NCS000508_APPLICATION_20100212

STORMWATER DIVISION CODING SHEET
NCS PERMITS
PERMIT NO.
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING REPORTS
Q APPLICATION
❑ COMPLIANCE
❑ OTHER
DOC DATE
❑ `7 UI 0 �-
YYYYM M D D

DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
FACTSHEET
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PERMIT TO DISCHARGE STORMWATER
Permit No. NCS000508 Date: February 12, 2010
TYPES OF DISCHARGES COVERED
a. Applicant
Piedmont `I riad Airport Authority
b. Types of Operations Covered
The requirements in this permit apply to stormwater discharges associated with industrial activity from
airport operations identified by SIC Code Major Group 45, specifically:
• Service, repair, or maintenance of aircraft and ground vehicles;
• Equipment cleaning and maintenance (including vehicle and equipment rehabilitation mechanical
repairs, painting, fueling, lubrication); and
• Deicing/anti-icing operations which conduct the above described activities.
c. Characteristics of Discharged Stonnwcrter
Discharged stormwater is expected to contain some pollutant materials associated with aircraft maintenance
operations (fueling, repairing, cleaning, and painting) as well as materials associated with fuel storage and
deicing chemicals. The activities, pollutant sources, and pollutants detailed in Table I are commonly found
at air transportation facilities and are expected to be present at the permitted facility.
Table 1. Common Activities, Pollutants Sources, and
Associated Pollutants at Air Transportation Facilities
Activity
Pollutant Source
Pollutant
Aircraft deicing/anti-
Runoff of spent deicing chemicals (e.g., ethylene
Biochemical oxygen demand
icing
glycol or propyiene glycol) from aircraft exteriors
(BOD)
Runway deicing/anti-
Runoff of spent deicing chemicals (e.g., ethylene
BOD, nitrogen, ammonia
icing
or propylene glycol, urea, potassium or sodium
acetate, potassium or sodium formate) from
deicing areas
Aircraft servicing
Spills or leaks during servicing
Engine oil, hydraulic fluid,
fuel, lavatory waste
Aircraft fueling
Spills and leaks during fuel transfer, spills due to
Jet fuel, fuel additives, oil,
"topping off' tanks, runoff front fueling areas,
lubricants, heavy metals
washdown of fireling areas, leaking storage tanks

NCS000508 Fact Sheet — NC DENR DWQ February 12, 2010
Aircraft, ground
Spills and leaks during maintenance
Engine oils, hydraulic fluids,
vehicle, and
transmission oil, radiator
equipment
fluids, and chemical solvents
maintenance and
washing
Disposal of waste parts
Batteries, oil, fuel filters, oily
rags
Spent washwater
TSS, metals, fuel, hydraulic
fluid, oil, lavatory waste
Runway maintenance
Materials removed from runway surface
Tire rubber, oil and grease,
paint chips, jiet fuel
Chemicals used to clean the runway surface
Chemical solvents
d. Location of Discharges
Piedmont Triad International Airport
6415 Byran Blvd.
Greensboro, Guilford County, NC
e. Receiving Waters
Brush Creek, East Fork Deep River and Horsepen Creek and their tributaries in the Cape Fear River Basin.
DISCHARGE CONTROLS AND LIMITATIONS
The renewal permit incorporates benchmark concentrations to provide a tool with which to assess the
effectiveness of best management practices (BMPs). These benchmark concentrations are not effluent limits but
provide guidelines for the facility's Stormwater Pollution Prevention Plan. Exceedences of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or install
stormwater BMPs in a tiered program. This proposed requirement is a new addition to the pennit and is
consistent with other general and individual permits issued by the Division since 2007,
Stormwater must be controlled by the development and implementation of a Stormwater Pollution Prevention
Plan (SPPP or Plan). Plan requirements were updated in this renewal to include: (a) indication in the Site Plan of
whether receiving waters are impaired, and (b) a revised schedule for stormwater facility inspections during the
calendar year that mirror analytical monitoring requirements (when applicable). The following are specific
requirements of the Plan:
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 stormwater discharges. The site plan
shall contain the following:
(a) 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, the name
of the receiving water(s) to which the stormwater outfall(s) discharges, or 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. The general location
map (or alternatively the site map) shall identify whether each receiving water is impaired (on
the state's 303(d) list of impaired waters) or is located in a watershed for which a TM'DL has
been established, and what the parameter(s) of concern are.
