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NC0083887_Permit Issuance_20060710
Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality July 10, 2006 Mr. T.J. Orr, Aviation Director Charlotte/Douglas International Airport P.O. Box 19066 Charlotte, NC 28219 Subject: NPDES Permit Issuance NPDES Permit NCO083887 Charlotte/Douglas International Airport Mecklenburg County Dear Mr. Orr: Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended The permit authorizes the City of Charlotte to discharge treated wastewater and stormwater from the Charlotte/Douglas International Airport to outfalls in Coffey Creek, an unnamed tributary to Ticer Branch and an unnamed tributary to Taggart Creek, which are Class C waters in the Catawba River Basin. The permit includes discharge limitations /or monitoring for flow, total suspended solids (TSS), oil & grease, benzene, toluene, propylene glycol, acute toxicity and other parameters. The modifications in the May 24th draft, remain a part of the final permit: A limit for benzene of 71 ug/1 has been added to the permit based on results of the reasonable potential analysis that indicated the potential to exceed the allowable effluent concentration. The monitoring frequency for benzene will be twice per month. • The monitoring frequency for the daily maximum toluene limit of 11 ug/1 has been increased to twice per month, per 15A NCAC 2B 0500 surface water monitoring regulations for treatment facilities. • Effluent monitoring for propylene glycol has been added to outfall 002, outfall 003, and instream sampling station 004. This will replace effluent monitoring for only glycol. Discussions between Division staff and Charlotte Douglas International Airport have determined that propylene glycol is now predominantly used for deicing/anti-icing. The monitoring frequency will remain the same. JCaro na tura��y North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service Internet: www.ncwuerquality.om Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax (919) 733-2496 1-877-623-6749 An Equal Opportunity/Affirmative Action Employer —500 Recyded/tOq Post consumer Paper Letter to Mr. Orr Page 2 I The "boilerplate" language is considered standard and cannot be changed to represent individual facilities. The requirement to include standard permit conditions verbatim or by reference is stipulated in 40 CFR 122.43. Language is interpreted appropriately for each facility. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding. Please take notice that this permit is not transferable. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits, which may be required by the Division of Water Quality, or permits required by the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local governmental permits may be required. If you have any questions or need additional information, please contact Ms. Jacquelyn Nowell at telephone number (919) 733-5083, extension 512. Sincerely, n'W IVY .E. Alan W. F3imek, P.E. Attachments cc: Mooresville Regional Office/Surface Water Protection Section Mr. Rusty Rozzelle, MCWQP 700 North Tryon St. Suite 205 Charlotte NC 28202 Brian Hennessey, City of Charlotte P.O. Box 19066 Charlotte NC 28219 Aquatic Toxicology Unit NPDES File Central Files Permit No. NCO083887 'STATE OF NORTH CAROLINA DEPARTMENT *OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER AND STORMWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELUdINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, 'as amended, City of Charlotte is hereby authorized to discharge wastewater and stormwater from a facility located at Charlotte/Douglas International Airport 5501 Josh Birmingham Parkway Charlotte, North Carolina Mecklenburg County to receiving waters designated as Coffey Creek, UT Taggart Creek, and UT Mcer Branch in the Catawba River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, H, III, and N hereof. The permit shall become effective August 1, 2006 This permit and the authorization to discharge shall expire at midnight on June 30, 2010 Signed this day July 10, 2006 C;-A Alan W. Klimek, P.E.; Director Division of Water Quality By Authority of the Environmental Management Commission Permit No. NCO083887 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit bearing this number. is. no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. City of Charlotte is hereby authorized to: 1. Outfall 001 (bulk jet fuel tank farm). Continue to operate ' a stormwater treatment system (consisting of oil/water separator and retention pond) at Charlotte/Douglas International e Airport, to treat stormwater . collected from the north side of the airport including the bulk jet fuel tank farm area, and discharge through Outfall 001 into an unnamed tributary to Ticer Branch, a Class C water in the Catawba River Basin, at the location specified on the attached map. 2. Outfall 002 (main airport runwayaarea). Continue to discharge untreated stormwater, used de-icing fluid, and washwater collected from the majority of the runway and tenant areas at Charlotte/Douglas International Airport, through,Outfa11002 into Coffey Creek, a Class C water in the Catawba River Basin, at the location specified on the attached map. 3.. Outfall 003 (southeastern runway area). Continue to operate A stormwater treatment system (retention pond) at Charlotte/Douglas International Airport, to ' treat stormwater, used de-icing fluid, and wastewater collected from the southeastern side of the. facility (includes small portion of runway and a few tenants), and discharge through Outfall 003 into an unnamed tributary to Taggart Creek, a Class C water in the Catawba River Basin, at the location specified on the attached map. The Charlotte/Douglas International Airport (CDIA) is located at 5501 Josh Birmingham Parkway in Charlotte within Mecklenburg County. Discharge Point 001 Latitude 35°13'47" Longitude 80°56'5T' Discharge Point 002 Latitude 35"11'55" Longitude 80°56'55" Discharge Point 003 Latitude 35112'25" Longitude 80"55'45" Instream Point 004 Latitude 35013'54" Longitude 80°56'19" Charlotte/Douglas Int. Airport - NCO083887 Facility ' 4t Location.::.' USGS Quad p: G15NW Receiving Stream: Coffey Creek (002, 004) UT Ticer Branch (001) UT Taggart Creek(003) �$CALE 1:24,000 Stream Class: C orth Permit No. NCO083887 A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge stormwater from Outfall 001- Jet Fuel Tank Farm from the north side of the CDIA facility. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS EFFLUENT LIMITATIONS MONITORING REgUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location F1ow2 Discharge Event Estimate E Total Suspended Solids 45 mg/1 Monthly Grab E Oil and Greases 45 mg/1 Monthly Grab E pH4 Monthly Grab E Benzene 71 ug/l 2/Month Grab E Ethylbenzene Monthly Grab E Toluene 11 ug/l 2/Month Grab E Xylene Monthly Grab E Acute Toxicity5 Quarterly Grab E Notes: 1. Sample locations: E- Effluent sample collected after the oil water separator/retention pond treatment system. 2. Discharge from the retention pond is controlled by a manual gate valve, and may not coincide with a storm event. Therefore, discharge flow for each manual release shall be estimated based on the surface area and drop in depth of the retention pond. if there is no discharge during a month, enter "No Flow" on the Discharge Monitoring Report submission for that month. 3. Where possible, the grab sample shall be slimmed from the surface of a quiescent (calm water) zone. 4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 5. Acute Toxicity (Fathead Minnow, 24-hour) Quarterly Monitoring; refer to Special Condition A (6)- Acute Toxicity Monitoring (guarterly). There shall be no discharge of floating solids or visible foam in other than trace amounts. There shall be no direct discharge of tank solids, tank bottom water, or the rag layer. Permit No. NCO083887 A (2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge stormwater and washwater from Outfall 002- Main Aircraft Runway Area (which includes runoff from the majority of the runway and tenant areas at CDIA, and includes vehicle washing, fuel storage, aircraft fueling, aircraft maintenance, and de-icing chemical storage/application). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS EFFLUENT LIMITATIONS MONITORING RE9UIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location Flow 2 2 E Total Rainfall (inches) 2 2 E Event Duration (minutes) 2 2 E Total Suspended Solids Quarterly Grab D Oil and Grease3 45 mg/1 Quarterly Grab D Detergents (MBAS) Quarterly Grab D PH4 Quarterly Grab D Propylene Glycols 3/Year Grab D NH3 as N5 3/Year Grab D Acute Toxicity6 Episodic Grab D Notes: 1. Sample locations: E- Effluent, D- The southwest quadrant of the intersection of Piney Top Road. 2. For each representative storm sampling event, the total precipitation, storm duration, and total flow must be monitored. Total flow shall be either: a) measured continuously; b) calculated based on the amount of area draining to the outfall, the amount of built -upon impervious area, and the total amount of rainfall; or c) estimated by the measurement of flow at 20-minute intervals during the rainfall event. 3. Where possible, the grab sample shall be skimmed from the surface of a quiescent (calm water) zone. 4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 5. Propylene Glycol shall be monitored during three discharge events each year at the time of de-icing/anti- icing, or during the next separate discharge event following de-icing/anti-icing. NH3-N shall be monitored only if urea is used for de-icing. 6. Acute Toxicity (Fathead Minnow, 24-hour). Refer to Special Condition A(7)- Acute Toxicity Monitoring (Episodic). There shall be no discharge of floating solids or visible foam in other than trace amounts. r p Permit No. NCO083887 A (3). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge stormwater and washwater from Outfall 003- Southeastern Runway Area (which includes runoff from the southeastern side of the CDIA facility containing a small portion of runway area and a few tenants, and includes vehicle washing, aircraft washing, aircraft fueling and maintenance, fuel storage, and de-icing chemical storage/application). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS EFFLUENT LIMITATIONS MONITORING REsUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location Flow 2 2 E Total Rainfall (inches) 2 2 E Event Duration (minutes) 2 2 E Total Suspended Solids Quarterly Grab E Oil and Greases 45 mg/1 Quarterly Grab E Detergents (MBAS) Quarterly Grab E PH4 Quarterly Grab E Propylene Glycols 3/Year Grab E NH3 as Ns 3/Year Grab E Acute Toxicitys Episodic Grab E Notes: 1. Sample locations: E- Effluent sample collected after the stonmwater retention pond treatment system. 2. For each representative stone sampling event, the total precipitation, storm duration, and total flow must be monitored. Total flow shall be either: a) measured continuously; b) calculated based on the amount of area draining to the outfall, the amount of built -upon impervious area, and the total amount of rainfall; or c) estimated by the measurement of flow at 20-minute intervals during the rainfall event. 3. Where possible, the grab sample shall be skimmed from the surface of a quiescent (calm water) zone. 4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 5. Propylene Glycol shall be monitored during three discharge events each year at the time of de-icing/anti- icing, or during the next separate discharge event following de-icing/anti-icing. NH3-N shall be monitored only if urea is used for de-icing. 