Glycol Recovery Vehicle Deicer Management Plan Spokane ...

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November 2005 Cascade Earth Sciences 12720 E. Nora Ave, Ste. A Spokane, WA 99216 (509) 921-0290 www.cascade-earth.com Glycol Recovery Vehicle Deicer Management Plan Spokane International Airport Spokane, Washington December 2011

Transcript of Glycol Recovery Vehicle Deicer Management Plan Spokane ...

November 2005

Cascade Earth Sciences12720 E. Nora Ave, Ste. A

Spokane, WA 99216 (509) 921-0290

www.cascade-earth.com

Glycol Recovery Vehicle Deicer Management Plan Spokane International Airport Spokane, Washington

December 2011

Cascade Earth Sciences – Spokane, WA Spokane International Airport PN: 2011230012-002 DRAFT Glycol Recovery Vehicle Deicer Management Plan Doc: 2011230012 GRV Managment Plan.docx December 9, 2011 / Page iii

CONTENTS

EXECUTIVE SUMMARY .......................................................................................................... IV

1.0 INTRODUCTION ..................................................................................................................1 1.1 Purpose and Scope ................................................................................................................ 1

2.0 FACILITY DESCRIPTION ...................................................................................................1

3.0 WATER QUALITY AND QUANTITY ................................................................................2

4.0 SHORT-TERM OPTIONS .....................................................................................................2 4.1 Deicer Collection Options..................................................................................................... 2

4.1.1 One Glycol Recovery Vehicle ................................................................................. 2 4.1.2 Multiple GRVs Plus Plug and Pump Stormwater Collection System ................... 3

4.2 Deicer Treatment/Discharge Options ................................................................................... 3 4.2.1 Concentrate and Reuse/Recycle Glycol .................................................................. 3 4.2.2 Land Treatment......................................................................................................... 4 4.2.3 Discharge to POTW ................................................................................................. 4

5.0 CURRENT DEICER BEST MANAGEMENT PRACTICES ...............................................5 5.1 Deicer Application BMPs ..................................................................................................... 5 5.2 Deicer Collection BMPs ....................................................................................................... 5 5.3 Recovered Deicer Storage and Disposal BMPs ................................................................... 6

6.0 MONITORING PLAN ...........................................................................................................7 6.1 Alpha and 3-21 Outfall ......................................................................................................... 7 6.2 Perimeter Ditch ...................................................................................................................... 7 6.3 Deicer Usage ......................................................................................................................... 8 6.4 Groundwater Monitoring Wells ........................................................................................... 8

7.0 SUMMARY ............................................................................................................................8

8.0 REFERENCES .......................................................................................................................9

TABLES

Table 1. Oxygen Demand of Airside Deicing Chemicals Table 3. Monitoring Requirements

FIGURES

Figure 1. Identification and Stormwater Discharge Map Figure 2. Deicer Application Area Map Figure 3a. Monitoring Location Map Figure 3b. Monitoring Well Locations

APPENDICES

Appendix A. 2010-2011 Glycol Load Calculations Appendix B. Monitoring Forms and Protocols

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EXECUTIVE SUMMARY Cold weather application of aircraft and pavement deicers (collectively referred to as “deicer”) at the Spokane International Airport (SIA) results in discharges of stormwater commingled with deicer to the stormwater infiltration/evaporation area northeast of the main runway. The deicer readily decomposes to cause chemically reducing conditions in the perched groundwater aquifer in the stormwater infiltration/evaporation area. These reducing conditions can mobilize naturally occurring arsenic and iron into the groundwater. SIA is implementing a management plan to collect used deicer at SIA with glycol recovery vehicles under SIA’s temporary state waste discharge permit starting in 2011 and going through the spring of 2015. Under this temporary permit, SIA will implement a monitoring plan to gain an understanding of the effects of deicer recovery on stormwater quality. As part of the management plan, SIA has submitted an Engineering Report (CES, 2011) and an industrial discharge permit application to the City of Spokane for the 2011 – 2012 deicing season to discharge the recovered deicer to the River Park Water Reclamation Facility (RPWRF). SIA is pursuing other available treatment/discharge options for the collected deicer, including land application, in parallel to POTW discharge. SIA will submit an engineering report to Ecology on other treatment/discharge options for approval prior to implementation. The data collected through operation of this management plan will be used to complete an engineering report to identify and determine long-term options for deicer collection, treatment, and/or disposal at SIA.

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1.0 INTRODUCTION During the winter months at freezing or near freezing conditions, the passenger airlines and air cargo operators (Carriers) at the Spokane International Airport (SIA) conduct deicing of aircraft as a safety precaution. In addition, SIA utilizes deicers, containing sodium formate, sodium acetate and potassium acetate, to melt and limit ice accumulation on paved surfaces including aprons, taxiways, and runways. Aircraft deicing fluids (ADF) are liquids consisting primarily of propylene glycol (glycol). They are sprayed onto aircraft to remove and control ice-buildup on critical flight control surfaces. The deicing chemicals are readily decomposable by microorganisms, thus creating an oxygen demand when dissolved in water. As a result, stormwater from the Facility can carry these oxygen demanding compounds offsite in stormwater runoff (ACRP, 2008). The SIA Facility has been designed to discharge stormwater to an infiltration/evaporation area east of Taxiway A (Alpha) and Runway 3-21 for more than 30 years (Figure 1). The discharge is regulated under temporary State Waste Discharge Permit No. ST0045499, dated November 7, 2011 that is in force for up to five years or until a new permit is issued. This temporary permit gives SIA the first step in an adaptive management plan to determine the effect of removing of a portion of the deicer on the groundwater quality in the stormwater infiltration area. 1.1 Purpose and Scope

The specific objective of this report is to address best management practices (BMP) for deicer application and collection. The required monitoring is also included in this plan to allow the collection of data to aid in determining the long-term options for deicer collection and treatment.

2.0 FACILITY DESCRIPTION SIA is located at 9000 W Airport Drive in Spokane, Washington. Airports are typically separated into two areas referred to as “airside”, which is typically the secure area at an airport, and “landside”, which is open to the general public. During precipitation events, deicing agents have historically drained from application areas into the stormwater collection system consisting of a perimeter drainage ditch, collection basins, conveyance pipelines, and trench drains (Figure 1). Stormwater from terminal buildings, parking structures and active aprons and boarding gates, where the majority of aircraft are deiced, is collected in drains and trench drains and carried in a buried pipeline along Taxiway A to the Alpha Outfall. Stormwater from the southeast portion of the airport including the general aviation facilities and aircraft maintenance buildings is collected in drains and discharges at the 3-21 Outfall. Stormwater from the southwestern end of the airport including a portion of the Air National Guard hangars and aprons is conveyed around the airport to the north via the Perimeter Ditch. The stormwater conveyed via the Perimeter Ditch discharges at a point near the Alpha Outfall at the northeast end of Taxiway A. In addition to runoff from the deicing areas, deicing agents can escape the application areas by being ‘tracked out’ on aircraft and service vehicle tires, dripping off the deiced aircraft as they move around the airport, and other losses associated with a stormwater collection system (i.e., infiltration through cracks or deposition in low areas, etc.). However, this represents a small percentage of the applied deicing agents, which is assumed at approximately 20% (EPA, 2009).

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3.0 QUALITY AND QUANTITY The ADF used by the Carriers at SIA consists mainly of two types of aircraft deicers, Type I and Type IV propylene glycol (glycol). Type I is applied to remove accumulated ice and snow. Type IV is applied prior to takeoff and is meant to stay on the wing until roll out and just before the pilot rotates the aircraft for flight, at which point it shears off. SIA has used three types of deicers for paved surfaces (pavement deicers) in recent years: sodium acetate, potassium acetate, and sodium formate. In addition to usage data, the oxygen demand for the glycol and other deicers is available from published sources (ACRP, 2008 and EPA, 2009) and presented in Table 1.

4.0 SHORT-TERM OPTIONS As part of the adaptive management approach, SIA is implementing options for collection of applied deicers and proper disposal of the collected deicers. 4.1 Deicer Collection Options

The options for collection in the short term for the purposes of this plan are related to the incremental implementation of the most effective, readily-available, easily-implemented practices.

4.1.1 One Glycol Recovery Vehicle

This option is currently being implemented by SIA with the intent to recover as much ADF as possible using a single glycol recovery vehicle (GRV). The GRV is being used to recover ADF in and around areas where ADF is applied to the aircraft. The GRV is a vacuum truck with an 8 foot-wide vacuum nozzle, 1,800 gallon (1,600 usable) tank, air liquid separation, power bar wash, and off load pump system at 450 gallons per minute (gpm). The GRV will vacuum up spent ADF plus a limited amount of surface deicer as well as precipitation and water from the power bar wash system resulting in a tank containing a mixture of water and deicer. The effectiveness of this option is dependent on the efficiency of the GRV to recover ADF. GRV recovery typically has an efficiency in the range of 23 to 48% of glycol applied (ACRP, 2008). Inland Technologies, a supplier and operator of GRVs with experience operating glycol recovery systems at airports in the United States and Canada, indicated that the typical concentration of glycol in the GRV tank may range from 6 to 25% glycol. Per conversations with Inland Technologies, operating one GRV at SIA will most likely result in a recovery efficiency of approximately 20% of applied glycol. This is also consistent with research conducted by the Environmental Protection Agency (EPA, 2009). Using the deicing data from 2010 – 2011 (Appendix A) and assuming a 20% collection efficiency and 15% concentration of glycol, the liquid volume of collected deicer stormwater and five-day biochemical oxygen demand (BOD5) load can be calculated. The collected volume would be approximately 130,000 gallons with a glycol load representing 190,000 pounds (lb) BOD5 under this option. With implementation of this option, SIA has leased one GRV. SIA also has to provide a way to discharge from the GRV directly to the treatment or disposal option chosen, or to storage for future treatment or disposal. Currently, the glycol is being stored in tanks while awaiting a suitable disposal option.

