United States
                 Environmental Protection
                 Agency
Office of Water
(4606)
EPA816-F-02-018
August 2002
oEPA    Source Water  Protection


                 Practices  Bulletin

                 Managing Aircraft and Airfield

                 Deicing Operations  to  Prevent

                 Contamination of Drinking  Water

                 The Federal Aviation Administration (FAA) requires that aircraft surfaces be deiced and anti-
                 iced to ensure the safety of passengers. However, when performed without prevention
                 measures in place, airport deicing operations can contribute to contamination of ground water
                 and surface water supplies. This bulletin addresses two basic types of deicing/anti-icing
                 operations that take place at airports: the deicing/anti-icing of aircraft, and the deicing/anti-icing
                 of paved areas including runways, taxiways and gate areas.  It also discusses some source
                 water contamination prevention measures available for use at smaller airports. Additional
                 information on deicing of roadways is presented in the bulletin on highway deicing.

                 AIRCRAFT DEICING/ANTI-ICING CHEMICAL USE

                 The most common technique for deicing/anti-icing of aircraft is the application of chemical
                 deicing/anti-icing fluids (ADF), which are composed primarily of ethylene or propylene glycol.
                 Frequently this is achieved using fixed booms or trucks with an operator bucket mounted on a
                 boom. Temperature and weather conditions dictate the required concentration of glycol in ADF,
                 but most operators use fluid with fifty percent glycol concentration by volume.  Deicing/anti-
                 icing fluids also contain additives, including corrosion inhibitors, flame retardants, wetting agents,
                 and thickeners that protect aircraft surfaces  and allow ADF to cling to the aircraft, resulting in
                 longer holdover times (the time between application and takeoff during which ice or snow is
                 prevented from adhering to aircraft surfaces). Limited information is available on the actual
                 chemical compositions of ADF because their formulations are considered trade secrets.

                 Four types  of deicing/anti-icing fluid are used on aircraft, and vary by composition and holdover
                 time.  Type I fluids, which contain glycol and less than one percent additives, are most
                 commonly  used for deicing and have relatively short holdover times. Types II, III, and IV fluids
                 are used for anti-icing protection because
                 they contain higher concentrations of
                 additives (two percent or less) in addition
                 to glycol. Larger airlines use both Type I
                 and Type IV fluids for deicing and anti-
                 icing. Because longer holdover times are
                 not as important  a consideration at smaller
                 airports, smaller airlines typically use Type
                 I  and II fluids, which contain smaller
                 amounts of additives, or no anti-icing fluids
                 at all.

-------
AIRFIELD PAVEMENT DEICING/ANTI-ICING CHEMICAL USE

Ice and snow is cleared from runways, taxiways, roadways, and gate areas using a combination
of mechanical methods (e.g., plows and brushes) and chemical deicing agents. Pavement is
typically cleared with mechanical equipment, then chemically treated to prevent further snow
and ice accumulation.  Chemicals commonly used for deicing/anti-icing include ethylene or
propylene glycol, urea, potassium acetate, sodium acetate, sodium formate, calcium magnesium
acetate (CMA), or an ethylene glycol-based fluid known as UCAR (containing ethylene glycol,
urea, and water).  Sand and salt (sodium or potassium chloride) may also be used, but they can
cause damage to aircraft surfaces and mechanical parts.

WHY IS IT IMPORTANT TO MANAGE RUNOFF OF DEICING FLUID NEAR
THE SOURCES OF YOUR DRINKING WATER?

EPA estimates that 21  million gallons of ADF (50 percent glycol concentration) are discharged
to surface  waters annually from airport deicing operations across the country, and an additional
                                                            2 million gallons  are discharged
                                                            to publicly owned treatment
                                                            works (POTWs).  Unless
                                                            captured for recycling, recovery,
                                                            or treatment, deicing agents will
                                                            run off onto bare or vegetated
                                                            ground where they may travel
                                                            through the soil and enter ground
                                                            water, or run off into streams.
                                                            Unprotected storm water drains
                                                            that discharge to surface water
                                                            or directly to the subsurface
                                                            (i.e., through a dry well) are also
                                                            of concern.