6. Acute Toxicity (Fathead Minnow, 24-hour). Refer to Special Condition A (7)- Acute Toxicity Monitoring (Episodic). There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit No. NCO083887 A (4). INSTREAM MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until expiration, the Permittee shall monitor Instream Station 004- Background (located in Coffey Creek upstream of the CDIA facility and just south of Walker Street), as specified below: INSTREAM CHARACTERISTICS EFFLUENT LIMITATIONS MONITORING REgUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location' Total Suspended Solids Quarterly Grab I Oil and Grease2 Quarterly Grab I Detergents (MBAS) Quarterly Grab I pH Quarterly Grab I Propylene Glyco13 Annual Grab I NH3 as N3 Annual Grab 1 Notes: 1. Sample locations: I- Instream background station, upstream of CDIA facility, just south of Walker Street. 2. Where possible, the grab sample shall be skimmed from the surface of a quiescent (calm water) zone. 3. Propylene Glycol shall be monitored annually during a discharge event at the time of de-icing/anti-icing, or during the next separate discharge event following de-icing/anti-icing. NH3-N shall be monitored only if urea is used for de-icing. Permit No. NCO083887 A (5). STORMWATER QUALITATIVE MONITORING REQUIREMENTS Qualitative monitoring requires an inspection of each stormwater outfall regardless of representative outfall status and shall be performed as specified below. Qualitative monitoring is for the purpose of evaluating the effectiveness of the Stonnwater Pollution Prevention Plan (SPPP) and assessing new sources of stormwater pollution. No analytical tests are required. Qualitative monitoring of stormwater outfalls does not need to be performed during a representative storm event. STORMWATER CHARACTERISTICS MONITORING REgUIREMENTS Measurement Frequency Sample Type Sample Location' Color Semi -Annual Visual SDO Odor - Semi -Annual Visual SDO Clarity Semi -Annual Visual SDO Floating Solids Semi -Annual Visual SDO Suspended Solids Semi -Annual Visual SDO Foam Semi -Annual Visual SDO Oil Sheen Semi -Annual Visual SDO Other obvious indicators of stormwater pollution Semi -Annual - Visual SDO Notes: 1. Sample locations: Qualitative monitoring shall be performed at each stormwater discharge outfall (SDO) regardless of representative outfall status. Qualitative monitoring will be required at outfalls 001, 002, and 003. 2. Qualitative monitoring will be conducted twice per year, once in the spring (April June) and once in the fall (September -November). y r' Permit No. NCO083887 SUPPLEMENT TO EFFLUENT SHEETS SPECIAL CONDITIONS A (6). ACUTE TOXICITY MONITORING- Quarterly Outfall 001(Jet Fuel Tank Farm) The permittee shall conduct quarterly toxicity tests using protocols defined as definitive in E.P.A. Document EPA/600/4-90/027F entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test. Effluent samples for self -monitoring purposes must be obtained below all waste treatment. The testing will be performed upon the first discharge from the facility during each quarter. The quarters defined as the months of January -March, April -June, July -September, *and October -December. The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DWg Form AT 1 (original) is to be sent to the following address: Attention: NC DENR / DWg / Environmental Sciences Section 1621 Mail Service Center Raleigh, N.C. 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as- all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a quarter in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water guality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the monthfollowing the month of the initial monitoring. A (7). ACUTE TOXICITY MONITORING- Episodic Outfalls 002 and 003 (Runway Areas) The permittee shall.conduct FIVE acute toxicity tests using protocols defined as definitive in E.P.A. Document EPA/600/4-90/027F entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test. Effluent samples for self -monitoring purposes must be obtained- below all waste treatment. Sampling and subsequent testing will occur on at least five occasions during the first year following permit issuance, during five discharge events at the time of de- v t T Permit No. NCO083887 icing/anti-icing or during the next separate discharge event following de-icing/anti-icing. After monitoring of the first five toxicity tests, the permittee will - conduct one test annually, with the annual period beginning in January of the next calendar year. The annual test requirement must be performed and reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this date. Toxicity testing will be performed on the next discharge event for the annual test requirement. The parameter code for this test is TAE6C. All toxicity testing results required as 'part of this permit condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DWQ Form AT 1 (original) is to be sent to the following address: Attention: NC DENR / DWQ / Environmental Sciences Section 1621 Mail Service Center Raleigh, N.C. 27699-1621 Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response. data. Total residual chlorine of the effluent toxicity sample- must be measured and reported if chlorine is employed for disinfection of the waste stream. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test, conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. A (8). STORMWATER POLLUTION PREVENTION PLAN The permittee shall maintain the Stormwater Pollution Prevention Plan, herein after referred to as the Plan. The Plan shall be considered public information in accordance with Boilerplate Part II, Section E.10 of this permit. The Plan shall include, at a minimum, the following items: a. Site Plan: The site plan'shall provide 'a description of the physical facility and the potential pollutant sources which may be expected to contribute to contamination of regulated stormwater discharges. The site plan shall contain the following: (1) A general location map (USGS quadrangle map, or appropriately drafted equivalent map), showing the facility's location in relation to transportation routes and surface waters, and the name of the receiving water(s) to which the stormwater outfall(s) discharges. If the discharge is to -a municipal separate storm sewer system, the name of the municipality and the ultimate receiving waters, and accurate latitude and longitude of the point(s) of discharge must be shown. (2) A narrative description of storage practices, loading and unloading activities, outdoor process areas, dust or particulate generating or control processes, and waste disposal practices. (3) A site map (or series of maps) drawn to scale with the distance legend indicating location of industrial activities (including storage of materials, disposal areas, process areas, and loading and unloading areas), drainage structures, drainage areas for each outfall and activities occurring in the drainage area, building locations and impervious surfaces, the percentage of each drainage area that is impervious. For each outfall, a narrative description of the potential pollutants which could be expected to be present in the regulated stormwater discharge. (4) . (5) Permit No. NCO083887 A list of significant spills or leaks of pollutants that have occurred at the facility during the 3 previous years and any corrective actions taken to mitigate spill impacts. Certification that the stormwater outfall stormwater discharges. The certification requirements found in Boilerplate Part II, have been evaluated for the presence of non - statement will be signed in -accordance with the Section B.1 1. b. Stormwater Management Plan: The stormwater management planshall- contain a narrative description of the materials management practices employed which control or minimize the exposure of significant materials to stormwater, including structural ' and non-structural measures. ' The stormwater management plan, at a minimum, shall incorporate the following: (1) Feasibility Study. A study addressing the technical and economic feasibility of changing the methods of operations and/or storage practices to eliminate or reduce exposure of materials and processes to stormwater. Wherever practicable the permittee should consider covering storage areas, material handling operations, manufacturing or fueling operations to prevent materials exposure to stormwater. In areas where elimination of exposure is not practicable, the stormwater management plan shall document the feasibility of diverting the-stormwater runoff away from areas of potential contamination. (2) Secondary Containment. A schedule to provide secondary containment for bulk storage of liquid materials, storage of Section 313 of Title ' III of the Superfund Amendments. and Reauthorization Act (SARA) water priority chemicals, or storage of hazardous materials to prevent leaks and spills from contaminating stormwater runoff. If the secondary containment devices are connected directly to stormwater conveyance systems, the connection shall be controlled by manually activated valves or other similar devices [which shall be secured with a locking mechanism] and any stormwater that accumulates in the containment area shall be at a minimum visually observed prior to release of the accumulated stormwater. Accumulated stormwater shall be released if found to be uncontaminated. Records documenting the 'individual making the observation, the description of the accumulated stormwater and the date and time of the release shall be kept for a period'of five years. (3) BMP Summary. A narrative description of Best Management Practices (BMPs) to be considered such as, but not limited to, oil and grease separation, debris control, vegetative filter strips, infiltration and stormwater detention or retention, where necessary. The need for structural BMPs shall be based on the assessment of potential of sources contributing significant quantities of pollutants to stormwater discharges and data collected through monitoring of stormwater discharges. (4) Inspection schedules of stormwater conveyances and controls and measures to be taken to limit or prevent erosion associated with the stormwater systems. C. Spill Prevention and Response Plan (SPRP): The Spill. Prevention and Response Plan shall incorporate an assessment of potential pollutant sources based on a materials inventory of the facility. Facility personnel (or team) responsible for implementing the SPRP shall be identified in the plan. A responsible person shall be on -site at all times during facility operations that have the potential to contaminate stormwater runoff through spills or exposure of materials associated with the facility operations. The SPRP must be site stormwater specific. Therefore, a SPCC plan may be a component of the SPRP, but may not be sufficient to completely address the stormwater aspects of the SPRP. The common elements of the Spill Prevention Countermeasures and Containment Plan (SPCC) with the SPRP may be incorporated by reference into the SPRP. d. Preventative Maintenance and Good Housekeeping Program: A preventative maintenance program shall be developed. The program shall document schedules of inspections and maintenance activities of stormwater control systems, plant equipment and systems. Inspection of material handling areas and regular cleaning schedules 'of these areas shall be incorporated into the program. e• Permit No. NCO083887 . Employee Training, Training schedules shall' on *an , annual basis on proper s be developed and tr ' maintenance activities for all personnel response and cleanup�g Provided at a minimum Involved in any of the fciprocedures ty s Operate ns preventative potential to contaminate stormwater Implementingthe g runoff. Facile that have the training