Email (2)

Grzyb, Julie
From: Grzyb, Julie
Sent: Monday, October 01, 2012 12:05 PM
To: Belnick, Tom
Subject: RDU permit renewal
To: Tom Belnick
From: Julie Grzyb
Date: 10/1/2012
Subject: RDU permit renewal
The Raleigh Durham Airport will expire on Feb., 28, 2013.
An application for renewal was received on Aug. 30, 2012.
While RDU recognizes they are subject to the new regulations I do not see a certification as to whether or not urea based
pavement deicers will be used. (see certification requirement below under 449.10).
These facilities can be regulated via a general stormwater permit or an individual permit. The effluent guidelines spell out some
general stormwater permit guidelines that should be considered as minimum standards/guidelines for the individula stormwater
permit.
Effluent Limitations Guidelines and New Source Performance Standards
for the Airport Deicing Category; Final Rule adopted Wednesday, May 16, 2012
see 40 CFR Parts 9 and 449). Effective June 15, 2012, however, For individual permits, ELG
provisions are typically incorporated when those permits are renewed, although permit
authorities may require modification upon promulgation upon consent of the permittee.
These permits are 100% stormwater related and I believe should be written as stormwater permts.
I can help with reasonable potential analyses to assess which pollutants discharged from the
Bulk Fuel Facility - 002 should be maintained and/or limited. However, after a review of the
regulations, it seems to me the stormwater unit should take the lead on this permit. Please
let me know the best way to proceed.
Most important aspects
449.10
of the regulations:
Table I --BAT Limitations
Wastestream Pollutant Daily maximum
Ammonia limitation. If a permittee chooses to comply with the
compliance alternative specified in Sec. 449.10(a) or Sec. 449.11(b),
the permittee must conduct effluent monitoring at all locations where
pavement deicing with a product that contains urea is occurring, prior
to any dilution or commingling wit any non -deicing discharge.
(c) Recordkeeping. (1) The permit shall provide that the permittee
must maintain on site, during the term of the permit, up to five years,
records documenting compliance with paragraphs (a) through (b) of this

section 'These records include, but are not limited to, documentation
of wastewater samples collected and analyzed, certifications, and
equipment maintenance schedules and agreements
(2) At the Director's discretion, a requirement may be included in
the permit for the permittee to collect, and maintain on site during
the term of the permit, up to five (5) years of data on the annual
volume of ADF used
A complete copy of the regulations can be found at
http 1/www regulations gov/#IdocumentDetail,D=EPA-HQ-OW-2004-0038-1295
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