NC0083887_NOV2018PC0033_20180220

Water Resources w
L'm ironmental Quality
20 February 2018
CERTIFIED MAIL #: 7016 1370 0000 2595 7917
Mr. Jack Christine
Chief Operating Officer
Charlotte -Douglas International Airport
PO Box 19066
Charlotte, North Carolina 28219
Dear Mr. Christine:
ROY COOPER
Clocernor
MICHAEL S. REGAN
.S'ecretm'r
LINDA CULPEPPER
hae, un Otre, for
Subject: Notice of Violation
Compliance Evaluation Inspection
Charlotte Douglas International Airport
NPDES Permit No. NCO083887
Mecklenburg County
Tracking #: NOV-2018-PC-0033
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted
at the subject facility on February 12, 2018, by Mr. Wes Bell of this Office. Please inform the facility's
CLT Environmental Manager and Operator -in -Responsible Charge (ORC) of our findings by forwarding
copies of the enclosed report.
This report is being issued as a Notice of Violation (NOV) due to the following:
- unpermitted discharge of wastewater into the stormwater system at the centralized disposal
location (Triturator) for airplane lavatory waste;
- failure to monitor flow at Outfall 001 in August 2017;
- failure to monitor the effluent (all parameters) at Outfall 001 in September 2017;
- analyses of pH outside the required holding time (2017 quarterly sampling at Stormwater
Outfalls 002, 003, 004, F, H, K);
- analyses of dissolved oxygen and pH outside the required holding time (January and March
2017 de-icing events at Stormwater Outfalls 002 and 004);
- failure to maintain ORC visitations and any associated operation/maintenance activities at
Outfall 001 treatment facility for August and September 2017.
Slate of North Carolina BMronmental Quality Water Resourced Water Quality Regional Operations
Mooresville Regional OITce610 Fast Center Avenue, Suite 310', Mooresville. North Carolina 281 IS
704-663-1699

Mr. Jack Christine
Page Two
February 20, 2018
All above -noted findings are violations of the subject NPDES Permit and North Carolina General
Statute (G.S.) 143-215.1 as detailed in the Record Keeping/Summary, Non-Stormwater/Summary,
and Laboratory Sections of the attached report. Pursuant to G.S. 143-215.6A, a civil penalty of not more
than twenty-five thousand dollars ($25,000.00) per violation, per day may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued
pursuant to G.S. 143-215.1.
It is requested that a written response be submitted to this Office by March 16, 2018, detailing
the actions taken to address all violations noted in this report. In responding, please address your
comments to the attention of Mr. Wes Bell.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell
at [phone], or via email at wes.bell( ncdenr.Kov.
Sincerely,
CDocuSigned by
J/14CC7425
W. �orey�asmger Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
cc: Jimmy Jordan, CDIA (via E -copy)
Rusty Rozzelle, MCWQP
MSC -1617 Central -Basement
m

United States Environmental Protection Agency
Form Approved.
EPA Washington, D C 20,430
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 15 I 3 I N00083887 111 12 18/02/12 17 18 I L` I 19 f ,e I 20 LJ
211 1 1 1 1 1 111 111 1 11 1 1 1 11 1111 1 1 11 1 1 1 11 1 1 11 1 11 I_ f6
I
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
67 2.0 701, I 71 72 LN] 731 751 I I I SO
LJ ty
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09'.00AM 18/02/12
11/12/01
Charlotte Douglas International Airport
Exit Time/Dale
Permit Expiration Date
5501 Josh Birmingham Pkwy
04'.00PM 18/02/12
15/06/30
Charlotte NC 28208
Names) of Onsite Representative(s)tTilles(s)/Phone and Fax Number(s)
Other Facility Data
Kellie H Hedrick/ORC/980-202-2377/
Name, Address of Responsible Officialf-rille/Phone and Fax Number
Contacted
Jack Chnsline,PO Box 19066 Charlotte NC 28219/Chief Operating
Officer/704-359-4932/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenancs Records/Reports
SelfMonitoringProgram 0 Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signatures) of Inspectors) Agency/Office/Phone and Fax Numbers Date
Wes Bell MRO WQ//704-663-1699 Ext.2192/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger MRO WQ//704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
DocuSigned by:
A14CC681AF27425...
Page#