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4.1.2 Multiple GRVs Plus Plug and Pump Stormwater Collection System

This option expands the GRV option by adding additional GRVs. In addition to increasing the recovery efficiency by having multiple GRVs, SIA could plug stormwater collection pipes in the stormwater system during ADF application and pump the deicer-laden stormwater from the catch basins to further increase the recovery efficiency. With multiple GRVs in operation at SIA and pumping the collection basins, it is estimated that the glycol recovery efficiency could increase to 40% (EPA, 2009). Based on the 2010-2011 (Appendix A) deicing data and assuming a 40% collection efficiency and 15% concentration of glycol the calculated deicer stormwater volume and BOD5 under this option would be approximately 256,000 gallons with a glycol load representing 385,000 lb BOD5. With this option, SIA would have to purchase, lease, or rent additional GRVs and plugs for use during periods of deicing. The glycol would be stored in tanks temporarily and treated or discharged using an approved option. 4.2 Deicer Treatment/Discharge Options

Once collected, the deicer must be managed in a way that it is sufficiently treated to mitigate degradation of groundwater. Several options exist and are currently being explored.

4.2.1 Concentrate and Reuse/Recycle Glycol

According to the Federal Aviation Administration (FAA, 2001), at the time of publication, glycol recovery and recycle was used at 12 airports in the United States. According to information provided by Inland Technologies, fluids with a glycol concentration of 1% or greater can be recovered and recycled. The stormwater meeting the required concentration is identified by use of a densitometer and discharged via a separate conveyance system to the recovery treatment process. Stormwater with a glycol concentration too low for recovery and reuse would be discharged or treated separately prior to discharge. With this option, a waste stream would be produced with a greatly reduced oxygen demand that would still have to be treated by either a land application site, a publicly owned treatment works (POTW), a stormwater infiltration area, a mechanical or biological systems or a combination of options. The unit processes required for the recovery and recycle system include:

• application area collection system • conveyance pumps and pipes • storage tanks • suspended solids removal • dissolved solids removal • polymer additives removal • water removal • concentrator

The cost for recovery and recycle of glycol from stormwater is greatly influenced by the concentration of glycol collected and the requirements for the quality of the reject stream. Inland Technologies stated that for this option to be viable, the volume of collected stormwater with a glycol concentration of 15% would need to be around 300,000 gallons. Another option for this

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treatment technology is to haul the collected fluid to an offsite recycling facility. The cost to ship thousands of gallons to an offsite location makes this option undesirable unless a closer recycling facility is found. The cost for transportation and recycling for this option ranges from $0.60 to $1.00 per gallon making it an unattractive option at this time. 4.2.2 Land Treatment

Land application is an efficient and cost effective option to standard mechanical-biological treatment technologies. The benefits associated with land application include:

• reduced pressure on local water resources (e.g., wastewater instead of fresh water is used to irrigate agricultural land),

• lower energy requirements, • system resiliency (e.g., land application systems can handle treatment upsets and short-term

overloads compared to traditional mechanical treatment systems) • capability to handle thermal loads (e.g., many rivers and streams are becoming limited for

thermal discharge). Land application does, however, carry the risk of impacting groundwater when a system is overloaded from a hydraulic and mass loading standpoint. This situation can be remedied by adding additional land, which has the effect of reducing the overall loading rate, and/or by removing the mass load prior to applying (e.g., improving treatment before delivering the effluent for irrigation). Land application where the collected stormwater is used as part of an irrigation water supply for crops is an inexpensive option. The glycol would be treated in the soil profile by native microbes just as it would be treated in a biological treatment. However, in this case, the irrigation would be controlled to retain the applied water in the soil profile for treatment and use with little or no discharge to groundwater. Because the stormwater is expected to contain almost no nutrients, such as nitrogen and phosphorus, the size of the land application system would be dependent on the appropriate oxygen demand loading rate for treatment. With this option, SIA will have to provide storage capacity and a delivery system to the irrigated land. There is land either owned by SIA or adjacent to SIA property that could potentially utilize the stormwater. An alternative to applying to croplands is to apply a portion of the collected stormwater mixture as deicer for access roads located on SIA property. This practice has been reportedly implemented by Fairchild Air Force Base under permit from Ecology.1 This practice could reduce the volume of collected stormwater to store until the growing season and reduce the BOD5 load to be applied to the land by an irrigation system. SIA could consider using a portion of the collected stormwater as a deicer on unpaved equipment access or maintenance roads located at SIA. This practice could reduce the cost of this option. 4.2.3 Discharge to POTW

Discussions with the City of Spokane indicate that discharge to its POTW, the Riverside Park Water Reclamation Facility (RPWRF), may be a viable option. Fees and load surcharges for accepting the

1 Personal communication, Scott Mallery, PE, Engineer, Washington Department of Ecology, Eastern Region Office. October 2011 to Dan Burgard, Cascade Earth Sciences, Spokane, WA

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stormwater will be based on volume and quality. The City of Spokane indicated that a formal permit process will be required. The discharge rate and quality will need to be limited to a specific maximum daily loading rate to avoid upsetting the existing treatment processes. As a result, storage would be required for this option to control the discharge to the POTW to within the approved limits. Under this option, SIA will have to obtain a permit to discharge the deicer stormwater at a predictable and limited load to avoid treatment upsets at the RPWRF. The process requires SIA to work with RPWRF operational personnel and process engineers to model what effect the glycol would have on the treatment system at RPWRF with regards to meeting effluent permit requirements and biosolids production. This process is currently on-going. SIA has met with City of Spokane staff, applied for a permit, and has prepared an engineering report in support of the permit application to pursue as one option for treatment/discharge for the 2011-2012 deicing season.

5.0 CURRENT DEICER BEST MANAGEMENT PRACTICES The following Best Management Practices (BMPs) apply to the current operations at SIA. These BMPs may be modified or additional BMPs implemented as needed or as appropriate to improve deicer recovery management as more experience is gained with the collection, storage, and disposal of the deicers.

5.1 Deicer Application BMPs

Deicers are applied during freezing weather to the runways, taxiways, ramps, and aircraft for aircraft safety. Additional deicers are also applied to parking lots, walkways, streets, and roadways at and around SIA for public safety. The majority of the deicers at SIA that are discharged to the stormwater infiltration system are applied to areas within the secure area of the airport. All deicer is currently applied to or on impervious surface such as asphalt or concrete. The general application areas for a majority of the surface deicer and aircraft deicer is identified on Figure 2. The current practice for aircraft deicing at SIA is to back the aircraft away from the gate and spray heated deicer onto the critical flight control surfaces of the aircraft. Backing away from the gate allows clear access to the aircraft to maximize the efficiency of application, limits the area where deicing occurs, and improves the accessibility to the GRV for deicer recovery. SIA limits the application of surface deicers to areas required to meet safety requirements. To avoid over application, SIA follows the manufacturer recommendations to determine the quantity of deicer to apply for a given area for the current and expected conditions. 5.2 Deicer Collection BMPs

The GRV is operated as soon as possible after each aircraft departs when aircraft deicing occurs. The current GRV operation procedures used at SIA are located in Appendix B1. Quick response in ADF recovery will also result in a glycol solution that is less diluted by precipitation. The goal of the GRV is to minimize the transport of deicer by the stormwater to the trench drains in a pattern that captures as much deicer as possible. To achieve the maximum containment and

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recovery of deicer the GRV should begin collecting from the downgradient edge of the application area nearest the trench drain and working upslope. The GRV operates in the application area until the entire area has been canvassed by the GRV. If multiple GRVs are implemented at SIA, the general BMPs stay the same with the possibility of the GRVs operating at different aircraft deicing locations on the ramp. With Multiple GRVs, SIA could also implement BMPs in the stormwater collection system to isolate stormwater-containing deicer from being conveyed to the outfalls. To achieve this SIA could plug or stop flow at some of the stormwater collection basins. This practice would require SIA to pump the collected stormwater containing deicer from the collection basins on a regular basis. Pumping of the plugged collection basins can be done with a GRV. With this BMP, the collection basin would be plugged during deicing and unplugged when the need to deice ceases. If plugged, the collection basins would need to be monitored to prevent overtopping or flooding other areas. If SIA implements a plugging and pumping operation, a management plan will need to be developed to identify how to operate such a system. 5.3 Recovered Deicer Storage and Disposal BMPs

The final step to collection is storing the collected deicer stormwater for disposal or treatment. The BMP for storage of deicer stormwater may vary depending on if the storage is temporary or permanent. All storage vessels need to hold liquid without leaking. Temporary storage can be provided in the form of baker tanks, frac tanks, or bladder tanks. All temporary tanks need to be certified clean to prevent the deicer stormwater from being contaminated from residues left in the tank from previous uses. Permanent storage vessels may consist of the above temporary storage vessels, steel tanks, synthetically-lined earthen ponds, or some combination to meet the required storage volume. All storage vessels will need to meet design standards as set forth by regulatory agencies. Spills that occur while off loading from a GRV will be cleaned up with the GRV. Flows to the City of Spokane for treatment, if approved, will be metered in terms of volume of deicer stormwater and overall BOD load. The BOD load will be determined from the concentration as measured by a refractometer using the Brix scale and correlation to glycol concentration. Land application of recovered deicer stormwater will be conducted under an approved procedure specifically developed to prevent groundwater contamination and reintroduction of deicer into stormwater runoff collection areas.

