999
1,000 to 9,999
>=10,000
Unknown
Totals
, Number of Businesses
Scheduled
147
436
415
484
286
219
252
75
31
43
6
1244
3638
Nonscheduled
381
1533
572
450
172
64
41
6
2
3
97
3321
Air courier
104
985
265
244
148
151
208
7
5
2
1
131
2252
Airports
854
1699
1092
837
386
217
189
79
27
25
3
1674
7071
Source: Dun & Bradstreet Marketplace, December 1997 (www.dnb.imarketinc.com)
Geographic Distribution
The air transportation industry is widely dispersed. Of the total of 16,282
U.S. establishments in the air transportation industry, most are located in
California, Texas, Florida, niinois, and New York. Exhibits 6 and 7 identify
the five states with the most establishments and employees by air
transportation SIC code.
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Air Transportation Industry
Introduction, Background, and Scope
Exhibit 6. Top Five States with Air Transportation Establishments
SIC Code
Air transportation,
scheduled (SIC 4512)
Air transportation,
nonscheduled (SIC 4522)
Air courier services
(SIC 45 13)
Airports, flying fields, &
services (SIC 4581)
States
(Number of Establishments)
CA
(426)
CA
(348)
CA
(328)
CA
(747)
FL
(369)
FL
(314)
NY
(308)
TX
(641)
NY
(321)
TX
(236)
FL
(208)
FL
(551)
TX
(258)
NY
(151)
TX
(194)
NY
(304)
IL
(200)
AK .
(146)
IL
(91)
EL
(264)
Source: Dun & Bradstreet Marketplace, December 1997 (www.dnb.imarketinc.com)
Exhibit 7. Top Five States with Air Transportation Industry Employees
SIC Code
Air transportation,
scheduled
(SIC 45 12)
Air transportation,
nonscheduled
(SIC 4522)
Air courier
services
(SIC 45 13)
Airports, flying
fields, & services
(SIC 4581)
,.'.., -,: : States
(Number of Employees)
TX
(37,691)
FL
(3,662)
TN
(20,374)
FL
(36,414)
CA
(31,396)
CA
(3,580)
CA
(6,299)
CA
(35,225)
MN
(31,363)
MN
(2,546)
OH
(6,299)
TX
(15,755)
GA
(30,484)
IN
(2,437)
NY
(5,762)
NY
(15,702)
NY
(18,111)
MI
(2,428)
TX
(5,143)
IL
(15,762)
Source: Dun & Bradstreet Marketplace, December 1997 (www.dnb.imarketinc.com)
Exhibit 8 presents the top five states for each SIC code with the highest total
sales in millions of dollars. California, Florida, New York, and Texas are
consistently among the top five for these sectors.
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Air Transportation Industry
Introduction, Background, and Scope
Exhibit 8. Top Five States with Highest Air Transportation Sales
SIC Code
Air transportation,
scheduled (SIC 45 12)
Air transportation,
nonscheduled
(SIC 4522)
Air courier services
(SIC 4513)
Airports, flying
fields, & services
(SIC 4581)
States
(Total sales in millions)
TX
(41,080.5)
IN
(1,019.9)
TX
(8,867.3)
FL
(3,426.5)
IL
(36,807)
OR
(776.7)
CA
(2,793.6)
NY
(2,544.7)
MN
(27,512)
FL
(516.2)
WA
(1,976)
TX
(1,762.8)
VA
(13,859)
CA
(534.70)
OH
(602.1)
VA
(1,639)
GA
(13,109.7)
NY
(506.1)
NY
(353.9)
CA
(596.4)
Source: Dun & Bradstreet Marketplace, December 1997 (www.dnb.imarketinc.com)
II.B.3. Economic Trends
Aviation Trends and Forecasts
The aviation industry has been growing steadily and is expected to continue.
U.S. commercial air carrier passenger enplanements, which had averaged less
than 1.0 percent growth between 1990 and 1993, grew at an annual rate of 6.2
percent over the last 3 years. In 1996, the large U.S. air carriers increased
their system capacity by only 2.9 percent, while passenger demand increased
by 6.1 percent. Exhibit 9 presents the trends for U.S. scheduled airlines in
passengers enplaned and domestic cargo from 1960 to 1996.
Exhibit 9: Summary of Domestic Passenger Traffic
1960-1996
600-
I I I I I I I I I I 1 I I I M I 1 I I I I I I I I I I I I
'60 '65 70 75 '80 '85 '90 '96
Source: ATA Airline Traffic Stats 1960-1996
Passengers Enplaned
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Air Transportation Industry
Introduction, Background, and Scope
The FAA predicts that domestic departures for commercial carriers will
increase from 7.1 in 1997 to 9.2 million by 2008. Exhibit 10 presents
additional FAA forecasts for the aviation industry.
Exhibit 10. Forecast for U.S. Commercial Carriers and
Regionals/Commuters FY]1998 - 2009
Year
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
Passengers
(Millions) l
656.1
676.3
699.1
724.7
753.2
782.9
813.7
845.6
878.8
913.4
949.4
986.7
Revenue
Passenger Miles
(Billions)1
635.3
660.7
688.5
720.3
755.2
791.7
829.7
869.7
911.6
955.6
1,001.9
1.050.2
Jet
Aircraft2
5,092
5,224
5,444
5,698
5,913
6,119
6,361
6,574
6,778
6,983
7,203
7.419
Aircraft
Operations,
(Millions)3
24.7
25.1
25.5
26.2
26.9
27.5
28.1
28.7
29.4
30.0
30.7
31.4
Source: Federal Aviation Administration.
1 U.S. commercial air carriers and regionals/commuters, domestic plus
international.
2 Commercial air carriers.
3 Landings and takeoffs of air carriers and air taxi/commuters at FAA and
contract tower airports.
Impacts of Deregulation
Before 1978, the United States airline economy was tightly regulated by the
federal government. However, due to complaints of high airfares and
growing concerns that government regulation was inhibiting the growth of
the airline industry, the Deregulation Act of 1978 was passed. Since then,
several important trends have characterized the airline industry.
Rapid expansion of overnight delivery of mail. Air cargo was deregulated
a year before the passenger airlines. Deregulation was responsible for
dramatic results for all aspects of the cargo business, but particularly for
express package delivery for high value and time sensitive packages.
Deregulation gave express carriers operating freedom, and the direct result
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Air Transportation Industry Introduction, Background, and Scope
was outstanding growth for that part of the aviation industry over the next
decade.
Increase of Total Revenue Sales. Total sales revenues for the industry as a
whole (in adjusted dollars) have increased each consecutive year except for
a brief decline from 1989 through 1991. This brief decline can be explained
largely by two factors: (1) Northwest Air Lines was private during those same
years, so its revenues were not included in the industry data, and (2) Eastern
Air Lines experienced a major labor strike that began in March 1989. As
indicated by its financial data from 1989 to 1991, Eastern was able to
continue operation, in spite of the labor strike, by charging fares below its
costs. Eastern's unusually low fares may have caused other airlines to reduce
fares in a similar fashion, and this reduced the total revenue earned by the
industry as a whole. Current projections are that industry revenues will
continue to rise due to the strengthened economy and a predicted 5% increase
in airline traffic.
Increased number of airlines. Following deregulation in 1978, the number
of companies increased dramatically from about 36 carriers in 1978 to a total
of 123 such carriers in 1984. This initial increase resulted from the market
becoming more accessible to new companies that sought to operate below the
costs of older, established airlines with higher cost structures. However, a
clear decline in the number of air carriers in the late 1980s followed this
initial increase due to weaker airlines being forced out of business or being
taken over by the stronger companies. Then by 1993, the numbers increased
again as numerous small airlines emerged, offering direct, low cost, no-frills
service. To compete with these lower cost airlines, many of the larger
airlines are initiating their own low cost divisions. The Brookings 1986
Report estimated that the traveling public was saving $5.7 billion a year
(measured in 1977 dollars) as a result of deregulation (www.air-
transport.org/handbk/chaptr02.htm).
Expanded market. A major development since deregulation was the creation
of hub and spoke networks. The hubs are strategically located airports used
as transfer points for passengers traveling from one location to another. The
hub and spoke systems were developed in order to enable airlines to serve far
more markets, with the same size fleet, than the traditional direct, point-to-
point service.
Deregulation also sparked marketing innovations used by most major airlines
and many smaller airlines that equate to fare discounts, such as the frequent
flyer program that is designed to reward repeat customers with free tickets
and other benefits.
The appearance of new airlines, combined with the rapid expansion into new
markets by many of the established airlines, resulted in unprecedented
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Air Transportation Industry
Description of Operations
popularity and competition in the airline industry. In 1977, the last full year
of government regulation of the airline industry, the US airlines carried 240
million passengers. By 1993 they were carrying nearly 490 million. A study
by the Department of Transportation a decade after deregulation found that
well over 90% of airline passengers had a choice of carriers compared to only
two-thirds in 1978 (www.air-transport.org/handbk/chaptr02.htm)
III. DESCRIPTION OF OPERATIONS
This section describes the major operations and maintenance activities within
the air transportation industry. The section is designed for those interested
in gaining a general understanding of the industry, and for those interested in
the relationship between the industrial process associated with air
transportation, and the associated environmental aspects and potential
impacts of the processes. This section is not exhaustive; the operations and
maintenance activities discussed are intended to represent the air
transportation practices and activities with potentially significant
environmental impacts. These activities are presented in two categories:
(1) Aircraft operations, including maintenance, cleaning, fueling, and
deicing; and
(2) Airport operations, including terminal activities, loading and off
loading.
This section does not attempt to replicate published engineering information
that is available for this industry. Refer to Section VET for a list of resource
materials that are available.
III.A. Aircraft Operations and Associated Environmental Aspects
III.A.l. Aircraft and Aviation-Support Vehicle Maintenance
Aircraft maintenance activities include scheduled preventive maintenance,
repairs required as a result of inspections, and aircraft refurbishing. When an
aircraft is built, the manufacturer creates a maintenance program for the
operator of the plane. Representatives from the manufacturer, the Federal
Aviation Administration (FAA), subcontractors, and the airline that purchases
the aircraft form a review board that develops minimum requirements of a
maintenance program. This maintenance program is then documented and
followed throughout the aircraft's life.
Together, scheduled maintenance and day-to-day preventive activities are
necessary to keep the aircraft safe and reliable. In general, aircraft
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Air Transportation Industry
Description of Operations
maintenance is the function of three factors: (1) hours of flight time, (2)
number of landing and take off cycles, and (3) calendar length of time from
prior maintenance. Aircraft preventive maintenance starts with daily
inspections of items such as tires, brakes, and fluid levels. The aircraft then
continues to receive many levels of maintenance that include fluid and filter
changes, detailed testing, inspections for cracks and corrosion, and after many
hours of flying (usually over 100,000), complete refurbishing of the aircraft
to return the plane to its original condition.
Aviation-support vehicles undergo a similar, yet less rigorous schedule of
inspections, testing, and maintenance that includes oil and fluid changes,
battery replacement, and repairs including metal machining.
Environmental Aspects and Potential Impacts of Aircraft Maintenance
Environmental aspects of aircraft maintenance include the use and disposal
of aircraft and vehicle fluids such as:
Wastewater from parts cleaning, metal finishing, or coating
applications
Generation of hazardous wastes consisting of flammable and metals-
contaminated solvents, used hand-wipes, and sludges collected during
all maintenance operations
Hazardous air pollutant (HAP) emissions from solvent-based cleaners
and coatings used in all activities.
Wastes generated as a result of aircraft and aviation-support vehicle
maintenance and repair activities can include used oil, spent fluids, batteries,
metal machining wastes, organic solvents, and tires. Some of these wastes
can be toxic or otherwise hazardous, and uncontrolled releases can
contaminate surface water, groundwater, and soils. Typical materials used
in each operation and the potential impacts of use and disposal of these
materials are identified in Exhibit 11. A description of these operations and
associated environmental impacts appear below.
Lubrication and Fluid Changes. Lubrication and fluid changes are part of
the aircraft standard maintenance program. These activities occur at regular
intervals, and as inspections indicate they are necessary. In conducting
aircraft lubrication and fluid changes, these operations may generate waste
oil and greases. These materials have the potential to contaminate water
supplies and soil if not properly stored. By storing these materials in secure
containers or tanks with secondary containment, the potential for releases to
impact the environment is significantly reduced.
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Air Transportation Industry
Description of Operations
Exhibit 11. Maintenance and Refurbishing Operations: Activities and
Potential Environmental Impacts
Operation
Lubrication and
Fluid Changes
Battery repair and
replacement
Chemical Milling
Maskant
Application and
Chemical Milling
Parts Cleaning
Metal Finishing
Coating
Application
Depainting
Painting
Activities
Storage, transfer, and
disposal of petroleum
products
Storage of batteries
containing sulfuric
acid
Use and disposal of
maskants containing
either toluene/xylene
mixture or
perchloroethylene
Aqueous, semi-
aqueous, and solvent-
based cleaner use and
disposal
Use and disposal of
processing solutions,
cyanide, heavy metal
baths
Primer and topcoats
application and
disposal
Chemical or blast
depainting agents use
and disposal
Paint use, storage,
and disposal
Environmental Aspects and ;
Potential Impacts
Potential to contaminate soil,
groundwater, and surface waters, if
spilled or allowed to enter storm drains
Potential to contaminate soil,
groundwater, and surface waters with
hazardous material, if not contained
and covered from weather
Air pollution from organic HAP
emissions, waste maskant
Water pollution from wastewater
containing cleaners, waste solvents;
metals, oil, and grease
Air pollution from organic HAP
emissions
Air pollution from HAP emissions;
contaminated wastewater including
cyanide solutions, corrosive acid and
alkali solutions; heavy metal sludges
Air pollution from organic HAP
emissions; waste paint; waste solvent
thinner
Contaminated sludge (stripper solution
and paint residue); air contamination
from VOC emissions from paints; solid
waste containing paint chips and spent
blasting media.
Soil or water contamination from
disposal of waste paint, thinners,
solvents, resins; air contamination by
VOC emissions.
Battery repair and replacement. Battery repair and replacement involve
removing, repairing, and recharging aircraft and vehicle batteries. These
operations have the potential to impact the environment if sulfuric acid in the
batteries is released. Acid has the potential to contaminate soil and
groundwater supplies, and to cause personnel injury if used batteries are not
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Air Transportation Industry
Description of Operations
properly handled. By using proper safety equipment during handling, and
storing batteries in a contained and covered area that is not exposed to rain
water, batteries are less likely to cause a significant impact.
Chemical Milling Maskant Application and Chemical Milling. This
operation uses etchant solutions to reduce the thickness of selected areas of
metal parts in order to reduce weight. Chemical milling maskants are
typically rubber- or polymeric-based coatings applied to an entire part or
subassembly by brushing, dipping, spraying, or flow coating. After the
chemical milling maskant is cured, it is removed from selected areas of the
part where metal is to be removed during the chemical milling process.
Chemical milling maskants typically contain either a toluene/xylene mixture
or perchloroethylene as solvent constituents. These chemical solvents
vaporize when exposed to air, and if not stored in tightly sealed containers,
become a source of hazardous air pollutants (HAPs). These organic HAP
emissions also occur as the solvent evaporates as the chemical milling
maskant is applied and cured.
Parts Cleaning. Aircraft components are cleaned frequently to remove
contaminants such as dirt, grease, and oil. Cleaning is performed using a
wide variety of cleaning materials, including aqueous, semi-aqueous, or, in
some cases, solvent-based cleaners. Recently, many aircraft maintenance
facilities have substituted solvent-based cleaners with water-based cleaning
materials. Many components are cleaned with soap and water.
Parts cleaning operations can include immersion, flush, spray gun cleaning,
or hand wiping of aircraft components. For most parts, cleaning is typically
performed by a hand wiping process. -However, parts that are either too large
or too intricate to hand wipe are cleaned by immersion in large solvent baths
or parts cleaning machines. Assemblies and parts with concealed or
inaccessible areas may be cleaned by pouring the cleaning material over or
into the part. The cleaning material is then drained from the part and the
procedure is repeated as many times as necessary to ensure the required
cldanliness. ,
The potential environmental impact of parts cleaning operations is dependent
on the type of cleaning solution used. Halogenated, solvent-based cleaning
materials potentially have the most significant impact. These solvents can
generate organic HAP emissions from the evaporation of solvents during the
cleaning process, including: (1) evaporation of solvent from open containers
and solvent-soaked cloth and paper, and (2) emissions from storage tanks
used to store cleaning solvents. In addition, solvent spills have the potential
to contaminate soil, groundwater, or surface water. Contamination can be
caused by hazardous constituents found in solvents themselves, as well as in
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Description of Operations
metals, oils, and other potential contaminants found in the parts being
cleaned. Spent hazardous solvents must be managed as hazardous wastes.
Typically, they are reclaimed by a RCRA permitted hazardous waste recycler.
Facilities that use aqueous or semi-aqueous cleaning materials have a much
less significant potential environmental impact because they do not generate
hazardous air emissions. They do, however, generate metals, oil, and grease
in the aqueous system that have the potential to contaminate water supplies.
Wastewater from these cleaning processes is required to be treated onsite in
accordance with the facility's wastewater discharge permit (known as a
National Pollutant Discharge Elimination System or NPDES permit) or
according to standards set by any local pretreatment programs.
Metal Finishing. Metal finishing processes are used to prepare the surface
of a part for better adhesion, improved surface hardness, and improved
corrosion resistance. Typical metal finishing operations include chemical
conversion coating, anodizing, electroplating, and any operation that
chemically affects the surface layer of a part. Each of these metal finishing
operations has the potential to significantly impact the environment by
discharging metals, cyanides, phosphates, acids, and other contaminants to
waterways, soil, or groundwater.
HAP emissions and contaminated wastewater are the most significant
environmental aspects of metal finishing operations. As the organic
chemicals in the processing solutions evaporate, they generate hazardous
vapors and emissions. Evaporation of solution also occurs from refurbished
parts as they are removed from the processing tanks. Wastewater from these
operations includes cyanide solutions, corrosive acid, and alkali solutions.