shall be identified in the plan ' Personnel (or team) responsible for f. Responsible Party. The Stormwater Pollution Prevention Plan shall identify responsible for the overall coordination, development, Responsibilities for all components of the P P t' implementation, a specific positions) Provided. Plan shall be documented and p sitionto () assignments revisionthe Plan. g• Plan Amendment: The permittee shall amend the Plan w construction, operation, or maintenance which has a si whenever there is a change in design, discharge of pollutants via a point source to s l�cant effect on the potential for the Prevention Plan shall be reviewed and updated on ace waters. The Stormwater Pollution al basis. The .Director may notify the permittee when the Plan does no requirements of the permit, y�i{� 30 days of such notice, the schedule to the Director for modifyingt meet one or more of the minimum shall provide certification in writing the Plan to meet pe�ttee shall submit a time (in accordance with Bow minimum � n ents. The permittee Director that the changes have been made. ,Section B. 11.) to the h• Facility Inspections: Inspections of the facility minimum on a semiannual schedule, once in te and all t °water systems shall occur at a the spring (Apt _June). The inspection and any f all ( ue mber - November) and once during shall be documented, recording date and time of inspection,subsequent maintenance activities performed and a narrative description of the facility's stormwater control mpg the inspection systems. Records of these inspections shall be inco 0 1 systems, plant equipment and Prevention Plan. rp rated into the Stormwater Pollution Visual monitorin g as required in A (5) Stormwater M Monitoring shall be performed in addition to facility ins*P ectionsonitoring Requirements/Qualitative i• Implementation: Implementation of the Plan shall measurements, inspections, maintenance activities anInclude trainingd°entation of all monitoring, Including the log of the sampling data. Activities taken to implement Provided to employees, Industrial activities, including vehicle maintenance activitial s associated with the required documentation shall be kept on -site fora period must also be recorded. All Director or his authorized representative immediately upon re P d of five years and made available to the Po quest. A (9). STORMWATER MI UMUM MOMTORING AND REPORTING REgUIREMENTS Minimum monitoring and reporting requirements are as follow the Director of the Division of Water Quality: sunless otherwise approved in writing by a• If a facility has multiple discharge locations with substanti that are required to be sampled, the permittee may Petition ally identical stormwater discharges status. If it is established that the stormwater dischar esthe Director for representative outfall permittee is granted representative outfallstatus, then sampling a ubstantially identical and the at a reduced number of outfalls. P g requirements may be performed b. Qualitative monitoring for - color, odor, weather flow shall be performed at all stormsvvatedisch sin monitoring shall be documented and recor g� visible sheens and dry discharge outfall locations. All qualitative Prevention Plan.. Qualitative monitoring of orrisstormto � d with the Stormwater Pollution during a representative storm event. ails does not need to be performed once in .the spring (April -June) and once thefanS monitoring will be performed twice per ear, . (eptember-November). P Y ' Permit No. NCO083887 C. Stormwater samples ' collected to meet the analytical monitoring requirements of this permit shall be collected from a discharge resulting from a representative storm event (see Boilerplate Part II, Section A), unless otherwise specifled. Failure to monitor storm events in accordance with the specified .frequency shall constitute a violation of this permit. d. Detergents used outdoors shall be biodegradable. The pH of the discharge shall be in the range of 6 to 9 standard units. e. Analytical results from sampling during the final year of the permit term -shall be submitted with the permit renewal application. f. This permit regulates wastewater and stormwater discharges associated with industrial activity. Non-stormwater discharges which shall be allowed in the stormwater conveyance system are: (1) All other discharges -that are authorized by an NPDES permit. (2) Uncontaminated groundwater, foundation drains, air -conditioner condensate without added chemicals, springs, waterline and fire hydrant flushing, water from footing drains, flows from riparian habitats and wetlands. (3) Discharges resulting from fire -fighting or fire -fighting training. g. If the storm event monitored and reported in accordance with this permit coincides with a non- stormwater discharge, the permittee shall separately monitor and report all parameters as required under the non-stormwater portion of this permit and provide this information with the stormwater discharge monitoring report. h. Glycol and Urea Usage. The permittee shall be responsible for summarizing the amount of glycol (and urea if applicable) dispensed each month for de-icing/anti-icing activities, and submit this data on an annual basis. This information shall be submitted with the February monthly DAM, covering the previous calendar year. DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NCO083887 Facility Information Applicant/Facility Name: City of Charlotte /Charlotte/Douglas International Air -port Applicant Address: P.O. Box 19066 Charlotte, NC 28219 Facility Address: 5501 Josh Birmingham Parkway Charlotte, NC 28219 Permitted Flow NA Type of Waste: Commercial Facility/Permit Status: Renewal Facility Classification County: Mecklenburg Miscellaneous Receiving Stream: UT Ticer Creek, Coffey Creek, UT Taggart Creek Regional Office: Mooresville Stream Classification: C USGS TooQuad: G15NW 303(d) Listed?: No Permit Writer: Jackie Nowell Subbasin: 030834 Date: 05/09/2006 Drainage Area (mi2)i NA Summer 7 10 (cfs) NA Winter 7Q10 (cfs): NA Avera e Flow (cfs): NA IWC (%): Primary SIC Code: 4581 SUMMARY OF FACILITY INFORMATION AND WASTELOAD ALLOCATION Charlotte/Douglas International Airport is requesting a renewal for its NPDES permit The Airport has three outfalls and one outfall for instream sampling only (004). The facility discharges used deicing fluid, stormwater and washwater. The airport has a total of 16740 tenants. This is an increase since the previous permit renewal. Outfall 001- Discharges into UT Ticer Creek- Discharge is stormwater runoff from the jet fuel tank farm. Stormwater is treated through an ofl/water separator (0.036 MGD) and discharged into a retention pond. Facility in the process of installing a filter system that pond effluent will pass through before discharging into outfall 001. There have been numerous permit violations with toluene,O&G, and TSR at this outfall, the filter should help with compliance with these parameters. Filter installed in June 2005. BTEX values are now mostly below detection. Outfall 002- Discharges to Coffey Creek. Mostly receives stormwater runoff from the majority of the main airport runway and tenant areas. This outfall is being relocated further downstream for better access and to be more representative of instream conditions. Outfall 003- Discharges to UT Taggart Creek. Mostly receives stormwater runoff from the southeastern side of the airport facility and contains a small portion of the runway area and a small number of tenants. Stormwater is directed through a retention pond prior to overflowing to Taggart Creek. Outfall 004 is an upstream monitoring site in Coffey Creek located upstream of the facility. RECEIVING STREAM INFORMATION: Ticer Creek, Coffey Creek and UT Taggart Creek are not listed on North Carolina's 2004 303(d) impaired streams list or on the draft 2006 303(d) Impaired Streams list. Cherlone/Douglas International Airport Pnetsheei. NPDES Renewal Page 1 INSTREAM MONITORING: t , Upstream station 004: located in Coffey Creek upstream of the CDIA (Charlotte Douglas ' International Airport) Frequency: Quarterly Parameters: TSS, Oil and Grease, MBAS, pH Frequency: Annually Parameters: Glycol- will be defined as propylene glycol, and NH3 as N Facility did not sample instream at station 004 from Sept. 2002 until June 2004. No annual samples of glycol or NH3 taken at 004. Monitoring results in October 2004, TSS=31 mg/l, MBAS=0.1 mg/l. O&G= <5 mg/l, pH=6.69 SU Monitoring results in September 2004, TSS=46 mg/l, MBAS=<0.2 mg/l. O&G= <5 mg/l, pH=5.6 SU Monitoring results in June 2004, TSS=9 mg/1, MBAS=0.1 mg/l. O&G= <5 mg/l, pH=6.8 SU Monitoring results in Jan. 2005, TSS=17 mg/l, MBAS=0.11 mg/l. O&G= <5 mg/l, pH=6.9 SU, propylene glycol <20 mg/1 Monitoring results in April 2005, TSS=20 mg/l, MB_AS=0.15 mg/l. O&G= <5 mg/l, pH=6.19 SU, propylene glycol <20 mg/1 - Monitoring results in July 2005, TSS=15 mg/l, MBAS=0.23 mg/l. O&G= <5 mg/l, pH=7.07 SU, Recommendation: Renewal of instream monitor_ ing at Upstream Station 004. Facility must start consistent quarterly monitoring. TOXICITY TEST RESULTS: Outfall 001 -Quarterly Acute Toxicity Fathead mirkrow- 24 hour. Test performed on a discharge event every quarter. Facility passed all tests in 2003 and 2004. *Per the' Compliance Evaluation Inspection done July 2005. ---Quarterly acute toxicity monitoring failed in 1st quarter 2005. Followup acute testing not done in February. Followup in March 2005 failed.' No testing in done in April 2005. Recommendation: Renewal of acute toxicity test for Outfall 001 Outfalls 002 and 003 - Acute toxicity monitoring -Episodic Tests run in January and February 2003, January 2004, no tests reported since January 2004 Recommendation Renewal of Acute episodic toxicity monitoring for Outfalls 002 and 003. PRIORITY POLLUTANT ANALYSIS RESULTS: PPA not done on this facility's discharge of stormwater iunoff. COMPLIANCE REVIEW: Compliance Evaluation Inspection done in July 2005, Facillity received unsatisfactory ratings for 1) Records/Reports, 2) Self -Monitoring Program, and Stormwater Pollution Prevention Plan. Facility has had exceedences for several parameters at Outfall 001 including Oil & Grease, TSS, pH, and Toluene - daily maximum exceeded several times in 2003, 2004, and 2005. Facility had frequency violations for benzene, ethylbenzene, Oil and Grease, toluene, xylene and pH. Late and missing DMRs were also reported to DWQ. Compliance record of this facility has been addressed by DWQ with the issuance of several NOVs and civil assessments. It should be noted that a carbon filter has been installed to help with compliance with limits/monitoring for BTEX. Charlotte/Douglas InternatiOlIal Airport Fiictsheet NPDES Renewal P14,e 2 REASONABLE POTENTIAL ANALYSIS RPA was run on BTEX data collected at Outfall 001 from February 2004 to March 2006. Benzene, toluene, ethylbenzene and xylene are sampled monthly at Outfall 001. Toluene is limited at 11 ug/1 for protection of the instream standard, the assumption was made in 2002 that the receiving streams have 7Q 10, 30Q2, and Average flows = 0 cfs. NC Standard for toluene is 11 ug/l. Benzene now has a NC freshwater human health standard of 71.4 ug/l (adopted in 4/2003). Ethylbenzene and xylene have EPA National water quality criteria values of 5700 ug/l and 780 ug/l, respectively. Ethylbenzene and xylene did not show reasonable potential to exceed the water quality criteria. No monitoring for these parameters will be required. Benzene indicated reasonable potential to exceed the water quality standard based on 25 data values and a max. predicted concentration that exceeded the allowable concentration. Recommend limit of 71 ug/1 . Toluene already limited at 11 ug/l. Parameter indicated reasonable potential to exceed the water quality standard based on 25 data values and a max predicted concentration that exceeded the allowable concentration. Recommend continuation of limit of 11 ug/L MBAS is discharged from the outfalls, however the NC water quality standard is applicable only to streams classified as water supply. Therefore no RPA was done for this parameter. Effluent monitoring will be continued since the receiving streams have low 7Q 10 flows. PROPOSED CHANGES: • Addition of a limit for benzene of 71 ug/1 based on results of the reasonable potential analysis that indicated potential to exceed the water quality standard. Monitoring for benzene will be twice per month. Based on NCAC 0500 regulations for Class I treatment facility. • Increase monitoring for toluene limit to twice per month, per NCAC 0500 regulations for Class I treatment facility. • Per request from MRO and Charlotte Douglas International Airport, monitoring for propylene glycol has been added to outfalls 002 and 003, it will also be sampled at the instream sampling point known as 004. This will replace monitoring for only glycol at 002, 003, and.004. There is no NC standard or EPA water quality criteria for propylene glycol, will monitor and analyze results of acute toxicity tests to determine if more stringent measures need to be taken in the future. