Mr. Geoffrey Wilson,President and CEO, Toronto Port Authority (TPA), in a March 10 email, tookissue with CommunityAIR’s Brian Iler’s observation that the TPA was in breachof Section 20 of the Tripartite Agreement. 

DRAINAGE AND DISCHARGE OF MATERIAL

20.  The Lesseeshall not discharge, cause or permit to be discharged or

howsoever to pass into the sewer systems, storm drainsor surface drainage facilities at the demised premises, if any, or elsewhereany noxious, contaminated or poisonous substances; it being expresslyunderstood and agreed that in the event of a discharge or escape from thedemised premises of such noxious, contaminated or poisonous substances in andunder the control of the Lessee, the Lessee shall be responsible to clean up tothe satisfaction of the Lessor al no cost to the Lessor.

Mr. Wilson wrote, “I'm afraid your assertion about breaches of theTripartite below (Section 20) is rather incorrect.”  Before examining Mr. Wilson’s argumentthat the TPA handles de-icing contaminants in a way that does not contraveneSection 20, a little background is in order.

On March 21, 2002, Dr. Sheila Brasur tabled a staff reportfor the Toronto Board of Health, Management of De-icing Activities at Toronto Lester B. PearsonInternational.

http://www.toronto.ca/health/hphe/pdf/deicingactivities.pdf  The report is an update on the measures thatthe Greater Toronto Airport Authority (GTAA) took at Pearson to mitigate thehealth and environmental effects of de-icing fluids discharged into thesanitary sewer system.

The report touches on the composition of the de-icing fluidsand their contaminating effects. 

“The activecomponent of aircraft de-icing or anti-icing fluids is ethylene glycol orpropylene glycol. Ethylene glycol is the active component in aircraft de-icingor anti-icing fluids used at Toronto Pearson International Airport. Althoughits toxicity is relatively low and it breaks down readily in the environment,rapid loading of large volumes of de-icing fluids into the surface water bodiescan lead to oxygen depletion, threatening the survival of aquatic life. Ethyleneglycol-based de-icing products are about 3-10 times more toxic to aquaticorganisms than pure ethylene glycol due to the presence of small amounts (about1%) of additives in the formulations. One of these is tolyltriazole, which functions as a corrosion inhibitorand a flame retardant.”

Clearly,untreated de-icing fluids are ‘noxious, contaminated or poisonous substances’.

Pearsonopened their Central De-Icing Facility (CDF) in 1998 and expanded it in1999/2000.  The facility’s purpose is tominimize the release ofcontaminants to the surrounding waterways. It does so by minimizingethylene glycol consumption and spillage as well as collecting, treating andsafely disposing of the chemical.

Usinga series of containment tanks and strict analysis, the CDF ensures that the Canadian Environmental ProtectionAct (CEPA) Part IV effluent guideline of 100 mg/L (i.e. 0.01%) at airports ismet before any discharge enters stormsewers.

As MsBrasur’s report points out, the GTAA conducts an annual review of its de-icingoperations and based on the findings endeavours to improve its operations andstormwater management plans.  The Compliance Manager for theOntario Clean Water Agency visits the facility weekly and is on 24-hour call totrouble shoot.  The GTAA  also allows Toronto Public Health to examineits facility. 

TheToronto Port Authority’s de-icing contaminant procedures are not quite asdetailed.  The Authority’s website http://www.torontoport.com/PortAuthority/airport_facts.aspoffers this description.  “TCCA has had a water sampling and mitigationprogramme in place since 1992. All storm water discharged into Lake Ontario isclosely monitored and tested. TCCA has created a new Glycol Containment Areawhere the run-off goes directly into storm sewers connected to Metro TorontoSanitary Sewage Network.”

Anothersource, the TPA’s consultant, Dillon Consulting Limited, wrote, “The Aircraftde-icing is carried out within specified areas of the terminal ramp wheresurface runoff is directed to a glycol collection system. This system ensuresthat there is no discharge to the surrounding water areas. The glycol/watermixture is discharged via the Metropolitan Toronto Sanitary Sewer system fortreatment.”  Source: Proposed Fixed Link Bridge to the TCCA, Final Ea Screening Report, P.45 Appendix A, Toronto Port Authority, August, 2003.

Mr. Wilson’s March 10, 2010 email doesn’t shed much more light on thematter.  He wrote, “The removal of deicing fluid does not enterthe sewer system.  Thisliquid waste or deicing fluid is collected through a series of catch basins onthe main apron which is separate from the storm water drainage sewers anddischarge areas.   From thecatch basin, the drainage flows to the Island’s sanitary treatment facility asper the Tripartite Agreement.   Sampling and analysis is conducted in order to confirm compliance withapplicable Sewer Use By-Laws.”

There areproblems with either Mr. Wilson’s understanding of the TPA’s handling of thede-icing fluid or with the TPA’s mitigating measures themselves.

For onething, there is no Island sanitary treatment facility.  By Mr. Wilson’s admission, the TPA is dumpingthe liquid waste into the sanitary sewer system.  It flows into the Ashbridges Bay facility.

Foranother thing, although the airport’s discharge is sampled and analyzed, thereis no indication that it is recycled or treated to meet the CEPA guideline,applicable sewer use bylaws notwithstanding.

Incomparing the available information on the treatment of de-icing fluid at thetwo airports, we can readily see that the GTAA has a transparent,sophisticated, effective process that invites outside scrutiny.  On the other hand, the TPA’s process remainslittle known or understood and depends on insiders and second party sources todescribe its basic workings.

We candraw a parallel between the TPA’s openness on its treatment of de-icing fluidand on its position on the number of slots available for commercial air carriersusing the airport.  In both cases itappears to be, ‘trust us; our consultants assure us that what we say willfly’.  As long as the TPA operates in thesame secretive manner, it will be open to charges that it’s contravening theTripartite Agreement. 

In the case of de-icing fluidentering the sewer system, the TPA’s word is not good enough.  The TPA must open its doors to Toronto PublicHealth and the Ontario Clean Water Agency.

Bob Kotyk