This water is typically treated prior to discharge, in accordance with a
facility's NPDES permit or applicable pretreatment requirements. For more
details on metal finishing processes and the associated environmental aspects,
see EPA's Sector notebook titled Profile Of The Fabricated Metal Products
Industry (EPA 310-R-95-007).
Coating Application. A coating is a material that is applied to the surface of
a part to form a decorative or functional solid film. The most common
coatings are primers and topcoats. Coatings are applied to aircraft
components using several methods of application. The methods most
commonly used are spraying, brushing, rolling, flow coating, and dipping.
Nearly all coatings contain a mixture of organic solvents. Spray guns and
other components of coating units must be cleaned when switching from one
coating to another. The cleaning of spray guns involves disassembling the
gun and placing the parts in a vat containing an appropriate solvent. The
residual coating is brushed or wiped off the parts.
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Description of Operations
Organic HAP emissions from coating application are generated from
evaporation of solvents during mixing, application, and from overspray,
which is exhausted from spray booths or hangars. Coating operations also
produce waste paint and waste solvent thinner that are typically drummed and
shipped offsite as RCRA hazardous waste.
Depainting. Depainting involves the removal of coatings from the outer
surface of aircraft. Two methods are chemical stripping and blast depainting.
During chemical stripping, stripping agents are applied to the aircraft,
allowed to degrade the coating, and then scraped or washed off with the
coating residue. Blast depainting methods use a media such as plastic, wheat
starch, carbon dioxide, or high pressure water to remove coatings by
physically abrading the coatings from the surface of the aircraft. Depainting
operations can produce either a liquid or solid waste stream, depending on the
type of process used.
Air pollution and soil or water contamination are potential impacts from
depainting. Chemical depainting generates organic HAPs from evaporation
of the solvents in the stripping solution, while particulate emissions occur
from the blasting media. Depainting operations can produce either a liquid
or solid waste stream, depending on the type of process. Chemical depainting
processes produce a liquid sludge that consists of the stripper solution and
paint residue. Blast depainting processes produce a solid waste stream that
consists of paint chips and spent blasting media. These wastes are required
to be characterized as hazardous or nonhazardous and disposed of
appropriately.
Painting. Aircraft painting generally occurs in an enclosed area to minimize
potential environmental and human health impacts. High pressure, low
volume, and electrostatic painting systems can reduce the amount of paint
needed for a job.
Aspects of painting with potential environmental impacts include
management of unused paints, spray paint booth air filters, and spent paint
thinner, and emissions of volatile organic compounds (VOCs) from thinners
and solvents. Spent paint filters often must be handled as hazardous waste
because of the presence of wet paint or paint containing lead or chromium.
Through proper training of employees and the use of high efficiency
equipment, painting operations have been able to reduce paint waste,
minimize air emissions, and protect the health of employees.
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Description of Operations
III.A.2. Fueling
An essential part of any airport operation is the fueling of aircraft. Fueling
is conducted either by tank trucks or a central, underground fueling system.
In both operations, fueling involves the transfer of a potentially hazardous
liquid to the aircraft. Aviation fuels are broken down into two classes. The
reciprocating engines use various grades of aviation gasoline, while the jet
class, which includes gas turbines, utilizes jet fuels. There are grades of
aviation gasoline that are readily identified by the color-coded dyes added to
them. The color-coded system aids maintenance personnel in finding fuel
leaks when they occur and prevents fueling mixups.
For jet fuel, there are two basic grades of jet fuel, Jet-A and Jet-B. Jet-A fuel,
a narrow cut kerosene product, is the standard commercial and general
aviation grade available in the United States. It usually contains no additives
but may be additized with an anti-icing chemical. Jet-Al is identical to Jet-A
except that it has a lower freeze point. It is used outside the United States
and is the fuel of choice for long haul flights where the fuel temperature may
fall to near the freeze point. It often contains a static dissipator additive.
Jet-B fuel is a wide cut kerosene with lighter gasoline-type naphtha
components. It is not used by the commercial air transportation sector,
however, it is used by the military.
Fuel tanks are generally located in the wings of light aircraft. However,
depending on the make and model of the aircraft, it is also common to find
fuel tanks in the main fuselage. Fuel lines range in diameter from 1/8 of an
inch to as large as 4 inches on very large aircraft. Fuel lines of aircraft using
wing tanks are located back from the leading edge of the wing. With fuselage
tank model twin-engine aircraft, the fuel lines run from the fuselage tanks out
through the wing structure along the wing spar into the engine compartment.
On single-engine aircraft, the fuel lines are routed from the fuel tank to the
firewall, and then to the engine.
Environmental Aspects and Potential Impacts of Fueling
The major environmental aspect of fueling operations is managing the fuel
so that it is not released to the environment, either to the air, water, or soil.
Leaking pipes or improper connections between fueling lines and the aircraft
can allow fuel vapors to be released to the air, causing air contamination.
Leaks, improper connections, and improperly monitored storage tanks also
can lead to fuel spills. As a contingency measure, many airports and airlines
employ vacuum sweeper trucks as well as hand operated sweeper units for
spill response. Vacuum sweepers allow the spilled material to be removed
quickly from the site while minimizing the spill's potential to impact the
environment. If spills are not contained or diverted to an established
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treatment system, they may end up being discharged to soil and groundwater
' either directly through storm drains, or as sheet runoff during rain events.
Underground fueling systems that are not maintained properly can leak into
the surrounding soils and eventually contaminate groundwater. EPA
regulations for underground storage tanks require tanks to be upgraded and
monitored to reduce the probability of leaks to groundwater.
By conducting activities to prevent releases such as maintaining fuel tanks,
lines, and fueling systems, and by assuring proper training of employees, the
possibility of leaking tanks, equipment leaks, or accidental spillage is reduced
substantially.
III.A.3. Aircraft Cleaning
Exterior cleaning of aircraft typically consists of washing with detergent
solutions and a water rinse. Small aircraft cleaning is carried out using hand
held spray nozzles, hoses and brushes. For larger aircraft, wet cleaning
usually is limited to wheel wells and landing gear and is conducted to
facilitate inspections. In addition, wet cleaning sometimes is performed on
wing structure and flap-sequencing carriage areas for overhaul and inspection
processes and on the lower aircraft fuselage for removal of accumulations of
oil and grease.
Because it can be more economical (e.g., lower water costs) to dry polish
aircraft fuselages rather than wash them with water and cleaning solutions,
aircraft are cleaned using dry methods whenever possible.
Environmental Aspects and Potential Impacts of Cleaning
The primary environmental aspect of aircraft cleaning is the generation and
disposal of'wastewater from cleaning aircraft exteriors. If high pressure
steam cleaners are used, water use may range from 10-20 gallons for washing
small aircraft, and between 100 and 200 gallons for large aircraft.2
Wastewater from cleaning activities may contain diluted cleaning chemicals,
low concentrations of metals, oil and grease, solvents, dirt and grit, or other
materials that are used as detergents, or are found in the aircraft itself. If not
treated, the washwater has the potential to pollute the soil, groundwater, and
surface waters.
2
A Boeing 727 is an example of a narrow-body aircraft, while MD-11's, Boeing 747's and 767's are examples of
wide-body aircraft.
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To prevent such contamination, wastewater from cleaning operations usually
drains to catch basins where it is mixed with other airport wastewater and
discharged at an onsite treatment facility prior to discharge in accordance
with the facility's NPDES permit. Prior to discharge, the wastewater may
also pass through a holding tank where metals, dirt, and grit settle to the
bottom, oil and grease are skimmed off the water surface, and the remaining
water is discharged. If the washwater is not treated onsite, it may be
discharged to a publicly owned treatment works (POTW), where it is treated
prior to discharge. Washwater discharged to the POTW may be subject to
pretreatment requirements established by EPA and the POTW.
III.A.4. Aircraft Deicing and Anti-Icing
As noted earlier, FAA regulations govern every aspect of airline and airport
operations, including procedures and standards for aircraft maintenance and
airworthiness, including aircraft deicing. Aircraft deicing and anti-icing are
key components in assuring cold weather aircraft safety. Deicing and anti-
icing remove from and inhibit for a period of time the formation of ice and
snow on wings, fuselages, and other parts of the airplane that provide lift
during takeoff. Common practice is to deice (remove accumulation) then
anti-ice (protect from further accumulation) aircraft before takeoff. These
processes use glycol-based materials, including ethylene glycol, diethylene
glycol, or propylene glycol.
Aircraft deicing is carried out either at the departure gate area or at a central
or remote facility in the vicinity of the runway to minimize the amount of
time between treatment and takeoff. Central and remote deicing areas
facilitate collection of deicing fluids for recycling and treatment.
Deicing is almost performed exclusively using hand held nozzles and hoses.
Automatic deicer spray machines, called "deicing gantries", have been
developed in recent years. However, there are some limitations on the
practicality of such equipment and the associated capital investment.
Environmental Aspects and Potential Impacts of Deicing
Deicing operations generate spent deicer fluids. These fluids drain from the
aircraft surfaces or from the runway surfaces to drains that direct the fluids
to onsite water treatment facilities, to storm drains, or simply to paved
surfaces where they may be discharged to local waterways or groundwater as
sheet runoff. In some cases, deicing fluids may be released directly to the
environment through runoff to surface waters or infiltration to groundwater.
Glycol-based fluids deplete oxygen from the waters in which they are
disposed and have toxic effects on life forms in those waters (Aviation Week
and Space Technology, January 1995).
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In general, each airport has its own distinct characteristics and drainage
systems and collecting deicing fluid for reuse or recycling may not be
practical. However, some airports have constructed deicing fluid collection
systems that prevent discharge to storm water sewers and segregate spent
deicer from other wastewater for reclamation, recycling, onsite treatment, or
disposal offsite. FAA allows the reuse of deicing fluids that are reformulated
and re-certified to meet appropriate aircraft deicing fluid specifications.
However, at this time, the aviation industry has not recycled glycols for reuse
on aircraft or runways due to cost. Some reclaimed deicing fluids may be
sold in secondary markets (e.g., windshield deicers for automobiles). In
compliance with Clean Water Act requirements, spent deicing fluids are
treated either in the facility wastewater treatment system, discharged to
publicly owned wastewater treatment plants, or discharged directly to surface
waters in accordance with permit conditions.
III.A.5. General Aircraft Operational Activities
As discussed earlier, the FAA has jurisdiction over all aircraft operations and
prohibits states and local governments from regulating in the areas of aircraft
operations and airspace management. In addition, the exclusive jurisdiction
also extends to environmental statutes as they relate to the aviation industry.
For example, Section 233 of the Clean Air Act specifically prohibits states
from regulating air pollution from aircraft engines.
Aircraft Operation. The mode of operation of the aircraft can be broken
down into five stages: idling at gate and runway; engine power up; taxiing;
takeoff and climb out; and approach and landing. Depending on the type of
engine and aircraft, these activities can consume varying amounts of
resources and produce various pollutants. Because fuel is the airline
industry's second largest expense, increasing fuel efficiency of aircraft
engines has been a top priority of U.S. airlines. Over the past two decades,
U.S. airlines have increased fuel efficiency nearly 50% by lowering cruising
speeds, using computers to determine optimum fuel loads and to select
altitudes and routes that minimize fuel burn; and keeping aircraft exteriors
trimmed (i.e., stowed) to minimize aerodynamic drag.3
The environmental aspects of aircraft operation are related to the use and
burning of fuel. Fuel has the potential to cause varying environmental
impacts depending on the type of fuel, the efficiency of burning, and the
manner in which excess fuel is discarded. During aircraft operations, engines
emit hydrocarbons, carbon monoxide, and nitrogen oxides (NOx).
Hydrocarbon and carbon monoxide emissions result from incomplete
combustion at the lower power settings for descent, or when idling or taxiing
The Airline Handbook, Chapter 9: Airlines and the Environment from the Air Transport Association, 1997.
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on the ground. NOx, the result of combustion products mixing with nitrogen
in the air, is produced when engines are at their hottest, such as during
takeoffs and, to a lesser extent, during cruise when jet engines also produce
carbon dioxide and water vapor.
Aircraft loading and offloading. Aircraft loading and off loading includes
all activities associated with the movement of materials, items, and people in
and out of airplanes. Regardless of the type of airport, aircraft loading and
off loading occur an infinite number of times daily throughout the U.S.
Aircraft cargo loads consist of several different items, including but not
limited to passengers, baggage, mail, live animals, dangerous goods
(including hazardous materials), and wet cargo (e.g., fresh fish, seafood,
meat, casings, etc.).
The primary loading and off loading activity with a potentially significant
impact on human health and the environmental is the loading and off loading
of hazardous materials. Though a rare occurrence, these loading activities
have the potential to contaminate soil, groundwater, or surface water in the
event of a spill or release. Facilities minimize and control these impacts
through development and implementation of spill prevention control and
countermeasures plans, storm water pollution prevention plants, and other
emergency response programs.
If hazardous materials are transported by aircraft, the materials are subject to
U.S. Department of Transportation (DOT) requirements that regulate aircraft
inspections, placement of materials, packaging, and shipping papers (e.g.,
waybills, manifests). If hazardous materials are loaded onto an airplane,
containers should be inspected for proper labeling/placarding, any signs of
leakage, and compatibility with other hazardous materials. If damage or
spillage of a package containing hazardous materials is observed on board an
aircraft or during loading/off loading, immediate action must be taken in
accordance with company or airport procedures.
Transportation of Dangerous Goods. Once hazardous materials are loaded
onto aircraft, they are transported to their destination. In preparation for
transport, they are stored, segregated and secured to assure safety during the
transportation process. If improperly stored and secured, dangerous goods
have the potential to not only impact the health of workers and passengers,
but also to impact the safety of the aircraft itself.
To assure that these goods are transported in a safe manner, regulations have
been established by DOT and the International Civil Aviation Organization
(ICAO) Dangerous Goods Panel. These standards regulate the types of
materials that can be transported, and the types of aircraft in which they can
be transported. The ICAO Dangerous Goods regulations include a detailed
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list of individual articles and substances specifying the United Nations
classification-of each article or substance, their acceptability for air transport,
and the conditions for their transport.
According to the regulations, dangerous goods may be transported in one of
the following ways: they may not be carried on any aircraft under any
circumstances; they are forbidden under normal circumstances, but may be
carried with specific approvals from the States concerned; they may be
carried only on cargo aircraft; or they may be safely carried on passenger
aircraft, provided certain requirements are met. It should be noted that most
dangerous goods fall into the latter transport category.
The ICAO Dangerous Goods regulations also provide packing instructions
for aU dangerous goods acceptable for air transport with a wide range of
options for inner, outer, and single packaging. In addition, all individuals
involved in the preparation or transport of dangerous goods must be properly
trained to carry out their responsibilities. Information on the goods must be
conveyed by the pilot to air traffic services to aid in the response to any
aircraft incident or accident. Finally, dangerous goods accidents or incidents
must be reported, so that an investigation by the relevant authorities can
establish the cause and take corrective action.
Aircraft Noise. Another type of pollution generated from the operation of
aircraft is noise pollution. Noise, from airports is a significant negative
impact for many people in the airport vicinity. Federal noise regulations
require all large aircraft to meet noise standards. FAR Part 150 regulations
address the issue of aircraft noise and provide a comprehensive scheme for
planning and mitigation measures funded by aviation trust funds intended to
reduce noise impacts on the public (US EPA Office of Federal Activities,
Pollution Prevention/Environmental Impact Reduction Checklist for
Airports).
Air Pollutants from Transportation
The EPA Office of Air Quality Planning and Standards has compiled air
pollutant emission factors for determining the total air emissions of priority
pollutants (e.g., total hydrocarbons, SOx, NOx, CO, particulates, etc.) from
many transportation sources. The Aerometric Information Retrieval System
(AIRS) contains a wide range of information related to stationary sources of
air pollution, including the emissions of a number of air pollutants which may
be of concern within a particular industry. Exhibit 12 summarizes annual
releases (from the industries for which a Sector Notebook Profile was
prepared) of carbon monoxide (CO), nitrogen dioxide (NO2), particulate
matter of 10 microns or less (PM10), total particulates (PT), sulfur dioxide
(SO2), and volatile organic compounds (VOCs).
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Exhibit 12. Annual Air Pollutant Releases by Industry Sector (tons/year)
Industry Sector
Power Generation
Petroleum Refining
Iron and Steel
Pulp and Paper
Stone, Clay, and Concrete
Transportation*
Organic Chemicals
Inorganic Chemicals
Nonferrous Metals
Lumber and Wood
Production
Metal Mining
Nonmetal Mining
Plastic Resins and Synthetic
Fibers
Metal Casting
Rubber and Misc. Plastics
Motor Vehicles, Bodies, Parts
and Accessories
Textiles
Printing
Fabricated Metals
Pharmaceuticals
Furniture and Fixtures
Ship Building and Repair
Electronics and Computers
Dry Cleaning
CO
366,208
734,630
1,386,461
566,883
105,059
128,625
112,410
153,294
214,243
122,061
4,670
25,922
16,388
116,538
2,200
15,109
8,177
8,755
4,925
6,586
2,754
105
356
102
N0^__
5,986,757
355,852
153,607
358,675
340,639
550,551
187,400
106,522
31,136
38,042
39,849
22,881
41,771
11,911
9,955
27,355
34,523
3,542
11,104
19,088
1,872
862
1,501
184
PM10
140,760
27,497
83,938
35,030
192,962
2,569
14,596
6,703
10,403
20,456
63,541
40,199
2,218
10,995
2,618
1,048
2,028
405
1,019
1,576
2,502
638
224
3
PT
464,542
36,141
87,939
111,210
662,233
5,489
16,053
34,664
24,654
64,650
173,566
128,661
7,546
20,973
5,182
3,699
9,479
1,198
2,790
4,425
4,827
943
385
27
' SO*
13,827,511
619,775
232,347
493,313
308,534
8,417
176,115
194,153
253,538
9,401
17,690
18,000
67,546
6,513
21,720
20,378
43,050
1,684
3,169
21,311
1,538
3,051
741
155
YOC
57,384
313,982
83,882
127,809
34,337
104,824
180,350
65,427
11,058
55,983
915
4,002
74,138
19,031
132,945
96,338
27,768
103,018
86,472
37,214
67,604
3,967
4,866
7,441
TOTALS
20,843,162
2,087,877
2,028,174
1,692,920
1,643,764
800,475
686,924
560,763
545,032
310,593
300,231
239,665
209,607
185,961
174,620
163,927
125,025
118,602
109,479
90,200
81,097
9,566
8,073
7,912
* 'Transportation" includes air, water, railroad, trucking, and pipeline categories and SIC codes, and as such,
represents a very broad range of industries. This represents stationary source air emissions only, not mobile
sources.