NPDES yr/mo/day Inspection Type
31 NCO083887 I11 12I 18/02/12 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On-site Representatives:
The following personnel were in attendance during the inspection: Mr. Jimmy Jordan/CLT
Environmental Manager/CDIA; Mr. Josh Eller/Environmental Compliance Specialist/CDIA; and Ms.
Kellie Hedrick/ORC/Environmental Process Solutions, PLLC.
RECORD KEEPING SECTION cont'd:
The following monitoring/documentation violations at Outfall 001 were noted during this review period:
- No effluent flow and pH were reported on the edmr during the sampling event in August 2017. The
Division has previously addressed the failure to monitor pH by issuing a Notice of Deficiency (NOD).
- No effluent monitoring was performed in September 2017.
- No facility visitations by the ORC and/or Backup ORC (Outfall 001) were documented on the edmr
for the entire month of August 2017 and the first three weeks of September 2017.
- No on-site records regarding ORC visitations, maintenance activities, etc. were available for review
during August — September 2017 time period, with the exception of the 9/29/17 visitation by the Backup
ORC.
Note: CDIA staff provided a written explanation of the circumstances that led to the August and
September 2017 monitoring violations (including personnel issues with the ORC at that time); however,
measurable storm events did occur during September 2017 with no monitoring being performed. It is
the permittee's responsibility to ensure compliance with all permit requirements (including all
monitoring frequencies, ORC/Backup ORC visitations, sampling documentation, record retention
requirements, etc.).
CDIA currently has appropriately certified operators (ORC and Backup ORC) with all visitations,
maintenance activities, etc. being properly documented and maintained on-site. CDIA had designated
a new ORC in October 2017. This office recommends that the CDIA staff maintain communications
with the ORC throughout the month (not during the end of the month as done previously) to ensure all
monitoring is performed in accordance with the permit. CDIA staff have also initiated the sampling of
all stormwater outfalls since 2017 (prior sampling was performed by the previous ORC).
STORMWATER:
The Stormwater Pollution Prevention Plan (SPPP) records were organized and well maintained.
Facility stormwater inspections were performed (usually with tenants) in 2017. Employee/Tenant
training events were performed in December 2017 and the SPPP was last updated on 12/13/17. A
contracted company is in the process of updating the SPPP including site maps, BMPs, etc. The
facility must ensure that the SPPP includes a listing of all structural BMPs on-site (as part of the BMP
Summary in the Stormwater Management Plan Section) and the re-evaluations of the effectiveness of
these BMPs as part of the annual SPPP update.
Qualitative monitoring was performed at all stormwater outfalls (approximately twenty-seven) in
June/July 2017 and December 2017. All qualitative monitoring data is documented on the Division
approved forms. Analytical monitoring (quarterly) at the representative outfall locations (002, 003, F, H,
K, 004) were performed in March, May, August, and November 2017. Note: Outfall 004 is an instream
background station upstream of the CDIA facility located in Coffey Creek. The facility did not exceed
any benchmark values.
Sampling was performed at all representative ouffalls (002, 003, F. H, K, 004) during de-icing events in
January, March, and December 2017 and January 2018. Note: The subject permit only requires
monitoring during de-icing events at Outfalls 002 and 004. Benchmark exceedances for BOD (1 -total)
Page#

