NC0083887_Regional Office Historical File Pre 2018 (5)

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DONALD It.. VAN DER VAART
ZIMMEUIA
Dintor
Certified Mail #7015 1520 0002 6984 7993
Return Receipt Requested
October 31, 2016
Jack Christine, Aviation Deputy Director
City of Charlotte
Post Office Box 19066
Charlotte, NC 28219
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute (G.S.) 143-215,1 6
and NPDES WW Permit No. NC0083887
City of Charlotte
Charlotte Douglas International Airport
Case No, MV-2016-0014
Mecklenburg County
Dear Mr. Christine:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $296.00 ($195.Q0 civil penalty +
$101.00 enforcement costs) against City of Charlotte,
This assessment is based upon the following facts: a review has been conducted of the discharge monitoring report (DMR)
submitted by City of Charlotte for the month ofJune 2016. This review has shown the subject facility to be in violation of
the discharge limitations and/or monitoring requirements found in NPDES WW Permit No. NC0083887. The violations,
which occurred in June 2016, are summarized in Attachment A to this letter.
Based upon the above facts, 1 conclude as a matter of law that City of Charlotte violated the terms, conditions or
requirements of NPDES WW Permit No. NC0083887 and G.S. 143-215.1(a)(6) in the manner and extent shown in
Attachment A. In accordance with the maximums established by G.S. 143-215,6A(a)(2), a civil penalty may be assessed
against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the Secretary
of the Department of Environmental Quality and the Director of the Division of Water Resources, 1, W. Corey Basinger,
Regional Supervisor, Mooresville Regional Office hereby make the following civil penalty assessment against City of
Charlotte:
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

$50.00 for 1 of the 1 failures to properly monitor BENZENE in violation of Permit No. NC0083887,
$70.00 for 1 of the 1 failures to properly monitor ETHYLBEN in violation ofPermit No. NC0083887,
$50.00 for 1 of the 1 failures to properly monitor TOLUENE in violation of Permit No. NC0083887.
$25.00 for 1 of the 1 failures to properly monitor XYLEN1 in violation of Permit No. NC0083887,
$195.00
$101.00
$296.00
TOTAL CIVIL PENALTY
Enforcement Costs
TOTAL AMOUNT DUE
Pursuant to G.S. 143-215,6A(c), in determining the amount of the penalty I have taken into account the
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
The degree and extent of harm to the natural resources of the State, to the public health, or to
resulting from the violation;
The duration and gravity of the violation;
The effect on ground or surface water quantity or quality or on air quality;
The cost of rectifying the damage;
The amount of money saved by noncompliance;
Whether the violation was committed willfully or intentionally;
The prior record of the violator in complying or failing to comply with programs over which
Management Commission has regulatory authority; and
The cost to the State of the enforcement procedures.
Findings of Fact and
private property
the Environmental
Within thirty (30) days of receipt of this notice, you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality (do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted, and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to request remission, you must complete and sub
sed "Re
Waiver of Ri t to an Administrative Hearin and Sti ulation of Facts" form
notice. The Division of Water Resources also re ue
Remission Request"
Both forms should be submitted to the following address:
withi
u corn tete and
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
or Remission of Civil Penalties
30 dads of recei t of this
submit the enc osed "Justification for

Option 3: File a petition for an administrative hearing with the Office of Administrative Hearino:
If you wish to contest any statement in the attached assessment document you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile (fax) or electronic mail by an attached file (with restrictions) - provided
the signed original, one (1) copy and a filing fee (if a filing fee is required by NCGS 5150B-23.2) is received in the
Office of Administrative Hearings within seven (7) business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
tiling process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DEQ as folio s:
Mr. Sam M. Hayes, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one ofthis letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal
date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions, please contact Wes Bell with the Division of ater Resources staff of the Mooresville Regional
Office at [phone] or via email at [e-mail].
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File

JUS
Case Number: MV-2016-0014
Assessed Party: City of Charlotte
Permit No.: NO0083887
ICATION FOR REMISSION REtUET
Coun
Amount Assessed:
Mecklenburg
$296.00
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Nearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the
how payment of the
compliance).
ANATION:
vil penalty will prevent payment for the remaining necessary remedial actions (Le. explain
ivil penalty will prevent you from performing the activities necessary to achieve

STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
IN T 1 ITER OF ASSESS NT
OF CIVIL PENADIES AGAINST
City of Charlotte
Charlotte Douglas International Airport
PERMII NO, NC0083887
DEPARTMENT OF ENVIRONMENTAL QUALITY
W. R OF ITIGEIT TO AN
AD IS T t1E1 G AND
STIPULATION OF FACTS
CASE NO.
4016-0014
Having been assessed civil penalties totaling for violation(s) as set fonh in the assessment document of the Division
of Water Resources dated October 31, 2016, the undersit ed, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned ftrther understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the
notice of assessment.
This the
day of 20
SIGNATURE
ADDRESS
TELEPHONE