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6.0 MONITORING PLAN Monitoring is required by State Waste Discharge Permit ST0045499 and will provide the critical information necessary for determining the appropriate long-term deicer management, treatment, and disposal strategy. The data collected will be used by SIA to manage the deicer usage and stormwater system in the future. This plan includes monitoring of the:

• Stormwater at the Alpha and 3-21 Outfall

• Stormwater at the Perimeter Ditch

• Groundwater Monitoring

• Aircraft Deicer and Surface Deicer usage and collection The monitoring locations or sample collection points are shown on Figures 3a and 3b and will be located within the area defined as Airside (Secure Area) except for the Perimeter Ditch outfall, which is located landside. Qualified individuals and laboratories will need to conduct sample collection and analysis. All samples will need to be collected, stored, and transported according to regulatory and laboratory standard methods. The constituents to be analyzed, as required in the State Waste Discharge Permit No. ST0045499, dated November 7, 2011 are listed in Table 2. Actual monitoring will be conducted to meet permit requirements should changes be made to the permit in the future. 6.1 Alpha and 3-21 Outfall

The monitoring location for the Alpha and 3-21 Outfalls will be located at a manhole located just upstream of the piped discharge point. The Alpha and 3-21 Outfall pipes do not have any connections or influent between the manhole and outfall points. The Alpha and 3-21 Outfalls require continuous metering of flow. The flow rate will be summarized and reported in the Discharge Monitoring Reports (DMRs). A twelve-hour composite water sample will be collected at the both outfalls once a week with an automatic sampler from October to April and then once a month the rest of the year. The samples are to be collected on variable days coupled with temperature/precipitation and deicer application. “Variable Days” means that samples are to be collected on a different day of the week to provide a range of sampling data. The sampling day and sample collection should be chosen to best represent the use of deicer at SIA as well as the length of time. The weekly weather forecast for the area will be used to determine the appropriate day to set the automatic sampler to collect a twelve-hour composite sample in order to get samples representative for the time period. 6.2 Perimeter Ditch

The Perimeter Ditch will require monitoring once a week from October to April and then once a month the rest of the year. The Perimeter Ditch will have two monitoring locations: one at the outfall and one prior to where the drainage ditch leaves or flows under the security fence. The sample collection will be a twelve-hour composite sample with an automated sampler when flow is present. Samples are to be collected on variable days coupled with temperature/precipitation and deicer application. The weekly weather forecast for the area will be used to determine what day to collect samples and observe the flow rate. The flow rate of stormwater in the perimeter ditch is to be a calculated value to estimate the average daily, total monthly, and total annual flows.

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Engineering judgment will be used to determine how to calculate flow, with the most likely method being the development of a water depth to flow relationship. All results will be reported in the monthly DMRs. 6.3 Deicer Usage

The deicer usage at SIA for both surface and aircraft deicer will be monitored to record the volumes and type of deicer applied at SIA each day. The form used by the airline carriers to record and report daily aircraft deicer usage to SIA staff is included in Appendix B2. These values are summarized for all carriers and reported in the monthly DMRs. The SIA maintenance staff will use a similar form to record and report daily surface deicer usage (Appendix B3). These values will be summarized and reported in the monthly DMRs. The other component related to deicer monitoring at SIA is the daily collection of deicer by the GRV. The GRV operation staff will record and report the daily operation and collection on the GRV form located in Appendix B4. The GRV operation staff will use a refractometer to measure the Brix of the deicer collected and record it on the form each day. The Brix value is used to determine the concentration of glycol in the solution. An example table to correlate the Brix value to glycol concentration is included in Appendix B5. The recorded information will be summarized and reported in the monthly DMRs. 6.4 Groundwater Monitoring Wells

The groundwater at monitoring wells at SIA will be monitored for the constituents and at the time intervals listed in Table 2 or as required. These values will be reported on the monthly DMRs. The current sampling methods and procedures used for monitoring the groundwater wells at SIA is located in Appendix B6. The current methods are representative of the methods that will be used to collect groundwater samples although minor differences may occur if the consultant changes in the future.

7.0 SUMMARY This report was developed by CES using information provided by SIA and the Carriers. The primary objective of this report is to identify management practices for managing stormwater at SIA under the adaptive management plan and temporary state waste discharge permit. Under the adaptive management plan, SIA will implement procedures to incrementally improve collection and recovery of deicers to reduce the BOD5 load in the stormwater discharged at SIA. The first step in the adaptive management plan is operation under the temporary discharge permit with SIA leasing one GRV for collection of deicer at SIA. SIA plans to operate a single GRV at this time with the option of operating multiple GRV in future deicing season if SIA determines it is beneficial to gather data during this temporary permit phase to see what effect multiple GRVs have at SIA. As part of this first step, SIA has submitted an Engineering Report (CES, 2011b) and an Industrial Discharge Permit Application to the City of Spokane for discharge to the RPWRF for disposal of collected ADF stormwater from the 2011 – 2012 deicing season as one treatment/discharge option

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that SIA is pursuing. SIA will work with the City of Spokane to prevent upsets at the RPWRF through close monitoring of the discharge flow rate and glycol concentration. A parallel option that SIA is pursuing is land application. The use of the collected stormwater as a surface deicer for equipment access and maintenance roadways at SIA will be considered to dispose of some of the collected volume under the land application option. As SIA pursues this treatment option or any other disposal/treatment options, an engineering report will be submitted to Ecology for review and approval. A major component of the adaptive management plan and this first step is the monitoring program, which is to be implemented as required in State Waste Discharge Permit ST-0045499. This will provide feedback on deicer, stormwater, and groundwater quality throughout the year, as well as over multiple years. Following the deicing season each year, SIA will analyze all the data collected from monitoring the groundwater, Alpha and 3-21 Outfalls, Perimeter Ditch, collected stormwater, and deicer used at SIA and submit an update report to Ecology on or before July 1 of each year. At the end of this first phase in the adaptive management plan or temporary state waste discharge permit, SIA will use the collected data and knowledge gained from operation of a collection system and treatment/disposal system to develop an AKART report to develop the next step in the adaptive management plan and identify long-term options. With sufficient operational and monitoring data, over time, it should be possible to determine the appropriate combination of recovery and treatment needed to mitigate degradation of groundwater.

8.0 REFERENCES ACRP, 2008. Formulations for Aircraft and Airfield Deicing and Anti-icing: Aquatic Toxicity and

Biochemical Oxygen Demand, ACRP Web-only Doc. 3. Contractors Phase I Interim Report for ACRP Project 02-01, November 2008. Airport Coop. Research Program, Transportation Research Board, Washington, DC.

CES, 2011. Aircraft Deicing Fluid POTW Discharge Engineering Report for Spokane International

Airport. Cascade Earth Sciences. October 2011. EPA, 2009. Technical Development Document for: Proposed Effluent Limitation Guidelines and

Standards for the Airport Deicing Category. US. Environmental Protection Agency, Washington, DC. July 2009.

FAA, 2001. History, Processing, and Usage of Recycled Glycol for Aircraft Deicing and Anti-

Icing. U.S. Department of Transportation - Federal Aviation Administration. February 2001.

TABLES

Table 1. Oxygen Demand of Airside Deicing Chemicals Table 2. Monitoring Requirements

Table 1. Oxygen Demand of Airside Deicing Chemicals Glycol Recovery Vehicle Management Plan Spokane International Airport

Theoretical OxygenDemand

Reported BOD5 @ 20oC Reported BOD28 @ 20oC

lb/gal lb/lb lb/gal lb/lb lb/gal mg/kg lb/lb lb/gal mg/kg

Propylene Glycol - 100% ACRP, 2008 I 8.7 1.61 14.01 1.13 9.83 1,130,000 -- -- --

Propylene Glycol - 88% ACRP, 2008 I 8.7 1.42 12.33 0.99 8.65 994,400 -- -- --

Propylene Glycol - 88% Dow Chemical, 2004 I 8.7 1.38 12.01 0.73 6.35 730,000 1.06 9.22 1,060,000

Propylene Glycol - 44% Calculated I 8.7 0.71 6.16 0.50 4.33 497,200 -- -- --

Propylene Glycol - 100% ACRP, 2008 IV 8.7 1.68 14.62 1.08 9.40 1,080,000 -- -- --

Propylene Glycol - 50% ACRP, 2008 IV 8.7 0.84 7.31 0.54 4.70 540,000 -- -- --

Potassium Acetate - 50% ACRP, 2008 liquid 13.1 0.25 3.24 0.25 3.24 247,000 -- -- --

Sodium Acetate - 96% ACRP, 2008 solid -- 0.57 -- 0.57 -- -- -- -- --

Sodium Formate - 98% ACRP, 2008 solid -- --3 -- -- -- -- -- -- --

NOTES:

Abbreviations: oC = degrees Celsius, BOD5 = 5-day biochemical oxygen demand, BOD28 = 28-day biochemical oxygen demand, lb/gal = pounds per gallon, lb/lb = pounds oxygen demand per

pound of chemical, mg/kg = milligrams per kilogram.