Source: U.S. EPA Office of Air and Radiation, AIRS Database, 1997.
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III.B. Airport Operations
Airport operations include all activities related to operating and maintaining
the airport. These activities include operation and maintenance of runways,
control towers, maintenance facilities, aircraft gates, baggage handling
facilities, and general airport operations. This section focuses on two of these
activities: runway deicing and general operations.
III.B.l. Runway Deicing
Airport runways, taxiways, and gate areas are sprayed with deicer and anti-
icer to remove and prevent the buildup of ice and snow that would inhibit
taxing, takeoff, and landing. Pavement deicing/anti-icing breaks the bond
holding ice and compacted snow to the surfaces of runways and taxiways,
facilitating mechanical ice and snow removal, and allowing aircraft to
maintain adequate friction between aircraft tires and the runway. Runway
and ramp deicing is usually done with one or more substances (e.g., glycol,
urea, sodium formate, and/or potassium acetate). Sand is usually reserved to
prevent slippage at the gate area, but not on taxiways and runways due to
potential engine ingestion hazards.
Environmental Aspects and Potential Impacts of Runway Deicing
Deicing mixtures have the potential to contaminate groundwater and surface
water supplies as they flow from airport runways to storm drains or to
waterways as sheet runoff. Sand has the potential to clog storm water drains
and contaminate water bodies through increased erosion and sediment
buildup. Deieing chemicals that mix with storm water discharges must be
managed according to the facility's NPDES storm water permit. In an effort
to control water contamination, many facilities direct storm water to an onsite
treatment facility prior to discharge.
III.B.2. General Airport Operations
General airport operations encompass many activities including passenger
and vehicle traffic, ticketing, baggage handling, passenger security, and
concessions and food services. Airports, like other administrative offices,
can generate large quantities of waste paper and consume large amounts of
energy from lighting, heating and cooling systems^ and computers.
Concession shops and food service operations can generate significant
quantities of solid waste, such as corrugated cardboard, paperboard, office
paper, newspapers, magazines, wooden pallets, aluminum, plastic, and glass
containers, as well as leftover food. Groundskeeping and landscaping
activities can generate waste pesticides and herbicides. Airport traffic
congestion can generate significant air emissions.
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Environmental Aspects and Potential Impacts of General Operations
The operation of airports can have a variety of impacts on the environment.
These impacts include erosion, sedimentation, soil compaction, noise
pollution, chemical pollution resulting.from aircraft maintenance and deicing,
aircraft emissions, contaminated runway and grounds runoff, generation of
waste construction materials, and litter and other debris from administrative
and food service operations.
In regards to wildlife, there is typically no significant destruction of wildlife
habitat. FAA is, however, aware of the problem that certain species (e.g.,
large waterfowl, birds that flock, deer) cause aviation. As a result, FAA
encourages, and in some cases requires, airport sponsors to work with
wildlife agencies to manage the habitat attracting these species. Such
measures are needed to reduce the number of collisions between these species
and aircraft to protect human and wildlife populations.
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IV. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place. Some
companies have creatively implemented pollution prevention techniques that
improve efficiency and increase profits while at the same time minimizing
environmental impacts. Airlines and airports are reducing material inputs, re-
engineering processes to reuse by-products, improving management practices,
and employing substitution of toxic chemicals. Some operations are able to
actually get below regulatory thresholds just by reducing pollutant releases
through aggressive pollution prevention policies. While implementing
pollution prevention techniques, it is important that the facility assure that
the techniques are conducted in accordance with FAA safety regulations
and airworthiness requirements. FAA's Advisory Circular entitled,
"Management of Airport Industrial Waste"(AC#150/5320-15), provides
guidance on managing industrial wastes that airport operations generate.
The Pollution Prevention Act of 1990 established a national policy of
managing waste through source reduction, which means preventing the
generation of waste. The Pollution Prevention Act also established as
national policy a hierarchy of waste management options for situations in
which source reduction' cannot be implemented feasibly. In the waste
management hierarchy, if source reduction is not feasible, the next alternative
is recycling of wastes, followed by energy recovery, and as a last alternative,
waste treatment.
In order to encourage these approaches, this section provides both general and
company-specific descriptions of some pollution prevention advances that
have been implemented within the air transportation industry. While the list
is not exhaustive, it does provide core information that can be used as the
starting point for facilities interested in beginning their own pollution
prevention projects. This section provides summary information from
activities that may be or are being implemented by this sector. When
possible, information is provided that gives the context in which the
technique can be used effectively.
Please note that the activities described in this section do not necessarily
apply to all facilities that fall within this sector. Facility-specific conditions
must be considered carefully when pollution prevention options are
evaluated, and the full impacts of each option must be evaluated for its effects
on air, land, and water pollutant releases.
Waste minimization generally encompasses any source reduction or recycling
that results in either the reduction of total volume or the toxicity of hazardous
waste. Source reduction is a reduction of waste generation at the source,
usually within a process. Source reduction can include process
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modifications, feedstock (raw material) substitution, housekeeping and
management processes, and increases in efficiency of machinery and
equipment. Source reduction includes any activity that reduces the amount
of waste that exits a process. Recycling refers to the use or reuse of a waste
as an effective substitute for a commercial product or as an ingredient or
feedstock in an industrial process.
IV.A. Air Transportation Operations
Pollution prevention/waste minimization opportunities in the air
transportation industry are available for many operations including aircraft
and vehicle maintenance and repair, washing and cleaning, deicing, fueling,
aircraft modification, and airport layout and operations. These areas are
addressed in the following sections.
IV.A.1. Maintenance and Refurbishing Operations
Aircraft maintenance activities generate wastes that are of great
environmental concern to the air transportation industry. The major
wastestreams from aircraft maintenance and refurbishing are lubricants,
batteries, scrap metal, parts cleaning'wastes (e.g., solvents), depainting wastes
(e.g., chemical paint stripping wastes, abrasive blast and surface preparation
wastes), and painting/painting equipment cleaning wastes. Source reduction
is the best pollution prevention approach for reducing the amount of wastes
produced. Source reduction can be achieved through material substitution,
process or equipment modification, recycling, or better operating practices.
Note: Such modifications must be made in accordance with FAA
requirements, as well as the extraordinarily specific maintenance practices
recommended by airframe and engine manufacturers. The following
material presents pollution prevention/waste minimization opportunities for
each type of waste.
Used Oil and Lubricants. Most airline maintenance facilities recycle used
oil. Recycling used oil requires equipment like a drip table with a used oil
collection bucket to collect oil dripping off parts. Drip pans can be placed
under aviation-support vehicles awaiting repairs in case they are leaking
fluids. Some facilities use absorbent materials (e.g., "pigs" or "quick dry")
to catch drips or spills during activities where oil drips may occur. While
absorbents prevent oil from impacting the environment, they actually create
more solid and potentially hazardous waste in the form of contaminated
absorbent materials. Preventing small spills in the first place, using drip
pans, or cleaning spills with rags, soap and water can prevent the generation
of additional waste. Recycling used oil by sending it to a commercial
recycling facility saves money and protects the environment.
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To encourage recycling, the publication How To Set Up A Local Program To
Recycle Used Oil is available at no cost from the RCRA/Superfund Hotline
at 1-800-424-9346 or (703) 412-9810.
Spent petroleum-based fluids and solids should be sent to a recycling center
whenever possible. Solvents that are hazardous waste must not be mixed
with used oil. If they are mixed, the entire mixture may be considered
hazardous waste, and thus subject to more stringent regulation. Non-listed
hazardous wastes will be mixed with waste oil, and as long as the resulting
mixture is not hazardous, can be handled as waste oil. All used drip pans and
containers should be-labeled properly.
Fluids. Aircraft and aviation-support vehicles require regular changing of
fluids, including oil, coolant, and others. To minimize releases to the
environment, these fluids should be drained and replaced in areas where there
are no connections to storm drains or municipal sewers. Minor spills should
be cleaned prior to reaching drains. Used fluid should be collected and stored
in separate containers. Fluids can often be recycled. For example, brake
fluid, transmission gear, and gear oil are recyclable. Some liquids are able to
be legally mixed with used motor oil which, in turn, can be reclaimed.
During the process of engine maintenance, spills of fluids are likely to occur.
The "dry shop" principle encourages spills to be cleaned immediately,
without waiting for the spilled fluids to evaporate into the air, to transmit to
land, or to contaminate other surfaces. The following techniques help
prevent spills:
/ Collect leaking or dripping fluids in designated drip pans or
containers. Keep all fluids separated so they may be properly
recycled.
/ Keep a designated drip pan under the vehicle while unclipping hoses,
unscrewing filters, or removing other parts. The drip pan prevents
splattering of fluids and keeps chemicals from penetrating the shop
floor or outside area where the maintenance is occurring.
/ Immediately transfer used fluids to proper containers. Never leave
drip pans or other open containers unattended.
Radiator fluids from aviation-support vehicles are often acceptable to
antifreeze recyclers. This includes fluids used to flush out radiators during
cleaning. Reusing the flushing fluid minimizes waste discharges. If a
licensed recycler does not accept the spent flushing fluids, consider changing
to another brand of fluid that can be recycled. Many maintenance facilities
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have purchased antifreeze recycling systems that connect directly to a vehicle
so that the antifreeze is taken from the vehicle, cleaned, and then put back
into the same vehicle.
If the maintenance facility services air conditioners in aviation-support
vehicles, special equipment must be used to collect the freon or other
refrigerant because it is not permissible to vent the refrigerant to the
atmosphere. Air conditioner maintenance activities require employee
training, specifically for handling refrigerants. Reusing refrigerants onsite is
less costly than the only other legal alternative, sending the refrigerant to an
offsite recycler.
Batteries. Facilities have many battery disposal options: recycling onsite,
recycling through a supplier, or direct disposal. Facilities should explore all
options to find one that is right for the facility. Many waste batteries must be
handled as hazardous waste. Lead acid batteries are not considered
hazardous waste as long as they are recycled. In general, recycling batteries
may reduce the amount of hazardous waste stored at a facility, and thus the
facility's responsibilities under RCRA. The following best management
practices are recommended when sorting used batteries:
S Place on pallets in a contained area, and label by battery type (e.g.,
lead-acid, nickel, and cadmium).
/ Protect them from the weather with a tarp, roof, or other means.
/ Store them on an open rack or in a watertight, secondary containment
unit to prevent leaks.
S Inspect them for cracks and leaks as they are removed from the
vehicle or aircraft. If a battery is dropped, treat it as if it is cracked.
Acid residue from cracked or leaking batteries is likely to be
hazardous waste under RCRA because it is likely to exhibit the
characteristic of corrosivity, and may contain lead and other metals.
/
Avoid skin contact with leaking or damaged batteries.
Neutralize acid spills and dispose of the resulting waste as hazardous
if it still exhibits a characteristic of a hazardous waste.
Machine Shop Wastes. The major hazardous wastes from metal machining
are waste cutting oils, spent machine coolant, and degreasing solvents.
However, scrap metal also can be a component of hazardous waste produced
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at a machine shop. Material substitution and recycling are the two best
means to reduce the volume of these wastes.
The preferred method of reducing the amount of waste cutting oils and
degreasing solvents is to substitute them with water-soluble cutting oils.
Recycling of waste cutting oils also is possible if nonwater-soluble oils must
be used. Machine coolant can be recycled, and a number of proprietary
systems are available to recycle the coolant. Coolant recycling is
implemented most easily when a standardized type of coolant is used
throughout the shop. Reuse and recycling of solvents also are achieved
easily, as mentioned above. Most shops collect scrap metals from machining
operations and sell these to metal recyclers. Metal chips which have been
removed from the coolant by filtration should be drained and included in the
scrap metal collection. Wastes should be segregated carefully to facilitate
reuse and recycling.
Small Parts Cleaning. Solvents are commonly used for small parts cleaning.
Spent solvents are often toxic and/or hazardous and should be disposed of in
an environmentally safe manner. Spent solvent, if hazardous, must be treated
and disposed of as hazardous waste, unless recycled properly. There are
several options for reducing the amount and/or toxicity of spent solvents:
Switch to non-hazardous substances. Switch from hazardous,
organic-based to non-hazardous, aqueous-based solvents. In addition,
certain aqueous parts washers can use detergents instead of solvents.
While water-based parts washers may be more expensive than
solvent-based parts washers (costs range from $1,000 to $3,000 for
water-based washers capable of washing small parts), the cost of the
parts washer can be quickly recovered as the cost of disposing or
recycling of hazardous solvent as well as the cost of any required
training for workers handling the solvent are eliminated. This will
reduce the amount of hazardous waste generated from cleaning
operations.
Keep lids closed when not in use. For solvents that contain volatile
organic compounds, keeping containers closed except when parts
actually are being cleaned reduces solvent emissions to the
atmosphere, improves worker safety, and allows the solvent to be
used longer, rather than simply to evaporate.
Reuse. Solvents can be reused if quality requirements are met and
until their effectiveness is compromised, and then they can be
recovered and recycled.
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Depainting
Recycle. Solvent, recycling also can decrease hazardous waste
production from small parts cleaning. Spent solvents can be cleaned
and recycled with a solvent still. Processes for recycling solvents are
well established and widely used in many industrial sectors. Solvents
should not be poured down sewer drains, mixed with used oil, or
stored in open containers to allow them to evaporate. Solvent stills
(e.g., distillation units) may only be installed in appropriately fire
rated areas.
Use good housekeeping practices. To minimize solvent waste
generation, facilities should use good housekeeping practices
including labeling of all chemicals and wastes to avoid misuse and
potential injury or contamination; keeping containers of hazardous
solvents closed to prevent air emissions; providing storage area leak
control and containment; and making improvements in drum location,
product transfer leak collection, and drum transport procedures. If
solvents are used, care should be taken to wear protective safety gear
and follow good housekeeping practices.
Chemical Stripping Wastes. Chemical stripping operations must be
conducted according to the appropriate and relevant requirements associated
with the original equipment manufacturers' specifications. Chemical
stripping wastes consist primarily of stripping agent and paint sludges.
Methylene chloride is the most commonly used paint stripping agent,
although the industry increasingly is using less toxic agents such as dibasic
esters, semi-aqueous, terpene-based products, aqueous solutions of caustic
soda, and detergent-based strippers that currently are available on the market.
In order to reduce compliance costs, many facilities are replacing methylene
chloride with nonhalogenated strippers.
The Aerospace National Emission Standards for Hazardous Air Pollutants
(NESHAP) (effective September 1998) places stringent limitations on the use
of chemical strippers containing hazardous air pollutants. (See discussion in
Section V.C Pending and Proposed Regulatory Requirements.)
Storing and reusing or recycling used strippers also are effective waste
minimization techniques. Solvent strippers, particularly stripping baths,
generally can be reused several times before their effectiveness is diminished.
Both spent caustic and organic stripping solutions can be treated to remove
contaminants. Segregating the spent stripping wastes from other waste
streams will help facilitate cost-efficient reuse and recycling of contaminated
strippers.
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Abrasive Blasting and Surface Preparation Wastes. Abrasive blasting is
being used as an alternative for chemical paint stripping. Although blasting
does not require disposal of chemical strippers, it does create a large amount
of water runoff and air pollution, and the presence of paint chips containing
hazardous metals and organometallic biocides can make abrasive blasting
wastes potentially hazardous. Research and testing are underway on a
number of innovative alternative paint removal and surface preparation
techniques including: plastic media blasting, steel shot slingers, water jet
stripping, thermal stripping, dry ice pellets, laser paint stripping, and
cryogenic stripping. However, an alternative as economically viable and easy
as chemical paint stripping has not been found.
Plastic media blasting has had mixed results. The same types and
quantities of solid wastes are generated as with grit blasting, but the
plastic media tend to be more easily recyclable through the use of
pneumatic media classifiers that are part of the stripping equipment.
The abrasion eventually turns the plastic media to dust, making the
waste paint the main waste to be disposed. However, it will not work
on epoxy or urethane paints. In addition, the blasting equipment is
more expensive and requires more highly trained operators.
Cavitating water jet stripping systems remove most paints, separate
the paint chips from the water, and treat the water to eliminate
dissolved toxic materials. Although relatively little hazardous waste
is generated by this process, it is not as efficient as grit blasting, and
the equipment has higher capital and operating costs.
The thermal stripping process softens the paint so it can be peeled
relatively easily. Although it generates only one waste stream (waste
paint), it is more labor-intensive than other stripping methods and can
only be used on non-heat-sensitive surfaces.
Carbon dioxide pellets can be used as a blast medium leaving only
paint chips that can be swept up and placed in containers for disposal
(the dry ice evaporates). However, the cost of the dry ice, storage,
and handling equipment can be substantial.
A pulsed carbon dioxide laser controlled by an industrial robot to
remove paint produces no residue. However, the method is complex,
capital intensive, and requires highly skilled operators.
Cryogenic stripping using liquid nitrogen baths followed by gentle
abrasion or plastic shot blasting is useful for small parts or objects,
but requires special equipment for handling the liquid nitrogen.