                                                            Ethylene and propylene glycol
can have harmful effects on aquatic life due to their high  biological oxygen demand (BOD).
Depletion  of oxygen, fish kills, and undesirable bacterial  growth in receiving waters may result.
Although pure ethylene and propylene glycols have low aquatic toxicity, ethylene glycol exhibits
toxicity in mammals, including humans (with the potential to cause health problems such as
neurological,  cardiovascular, and gastrointestinal problems, serious birth defects,  and even death
when ingested in large doses). Additionally, ethylene glycol is considered a hazardous air
pollutant (HAP), and is subject to reporting requirements under the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA).

Additives in deicing/anti-icing fluids can be significantly more toxic to  the aquatic environment
than glycols alone. Corrosion inhibitors are highly reactive with  each other and with glycols;
reactions can produce  highly toxic byproducts.  Other additives such as wetting agents, flame
retardants, pH buffers, and dispersing agents also exhibit  high aquatic and mammalian toxicities.
Manufacturers and formulators have attempted to reduce the toxicity of additives present in
their ADF formulations and, when possible, use environmentally benign chemicals.  The Society
for Automotive Engineers (SAE) is currently working to  set an ADF toxicity standard in the
near future.

Sodium chloride, or salt, is applied to paved  surfaces to prevent icing.  (See the bulletin on
highway deicing for more information on deicing paved  surfaces.) Sodium can contribute to
cardiovascular, kidney, and liver diseases,  and has a direct link to high blood pressure.  There is
no MCL or health advisory level for sodium; however, there is a Drinking Water Equivalent
Level of 20 mg/L, a non-enforceable guidance level considered protective against

-------
non-carcinogenic adverse health effects.  Sodium is one of the contaminants EPA is considering
for a regulatory determination.  Chloride, which has a national secondary drinking water
standard of 250 mg/L, adds a salty taste to water and corrodes pipes.

AVAILABLE PREVENTION MEASURES TO ADDRESS AIRCRAFT AND
AIRFIELD DEICING

An overview of several management measures are  described in this section, though they are not
exhaustive. The reference materials below can provide additional resources and information.
Please keep in mind that individual prevention measures may or may not be adequate to prevent
contamination of source waters.  Most likely, individual measures should be combined in an
overall prevention approach that considers the nature of the potential source of contamination,
the purpose, cost, operational, and maintenance requirements of the measures, the vulnerability
of the source water, the public's acceptance of the measures,  and the community's desired
degree of risk reduction.

Alternative Deicing/Anti-Icing Materials

Use alternative airfield deicing products such as potassium acetate, sodium acetate, sodium
formate, potassium formate, or CMA instead of urea or glycol deicers.  These products have
lower toxicities, are readily biodegradable, and have a lower BOD in the environment.  Many of
these products can be applied using the same mechanical spreaders used for urea or spray
booms used for glycol-based fluids.  (See the bulletin on highway deicing for more information
on some of these alternative deicers.)

Reducing Deicing/Anti-Icing Fluid Usage

On Aircraft:

Mechanical deicing technologies eliminate
the need for deicing fluids and reduce the
need for anti-icing fluid. Below are some
examples of newer technology.
«       Boot deicing works by inflating a
        rubber boot located on the leading
        edge of an aircraft wing. When
        inflated, the boot causes ice to
        crack and become dislodged from
        the surface. Passing air blows the
        ice away. This method is used
        primarily on propeller-driven
        aircraft.
•       For small aircraft, infra-red deicing systems use natural-gas-fired radiant heaters
        inside a drive-through hanger. Follow-up chemical deicing or anti-icing is usually
        required to prevent re-freezing.
•       Electrical resistive heating can remove ice from the surface of small to medium sized
        aircraft.  By applying resistive heating to heating mats  located near the skin of an
        aircraft, ice is melted and  is easily dislodged from aircraft surfaces.
•       Hot air blast deicing systems use heated compressed air to blow snow and ice off of
        aircraft wings.  This may be followed by conventional deicing/anti-icing.