1 Sources of data include:

ACRP, 2008. Formulations for Aircraft and Airfield Deicing and Anti-icing: Aquatic Toxicity and Biochemical Oxygen Demand, ACRP Web-only Doc. 3. Airport Coop. Research Bd. Contractors Phase I Interim

Report for ACRP Project 02-01, November 2008.

Dow Chemical, 2004. UCAR PG Aircraft Deicing Fluids, SAE AMS 1424 Propylene-Glycol based Type I Fluids. Prod Info Bull 183-00024-0704 AMS. Dow Chemical Co. Midland, Michigan. July 2004.

2 Density data from manufacturer product information.

3 BOD5 test results for sodium formate deicer were not considered reliable estimates of potential BOD exertion in environmental situation due to apparent toxicity of the formulation to BOD seed organisms.

Density2

Chemical Source1 Type

Cascade Earth Sciences - Spokane, WADoc: 2011230012 GRV Managment Plan.xlsx (T1 Oxygen Demand)

SIA - Spokane, WA12/9/2011

Table 2. Monitoring Requirements Glycol Recovery Vehicle Management Plan Spokane International Airport

Sample Type Frequency Parameter Reporting

Alpha and 3-21 Outfall

Meter reading Continuous Flow (gallons per day)

Weekly 1

(October through April)

Monthly(May through September)

Perimeter Ditch Outfall and Perimeter Ditch at Security Fence

Weekly 1

(October through April)

Monthly(May through September)

Weekly 1

(October through April)

Monthly(May through September)

Monitoring Wells

Field Measurement MonthlyDepth to Groundwater, pH, Conductivity, Turbidity, DO, Temperature,

Oxygen Reduction Potential

Monthly BOD

Quarterly(January, April, July, October)

Total Metals (arsenic, iron, calcium, manganese),Total Dissolved Metals (arsenic, iron, calcium, manganese)

Annually - OctoberCations and Anions (sodium, calcium, magnesium, potassium, chloride,

sulfate, total phosphorus, bicarbonate)

Deicer

Surface Deicer Observation and/or Calculated Daily Volume Applied (gallons or pounds), Application Areas

Aircraft Deicer Observation and/or Calculated Daily Volume Applied (gallons), Application Areas

Collected Deicer Stormwater

Observation and/or Calculated DailyVolume Collected (gallons), Glycol Concentration (%), Areas of glycol

recovery vehicle operation

NOTES:Abbreviations: BOD = biochemical oxygen demand, COD = chemical oxygen demand, DO = dissolved oxygen, DMR = discharge monitoring reportThe monitoring requirements listed are required by State Waste Discharge Permit No. ST0045499.1 Varied days based on deicer usage and weather.

MonthlyDMR

MonthlyDMR

MonthlyDMR

Grab

MonthlyDMR

pH, BOD, COD, visible sheen

Flow (gallons per day)

pH, BOD, COD, visible sheen

Stormwater

Stormwater

Groundwater

Observation and/or Calculated

12-hour composite

12-hour composite

Cascade Earth Sciences - Spokane, WADoc: 2011230012 GRV Managment Plan.xlsx (T2. Monitoring Plan)

SIA - Spokane, WA12/9/2011

FIGURES

Figure 1. Identification and Stormwater Discharge Map Figure 2. Deicer Application Area Map Figure 3a. Monitoring Location Map Figure 3b. Monitoring Well Locations

APPENDICES

Appendix A. 2010-2011 Glycol Load Calculations Appendix B. Monitoring Forms and Protocols

Appendix A.

2010 -2011 Glycol Load Calculations

Appendix A. 2010-2011 Glycol Load Calculations Glycol Recovery Vehicle Management Plan Spokane International Airport

Volume Glycol Applied Applied BOD5 as Glycol 4

Type I 2 Type IV 3 Total Type I Type IV Total

gal lb

10/1/2010 0 0 0 0 0 0 0 0 0

10/2/2010 0 0 0 0 0 0 0 0 0

10/3/2010 0 0 0 0 0 0 0 0 0

10/4/2010 0 0 0 0 0 0 0 0 0

10/5/2010 0 0 0 0 0 0 0 0 0

10/6/2010 0 0 0 0 0 0 0 0 0

10/7/2010 0 0 0 0 0 0 0 0 0

10/8/2010 0 0 0 0 0 0 0 0 0

10/9/2010 0 0 0 0 0 0 0 0 0

10/10/2010 0 0 0 0 0 0 0 0 0

10/11/2010 102 0 102 45 0 45 440 0 440

10/12/2010 156 0 156 69 0 69 677 0 677

10/13/2010 102 0 102 45 0 45 440 0 440

10/14/2010 0 0 0 0 0 0 0 0 0

10/15/2010 0 0 0 0 0 0 0 0 0

10/16/2010 51 0 51 22 0 22 220 0 220

10/17/2010 361 0 361 159 0 159 1,561 0 1,561

10/18/2010 481 0 481 212 0 212 2,081 0 2,081

10/19/2010 215 0 215 95 0 95 930 0 930

10/20/2010 51 0 51 22 0 22 220 0 220

10/21/2010 0 0 0 0 0 0 0 0 0

10/22/2010 0 0 0 0 0 0 0 0 0

10/23/2010 0 0 0 0 0 0 0 0 0

10/24/2010 0 0 0 0 0 0 0 0 0

10/25/2010 0 0 0 0 0 0 0 0 0

10/26/2010 51 0 51 22 0 22 220 0 220

10/27/2010 0 0 0 0 0 0 0 0 0

10/28/2010 0 0 0 0 0 0 0 0 0

10/29/2010 0 0 0 0 0 0 0 0 0

10/30/2010 51 0 51 22 0 22 220 0 220

10/31/2010 0 0 0 0 0 0 0 0 0

11/1/2010 0 0 0 0 0 0 0 0 0

11/2/2010 29 0 29 13 0 13 124 0 124

11/3/2010 0 0 0 0 0 0 0 0 0

11/4/2010 52 0 52 23 0 23 224 0 224

11/5/2010 80 0 80 35 0 35 348 0 348

11/6/2010 80 0 80 35 0 35 348 0 348

11/7/2010 0 0 0 0 0 0 0 0 0

11/8/2010 182 0 182 80 0 80 788 0 788 1,291

11/9/2010 1,028 0 1,028 452 0 452 4,447 0 4,447 1,241

11/10/2010 472 0 472 208 0 208 2,044 0 2,044 1,531

11/11/2010 246 0 246 108 0 108 1,063 0 1,063 1,747

11/12/2010 0 0 0 0 0 0 0 0 0 1,635

11/13/2010 549 0 549 242 0 242 2,375 0 2,375 1,072

11/14/2010 350 0 350 154 0 154 1,515 0 1,515 1,376

11/15/2010 0 0 0 0 0 0 0 0 0 4,447

11/16/2010 118 0 118 52 0 52 509 0 509 4,782

11/17/2010 965 0 965 424 0 424 4,172 0 4,172 5,119

11/18/2010 4,694 458 5,153 2,066 229 2,295 20,306 2,253 22,559 5,929

11/19/2010 542 0 542 239 0 239 2,346 0 2,346 12,920

11/20/2010 1,093 0 1,093 481 0 481 4,729 0 4,729 16,494

Date

ADF

Total 1Type IV 1Type I 1

7 DayAverage

BOD5 5

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Appendix A. 2010-2011 Glycol Load Calculations Glycol Recovery Vehicle Management Plan Spokane International Airport