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: 05/24/2006 Permit Scheduled to Issue: 07/ 17/2006 Projected Effective Date of Permit: 09/01/2006 STATE CONTACT: If you have any questions on any of the above information or on the attached permit, please contact Ja*e Nowell at (919) 733-5083 ext. 512. / '11 1 /4 I I1ATF.• �/Z,3/ZOI CharlotteiDouglas International Airport Pactsheet NPDES Reno%al Page 3 REGIONAL OFFICE COMMENT: u NAME: r DATE: NPDES SUPERVISOR COMMENT: NAME: DATE: CharlotteiDouglas International Airport Factsheet NPDES Renewal Paue 4 . REASONABLE POTENTIAL ANALYSIS Charlotte/Douglas International Airport Outfall 001 NCO083887 Ow = 0.2245 MGD Time Period Februay 2004- March 200E Ow (MGD) 0.2245 WWTP Class 7010S (ds) 0 IWC (%) 0 70I0S 100 701OW(ds) 0 0 701OW- 100 3002 (ds) 0 03002 100 Avg. Stream Flow. 0A (ds) 0 0 OA 100 RecVing Stream UT Mcer Branch Stream Class C STANDARDS & PARAMETER TYPE CRITERIA M POL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION (1) zwos/ 5FAyr a /ac MaA dL1► AtibraWcw choertr AwN Acute: WA Benzene C 71.4 uglL 25 9 170.9 _ Chrocsi -- 71 Acute: WA FlItrationsystem brought cntine In Jrine 2005, ,,' Toluene NC 11.0 ugJl 25 9 497.8 S '' • �` _ Chron�: _ 11-- — — — -•s — Acute: WA Ethytbenzsne NC 5700 ug/L 25 11 277.0 Chronic; 5.700 ' , Acute: WA Xylene NC 780. ugll 25 13 1880.0 — f Acute: 7 Copper NC 7 AL 7.3 uglL 0 0 WA ---�-- ----- ---- --- Acute: 22 „ S Cyanide NC 5 N 22 10 uglL 0 0 WA _ Acute: WA Fluoride NC 1.800 uglL 0 0 WA _ _ Chrorrir~ _ 1,800 — — --- — — - — — — Acute: 34 Lead NC 25 N 33.8 ug/L 0 0 WA Chron�: - 25• — — — — — — — — Acute: WA Mercury NC 12 nWL 0 0 WA _ Acute: WA Molybdenum A 3,500 UA 0 0 WA Acute: 261 Nickel NC 86 261 uWL 0 0 WA _ Ctvordc Acute: WA Phenols A 1 N ug/L 0 0 WA Chronic: --• 1 — — Acute: 56 Selenium NC 5.0 56 uglL 0 0 WA Ctvotsicc: --- 5 -- — — — — — — Acute: 1 Silver NC 0.08 AL 1.23 uplL 0 0 WA _ — r Acute: 67 Zinc NC 50 AL 67 ug/L 0 0 WA Chron�: - 50 — — — • Legen& — Freshwater Discharge C a Cam&xgenla NC a Non-carck"erric A c Aesthetic CDIArpa2o06, rpa 5/9/2006 REASONABLE POTENTIAL ANALYSIS I Benzene I Toluene I Date Data BDL--MDL Results 1 Jul-2005 c 1.0 0.5 Std Dev. 2 < 1.0 0.5 Mean 3 Apr-2005 < 1.0 0.5 C.V. 4 Feb-2005 9.4 9.4 n 5 , Jan-2005 < 1.0 0.5 6 < 1.0 0.5 Mult Factor= 7 1 1.0 0.5 Max Value e < 1.0 0.5 Max Pred Cw 9 < 1.0 0.5 10 < 1.0 0.5 11 Jan-2006 <. 1.0 0.5 12 <. 1.0 0.5 13 Mar-2006 <. 1.0 0.5 14 Dec-2004 4-3 4.3 15. '< 1.0 0.5 16 < 1.0 0.5 17 Sep-2004 < 1.0 0.5 18 33.0 33.0 19 1.1 1.1 20 < 1.0 0.5 21 0.9 0.9 22 Apr-2004 18.0 18.0 23 Mar-2004 8.5 8.6 24 21.0 21.0 25 Feb-2004 8.5 8.5 26 27 yy Date Data BDL=IMDL Results 8.1736 1 Jul-2005 1.0 0.5 Std Dev. 4.5076 2 - 1.0 0.5 Mean 1.8133 3 Apr-2005- 1.0 0.5 C.V. 25 4 Feb-2005a 38 38.0 n 5 Jan-2005" 1.0 0.5 5.1800 6 1.0 0.5 Mult Factor= 33.0 ug4. 7 1.0 0.5 Max. Value 170.9 uglL 8 1.0 0.5 Max. Prod Cw 9 1.0 0.5 10 1.0 0.5 11 Jan-2006 1.0 0.5 12 1.0 0.5 13 Mar-2006. 1.0 0.5 14 Dec-20D4 19 19.0 15 1.0 0.5 16 1.0 0.5 17 Sep-2004 1.0 0.5 18 53 53.0 19 4.2 4.2 20 1.0 0.5 21 0.5 0.5 22 Apr-2004` 76.0 76.0 23 Mar-2004 40.0 40.0 24 97.0 97.0 25 Feb-2004 40.0 40.0 26 27 26.9057 15.0292 1.7902 25 5.1300 97.0 497.6 CDIAtpa2006, data 1 ' 5/9/2006 REASONABLE POTENTIAL ANALYSIS Ethylbenzene I Xylene Date Data BDL-1/2DL Results 1 Jul-2005 1.0 0.5 Std Dev. 12.6934 2 1.0 0.5 Mean 7.0880 3 Apr-2005 1.0 0.5 C.V. 1.7908 4 Feb-2005 14. 14.0 n 25 5 Jan-2005 -5.9 5.9 6 1.0 0.5 Mult Factor = 6.1300 7 -:1.0 0.5 Max Value 64.0 8 1.0 0.5 Max Pred Cw 277.0 9 _ 1.0 0.50 10 1.0 0.50 11 Jan-2006 1.0 0.50 12 - 1.0 0.50 13 Mar-2D06 1.0 0.50 14 Dec-2004 11 11.00 15 1.0 0.50 16 1.0 0.50 17 Sep-2004 1.0 0.60 18 17 17.00 19 1A 1.40 20 - 1.8 1.80 21 1.2 1.20 22 Apr-2D04 9.9 9.90 23 Mar-2004 27.0 27.00 24 c 54.0 54.00 25 Feb-2004 27.0 27.00 26 27 Date Data BDL--I2DL 1 Jul-2005 ;f<f 3.0 1.5 2 c 3.0 1.5 3 Apr-2005 6.7 6.7 4 Feb-2005 'r 144 144.0 5 Jan-2005 130 130.0 6 `. <r; 3.0 1.5 7<'• 3.0 1.5 8 <> 3.0 1.5 9 <' 3.0 1.5 10 . <. 3.0 1.5 11 Jan-20D6 <' 3.0 1.5 12 <; 3.0 1.5 13 Mar-2D06 .c 3.0 1.5 14 Dec-2004 �' 101.0 101.0 16 3.0 1.5 16 3.0 1.5 17 Sep-2DD4 5.4 5.4 18 150.0 150.0 19 12.0 12.0 20 8.9 8.9 21 17.0 17.0 22 Apr-2004 220.0 220.0 23 Mar-2004 2D0.0 200.0 24 r 400.0 400.0 25 -. Feb-2004 200.0 200.0 26 27 Results Std Dev. 103.1341 Mean 64.5200 C.V. 1.5985 n 25 Mult Factor = 4.6500 Max. Value 400.0 Max. Pred Cw 1860.0 CDIArpa2006, data -2- 6/9/2006 Re: Draft Permits (12) Subject: Re: Draft Permits (12) From: John Giorgino <john.giorgino@ncmail.net> Date: Wed, 05 Jul 2006 11:07:18 -0400 To: Jackie Nowell <jackie.nowell@ncmail.net> Jackie, that should have gone through OK. Jackie Nowell wrote: John Giorgino wrote: Jackie, I have reviewed the following permits (I am late getting back to you on some of them, but did not have any comments). Thanks for forwarding them. NCO025321 NCO021962 N00074705 NCO023884 NC0005177 NC0000361 NC0000400 NCO084620 NCO085839 NC0000353 NC0000175 NCO060534 Hello John, Do you have any comments on NC0083887-Charlotte Douglas International Airport? It was forwarded on May 24, 2006. Thanks Jackie John Giorgino Environmental Biologist North Carolina Division of Water Quality Environmental Sciences Section Aquatic Toxicology Unit Mailing Address: 1621 MSC Raleigh, NC 27699-1621 Office: 919 733-2136 Fax: 919 733-9959 "The real work of men was hunting meat. The invention of agriculture was a giant step in the wrong direction, leading to serfdom, cities, and empire. From a race of hunters, artists, warriors, and tamers of horses, we degraded ourselves to what we are now: clerks, functionaries, laborers, entertainers, processors of information." - Edward Abbey I of 1 7/5/2006 11:07 AM 14i1.1jRob 1.4 PUBLIC.INOTICE `� , Public Notice' ) r Stale of North -Carolina $ S Enyrronfnenfat INana jernent Commission/IPDES .Urnt Ivtail Service Cei%ter,g g� i 27699 1617 � �* :; ti ,Y s� 1 F;y #t'.Sfs~'+- I *,crr t d_ t r Notificgtion of Intent to Issue a NODES .1Nastewpfer Permit On the bgsis of ft%rough staff review and application ofNC General s#atufe� },4 2 } ^ "other lawful standards atict regirlations;;the North Ccirolrnp'Eniro.nmentaF'taiana emQnao �OO.�rnd. {' I b ►lmsro 'I :rproposes fo''issue a Natrona) Pollutant Discharge EUminafion=System {NPDESj �ivastewater perrt�if tothet: t i person(sj listed below effecfive 45 days frm fhe ubfrsh daterof -this" ,° r 1, r p x . }. - ? 4 x {-''%•jt .b o q, c, •^s 7 N1 rr ! ..I, •4.*t ++'-'•Y '-„ , Written commenf regarding the proposed permit will be accepted until 30Jays after°thepublish cfat of ti 4 i.y�.r ` ithis notice qll comments received pnor fo'thdt date are -considered in the final defermrnatraiis tegcirdmg" the proposed peripit The Director of the t C Divislorl of water. Quality may decide to hold a ublic meeting t.Y; for the' proposed perrrii should the'brvision receive a'significant degree of interest - r 'g i .3 .,, s' +.keha' i Copies of fhe dra'ff permit and other Su�ggrtin information qn file used to determine condjtrc ns{present m the draft permit are available upon request and 6 :and/or requests fcosts' f, or inforrration•#o the NCDivisron"o Wa er Qual'te'at the reproduction Lve vtail comments;; Source Branch at 919-733=5083 extension`52Q Please include'.fhe NPDES pe m�t number (attached enPan't. `communication fnteresfed:person5 maity 1 Y ' Raleigh�NC 27604 i }48 between the h uraslof 8i00ta mDand 600 p m t ter�revarlew the inform Sals(�iaryr$treet,? i. w ; , i.ri i tation on file r (,Charlotte Mecklenburg UtilityxDepa;tment'.(4000„Westmont t Chat otte, NC 282:}7jhas apphecf Corr .renewal of NPDES permit NC002497Q for' the McAlpine Creek WiNTP in ivlecklenburg Cqunfy This permitted, 11 y(_o�d .facility drschprges 64 MGD treaf, d wasteJwater.;to McAlpine Creek Fn the Catawba River. B` "' " .CBgD :ammortra nifragen fecal;Colrform and:;total<"resfdual`chlonne farafer psrn Cuiron discharge may affect future allocations in this portion of fhe Catawba River_ Basin. :, g4altrte This Gough :Eton Inc (PO Box 669583 Charlotte ' NC 2822b) h¢s. applied. for renewc.c' h .. for the' Gough Econ,. !nc VviWTP in Mecklenburg County This of NPDES permt NCd058084': wastewate{r town r�nnamed tributary to the;Catawba River to the Catavviba River BiasrnaSorrie pearerre nefe ,dt maybe water quality limited, whiclh may affect future allocations m this p pion of the�Catawba River. 1 Basin ° - } x y l : } �� NPDES.Permit-Number?NC0083887 Cityoff.Charlotfe McklenburgCount hps:.a ` Y d for renewal pf its permrt..for Chd'rlofte ;Douglas: Internatiohal::Airport„ di$6hidrging .treated wastewater andastorrnwgter .to' F Coffey Creek `UT Ticer'Branch and UTTaggdrt Creekinthe Catawba River Basin: Currenfly total suspended` i solids :oil and gre rse ben;'erie and t.oluene are water qualify limited This discharge may ciffect.future allocations in this portion of the receiving stream x �1�Iuz�p SOC PRIORITY PROJECT: No To: Permits and Engineering Unit I [A Water Quality Section , r Attention: Jackie Nowell ! 1 1 SEP Date: September 7, 2005 1 _ NPDES STAFF REPORT AND RECOMMENDATI01S-- — - County: Mecklenburg NPDES Permit No.: NCO083887 MRO No.: 05-22 PART I - GENERAL INFORMATION 1. Facility and address: Charlotte -Douglas International Airport Post Office Box 19066 Charlotte, N.C. 28219 2. Date of investigation: August 17, 2005 3. Report prepared by: Michael L. Parker, Environmental Engineer II 4. Person contacted and telephone number: Brian Hennessey, P.E., (704) 359-4000. 5. Directions to site: The Charlotte -Douglas International Airport (CDIA) is located at 5501 Josh Birmingham Parkway on the west side of the City of Charlotte. 6. Discharge point(s), list for all discharge points: Outfall001 Outfall002* Outfall002** Outfall003 Outfa11004 Latitude: 350 13' 47" 350 12' 18" 350 11' 55" 350 12' 25" 35 ° 13' 54" Longitude: 80' 56' 57" 800 56' 56" 800 56' 55" 800 55' 45" 800 56' 19" *Existing outfall location **Proposed outfall relocation USGS Quad No.: G 15 NW 7. Site size and expansion area consistent with application: Yes. Sufficient area is available for expansion, if necessary. 8. Topography (relationship to flood plain included): The site is relatively flat, 0-2% slopes. The site is not located in a flood plain. 9. Location of nearest dwelling: Approx. 