The installation of a computerized spraying system to apply deicing chemicals may reduce the
use of deicing/anti-icing fluids. These systems can reduce both the volume of deicing fluid used
and the time needed for deicing, and increase the collection efficiency  of runoff.  These "car-
wash" style systems can be operated by personnel with a minimum of training. This option may
Infra-red radiant heating unit.

-------
be cost-prohibitive for smaller airports, and in some cases, planes may need additional deicing
using traditional means (trucks or fixed booms) to deice engine inlets, undercarriages, or the
underside of aircraft wings.  Deicing fluid sprayed from truck-mounted booms allows more
effective and efficient deicing. The deicer can be sprayed closer to the aircraft surface,
reducing over-spray and wastage.

                                                Using ice detection systems or sensors,
                                                especially on larger aircraft, can reduce and,
                                                in some cases, eliminate application of
                                                deicing fluid.  Because operators and flight
                                                crews often have difficulty detecting ice on
                                                aircraft wings,  aircraft are deiced whenever
                                                ice is suspected to be present.
                                                Magnetostrictive, electromagnetic, and
                                                ultrasonic devices can detect ice on aircraft
                                                surfaces, including areas that are difficult to
                                                inspect visually and in cases where ice build-
                                                up is not apparent.  This allows operators to
more accurately determine when deicing is unnecessary and can decrease the amount of ADF
used at an airport.

Increase storage for multi-strength glycol solutions. Using a technique called "blending to
temperature," operators can vary the concentration of glycol in deicing fluid.  Operators,
particularly at small airports, commonly use a fluid with 50 percent glycol, a concentration that is
formulated for worst-case cold weather conditions. However, concentrations of 30 to 70
percent glycol may be used in different conditions.  Reducing the glycol concentration in deicing
fluid decreases  the amount of glycol in surface runoff and storm water collection systems.

On Pavement Surfaces:

Prevent strong  bonding of ice to pavement surfaces by pre-treating and/or promptly treating
pavement using either mechanical methods or chemicals. Pre-treating pavement with chemicals
such as aqueous potassium acetate prior to the onset of freezing conditions or a storm event can
allow easy removal of snow and ice using sweepers and plows.  The FAA estimates that the
correct application of pavement anti-icing chemicals can reduce the overall quantity of
pavement deicing/anti-icing agents used by 30 to 75 percent.

Use mechanical methods for dry snow removal rather than applying chemicals.

Use the proper amount of pavement deicing/anti-icing chemicals by following
recommendations from the manufacturer,  and properly maintaining spreading equipment.  This
will reduce unnecessary or over-application of chemicals. Avoid applying glycol-based deicers
near storm drains, particularly those that are not routed to a publicly-owned sewage treatment
plant.

Collection and Disposal of Spent Fluid to Reduce Runoff

Centralized deicing pads restrict aircraft deicing to a small area, minimizing the volume and
allowing for the capture of deicing waste.  A deicing pad is specially graded to capture and route
contaminated runoff to tanks. If the pads  are located near gate areas or at  the head of runways,
deicing may be  completed just prior to takeoff; as a result, less Type IV anti-icing fluid may be
necessary for shorter holdover times, reducing the amount of glycols released onto the runway
or into the air.  In addition, fluids  recovered from deicing pads may be suitable for reuse.

-------
Vacuum sweeper trucks collect spent aircraft and airfield deicing fluids as well as any slush or
snow from gate areas, ramps, aircraft parking areas, taxiways, and aircraft holding pads.
Vacuum vehicles  are a cost-effective alternative to installing traditional drainage collection
systems or deicing pads, typically ranging in cost from $200,000 to $400,000 each.  In addition,
the recovered fluid may be suitable for recycling.