Volume Glycol Applied Applied BOD5 as Glycol 4

Type I 2 Type IV 3 Total Type I Type IV Total

gal lb

Date

ADF

Total 1Type IV 1Type I 1

7 DayAverage

BOD5 5

11/21/2010 1,583 70 1,652 696 35 731 6,846 343 7,189 16,972

11/22/2010 10,083 1,083 11,166 4,437 541 4,978 43,615 5,323 48,939 17,023

11/23/2010 4,512 1,222 5,735 1,985 611 2,597 19,519 6,008 25,527 20,934

11/24/2010 1,737 0 1,737 764 0 764 7,515 0 7,515 26,009

11/25/2010 4,529 677 5,206 1,993 339 2,331 19,590 3,328 22,919 26,181

11/26/2010 6,635 208 6,843 2,919 104 3,023 28,700 1,021 29,721 20,684

11/27/2010 7,982 1,165 9,147 3,512 582 4,094 34,527 5,724 40,252 19,892

11/28/2010 1,833 95 1,928 806 48 854 7,928 467 8,395 22,107

11/29/2010 2,300 104 2,404 1,012 52 1,064 9,947 511 10,458 19,592

11/30/2010 3,931 606 4,538 1,730 303 2,033 17,005 2,981 19,986 17,274

12/1/2010 5,138 161 5,300 2,261 81 2,342 22,227 793 23,019 12,196

12/2/2010 1,229 0 1,229 541 0 541 5,314 0 5,314 11,409

12/3/2010 2,930 166 3,096 1,289 83 1,372 12,676 816 13,491 10,662

12/4/2010 1,088 0 1,088 479 0 479 4,706 0 4,706 8,943

12/5/2010 668 0 668 294 0 294 2,888 0 2,888 6,101

12/6/2010 1,153 50 1,203 507 25 532 4,985 246 5,231 5,677

12/7/2010 1,837 0 1,837 808 0 808 7,948 0 7,948 7,376

12/8/2010 699 22 721 307 11 318 3,023 107 3,130 7,656

12/9/2010 506 31 537 223 16 238 2,190 152 2,342 8,111

12/10/2010 5,869 0 5,869 2,582 0 2,582 25,387 0 25,387 7,397

12/11/2010 1,472 61 1,533 648 31 678 6,366 302 6,668 6,369

12/12/2010 1,403 0 1,403 617 0 617 6,070 0 6,070 6,448

12/13/2010 54 0 54 24 0 24 235 0 235 7,224

12/14/2010 173 0 173 76 0 76 749 0 749 4,175

12/15/2010 827 22 849 364 11 375 3,576 109 3,685 6,045

12/16/2010 1,798 0 1,798 791 0 791 7,777 0 7,777 6,135

12/17/2010 934 0 934 411 0 411 4,041 0 4,041 8,192

12/18/2010 3,759 712 4,471 1,654 356 2,010 16,262 3,499 19,761 8,629

12/19/2010 1,509 35 1,544 664 18 681 6,526 172 6,698 10,366

12/20/2010 3,208 153 3,362 1,412 77 1,488 13,878 754 14,632 10,095

12/21/2010 880 0 880 387 0 387 3,807 0 3,807 10,123

12/22/2010 3,542 106 3,648 1,558 53 1,612 15,321 523 15,844 7,694

12/23/2010 1,333 24 1,357 587 12 599 5,767 118 5,885 7,653

12/24/2010 978 0 978 431 0 431 4,233 0 4,233 6,253

12/25/2010 638 0 638 281 0 281 2,760 0 2,760 6,515

12/26/2010 1,345 120 1,465 592 60 652 5,817 591 6,409 15,577

12/27/2010 1,117 0 1,117 492 0 492 4,834 0 4,834 17,158

12/28/2010 1,226 68 1,295 540 34 574 5,305 336 5,641 17,286

12/29/2010 14,684 3,207 17,891 6,461 1,604 8,064 63,516 15,765 79,281 17,536

12/30/2010 3,907 10 3,917 1,719 5 1,724 16,901 49 16,950 17,268

12/31/2010 1,185 0 1,185 521 0 521 5,124 0 5,124 17,500

1/1/2011 1,037 5 1,042 456 3 459 4,485 25 4,510 17,319

1/2/2011 1,003 40 1,042 441 20 461 4,338 195 4,532 7,708

1/3/2011 1,494 0 1,494 657 0 657 6,462 0 6,462 5,926

1/4/2011 994 15 1,009 437 8 445 4,298 74 4,372 5,397

1/5/2011 2,519 226 2,745 1,108 113 1,221 10,896 1,109 12,005 5,192

1/6/2011 978 50 1,028 430 25 455 4,229 246 4,475 5,044

1/7/2011 329 0 329 145 0 145 1,423 0 1,423 4,450

1/8/2011 711 0 711 313 0 313 3,077 0 3,077 4,169

1/9/2011 791 15 806 348 8 356 3,422 74 3,496 11,117

1/10/2011 532 0 532 234 0 234 2,301 0 2,301 10,654

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Appendix A. 2010-2011 Glycol Load Calculations Glycol Recovery Vehicle Management Plan Spokane International Airport

Volume Glycol Applied Applied BOD5 as Glycol 4

Type I 2 Type IV 3 Total Type I Type IV Total

gal lb

Date

ADF

Total 1Type IV 1Type I 1

7 DayAverage

BOD5 5

1/11/2011 513 39 552 226 20 245 2,217 192 2,409 10,457

1/12/2011 13,290 641 13,931 5,848 320 6,168 57,487 3,150 60,637 10,038

1/13/2011 286 0 286 126 0 126 1,235 0 1,235 9,538

1/14/2011 11 0 11 5 0 5 46 0 46 9,209

1/15/2011 32 0 32 14 0 14 139 0 139 11,329

1/16/2011 0 0 0 0 0 0 0 0 0 3,092

1/17/2011 0 0 0 0 0 0 0 0 0 4,312

1/18/2011 3,572 364 3,937 1,572 182 1,754 15,453 1,791 17,243 5,475

1/19/2011 689 0 689 303 0 303 2,981 0 2,981 6,195

1/20/2011 2,166 83 2,248 953 41 994 9,369 406 9,775 6,408

1/21/2011 1,632 230 1,862 718 115 833 7,061 1,129 8,190 7,936

1/22/2011 1,197 0 1,197 527 0 527 5,177 0 5,177 5,742

1/23/2011 344 0 344 151 0 151 1,487 0 1,487 5,789

1/24/2011 1,931 477 2,408 850 239 1,088 8,352 2,347 10,699 4,786

1/25/2011 436 0 436 192 0 192 1,884 0 1,884 3,748

1/26/2011 766 0 766 337 0 337 3,314 0 3,314 3,009

1/27/2011 636 0 636 280 0 280 2,752 0 2,752 3,272

1/28/2011 214 0 214 94 0 94 927 0 927 1,988

1/29/2011 0 0 0 0 0 0 0 0 0 2,233

1/30/2011 769 0 769 338 0 338 3,326 0 3,326 2,088

1/31/2011 397 0 397 175 0 175 1,716 0 1,716 2,051

2/1/2011 832 0 832 366 0 366 3,598 0 3,598 1,918

2/2/2011 532 0 532 234 0 234 2,299 0 2,299 2,293

2/3/2011 575 0 575 253 0 253 2,489 0 2,489 2,810

2/4/2011 0 0 0 0 0 0 0 0 0 2,708

2/5/2011 607 0 607 267 0 267 2,625 0 2,625 2,784

2/6/2011 1,263 300 1,563 556 150 706 5,464 1,475 6,938 2,993

2/7/2011 232 0 232 102 0 102 1,003 0 1,003 3,054

2/8/2011 955 0 955 420 0 420 4,133 0 4,133 3,198

2/9/2011 869 0 869 382 0 382 3,759 0 3,759 2,829

2/10/2011 675 0 675 297 0 297 2,919 0 2,919 1,838

2/11/2011 233 0 233 103 0 103 1,008 0 1,008 1,694

2/12/2011 10 0 10 4 0 4 43 0 43 1,905

2/13/2011 0 0 0 0 0 0 0 0 0 1,827

2/14/2011 0 0 0 0 0 0 0 0 0 2,299

2/15/2011 914 336 1,250 402 168 570 3,954 1,653 5,607 2,875

2/16/2011 742 0 742 326 0 326 3,210 0 3,210 3,270

2/17/2011 1,429 8 1,437 629 4 633 6,182 39 6,222 3,278

2/18/2011 1,166 0 1,166 513 0 513 5,044 0 5,044 3,548

2/19/2011 649 0 649 286 0 286 2,807 0 2,807 3,762

2/20/2011 0 11 11 0 6 6 0 54 54 5,321

2/21/2011 438 0 438 193 0 193 1,895 0 1,895 7,764

2/22/2011 1,631 10 1,641 718 5 723 7,055 49 7,104 7,402

2/23/2011 3,089 154 3,243 1,359 77 1,436 13,362 757 14,119 7,360

2/24/2011 4,891 441 5,332 2,152 220 2,372 21,158 2,166 23,324 7,547

2/25/2011 581 0 581 256 0 256 2,513 0 2,513 8,036

2/26/2011 580 0 580 255 0 255 2,509 0 2,509 9,140

2/27/2011 315 0 315 139 0 139 1,363 0 1,363 7,540

2/28/2011 1,186 39 1,225 522 20 542 5,132 192 5,324 4,583

3/1/2011 3,136 257 3,393 1,380 129 1,508 13,565 1,263 14,828 4,511

3/2/2011 670 4 674 295 2 297 2,898 20 2,918 4,514

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Appendix A. 2010-2011 Glycol Load Calculations Glycol Recovery Vehicle Management Plan Spokane International Airport