1500+ feet from the airport site. Page Two 10. Receiving stream or affected surface waters: Unnamed tributaries to Ticer Creek, Coffey Creek and Taggart Creek. a. Classification: C (for all receiving streams) b. River Basin and Subbasin No.: Catawba 030834 C. Describe receiving stream features and pertinent downstream uses: all outfalls (with the exception of outfall 004) discharge to dry ditches, which eventually discharge to their respective receiving streams. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. -a. Volume of wastewater: Intermittent discharge from all three outfalls (outfall 004 is for instream sampling only). Outfall 001 consists of stormwater runoff from the jet fuel tank farm. All stormwater from this area is treated through an oil/water separator and then discharged into a retention pond, which also acts as secondary containment. Discharges from the retention pond are through a manually operated gate valve, which means that discharges may not coincide with a storm event. CDIA is also in the process of having a filter system designed, which will provide additional treatment of the retention pond's effluent, and potentially eliminate the sporadic non -compliances with Toluene, Oil and Grease, and TSR that this outfall occasionally experiences. Outfall 002 is an instream monitoring point in Coffey Creek. This outfall consists of stormwater runoff from the majority of the main airport runway and tenant areas. CDIA has requested in this renewal that this outfall be relocated to provide better access and be more representative of instream conditions, especially with future airport expansion being planned in late 2005 or early 2006. Outfall 003 consists of stormwater runoff from the southeastern side of the site, which includes a small portion of the runway area and a few tenants. This stormwater is directed through a retention pond prior to overflowing into Taggart Creek. The NC Air National Guard, which is located adjacent to CDIA, also discharges into Taggart Creek under a separate NPDES Permit. Outfall 004. No treatment exists. CDIA is required to monitor Coffey Creek upstream of the airport at a point designated as outfall 004 (upstream sample point). No wastewater or stormwater is discharged through this outfall. b. What is the current permitted capacity: All outfalls are intermittent. C. Actual treatment capacity of current facility (current design capacity): 0.036 MGD (outfall 001). Page Three d. Date(s) and construction activities allowed by previous ATCs issued in the previous two years: There have been no ATCs issued in the past two years. An ATC may be necessary for the WWT additions planned for outfall 001. e. Description of existing or substantially constructed WWT facilities: The existing WWT facilities at outfall 001 consist of a 0.036 MGD oil/water separator followed by a retention pond. There is also a retention pond at outfall 003. f. Description of proposed WWT facilities: WWT facilities are being planned for outfall 001 (see Part II, No. 1(a) above). These proposed changes may effect the facility description in the renewed permit. g. Possible toxic impacts to surface waters: Toxic impacts potentially resulting from the discharge of glycol (de-icing fluid) should be evaluated prior to permit reissuance. h. Pretreatment Program (POTWs only): Not Needed. 2. Residual handling and utilization/disposal scheme: Residuals generation at any of the outfalls is not expected. 3. Treatment plant classification: No rating. 4. SIC Code(s): 5171 Wastewater Code(s): 37, 39 MTU Code(s): 53000 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? Public monies were used in the construction of this facility. 2. Special monitoring or limitations (including toxicity) requests. CDIA is not requesting any changes to either the current monitoring or effluent limitations during this renewal. 3. Important SOC/JOC or Compliance Schedule dates: This facility is neither under an SOC nor is one being considered at this time. 4. Alternative analysis evaluation: There is no known alternative to the current discharges. Page Four PART IV - EVALUATION AND RECOMMENDATIONS The permittee, Charlotte -Douglas International Airport (CDIA), requests renewal of the subject permit. The permit provides for the approval to discharge de-icing fluid, stormwater, and wash water through three (3) outfalls. Modifications planned for CDIA during the term of the new permit are detailed in Part II, No. 1(a) above. Pending a final technical review of CDIA's renewal request by the NPDES Unit, it is recommended that the NPDES Permit be renewed. r- Signature of Report Preparer / < Date �.� e-7 Os Water Quality Vgional Supervisor Date h:ldsAdsr05\charaou&dsr till?�f s ar G �s 710� 2so dJ`� �5 zs 9105- iie//off Owvy� rz Dui Oo� vd-G j�S �fr3ifs a�G TSS w0 za �ny c-( �.e C� < 5' �f, 8 /6a 7y /JD C 005 C z�� Ajq (, 3-11 DO p 4- -- / 0, T� I � cw�� ot A& 1-1 V- AIA-L-- Of b u— ,� i l �QQ - (coo (7+ X IL �{o � Q � 3� Whole Effluent Toxicity Testing Self -Monitoring Summary January 18, 2006 FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Carolina Trace Subdivision WWTP chr lim: 76%; no tox until expand to 1.0MGD 2002 NCO038831/001 Begin-II/I/2001 Frequency-Q + Jan Apr Jul Oct NonComp:Single 2003 County. Lee Region: RRO Subbasin: CPFI3 2004 PF: 1.0 Special 2005 7Q10: 0.49 IWC(-/°) 76.0 Order 2006 Cary north WWTP chr lim: 90-/. ;f 2002 - Pass - - Pass - - Pass - - Pass NCO048879/001 Begin: l0/I/2003 Frequency: Q Feb May Aug Nov + NonComp:Single 2003 - pass -- - Pass - - pass - - Pass - County. Wake Region: RRO Subbasin: NEU02 2004 - Pass - - Pass - - Pass - - Pass - PF- 12.0 Special 2005 - Pass - - Pass - - Fag >100 >100 Pass 7Q10:0.30 IWC(%)95.8 order: 2006 Cary South WWTP chr lim: 90% 2002 - Pass - - Pass - - Pass - - Pass - NCO065102/001 Begiw 10/1/2003 Frequency. Q Feb May Aug Nov + NonComp:Single 2003 - Pass - - Pass •- - Pass - - Pass - County. Wake Region: RRO Subbasin: NEU02 2004 - Pass - - Pass - - - Pass - - Pass - PF: 12.8 Special 2005 - Pass - - Pass - • - Pass - - Pass 7Q10: 0.3 IWC(°/.) 90 order: 2008 Catawba WWTP chrlim:2.1% 2002 - Pass - - Pass - -- Pass - - Pass » NCO025542/001 Begin: l0/I/2005 Frcqucncy: Q Feb May Aug Nov + NonComp:Single 2003 - Pass - - Pass - Pass - - Pass - County Catawba Region: MRO Subbasin: CTB32 2004 - Pass - » Pass - Pass - - Pass - PF- 0.225 Special 2005 - Pass - - Pass - - Pass - - Pass 7Q10: 16 IWC(%) 2.1 Order: 2006 Centerclalr Nursing Home chr lim: 90% 2002 Pass - - Pass - - Pass - - Pass - - NCO036561/001 Begin:5/1/2004 Frequency:0 Jan Apr Jul Oct + NonComp:Single 2003 Pass - --- Pass - - Pass - --- Pass - » County Davidson Region: WSRO Subbasin: YAD07 2004 Pass - - Pass - - Pass - - Pass - - PF: 0.010 Special 2005 Pass - - Pass - - Pass - - Pass - 7Q10: 0.0 IWC(°/.) 100 Order- 2006 Chadbourn WWTP chr lim: 90% if 2002 - - pass - - Pass - - Pass - - Pass NCO021865/001 Begin 9/1/2004 Frequency. Q Mar Jun Sep Dec + NonComp:Singic 2003 - - Pass - -- Pass - - Pass - - Pass County Columbus Region: WIRO Subbasin: LUM58 2004 - - Pass>100(p) >100(p) >100(P) Pau,3,100(P) - - Pass - - pass PF: 1.0 Special 2005 - - Pass - » Pass - - Pass - - 7Q10. 0.15 IWC(%.)90 Order: 2006 Charles F. Cates & Sons P-2 chr monit (100,50,25,12.5,6.25) K 2oo2 aA - - <6.26 - - 35A - - 17.7 - - NC0001970/001 Begin:2/1/1996 Frequency Q Jan Apr Jul Oct NonComp: 2003 36A - -- 17.7 - - 35.4 - - 17.7 - - County. Duplin Region: WIRO Subbasin: CPF22 2004 17.7 - - 17.7 - - 35.4 - - Late 35.4 - PF:0.50 Special 2005 17.7 - - 17.7 - - 17.7 - - Late 17.7 7Q10. 0.0 IWC(-/.) 100 Order; 2006 Charlotte -Douglas Airport-001 24hr LC50 ac monit epic Rhd 2002 - - - - - - - - - - - - NCO083887/001 Begin:9/l/2002 Frequency: Q I/calendar Q NonComp: 2003 N110100 - - NR/>100 - » NR - - NR!>10o - - County. Mecklenburg Region: MRO Subbasin: CTB34 2004 3,100 - - - - - :-too - - >100 - - PF: VAR Special 2005 - iD/Q%%�s �'00 - - - - - - - - .-. 7Q10:0.0 IWC(%)NA Order:D�¢ •MJ 2006 Charlotte -Douglas Airport-002 24hr LC50 ac monit epis [lhd 2002- � 2003 NR/aloot NCO083887/002 Begin:9/1/2002 Frequency: 5OWD/A NonComp: 07 N11I33.0t County: Mecklenburg Region: MRO Subbasin: CTB34 �� ?1(p t ; C t` 2004 2-100 PF: NA Special y� O A 2005 7Q10: NA IWC(°/.)NA OrderU�- = tj�ij2�'; �t �Mlf 2ooa 6 Charlotte -Douglas Airport-003 24hr LC50 ac monit epis flhd 2002 NC0083887/003 B4n:9/l/2002 Frequency.5OWD/A NonComp: 2003 NRh1Wt NW2-1Wt - - - -- --• - - - -- - County: Mecklenburg Region: MRO Subbasin: CTB34 2004 - - - - - - - - - - NR PF: NA Special A 2005 22� t./ �i ��s �� o� .7 rA1 2008 7Q10: NA IWC(°/.)NA f 4 Chemetall Foote Corporation 24hr p/f ac MON1T: 90% fthd 2002 - - Fag Fag » Pass- NCO033570/001 Begin 7/12004 Frequency A NonComp: 2003 - - - Pass -- - - - - - - - County. Cleveland Region: MRO Subbasin: BRD05 2004 - - - - Pass PF: NA Special 2005 Pass - - - - - - - - 7QIO: 0.9 IWC(-/.) 17 Order- 2006 it Pre 2002 Data Available LEGEND: PERM = Permit Requirement LET -Administrative Letter - Target Frequency = Monitoring frequency: Q- Quarterly; M- Monthly; BM- Bimonthly; SA- Semiannually; A- Annually; OWD- Only when discharging, D- Discontinued monitoring requirement Begin = First month required 7Q I O = Receiving stream low flow criterion (cfs) + = quarterly monitoring increases to monthly upon failure or NR Months that testing must occur -ex. Jan, Apr, Jul, Oct PF = Permitted flow IWC°/. = Instream P/F = Pass/Fail = NonComp z Current Compliance Requirement (MGD) waste concentration test . AC Acute Data Notation: f - Fathead Minnow; • - Ceriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at CHR - Chronic highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test Reporting Notation: - - = Ditto not required; NR - Not reported Facility Activity Status: I - Inactive, N -Newly Issued(To construct); H - Active but not discharging; t-More data available for month in question; - ORC signature needed 7 Facility: Charlotte/Douglas Airport NPDES#: NCO083887 Receiving Stream: UT Ticer Branch Comment(s): Low Flow Record Station Number: Hydrologic Area Number: Drainage Area Low Flow Record Station: Qave Low Flow Record Station: s7Q10 Low Flow Record Station: w7Q10 Low Flow Record Station: 30Q2 Low Flow Record Station: HA10 must be < 400 sq. miles Drainage Area New Site: 0.00 sq. miles MAR New Site: 1 Qave per Report Equation: 0 cfs s7Q10 per Report Equation: 0.00 cfs w7Q10 per Report Equation: 0.00 cfs 30Q2 per Report Equation: 0.00 cfs Unuseable Drainage Area Drainage Area Ratio: #VALUE! [ new DA / Da at gage #VALUEI Weighted Ratio: #VALUEI Over -ride Inappropriate Site ( y ): Drainage Area New Site: 0.00 miles squared MAR New Site: 1 Weighted Qave per Report Equation: #VALUEI Weighted s7Q10 per Report Equation: #VALUEI Weighted w7Q10 per Report Equation: #VALUEI Weighted 30Q2 per Report Equation: #VALUEI December 30, 2004 Charles We#ver NPDES Unit, -Division of Water Quality .Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, NC 27669-1617 Subject: NPDES Permit Renewal Application Permit No. NCO083887 Charlotte/ Douglas International Airport Mecklenburg County Dear Mr. Weaver: Charlotte/Douglas International Airport (CLT) is submitting the enclosed Short Form C for renewal of the subject NPDES permit. The NPDES permit expires on June 30, 2005, and the permit renewal application must be postmarked by December 31, 2004, as stated in your letter to CLT dated September 9, 2004. Outfalls CLT is currently permitted to discharge used deicing fluid, storm water and washwater through several outfalls. CLT is currently required to monitor storm water discharges from three outfalls as well as at a surface water location upstream of the facility. Outfall 001 contains runoff from the north side of the CLT facility including the jet fuel tank farm. Stormwater from the jet fuel tank farm is treated through an oil/water: separator and discharged into a retention pond. Additionally, as further described in Appendix A of this application, CLT is installing a filter system that pond effluent will pass through before discharging through outfall 001. This system has been designed by an environmental consulting firm and will address CLrs sporadic limit exceedances of Toluene, Oil and Grease, and Total Suspended Solids. The retention pond is used as a means of secondary containment in the event of a spill at the tank farm and has a gate valve that must be manually opened to discharge storm water through the filter systemand then outfall 001. Therefore, storm water is discharged at Outfall 001 throughout the year and may or may not coincide with a storm event. Discharge flow is estimated based on the area and the -drop in depth of the retention pond. Since the discharge does not correspond with a rainfall event, total rainfall and storm duration will not be reported on the Discharge Monitoring Report. Outfall 001 discharges into Ticer Creek. Mr. Charles Weaver Page 2 March 2, 2001 Outfall 002 is an instream monitoring point in Coffey Creek. Outfall 002 includes storm water runoff from the majority of the runway and tenant areas at CLT. CLT requests it be relocated per this application as indicated in Appendix B. Outfall 003 contains storm water runoff from the southeastern side of the CLT facility and contains a small portion of runway area and a few tenants. Storm water at Outfall 003 is directed through a retention pond prior to overflowing to Taggart Creek. The North Carolina Air National Guard located on CLT property also discharges into Taggart Creek under a separate NPDES permit. CLT is also required to monitor Coffey Creek at a point upstream of the facility, which is designated as Outfall 004. Facility Changes CLT will continue to discharge used deicing fluid, storm water and washwater. New tenants have been added at CLT since the 2001 NPDES permit application submittal. The operations for these new tenants are comparable to the existing tenants. Construction for a new fourth runway is planned to begin in late 2005 or early 2006. Likely, a few tenants will be added, and a tenant may be relocated. Runoff from this facility expansion will likely ,ow� discharge into Coffey Creek upstream of the requested 002 relocation point indicated in Appendix B of this application. After plans for the expansion are finalized, CLT will submit a short form permit application with these plans so that an updated permit can be issued. Monitoring Data The NPDES permit requires that one year of monitoring data be submitted with the permit renewal application. Tables 1 through 4 present the monitoring data for Outfalls 001, 002, 003, and 004, respectively. Several tenants at CLT use glycol. Estimated glycol usage for 2004 is presented in Table 5. eub1 /004, Mr. Charles Weaver Page 3 March 2, 2001 TABLE 1 Discharge Monitoring Report Data for Outfall 001 Date Average Effluent Flow MGD Oil & Grease mg/I TSS mg/I Toluene ug/l PH S.U. Acute Toxicity Ethylbenzene ug/I Benzene ug/I Xylene ug/I Permit Limit --------- 45 45 11 6 < x < 9 --------- --------- --------- ___ Jan-04 .21 6 35 82 7.1 Passed 17 19 170 Feb-04 .58 NR Mar-04* .34 11 & 33 11 & 27 40 & 97 7.1 & 7 NR 27 & 54 8.5 & 21 200 & 400 Apr-04 .41 <5 23 76 6.9 Passed 9.9 18 220 May-04 .31 8 58 .53 8.7 NR 1.2 0.89 17 Jun-04 .426 17 16 <1 5.9 NR 1.8 <1 8.9 Jul-04 .276 <5 20 4.2 7.1 Passed 1.4 1.1 12 Aug-04 .423 <5 21 53 7.5 NR 17 33 150 Sep-04 .42 <5 7 <1 6.9 NR <1 <1 5.4 Oct-04 .41 <5 14 <1 6.99 Passed <1 <1 <3 Nov-04 .42 <5 12 <1 7.24 & 7.38 NR <1 <1 <3 Dec-03 <5 6 28 6.4 NR <1 3 220 Notes: * - Error resulted in samples being pulled on 3-1-04 instead of in February 2004 NR - Not Required r►, Mr. Charles Weaver Page 4 March 2, 2001 TABLE 2 Discharge Monitoring Report Data for Outfall 002 Date Average Oil & TSS MBAS Propylene NH3-N PH Effluent Grease Glycol Flow mg/I mg/I mg/l mg/I S.U. MGD mg/I Permit Limit -------- 45 --- --------- -------- -- 6 < x < 9 Jan-04 5.6 <5 7 0.2 6740 .1 &.9 5.8' Sept-04` 35.07 <5 25 <0.2 NR NR 4.9 ` Nov-04 <5 12 <0.1 NR NR 7.08 Suspect pH was read incorrectly by the Laboratory Technician. - Second Quarter sample not collected by Laboratory personnel. Samples collected in January, September, and November. ` - Rainfall not recorded for this event therefore the flow could not be calculated. NR — Not Required As a result of above, a licensed wastewater treatment plant operator now collects all stormwater samples for CLT. TABLE 3 Discharge Monitoring Report Data for Outfall 003 Date Average Oil & TSS MBAS Propylene NH3-N pH Effluent Grease Glycol Flow mg/I mgll mgll mgll S.U. MGD mg/l Permit Limit --------- 45 --------- --------- --------- --------- 6 < x < 9 Jan-04 0.69 <5 14 0.2 62.1 0.2 6.3 Jun-04 0.29 <5 74 <0.2 NR NR 6.7 Sept-04 4.33 <5 25 <0.2 NR NR 3.1` Oct-04" 0.18 <5 4.8 <0.1 NR NR 6.72 Suspected Laboratory technician error. CLT has contracted a licensed wastewater treatment plant operator to collect its stormwater samples as a result or repeated technician sampling problems. The operator observed the technician collected the pH in an incorrect manner that probably led to results that are believed to be inaccurate. - Since contracting the aforementioned wastewater operator, CLT is having its quarterly required samples pulled in the first month of each quarter rather than the last month of each quarter. NR — Not Required Mr. Charles Weaver Page 5 March 2, 2001 TABLE 4 Discharge Monitoring Report Data for Outfall 004 Date Average Oil & TSS MBAS Glycol NH3-N pH Effluent Grease Flow mg/I mg/I mg/I mg/I mg/l S.U. MGD Jan-04 NR <5 4 <0.1 * <0.1 6.5 Jun-04 NR <5 9 0.1 NR NR 6.8 Sept-04 NR <5 46 <0.2 NR NR 5.2** Oct-04 NR <5 31 0.1 NR NR 6.69 * - Laboratory error — hold time expiration — resulted in no reportable test result ** - Suspected laboratory technician error in collecting pH results. Suspect this result is low. This is the background measuring point for CLT, upstream of our facility. Suspect similar errors with other values that were out of range. NR -Not Required TABLE 5 Estimated Glycol Usage for 2003/2004 Deicing Season Month Gallons of Propylene Glycol Used Type I Type IV Jan-04 83999 15135 Feb-04 57625 10068 Mar-04 10443 0 Oct-03 20885 20137 Nov-03 , 10443 10068 Dec-03 5221 5034 Total 188615 60443 Mr. Charles Weaver r1"1 Page 6 March 2, 2001 Recommended Permit Changes CLT is recommending that no changes be made to its current permit limits. CLT is installing a filter system to address its 001 Qutfall problems A A""� Sludge Management Plan Currently, CLT does not generate solids; therefore, a sludge management plan is not being submitted. Primary Industry PPA Airports are not classified as a Primary Industry according to 40 CFR Subpart 122, Appendix A. Therefore, a priority pollutant analysis (PPA) is not being submitted. If you have any questions or require additional information, please contact Brian J. Hennessey, P.E. of my staff at (704) 359-4000. Sincerely, Charlotte/ Douglas International Airport j".o,1 jr Avi ti n Director D:\cdia\environmental\compliance\npdes\renewals\2004renewal\Let Permit appl cover_.doc cc: Brian Hennessey/ CLT CITY OF CHARLOTTE DATE: 12-30-04 TO: NCDENR File SUBJECT: Relocation of Outfall 002 The following is a brief summary of the request. FROM: Brian J. Hennessey, P.E. Environmental Affairs Manager 1. Access to Outfall 002 is difficult. During CLT's annual stormwater inspection the Inspector made a request that access be improved. CLT is happy to do so but thinks relocating it slightly will assist in this endeavor. 2. The attached map indicates CLT's desired location of 002. 3. In choosing this location, CLT is anticipating some of the drainage from its soon -to -be -built new runway will drain through the unnamed tributaries into Coffee Creek, upstream of the requested new 002 site. 4. The access that can be provided to this site will be greatly improved over the current site. CLT appreciates the consideration given to this request. Should you have any questions about this request, please let us know. D:\cdia\environmental\compliance\npdes\renewals\appendixbmemo.doc C December 8, 2004 NC DENR Division of Water Quality, NPDES Permitting 1617 Mail Service Center Raleigh, NC 277699-1617 Attention: David Goodrich Division of Water Quality Re: Notice of Stormwater Discharge Modification NPDES Permit #NC0083887, Outfall 001 Charlotte Douglas International Airport Fuel Farm H&H Job No. CDA-017 Dear David: tijkrl & Hickman 2923 South -I ryon Street Suite 100 Charlotte, NC 28203-5449 704-586-0007 phone 704-586-0373 fax _ __ ..nryWu-.hatthiilulL'u1,CUm _.e, ........ . DEC 1 0 2004 DENR - WATER QUALITY POINT SOURCE BRANCH C i Hart & Hiclanan, PC (H&H) is submitting this notice on behalf of the Charlotte Douglas International Airport to advise that a stormwater treatment system design is being completed to improve the discharge quality from the fuel farm stormwater detention pond. The modifications described in this submittal are proposed to more reliably meet the permitted organic compound discharge concentrations at Outfall 001. In accordance with the referenced permit, stormwater currently accumulates in a lined stormwater detention pond and is periodically discharged through a manually operated valve in an existing concrete wet well. Water exits the wet well via a 15" corrugated metal pipe (CMP) and discharges to an unnamed tributary. The proposed modification to treat the stormwater discharge includes the following components (refer also to the attached drawings): • The 15" CMP outlet in the existing wet well will be closed to allow the wet well to serve as a sump. The water level in the wet well will rise at the same rate the pond water level rises. Pump on/pump off level switches will be installed in the wet well to automatically control a surface mounted centrifugal pump, and a third level switch will be installed to indicate a high level in the wet well. • The centrifugal pump will be installed on a concrete pad next to the wet well and will remove water from the wet well as it rises. The pump discharge will be equipped with a low flow alarm. The low flow alarm and wet well high level alarm will be connected to an auto -dialer to advise facility personnel of the alarm conditions. S:N -Master Proiccu\Charlotte Douglas Into tienal Air n\CDA-017 S W O ign\notice letter.doc Mr. David Goodrich December 8, 2004 Page 2 • The pump will discharge to a bag filter to remove solids, then to a flow -totalizing meter, and will then flow to an organo-clay filter to remove oil and grease. • The clay filter will discharge to two activated carbon vessels arranged in lead -lag configuration. The carbon vessel effluent will discharge to the existing 15" CMP, and the treated stormwater will discharge from the 15" CMP at the same point that it currently discharges from. The treatment system flow rate is designed to empty the detention pond within approximately 48 hours after a 10-year storm event, and will require less time for typical, smaller rainfalls. Based on average hydrocarbon loading and the average annual rainfall for Charlotte, the 1,500 lb clay filter and 1,000 lb carbon filters are expected to require change -out every 6 to 12 months. The bag filter will be changed as needed based on the differential pressure across the filter. The completed design package will be submitted to Mecklenburg County for building permit review in the coming days. Please contact me if you have questions or suggestions regarding this