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IV.A.2. Fueling
Blasting cannot be used as a paint stripping method on certain substrate
because the abrasive media will cause damage, especially to composite
materials.
Painting and Painting Equipment Cleanup Wastes. Methods for
minimizing paint and painting equipment cleanup wastes include tight
inventory control, material substitution, and minimization of fugitive
oversprays. Tight inventory control techniques such as monitoring employee
operations or limiting access to raw materials storage areas force employees
to stretch the use of the raw materials. Use of less toxic types of paints can
reduce the amount of hazardous paint waste as well as painting equipment
cleanup waste (i.e., solvent wastes). Also, the use of powder coatings based
on finely pulverized plastics that are baked on at 400 °F has been tried as a
substitute for paint for some industrial applications.
Minimizing overspray has benefits in terms of both inventory control and
elimination of surface water runoff. For inventory control, overspray can be
minimized by using air-assisted, airless, high volume, low pressure turbine,
air-atomized electrostatic, and airless electrostatic application techniques. In
addition, overspray can be minimized by maintaining a fixed distance from
the surface while triggering the paint gun, and releasing the trigger when the
gun is not aimed at the target. Overspray control for minimizing runoff can
be achieved by using plastic sheeting under and around the aircraft being
painted, or using a paint booth for smaller parts.
To reduce the amount of wastes created by painting operations, all paint
should be used until containers are completely empty. Containers that are
considered empty under the Resource Conservation and Recovery Act
(RCRA) may be disposed of as solid waste (40 CFR 265). However, they
may face requirements under DOT regulations depending on the amount of
hazardous waste remaining in the container. Used containers of paint may
need to be disposed of as hazardous wastes if they are not completely empty.
Also, paint may be purchased in recyclable and/or returnable containers to
reduce disposal costs.
Pollution prevention opportunities for aircraft and vehicle refueling
operations primarily focus on the prevention of fuel spillage and the
associated air, water, and hazardous waste pollution. Fuel tank monitoring
and automatic shutoff devices are key spill prevention measures. Although
not permitted for jet fuel, using color-coded dyes to identify fuel grades of
aviation fuel is commonly used to prevent mixtures of fuel and to find fuel
leaks. One technique to prevent fuel spills is to install catchment basins,
including containment at hydrant pits. All leaking pipe joints, nozzle
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connections, and any damage to the fueling hose (e.g., kinks, crushing, breaks
in the carcass, bulges, blistering, soft spots at the coupling, deep cracks or
cuts, spots wet with fuel, or excessive wear) should be reported immediately
to reduce their potential impact on the environment. Using dry cleanup
methods for the fuel area reduces water runoff and associated contamination
of groundwater and surface water supplies.
Pollution prevention techniques for aircraft fueling include:
S Inspect fueling equipment daily to ensure that all components are in
satisfactory condition.
/ Employ proper grounding and bonding techniques for a safe fueling
operation.
S If fueling of an airplane occurs at night, assure it is carried out it in
well lit areas.
/ Where possible, avoid fueling an aircraft during aircraft maintenance
activities that might provide a source of ignition to fuel vapors.
Similarly, assure that all radio and radar equipment is off during the
refueling process.
«/ While fueling, check for leaks and assuring that the fueling operator
has a clear view of control panel.
/ Never leave the nozzle unattended during overwing fueling, or wedge
or tie the nozzle trigger in the open position.
/ Discourage topping off of fuel tanks, except when required for
compliance with FAA safety regulations.
S Sump of hydrant pits.
Vehicle fueling. Self-locking fueling nozzles minimize the risk, of both fuel
spillage and air pollution by ensuring a secure seal between the fuel source
and tank.
Fuel in vehicle operations. Use of battery-operated or alternative fuel
vehicles provides two ways to reduce emissions from aviation-support
vehicles. Natural gas vehicles, for example, are a viable alternative to
gasoline- and diesel-powered transportation. Almost any gasoline-powered
vehicle can be converted to run on natural gas by installing a natural gas fuel
system and storage tanks without removing any existing equipment. Diesel
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conversions are somewhat more complicated because they also involve
reducing compression and adding a sparked-ignition system. Other fuels
suitable for vehicles include methanol, ethanol, and propane.
In 1997, there were alternative fuel vehicle programs at virtually every major
airport in the United States. The alternative vehicle usage at airports runs the
gamut from taxis, shuttle buses, passenger busses, transport busses, minivans,
trucks, cars, tugs, tractors, belt loaders, and ground power units, to catering
vehicles. The use of natural gas vehicles is being driven by both cost
effectiveness and regulation. Many states require companies with fleets of
twenty or more vehicles to phase in alternative fuel vehicles. The 1990 Clean
Air Act also contains incentives to encourage the use of alternative fuels.
Federal (and in some areas, State) tax deductions for "alternative fuel
vehicles" and related refueling equipment are available. The maximum tax
deductions range from $2,000 to $50,000 for each alternative fuel vehicle and
up to $100,000 on refueling stations.
IV.A.3. Aircraft and Vehicle Exterior Cleaning
Pollution prevention opportunities for aircraft and aviation-support vehicle
cleaning focus on the reduction of wastewater discharges.
Note: Air worthiness
requirements may
dictate the quantity of
water used in certain
cleaning operations.
Aircraft Cleaning. For washing aircraft,
it is best to utilize a designated cleaning
area, recycle washwater (if possible), and
use phosphate-free detergents.
Washwater should be contained and an
oil/water separator should be used.
Washwater can be captured, filtered, and
reused in aircraft washing and other activities. If the washwater is
reused for washing aircraft, it must meet the manufacturer's
specifications for washwater. Washwaters containing contaminants
can result in corrosion of potentially critical aircraft parts.
Another water reduction tool, a flow restrictor, can be used to control
the amount of water being used to wash aircraft. A reduction in water
usage will translate into a reduction in the volume of generated
wastewaters. (Note that technologies for water reduction are only
suggestions and should be evaluated individually to address the
circumstances appropriate to each site.)
Vehicle Washing. Vehicle washing has become a major
environmental compliance issue for most companies that operate a
fleet of vehicles. While pollutants from vehicle washing are generally
controlled by routing the water through an oil and water separator,
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many techniques are available that prevent the water from being
generated at all. The following pollution prevention activities will
help ensure that a facility is addressing potential sources of pollution:
i/ Wastewater discharge can be prevented by dry washing
vehicles using a chemical cleaning and waxing agent, rather
than detergent and water. The dry washing chemical is
sprayed on and wiped off with rags. No wastewater is
generated. Dry washing is labor intensive and creates solid
waste that must be disposed of properly.
/ Wastewater can be contained by washing at a low point of the
facility, blocking drains from the facility using a containment
dike or blanket, or washing on a built-in or portable
containment pad.
S Wastewater can be disposed of by evaporation from a
containment area, or by discharging the wastewater to a
sanitary sewer system. Permission must be obtained from the
POTW before washwater can be drained, pumped, or
vacuumed to a sanitary sewer connection.
IV.A.4. Aircraft Deicing
As noted earlier, FAA regulations and advisory circulars govern in detail
virtually every aspect of airline and airport operations, particularly with
respect to procedures and standards for aircraft maintenance and
airworthiness, including aircraft deicing. Potential pollution prevention
opportunities for aircraft deicing operations include (1) providing the
appropriate training on the use of glycol products to ensure they are
efficiently applied to reduce polluting airport runoff and (2) collecting deicing
fluid to prevent direct discharges to surrounding surface water and
groundwater along with facility storm water. Appropriate liquid aircraft
deicers include ethylene glycol, propylene glycol, and di-ethylene glycol.
Recycling deicing fluid. In general, the reuse of deicier fluid on aircraft is
problematic and usually prohibited due to quality control and the cost issues
associated with storage and treatment. However, recycling deicing fluid is
a method employed by some airports and airlines as recycled deicing fluid
can be used for nonaircraft applications. There are two main processes used
to recycle deicing fluid. The first process involves filtering collected fluid,
demineralizing it, removing salts, and then evaporating the water to leave a
higher glycol concentration.
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The second process uses reverse osmosis membrane technology to recover
glycol by preconcentrating dilute runoff prior to distillation. In order to make
recycling practical and economically feasible, it is necessary to collect
concentrations that contain more than 10% glycol. Traditionally to allow
recycling, only one type of chemical glycol (ethylene or propylene) could be
used at an airport. However, newer methods are available to handle mixtures.
The benefits of recycling fluids include recovery of the cost of glycol,
recovery of the utility cost for water, and reduced disposal cost for spent
glycol.
The most widespread collection method involves the collection of deicer
through separate drainage areas around aircraft deicing operations, which
minimizes the mixing of storm water and deicing fluid. The collection
systems can be located either at the gate area or at a remote deicing area.
Deicer fluid at gate area surfaces can be collected using vacuum sweeping
machines, sponge rollers, and pumps.
Alternative deicing methods. Additional technology-based, alternative
deicing methods currently are being developed by industry. While some of
these have yet to be proven cost effective, they do present viable alternatives
as technology is improved.
FAA has approved site-specific procedures for infra-red equipment
designed to de-ice aircraft.
Deicing truck with a cab. This type of enclosure for the operator
reduces overspray since the operator can get closer to the job.
However, minimum safe distances must be maintained to avoid
accidents and damage to aircraft or personnel. Customers of such a
system have reported up to 30% reductions in consumption of glycol-
based and other anti-deicing fluids.
More advanced computerized ice detection protection systems. For
example, a system that takes electronic measurements from a wing-
mounted sensor disc to identify the type and thickness of ice
contamination has been developed. The system also can tell when the
deicing fluid is in a transition stage and about to fail as a protective
coat. Such a mechanism would be useful in determining when and
where the aircraft needs to be deiced.
Segregation ofWastestreams. Wastewater segregation can be an effective
technique that often does not require significant process or equipment
modifications. In some cases, wastewater streams can be treated more
effectively and economically if they are segregated from other streams which
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do not require the same degree of treatment. Highly contaminated
wastewater streams, oily wastewater streams, and wastewater streams
containing contaminants requiring a specific treatment method (e.g., metals
removal) can be segregated to reduce the volume of wastewater receiving
certain treatment steps. Wastewater treatment can also be improved by
adding stages to existing wastewater treatment systems. Additional stages,
such as biological treatment, chemical precipitation, filtration, ion exchange,
and sludge dewatering, improve system effectiveness and treatment costs
through reduced sludge generation, recovery of metals for resale, and
replacement of more costly treatment stages. By segregating wastestreams,
facilities can provide the appropriate treatment to each wastewater stream.
(Note: Wastestream segregation should be considered as a preferred
alternative at a new or existing facility when it can be accomplished at a
reasonable cost.)
IV.A.5. General Aircraft Operations
Modifications. Pollution prevention opportunities for aircraft modification
primarily focus, on improving the efficiency of the engine. Engine
manufacturers are being encouraged or required to research and develop
cleaner, quieter, and more fuel-efficient aircraft. Air pollution is a function
of both the type of aircraft engine and the mode of operation of the aircraft,
which can be broken down into the following stages: idling at gate and
runway; engine power up; taxiing; takeoff and climb out; and approach and
landing. With respect to the type of engine, one mechanism that can improve
air quality in and around airports is for airlines and associated personnel to
encourage and support aviation research that would reduce aircraft emissions.
In the meantime, airlines have the option of buying and leasing aircraft that
meet or exceed the strictest requirements while retiring, replacing, or
retrofitting older equipment as rapidly as possible to reduce both the amount
of air and noise pollution.
Operations. Pollution prevention opportunities for aircraft operations at the
airport include the following:
/ Utilize more efficient aircraft. By operating more efficient aircraft,
airlines have been able to reduce fuel consumption and decrease the
cost of operations. Since 1976, the introduction of more fuel efficient
aircraft has reduced fuel consumption per passenger mile by
approximately 50%.4
Airline Fuel Consumption, The Boeing Company, 1997.
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Retrofit gate facilities to centralized ground power in order to reduce
aircraft engine running and prevent extraneous air emissions
associated with engine and auxiliary power unit usage.
Reduce holdover time from deicing to takeoff to eliminate the need
for a plane to require deicing more than once.
Checking cargo prior to loading for leaking or otherwise damaged
shipments will prevent the leakage of wastes. This is of particular
importance for loading dangerous goods, wet cargo, live animals, or
other cargo prone to leakage. After unloading, it is useful to check
the cargo compartments to ensure that all of the load for a given
station has been removed. Inspecting any traces of leakage at once
will enable the operator to establish the source of such leakage.
IV.B. Airport Operations
IV.B.1. Runway Deicing
In addition to collection and recycling of deicing fluids, pollution prevention
opportunities include the use of alternative, less polluting deicers such as
magnesium acetate and potassium acetate. These fluids have been approved
by FAA on both safety and environmental grounds, and have no significant
impact on water quality. It should be noted that although they have received
FAA approval, magnesium acetate and potassium acetate have caused safety
problems.by damaging aircraft lighting systems. As in all cases where
alternative technologies are used to minimize environmental impacts, aircraft
safety is a major concern and must be addressed.
IV.B.2. General Airport Operations
Pollution prevention opportunities for airports focus primarily on alleviating
air and noise pollution by implementing layout modifications and changes in
airport operations. These improved practices can reduce the amount of air
and noise pollution generated by aircraft and associated airport activities.
For existing airports, engage in comprehensive noise mitigation
planning and implement feasible measures to reduce noise impacts on
densely populated regions. For new airports, if possible, choose an
optimal site for the airport that is away from large communities.
Use proper land use planning, which is a local government
responsibility, for the areas affected by airport noise. For examples,
airports may choose to purchase land surrounding the airport for
airport use or acquire land as aviation easements. Airports may also
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work with local zoning boards and encourage them to zone land near
airports for airport compatible uses. In particular, FAA is concerned
about sanitary landfill locations near airports because landfills attract
certain bird species that are hazards to aviation due to their size
and/or flocking behavior.
Additional Airport Activities Impacting Air Quality. Air pollution resulting
from airport operations is dependent on both mobile sources of pollution such
as airplanes, ground-service vehicles, and automobiles accessing the airport
as well as point sources of pollution such as power plants, fueling systems,
fuel storage facilities, aircraft maintenance facilities, and deicing facilities.
Airport Traffic. Air quality in and around the airport vicinity is related not
only to aircraft using the airport but to travelers and employees accessing the
airport and maintenance vehicles that service the airport. Automobiles and
busses used by motorists that enter and leave airports create a large source of
air pollution through automobile exhaust. To reduce emissions from private
vehicles, airports can link or improve public transport access, provide express
bus services, and institute bus/high occupancy vehicle lanes on access roads.
Employee Programs. Initiating employee programs can reduce air pollution
in and around the airport. For instance, modifying airport employee work
weeks to a revised schedule that limits trips made by employees will decrease
air emission (e.g., an airport may implement a 9 day/80 hour two-week
schedule). Other options are voluntary employee Rideshare Programs or day
care services to prevent employees from having to travel unnecessary miles,
which in turn reduces the quantity of auto emissions associated with airport
operations.
Recycling solid waste. Recycling all paper, cardboard, plastics, metal, and
airport-specific items such as wood and film plastic will prevent pollution.
In addition, distributing recycling literature and educational materials to
employees and travelers will encourage more recycling of these materials.
Pest Management. Food waste from the large number of concessionaires at
major airports create pest management problems at airports. Various
pesticides, fumigants, and other pest management techniques are used at
airports to control pests.
Landscaping. Airport erosion control projects should use environmentally
and economically beneficial landscaping methods. Any plantings near
runways should avoid attracting hazardous wildlife (e.g., geese, gulls, large
mammals, or prey species that attract large mammals). However, careful
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planting can reduce the use of pesticides, herbicides insecticides, and
rodenticides; control erosion; reduce water usage; reduce energy usage;
reduce runoff and air emissions from mowers; and associated exposure to
workers and the public.
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Federal Statutes and Regulations
V. SUMMARY OF FEDERAL STATUTES AND REGULATIONS
This section discusses the Federal regulations that may apply to this sector.
The purpose of this section is to highlight and briefly describe the applicable
Federal requirements, and to provide citations for more detailed information.
The three following sections are included:
Section V.A. contains a general overview of major statutes
Section V.B. contains a list of regulations specific to this industry
0 Section V.C. contains a list of pending and proposed regulations
;
The descriptions within Section V are intended solely for general
information. Depending upon the nature or scope of the activities at a
particular facility, these summaries may or may not necessarily describe all
applicable environmental requirements. Moreover, they do not constitute
formal interpretations or.clarifications of the statutes and regulations. For
further information, readers should consult the Code of Federal Regulations
and other state or local regulatory agencies. EPA Hotline contacts are also
provided for each major statute.
V.A. General Description of Major Statutes
Resource Conservation and Recovery Act
The Resource Conservation And Recovery Act (RCRA) of 1976 which
amended the Solid Waste Disposal Act, addresses solid (Subtitle D) and
hazardous (Subtitle C) waste management activities. The Hazardous and
Solid Waste Amendments (HSWA) of 1984 strengthened RCRA's waste
management provisions and added Subtitle I, which governs underground
storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
260-299) establish a "cradle-to-grave" system governing hazardous waste
from the point of generation to disposal. RCRA hazardous wastes include the
specific materials listed in the regulations (commercial chemical products,
designated with the code "P" or "U"; hazardous wastes from specific
industries/sources, designated with the code "K"; or hazardous wastes from
non-specific sources, designated with the code "F") or materials which
exhibit a hazardous waste characteristic (ignitability, corrosivity, reactivity,
or toxicity, and designated with the code "D").