Volume Glycol Applied Applied BOD5 as Glycol 4

Type I 2 Type IV 3 Total Type I Type IV Total

gal lb

Date

ADF

Total 1Type IV 1Type I 1

7 DayAverage

BOD5 5

3/3/2011 608 0 608 268 0 268 2,630 0 2,630 4,636

3/4/2011 463 0 463 204 0 204 2,003 0 2,003 4,064

3/5/2011 586 0 586 258 0 258 2,535 0 2,535 2,557

3/6/2011 512 0 512 225 0 225 2,215 0 2,215 2,935

3/7/2011 305 0 305 134 0 134 1,319 0 1,319 2,564

3/8/2011 923 59 982 406 30 436 3,993 290 4,283 2,480

3/9/2011 1,189 85 1,274 523 43 566 5,143 418 5,561 2,219

3/10/2011 7 0 7 3 0 3 30 0 30 2,050

3/11/2011 327 0 327 144 0 144 1,414 0 1,414 1,929

3/12/2011 165 0 165 73 0 73 714 0 714 1,317

3/13/2011 237 0 237 104 0 104 1,025 0 1,025 609

3/14/2011 110 0 110 48 0 48 476 0 476 806

3/15/2011 0 0 0 0 0 0 0 0 0 721

3/16/2011 140 0 140 62 0 62 606 0 606 1,188

3/17/2011 325 0 325 143 0 143 1,406 0 1,406 1,171

3/18/2011 190 0 190 84 0 84 822 0 822 1,118

3/19/2011 920 0 920 405 0 405 3,980 0 3,980 1,149

3/20/2011 210 0 210 92 0 92 908 0 908 1,063

3/21/2011 25 0 25 11 0 11 108 0 108 862

3/22/2011 50 0 50 22 0 22 216 0 216 745

3/23/2011 0 0 0 0 0 0 0 0 0

3/24/2011 0 0 0 0 0 0 0 0 0

3/25/2011 0 0 0 0 0 0 0 0 0

3/26/2011 0 0 0 0 0 0 0 0 0

3/27/2011 0 0 0 0 0 0 0 0 0

3/28/2011 0 0 0 0 0 0 0 0 0

3/29/2011 0 0 0 0 0 0 0 0 0

3/30/2011 0 0 0 0 0 0 0 0 0

3/31/2011 0 0 0 0 0 0 0 0 0

4/1/2011 0 0 0 0 0 0 0 0 0

4/2/2011 0 0 0 0 0 0 0 0 0

4/3/2011 150 0 150 66 0 66 649 0 649

4/4/2011 0 0 0 0 0 0 0 0 0

4/5/2011 30 0 30 13 0 13 130 0 130

4/6/2011 85 0 85 37 0 37 368 0 368

4/7/2011 195 0 195 86 0 86 843 0 843

4/8/2011 80 0 80 35 0 35 346 0 346

4/9/2011 100 0 100 44 0 44 433 0 433

4/10/2011 0 0 0 0 0 0 0 0 0

4/11/2011 0 0 0 0 0 0 0 0 0

4/12/2011 125 0 125 55 0 55 541 0 541

4/13/2011 0 0 0 0 0 0 0 0 0

4/14/2011 125 0 125 55 0 55 541 0 541

4/15/2011 0 0 0 0 0 0 0 0 0

4/16/2011 0 0 0 0 0 0 0 0 0

4/17/2011 0 0 0 0 0 0 0 0 0

4/18/2011 0 0 0 0 0 0 0 0 0

4/19/2011 0 0 0 0 0 0 0 0 0

4/20/2011 0 0 0 0 0 0 0 0 0

4/21/2011 0 0 0 0 0 0 0 0 0

4/22/2011 0 0 0 0 0 0 0 0 0

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Appendix A. 2010-2011 Glycol Load Calculations Glycol Recovery Vehicle Management Plan Spokane International Airport

Volume Glycol Applied Applied BOD5 as Glycol 4

Type I 2 Type IV 3 Total Type I Type IV Total

gal lb

Date

ADF

Total 1Type IV 1Type I 1

7 DayAverage

BOD5 5

4/23/2011 200 0 200 88 0 88 865 0 865

4/24/2011 0 0 0 0 0 0 0 0 0

4/25/2011 100 0 100 44 0 44 433 0 433

4/26/2011 300 0 300 132 0 132 1,298 0 1,298

4/27/2011 50 0 50 22 0 22 216 0 216

4/28/2011 900 3 903 396 2 398 3,893 15 3,908

4/29/2011 0 0 0 0 0 0 0 0 0

4/30/2011 0 0 0 0 0 0 0 0 0

Total 201,516 14,529 216,045 88,667 7,265 95,932 871,686 71,417 943,103

Avg Day 951 69 1,019 418 34 453 4,112 337 4,449 6,833

Max Day 14,684 3,207 17,891 6,461 1,604 8,064 63,516 15,765 79,281 26,181

NOTES:

Abbreviations: ADF = aircraft deicing fluid, BOD5 = five-day biochemical oxygen demand, gal = gallons, lb = pounds, lb/gal = pounds per gallon.

BOD5 values represented as Total Glycol for Type I of 1.13 lb/lb and Type IV of 1.08 lb/lb taken from ACRP 2008.

1 Type I and Type IV ADF Applied (gal) as reported by the Air Carriers.

2 Type I ADF Applied (gal) *Concentration Glycol (.88)*(.5) dilution = Volume Glycol Type I (gal).

3 Type IV ADF Applied (gal)*Concentration Glycol (.5) = Volume Glycol Type IV (gal).

4 Volume Glycol (gal) * Glycol Density (lb/gal) * BOD5 lb/lb = Glycol BOD5 (lb). Deicing density of 8.7 lb/gal taken from manufacture product information.

5 Running 7 day average of glycol BOD5 collected: Time period 11/8/2010 to 2/10/2011 was chosen because ADF was used on a

daily basis during this time frame. In addition, all carriers maintained deicer records during this time frame too.

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Appendix B.

Monitoring Forms and Protocols

Appendix B1. Spokane International Airport

Glycol Recovery Plan Purpose:

The purpose of this plan is to provide an overview of the plans, policies and procedures that will be used by Spokane International Airport during the recovery of Aircraft Deicing Fluid. Definitions:

AD Aircraft Deicing ADF Aircraft Deicing Fluid ADO Aircraft Deicing Operations AFM Airfield Maintenance GRO Glycol Recovery Operations GRP Glycol Recovery Plan Responsibilities:

Airport Operations 1. When Airport Operations see ADO on the ramps and temperatures are above 40 degrees

they will notify AFM.

Airfield Maintenance 1. When temperatures are below 40 degrees AFM will check the weather to see if it is in the

frost range and check for precipitation. 2. When temperatures are below 40 degrees and frost is suspected AFM will daily inspect

the terminal and cargo ramps during normal staffing hours for ADO. 3. When AFM is notified of or detects ADO then GRO will begin. 4. GRO will generally work clockwise around the terminal gates picking up ADF. Starting

at terminal “A” and working toward terminal “C” then moving on to the Cargo areas. 5. The AFM operator will note on a GRV log:

a. Date b. Shift c. Driver d. Number of spot picked up at each gate e. Discharge location, tank 5, 6, 7 f. Discharge quantity g. Discharger glycol percentage

6. GRV log will be maintained electronically, transcribed from the operator’s log. Special Conditions:

GRO are contingent on available resources, staffing and equipment. During times of snow removal operations GRO may be reduced, limited or halted.

Appendix B2. Aircraft Deicer Carrier Reporting Form - Weekly Glycol Recovery Vehicle Management Plan Spokane International Airport

Instructions: 1. Report total gallons of PURE Aircraft Deicers applied, not diluted quantities.2. Insert the correct dates for the reporting period.3. Complete this form and return to the airport each week, even if no deicing occurred.4. Email the completed form to [email protected]

Sunday Monday Tuesday Wednesday Thursday Friday Saturday

Type 1

Type 2

Type 4

Comments:

Name:

Company:

Signature:

Date

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Appendix B3. Surface Deicer Reporting Form - Daily Instructions: 1. Report areas and times of surface deicer application. Glycol Recovery Vehicle Management Plan Spokane International Airport 2. Measure and record the type and volume applied (gallons or pounds).

3. Insert the correct dates for the reporting period.4. Complete this form and return to the airport each week, even if no operation occurred.5. Email the completed form to [email protected]

Ramps Runways Taxiways Roadways Parking Lots Other 1 Other 1 Other 1

Comments:

1. Description to describing area that Surface Deicer was applied.

Volume Applied

Surface Deicer Type

Driver Initials

Time Stopped

Time Started

DateArea Surface Deicer Applied

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Appendix B4. Glycol Recovery Vehicle Reporting Form - Daily Instructions: 1. Report Areas and Times of GRV Operation. Glycol Recovery Vehicle Management Plan Spokane International Airport 2. Measure and record the glycol concentration in the GRV tank prior to discharge to storage vessel.

3. Insert the correct dates for the reporting period.4. Complete this form and return to the airport each week, even if no operation occurred.5. Email the completed form to [email protected]

Southwest United SkyWestUS

Airways Delta Horizon Alaska Frontier UPS FedEx OtherDischarge Location

Comments:

NOTE:

Full load of spent ADF in the GRV's is 1,600 U.S. Gallons

DateTime

StartedTime

StoppedDriver

AREA/GATE LOCATION COLLECTEDVolume CONC. %

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Appendix B5. Correlation Table Brix Value to Glycol Concentration Glycol Recovery Vehicle Management Plan Spokane International Airport

GlycolConcentration

in Water (Percent by Volume)

Refractionat 20˚C ˚Brix

0 0.01 0.4 Brix Value to Glycol Concentration 2 1.23 1.94 2.65 3.46 4.17 4.88 5.59 6.2

10 6.9 20.0

25.0

30.0

35.0

40.0

n a

t 20

˚C ˚

Bri

x

yCorrelation

11 7.612 8.313 9.014 9.715 10.416 11.017 11.718 12.419 13.020 13 7

0.0

5.0

10.0

15.0

0 5 10 15 20 25 30 35 40 45 50 55 60

Ref

ract

ion

Glycol Concentration in Water (Percent by Volume)

20 13.721 14.422 15.0 NOTE:

23 15.6 Information was obtained from DOW Chemicals MSDS for Type I PG ADF (UCAR).