(b) A narrative description of storage practices, loading and unloading activities, outdoor process
areas, dust or particulate generating or control processes, and waste disposal practices. A
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NCS000508 Fact Sheet —NC DENR DWQ February 12, 2010
narrative description of the potential pollutants which could be expected to be present in the
stormwater discharge from each outfall.
(c) A site map drawn to scale (including a distance legend) showing: the site property boundary, the
stormwater discharge outfalls, all on -site and adjacent surface waters and wetlands, industrial
activity areas (including storage of materials, disposal areas, process areas, loading and
unloading areas, and haul roads), site topography, all drainage features and structures, drainage
areas for each outfall, direction of flow in each drainage area, industrial activities occurring in
each drainage area, buildings, existing BMPs, and impervious surfaces. The site map must
indicate the percentage of each drainage area that is impervious. In addition, the following
industrial activity areas must also be identified on the site map: fueling, engine maintenance and
repair, vessel maintenance and repair, pressure washing, painting, sanding, blasting, welding, and
metal fabrication.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility during the three
(3) previous years and any corrective actions taken to mitigate spill impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of non-stommater
discharges. The certification statement will be signed in accordance with the requirements found
in Part 111, Standard Conditions, Section B, Paragraph 5. The permittee shall re -certify annually
that the stornwater outfalls have been evaluated for the presence of non-stormwater discharges.
Stonnwater Management Plan. The stormwater management plan shall contain a narrative description of
the materials management practices employed which control or minimize the exposure of significant
materials to stormwater, including structural and nonstructural measures. The stormwater management
plan, at a minimum, shall incorporate the following:
(a) Feasibility Study. A review of 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 practical, the permittee shall prevent exposure of all storage areas,
material handling operations, and manufacturing or fueling operations. In areas where
elimination of exposure is not practical, the stormwater management plan shall document the
feasibility of diverting stormwater runoff away from areas of potential contamination.
(b) Secondary Containment Requirements and Records. Secondary containment is required for:
bulk storage of liquid materials; storage in any amount of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority chemicals; and storage
in any amount of hazardous substances, in order to prevent leaks and spills from contaminating
stormwater runoff. A table or summary of all such tanks and stored materials and their
associated secondary containment areas shall be maintained. If the secondary containment
devices are connected to stormwater conveyance systems, the connection shall be controlled by
manually activated valves or other similar devices (which shall be secured closed with a locking
mechanism), and any stormwater that accumulates in the containment area shall be at a minimum
visually observed for color, foam, outfall staining, visible sheens and dry weather flow, prior to
release of the accumulated Stonnwater. Accumulated stormwater shall be released if found to be
uncontaminated by any material. 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.
(c) BMP Summary. A listing of site structural and non-structural Best Management Practices
(BMP) shall be provided. The installation and implementation of BMPs shall be based on the
assessment of the potential for sources to contribute significant quantities of pollutants to
stormwater discharges and data collected through monitoring of stormwater discharges. The
BMP Summary shall include a written record of the specific rationale for installation and
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NCS000508 Fact Sheet — NC DEN R D WQ February 12. 2010
implementation of the selected site BMPs. The BMP Summary sltall be reviewed and updated
annually.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP) shall incorporate
an assessment of potential pollutant sources based on a materials inventory of the facility. Facility
personnel (or the team) responsible for implementing the SPRP shall be identified in a written list
incorporated into the SPRP and signed and dated by each individual acknowledging their responsibilities
for the plan. A responsible person shall be on -site at all times during facility operations that have the
potential to contaminate storntwater runoff through spills or exposure of materials associated with the
facility operations. The SPRP must be site stormwater specific. Therefore, an oil Spill Prevention
Control and Countermeasure plan (SPCC) 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 SPCC with the
SPRP may be incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative maintenance and good
housekeeping program shall be developed. "file program shall list all storntwater control systems,
stormwater discharge outfalls, all on -site and adjacent surface waters and wetlands, industrial activity
areas (including material storage areas, material handling areas, disposal areas, process areas, loading
and unloading areas, and haul roads), all drainage features and structures, and existing structural BMPs.
