MEMORANDUM

TO:		Mr. Brian D’Amico, USEPA/OW/OST/EAD	

FROM:	Ms. Mary Willett, ERG

DATE:	October 31, 2006

SUBJECT:	Meeting with DOW Deicer Product Representatives on October 19,
2006

On October 19th, EPA and ERG met with DOW deicer product representatives
to discuss the status of current Agency efforts on the airport deicing
operations effluent guideline development and to obtain information from
DOW concerning their deicer products.  Attendees at the meeting
included:

Mr. Brian D’Amico, EPA

Mr. James Covington, EPA

Mr. Jesse Pritts, EPA

Mr. Eric Strassler, EPA

Ms. Ashly Allen, EPA

Mr. Lemuel Walker, EPA

Ms. Mary Willett, ERG

Ms. Cheryl Wizda, DOW, R&D, Deicers/Peformance Fluids

Mr. Jim Williams, DOW, EH&S Expertise Center

Ms. Connie Deford, DOW, EH&S Global Product Leader, Specialty Chemicals
(via phone)

Mr. Kendall Justiniano, DOW, Marketing Manager (via phone)

Mr. Rich Tarantino, EH&S Product Steward Specialist, Specialty Chemicals
(via phone)

Mr. Keith Belton, DOW, Director DOW Washington Office

The following topics were discussed:

Status of EPA Efforts

Mr. Eric Strassler provided an overview of current EPA efforts.  Work on
the current guideline effort started in late 2004 and EPA/ERG have been
conducting data collection efforts to date.  These efforts include
characterization sampling at the Minneapolis/St. Paul and Detroit
airports in the winter of 2005 and sampling of treatment performance at
the Albany, Pittsburgh, Denver, and Rockford airports during the winter
of 2006.  During 2005, EPA/ERG also worked on questionnaires to solicit
information from both the airports and the airlines.  The airport
detailed questionnaires and the airline screener questionnaires were
sent out in April of 2006.  The airline detailed questionnaire will be
sent to a statistically derived sample set of airlines which is
currently being developed.  EPA anticipates sending out the airline
detailed questionnaires in November of 2006.

Also during this timeframe, EPA has conducted about 20 airport site
visits and has been collecting information on the technologies and
practices that are common to the airport deicing operations industry.

Currently, EPA has published a schedule to propose in December 2007. 
Due to the timeframe for getting out the airline detailed
questionnaires, this schedule may slip back by a few months.

The various stakeholders that EPA has been working with to date include;
the airports, airlines, industry trade associations, vendors (including
the recycle/recovery vendors), and environmental entities (NRDC).

Overview of Deicer Products by DOW

Ms. Cheryl Wizda then provided a presentation on DOW deicer products. 
The presentation slides are included here as Appendix A.  Some of the
main topics/points made during the presentation included the following:

There are not that many deicing fluid manufacturers around the world. 
DOW is a major supplier in North America (including U.S. and Canada). 
Currently DOW only provides wing (aircraft) deicing products and the
company exited the airfield deicing chemical business in 2003. 
Previously Union Carbide was a supplier of deicing chemicals and the two
units have merged into one (under the DOW name).

DOW is the only integrated supplier of both ethylene and propylene
glycol based fluid systems which means they manufacture their deicer
products starting from glycol to the final product all in-house.

DOW has a continual reformulation effort directed at improving product
performance.  This includes communication with the product users during
the deicing season.  DOW provides analysis assistance at various points
in the utilization process to ensure that performance requirements are
and can be met.  In general, minimal support is needed for Type I fluids
which are fairly simple to use and more support is needed for the Type
IV fluids which are sensitive to sheer forces or contamination that can
compromise performance.

DOW conducts “Product Stewardship” covering all stages of their
product’s life including R&D, manufacturing, quality assurance
monitoring, distribution, and marketing.  Part of this effort includes
safety and use information for product users, monitoring of the use and
disposal of their products, incorporation of stringent distributor
requirements, an internal Business Risk Review, and manufacturing and
quality assurance programs and procedures.