ATTACHMENT A
City of Charlotte
CASE NUMBER: V-20 6-0014
PERMIT: NC 083887
FACILITY: Charlotte Douglas International Airpo
MONITORING `IOLATIO
SAMPLE LOCATION: Outfall 001 - Effl nt
Violation Report
Date Mont r
6/3 12016 - 01 Benzene
6J3012016 -2016 Ethyltaenzen
REGION: on �hville
COUNTY: klenburg
Unit of Calculated % Over Violation Penalty
Frequency Measure Value Value Limit Type ount
Monthly uJl Frequency
Violation
Monthly ugit
6F30i2016-2016 Toluene
Monthly
6C30i2016 6-2016 . ylene (mix of rn °o+ Monthly
uli
Frequency
Violation
Frequency
Violation
Frequency
Violation
$70.00
2500

Water;esa
ENVIRONMENTAL QUA
February 8, 2017
CERTIFIED MAIL 7009 2250 0000 8087 0934
RETURN RECEIPT REQUESTED
Mr. Jack Christine
Charlotte Douglas International Airport
CLT Center
5601 Wilkinson Blvd
Charlotte NC, 28208
Dear Mr. Christine:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Subject: Request to Remit Civil Penalties - Denied
Decision in. Case Number: MV-2016-001.4
for Charlotte Douglas International Airport
NPDES Permit NC0083887
Mecklenburg County
In accordance with North Carolina General Statute 143-215.6A(f), the North Carolina Division of Water
Resources (the Division) has reviewed your request to remit civil penalties in the subject case. We regret
to inform you that the Director has denied your request.
Therefore, your outstanding balance ($296.00) is due and payable. Two options are available to you at
this stage of the remission process:
) You may pay this balance.
If you decide to pay the penalty, please make your check payable to the Department of Environmental
Quality (DEQ). Send the payment, within thirty (30) calendar days of receiving this letter, to the
attention of:
Attn: Wren Thedford
NC DEQ Division of Water Resources
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
State of North Carolina 1 Environmental. Quality Water Resource
161.7 Mail Service Center I Raleigh, North Carolina 27699-161.7
91. 9-707-9000

2) You may request the Environmental Management Commission's (ENIC's)
Committee on Civil Penalty Remissions (the Committee) to make the final decision
on your remission request considering your additional oral input, as warranted.
If payment is not. received within 30 calendar days from your receipt of this letter, your current request
for remission and this letter of denial will be delivered to the Committee on Civil Penalty Remissions for
final agency decision.
If you or your representative would like to speak before the Committee, you must complete and return
the attached Request Jar Oral Presentation .Form within thirty (30) calendar days of receiving this letter.
Send completed form(s) to:
.Attn: Wren Thedford
NC DEQ Division of Water Resources
WQ Pemiitting Section - NPDES
1617 Mail Service Center
Raleigh, North Carolina. 27699-1617
11.. you make such a request, the EMC Chairman will review the supporting documents and your request
fOr an oral presentation. lf, in his/herjudgment, the Chairman determines that: there is compelling reason
to require a presentation, you will be notified as to when and where you should appear. If your
presentation is not required, the final decision will be based upon the written record.
Please be advised that the EMC's Committee on Civil Penalty Remissions wili make its remission
decision based on the original assessment amount. Therefore, the EMC may choose to uphold the
original penalty and offer no remission, they may agree with the DWR. Director's remission.
recommendation detailed above, or the penalty arnount may be further remi.tted.
If you have any questions about this matter, please contact me at [phone] or via e-mail at
[e-mail].
Attach men
cc.
Sincerely,
Derek C. Denard, Environmental Specialist
Division of Water Resources, NCDEQ
s: Director's Decision; Request for Oral Presentation form
Permittee's Request for Remission
Waver of Rights to Administrative Hearing and Stipulation of Facts
Permittec's Justification for Remission Request
Enforcement File
Central Files

DWR SIGNATURE PAGE
SUMMARY OF REMISSION FACTORS FOR ASSESSING CIVIL PENALTIES
Case Number: MV-20
Region: Mooresville
County: Mecklenburg
Assessed Entity: City of Charlotte — Charlotte Douglas Airport Permit No.: NC0083887
Assessment Factors
El (a) Whether one or more of the civil penalty assessment factors were wrongly applied to the detriment
of the petitioner;
NOT ASSERTED,
(b) Whether the violator promptly abated continuing environmental damage resulting from the
violation:
The permittee asserts that there was minimal or perhaps no environmental. damage as a result of the missed
testing because of the following: the treatment system (managed -containment pond) has been effective with the
last BTEX exceedance occurring in January 2013, sedimentation and pump filters are charged on a regular basis,
the carbon within the GAC treatment canisters was schedule to be replaced the following week, no discharge
occurred from July 4'11 through early August after the missed collection due date of June 30' and follow-up
sampling did not detect. any BTEX analytes,
DWR Notes: The facility has demonstrated a good compliance history with treatment and/or removal of BTEX
from the waste stream.
(c) Whether the violation was inadvertent or a result of an accident:
The permittee asserts that the missed sampling was inadvertent because they did not have the proper sampling
containers (40 ml VOA glassware) on the day sampling was scheduled.
DWR Notes: The permittee reported two separate discharge events during this month (satne week) and failed to
collect the required BTEX samples (monthly sampling requirement). The request states that the laboratory
contactor was on site the last day of the month, which gave no opportunity to reschedule or resample.
(d) Whether the violatorhad been assessed civil penalties for any previous violations:
NOT ASSERTED,
[1] (e) Whether payment of the civil penalty will prevent payment for the remaining necessary remedial
actions:
NOT ASSERTED Not Applicable,
_DECISION (Check One)
Request Denied
.Full Remission 0 Retain Enforcement Cost? 'Yes No
Partial Remission ri (Eher .ount
R. 10/2006
Date

STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF MECKLENBURG
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST:
CITY OF CHARLOTTE
CHARLOTTE DOUGLAS INTERNATIONAL AIRPORT)
DWR Case Number MV-2016-0014
REQUEST FOR ORAL PRESENTATION
1 hereby request to make an oral presentation before the Environmental Management Commission's Committee On Civil Penalty
Remissions in the matter of the case noted above. In making this request. I assert that 1 understand all of the following statements:
• This request will be reviewed by the Chairman of the Environmental Management Commission and may be either granted or
denied,
Making a presentation will require the presence of myself andlor my representative during a Committee meeting held in Raleigh,
North Carolina.
• My presentation will be limited to discussion ofissues and information submitted in my original remission request, and because
no factual issues are in dispute, my presentation will be limited to five (5) minutes in length.
The North Carolina State Bar's Authorized Practice of Law Committee has ruled that the appearance in a representative capacity at
quasi-judicial hearings or proceedings is limited to law ers who are active members of the bar. Proceedings before the Committee on
Remissions are quasi-judicial. You should consider how you intend to present your case to the Committee in light of the State Bar's
opinion and whether anyone will be speaking in a representative capacity for you or a business or governmental entity. If you or your
representative would like to speak before the Committee, you must complete and return this form within thirty (30) days of receipt of
this letter,
Depending on your status as an individual, corporation, partnership or municipality, the State Bar's Opinion affects how you may
proceed with your oral presentation. See www,ncbar.comiethics, Authorized Practice Advisory Opinion 2006-1 and 2007 Formal
Ethics Opinion 3.
If you are an individual or business owner and are granted an opportunity to make an oral presentation before the Committee,
then you do not need legal representation before the Committee; however, if you intend on having another individual speak
on your behalf regarding the factual situations, such as an expert, engineer or consultant, then you must also be present at the
meeting in order to avoid violating the State Bar's Opinion on the unauthorized practice of law,
• If you are a corporation, partnership or municipality and are granted an opportunity to make an oral presentation before the
Committee, then your representative must consider the recent State Bar's Opinion and could be considered practicing law
without a license if he or she is not a licensed attorney, Presentation of facts by non -lawyers is permissible.
If you choose to request an oral presentation, please make sure that signatures on the previously submitted Remission Request form
and this Oral Presentation Request form are: 1) for individuals and business owners, your own signature and 2) for corporations,
partnerships and municipalities, signed by individuals who would not violate the State Bar's Opinion on the unauthorized practice of
law.
Also, be advised that the Committee on Civil Penalty Remissions may choose not to proceed with hearing your case if the Committee
is informed that a potential violation of the statute concerning the authorized practice of law has occurred,
This the day of 20
SIGNATURE
TITLE (President, Owner, etc,)
ADDRESS
TELEPHONE (

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF MECKLENBURG
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
City of Charlotte
Charlotte Douglas International Airport
PERMIT NO, NC0083887
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. IVY'-2O16-OOi4
Having been assessed civil penalties totaling $296.00 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated October 31, 2016, the undersigned, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above -stated: matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the
notice of assessment*
This the r i day of
RECEIVEDINCDECVD R
DEC 01 2015
Water Quality
Perling Section
SIGNATURE
ADDRESS
TELEPHONE
7 bt j - °351

JUSTIFICATION FOR REMISSION REOUEST
Case Number: MV-2016-0014
Assessed Party: City of Charlotte
Permit No.: NC0083887
County: Mecklenburg
Amount Assessed: $296.00
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting docurnents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. I43B-28.2.1(b) were wrongfully applied to the
zdetriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the .violator promptly abated continuing environmental damage resulting from the violation (ie.; explain the
steps that you took to correct the violation and prevent ture occurrences);
(c) the violation was inadvertent or a result of an accident (Le., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (Le., explain
how payment of the civil penalty will prevent youfroin performing the activities necessary to achieve
compliance).
EXPLANATION:
pie,c, $6e et-f4Acti.a. ciocukvtekt LAfi
RECEIVED/NCDEQI AR
D-H 01 2O
Water Quaiity
Permitting Section