Permit: NCO083887
Inspection Date: 02/12/2018
Owner - Facility: Charlotte Douglas International Airport
Inspection Type: Compliance Evaluation
and COD (4 -total) were reported at Outfall 002. The results of the additional monitoring performed on
the remaining outfalls would have also revealed benchmark exceedances (if monitoring was required)
at Outfall 003 (2 — BOD, 3 — COD), Outfall H (1- BOD, 1 -ammonia). and Outfall K (2 -BOD, 2 -COD).
Note: (2 - BOD) as an example, denotes two separate BOD exceedances during the listed review
period.
The facility is currently in the Tier 2 monitoring protocol (monthly) at Outfall 002 due to the COD
benchmark exceedances.
NON-STORMWATER DISCHARGE:
The wastewater from the airplanes is removed and transported to a centralized location (Triturator)
prior to being conveyed into the sanitary sewer system. During the facility inspection, one of the
tenant's employees/sub-contracted personnel was observed washing residual wastewater and debris
(toilet paper, etc.) from the inside the disposal area of the Triturator and into an adjacent stormwater
drainage system. In addition, multiple puddles of a deodorizer were also observed adjacent to the
stormwater drainage system at this location. All drainage from this area is conveyed to Coffee Creek.
Please be advised that the discharges of wastewater and/or deodorizer are not allowed under this
permit and must be properly disposed into the sanitary sewer system.
Page#

Permit: NCO083887
Inspection Date: 02/12/2018
Permit
Owner - Facility: Charlotte Douglas International Airport
Inspection Type: Compliance Evaluation
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Yes No NA NE
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
M ❑ ❑ ❑
Comment: The Division received the permit renewal application package on 1/2/15.
0
❑
❑
❑
The last compliance evaluation inspection was performed at the facility on 11/4/15
by DWR
❑
❑
staff.
Is the backup operator certified at one grade less or greater than the facility classification?
0
❑
❑
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
❑
0
❑
❑
Is all required information readily available, complete and current?
❑
0
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
❑
❑
0
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
0
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
M
❑
(If the facility is = or> 5 MGD permitted Flow) Do they operate 24/7 with a certified operator
❑
❑
M
❑
on each shift?
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
0
❑
❑
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
0
❑
Comment: Outfall 001 effluent monitonna data was reviewed for 2017. No effluent limit violations were
reported during the review period. An acute toxicity failure was reported in March 2017:
however, this parameter does not have an effluent limit (monitor only).
See "Summary" Section for additional comments regarding the self-monitoring program
(Outfall 001 and Stormwater).
Page# 4

PenniC NC0083887 Owner -Facility: Charlotte Douglas International Airport
Inspection Date: 02/12/2018 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
M
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
❑
❑
0
❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
❑
Comment: On-site field analyses are currently being performed under CDIA's laboratory certification
#5706 (dissolved oxygen and pH) and Environmental Process Solutions' certification #5695
(pH — Outfall 001 only). Pace Analytical Services and ETT (toxicity) have also been
contracted to provide analytical support.
The quarterly pH samples collected in March, May. August, and November 2017 at Outfalls
002 003 004 F H and K were not analyzed within fifteen -minutes. In addition, the
dissolved oxygen and pH samples at all above -noted outfalls were not analyzed within
fifteen -minutes during the January and March 2017 de-icing sampling events. Please be
advised that dissolved oxygen and pH samples must be collected and analyzed within
fifteen -minutes as required by the subject NPDES Permit and 40 CFR 136.3, Table II.
Effluent Sampling
Yes No NA NE
Is composite sampling Flow proportional?
❑
❑
M
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
M
❑
❑
❑
representative)?
Comment: The subject permit requires effluent grab samples at all outfalls.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑
sampling location)?
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? M ❑ ❑ ❑
Page# 5

Permit: NCO083887
Inspection Date: 02/12/2018
Owner -Facility: Charlotte Douglas International Airport
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ M ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The treatment facility for Outfall 001 consists of the following: oil/water separator, settling
basin/pond: pump/wet well: particulate filter: flow measurement, and three GAC units
operated in series. The contents in the oil/water separator are removed and disposed
(as -needed basis) by a contracted company (HazMat).
The treatment facility appeared to be properly operated and well maintained.
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
❑
❑
0
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
N
❑
Comment: Outfall 001 flow measurements are based on an in-line flow meter that was installed in
December 2015.
Effluent Pipe
Yes
No NA NE
Is right of way to the outfall properly maintained?
N
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
IN
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: No discharge was observed at Outfall 001. The discharges at Outfalls H, K. 003, and 004
were clear with no petroleum sheens. The discharges at Outfalls 002 and Danga Lake were
turbid due to runoff from recent rainfall events.
Page# 6