24 16.3 Source:

25 16.9 Dow Chemical, 2004. UCAR PG Aircraft Deicing Fluids, SAE AMS 1424 Propylene-Glycol

26 17.6 based Type I Fluids. Prod Info Bull 183-00024-0704 AMS. Dow Chemical Co. Midland, Michigan.

27 18.2 July 2004.

28 18.829 19 429 19.430 20.031 20.632 21.333 21.934 22.535 23.036 23.637 24.238 24.839 25.440 25.941 26.542 27.143 27.644 28.245 28.746 29.347 29.848 30.349 30.950 31.451 31.952 32.453 33.054 33.555 34.056 34.557 35 057 35.058 35.559 35.960 36.4

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ATTACHMENT 3 GROUNDWATER SAMPLING PROCEDURES

1.1 GROUNDWATER SAMPLING EQUIPMENT The following equipment is required for groundwater sampling at the SIA site. • Key to well locks • Tool Box (bolt cutters, screwdrivers, ½-inch Allen wrench, 9/16 ratchet, hammer) • Plastic Sheeting • Peristaltic pump • 12-volt battery • Groundwater sample filters • Tubing • Nitril and/or latex gloves • Water level indicator • Leatherman® or other cutting tool • Calibrated Water Quality Meter - pH, conductivity, temperature, turbidity, dissolved

oxygen, oxygen reduction potential • Ferrous iron field kit • Stop watch • Graduated cylinder • Purge containers (5-gallon buckets) • Sample bottles and materials (labels, preservative, plastic baggies, coolers, ice) • Bubble wrap and/or other packaging material • Decontamination equipment (potable water, deionized water, tubs, brushes, detergent) • Logbook, sampling forms, COCs, pens, sharpies, calculator • Cell Phone 1.2 GROUNDWATER SAMPLING Groundwater sampling will be performed at the subject property. All sampling procedures and data shall be recorded in the field logbook. Additionally, all sampling data shall be recorded on a unique monitor well purging/sampling form. Field Sampling Forms are presented at the end of this attachment. Before groundwater sampling begins, wells shall be inspected for signs of tampering or other damage. If tampering is suspected, (i.e., casing is damaged, lock or cap is missing) this shall be recorded in the field logbook and on the well sampling form, and reported to the URS Project Manager. Wells suspected to have been tampered with, shall not be sampled until the Site Coordinator has discussed the matter with the Project Manager. Before the start of sampling activities, plastic sheeting shall be placed on the ground surrounding the well and/or sampling surface. The plastic sheeting shall be used to provide a clean working area around the well monument and prevent any soil

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contaminants from contacting sampling equipment. Standing water, if present, will be removed from the monument prior to venting and purging. 1.2.1 Groundwater Level Measurement Prior to each time a well is sampled, and prior to installing other equipment into the well casing, water level measurements shall be performed to determine the water table or piezometric surface elevation. Any conditions (e.g., precipitation) that may affect water levels shall be recorded in the field log. The field log shall also include the previous water-level measurement for each well to evaluate if the current water level is consistent. The groundwater level shall be measured to the nearest 0.0l foot using an electric water-level indicator. Two or more sequential measurements shall be taken at each well until measurements agree to within + or – 0.01 foot. The probe and attached tape will be thoroughly washed with a solution of phosphate-free, laboratory-grade detergent (Liquinox or equivalent) and distilled water, and rinsed with distilled water before use in each well. The water-level indicator will be constructed of chemically inert materials to prevent equipment damage and cross-contamination between wells. Water levels shall be measured from the notch located at the top of the well casing and recorded on the well sampling form. If well casings are not notched, measurements shall be taken from the north edge of the top of the well casing, and a notch shall be made using a decontaminated metal file. After sampling is complete, the total depth of the well will be measured by slowly inserting the probe to the bottom of the well until resistance is felt. Insert the probe slowly to minimize disturbance of any sediment that may have accumulated in the well. Well total depth shall be recorded in the field logbook and on the groundwater sampling form. The water level depth shall then be subtracted from the total depth of the well to determine the height of the water column present in the well casing. The measured total depth of the well will be compared to well construction details to ascertain the thickness of accumulated sediment, if any. The calculated thickness of well sediment will also be recorded in the logbook and on the groundwater sampling form. All water level and total depth measuring devices shall be routinely checked with a steel tape measure to ensure accurate measurements. The wells will be capped and locked following measurement of the well total depth. Well caps will be loosely fixed to the well so that the water level in the well will equilibrate with atmospheric pressure. Allowing the well to equilibrate with the atmosphere results in more accurate static water level measurements. The water level indicator probe and cable will be decontaminated before use at each well by washing the probe and cable with a Liquinox detergent and potable water solution and then thoroughly rinsing with distilled water. Waste handling procedures are provided below.

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1.2.2 Low-Flow Purging Procedure The following information shall be recorded each time a well is purged prior to sampling: • Weather conditions (precipitation, wind and temperature); • Condition of each well; • Depth to water before and after purging; • Flow rate, total volume purged and well bore volume calculation; • Sounded total depth of the monitor well; and • Field parameters, such as pH, temperature, specific conductance, dissolved oxygen

and turbidity collected while purging. A low-flow, minimal draw down technique will be used for monitoring well purging and sampling at this site. This procedure induces laminar (non-turbulent) flow and is designed to ensure that samples collected from the wells are representative of groundwater. The low-flow rates minimize disturbance in the screened aquifer, resulting in: (1) minimal production of artificial turbidity and oxidation; (2) minimal mixing of chemically distinct zones; (3) minimal loss of volatile organic compounds; and (4) collection of representative samples while minimizing purge volume (Puls & Barcelona, 1996). Low-flow purging typically consists of pumping water from the sampled well at a flow rate of approximately 0.1 to 0.5 L/min. However, the flow rate is dependent upon site-specific conditions. Some extremely coarse-textured formations have been successfully sampled in this manner at flow rates to 1 L/min. Following water-level measurement (Section 1.2.1), the well tubing will be positioned adjacent to, or slightly above the midpoint of, the screened interval and the tubing shall be equipped with a positive foot check valve to prevent purged water from flowing back into the well. Care will be taken to gently insert the tubing to minimize disturbance of any sediment that may have accumulated in the well. Equipment shall not be allowed to free-fall into a well. Purging will proceed by pumping groundwater from the well at a rate of approximately 0.1 to 0.5 L/min. The flow rate will be measured by filling a 1-liter graduated cylinder and measuring the flow rate using a stopwatch. During purging, the water level in the well will be monitored at least every three to five minutes to ensure that the water level is not receding and allowing water to cascade down the sides of the well screen. Cascading can aerate the groundwater, possibly affecting its chemical characteristics. During purging, specific conductance, temperature, pH, dissolved oxygen and turbidity of the produced water will be measured every three to five minutes using a Horiba™ U-22 water quality meter (or similar) and flow-through cell. The water-quality meter will be calibrated at the start of each field day, prior to sampling, according to the manufacturer’s instructions. All water-quality measurements made during purging will be recorded on a groundwater sampling form. When water-quality readings have stabilized over three

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measurements, purging may cease and samples may be collected. Stabilization is reached when three successive readings are within ±0.1 for pH, ±3 percent for conductivity and ± 10 percent for dissolved oxygen and turbidity (Puls & Barcelona, 1996). If one or more of the readings have not stabilized within one hour, samples will be collected and the unstable readings will be noted on the sampling form. Wells will be purged using a peristaltic pump and dedicated polyethylene tubing. The low-flow sampling technique described above will be used. If a well goes dry during purging, the well will be allowed to recharge before collecting the sample. This condition shall be noted in the field logbook and well sampling forms. 1.2.3 Alternative Well Sampling Procedures An alternative to low-flow purging is to remove at least three well volumes from the well before it is sampled. Groundwater elevation measurement procedures are provided in Section 1.2.1. One well volume can be calculated using the following equation (reference: Ohio EPA Technical Guidance Manual for Hydrogeologic Investigations and Ground Water Monitoring Programs, June 1993):

V = H x F where V = one well volume H = the difference between the depth of well and depth to water (ft) F = factor for volume of one foot section of casing (gallons) from below.

Volume of Water in One-Foot Section of Well Casing

Diameter of Casing (inches)

F Factor (gallons)

1.5 0.09 2 0.16 3 0.37 4 0.65 6 1.47

F can also be calculated from the formula: F = π(D/2)2 x 7.48 gal/ft3

where D = the inside diameter of the well casing (inches) and pi is approximated by 3.14. Wells with yields too low to produce three well volumes before the well goes dry shall be purged to dryness and sampled following water level recovery. This condition shall be noted in the field logbook and well sampling forms. Purge water temperature, pH, specific conductance, DO, ORD, and turbidity shall be measured and recorded on the well sampling form after removing each well volume during purging. Water removed from the well during purging shall be containerized.