proposed modification. If you have no comments, please contact me at your earliest convenience to confirm we may proceed. Sincerely, Hart & Hickman, PC Bruce Hickman, PE Principal Engineer BKH/mlc Attachments: Dwgs G-100 and M-101 cc: Brian Hennessey — CDIA S. W -Mara Psajcm\CWolle Douglas Intanaional Aigmn\CDA-I ID fk-� .s fO� � — Co, )i ed rs-,A-u- aAJ I&[ rim PYI-OU-14 (2) APPROXIMATE 0 2000 4000 SCALE IN FEET ,m SITE Ar 0 T[ MOW virU^ U a 1. SITE LOCATION MAP DRAWING_ NO. DRAWING TITLE G-100 SITE LOCATION AND WORK SITE LAYOUT M-101 P&ID AND SYSTEM LAYOUT 2. WORK SITE LAYOUT ROAD m - Y NOTES: 1. BASE DRAWINGS PROVIDED BY HDR ENGINEERING, INC. APPROXIMATE 2. SITE TOPOGRAPHY BASED ON SURVEY BY AVIOIMAGE MAPPING 0 50 100 3. POND AREA SERVICES, INC. CHARLOTTE, NORTH CAROLINA DATED NOVEMBER 26, 2001 SCALE IN FEET SITE LOCATION AND WORK SITE LAYOUT DATE: REv. FIGURE NO, 10-25-04 A G- 1 QQ AUTODIALER ----- LOCAL ___________9 ------ ONTRO 1 p o6 PANEL 2' HOSE WITH �----------- �SL�-I PI Fl CAMLOCKS 2' (TYPICAL OF 4) I I I III I r I � I P-10 F-101 CENTRIFUGAL PUMP 2 EFFLUENT BAG FILTER 50 --if--- 20-30 gpm MICRON, 20-30 gpm 5 HIGH LEVEL J 4 I , I , •. PI PI PI M1 PUMP 8A1 EXISTING ON 2- FNPT n2'FNP-TGATE VALVE1)YFOOT VALVE EXISTING10' DIP FROMPOND EXI ONOIJTFALLNP2' FNPT 2- TO TO BE PLUGGED EXISTING WET WELL NOTES: OAUTODIALER, PHONETICS, INC. MODEL THE 4100 OR APPROVED EQUAL, EQUIPPED WITH CELL PHONE DIAL -OUT AND DULL -IN CAPABILITIES AND ACCESSORIES O GOULDS GT07 SELF -PRIMING CENTRIFUGAL PUMP, 20 TO 30 GPM AT 90 FT DISCHARGE HEAD MAX.. OR APPROVED EQUAL O TETRASOLV A-1000 LIQUID PHASE ORGANO-CLAY FILTER. RATED TO 40 PSIG MAX. AT 50 GPM, OR APPROVED EQUAL. FULLY LOADED WITH 1000 LB EC-100 CLAY MEDIA OTETRASOLV AF-1000 LIQUID PHASE ACTIVATED CARBON FlLTER, RATED TO 40 PSIG MAX. AT 50 GPM, OR APPROVED EQUAL, FULLY LOADED WITH 1000LB VIRGIN CARBON ® INTRINSICALLY SAFE FLOAT -TYPE LEVEL SWITCH (TYPICAL FOR THREE) ©FREESTANDING PAINTED STEEL BAG FILTER RATED TO 50 GPM AND 75 PSIG MIN., WITH (10) /1 SIZE MICRON BAGS SUITABLE FOR HYDROCARBON EXPOSURE, SWING -BOLT LID. 2- FPT INLET AND OUTLET OTOTALIZING FLOW METER RATED FOR 50 GPM MAX, NO BRASS, BRONZE OR COPPER WETTED PARTS OLOW FLOW SWITCH, DPDT CONTACTS. NO BRASS, BRONZE OR COPPER WETTED PARTS ODIFFERENTIAL PRESSURE GAUGE RATED TO 75 PSIG MIN., O TO 20 PSIG 9 RANGE, DWYER OR APPROVED EQUAL, NO BRASS BRONZE OR COPPER WETTED PARTS ® PRESSURE GAUGE, OIL -FILLED, 3 DIAL FACE, O TO 60 PSIG RANGE, NO BRASS, BRONZE OR COPPER WETTED PARTS (TYPICAL OF 4) OGLOBE VALVE WITH TAPERED TRIM, SUITABLE FOR HYDROCARBON SERVICE, NO BRASS, BRONZE OR COPPER WETTED PARTS EXISTING LINED POND _ REV I DATE CLAY FILTER 1,000 ACTIVATED CARBON ACTIVATEDC BON lb, 40psig, SOgpm CANISTER SOOIb, CANISTER 5001b, P&ID MAX 40paig, SOgpm MAX 4Opsig, 50gpm MAX 6110 a B'L z 8'H OPEN WALL SHELTER , / EL 748 EL 748 1 , 1 16' 6' PERFORATED DRAIN PIPE W/GRAVEL COVER SECTION A -A' ELEVATION APPROXIMATE 0 5 10 SCALE IN FEET NOTE A CONTRACTOR TO HAND DIG WITHIN 10FT OF COLONIAL PIPELINE. COLONIAL REPRESENTATIVE (TOMMY LANE 704-506-4896 CELL. 704-392-8610 EXT 18 OFFICE) MUST BE NOTIFIED 5 DAYS IN ADVANCE AND MUST BE PRESENT DURING EXCAVATION. 2'a4' TO 15' CMP TO DISCHARGE RETAINING WALL ---_ �G �G � G — u CARBON FILTER DISCHARGE LINE ---.pTO EXISTING 15" CMP<DISCHARGE I EGENFI EXISTING GRADE G - EXISTING GAS LINE EXISTING 15" CMP DISCHARGE TO CARBON FILTER DISCHARGE LINE 0 .. , ,. 5 10 SCALE IN FEET WORK AREA LAYOUT DESCRIPTION DATE: 10-25-04 PREPARED BY PROJECT TITLE DESIGNED BY: H&H Hart & Dickman CHARLOTTE DOUGLAS P&ID AND SYSTEM LAYOUT DRAWN BY: BNR INTERNATIONAL AIRPORT CHECKED BY: BKH )WA PROFESSIONAL CORPORATION CHARLOTTE, NORTH CAROLINA DATE: REV. FIGURE NO, 2923 S. TRYON STREET SUITE 100 CHARLOTTE, NO ZB203 10-25-04 A M -101 JOB NO. COA-017 704-SS6-013137(P) 704-566-0373(F) WWW.HARTHICKMAN.COM MEMORANDUM TO: FROM: PREPARED BY: SUBJECT: October 26, 2004 Susan Wilson, Acting Supervisor Western NPDES Program D. Rex Gleason Q�a Richard Bridgeman � rs Charlotte/Douglas International Airport NPDES Permit No. NC0083887 Mecklenburg County OCT 2 9 2004 i_ In response to compliance inspections conducted on June 26, 2003 and June 29, 2004, T.J. Orr, CDIA's Aviation Director, has submitted a request (enclosed) for actions from the DWQ. The current permit (relevant monitoring/limits pages enclosed) requires "Glycol" monitoring at Outfalls 002 (Main Aircraft Runway Area) and 003 (Southeastern Runway Area) and Instream Station 004 (Background). The monitoring is required three times each year for the two Outfalls and annually for Instream Station 004. The monitoring should be conducted at a defined appropriate time relative to de-icing/anti- icing chemical use. CDIA had historically monitored for ethylene glycol. Enclosed is a copy of an e-mail message dated July 30, 2003 from this office to Tom Belnick concerning appropriate monitoring for "Glycol". It was determined that since CDIA and its tenants predominantly use propylene glycol, rather than ethylene glycol, that the analytical monitoring should reflect that; CDIA has since monitored for propylene glycol. Hopefully, this will be resolved during the next permit renewal process; the permit is scheduled to expire on June 30, 2005. Unless advised to the contrary, this Office will reiterate the previous request for CDIA to monitor for propylene glycol during the coming winter months. CDIA is also requesting the relocation of the downstream monitoring site associated with Outfa11002. The permit currently specifies the sampling location to be 100 feet below the double box culvert at the end of New Dixie Road. Because of the difficulties of access at this site, CDIA proposes to relocate the downstream monitoring site to the southwest quadrant of the intersection of Piney Top Road. A map indicating the desired relocation is enclosed. A similar previous request for the relocation of the sampling site for Instream Station 004 resulted in the issuance of a permit modification (11/6/03). Again, since the permit renewal process is imminent, this is a matter that can ultimately be resolved then. In the interim, this Office will give CDIA approval to relocate the sampling site. Please note on the enclosed map that two unnamed intermittent streams intersect Coffey Creek between the current and proposed sites. Should our approval of the relocation not be acceptable, please advise immediately. Contact either Richard or me should you have questions or comments. October 22, 2004 Point Source Compliance/Enforcement Unit North Carolina Department of Environment and Natural Resources Division of Water Quality 919 North Main Street Mooresville, North Carolina 28115 RE: Notice of Violation — NPDES Permit No. NCO083887 Dated July 29, 2004 Charlotte Douglas International Airport Dear Mr. Bridgeman: This letter is being submitted in response to the subject Notice of Violation. The response uses the same section headings as the NOV and each section is a response to the corresponding NOV section. As such, CDIA would like to respond to the findings of DWQ as follows: Records/Reports: See Attachments > The August 2003 DMR was available for the Inspector's review — we were not told of his trouble locating the report. However, while verifying that we did have this report it became understandable why the Inspector probably had trouble locating it — an administrative error resulted in the first page of the 8/03 DMR not being copied into our records and therefore that page was not in our records with the balance of the report. Further, the entire report was filed appropriately with the Central Files. We had the front page of that report faxed to us from the Central Office and the entire report is attached to this response. ➢ Propylene Glycol is being sampled in response to our Stormwater Inspection of June 2003. At that time we were questioned as to w y we were not testingio�opylene Glycol instead of Ethylene Glycol. Our permit cover letter dated 7-25-02 indicates that Ethylene Glycol and not Propylene Glycol is what we were to sample for (see attached letter). However, in our subsequent response to the 2003 inspection and NOV we indicated that we would test for Propylene Glycol in lieu of Ethylene Glycol. Since we did not hear otherwise from DWQ we assumed this was how we were to proceed. Please clarify which the Airport should be testing. Charlotte/Douglas International Airport P.O. Box 19066 Charlotte, NC 28219 704i359-rCGG Facility Site Review: See Attachments > Access to Outfall 002 is difficult due to security fences and requirements at airports. If DENR could approve relocating this sampling point downstream — please not the attached sketch showing the proposed location to the Southwest Quadrant of the intersection of Piney Top Road and Coffey Creek — CDIA could make access much easier. Further, we will build steps to the new outfall location. > Outfall 004 was approved for relocation by DWQ and the letter indicating such is attached. Flow Measurement: See Attachments > The staff gauge for Outfall 001 has been replaced and a picture of such is attached. Self -Monitoring Program: See Attachments Outfall 001 ➢ All Non -detectable reporting will be changed to reporting as less than the detection limit. ➢ Toluene and Oil & Grease limit exceedances should be rectified by the installation of a carbon absorption unit at outfall 001. The tentative design and installation schedule is attached. ➢ Monitoring is now performed by a licensed wastewater operator and no longer done by the laboratory. The laboratory will still conduct the laboratory testing. This will eliminate missed sampling events such as the TSS in January 2004 and the "February" samples that were taken on 3/1/04. ➢ The wastewater operator will test the pH prior to release and if not acceptable we will adjust the pH accordingly. ➢ All amended DMR's are attached as requested. Outfall 002 ➢ Amended DMR's with the flow, rainfall, and event duration are attached. Outfall 003 ➢ Amended DMR's with the flow, rainfall, and event duration are attached. Outfall 004 ➢ Glycol was sampled during this time; however, a laboratory error resulted in the sample not being tested. A letter from the laboratory is attached. CDIA will make additional efforts regarding testing being conducted on all samples taken. Operations & Maintenance: > The airport intends to review and update the SWPPP to accommodate the changes that occur. Stormwater: > Training has been conducted since the inspection date. Further, a videotape of the training was made and is available for tenants to use as needed. However, as part of updating and complying with our SWPPP, we will continue to implement new training procedures. Charlotte/Douglas International Airport looks forward to continuing to work with NCDENR in managing this process. I ask for your speedy reply to our request to relocate Outfall 002. Should you have any questions about this information, please feel free to contact Brian J. Hennessey at (704) 359-4916. Sincerely, T.. r Avi ti n Director CC: Mr. Rusty Rozzelle NCWQP 700 North Tryon Street, Suite 205 Charlotte, North Carolina 28202 Brian J. Hennessey — CDIA Elmo Langley — CDIA D:\cdia\environmental\compliance\npdes\administration\04novresponse.doc Permit No. NCO083887 A (2). EFFLUENT LINUTATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until e-%-piration. the Permitter is authorized to discharge stormwater and wastewater from OutfaU 002- Main Aircraft Runway Area (which includes runoff from the majority of the runway and tenant areas at CDIA, and includes vehicle washing, fuel storage. aircraft fueling. aircraft maintenance. and de-icing chemical storage/application). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS EFFLUENT LBUTATIONS MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Locations Flow 2 2 E Total Rainfall (inches) 2 2 E Event Duration (minutes) 2 2 E Total Suspended Solids Quarterly Grab D Oil and Grease3 45 mg/1 Quarterly Grab D Detergents (MBAS) Quarterly Grab D pHa Quarterly Grab D Glycols 3/Year Grab D NH3 as N5 3/Year Grab D Acute Toxicity6 Episodic Grab D Notes: 1. Sample locations: E- Effluent. D- Downstream 100-foot below double box culvert at end of New Dbde Road. 2. For each representative storm sampling event, the total precipitation. storm duration, and total flow must be monitored. Total flow shall be either: a) measured continuously: b) calculated based on the amount of area draining to the outfall, the amount of built -upon impervious area, and the total amount of rainfall: or c) estimated by the measurement of flow at 20-minute intervals during the rainfall event. 3. Where possible, the grab sample shall be skimmed from the surface of a quiescent (calm water) zone. 4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 5. Glycol shall be monitored during three discharge events each year at the time of de-icing/anti-icing. or during the next separate discharge event following de-icing/anti-icing. NH3-N shall be monitored only if urea is used for de-icing. 6. Acute Toxicity (Fathead Minnow. 24-hour). Refer to Special Condition A(?)- Acute Toxicity Monitoring (Episodic). There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit No. NCOOS3887 N A (3). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge stormwater and washwater from OutfaH 003- Southeastern Runway Area (which includes runoff from the southeastern side of the CD1A facility containing a small portion of runway area and a few- tenants, and includes vehicle washing, aircraft washing, aircraft fueling and maintenance. fuel storage, and de-icing chemical storage/application). Such discharges shall be limited and monitored by the Permittee as specified below*: EFFLUENT CHARACTERISTICS EFFLUENT LINUTATIONS MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location, Flow 2 2 E Total Rainfall (inches) 2 2 E Event Duration (minutes) 2 2 E Total Suspended Solids Quarterly Grab E Oil and Grease3 45 mg/l Quarterly Grab E Detergents (MBAS) Quarterly Grab E pHa Quarterly Grab E Glycols 3/Year Grab E NH3 as Ns 3/Year Grab E Acute Toxicitys Episodic Grab E Notes: 1. Sample locations: E- Effluent sample collected after the stormwater retention pond treatment system. 2. For each representative storm sampling event, the total precipitation, storm duration, and total flow must be monitored. Total flow shall be either: a) measured continuously: b) calculated based on the amount of area draining to the outfall, the amount of built -upon impervious area, and the total amount of rainfall: or c) estimated by the measurement of flow at 20-minute intervals during the rainfall event. 3. Where possible, the grab sample shall be skimmed from the surface of a quiescent (calm water) zone. 4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 5. Glycol shall be monitored during three discharge events each year at the time of de-icing/anti-icing, or during the next separate discharge event following de-icing/anti=icing. NH3-N shall be monitored only if urea is used for de-icing. 6. Acute Toxicity (Fathead Minnow, 24-hour). Refer to Special Condition A(?)- Acute Toxicity Monitoring (Episodic). There shall be no discharge of floating solids or visible foam in other than trace amounts. ti Permit No. NC0083887 } A (4). INSTRFisM MONITORING REQUIREMENTS Beginning on the effective date of this expiration. the Permittee shall monitor d permit (located in Coffey Creek up tream of the CDIA facilitti•), as specified Instream Station 004- Backgroun below: Notes: 1. Sample locations: I- Instream backgroundall be skimmed from the surface IA facility. 2. Where possible, the grab sample shall of a quiescent (calm water) zone. g/anti-icing. or g the 3. Glycol shall be monitored annually during a discharge event at the time of monitored only if urea isr used for next separate discharge event following de-icing/anti-icing. NH3 -N shall de-icing. Charlotte/Douglas International Airport (NC0083887) Subject: Charlotte/Douglas International Airport (NC0083887) From: Richard Bridgeman <Richard.Bridgeman@ncmail.net> Date: Wed, 30 Jul 2003 10:04:08 -0400 To: Tom Belnick <Ibm.Behrick@ncmail.net>, Michael Parker <MichaeLParker@ncmaiLnev Tom, following our telephone conversation concerning why the NPDES permit includes "Glycol" monitoring for Outfalls 002 and 003, I had the MCWQP staff gather more info on the deicing/anti-icing solutions used by the airlinestairport. The last Fact Sheet and DMR's indicate that the reported data is for ethylene glycol. The lab sheets indicate that Method 8015 (???".Y. 7?) is used to analyze for ethylene glycoL It has been determined that although CDIA encourages the use of propylene glycol, each of the airlines can choose whatever they want to use for deicing/anti-icing. Last winter 153,445 gallons of propylene glycol, 985 gallons of ethylene glycol, and 60,350 pounds of urea were used. That means that 99.36% of the "glycols" used was propylene glycol and only 0.64% was ethylene glycol. Based on the DMR for 1/03, ethylene glycol concentrations ranged from "Not Detected" for Outfall 004 (Background) to as high as 484,000 ug/L for Outfall 002. I'm not sure whether the apparent high concentrations of this very toxic organic are actually significant relative to water quality, but can you imagine what concentrations would have been reported had they tested for non -toxic propylene glycol. I would suggest that the next permit require monitoring/reporting based on the deicing/anti-icing solutions actually used, and that CDIA be discouraged from using ethylene glycol; in the current permit there is no restriction on how much antifreeze can be discharged into our surface waters. Richard Bridgeman - Richard.Bridgeman@ncmail.net Environmental Chemist II North Carolina Dept. of Environment & Natural Resources Div. of Water Quality 919 N. Main St. Mooresville, NC 28115 Ph: (704) 663-1699 Fax: (704) 663-6040 Richard Bridgeman <Richard.Bridgeman(@ncmail.net> Environmental Chemist II Div. of Water Quality NC DENR - Mooresville 1 Of 10/26/2004 10:13 AM Discharge Point 001 Latitude 35"13'47" Longitude 80'5657" Jfffil I - -f r I I InstreamPomtWl latitude 35'13'54' 1.a10tude 80156, Igr Discharge 0, Longitude 8T59 56" — — lot A Discharge Point UU3 LQ\ latitude 35*120'25" J.ong:iuide. 80'55'45" Chariotte/Douglas int. Ai, -Port - NC0083887 Facility USGS Quad t: n Location 15NW Lai: 35013'47" Receiving Strearn:Cofiey Creek Long:80056'57" 7i-e- Creek qf-." Tagger Creek AjOrth] I SCALE 1:24,000 1,05 1�146F— RErLAczfj mpVYE-k w NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Govemor November 9, 2004 Mr. T. J. Orr,' Aviation Director CharlottelDouglas International Airport P.O. Box 19066 Clzarlotte; NC- 28219 Dear Mr. Orr: William G. Ross, Jr., Secretary Alan W. Klimek, P.E., DiM.Ctvr«�. 1 � � N 0 d �D � 4 NOV 1 2 2004 LD 1' DENR - WATER QUALITY. POINT SOIJRCE_.13RANCH. _` Subject: Requests - CDIA Response Let eiDated"October 22, 2004: Charlotte/Douglas International Airport NPDES Permit No. NC0083887- Mecklenburg County This is in response to your letter dated October 22, 2004, which was submitted, in part, in response to a Compliance Evaluation Inspection Report. In the referenced letter, you ask for clarification concerning the required monitoring for "glycol". ' Glycol' is specified, but not defined in the NPDES Permit. In past years, CDIA and its tenants used ethylene glycol predominantly for deicinglanti-icing. , During the compliance inspection conducted in June 2003, it was determined that a change to propylene glycol had been made. Based on information supplied by CDIA, it was determined that during the winter of 2002/2003.>99% ofthe "glycols" used was propylene glycol and <1.0% was ethylene glycol. If ,propylene glycol is used predominantly for the deicing/anti-icing solution this coming winter, it is requested that the required monitoring reflect that use. This issue should be addressed during the forthcoming permit renewal process. have also o requested the relocation of the downstreammonitoring site asses with O&M 002. There appear to be two unnamed intermittent streams that intersect Coffey Creek between the current and proposed sites. Neither the MRO staff nor the relevant Raleigh staff presently has objections to the relocation of the current monitoring site to that proposed by CDIA. Be afire, however, that this issue will be given further consideration during the permit renewal process. In the interim, you have the approval of this office to relocate the downstream monitoring site to the southwest quadrant of the intersection of Piney Top Road, as proposed MooresvMe Regional Office One 610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115 NofthCarohna Phone: 704-663-1699 / Fax 704-663-60401 Internet: h2menr.statextus A7ll fs iyrev /Ar An Equal Opportunity/AfRrmabe Action Employer— 50°% RecycWl0% Post Consumer Paper Mr. T. I Orr CDIA Page Two November 9, 2004 Should you have questions or comments, please do not hesitate to contact Richard Bridgeman or me at 704/663-1699. Sincerely, D. Rex Gleason, P.E. Surface Water Protection Regional Supervisor Cc: SWP/WestemNPDES Program Rusty Roaelle, MCWQP 1_: Charlotte/Douglas International Airport (NC0083887) , • P l Subject: Charlotte/Douglas International Airport (NC0083887) Date: Wed, 30 Jul 2003 10:03:56 -0400 From: Richard Bridgeman <Richard.Bridgeman@ncmail.net> Organization: NC DENR - Mooresville Regional Office To: Tom Belnick <Tom.Belnick@nemail.net>, Michael Parker <Michael.Parker@ncmail.net> Tom, following our telephone conversation concerning why the NPDES permit includes "Glycol" monitoring for Outfalls 002 and 003, I had the MCWQP staff gather more info on the deicing/anti-icing solutions used by the airlines/airport. The last Fact Sheet and DMR's indicate that thereported data is for ethylene glycol. The lab sheets indicate that Method 8015 (?????????) is used to analyze for ethylene glycol. It has been determined that although CDIA encourages the use of propylene glycol, each of the airlines can choose whatever they want to use for deicing/anti-icing. Last winter 153,445 gallons of propylene glycol, 985 gallons of ethylene glycol, and 60,350 pounds of urea were used. That means that 99.36% of the "glycols" used was propylene glycol and only 0.64% was ethylene glycol. Based on the DMR for 1/03, ethylene glycol concentrations ranged from "Not Detected" for Outfall 004 (Background) to as high as 484,000 ug/L for Outfall 002. I'm not sure whether the apparent high concentrations of this very toxic organic are actually significant relative to water quality, but can you imagine what concentrations would have been reported had they tested for non -toxic propylene glycol. I would suggest that the next permit require monitoring/reporting based on the deicing/anti-icing solutions actually used, and that CDIA be discouraged from using ethylene glycol; in the current permit there is no restriction on how much antifreeze can be discharged into our surface waters. Richard Bridgeman - Richard.Bridgeman@ncmail.net Environmental Chemist II North Carolina Dept. of Environment & Natural Resources Div. of Water Quality 919 N. Main St. Mooresville, NC 28115 Ph: (704) 663-1699 Fax: (704) 663-6040 Richard Bridgeman <Richard.Bridgeman@ncmail.net> Environmental Chemist II NC DENR - Mooresville Div. of Water Quality I of 1 7/30/03 10:10 AM