Regulated entities that generate hazardous waste are subject to waste
accumulation, manifesting, and recordkeeping standards. Facilities must
generally obtain a permit either from EPA or from a State agency which EPA
has authorized to implement the permitting program if they store hazardous
wastes for more than 90 days (or 180 or 270 days depending on the amount
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of waste generated and the distance the waste will be transported) before
treatment or disposal. Facilities may treat hazardous wastes stored in less-
than-ninety-day tanks or containers without a permit. Subtitle C permits
contain general facility standards such as contingency plans, emergency
procedures, recordkeeping and reporting requirements, financial assurance
mechanisms, and unit-specific standards. RCRA also contains provisions (40
CFR Part 264 Subpart S and §264.101) for conducting corrective actions
which govern the cleanup of releases of hazardous waste or constituents from
solid waste management units at RCRA treatment, storage, and disposal
facilities.
Although RCRA is a Federal statute, many States implement the RCRA
program. Currently, EPA has delegated its authority to implement various
provisions of RCRA to 47 of the 50 States and two U.S. territories.
Delegation has not been given to Alaska, Hawaii, or Iowa.
Most RCRA requirements are not industry specific but apply to any company
that generates, transports, treats, stores, or disposes of hazardous waste. Here
are some important RCRA regulatory requirements:
Identification of Solid and Hazardous Wastes (40 CFR Part 261
and 262) provides definitions and lays out the procedure every
generator must follow to determine whether the material in question
is considered a hazardous waste or solid waste, or is exempted from
regulation.
Standards for Generators of Hazardous Waste (40 CFR Part 262)
establish the responsibilities of hazardous waste generators including
obtaining an EPA ID number, preparing a manifest, ensuring proper
packaging and labeling, meeting standards for waste accumulation
units, and recordkeeping and reporting requirements. Providing they
meet additional requirements described in 40 CFR 262.34, generators
may accumulate hazardous waste for up to 90 days (or 180 or 270
days depending on the amount of waste generated and the distance the
waste will be transported) without obtaining a permit.
Land Disposal Restrictions (LDRs) (40 CFR Part 268) are
regulations prohibiting the disposal of hazardous waste on land
without prior treatment. Under the LDRs program, materials must
meet LDR treatment standards prior to placement in a RCRA land
disposal unit (landfill, land treatment unit, waste pile, or surface
impoundment). Virtually all hazardous wastes are subject to LDR
requirements. Generators of waste subject to the LDRs must provide
notification of such to the designated treatment, storage, and disposal
facility to ensure proper treatment prior to disposal.
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Federal Statutes and Regulations
Used Oil Management Standards (40 CFR Part 279) impose
management requirements affecting the storage, transportation,
burning, processing, and re-refining of the used oil. For parties that
merely generate used oil, regulations establish storage standards. For
a party considered a used oil processor, re-refiner, burner, or marketer
(one who generates and sells off-specification used oil directly to a
used oil burner), additional tracking and paperwork requirements
must be satisfied.
RCRA contains unit-specific standards for all units used to store,
treat, or dispose of hazardous waste, including Tanks and
Containers. Tanks and containers used to store hazardous waste
with a high volatile organic concentration must meet emission
standards under RCRA. Regulations (40 CFR Part 264-265, Subpart
CC) require generators to test the waste to determine the
concentration of the waste, to satisfy tank and container emissions
standards, and to inspect and monitor regulated units. These
regulations apply to all facilities that store such waste, including large
quantity generators accumulating waste prior to shipment off-site.
Underground Storage Tanks (USTs) containing petroleum and
hazardous substances are regulated under Subtitle I of RCRA.
Subtitle I regulations (40 CFR Part 280) contain tank design and
release detection requirements, as well as financial responsibility and
corrective action standards for USTs. The UST program also
includes upgrade requirements for existing tanks that must be met by
December 22, 1998.
Boilers and Industrial Furnaces (BIFs) that use or burn fuel
containing hazardous waste must comply with design and operating
standards. BIF regulations (40 CFR Part 266, Subpart H) address unit
design, provide performance standards, require emissions monitoring,
and restrict the type of waste that may be burned.
EPA's RCRA, SuperfundandEPCRA Hotline at 1-800-424-9346 responds
to questions and distributes guidance regarding all RCRA regulations. The
RCRA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST,
excluding Federal holidays.
Comprehensive Environmental Response, Compensation, and Liability Act
The Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), a 1980 law known commonly as Superfund, authorizes EPA
to respond to releases, or threatened releases, of hazardous substances that
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may endanger public health, welfare, or the environment. CERCLA also
enables EPA to force parties responsible for environmental contamination to
clean it up or to reimburse 'the Superfund for response costs (including
remediation costs) incurred by EPA. The Superfund Amendments and
Reauthorization Act (SARA) of 1986 revised various sections of CERCLA,
extended the taxing authority for the Superfund, and created a free-standing
law, SARA Title HE, also known as the Emergency Planning and Community
Right-to-Know Act (EPCRA).
The CERCLA hazardous substance release reporting regulations (40 CFR
Part 302) direct the person in charge of a facility to report to the National
Response Center (NRC) any environmental release of a hazardous substance
which equals or exceeds a reportable quantity. Reportable quantities are
listed in 40 CFR §302.4. A release report may trigger a response by EPA, or
by one or more Federal or State emergency response authorities.
EPA implements hazardous substance responses according to procedures
outlined in the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) (40 CFR Part 300). The NCP includes provisions for permanent
cleanups, known as remedial actions, and other cleanups referred to as
removals. EPA generally takes remedial actions only at sites on the National
Priorities List (NPL), which currently includes approximately 1300 sites.
Both EPA and states can act at sites; however, EPA provides responsible
parties the opportunity to conduct removal and remedial actions and
encourages community involvement throughout the Superfund response
process.
EPA's RCRA, Superfund and EPCRA Hotline at 1-800-424-9346 answers
questions and references guidance pertaining to the Superfund program. The
CERCLA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST,
excluding Federal holidays.
Emergency Planning And Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created the Emergency Planning and Community Right-to-Know Act
(EPCRA, also known as SARA Title HI), a statute designed to improve
community access to information about chemical hazards and to facilitate the
development of chemical emergency response plans by State and local
governments. EPCRA required the establishment of State emergency
response commissions (SERCs), responsible for coordinating certain
emergency response activities and for appointing local emergency planning
committees (LEPCs).
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EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four
types of reporting obligations for facilities which store or manage specified
chemicals:
EPCRA §302 requires facilities to notify the SERC and LEPC of the
presence of any extremely hazardous substance (the list of such
substances is in 40 CFR Part 355, Appendices A and B) if it has such
substance in excess of the substance's threshold planning quantity,
and directs the facility to appoint an emergency response coordinator.
EPCRA §304 requires the facility to notify the SERC and the LEPC
in the event of a release equal to or exceeding the reportable quantity
of a CERCLA hazardous substance or an EPCRA extremely
hazardous substance.
» EPCRA §311 and §312 require a facility at which, a hazardous
chemical, as defined by the Occupational Safety and Health Act, is
present in an amount exceeding a specified threshold to submit to the
SERC, LEPC and local fire department material safety data sheets
(MSDSs) or lists of MSDSs and hazardous chemical inventory forms
(also known as Tier I and H forms). This information helps the local
government respond in the event of a spill or release of the chemical.
EPCRA §313 requires manufacturing facilities included in SIC codes
20 through 39, which have ten or more employees, and which
manufacture, process, or use specified chemicals in amounts greater
than threshold quantities, to submit an annual toxic chemical release
report. This report, known commonly as the Form R, covers releases
and transfers of toxic chemicals to various facilities and
environmental media, and allows EPA to compile the national Toxic
Release Inventory (TRI) database.
All information submitted pursuant to EPCRA regulations is publicly
accessible, unless protected by a trade secret claim.
EPA's RCRA, Superfund and EPCRA Hotline at 1-800-424-9346 answers
questions and distributes guidance regarding the emergency planning and
community right-to-know regulations. The EPCRA Hotline operates
weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding Federal holidays.
Clean Water Act
The primary objective of the Federal Water Pollution Control Act, commonly
referred to as the Clean Water Act (CWA), is to restore and maintain the
chemical, physical, and biological integrity of the nation's surface waters.
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Pollutants regulated under the CWA include "priority" pollutants, including
various toxic pollutants; "conventional" pollutants, such as biochemical
oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and
grease, and pH; and "non-conventional" pollutants, including any pollutant
not identified as either conventional or priority.
The CWA regulates both direct and indirect discharges. The National
Pollutant Discharge Elimination System (NPDES) program (CWA §502)
controls direct discharges into navigable waters. Direct discharges or "point
source" discharges are from sources such as pipes and sewers. NPDES
permits, issued by either EPA or an authorized State (EPA has authorized 42
States to administer the NPDES program), contain industry-specific,
technology-based and/or water quality-based limits, and establish pollutant
monitoring requirements. A facility that intends to discharge into the nation's
waters must obtain a permit prior to initiating its discharge. A permit
applicant must provide quantitative analytical data identifying the types of
pollutants present in the facility's effluent. The permit will then set the
conditions and effluent limitations on the facility discharges.
A NPDES permit may also include discharge limits based on Federal or State
water quality criteria or standards, that were designed to protect designated
uses of surface waters, such as supporting aquatic life or recreation. These
standards, unlike the technological standards, generally do not take into
account technological feasibility or costs. Water quality criteria and
standards vary from State to State, and site to site, depending on the use
classification of the receiving body of water. Most States follow EPA
guidelines which propose aquatic life and human health criteria for many of
the 126 priority pollutants.
Storm WaterDischarges
In 1987 the CWA was amended to require EPA to establish a program to
address storm water discharges. In response, EPA promulgated the NPDES
storm water permit application regulations. These regulations require that
facilities with the following storm water discharges apply for an NPDES
permit: (1) a discharge associated with industrial activity; (2) a discharge
from a large or medium municipal storm sewer system; or (3) a discharge
which EPA or the State determines to contribute to a violation of a water
quality standard or is a significant contributor of pollutants to waters of the
United States.
The term "storm water discharge associated with industrial activity" means
a storm water discharge from one of 11 categories of industrial activity
defined at 40 CFR 122.26. Six of the categories are defined by SIC codes
while the other five are identified through narrative descriptions of the
regulated industrial activity. If the primary SIC code of the facility is one of
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those identified in the regulations, the facility is subject to the storm water
permit application requirements. If any activity at a facility is covered by one
of the five narrative categories, storm water discharges from those areas
where the activities occur are subject to storm water discharge permit
application requirements.
Those facilities/activities that are subject to storm water discharge permit
application requirements are' identified below. To determine whether a
particular facility falls within one of these categories, consult the regulation.
Category I: Facilities subject to storm water effluent guidelines, new source
performance standards, or toxic pollutant effluent standards.
Category ii: Facilities classified as SIC 24-lumber and wood products
(except wood kitchen cabinets); SIC 26-paper and allied products (except
paperboard containers and products); SIC 28-chemicals and allied products
(except drugs and paints); SIC 291-petroleum refining; SIC 311-leather
tanning and finishing; SIC 32- (except 323)-stone, clay, glass and concrete;
SIC 33-primary metals; SIC 3441-fabricated structural metal; and SIC 373-
ship and boat building and repairing.
Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal
mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
mining.
Category iv: Hazardous waste treatment, storage, or disposal facilities.
Category v: Landfills, land application sites, and open dumps that receive
or have received industrial wastes.
Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
SIC 5093-automotive scrap and waste material recycling facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41-
local passenger transportation; SIC 42-trucking and warehousing (except
public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
storage stations and terminals.
Category ix: Sewage treatment works.
Category x: Construction activities except operations that result in the
disturbance of less than five acres of total land area.
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Category xi: Facilities classified as SIC 20-food and kindred products; SIC
21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related
products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture
and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
paper and paperboard products; SIC 27-printing, publishing, and allied
industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
allied products; SIC 30-rubber and plastics; SIC 31-leather and leather
products (except leather tanning and finishing); SIC 323-glass products; SIC
34-fabricated metal products (except fabricated structural metal); SIC 35-
industrial and commercial machinery and computer equipment; SIC 36-
electronic and other electrical equipment and components; SIC 37-
transportation equipment (except ship and boat building and repairing); SIC
38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous
manufacturing industries; and SIC 4221-4225-public warehousing and
storage.
Pretreatment Program
Another type of. discharge that is regulated by the CWA is one that goes to
a publicly owned treatment works (POTWs). The national pretreatment
program (CWA §307(b)) controls the indirect discharge of pollutants to
POTWs by "industrial users." Facilities regulated under §307(b) must meet
certain pretreatment standards. The goal of the pretreatment program is to
protect municipal wastewater treatment plants from damage that may occur
when hazardous, toxic, or other wastes are discharged into a sewer system
and to protect the quality of sludge generated by these plants. Discharges to
a POTW are regulated primarily by the POTW itself, rather than the State or
EPA.
EPA has developed technology-based standards for industrial users of
POTWs. Different standards apply to existing and new sources within each
category. "Categorical" pretreatment standards applicable to an industry on
a nationwide basis are developed by EPA. In addition, another kind of
pretreatment standard, "local limits," are developed by the POTW in order
to assist the POTW in achieving the effluent limitations in its NPDES permit.
Regardless of whether a State is authorized to implement either the NPDES
or the pretreatment program, if the State develops its own program, it may
enforce requirements more stringent than Federal standards.
Spill Prevention Control and Countermeasure Plans
The 1990 Oil Pollution Act requires that facilities that could reasonably be
expected to discharge oil in harmful quantities prepare and implement more
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rigorous Spill Prevention Control and Countermeasure (SPCC) Plan required
under the CWA (40 CFR § 112.7). There are also criminal and civil penalties
for deliberate or negligent spills of oil. Regulations covering response to oil
discharges and contingency plans (40 CFR Part 300), and Facility Response
Plans to oil discharges (40 CFR §112.20) and for polychlorinated biphenyl
(PCB) transformers and PCB-containing items were revised and finalized in
1995.
EPA's Office of Water, at (202) 260-5700, will direct callers with questions
about the CWA to the appropriate EPA office. EPA also maintains a
bibliographic database of Office of Water publications which can be
accessed through the Groundwater and Drinking Water Resource Center at
(202)260-7786.
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) mandates that EPA establish
regulations to protect human health from contaminants in drinking water.
The law authorizes EPA to develop national drinking water standards and to
create a joint Federal-State system to ensure compliance with these standards.
The SDWA also directs EPA to protect underground sources of drinking
water through the control of underground injection of liquid wastes.
EPA has developed primary and secondary drinking water standards under
its SDWA authority. EPA and authorized States enforce the primary
drinking water standards, which are, contaminant-specific concentration
limits that apply to certain public drinking water supplies. Primary drinking
water standards consist of maximum contaminant level goals (MCLGs),
which are non-enforceable, health-based goals, and maximum contaminant
levels (MCLs), which are enforceable limits set as close to MCLGs as
possible, considering cost and feasibility of attainment.
The SDWA Underground Injection Control (UIC) program (40 CFR Parts
144-148) is a permit program which protects underground sources of
drinking water by regulating five classes of injection wells. UIC permits
include design, operating, inspection, and monitoring requirements. Wells
used to inject hazardous wastes must also comply with RCRA corrective
action standards in order to be granted a RCRA permit, and must meet
applicable RCRA land disposal restrictions standards. The UIC permit
program is primarily State-enforced, since EPA has authorized all but a few
States to administer the program.
The SDWA also provides for a Federally-implemented Sole Source Aquifer
program, which prohibits Federal funds from being expended on projects that
may contaminate the sole or principal source of drinking water for a given
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area, and for a State-implemented Wellhead Protection program, designed to
protect drinking water wells and drinking water recharge areas.
EPA's Safe Drinking Water Hotline, at 1-800-426-4791, answers questions
and distributes guidance pertaining to SDWA standards. The Hotline
operates from 9:00 a.m. through 5:30 p.m., EST, excluding Federal holidays.
Toxic Substances Control Act .
The Toxic Substances Control Act (TSCA) granted EPA authority to create
a regulatory framework to collect data on chemicals in order to evaluate,
assess, mitigate, and control risks which may be posed by their manufacture,
processing, and use. TSCA provides a variety of control methods to prevent
chemicals from posing unreasonable risk.
TSCA standards may apply at any point during a chemical's life cycle.
Under TSCA §5, EPA has established an inventory of chemical substances.
If a chemical is not already on the inventory, and has not been excluded by
TSCA, a premanufacture notice (PMN) must be submitted to EPA prior to
manufacture or import. The PMN must identify the chemical and provide
available information on health and environmental effects. If available data
are not sufficient to evaluate the chemicals effects, EPA can impose
restrictions pending the development of information on its health and
environmental effects. EPA can also restrict significant new uses of
chemicals based upon factors such as the projected volume and use of the
chemical.
Under TSCA §6, EPA can ban the manufacture or distribution in commerce,
limit the use, require labeling, or place other restrictions on chemicals that
pose unreasonable risks. Among the chemicals EPA regulates under §6
authority are asbestos, chlorofluorocarbons (CFCs), and PCBs.
EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
questions and distributes guidance pertaining to Toxic Substances Control
Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST,
excluding Federal holidays.
Clean Air Act
The Clean Air Act (CAA) and its amendments, including the Clean Air Act
Amendments (CAAA) of 1990, are designed to "protect and enhance the
nation's air resources so as to promote the public health and welfare and the
productive capacity of the population." The CAA consists of six sections,
known as Titles, which direct EPA to establish national standards for ambient
air quality and for EPA and the States to implement, maintain, and enforce
these standards through a variety of mechanisms.
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Under the CAAA, many facilities will be required to obtain permits for the
first time. State and local governments oversee, manage, and enforce many
of the requirements of the CAAA. CAA regulations appear at 40 CFR Parts
50-99.
Pursuant to Title I of the CAA, EPA has established national ambient air
quality standards (NAAQSs) to limit levels of "criteria pollutants," including
carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, sulfur
dioxide, and volatile organic compounds (VOCs). Geographic areas that
meet NAAQSs for a given pollutant are classified as attainment areas; those
that do not meet NAAQSs are classified as non-attainment areas. Under
Section 110 of the CAA, each State must develop a State Implementation
Plan (SIP) to identify sources of air pollution and to determine what
reductions are required to meet Federal air quality standards. Revised
NAAQSs for particulates and ozone were proposed in 1996 and may go into
effect as early as late 1997.