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Detailed information concerning disposal of investigative derived wastes is presented below. 1.2.4 Groundwater Sample Collection Sampling can be initiated after water-quality parameters have stabilized in accordance with Section 1.2.2. Before collecting groundwater samples, the sampler shall don clean, phthalate-free protective gloves. In-line water-quality measurement devices should be disconnected or bypassed during sample collection. Sampling flow rate may remain at the established purge rate or may be adjusted slightly to minimize aeration, bubble formation, turbulent filling of sample bottles or loss of volatiles due to extended residence time in tubing. Typically, flow rates less than 0.5 L/min are appropriate. The same device will be used for sampling as was used for purging. For metals analysis samples will be field filtered using inline filters of 0.45 μm filtering capacity. Required sample containers, preservation methods, volumes and holding times are provided in Table 3. Sampling equipment shall be decontaminated in accordance with Section 3.0: Equipment Decontamination, following completion of sampling activities. 1.3 SAMPLE HANDLING 1.3.1 Sample Containers All samples will be collected into glass or plastic containers supplied by TestAmerica Laboratories. Sample containers shall be stored in clean areas to prevent exposure to fuels, solvents, and other contaminants. Appropriate soil and groundwater sample container information including preservation techniques, required volumes and holding times is provided in Table 3. 1.3.2 Sample Hold Time Sample holding time tracking begins with the collection of samples and continues until the analysis is complete. Holding times for methods utilized in this study are specified in Table 3. Holding times for samples collected from wells that purged dry will be counted from the first day of sample collection. 1.3.3 Sample Preservation Sample preservation procedures are used to maintain the original character of analytes during storage and shipment. Before shipping sample bottles to the field, the contract laboratory will add the required preservatives to the sample bottles that will be used for groundwater and equipment blanks. The laboratory will also provide a small container of the appropriate acid(s) in case additional preservative must be added in the field. The laboratory will affix waterproof labels to the bottles, on which the type of analysis and the type and amount of preservative will be written. Samples not preserved in accordance with these requirements shall be resampled and analyzed.

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All groundwater samples will be placed in the appropriate sample containers and chilled (on ice or an ice-substitute in a cooler) immediately upon sample collection. The samples will be submitted to TestAmerica Laboratories of Spokane, Washington for laboratory analysis. Samples will be submitted under chain-of-custody. 1.3.4 Storage Requirements Samples will be placed in secure, on-site storage, or remain in the possession of the sampling personnel until they are delivered to the laboratory. Immediately after collection, and during shipment to the analytical laboratory, samples will be stored in coolers on ice or an ice-substitute at approximately 4°C. Either ice packaged in plastic storage bags or prepackaged ice substitute will be used to maintain the temperature in the shipping containers at approximately 4°C. Ice will be replenished as needed to ensure adequate cooling of samples during storage. Cubed ice will be double-bagged. Prepackaged ice substitute will also be placed in a Ziploc storage bag. 1.3.5 Sample Identification To provide a sample tracking mechanism, each sample collected will be given a unique sample identification number using the numbering system described below. The sample identification number will include the site name, sample type, well number, and date. Example 1: A primary groundwater sample collected from monitoring well number

MW-1 on November 9, 2008 would be labeled SIA-MW1-110908. SIA = Site, MW-1 = Monitor Well and Well Number, 110908 = date.

Matrix spike/matrix spike duplicate (MS/MSD) samples will not be designated in the primary sample number. The sample to be used for MS/MSD will be specified in the comments section of the chain of custody. Sample labels, whether blank or preprinted, will contain an abbreviated summary of the logbook entry for the sample. The following information should be included on sample container labels: • URS project number • Sample identification number • Date and time of sampling • Name of sampling personnel • Type of sample preservatives • Matrix (incorporated as part of the sample identification number) • Analyses to be performed

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1.4 SAMPLE CUSTODY Procedures to ensure the custody and integrity of the samples begin at the time of sampling and continue through transport, sample receipt, preparation, analysis and storage, data generation and reporting, and sample disposal. Documentation of the custody and condition of the samples is maintained in field and laboratory records. URS personnel shall maintain chain-of-custody records for all field samples while samples are in their possession and until relinquished to the analytical laboratory. All sample containers shall be sealed in a manner that shall prevent or detect tampering if it occurs. In no case shall tape be used to seal sample containers. The following minimum information concerning the sample shall be documented on the chain of custody. • Unique sample identification • Date and time of sample collection • Source of sample (including name, location, and sample type) • Designation of MS/MSD • Preservative used • Analyses required • Name of collector(s) • Serial numbers of custody seals and transportation cases (if used) • Custody transfer signatures and dates and times of sample transfer from the field to

transporters and to the laboratory or laboratories • Bill of lading or transporter tracking number (if applicable) Samples collected in the field shall be transported to the laboratory as expeditiously as possible. When a 4°C requirement for preserving the sample is indicated, the samples shall be packed in ice or chemical refrigerant to keep them cool during collection and transportation. 2.0 FIELD MEASUREMENTS FOR GROUNDWATER 2.1 GROUNDWATER MONITORING INSTRUMENTATION, CALIBRATION

AND QUALITY CONTROL Instruments to be used during field activities that require calibration by field personnel are the Horiba™ U-10/U22. 2.1.1 Horiba™ Water Quality Meter The Horiba™ Water Quality Meter will be used to measure the groundwater quality parameters (pH, specific conductance, turbidity, temperature and DO). The Horiba will be calibrated daily according to the manufacturer’s instructions using stock pH,

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conductivity and turbidity standards. Atmospheric oxygen will be used to calibrate the DO element. If the measured calibration concentration is not within 5% of the standard concentration, the meter will be recalibrated according to the manufacturer’s instructions. Alternatively, the manufacturer will be contacted for assistance. If these alternatives do not result in a properly calibrated meter, a replacement unit will be obtained. Calibration data will be recorded in the field logbook. The meter calibration will be performed in accordance with manufacturer's instructions. 2.1.2 Water Level Indicator The water level indicator will be used to measure groundwater. The 9-volt battery will be replaced as needed. 3.0 EQUIPMENT DECONTAMINATION The objectives of equipment decontamination are to prevent the introduction of contaminants into samples from sampling equipment, the environment or other samples. This section outlines procedures that will be followed to meet decontamination objectives. Groundwater sampling equipment shall be decontaminated between sample locations (monitor wells) using the following procedure: • Scrub equipment thoroughly with phosphate free detergent (Liquinox) and potable

water using a brush to remove any particulate matter or surface film; the submersible pump (if used) will also be flushed with phosphate-free detergent and warm potable water;

• Rinse and/or flush with clean potable water; • Triple rinse and/or flush with clean deionized water; • Package and seal equipment in appropriate containers to prevent recontamination; Non-dedicated sampling equipment that comes in contact with sampled water (such as water level indicators, sampling pump, hose assemblies, dippers, and filtration apparatus) will be decontaminated before and after each use. Meter sensors that contact sample water will be thoroughly rinsed with distilled water. The water level indicator probe and cable will be decontaminated before use at each well by washing the probe and cable with a Liquinox detergent and potable water solution and then thoroughly rinsed with deionized water. 4.0 WASTE HANDLING 4.1 GENERAL WASTE HANDLING PROCEDURES Waste may be classified as non-investigative or investigative-derived waste. Non-investigative waste such as litter shall be collected on an as-needed basis to maintain each site in a clean and orderly manner. This waste shall be containerized and transported to

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the designated sanitary landfill or collection bin. Acceptable containers shall consist of sealed boxes or plastic garbage bags. Investigation-derived waste (IDW) generated during the project will be stored, handled, and disposed of according to this section. The IDW guidelines presented in this section were set forth in Management of Investigation-Derived Wastes during Site Inspections (EPA 1991). According to the EPA guidelines, the most important elements of managing IDW include: • Leaving the site in no worse condition that existed before the investigation • Removing wastes that present an immediate threat to the human health or the

environment • Complying with federal and state ARARs to the extent practicable • Planning and coordination of IDW management • Minimizing the quantity of generated wastes The IDW shall be segregated at the site according to matrix (solid or liquid,) and as to how it was derived (decontamination fluids and purged groundwater). Each container shall be properly labeled with site identification, sampling point, depth, matrix, constituents of concern, and other pertinent information for handling. 4.2 EXPECTED TYPES OF IDW The methods for handling and disposing of IDW generated at the site were developed under the assumption that it is unlikely that any IDW generated during this project will require special handling or disposal. The following types of IDW may be generated during this project. 4.2.1 Purge Water During development and purging of monitoring wells, field personnel will observe the produced water for visual and olfactory evidence of contamination. Use of low flow, minimal draw down sampling procedures greatly reduces the volume of water produced during monitoring well purging. All purge water will be allowed to flow to the ground. We expect that the purge water volume will be minimal and concentrations of likely contaminants will not represent an immediate threat to human health or the environment. 4.2.2 Decontamination Solutions Decontamination solutions will consist of a mixture of Liquinox nonphosphatic laboratory detergent and potable water. Liquinox is nontoxic, nonhazardous, and biodegradable. Approximately two gallons of Liquinox solution will be generated at each well from decontamination of sampling pumps and other reusable equipment.

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Decontamination water will be allowed to flow to the ground downgradient (east) of each well. 4.2.3 Personal Protective Equipment The sampling tasks to be performed for this project will be performed in Level D personal protective equipment (PPE). The only PPE that will require disposal is expected to be used latex gloves. All used PPE will be bagged and disposed with other inert solid wastes. 4.2.4 Solid Wastes Nonhazardous solid wastes (i.e., used paper towels, used gloves, used tubing) will be placed into plastic refuse sacks and discarded into a solid waste receptacle.

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