REQUEST FOR REMISSION
CITY OFCHARLOTTE
CHARLOTTE OOWGLA5INTERNATIONAL AIRPORT NCOQ83887
CASE: rnv-2016'0024
AMOUNT: $296
(b) We believe that there was minimal or perhaps no environmental damage resultant of the
omitted testing (i.e,"imddont°)because ofthe following:
w The treatment system for this managed -containment pond has been overwhelmingly
effective, and the last recorded incident where any one BTEX constituent exceeded the
permit benchmark was inJanuary 3O23. Given this rare occurrence (one time inthe past 43
months), it is statistically unlikely that DTEX contaminated water was discharged from the
premises and into local surface waters.
~ The sedimentation and pump filters are changed on a regular (monthly) basis, and the
Airport has a contractor scheduled to come tothe facility next week beginning November
21" tmreplace the Carbon within the GA[treatment canisters,
• The follow up sampling was performed nearly as soon as practical after the violation.
Although many days elapsed between the sample collection deadline of June 30and August
m
7 ' it is important to note that the pond is a managed and metered containment structure
from which discharge is (or can be) routinely manually controlled, /t is a fact that no
discharge of water occurred from July 4m through early August.
» Follow-up water wastewater samples collectedin August exhibited no BTEX analytes,
(c) As mentioned in our October 24* correspondence, the cooler provided to our contractor
(Mr. James Smith) by Prism Laboratories, did not include the 48 milliliter VOA containers that
would have been needed to collect, transport, and analyze the samples for the EPA Method
8760 volatile organic compound analySiS. While it might have been possible to acquire the
needed glassware prior to the end of the day expiring, this does not seem to have been an
option based nnour conversations with the technician. Since Mr. Smith was onsite the last day
of the month, collecting the sample the following day would not seem to fulfill the permit
technical requirement any more than returning to the site to collect the sample on the Znd,
3rd,5 morseveral days later.
Mr. Smith has performed the sampling since 2001, and the Airport also has long standing
relationship with Prism Laboratories. While there has been an occurrence of missed sampling
at OutfaU OOI, and admittedly other minor violations over the years, this is an isolated incident
that was unexpected and at least in part, the fault of the laboratory.
In the future' the Airport has committed to receiving the sample containers beno at our
administrative office for inspection prior to delivery of the glassware to Mr. Smith. We believe
bydoing sothat monitoring violations due tnlack ofequipment can beeliminated.

The Airport has made considerable effort to do that which is necessary to comply~ with the
sampling schedule and the benchmarks noted by the expired permit, The pond has been
drained and cleaned 2 times within the past 6 years, sediment filters are changed once per
month, and next week (as stated), the GAC columns which are integral to the overall treatment
of the discharge will be drained, cleaned, and overhauled with new carbon media. These
actions are being done at considerable costs and effort ($1 , labor disposal costs) to
ensure the GC treatment system operates at its optimal performance.
Because of reasons cited, we respectfully ask for remission of the Civil Assessment against the Ci of
Charlotte, in the amount of $296

ATTACHMENT A
City of Charlotte
CASE Nil B •;i V-01-01
PER IT: NC0083887
FACILITY: Charlotte owls International Airport
MONITOFtING VIO TION(S)
REGION: re vlil
COUNTY: Mecklenburg
SAMPLE ATION ® all: 0 - fn nt
Viol on Report
Month/Yr Par
6/3Bd2{ 16 6-2016 Benzene
6/3612016 6-2016 Ethylbenzene
016 6-2016 Toluene
Frequency
nthly ugh'
fonthly ugli
Monthly
Calculated " Oyer Violation Penalty
Value Llrnit Type Amount
6/3 016 6- 616 Xylem rnix of
+pl
ntly unit
Frequency
Violation
Frequency $70,
Violation
Frequency
Violation
0
Frequency
Violation
$25 00

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF MECK.LENBURG
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
City of Charlotte
Charlotte Douglas International Airport
PERMIT NO, NC0083887
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. MV-2D1ti 0014
Having been assessed civil penalties totaling $29&00 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated. October 31, 2016, the undersigned, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted' to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the
notice of assessment.
This the
RECEIVEDINCDBIDWR
DEC 01 2016
Water Quality
Perrnitting Section
day of w+.6 +~r
ADDRESS
TELEPHON E
201(1
SIGNATURE
90 --. - 402

JUSTLFICATION FOR Ri
Case Number: MV-2016-0014
Assessed Party: City of Charlotte
Permit No.: NC0083887
ON REQUEST
County: Mecklenburg
Amount Assessed: $296.00
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S,. § 143B-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed),
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-2 — b were wrongfully applied to the
zd.etriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e„, explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:
pteq.5e 566
RECEIVED/NCDEQOAR
DEC 0 1 2015
Water Quakty
Permitting Section

REQUEST FOR REMISSION
CITY OFCHARLOTTE
CHARLOTTE [}OUGLA5INTERNATIONAL AIRPORT NCOO83887
CASE: nnv'2018-0814
AMOUNT:SI96
N We believe that there was nniOirnai or perhaps no environmental damage resultant of the
omitted testing /ie,"incideot"\because ofthe following:
� The treatment system for this managed -containment pond has been overwhelmingly
effective, and the last recorded incident where any one 8TEX constituent exceeded the
permit benchmark was inJanuary ZO13. Given this rare occurrence (one time inthe past 43
months), it is statistically unlikely that 8TEX contaminated water was discharged from the
premises and into local surface waters.
� The sedimentation and pump filters are changed on a regular (monthly) basis, and the
Airport has a contractor scheduled tocome tothe facility next week beginning November
��
�I toreplace the Carbon within the GACtreatment canisters.
� The {nHovv up sampling was performed nearly as soon as practical after the vio|atioo.
Although many days elapsed between the sample collection deadline of June 30 and August
m
7 , it is important tonote that the pond is managed and metered containment structure
from which discharge is [or can be) routinely manually controlled, It is a fact that no
discharge of water occurred from July 4m through early August,
� Follow-up water wastewater samples collected in August exhibited no BTEX analytes,
(c) As mentioned in our October 24m correspondence, the cooler provided to our contractor
(K4c James Smith) by Prism Laboratories, did not include the 40 milliliter VOA containers that
would have been needed to collect, transport, and analyze the samples for the EPA Method
8260 volatile organic compound analysis. VVhi|g it might have been possible to acquire the
needed glassware prior tothe end of the day expiring' this does not seem to have been an
option based onour conversations with the technician. Since Mr. Smith was onsite the last day
of the month, collecting the sample the following day would not seem to fulfill the permit
technical requirement any more than returning to the site to collect the sample on the 2nd,
3md,5t» orseveral days later,
h4c Smith has performed the sampling since ZQOl and the Airport also has a long standing
relationship with Prism Laboratories, While there has been an occurrence of missed sampling
at Outfall 001, and admittedly other minor violations over the years, this is an isolated incident
that was unexpected and at least in part, the fault of the laboratory,
In the future, the Airport has cornrnh1ed to receiving the sample containers here at our
administrative office for inspection prior to delivery of the Q|aasvvarc to Mr. Smith. We believe
by doing so that monitoring violations due to lack of equipment can be eliminated.

