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HomeMy WebLinkAboutNC0083887_Inspection_20190715ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Mr. Jack Christine Chief Operating Officer Charlotte Douglas International Airport PO Box 19066 Charlotte, North Carolina 28219 Dear Mr. Christine: NORTH CAROLINA Environmental Quality July 15, 2019 Subject: Compliance Evaluation Inspection Charlotte Douglas International Airport NPDES Permit No. NCO083887 Mecklenburg County Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on July 9, 2019, 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 a copy of the enclosed report. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell(cr�,ncdenr.gov. Sincerely, DocuSigned by: >�44" H PU4,f for F161FB69A2D84A3... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosure: Inspection Report D Q � North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 NORTH CAROLINA Da"MoM a enWmn�bl mwnq 704,663.1699 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 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 I 2 IF I 3 I NCO083887 111 12 I 19/07/09 I17 18 I S i 19 i G i 201 I 211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 2.0 70 Id I 71 [.. I 72 73 L_LJ74 751 I I I I I I I80 I —I u 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 oermit Number) 09:20AM 19/07/09 11/12/01 Charlotte Douglas International Airport 5501 Josh Birmingham Pkwy Exit Time/Date Permit Expiration Date Charlotte NC 28208 03:15PM 19/07/09 15/06/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Kellie H Hedrick/ORC/980-202-2377/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Jack Christine,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 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Laboratory Storm Water Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date EDoby: 7/15/2019 Wes Bell �� �� MRO WQ//704-663-1699 Ext.2192/ A61696D90CC343T Signature of Management Q A Reviewer Agency/Office/Phone d Faic`�i]grn�6ebrSy anDate A!*,t" H Pa*." Andrew Pitner MRO WQ//704-663-1699 Ext.21 7.15.19 F 161 FB69AMUA3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO083887 I11 121 19/07/09 117 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: Kellie Hedrick/Environmental Process Solutions - ORC, Jimmy Jordan/CDIA — Environmental Manager and Josh Eller/CDIA — Environmental Compliance Specialist. STORMWATER: The Stormwater Pollution Prevention Plan (SPPP) records were organized and well maintained. Facility stormwater inspections were performed (usually with tenants) in 2018. Employee/Tenant training events were performed in December 2018 and the SPPP was last updated in February 2019. The facility must ensure that the effectiveness of any on -site structural BMPs are re-evaluated (and documented) as part of the annual SPPP update. Semi-annual qualitative monitoring was performed at twenty-six (26) stormwater outfalls and documented on the Division approved forms. Analytical monitoring (quarterly) at the representative outfall locations (002, 003, F, H, K, 004) was performed in March, April, May, September and November 2018 and April 2019. The following benchmark exceedances were reported during the 4/23/18, 9/26/18 and 12/14/18 sampling events: 4/23/18 — Outfall 002 (COD, turbidity, TSS) and Outfall 003 (BOD); 9/26/18 — Outfall 004 (turbidity); 12/14/18 — Outfall 002 (BOD), Outfall 004 (turbidity) and Outfall H (turbidity). Note: Outfall 004 is an instream background station upstream of the CDIA facility located in Coffey Creek. The last sampling during a de-icing event was performed at all representative outfalls (002, 003, F, H, K, 004) on 4/3/19. The subject permit only requires monitoring during de-icing events at Outfalls 002 and 004. Benchmark exceedances for BOD and COD were reported at Outfall 002. The additional monitoring at the remaining outfalls also revealed benchmark exceedances at Outfall 003 for BOD and COD. The summary of aircraft de-icing fluid usage for the winter season (October 2018 — April 2018) was included with the May 2019 edmr. Urea is no longer being purchased and sodium formate is now the primary solid deicer. 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. Residual paper debris was observed on the ground leading to the stormwater drainage system. Note: No discharges were observed during this inspection. Due to the history of poor housekeeping measures and unpermitted wastewater discharges into the stormwater drainage systemat at this location, CDIA staff should perform (and document) periodic inspections throughout the week to ensure all wastewater/paper products are being properly disposed. PETROLEUM RELEASE: CDIA staff have continued to address small petroleum releases originating from the bank and into Coffey Creek adjacent to the American Airlines Maintenance Hangar. The petroleum sheens were originally observed in Coffey Creek in early December 2018 and CDIA staff initiated remedial activities including the containment, collection and disposal of the petroleum discharges. The origin of the petroleum discharges has not been determined and the assessment and delineation activities are currently being performed according to the Division of Waste Management/UST Section's requirements. Petroleum sheens were observed at this location during this inspection. Absorbent pads were immediately placed in the stream to contain/collect the petroleum discharges. CDIA staff Page# Permit: NC0083887 Inspection Date: 07/09/2019 Owner -Facility: Charlotte Douglas International Airport Inspection Type: Compliance Evaluation must continue to ensure that all absorbent pads, booms, etc. are properly maintained at all times until the source and all affected areas are properly remediated. Page# Permit: NCO083887 Owner -Facility: Charlotte Douglas International Airport Inspection Date: 07/09/2019 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new 0 ❑ ❑ ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? 0 ❑ ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The Division received the permit renewal package on 1/2/15. The last compliance evaluation inspection was performed by DWR staff on 2/12/18. 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)? M ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? ❑ ❑ ❑ 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? ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ ❑ on each shift? Is the ORC visitation log available and current? ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: The records reviewed during the inspection were organized and well maintained. Outfall 001's eDMRs were reviewed for the period June 2018 through May 2019. No effluent limit violations were reported and all monitoring frequencies were correct. Laboratory Yes No NA NE Page# 4 Permit: NCO083887 Owner -Facility: Charlotte Douglas International Airport Inspection Date: 07/09/2019 Inspection Type: Compliance Evaluation 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? 0 ❑ ❑ ❑ # 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)? 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 performed under CDIA's laboratory certification #5706 (dissolved oxygen and PH) and Environmental Process Solutions' certification #5695 (pH — Outfall 001 only). Pace Analytical Services (all permit parameters except field and toxicity) and ETT Environmental (toxicity) have also been contracted to provide analytical support. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ 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 0 ❑ ❑ ❑ representative)? Comment: The subject permit requires effluent grab samples. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ 0 ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The treatment facilitv for Outfall 001 consists of the followina: oil/water seDarator. settlin basin/pond, pump/wet well, particulate filter (10 micron), flow measurement, sand filtration tank, and two GAC units operated in series. The contents in the oil/water separator are removed and disposed by a contracted company (HazMat). The treatment facility appeared to properly operated and well maintained. The settling basin/pond liner was replaced in June 2018 and the media in both GAC units was replaced in January 2019. The ORC and staff must ensure that any backwash water from the sand filtration tank (manually performed) is returned back to the pond for continued treatment. Flow Measurement - Effluent # Is flow meter used for reporting? ■ ❑ ❑ ❑ Page# 5 Permit: NCO083887 Owner -Facility: Inspection Date: 07/09/2019 Inspection Type: Charlotte Douglas International Airport Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Is flow meter calibrated annually? ❑ ❑ 0 ❑ Is the flow meter operational? M ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: Outfall 001 flow measurement consists of an in -line flow meter. Flows are based on the flow rate and pump run time during the manual discharge/sampling events. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ❑ ❑ 0 ❑ Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ M ❑ Comment: No discharges were observed at Outfall 001 during the inspection. The CDIA staff must ensure that the vegetation is properly maintained at the outfall location. The discharges from Outfalls 002, 003, 004, F, H and K were clear with no petroleum sheens. Page# 6