Detention basins  or constructed wetlands are open-water ponds that collect ADF runoff from
runways and airport grounds. Basins allow solids to settle, and reduce oxygen demand before
the runoff is discharged to receiving waters. A pump station can discharge metered runoff by
way of an airport storm sewer.  Airports operating these may be required to install liners to
protect ground water and monitoring wells to detect leakage from breached liners. An aeration
system may be required to treat glycol contaminated runoff.  See the storm water bulletin for
more information on runoff controls.

Anaerobic bioremediation systems, in conjunction with sewage treatment plants  or detention
basins, can be an  effective means to dispose of glycol-contaminated runoff.  Bioremediation
systems generally consist of a runoff collection and storage system, an anaerobic bioreactor
treatment system  (one that requires little or no oxygen),  and a gas/heat recovery system.  These
systems can reduce oxygen demand levels sufficiently to permit unrestricted disposal to a
sewage treatment plant.  Additionally, these systems can remove additives from runoff. An
economic benefit to the anaerobic process is that it  converts glycol in runoff to methane gas  that
can be used for heating.

Transport of spent fluid to a sewage treatment plant by way of a sanitary sewer is almost
always the  most economical method of treating deicing fluid, provided that sufficient biological
loading capacity is available at the treatment plant.  However, many sewage treatment plants
will only accept limited quantities of glycol-contaminated runoff; check with the appropriate local
agency to verify applicable regulations. Airport maintenance crews should not assume that
storm drains are routed to a sanitary sewer. They should be knowledgeable  about which drains
or collection systems discharge directly to surface  waters  or to the subsurface, e.g., through a
dry well.

Recycling  and Recovery of Spent Fluid

Recycling of glycol from spent deicing/anti-icing fluid decreases the amount that reaches and
potentially impairs surface and ground waters. The recycling process consists  of several steps
including filtration, reverse osmosis, and distillation to  recover glycol from spent deicing fluid.
Technology is available to recycle fluids containing at least 5 percent glycol. Glycol recycling
reduces the amount and strength of wastewater, reducing wastewater disposal costs. In addition,
the recovered glycol may be sold; the value of recovered glycol depends  on the type of glycol
and its concentration and purity. Recent developments have made on-site recycling successful at
smaller airports; however, the volume of fluid used  at very  small airports  may still be insufficient
to make recycling economically viable at these facilities.

Additional Prevention Measures

Under the National Pollutant Discharge Elimination System (NPDES) Permitting Program,
airports are required to obtain permit coverage for storm water discharges from vehicle
maintenance, equipment cleaning operations, and airport deicing operations. While specific
permit conditions vary from state-to-state, in general, NPDES storm water permits require
airports to develop and implement Storm  Water Pollution Prevention Plans (SWPPPs) that
include the following elements:

-------
•       Description of potential pollutant sources and a site map indicating the locations of
        aircraft and runway deicing/anti-icing operations and identification of any pollutant or
        pollutant parameter of concern.
•       Description of storm water discharge management controls appropriate for each area of
        operation.
•       Consideration of alternatives to glycol- and urea- based deicing/anti-icing chemicals to
        reduce the aggregate amount of deicing chemicals used and/or lessen the environmental
        impact.
•       Evaluation of whether deicing/anti-icing  over-application is occurring and adjustment as
        necessary.
•       Employee training on topics such as spill response, good housekeeping, and material
        management practices for all personnel that work in the deicing/anti-icing area.

Many NPDES storm water permits issued to airports  also require a variety of monitoring
activities to evaluate the effectiveness of storm water controls in preventing deicing/anti-icing
activities from impacting receiving water quality. For example, monitoring requirements for
airport deicing/anti-icing activities in EPA's Multi-Sector General Permit include monthly
inspections of existing storm water controls during the deicing season (weekly if large quantities
of deicing chemicals are being spilled or discharged), quarterly visual monitoring of storm water
discharges, and periodic effluent monitoring for BOD, chemical oxygen demand (COD),
ammonia, and pH (for larger users of deicing/anti-icing chemicals) during storm events.