The Airport has made considerable effort to do that which is necessary to comply with the
sampling schedule and the benchmarks noted by the expired permi. The pond has been
drained and cleaned 2 times within the past 6 years, sediment filters are changed once per
month, and next week (as stated) the GAC columns which are integral to the overall treatment
of the discharge will be drained, cleaned, and overhauled with new carbon media. These
actions are being done at considerable costs and effort 1 ,0l 0 labor disposal costs) to
ensure the GAC treatment system operates at its optimal performance.
Because of reasons cited, we respectfully ask for remission of the civil Assessment against the City o
Charlotte, in the amount t f $296

PERMIT: NC0083887
ATTACNMENT A
City of Charlotte
CASE NUMBER: V- 01 - 014
FACILITY: : Charlotte Douglas Internati nal Airport
MONITORING VIOLATIONS)
SAMPLE LOCATION: ell 001 - Effluent
Violation Report
Date t
016 6-2016 Benzene
6/ 0/2016 6-2016 Ethyl benzene
REGION:ooresellte
COUNTY: Mecklenburg
Unit of Calcine d Over Violation Pen
ncy Measure Value Value Limit Type Amount
Monthly
Monthly u01l
6/ 0/2016 6-2016 Toluene
Monthly ugll
Frequency 50,
Violation
Frequency
Violation
Frequency
%elation
70
60.1
6/30/2016 6-2016 Xylene (mix of m+o+p) i 9onthly u /l
Frequency
Violation
2500

Y COOPER
Governor
MICHAEL S. REGAN
ecr.i r»
S.JAY ZIMMERMAN
Resources
enui Quality
MEMORANDUM
TO: Derek Denard
FROM: Corey Basinger, Regional Supervis
THROUGH: Wes Bell
DATE: January 24, 2017
SUBJECT: Request for Remission of Civil Penalty Assessment
NPDES Permit Number NC0083887
Charlotte Douglas International Airport
Mecklenburg. County
Case Number MV-2016-0014
CDIA attributed the monitoring violations to the contract laboratory's failure to include the BTEX sample
container in the cooler and that no environmental damage resulted from the violations. CDIA reported
flow on two separate days (same week) during, this month and failed to collect the required BTEX
samples. This Office does not support any reductions to the civil penalty.
State of North Carolina
7',`,.Notht (ornpare .,...,.
eniu1 Quality f Water Resources l S atur Quality i ioaaal C)[aerrt4 osa:
Mooresville Regional Mee Ibis Asa tCenter Avenue, Suite 30I Mooresville, North Cartrna 281 I
704-64 3- l 699

DWR — CIVIL PENALTY REMISSION FACTORS
Case Number: MV-2016-0014 Region: MRO
Assessed Entity: Charlotte Douglas International Airport
County: Mecklenburg
Permit: NC0083887
0 (a) Whether one or more of the civil penalty assessment factors were wrongly applied to the detriment of the
petitioner;
(b) Whether the violator promptly abated continuing environmental damage resulting from the violation;
Whether the violation was inadvertent or a result of an accident;
EJ (d) Whether the violator had been assessed civil penalties for any previous violations;
E (e) Whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
MRO staff has reviewed the subject request for remission, The permittee asserts that minimal to no environmental
damage resulted from the monitoring violations and the facility has demonstrated a good compliance history with the
treatment/removal of BTEX from the waste stream. In addition, the permittee indicated that the monitoring violations
were also attributed to the contract laboratory's failure to include the sample container for BTEX in the cooler,
A review of the facility's compliance history, from June 2011 to May 2016, reflects a history of reporting and monitoring
violations at Ouffall 001. The permittee has been issued a NOD and three NOVs for the late submittal of DMRs (8
total DMRs), two NODs for monitoring violations (November 2011 and March 2012 DMRs); NOV for a TSS daily
maximum limit violation; and an enforcement for monitoring violations (September 2015). The enforcement ($306.53
total penalty) was paid in full on February 22, 2016. The permittee reported two separate discharge events during this
month (same week) and failed to collect the required BTEX samples (monthly sampling requirement); therefore, this
Office does not support any reduction of the penalty.
Regional Recommendation (Check One)
Request Denied Full Remission E
Central Office Recommendation (Check One)
Request Denied EJ Full Remission
Director's Decision (Check One)
Request Denied 0 Full Remission
Date
Partial Remission
Partial Remission
Partial Remission E Amount Remitted $
S. Jay Zimmerman, Director