Title I also authorizes EPA to establish New Source Performance Standards
(NSPSs), which are nationally uniform emission standards for new stationary
sources falling within particular industrial categories. NSPSs are based on
the pollution control technology available to that category of industrial
source.
Under Title m, EPA establishes and enforces National Emission Standards
for Hazardous Air Pollutants (NESHAPs), nationally uniform standards
oriented towards controlling particular hazardous air pollutants (HAPs).
Title I, section 112(c) of the CAA further directed EPA to develop a list of
sources that emit any of 189 HAPs, and to develop regulations for these
categories of sources. To date EPA has listed 174 categories and developed
a schedule for the establishment of emission standards. The emission
standards will, be developed for both new and existing sources based on
"maximum achievable control technology" (MACT). The MACT is defined
as the control technology achieving the maximum degree of reduction in the
emission of the HAPs, taking into account cost and other factors.
Title n of the CAA pertains to mobile sources, such as cars, trucks, buses,
and planes. Reformulated gasoline, automobile pollution control devices,
and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA
uses to regulate mobile air emission sources.
Title IV of the CAA establishes a sulfur dioxide and nitrogen oxide
emissions program designed to reduce the formation of acid rain. Reduction
of sulfur dioxide releases will be obtained by granting to certain sources
limited emissions allowances, which, beginning in 1995, will be set below
previous levels of sulfur dioxide releases.
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Title V of the CAA of 1990 created a permit program for all "major sources"
(and certain other sources) regulated under the CAA. One purpose of the
operating permit is to include in a single document all air emissions
requirements that apply to a given facility. States are developing the permit
programs in accordance with guidance and regulations from EPA. Once a
State program is approved by EPA, permits will be issued and monitored by
that State.
Title VI of the CAA is intended to protect stratospheric ozone by phasing out
the manufacture of ozone-depleting chemicals and restrict their use and
distribution. Production of Class I substances, including 15 kinds of
chlorofluorocarbons (CFCs) and chloroform, were phased out (except for
essential uses) in 1996.
EPA's Clean Air Technology Center, at (929) 541-0800, provides general
assistance and information on CAA standards. The Stratospheric Ozone
Information Hotline, at 1-800-296-1996, provides general information about
regulations promulgated under Title VI of the CAA, and EPA's EPCRA
Hotline, at 1-800-535-0202, answers questions about accidental release
prevention under CAA §112(r). In addition, the Clean Air Technology
Center' s website includes recent CAA rules, EPA guidance documents, and
updates of EPA activities (www.epa.gov/ttn then select Directory and then
CATC).
V.B. Industry Specific Requirements
As noted earlier, several government entities regulate specific transportation
sectors. The air transportation industry is regulated by several different
Federal, State, and local agencies. The air transportation industry is regulated
by DOT's largest agencythe Federal Aviation Administration (FAA). The
DOT has traditionally established national standards that are not affected by
local or State laws.
EPA has traditionally relied on delegation to States to meet environmental
standards, in many cases without regard to the methods used to achieve
certain performance standards. This has resulted in States with more
stringent air, water, and hazardous waste requirements than the Federal
minimum requirements. This document does not attempt to discuss State
standards, but rather highlights relevant Federal laws and proposals that
affect the air transportation industry.
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Clean Water Act
NPDES Requirements. Wastewater from air transportation facilities
discharging to surface waters is regulated under the Federal Water Pollution
Control Act (FWPCA). National Pollutant Discharge Elimination System
(NPDES) permits must be obtained to discharge wastewater into navigable
waters. The airport is usually considered the "discharger" for regulatory
control and permitting purposes, and the individual tenants may not hold
specific discharge permits. However, in some cases, the airport is the
permittee and the tenants are the co-permittees. In the event of a discharge
problem, a tenant who is a co-permittee contributing wastewater to an
airport's discharge may be subject to action on the part of the airport or
regulators (EEA, 1996).
As mandated by Section 304(m) of CWA, EPA is developing effluent
limitation guidelines for certain industrial wastewater discharges from
operations. At this time, there are no effluent limitation guidelines
established specifically, for aviation operations, however, other wastewater
discharge restrictions may apply. For example, existing categorical
guidelines for metal finishing currently apply to certain discharges from this
industry sector. In addition, EPA is in the process of establishing effluent
limitation guidelines for the transportation equipment cleaning, which will
include operations such as exterior cleaning. These guidelines are scheduled
to be promulgated in 2000. (Contact: Gina Matthews or Jan Goodwin, Office
of Water, (202) 260-6036 and (202) 260-7152, respectively).
Storm Water Requirements. As discussed under the general description of
the Clean Water Act, EPA published storm water regulations on November
16, 1990, which require certain dischargers of storm water to waters of the
U.S. to apply for NPDES permits. According to the final rule, facilities with
a "storm water discharge associated with industrial activities" are required to
apply for a storm water permit. The rule states that transportation facilities
classified in SIC 40 through 45, and 5171 which have vehicle maintenance
shops, equipment cleaning operations, or airport deicing operations are
considered to have a storm water discharge associated with industrial
activity. However, only those portions of the facility that are either involved
in vehicle maintenance (including vehicle refurbishing, mechanical repairs,
painting, fueling, and lubrication), equipment cleaning operations, airport
deicing operations, or which are otherwise identified under paragraphs
(b)(14)(I)-(xi) of Section 122.26 are considered to be associated with
industrial activity. It is also important to that co-permittee permitting is
available if appropriate to a specific tenant/airport relationship for covering
storm water run off.
Facilities covered by this rule must submit one of the following permit
applications:
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Individual permit application.
Group permit application. A group permit application can be filed by
facilities with like operations and discharges. In 1991, a group storm
water permit application that covered airports was filed by the
American Association of Airport Executives and the Airport
Research and Development Foundation. On the application, airports
were identified as the permittee and all tenants as co-permittees
(EEA, 1996).
Notice of Intent for general permit coverage.
SPCC. The CWA requires facilities to develop Spill Prevention Control and
Countermeasure (SPCC) plans for petroleum products, such as oil or any
substance, that cause a sheen on water, if they are stored in large quantities
at a particular site. The SPCC program requires reporting spills to navigable
waters and the development of contingency plans that must be kept onsite.
SPCC plans document the location of storage vessels, types of containment,
dangers associated with a major release of material from the tanks, types of
emergency equipment available at each site, and procedures for notifying the
appropriate regulatory and emergency agencies. No SPCC plan is considered
complete'until it has been reviewed and certified by a registered Professional
Engineer.
Resource Conservation and Recovery Act
Air transportation facilities generate a variety of RCRA-regulated wastes in
the course of normal operations and utilize underground storage tanks for
fuel storage. However, underground airport hydrant fuel systems have been
deferred from the bulk of federal UST requirements pursuant to an exclusion
set forth in 40 CFR §280.10. Aircraft refurbishing and maintenance
operations generate hazardous wastes such as certain spent solvents and
caustics, and paints and paint sludges. Additional common materials from
aviation maintenance facilities that may be hazardous include:
Rechargeable nickel-cadmium batteries and lead-acid motor vehicle
batteries .
Vehicle maintenance fluids
Fluorescent light bulbs
Scraps of metals (cadmium, chromium, lead, mercury, selenium, and
silver) and materials containing these metals (e.g., high-grade
stainless steel or paint waste) (exempt if recycled)
Waste solvents
Near-empty paint cans and spray cans
Paint stripping residue.
Note that petroleum products and petroleum-containing wastes (e.g., waste
oil, contaminated fuel, or fuel spill clean-up wastes) are specifically
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exempted from RCRA regulations, unless they exhibit any of the hazardous
waste characteristics (EEA, 1996). "Many air transportation facilities qualify
as hazardous waste generators under RCRA law. Under RCRA, it is the
facility's responsibility to determine whether a waste is hazardous. A list of
EPA hazardous wastes can be found in 40 CFR §§261.31-261.33. Wastes
are also hazardous if they exhibit a characteristic described in 40 CFR
§§261.21-261.24. RCRA wastes are subject to the hazardous waste
regulations of 40 CFR Parts 124, 261-266, 270-273, and 302. Used oil and
USTs are subject to different rales.
Oil Pollution Act
The 1990 Oil Pollution Act (OPA) establishes strict, joint and several
liability against facilities that discharge oil or which pose a substantial threat
of discharging oil to navigable waterways. OPA imposes contingency
planning and readiness requirements on certain facilities that may include
vehicle maintenance shops. These requirements may affect some air
transportation maintenance establishments. Regulations covering response
to oil discharges and contingency plans (40 CFR Part 300), and facility
response plans to oil discharges (40 CFR Part 112) were revised and finalized
in 1994.
Comprehensive Environmental Response, Compensation, and Liability Act
A number of wastes generated from the air transportation refurbishing and
maintenance processes contain CERCLA hazardous substances. Therefore,
past spills and on-site releases of such substances may require remedial
clean-up actions under Superfund.
Emergency Planning and Community Right-to-Know Act
CERCLA/EPCRA Emergency Release Notification. Any person in charge
of a facility is required to immediately notify the LEPCs and SERCs likely
to be affected if there is a release into the environment f a hazardous
substance that exceeds the reportable quantity for that substance. Substances
subject to this requirement include those on the list of "extremely hazardous
substances" (40 CFR Part 355) as well as more than 700. hazardous
substances subject to the emergency notification requirements under
CERCLA Section 103(a) (40 CFR Section 302.4).
Many materials commonly used in the aviation industry fall into this category
of CERCLA hazardous substances, including many solvents, ethylene glycol,
methanol, methylene chloride, and 1,1,1-trichloroethane. With regard to the
obligation to report releases of ethylene glycol being used for aircraft deicing
at airports, the "facility" may include the track applying the deicer, the
aircraft to which the deicer is applied, or the entire airport. The person in
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charge of the "facility" must report a release into the environment of 5,000
pounds or more of ethylene glycol in any 24-hour period (EPA, 1996).
Federally Permitted Release Exemption. CERCLA Section 103(a) exempts
those persons in charge of facilities from reporting releases that are federally
permitted. On February 4, 1992, EPA issued OSWER Directive 9360.4-12
regarding CERCLA Reporting Requirements for Releases of Ethylene Glycol
From Airplane Deicing Operations. This Interpretative Memorandum and
OSWER Directive allows the airline industry to classify releases of the
ethylene glycol as nonreportable (or exempt) discharges if a facility (1) has
an NPDES permit covering ethylene glycol, (2) has applied for an NPDES
permit, or (3) discharges to a publicly-owned treatment works (POTW)
meeting the applicable pretreatment standards. Since most if not all fluid
discharges resulting from aircraft deicing operations usually fit into one of
the permitted release exemptions found in CERCLA Section 101(10), most
water discharges of ethylene glycol-based deicing fluids will not result in a
reporting requirement. (EPA, 1992)
Emergency Planning. Under EPCRA, a facility must notify authorities if it
has onsite at any time a listed hazardous substance in an amount over the
substance's threshold planning quantity. Extremely hazardous substances
that may be present in aviation-related facilities include nitric acid, sulfuric
acid, phenol and ammonia (EEA, 1996).
Clean Air Act
Sections 231-234 of the Clean Air Act gives exclusive jurisdiction to the
federal government and preempts any state or local regulation with respect
to emissions of any air pollutant from any aircraft or engine.
Air Quality Standards - Ozone Non-Attainment Areas. The most important
pollutant affected by air quality standards is ozone. In attainment areas, a
major source emits or has the potential to emit more than 100 tons per year
of any criteria pollutant or 10 tons per year of any hazardous air pollutant or
25 tons per year of any combination of hazardous air pollutants (emission
thresholds differ for various categories of nonattainment areas). Large
aircraft maintenance facilities performing aircraft painting or using large
amounts of solvents may exceed these limits. Emission rates are dependent
on the types of chemicals and methods used and the types of air emission
control equipment used. Some regulations apply to substances (e.g., solvent
degreasers) regardless of the size of the source. These regulations are
designed to reduce emissions from solvent evaporation (EEA, 1996).
To assist State and local agencies in establishing regulations that reduce VOC
emissions from the air transportation industry, EPA developed a control
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Federal Statutes and Regulations
technique guideline. This guideline offers an incentive of reduced
recordkeeping requirements for facilities that use only approved cleaning
agents, and.requires vapor pressure limits for non-listed cleaning agents.
Additionally, the guideline requires unused cleaning agent and solvent-laden
rags to be stored in containers to prevent evaporation. (EEA, 1996) Airports
located in ozone non-attainment areas may be subject to restrictions
applicable to motor vehicles. These restrictions may affect the type and use
of both airside and landside vehicles.
NESHAPs/MACT Standard. National emission standards for hazardous air
pollutants (NESHAP) attempt to control several hundred compounds, the
most notable for airports being asbestos. Airports must comply with the
NESHAP requirements for asbestos when demolishing, or significantly
remodeling, a building containing asbestos. Asbestos is commonly found in
ceiling tile, floor tile, boiler room insulation, and sprayed-on insulation
installed more than 20 years ago.
As stated earlier, MACT is the control technology achieving the maximum
reduction in the emission of the hazardous air pollutants, taking into account
cost and other factors. A MACT standard for coating operations conducted
by aerospace manufacturing and reworking facilities was finalized by EPA
in 1996. The emission limit from primers is 2.9 pounds per gallon and the
topcoat emission limit is 3.5 pounds per gallon. Generally, HAP emissions
are not permitted during paint removal operations (except during spot
stripping and decal removal) (EEA, 1996). However, a number of exceptions
may apply which permit such emissions under circumstances addressed in the
NESHAP. According to the aerospace NESHAP, the provisions restricting
HAP emissions during paint removal do not apply to the removal of paint
from parts or units normally removed from the plane.
New Source Performance Standards (NSPS). Some facilities subject to
NSPS may be found at airports, including industrial and utility boilers,
vehicle maintenance facilities, and fuel storage and delivery facilities.
State Implementation Plans (SIPs). SIPs regulate stationary sources, such
as buildings and other permanent installations, and mobile sources, such as
automobiles. Typical airport facilities and activities which may be subject
to stationary source regulations include heating and refrigeration plants;
fueling systems; fuel storage facilities; aircraft maintenance facilities;
deicing; roadways, garages, and parking lots; landside development; building
demolition; and building construction. SIPs may also control mobile sources
such as fleet vehicles and other vehicles using the airport. Airports are large
parking areas for automobiles, trucks, and aircraft. SIPs may have to limit
motor vehicle emissions through "transportation control measures." These
measures are designed to reduce congestion and the number of vehicle miles
Sector Notebook Project
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Air Transportation Industry
Federal Statutes and Regulations
traveled in a region. Measures which affect airports include improved public
transit, measures to encourage uses of buses and other high occupancy
vehicles, mandatory trip reduction, and traffic flow improvements.
Where applicable, SBPs must address the requirements of general air
conformity (40 CFR Part 93). In addition, FAA is required to ensure
compliance with general air conformity requirements for federal airport
actions planned for nonattainment or maintenance areas.
Ozone-Depleting Substances. The amended CAA is phasing out the
production and restricting the use and distribution of ozone-depleting
chemicals. One ozone-depleting chemical widely used in the air
transportation industry for fire suppression is halon. Halon production has
ceased and future purchases must be from recycled stock. For consistency
with these regulations, FAA has revised its policy and no longer requires
halon use during firefighting drills conducted under FAR 121.417 and FAR
135.331 (EEA, 1996).
Additionally, EPA has established requirements for servicing and disposal
of air conditioning and refrigeration equipment containing regulated ozone-
depleting refrigerants. Certified, self-contained recovery equipment must be
available during refrigeration equipment servicing. Additional recordkeeping
and reporting requirements apply for appliance owners/operators and
technicians. Facilities with refrigeration equipment containing ozone-
depleting chemicals must comply with 40 CFR Part 82 (EEA, 1996).
Federal Insecticide, Fungicide, and Rodenticide Act
FEFRA regulations are applicable to air transportation facilities and
operations where herbicides are used to control weeds and brash, or when
pesticides and rodenticides are used for pest control in buildings. Air
transportation operations should only apply herbicides, both general and
restricted use, according to label instructions. Certification is required for
use of restricted use herbicides.
V.C. Pending and Proposed Regulatory Requirements
Clean Water Act
Presently, there are no effluent limitations guidelines specific to the air
transportation industry. Effluent guidelines are currently being developed for
tank interior cleaning, including aircraft cleaning, by the Office of Water.
These guidelines are to be proposed in January 1998 and issued in final by
February 2000 (Contact: Gina Matthews or Jan Goodwin, Office of Water,
(202) 260-6036 and (202) 260-7152, respectively).
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Federal Statutes and Regulations
On January 31, 1997, EPA proposed a package of negotiated amendments,
including deadline extensions, to the effluent guidelines plan set forth in a
1992 Consent Decree. For metal products and machinery industry
guidelines, which are applicable to certain maintenance and refurbishing
activities, the proposed modifications would allow EPA to combine the
current two-phase guideline development process into one streamlined
effluent guideline procedure. The new combined rule is scheduled to be
finalized by December 2002.
The modified consent decree also targets airport deicing operations. The
consent decree allowed EPA to remove deicing discharges from the scope of
the categorical rulemaking, and instead initiate a study of water pollution
problems associated with airport deicing operations and storm water runoff.
Recently issued FAA guidelines on aircraft deicing and the recent EPA storm
water rules are likely to have a significant effect on airport deicing
operations.
In addition, the EPA Office of Water will also work with the Department of
Defense to study deicing operations at military installations. Depending on
the results of this study, guidelines specific to deicing at military installations
may be developed.