Storm water that  discharges directly to the subsurface by way of dry wells, drain fields, or any
other type of distribution system is subject to Underground Injection Control (VIC) Flagrant
requirements.  These types of drainage  systems are regulated as Class V injection wells and
operators should contact their state or federal UIC Program authority for information on
applicable regulations.

Employee training is an important tool in reducing contaminated runoff.  Deicing personnel
receive eight hours of FAA-mandated training, but industry sources  state that three years of
experience is required to become adept at aircraft deicing.  Personnel should be trained on
proper application techniques and best  management practices, and be informed of the presence
of any sensitive water areas nearby. Properly trained  personnel will also use less deicing/anti-
icing fluid, saving money and reducing  contamination.

Monitor ground water quality and identify the direction of ground water movement on-site
through the creation of a water table map. Once the direction of ground water flow is known,
annual monitoring up  gradient and down gradient of deicing areas should provide early detection
of deicing fluid contamination and other harmful  impacts.

FOR ADDITIONAL INFORMATION

These sources contain information on airport deicing  practices and facilities and provide
prevention measures to avoid source water contamination.  All of the documents listed are
available for free  on the Internet.

Bremer, Karl. The Double Deicing Dilemma. Airport Magazine.
http://www.airportnet.org/depts/publicat/airmags/am91093/deicing.htm

Bremer, Karl. The Three Rs, Reduce, Recover and Recycle.  Airport Magazine.
http://www.airportnet.org/depts/publicat/AIRMAGS/Am3498/deicing.htm

FAA (2001)  Northwest Mountain Regional Airport Plan 2001.
http://www.nw.faa.gov/airports/Plans/RAP/

-------
FAA (2001) Electronic Aircraft Icing Handbook. Chapter III.
http://www.fire.tc.faa.gov/aar421/eaihbpg.html

FAA  Management of Airport Industrial Waste. Change 1 (1997) and Change 2 (2000)
http: //www.faa. gov/arp/pdf/53 20-151 .pdf
http://www.faa.gov/arp/pdf/5300-142.pdf

Minnesota Pollution Control Agency. (2000) Protecting Water Quality in Urban Areas: Best
Management Practices for Dealing with Storm Water Runoff from Urban, Suburban and
Developing Areas of Minnesota,  http://www.pca.state.mn.us/water/pubs/swm-ch7.pdf

Switzenbaum, Michael S., Shawn Veltman, Theodore Schoenberg, Carmen Durand, Dean
Mericas, and Bryan Wagoner. (1999) Best Management Practices for Airport Deicing
Stormwater. University of Massachusetts Water Resources Research Center.
http: //www. um ass. edu/tei/wrrc/pdf/S witz 173. pdf

USEPA. (1999) Storm Water Technology Fact Sheet: Airplane Deicing Fluid Recovery
Systems. EPA-832-F-99-043, United States Environmental Protection Agency Office of Water,
Washington DC. http://www.epa.gov/owm/mtb/airplnde.pdf

USEPA. (1998) EPA Office of Compliance Sector Notebook Project: Air Transportation
Industry, Sector Notebook Project, EPA/310-R-97-001. http://es.epa.gov/oeca/sector/tfair

USEPA. (2000) Preliminary Data Summary: Airport Deicing Operations (Revised). EPA-821-
R-00-016, United States Environmental Protection Agency Office of Water,  Washington, DC.
http://www.epa.gov/ost/guide/airport/airport.pdf

USEPA. (2001) Contaminant Candidate List Preliminary Regulatory Determination Support
Document for Sodium, EPA 815-R-01-014, United States Environmental Protection Agency,
Office of Water, http://www.epa.gov/safewater/ccl/pdf/sodium final rsd.pdf

USEPA. (No Date) EPA Office of Federal Activities: Pollution Prevention / Environmental
Impact Reduction Checklist for Airports,  http://es.epa.gov/oeca/ofa/pollprev/airport.html

USEPA. (No Date) Shallow Injection Wells (Class V ). Available at
http://www.epa.gov/safewater/uic/classv.html

-------