Jack Christine
Charlotte Douglas International Airport
CLT Center'
5601 Wilkinson Blvd
Charlotte NC, 28208
December 11
PAT CCRORY
Governor
DON Lid R. VAN DER V T'
Subject: Remission Request of Civil Penalty Assessment
Charlotte Douglas hit ational Airport
NPDES Permit NSS
Case Number l- 1 -00 14
Dear Mr, Christine:
Mecklenburg County
S
Neer
AY Z
Director
This letter is to acknowledge your request for remission of the civil penalty levied
facility. Your request will be scheduled for review by the Director and you will be
against the subject
notified of the result..
If you have any questions about this matter,`ple e ntaet nee at 19807-6307 of
derek.denard edenr.gov.
Sincerely,
Derek d, Errvironmental Specialist
Compliance & Expedited PermittingUnit
Division of Water Resources
cc. Enforeetrtent File wforiginals-
Central Files is hments
a e-mail at
State ofNorth Cardliaa, j Fnvi tat Quality Water Resources
16177 Mail Service Center 1 Raleigh, North Caroline 27 9 -1617
91 -707-9

STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
City of Charlotte
Charlotte Douglas International Airport
PERMIT NO. NC0083887
DEPARTMENT OF ENVIRONMENTAL QU
Vf'AIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
CASE NO. MV-2016-0014
TY
Having been assessed civil penalties totaling $296.00 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated October 31, 2016, the undersigned, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty (30) days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the
notice of assessment.
This the tn day of
RECEIVEDINCDEOJD R
DEC 01 2016
Water Quality
Permitting Section
SIGNATURE
ADDRESS
C Ow
CA-1- Cenhr
4elm l-
TELEPHONE
9btI -3 i- 4b12
20 lG

JUSTIFICATION FOR REMISSION RE UEST
Case Number: MV-2016-0014
Assessed Party: City of Charlotte
Permit No.: NC0083887
County: Mecklenburg
Amount Assessed: $296.00
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the
yletriment of the petitioner (the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the
steps that you took to correct the violation and prevent future occurrences):
V(c) the violation was inadvertent or a result of an accident (Le., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
ANATION:
eA,-{-+Acttil Aoctmitext
RECEIVEDINCDECO R
DEC 0 1 2016
Water Quality
Permitting Section

REQUEST FOR REMISSION
CITY OFCHARLOTTE
CHARLOTTE D{]UGLASINTERNATIONAL AIRPORT N[DQ83887
LASE: nmv-2016'0014
AMOUNT: $296
M We believe that there was minimal orperhaps no environmental dmmn �
ornK1edt�stin�U.�., °inc|d�nt") because ofthe fo||ovvin8' a�� resotamt of the
� The treatment system for this managed -containment pond �a� h
effective, and the last recorded incident where any ''^ been overwhelmingly
pernnitbenchnlarkvvesinJanuary J013'Giyenthione 8T�� constituent exceeded the
months), it is statistically unlikely that BTEX contaminated
non3 occurrence (one time >n t�� past
is 'sand into �inated water was disch�r��� from��e
premises
� The sedimentation and Pump filters are changed on a regular (monthly) bass,
Airport has a contractor scheduled to come to the facility t ` y' o�s~ and the
2I�within eek beginning November
� The fo(|ofollowup sampling was performed nearly as soon '
/\|thou0hnmanydmys elapsed betvveenthe nannp|e coU ti on�u practical after the violation.
7m'itisirnportanttonote that the pond /sa nlanageec g�adUneof�une�Oan�Ao�ust
from which discharge /s (or can be) routinely d and metered containment structure
discharge of water , , o ne/y manually controlled. |t /s a fact that no
er�o�urr��frOnm}u/y4� through early August.
� Follow-up water wastewater samples collected in August exhibited no BTEX analytes.
(a) As mentioned in our October 241h correspondence, the cooler provided to our contractor
(uwr.Jamncs Smith) by Prism Laboratories, did not include the40 milliliter VOA
xvou/d have been needed to collect, transport, and analyze the samnp/�S fo t containers that
8260 volatile organic con�pounc/analysis. While it might have been possible r �� EPA Method
glassware prior to the end oftheday expiring, this does not
t� acquire the
option based onour conversations with thooI seem to have been an
of ��� monthay
collecting the sample the the Since Mr. Smith was on site the last drequirementp/e e following day would not s�seemto fulfill the permit r�Q
3rd 5mors�*�r�| d any more than returning to the site to collect the sample on the 3nd ' veays|ater. '
Mr. Smith has performed the sampling since 2001and the Airport also has a lo
ngstanding
relationship with Prism Laboratories'While there has been an occurrence Of missed samplingat ]utfa|/0Q1, and admittedly other minor violations over the years, this is an isolated incident
that was unexpected and at least in part, the fault Vf the laboratory.
In the future, the Airport has committed to receiving the sample �o��aim �
aornmistrativg office for inspection prior to delivery of the glassware to K4 � ers ere at our
bydoing snthat mnonitoriugviolations due to lack ofequiprnentcan b |� r� mm>th' We believe
�e nn|nated.