EPA's five-year-old baseline general permit for industrial storm water
dischargers expired on September 30, 1997. EPA suggests that industries
covered by the baseline permit should explore their permit options. Most
State five-year industrial permits expired along with the EPA Baseline
General Permit on September 30, 1997. Most permits contain a provision
stating that the expired permit remains effective and enforceable until
replaced. However, the permits also contain a provision requiring permittees
to'submit a new Notice of Intent (NOI) prior to permit expiration to remain
covered. Once an airport is without a permit, it generally cannot reapply for
coverage under the expired permit.
Emergency Planning and Community Right-to-Know Act
Under EPCRA 313, Toxic Release Inventory (TRI) reporting is required by
manufacturing and certain other facilities. Air transportation facilities are
currently not subject to TRI reporting requirements. EPA recently expanded
the TRI program and did not include airports (62 FR 23834), however, they
may be added in the future.
Clean Air Act
EPA has completed its final amendments to the Aerospace NESHAP under
the CAA which will be implemented September 1, 1998. The Aerospace
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Federal Statutes and Regulations
NESHAP establishes work practice, equipment, and pollution control
standards for maintenance procedures.
EPA will issue its final Control Techniques Guidelines document for the
aerospace industry addressing reasonably available control technology
(RACT) for volatile organic compounds (VOC) emissions, which will
address the maintenance issues discussed in the document.
EPA's Clean Air Technology Center, at (919) 541-0800, provides general
assistance and information on CAA standards. In addition, the Clean Air
Technology Center' s website includes recent CAA rules and EPA guidance
documents (www.epa.gov/ttn then select Directory and then CATC).
Sector Notebook Project
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Compliance and Enforcement History
VI. COMPLIANCE AND ENFORCEMENT HISTORY
Background
Until recently, EPA has focused much of its attention on measuring
compliance with specific environmental statutes. This approach allows the
Agency to track compliance with the Clean Air Act, the Resource
Conservation and Recovery Act, the Clean Water Act, and other
environmental statutes. Within the last several years, the Agency has begun
to supplement single-media compliance indicators with facility-specific,
multimedia indicators of compliance. In doing so, EPA is in a better position
to track compliance with all statutes at the facility level, and within specific
industrial sectors.
A major step in building the capacity to compile multimedia data for
industrial sectors was the creation of EPA's Integrated Data for Enforcement
Analysis (IDEA) system. IDEA has the capacity to "read into" the Agency's
single-media databases, .extract compliance records, and match the records
to individual facilities. The IDEA system can match Air, Water, Waste,
Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
facility, and generate a list of historical permit, inspection, and enforcement
activity. IDEA also has the capability to analyze data by geographic area and
corporate holder. As the capacity to generate multimedia compliance data
improves, EPA will make available more in-depth compliance and
enforcement information. Additionally, sector-specific measures of success
for compliance assistance efforts are under development.
Compliance and Enforcement Profile Description
Using inspection, violation and enforcement data from the IDEA system, this
section provides information regarding the historical compliance and
enforcement activity of this sector. With this decision, the selection criteria
are consistent across sectors with certain exceptions. For the sectors that do
not normally report to the TRI program, data have been provided from EPA's
Facility Indexing System (FINDS) which tracks facilities in all media
databases. Please note, in this section, EPA does not attempt to define the
actual number of facilities that fall within each sector. Instead, the section
portrays the records of a subset of facilities within the sector that are well
defined within EPA databases.
As a check on the relative size of the full sector universe, most notebooks
contain an estimated number of facilities within the sector according to the
Bureau of Census (see Section II). With sectors dominated by small
businesses, such as metal finishers and printers, the reporting universe within
the EPA databases may be small in comparison to Census data. However,
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Compliance and Enforcement History
the group selected for inclusion in this data analysis section should be
consistent with this sector's general make-up.
Following this introduction is a list defining each data column presented
within this section. These values represent a retrospective summary of
inspections and enforcement actions, and reflect solely EPA, State, and local
compliance assurance activities that have been entered into EPA databases.
To identify any changes in trends, the EPA ran two data queries, one for the
past five calendar years (April 1, 1992 to March 31, 1997) and the other for
the most recent twelve-month period (April 1, 1996 to March 31, 1997). The
five-year analysis gives an average level of activity for that period for
comparison to the more recent activity.
Because most inspections focus on single-media requirements, the data
queries presented in this section are taken from single media databases.
These databases do not provide data on whether inspections are state/local or
EPA-led. However, the table breaking down the universe of violations does
give the reader a crude measurement of the EPA's and States' efforts within
each media program. The presented data illustrate the variations across EPA
Regions for certain sectors.5 This variation may be attributable to state/local
data entry variations, specific geographic concentrations, proximity to
population centers, sensitive ecosystems, highly toxic chemicals used in
production, or historical noncompliance. Hence, the exhibited data do not
rank regional performance or necessarily reflect which regions may have the
most compliance problems.
Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) - this system assigns a common facility
number to EPA single-media permit records. The FINDS identification
number allows EPA to compile and review all permit, compliance,
enforcement and pollutant release data for any given regulated facility.
Integrated Data for Enforcement Analysis (IDEA) - is a data integration
system that can retrieve information from the major EPA program office
databases. IDEA uses the FINDS identification number to link separate data
records from EPA's databases. This allows retrieval of records from across
media or statutes for any given facility, thus creating a "master list" of
5 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD,
PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, MM, OK, TX);
VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK,
ID, OR, WA).
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Air Transportation Industry
Compliance and Enforcement His tory
records for that facility. Some of the data systems accessible through IDEA
are: AIRS (Air Facility Indexing and Retrieval System, Office of Air and
Radiation), PCS (Permit Compliance System, Office of Water), RCRIS
(Resource Conservation and Recovery Information System, Office of Solid
Waste), NCDB (National Compliance Data Base, Office of Prevention,
Pesticides, and Toxic Substances), CERCLIS (Comprehensive
Environmental and Liability Information System, Superfund), and TRIS
(Toxic Release Inventory System). IDEA also contains information from
outside sources such as Dun and Bradstreet and the Occupational Safety and
Health Administration (OSHA). Most data queries displayed in notebook
sections IV and YE were conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search - are based on the universe of TRI reporters within the
listed SIC code range. For industries not covered under TRI reporting
requirements (metal mining, nonmetallic mineral mining, electric power
generation, ground transportation, water transportation, and dry cleaning), or
industries in which only a very small fraction of facilities report to TRI (e.g.,
printing), the notebook uses the FINDS universe for executing data queries'
The SIC code range selected for each search is defined by each notebook's
selected SIC code coverage described in Section H
Facilities Inspected - indicates the level of EPA and state agency
inspections for the facilities in this data search. These values show what
percentage of the facility universe is inspected in a one-year or five-year
period.
Number of Inspections - measures the total number of inspections
conducted in this sector. An inspection event is counted each time it is
entered into a single media database.
Average Time Between Inspections - provides an average length of time,
expressed in months, between compliance inspections at a facility within the
defined universe.
Facilities with One or More Enforcement Actions - expresses the number
of facilities that were the subject of at least one enforcement action within the
defined time period. This category is broken down further into federal and
state actions. Data are obtained for administrative, civil/judicial, and
criminal enforcement actions. Administrative actions include Notices of
Violation (NOVs). A facility with multiple enforcement actions is only
counted once in this column, e.g., a facility with 3 enforcement actions
counts as 1 facility.
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Air Transportation Industry
Compliance and Enforcement History
Total Enforcement Actions - describes the total number of enforcement
actions identified for an industrial sector across all environmental statutes.
A facility with multiple enforcement actions is counted multiple times, e.g.,
a facility with 3 enforcement actions counts as 3.
State Lead Actions -- shows what percentage of the total enforcement
actions are taken by state and local environmental agencies. Varying levels
of use by states of EPA data systems may limit the volume of actions
recorded as state enforcement activity. Some states extensively report
enforcement activities into EPA data systems, while other states may use
their own data systems.
Federal Lead Actions - shows what percentage of the total enforcement
actions are taken by the United States Environmental Protection Agency.
This value includes referrals from state agencies. Many of these actions
result from coordinated or joint state/federal efforts.
Enforcement to Inspection Rate - is a ratio of enforcement actions to
inspections, and is presented for comparative purposes only. This ratio is a
rough indicator of the relationship between inspections and enforcement. It
relates the number of enforcement actions and the number of inspections that
occurred within the one-year or five-year period. This ratio includes the
inspections and enforcement actions reported under the Clean Water Act
(CWA), the Clean Air Act (CAA) and the Resource Conservation and
Recovery Act (RCRA). Inspections and actions from the TSCA/FIFRA/
EPCRA database are not factored into this ratio because most of the actions
taken under these programs are not the result of facility inspections. Also,
this ratio does not account for enforcement actions arising from non-
inspection compliance monitoring activities (e.g., self-reported water
discharges) that can result in enforcement action within the CAA, CWA, and
RCRA.
Facilities with One or More Violations Identified - indicates the
percentage of inspected facilities having a violation identified in one of the
following data categories: In Violation or Significant Violation Status
(CAA); Reportable Noncompliance, Current Year Noncompliance,
Significant Noncompliance (CWA); Noncompliance and Significant
Noncompliance (FIFRA, TSCA, and EPCRA); and Unresolved Violation and
Unresolved High Priority Violation (RCRA). The values presented for this
column reflect the extent of noncompliance within the measured time frame,
but do not distinguish between the severity of the noncompliance.
Violation status may be a precursor to an enforcement action, but does not
necessarily indicate that an enforcement action will occur.
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Air Transportation Industry
Compliance and Enforcement History
Media Breakdown of Enforcement Actions and Inspections -- four
columns identify the proportion of total inspections and enforcement actions
within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
column is a percentage of either the "Total Inspections" or the "Total
Actions" column.
VI.A. Air Transportation Industry Compliance History
Exhibit 13 provides an overview of the reported compliance and enforcement.
data for the air transportation industry over the past five years (April 1992 to
April 1997). These data are also broken out by EPA Regions thereby
permitting geographical comparisons. A few points evident from the data are
listed below.
As shown, there were 444 facilities identified through IDEA with air
transportation SIC codes. Of these, 52 percent (231) were inspected in the
last 5 years.
Over the 5 years, 973 inspections were conducted at those 231
facilities. On average, each facility was inspected between 4 and 5
times, or about once a year.
The 973 inspections resulted in 48 facilities having enforcement
actions taken against them. At those 48 facilities, there were a total
of 97 enforcement actions, meaning each facility averaged
approximately 2 enforcement actions over the past 5 years.
The. average enforcement to inspection rate is 0.10. This average rate
means that for every 10 inspections conducted, there is 1 resulting
enforcement action taken. Across the regions, this rate ranged from
0.03 to 0.30.
Sector Notebook Project
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Air Transportation Industry
Compliance and Enforcement History
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February 1998
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Air Transportation Industry
Compliance and Enforcement History
VLB. Comparison of Enforcement Activity Between Selected Industries
Exhibits 14 and 15 allow the compliance history of the air transportation
sector to be compared to the other industries covered by the industry sector
notebooks. Comparisons between Exhibits 14 and 15 permit the
identification of trends in compliance and enforcement records of the various
industries by comparing data covering the last five years (April 1992 to April
1997) to that of the past year (April 1996 to April 1997). Some points
evident from the data are listed below.
Overall, the air transportation sector enforcement numbers are mostly
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As shown in Exhibit 14, the air transportation enforcement-to-
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shown in Exhibit 15, the air transportation enforcement-to-inspection
rate is 0.08.
Exhibits 16 and 17 provide a more in-depth comparison between the air
transportation industry and other sectors by breaking out the compliance and
enforcement data by environmental statute. As in the previous exhibits, the
data cover the last five years (Exhibit 16) and the last year (Exhibit 17) to
facilitate the identification of recent trends. A few points evident from the
data are listed below.
As shown, over the past 5 years, nearly half of all inspections
conducted and resulting in enforcement actions at air transportation
facilities have been under RCRA.
Over the past year, while RCRA accounted for more than half of all
inspections, only 25 percent of the enforcement actions were under
RCRA.
Sector Notebook Project
73
February 1998
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Compliance and Enforcement History
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14
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Air Transportation Industry-
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Compliance and Enforcement History
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Air Transportation Industry
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Compliance and Enforcement History
VI.C. Review of Major Cases/Supplemental Environmental Projects
This section provides summary information about major cases that have
affected this sector, and a list of Supplemental Environmental Projects
(SEPs).
VI.C.l. Review of Major Cases
As shown in the previous tables, there have been only 97 enforcement actions
taken against air transportation industries over the past 5 years. Stemming
from those 97 actions are at least 34 cases, some of which are discussed in
more detail below. The 34 cases can be categorized as follows:
1 Clean Air Act case (new source performance standards)
2 Clean Water Act cases (pretreatment and NPDES permit violations)
21 RCRA (USTs, unpermitted storage units, etc.)
5 CERCLA
4 TSCA (PCBs)
1 EPCRA (release reporting).
Of these 34 cases, 16 were against federal facilities and 2 were criminal
cases. Supplemental environmental projects were negotiated in 3 of the
cases. (These are discussed in more detail in the following section.) The
following cases are examples of EPA's enforcement against air transportation
industries.
Pacific Southwest Airmotive, Inc. (PSA) owned and operated a jet
engine overhaul facility in San Diego, California. EPA brought an
enforcement action against PSA (and ultimately its new owner U.S.
Air) under the Clean Water Act for violations of the pretreatment
standard for metal finishing operations. During operations, PSA
discharged an average of 73,000 gallons per day of regulated
industrial wastewater through the sewers to San Diego's Point Loma
wastewater treatment plant. The court entered a civil consent decree
in which U.S. Air agreed to pay $335,000 in civil penalties.
Grumman St. Augustine Corporation strips, paints, and refurbishes
aircraft at its St. Augustine, Florida, facility. EPA brought an
enforcement action against Grumman in 1991 as part of the RCRA
Land Disposal Restrictions Initiative. A consent decree in 1993
settled the enforcement action. The decree calls for a civil penalty of
$2.5 million, of which Grumman will initially pay $1.5 million in
cash. The penalty would be reduced by $1 million if Grumman
completed several innovative pollution prevention projects.
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The pollution prevention provisions would substantially reduce or eliminate
several highly toxic waste streams, including a paint stripper, methylene
chloride, and ozone-depleting chemicals (e.g., CFCs). EPA estimated that
up to 240,000 pounds of hazardous emissions per year will be eliminated and
toxic sludge will be reduced if Grumman complied. with RCRA.
Furthermore, if compliance with RCRA is achieved, approximately 2.4
million gallons of potable water will be conserved.
As a result of an imminent and substantial endangerment situation,
EPA issued Reese Air Force Base -in Lubbock, Texas, an
.administrative order under RCRA'Section 7003. In March 1993,
EPA, learned that Reese had detected trichloroethylene above safe
drinking water standards in some privately-owned drinking water
wells near the base. After confirming the data, EPA issued the
administrative order. The order requires the base to conduct the
following activities:
(1) Collect samples from wells in a 36-square-mile area (within
a 2-mile perimeter of the base) to determine the extent of the
contamination
(2)' Notify the owners of any contamination
(3) Supply an alternate source of drinking water to the residents
with contaminated wells
(4) Monitor the ground water in and adjacent to the plume.
Reese has completed the initial sampling of about 950 wells,
provided carbon filters for all the impacted water wells, and
connected some of the users to the City of Lubbock's water system.
The city is in the process of connecting its water lines to the residents
that live within the city limits. The residents living outside the city
limits may use the water from the wells after it has been carbon
filtered.
Region n conducted a major consolidated multimedia inspection of
Kennedy International Airport in New York City, which is operated
by the Port Authority of New York and New Jersey. A number of
violations were documented, both at facilities operated by the Port
Authority itself, as well as at some facilities operated by airline or
service companies. In 1993 a complaint was issued to the Port
Authority citing it for TSCA violations and proposing a penalty of
$289,000. On June 28, 1994,,Region H issued three additional
administrative complaints to Ogden Aviation Services, Inc., citing
that company for violations of the federal underground storage tank
regulations, and proposing penalties totaling $109,125.
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VI.C.2. Supplementary Environmental Projects (SEPs)
SEPs are compliance agreements that reduce a facility's non-compliance
penalty in return for an environmental project that exceeds the value of the
reduction. Often, these projects fund pollution prevention activities that can
reduce the future pollutant loadings of a facility. Information on SEP cases
can be accessed via the Internet at EPA's Enviro$en$e website:
http://es.inel.gov/sep.
The following are examples of three SEPs negotiated with air transportation
facilities.
In response to violations of EPCRA Section 304 and CERCLA
Section 103 at the Memphis/Shelby County Airport (Tennessee), the
County Airport Authority agreed to implement a $475,000 pollution
prevention SEP. The SEP involves the purchase of equipment that
will assist in the deicing of runways. The use of this equipment will
reduce the amount of deicing fluid required, which results in a
substantial reduction in the use of ethylene glycol. In addition, the
Authority agreed to pay a $9,000 penalty to resolve its past violations.
EPA achieved a comprehensive settlement of a TSCA administrative
complaint against the Port Authority of New York and New Jersey,
which is a joint State agency that operates Kennedy and LaGuardia
Airports in New York City. The Region had cited the Authority for
multiple violations of PCB regulations at the airports. The
settlement provides that the port authority will pay a civil penalty of
$19,500 and conduct two SEPs. One SEP consists of a 3-year
fluorescent bulb recycling program for all Port Authority facilities in
the New York metropolitan area. The total cost to implement the
SEP is $130,000. The second SEP is a storm water management
training program that will be conducted at the airports over a 2-year
period. This SEP will cost $90,000.
American Airlines, Inc. was charged with violations of the RCRA
land disposal restrictions for discharging degreasing solvents, which
are hazardous waste, into their onsite injection wells. A consent
order was filed against American Airlines, in which it agreed to pay
a cash penalty of $20,000, take affirmative actions to prevent further
injection of restricted wastes, and conduct a SEP in the amount of
$385,235. The SEP reduces chrome wastes by subjecting them to a
chrome waste recovery system. The system reduces the waste by 98
percent or, in this case, 6,969 pounds per year. In addition, this
system results in the elimination of 26 million gallons of wastewater
annually into injection wells.