Ms. Wizda then provided an overview of the current DOW deicing products,
both ethylene glycol and propylene glycol –based.  DOW started making
propylene glycol-based fluids in 2002.  In 2004, they reformulated the
fluids to make them triazole-free.  They have since moved to a
triazole-free formulation for the ethylene glycol-based fluids as well.

See the slides in Appendix A for information on the glycol content for
each product and information on the biodegradation and aquatic toxicity
for the products.  Some items of note from this part of the presentation
included:

Type IV fluids require more additives to provide the appropriate
performance level.  As such, the Type IV products have greater toxicity
than the Type I products.

DOW’s propylene glycol Type IV fluid formulation is very similar to
that of the other propylene glycol formulations currently on the market
by other manufacturers.

DOW’s Type IV UCAR Ultra+ fluid is manufactured using a patented
technology that makes the fluid shear-resistant so that pumping of the
fluid will not degrade the product performance.

Ms. Wizda then provided an overview of the SAE AMS specifications that
apply to deicer chemicals.  All products must be certified and currently
there are two labs that perform 3rd party certifications; Amiel Lab in
Canada and the SMI lab in Miami, Florida.  The slide on this topic
includes information on the range of costs associated with the required
certifications.

SAE does not currently have an environmental subcommittee for the deicer
products.  When asked why not, Ms. Wizda indicated that the committee
members qualified for such a committee are not currently available and
are busy with other needs.

The group discussed the ingredients in DOW’s deicer products by
category.  Ms. Wizda  commented on the following specific additives:

In general the industry uses one particular class of thickeners, though
performance levels among the various individual chemicals within that
general class vary widely.  There are a few special thickeners being
developed.

Surfactants are needed to get a good wetting effect with the fluid. 
Some surfactant ingredients may also act as a thickening agent as well.

Additives for pH control are used to produce products with a neutral pH
(7 - 8.5 or 9.5 pH is typical).  In addition, ingredients may be added
to the fluids to provide hard water stability.

Triazoles became a component of the deicer products as part of flame
retardant requirements.  Several years ago, there was concern about
electrical circuit fires and the need for inflammabilty of the deicing
fluids.  SAE considered requiring fluid manufacturers to include 0.5%
toly triazoles in the fluids.  DOW pointed out that because of the
potential environmental impacts and a better understanding of the
flammability risk, triazole use is not required.  Ms. Wizda also noted
that there are only a few flame retardants available for use in deicing
fluids.

While most deicer products have dyes in them (orange for Type I and
green for Type IV products), the manufacturers can produce and get
certification for undyed products.

The group discussed trends related to deicing operations.  Ms. Wizda
noted that FBOs commonly perform deicing operations at the airports in
Canada and their use is expanding here in the U.S.  However, DOW does
not see the deicing operation sector as becoming controlled by a few
large FBO companies.  EPA noted that our airline screener responses
showed a large variety in the entities providing deicing operations.

One issue that is under review is residue issues on planes operating in
Europe.  There have been 88 incidents of a loss or impairment of flight
control for European flights due to what is believed to be thickened
deicing fluid residues.  There is an investigation underway to try to
determine the cause(s).  So far, the best guesses for the source of the
problem are:

Europeans tend to use diluted Type IV fluids for deicing (and not just
for anti-icing) as opposed to Type I use.  Thus, there is not the same
level of rinsing that you get with Type I fluid use in the U.S.  This
activity may be leaving behind residue buildup.

In general, European deicing operators do not have as much experience as
their counterparts in the U.S.  This is due in part to the fact that
European airports have fewer deicing events per season and staff
turnover.  Staff sometimes have to go through re-training because it has
been more than six weeks since they have deiced.

There is also the possibility that there may be interaction occurring
between the aircraft deicing fluids and the airfield deicers.

DOW noted that one of the main concerns for their customers is product
availability during the winter season.  To help ensure consistent
supplies, DOW manufactures fluid at a minimum of two locations for each
fluid.  Multiple location manufacturing will also help with fluid
distribution.  The products will go from the manufacturing centers to
various distribution centers.



Appendix A

 

Memorandum

31 October 2006

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