The Airport has made considerable effort to do that which is necessary to comply with the
sampling schedule and the benchmarks noted by the expired permit. The pond has been
drained and cleaned 2 times within the past 6 years, sediment filters are changed once per
month, and next week (as stated), the GAC columns which are integral to the overall treatment
of the discharge will be drained, cleaned, and overhauled with new carbon media. These
actions are being done at considerable costs and effort > 1 , labor + disposal costs) to
ensure the GAC treatment system operates at its optimal performance.
Because of reasons cited, we respectfully ask for remission of the iviI Assessment against the City of
Charlotte, in the amount of B296

ATTACHMENT A
CI ty at Charlott+
CASE NUM ER: V- 016- 014
PERMIT: NC0083881
FACILITY: Charlotte Douglas Int+ernational Airport
REGION: ellle
COUNTY: Mecklenburg
MONITORING VIOLATION(S)
SAMPLE LOCATION: Outfall 001 - Effluent
Violation Rep
Date Mon r Parar
6/30/2016 6-2016 Benzene
Unit of Limit Calcula d Oyer Violation P alty
Frequency Measure Value Value t lml Type Bunt
Monthly ugA
6130/2 °l6 6-2016 Ethyl be ene
6130/ 016 6-2016 Toluene
Monthly ugil
Frequency
Violation
a0,00
Frequency
Violation
7
6
016 Xylene (mix of m+o+p) Monthly
Frequency $25.00
Violation

• ,
0
1
Facility:
Pa
Date Para
6
Parameter
Remarks:
DMR Review Record
Remit Noit/C-OC)C3% q' 7 Pipe No.:
MonthlyAvera e Violations
Perrntt DMR Value
Per
MonthrYear,
% Over Limit Action
Weekly/Daily Violations
Limit Type DIOR Va % Over Limit Action
Monitoring Frequency Violations
Permit Frequency Values Reported
c +41 /../ n OA e
(1,1(201f-hi
k\otte
11 n
nrk-th 1y c,
2 At
A.70 V— 07 Al C r
/
# of Violations
Action
.2,5
4-3
j-
74:
Sup ry or R k
Completed by:
by:
Assistant Regional
Supervisor Sign Off:
Regional Supervisor Sign
Off:
Date:
Date:
Date:
„ /101116 1117 PM
nmR RPuipw Rprrirri Mactor lACI) Withnitt A mt

1
Certified Mail #7015
0 0002 6984 7931
Return Receipt Requested
October 17, 2016
Mr. Jack Christine
Deputy Aviation Director
City of Charlotte
PO Box 19066
Charlotte, NC 28219
AU)
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2016-MV-0116
Permit No. NC0083887
Charlotte Douglas International Airport
Mecklenburg County
Dear Mr, Christine:
VANDERVAART
A review of the June 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Monitoring Violation(s);
Sample
Location Parameter
Monitoring
Date Frequency Type of Violation
001 Effluent
Benzene (34030)
6/30/2016 Monthly Frequency Violation
001 Effluent
001 Effluent
001 Effluent
Ethylbenzene (34 71)
Toluene (34010)
Xylene (mix of m+o+p) (8
6/30/2016
6/30/2016
Monthly
Frequency Violation
6/30/2016 Monthly Frequency Vi
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
State of North Carolina I Environmental Quality I Water Resources
610 East Centel- Avenue, Suite 301, Mooresville, NC 28115
704453-1699

If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Discharge
Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the
violations. If no response is received in this Office within the 10-day period, a civil penalty
assessment may be prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
Additionally and if you have not already done so, you may wish to consider registering to use the Division's new
e-DMR system for the completion and electronic submittal of monthly Discharge Monitoring Reports (DMRs).
For more information, please visit the eDMR Website at the following address:
http ://portal .ncdenr.org/webfwq/adminibog/ipuiedmr.
If you have any questions concerning this matter or to apply for an SOC, please contact Wes Bell of the
Mooresville Regional Office at 704-663-1699.
Sincerely,
W. Corey :.singer, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
State ofNorth Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

Charlotte.Dou as*
INTERNATIONAL AIPORT
24 October 2016
Mr. Wes Bell
NCDENR Division of Water Quality
Mooresville Regional Office
610 East Center Street
Mooresville, NC 28115
Notice of Violation NOV-2016-MV-0116
Charlotte Douglas International Airport Permit NC0083887
Mr. Bell;
As you are probably aware, the Charlotte Douglas International Airport is in receipt of the
referenced notice regarding a June 2016 Discharge Monitoring Report for our facility. The cited
violation indicates the airport did not fulfil the "frequency" (Le., monthly) monitoring for our
wastewater outfall 001 for the month of June. This correspondence is to acknowledge the
violation, and provide an explanation.
The DMR shows that the contracted sampling technician and ORC (Mr. James Smith) for the
facility was on site to collect the samples Thursday, June 30th. I have spoken with Mr. Smith and
he indicated to me that the ice cooler provided to him by Prism Laboratories, did not include
the 40 milliliter VOA containers that would have been needed to collect and transport the
samples for the EPA Method 8260 volatile organic compound analysis. The samples were not
collected, and this of course, is reflected by the absence of values representing Benzene, Ethyl -
benzene, Toluene, and Total Xylenes on the DMR.
If an effort to comply with the permit requirements for "Tier II" sampling, Mr. Smith indicated
he returned to the site six times in the very dry month of July to collect the BTEX samples the
earliest being the following Monday, July 4 - but there was no flow for that day, nor the entire
month. Mr. Smith collected the next round of BTEX samples on August 7th and that data was
provided to NCDEQ on the corresponding DMR form.
The Airport regrets the omission error that has led to the violation of the expired NPDES Permit.
Because we have depended on our contract laboratory to supply all the necessary glassware to
collect the samples, (and they have overwhelmingly done this) we have erroneously assumed
all needed containers will be available. We feel there are several reasons for why no civil
penalty should be issued regarding the missed frequencies;
• The discharge mechanism for this particular sampling event was manually activated
due to a low water level in the effluent pond. Once the pump was activated on the
charlotteairportcom
PO Box 19066 1 Charlotte, NC 28219
Owned and operated by the City of Cheri
P: 704,3594000
F: 704 359.4030