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VII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector and
public agencies to voluntarily improve the sector's environmental
performance. These activities include those initiated independently by
industrial trade associations. In this section, the notebook also contains a
listing and description of national and regional trade associations.
VILA. Sector-Related Environmental Programs and Activities
VII.A.1. EPA Voluntary Programs
Environmental Leadership Program
The Environmental Leadership Program (ELP) is a national initiative
developed by EPA that focuses on improving environmental performance,.
encouraging voluntary compliance, and building working relationships with
stakeholders. EPA initiated a one year pilot program in 1995 by selecting
12 projects at industrial facilities and federal installations that demonstrate
the principles of the ELP program. These principles include: environmental
management systems, multimedia compliance assurance, third-party
verification of compliance, public measures of accountability, pollution
prevention, community involvement, and mentor programs. In return for
participating, pilot participants-received public recognition and were given
a period of time to correct any violations discovered during these
experimental projects.
'. EPA is making plans to launch its full-scale Environmental Leadership
Program in 1998. The full-scale program will be facility-based with a 6-year
participation cycle. Facilities that meet certain requirements will be eligible
to participate, such as having a community outreach/employee involvement
programs and an environmental management system (EMS) in place for 2
. years. (Contact: http://es.inel.gov/elp or Debby Thomas, ELP Deputy
Director, at (202) 564-5041)
Project XL
Project XL was initiated in March 1995 as a part of President Clinton's
Reinventing Environmental Regulation initiative. The projects seek to
achieve cost effective environmental benefits by providing participants
regulatory flexibility on the condition that they produce greater
environmental benefits. EPA and program participants will negotiate and
sign a Final Project Agreement, detailing specific environmental objectives
that the regulated entity shall satisfy. EPA will provide regulatory flexibility
as an incentive for the participants' superior environmental performance.
Participants are encouraged to seek stakeholder support from local
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governments, businesses, and environmental groups. EPA hopes to
implement fifty pilot projects in four categories, including industrial
facilities, communities, and government facilities regulated by EPA.
Applications will be accepted on a rolling basis. For additional information
regarding XL projects, including application procedures and criteria, see the
April 23, 1997 Federal Register Notice. (Contact: Fax-on-Demand Hotline
(202) 260-8590, Web: http://www.epa.gov/ProjectXL, or Christopher
Knopes at EPA's Office of Policy, Planning and Evaluation at (202) 260-
9298.)
Climate Wise Program
EPA's ENERGY STAR Buildings Program is a voluntary, profit-based program
designed to improve the energy-efficiency in commercial and industrial
buildings. Expanding the successful Green Lights Program, ENERGY STAR
Buildings was launched in 1995. This program relies on a 5-stage strategy
designed to maximize energy savings thereby lowering energy bills,
improving occupant comfort, and preventing pollutionall at the same time.
If implemented in every commercial and industrial building in the United
States, ENERGY STAR Buildings could cut the nation's energy bill by up to
$25 billion and prevent up to 35% of carbon dioxide emissions. (This is
equivalent to taking 60 million cars of the road). ENERGY STAR Buildings
participants include corporations; small and medium sized businesses; local,
federal and state governments; non-profit groups; schools; universities; and
health care facilities. EPA provides technical and non-technical support
including software, workshops, manuals, communication tools, and an
information hotline. EPA's Office of Air and Radiation manages the
operation of the ENERGY STAR Buildings Program. (Contact: Green
Light/Energy Star Hotline at 1-888-STAR-YES or Maria Tikoff Vargas, EPA
Program Director at (202) 233-9178 or visit the ENERGY STAR Buildings
Program website at http://www.epa.gov/appdstar/buildings/)
Green Lights Program
EPA's Green Lights program was initiated in 1991 and has the goal of
preventing pollution by encouraging U.S. institutions to use energy-efficient
lighting technologies. The program saves money for businesses and
organizations and creates a cleaner environment by reducing pollutants
released into the atmosphere. The program has over 2,345 participants which
include major corporations, small and medium sized businesses, federal, state
and local governments, non-profit groups, schools, universities, and health
care facilities. Each participant is required to survey their facilities and
upgrade lighting wherever it is profitable. As of March 1997, participants
had lowered their electric bills by $289 million annually. EPA provides
technical assistance to the participants through a decision support software
package, workshops and manuals, and an information hotline. EPA's Office
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of Air and Radiation is responsible for operating the Green Lights Program.
(Contact: Green Light/Energy Star Hotline at 1-888-STAR-YES or Maria
Tikoff Vargar, EPA Program Director, at (202) 233-9178.)
Waste Wi$e Program
The WasteWi$e Program was started in 1994 by EPA's Office of Solid
Waste and Emergency Response. The program is aimed at reducing
municipal solid wastes by promoting waste prevention, recycling collection
and the manufacturing and purchase of recycled products. As of 1997, the
program had about 500 companies as members, one third of whom are
Fortune 1000 corporations. Members agree to identify and implement
actions to reduce their solid wastes setting waste reduction goals and
providing EPA with yearly progress reports. To member companies, EPA,
in turn, provides technical assistance, publications, networking opportunities,
and national and regional recognition. (Contact: WasteWi$e Hotline at 1-
800-372-9473 or Joanne Oxley, EPA Program Manager, (703) 308-0199.)
NICE3
The U.S. Department of Energy is administering a grant program called The
National Industrial Competitiveness through Energy, Environment, and
Economics (NICE3). By providing grants of up to 45 percent of the total
project cost, the program encourages industry to reduce industrial waste at its
source and become more energy-efficient and cost-competitive through waste
minimization efforts. Grants are used by industry to design, test, and
demonstrate new processes and/or equipment with the potential to reduce
pollution and increase energy efficiency. The program is open to all
industries; however, priority is given to proposals from participants in the
forest products, chemicals, petroleum refining, steel, aluminum, metal casting
and glass manufacturing sectors. (Contact: Chris Sifri, DOE at
(303) 275-4723 or Eric Hass, DOE at (303) 275-4728 or
http//www.oit.doe.gov/access/nice3.)
Design for the Environment (DfE)
DfE is working with several industries to identify cost-effective pollution
prevention strategies that reduce risks to workers and the environment. DfE
helps businesses compare and evaluate the performance, cost, pollution
prevention benefits, and human health and environmental risks associated
with existing and alternative technologies. The goal of these projects is to
encourage businesses to consider and use cleaner products, processes, and
technologies. For more information about the DfE Program, call (202) 260-
1678. To obtain copies of DfE materials or for general information about
DfE, contact EPA's Pollution Prevention Information Clearinghouse at (202)
260-1023 or visit the DfE Website at http://es.inel.gov/dfe.
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VII.A.2. Trade Association/Industry Sponsored Activity
Industry Working Group on Deicing
ISO 14000
A deicing working group was formed by the American Association of Airport
Executives and the Airports Council International - North America to (1)
study the use of deicing chemicals on aircraft; (2) study the feasibility of
locating deicing facilities away from airport gates; and (3) provide
information to both industry members and the federal government on ways
in which deicing operations can be improved upon. As part of their
investigation, the working group sent out surveys to the major airports to
determine which deicing procedures and chemicals are being used by the
industry. Some of the survey questions relate to environmental effects of
deicing and recoveiy, reuse, and recycling of waste deicer. The results of the
survey indicated that a number of air carriers are using alternative chemicals,
and have constructed remote deicing facilities with deicer recovery systems.
(Contact: Carter Morris, American Association of Airport Executives, (703)
824-0500.)
ISO 14000 is a series of internationally-accepted standards for environmental
management. The series includes standards for environmental management
systems (EMS), guidelines on conducting EMS audits, standards for auditor
qualifications, and standards and guidance for conducting product lifecycle
analysis. Standards for auditing and EMS were adopted in September 1996,
while other elements of the ISO 14000 series are currently in draft form.
While regulations and levels of environmental control vary from country to
country, ISO 14000 attempts to provide a common standard for
environmental management. The governing body for ISO 14000 is the
International Organization for Standardization (ISO), a worldwide federation
of 110+ country members based in Geneva, Switzerland. The American
National Standards Institute (ANSI) is the United States representative to
ISO.
VII.B. Summary of Trade Associations
American Association of Airport Executives
4212 King Street
Alexandria, VA 22302
Phone:(703)824-0500
Fax: (703) 820-1395
The American Association of Airport Executives (AAAE) is comprised of
airport management personnel and representatives of companies serving the
civil airport industry. The AAAE sponsors educational seminars, conducts
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examinations, and maintains a speakers' bureau. AAAE has an
Environmental Service/Environmental Affairs Committee that provides
assistance on complying with environmental regulations (e.g., regulation
interpretations, training seminars, and manuals). Environmental compliance
assistance is focused on the storm water rules. Publications are the bimonthly
Airport Executive Magazine and the Airport Report Newsletter. Separate
yearly conferences are held on topics such as national airports, legislative
issues (semiannual), international facilities, and general annual issues.
Airports Association Council International
1220 19th Street NW, Suite 200
Washington, B.C. 20036
Phone: (202) 293-8500
Fax:(202)331-1362
The Airports Association Council International (AACI) is comprised of
operators of public airport facilities. The group also includes government
bodies that own and operate major airports. The association provides
compliance assistance to members through seminars, meetings, conferences,
regulation interpretations, and manuals. One day conferences are frequently
held on environmental management and auditing techniques. Committees
include planning and environmental, safety and security, and U.S.
government affairs. Publications are the weekly Airport Highlights, the
annual Worldwide Airport Traffic Report, and the Airport Environmental
Management Handbook. The AACI holds an annual meeting in September
or October.
National Air Transportation Association
4226 King Street
Alexandria, VA 22302
Phone: (703) 845-9000
Fax: (703) 845-8176
The National Air Transportation Association (NATA) represents the interests
of aviation services companies such as fixed-based operators and on-demand
air taxis. NATA provides compliance assistance to members in the form of
guidelines, explanations of regulations, and seminars. Most of NATA's work
relates to Federal Aviation Administration regulations; however,
environmental services are also provided. Environmental aspects of deicing
and aircraft cleaning are not a major focus, because the membership does not
include the carrier companies, however, some fixed-based operators carry out
deicing operations: Publications include an annual membership directory, an
annual report, and the monthly ATAnews.
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Airports Council International - North America.
1775 K Street, NW Suite 500
Washington, D.C. 20006
Phone: (202) 293-8500
Fax:(202)331-1362
Airports Council International - North America (ACI-NA) is the "voice of
airports" representing local, regional, state, and national governing bodies
that own and operate commercial airports in the U.S. ACI-NA member
airports enplane more the 90 percent of the domestic and virtually all of
the international airliner passenger and cargo traffic in North America.
Aerospace Industries Association
1250 Eye Street, NW
Washington, D.C. 20005
Phone: (202) 371-8400
Member companies of Aerospace Industries Association (AIA) represent
the primary manufacturers of military and large commercial aircraft,
engines, accessories, rockets, spacecraft, and related items.
General Aviation Manufacturers Association
1400 K Street, NW Suite 801
Washington, D.C. 20005
Phone: (202) 393-1500
The General Aviation Manufacturers Association (GAMA) is a national
trade association, headquartered in Washington, D.C., representing 53
manufacturers of fixed-wing aircraft, engines, avionics, and components.
In addition to building nearly all U.S. general aviation aircraft, GAMA
member companies also operate aircraft fleets, airport fixed-based
operations, pilot schools, and training facilities.
Air Transport Association of America
1709 New York Ave., NW
Washington, D.C. 20006
Phone: (202) 626-4000
Fax:(202)626-4181,
The Air Transport Association of America (ATA) represents 22 major
scheduled airlines in the U.S. engaged in transporting persons, goods, or
mail by aircraft. ATA serves its membership by providing aviation safety,
advocating industry positions, conducting designated industry-wide
programs and monitoring public understanding. ATA publishes annually
Air Transport as well as fact sheets, press releases, studies, speeches, and
references pertaining to air transport. The ATA holds quarterly meetings.
v
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Air Line Pilots Association
535 Herndon Parkway
P.O. Box 1169
Herndon, VA 20170
Phone:(703)689-2270
Fax:(703)689-4370
The Air Line Pilots Association (ALPA) is a union representing 46,000
airline pilots at 45 U.S. airlines. ALP A provides lobbying of airline pilot
views to Congress and government agencies, and devotes approximately
20 percent of its dues income to support aviation safety.
Regional Airline Association
1200 19th Street, N.W. Suite 300
Washington, D.C. 20036
Phone:(202)857-1170
Fax: (202)429-5113
The Regional Airline Association (RAA) represents regional air carriers
and suppliers of products and services that support the industry before the
Congress, Federal Aviation Administration, Department of Transportation
and other federal and state agencies. RAA member airlines transport
between 90-95 percent of all regional airline passengers. RAA developed
an Environmental Compliance Handbook addressing compliance issues.
Aircraft Owners & Pilots Association
421 Aviation Way
Frederick, MD 21701
Phone: (301) 695-2000
With oyer 270,000 members, the Aircraft Owners & Pilots Association
(AOPA) represents the interests of general aviation pilots. It provides
insurance plans, flight planning, and other services, and sponsors large fly-
in meetings.
Helicopter Association International
1619 Duke Street
Alexandria, VA 22314
Phone: (703) 683-4646
Fax: (703) 683-4745
The members of Helicopter Association International (HAI) represent
rotocraft operators and manufacturers.
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National Association of State Aviation Officials
8401 Colesville Road, Suite 505
Silver Spring, MD 20910
Phone: (301) 588-0587
Fax: (301) 585-1803
The National Association of State Aviation Officials (NAS AO) represents
departments of transportation and state aviation departments and
commissions from 49 states, Puerto Rico, and Guam.
National Business Aircraft Association
1200 18th Street, NW, Room 200
Washington, D.C. 20036
Phone: (202) 783-9000
The National Business Aircraft Association (NBAA) represents 361
companies that own and operate aircraft flown for corporate purposes.
NBAA is affiliated with the International Business Aircraft Council.
Flight Safety Foundation
2200 Wilson Boulevard
Arlington, VA 22201
Phone: (703) 739-6700
Fax: (703) 739-6708
The Flight.Safety Foundation (FSF) promotes air transport safety. Its
members include airport and airline executives and consultants.
Experimental Aircraft Association
EAA Aviation Center
Oshkosh, WI54903
Phone: (414) 426-4800
The Experimental Aircraft Association (EAA), with over 700 local
chapters, promotes the interests of home-built and sport aircraft owners.
Aviation Distributors & Manufacturers Association
1900 Arch Street
Philadelphia, PA 19103
Phone:(215)564-3484
Fax: (215) 564-3484
The Aviation Distributors & Manufacturers Association (ADMA)
represents the interests of a wide variety of aviation firms including FBOs
and component parts manufacturers.
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International Air Transport Association
2000 Peel Street
Montreal, PQ, Canada H3A2R4
Phone:(514)844-6311
Fax:(514)844-5286
The International Air Transport Association (IATA) is an association of
105 international air carriers whose main functions include coordination of
fares and operations.
Cargo Airline Association
1220 19th Street, N.W. Suite 400
Washington, D.C. 20036
Phone: (202) 293-1030
Fax: (202) 293-4377
The Cargo Airline Association (CAA) is a nationwide trade organization
with members made up of all segments of the air cargo community. The
Association is responsible for promoting the use of air freight services;
monitoring regulatory activity; representing the industry before Congress,
various agencies, and courts; providing educational programs; and keeping
members up-to-date on all issues affecting air cargo.
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References/B ibliography
Environmental Research Brief - Pollution Prevention Assessment of Manufacturing of Aircraft
Landing Gear. Office of Research and Development, EPA 600-S-95/032, August 1995.
Program Summary - Parts Washing Alternatives Study, U.S. Coast Guard, Office of Research
and Development. EPA-600-SR-95/006, February 1995.
Demonstration of Alternative Cleaning Systems, Office of Research and Development,
EPA/600/R-95-120, August 1995.
Airline Fuel Consumption, The Boeing Company, 1997.
Section V: Summary of Applicable Federal Statutes and Regulations
Environmental Regulatory Compliance Handbook. Prepared for Regional Airline Association,
Prepared by Energy and Environmental Analyses, Inc., 1996.
Overview of the Storm Water Program, Office of Water, U.S. Environmental Protection Agency,
June 1996. EPA 833-R-96-008.
New Technology Plays Key Role in Deicing Gear, Aviation Week & Space Technology, January
9, 1995, pp. 40-41.
Airports and the Environment: A Study of Air Transport. Stratford, A.H.
Flyi?ig Off Course: Environmental Impacts of America's Airports, Natural Resources Defense
Council, October 1996.
Section VII; Compliance Activities and Initiatives
Enforcement Accomplishments Report, FY 1992, U.S. EPA, Office of Enforcement (EPA/230-
R93-001), April 1993.
Enforcement Accomplishments Report, FY 1993, U.S. EPA, Office of Enforcement (EPA/300-
R94-003), April 1994.
Enforcement Accomplishments Report, FY 1994, U.S. EPA, Office of Enforcement (EPA/300-
R95-004), May 1995.
Enforcement Accomplishments Report, FY 1995, U.S. EPA, Office of Enforcement (EPA/300-
R96-006), July 1996.
Enforcement Accomplishments Report, FY 1996, U.S. EPA, Office of Enforcement (EPA/300-
R97-003), May 1997.
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APPENDIX A
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This Notebook is available on the Internet through the World Wide Web. The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental-
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ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB
To access this Notebook through the Enviro$en$e World Wide Web, set your World Wide Web
Browser to the following address:
http://es.epa.gov/sector/index.html
or use
WWW.epa.gOV/OeCa - then select the button labeled Industry and Gov't
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Direct technical questions to the Feedback function at the bottom of the web page or call Shhonn
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Appendix A
*U.S. GOVERNMENT PRINTING OFFICE: 1998-618-895X906S5
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