The program shall establish schedules of inspections, maintenance, and housekeeping activities of
stormwater control systems, as well as facility equipment, facility areas, and facility systems that present
a potential for stormwater exposure or stormwater pollution. Inspection of material handling areas and
regular cleaning schedules of these areas shall be incorporated into the program. Timely compliance
with the established schedules for inspections, maintenance, and housekeeping shall be recorded in
writing and maintained in the SPIT.
Employee Training. "Graining programs shall be developed and training provided at a minimum on an
annual basis for facility personnel with responsibilities for: spill response and cleanup, preventative
maintenance activities, and for any of the facility's operations that have the potential to contaminate
storntwater runoff. Facility personnel (or team) responsible for implementing the training shall be
identified, and their annual training shall be documented by the signature of each employee trained.
Additional required training items include: used oil management, spent solvent management, disposal of
spent abrasives, disposal of vessel wastewaters, fueling procedures, sanding, painting and blasting
procedures, and used battery management.
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific position(s)
responsible for the overall coordination, development, implementation, and revision to the Plan.
Responsibilities for all components of the Plan shall be documented and position assignments provided.
Plan Amendment. 'File permittee shall amend the Plan whenever there is a change in design,
construction, operation, or maintenance which has a significant effect on the potential for the discharge
Of pollutants to surface waters. All aspects of the Stormwater Pollution Prevention Plan shall be
reviewed and updated on an annual basis. The annual update sltall include an updated list of significant
spills or leaks of pollutants for the previous three years, or the notation that no spills have occurred. The
annual update shall include re -certification that the stormwater outfalls have been evaluated for the
presence of non-stormwater discharges. Each annual update shall include a re-evaluation of the
effectiveness of the BMPs listed in the BMP Summary of the Stormwater Management Plan.
The Director may notify the permittee when the Plan does not meet one or more of the minimum
requirements of the permit. Within 30 days of such notice, the permittee shall submit a time schedule to
the Director for modifying the Plan to meet minimum requirements. The permittee shall provide
certification in writing (in accordance with Part III, Standard Conditions, Section B, Paragraph 5) to the
Director that the changes have been made.
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NCS000508 Fact Sheet — NC DENR DWQ February 12, 2010
Facility Inspections. Inspections of the facility and all stormwater systems shall occur as part of the
Preventative Maintenance and Good Housekeeping Program at a minimum on a semi-annual schedule,
once during the first half of the year (January to June), and once during the second half of the year (July
to December), with at least 60 days separating inspection dates (unless performed more frequently than
semi-annually). These facility inspections are different from, and in addition to, the stormwater
discharge characteristic monitoring required in Part II of this permit.
Implementation. The permittee shall implement the Plan. Implementation of the Plan shall include
documentation of all monitoring, measurements, inspections, maintenance activities, and training
provided to employees, including the log of the sampling data and of actions taken to implement BMPs
associated with the industrial activities, including vehicle maintenance activities. Such documentation
shall be kept on -site for a period of five years and made available to the Director or the Director's
authorized representative immediately upon request.
3. MONITORING AND REPORTING REQUIREMENTS
This renewal permit specifies monitoring and reporting requirements for both quantitative and qualitative
assessment of the stormwater discharge and operational inspections of the entire facility. Specific pollutant
parameters for which sampling nmst be performed and the frequency of the sampling are based upon the types of
materials used, onsite facility activities and the potential for contamination of stormwater runoff .
Total Flow and Event Duration parameters have been removed from this renewal permit. Instead, this permit
clarifies that the SPPP site map should include the percentage of each drainage area that is impervious, which
provides information necessary should flow ever need to be estimated. (This permit still requires total rainfall
amount be recorded). The rationale for removing Total Flow is that (1) flow does not demonstrate compliance
with any permit condition, (2) DWQ does not using the stormwater discharge flow monitoring data, (3) many
permittees were reporting erroneous values because of a lack of understanding about how to calculate stormwater
discharge flow, and (4) the permit still requires the pennittee to record all information necessary to estimate flow
for a given monitoring event.