date the samples were collected, there was Insufficient water in the system to allow
for follow up sampling the next day. The samples for BTEX must be collected from
the discharge hose effluent of the treatment system —this cannot be done if there is
no discharge.
Due to a lack of rainfall, no flow was discharged in the month of July. A return to the
system in early August revealed sufficient flow for sample collection, and the BTEX
samples were collected and submitted August 7. This early submittal date for the
month of August Is in contrast to the typical sampling that is done later in the
month. In other words, the contractor submitted the samples for BTEX about as
soon as it could have been done.
The treatment system for outfall 001 is overwhelmingly effective and exceedances in
the permit benchmarks for BTEX are extremely rare. In consideration of this fact
and the very limited flow out of the system, it is very unlikely that any BTEX
impacted water was discharged during the monitoring period.
The Airport has made considerable effort to do that which is necessary to comply
with the sampling schedule and the benchmarks noted by the expired permit. The
pond has been drained and cleaned 2 times within the past 6 years, and sediment
filters are changed once per month. These things are beyond what is specifically
required by the permit and are being done to ensure the GAC treatment system
operates at its optimal performance.
In addition to the above, the Airport hired a new Environmental Compliance Inspector in May
2016. One of the compliance inspector's responsibilities is to ensure that all NPDES permit
sampling is completed, all sampling is properly performed, documented, all equipment is
calibrated, and that all required sampling is done within the prescribed parameters and within
the period time -frame. Outside of extenuating circumstances beyond our control, we do not
expect frequency violations will occur in the future. If they do, we commit to notify your
agency as soon as possible.
Jimmy D. Jordan, P.G.
Environmental Affairs Manager
Charlotte Douglas International Airport
cltairport.com I PO Box 19066 I Charlotte, NC 28219 I P: 704,359.4000
Owned and operated by the City of Charlotte

Certified
al
7015 1520 0002 6984 7931
Return Receiipt Requested
October 17, 2016
Mr. Jack Christine
Deputy Aviation Director
City of Charlotte
P© Box 19066
Charlotte, NC 28219
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2016-MV-0116
Permit No. NC0083887
Charlotte Douglas International Airport
Mecklenburg County
Dear Mr. Christine:
A review of the June 2016 Discharge Monitoring Re
indicated below:
Monitoring Vlolation(s).
Sample
Location Parameter
001 Effluent Benzene (34030)
1 Effluent Ethylbenzene (34371.
001 Effluent Toluene (34010)
rt
r the subject facility revealed tie v olation(s)
Monitoring
Date Frequency Type of Violation
6/30/2016
/30/2016
/30/2©16
Monthly
Monthly
Frequency Violation
Frequency Violation
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or falls
to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
State of North Carolina i Environmental Airy I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
7NI-6457-1649

From:
es
Jordan, Jimmy <jd ordan dtalrportcom
Tuesday, October 25, 2016 1:47 PM
To: Bell, Wes
Cr: Weaver, JC;iisses @yah acorn Dennis, Katherine
SubNOV
Attachments: response toNOV-21-M-011 Wes Bell OCT 2O16.df
Wes;
Please open the attached document, It is the Airport's response to the noted NOV recently received to us Please
forward a copy of this response to whomever necessary in Raleigh or other wise, as I do not intend to mail a copy o the
document unless directed to do soo
Have a good week,
y m Jordan, P.O.
n itonmental Affairs Manager
Charlotte Douglas Int atlonal Airport
Airport Development
Phone: [phone]
i� fdi(?rda�cca6r�rt,csarr,

DIVISION OF WATER RESOURCES - CIVIL PENALTY ASSESSMENT
Violator: City of Charlotte
Facility Name: Charlotte Douglas International Airport
Permit Number: NC0083887
County: Mecklenburg
Case Number: MV-2016-0014
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private
property resulting from the violation;
Ntria
2) The duration and gravity of the viol
3) The e
on;
i
on ground or surface water quantity or quality or on air qu
4) The cost of rectifying the damage;
5) The amount of money saved by noncompliance;
6) Whether the violation was committed willfully or intentionally;
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
NOV-2015-LV-0142 — Outfall 0011TSS Daily Maximum Violation (August 2014 DMR);
Case #: MV-2016-0004 Outfall 001/Failure to monitor total nitrogen, total phosphorus, and toxicity (September
2015 DMR),
8) The cost to the State of the enforcement procedures.
Date
Enforcement Cost:
1 hour staff time,.,,...o.............................................$ 33,44
1 hour supervisor time, .$ 52.56
Administrative staff cost.. ,.$ 15.00
Total Enforcement Cost $ 101.00
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional. Office
Division of Water Resources, NCDEQ