March 29, 1998
OPPT Document Control Officer (7407)
Office of Pollution Prevention and Toxics
Environmental Protection Agency
401 M Street, SW
Room G-099, East Tower
Washington, DC 20460
RE: NRDC Petition on SIC Code 45
Ms. Lynn Goldman
Assistant Administrator for Prevention, Pesticides and Toxic Substances
Environmental Protection Agency
Dear Ms. Goldman,
Citizens for the Abatement of Aircraft Noise (CAAN) writes to strongly support the petition of the Natural Resources Defense Council, Defenders of Wildlife, National Audubon Society and Humane Society of the United States requesting that EPA require SIC Code 45 facilities (airports, airline terminals and aircraft maintenance facilities) to report releases of toxic chemicals listed on the toxic release inventory.
As part of its ongoing efforts CAAN, who considers all form of airport pollution a serious matter, has recently learned of the lack of monitoring and control of toxic chemicals released into the air and deposited into the Potomac River from the activities at our two airports, Washington National Airport and Dulles International Airport. In the case of water discharges we were under the impression that EPA, the State of Maryland Department of Natural Resources and the District of Columbia were monitoring the quality of the water coming from the Potomac River which is our drinking water supply. We find we were wrong. Little or no monitoring is done according to representatives from these three agencies.
Both airports are using large quantities of deicer and anti-icing chemicals and have no methods for recovering them before they reach the Potomac River. Although Dulles has a holding pond from which the overflow material ultimately reaches the river, National Airport is situated directly adjacent to the river and toxic material is allowed to flow directly into it. Furthermore, although National has a discharge permit to dump untreated storm water mixed with these toxic chemicals into the river, they have never, to our knowledge, had a permit to discharge process waste water into the river. We find this appalling! If they had been required to report their chemical discharge operations under SIC Code 45 regulations, citizens would have been informed of this oversight and would also know to what degree the river was being polluted with these and other toxic chemicals used by the airports.
Additionally, not knowing what is being done to our river with regard to these aviation pollutants, leaves us ignorant of what effect operations at National are having on the wildlife refuge just north of the airport. Because the Potomac is subject to tidal action at that point of the river, chemical discharges from National Airport, instead of going downstream, can drift directly back into the refuge. We would like to know what damage is being done, but there is no data available.
With respect to air pollution caused by the two airports, the situation at National Airport is by far the worst. Whereas Dulles has 12,000 acres and can have their aircraft achieve reasonable altitudes before passing into adjacent residential communities, National Airport has only about 800 acres to conduct all its operations. Consequently, arriving and departing commercial aircraft are flying low for several miles over residential communities before reaching the airport. On a warm day, one has no difficulty in smelling the jet fuel in these communities. Is this situation dangerous to these residents? Again, there is no data available to indicate the level of this air pollution. Data from the King County Public Health Department in Washington State suggest that the long term consequences are significant.
As you no doubt know, both airports are large operations, handling an aggregate of 29 million passengers per year. The impact of air pollution and discharges into the Potomac River on the metropolitan Washington area population can only be surmised. The Washington area public needs to know how much damage is being done, and the only way we can get this information is through regularly required reporting via the Emergency Planning and Community Right to Know Act and SIC Code 45. We urge you to grant the NRDC petition and hold rule making hearings.
for the Board of Directors