The previous permit's analytical monitoring requirements included:
• quarterly monitoring at representative outfalls for TSS, BOD, and NH3-N;
• in -stream monitoring quarterly for DO, pH, turbidity, and conductivity;
• monitoring following every deicing event at representative outfalls for ethylene glycol, propylene
glycol, and acute toxicity;
• in -stream monitoring following every de-icing event for BOD and acute toxicity.
Analytical and qualitative data collected during the previous pennit term was carefully reviewed in order to
develop a useful monitoring program for the renewal permit. The renewal permit contains the following
analytical monitoring requirements:
• quarterly monitoring at representative outfalls for TSS, BOD, COD, pH, TPH, MBAS, NH3-N,
NO3+NO2-N, TP, and turbidity;
• monitoring following four (4) deicing events at representative outfalls for ethylene glycol, propylene
glycol, BOD, COD, pH, NH3-N, and acute toxicity;
• in -stream monitoring following four (4) de-icing events for DO, pH, turbidity and acute toxicity.
The rationale for retaining previous parameters in this renewal permit was based on their continued usefulness as
stormwater pollution indicators within the revised monitoring scheme and based on historical analytical and
qualitative monitoring results. New analytical monitoring parameters in this renewal permit were added either
based on (1) their inclusion in the 2008 EPA MSGP, (2) use at like -permitted industrial facilities within the
NPDES program, (3) receiving stream nutrient -sensitive water classification or TMDL, or (4) observed in -stream
water quality standard violations.
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NCS000508 Fact Sheet — NC DENR DWQ February 12. 2010
In addition to analytical monitoring, this renewal permit specifies quarterly qualitative (visual) monitoring of
each stormwater outfall for the purpose of evaluating the effectiveness of the Stormwater Pollution Prevention
Plan and assessing new sources of stormwater pollution. Qualitative monitoring parameters include color, odor,
clarity, floating and suspended solids, foam, oil sheen, and other obvious indicators of stormwater pollution. In
this proposed renewal permit, qualitative monitoring must now be performed during a representative storm event
and at the same time as the analytical monitoring. The permittee now must also use a standard form provided by
DWQ to record results. In addition, the permittee must now submit an annual summary report of analytical
monitoring results to the Regional Offices.
This renewal pennit has a revised "response action' commitment based on qualitative monitoring. If the
permittee identifies that BMPs are ineffective or there is evidence of stormwater contamination problems, the
permittee must document the potential causes and corrective actions, and include this information in the SM. If
the permittee repeatedly fails to respond to problems, or stormwater discharges cause or contribute to a water
quality standard violation, DWQ may require more frequent qualitative monitoring, increased stormwater
management actions, or application for coverage under an individual permit.
Additional monitoring and reporting requirements include:
a. "file Stormwater Pollution Prevention Plan shall be reviewed and updated on an annual basis.
Implementation of the plan shall include documentation of all sampling, measurements, Tier I and Tier 2
actions, inspections and maintenance activities and training provided to employees. Such documentation
shall be kept on -site for a period of five years and made available to DWQ immediately upon request. If
DWQ determines that a Plan does not meet requirements of the permit, the permittee must give DWQ a time
schedule for modifying the Plan and certify that the Plan has been so modified.
Self -inspections of the facility and all stormwater systems shall occur at a minimum on a semi-annual
schedule. The inspections and any subsequent maintenance activities performed shall be documented,
recording date and time of inspection, individual(s) making the inspection and a narrative description of the
facility's stormwater control system, plant equipment and systems. Records of these inspections shall be
incorporated into the Plan.
c. A log of the sampling results and activities taken to implement BMPs associated with the vehicle
maintenance activities shall be maintained and incorporated into the Plan.
Analytical monitoring is to be performed at specific outfalls that the permit identifies as Representative
Outfalls. Stormwater discharge outfalls to be analytically monitored are 004, 006, O16A, 024, 026, 027, 030,
and 032. Outfall 032 is a new representative outfall to be monitored in association with recent expansion at
the facility. Outfall 016A replaces previously monitored outfall 014 as a more representative discharge
outfall to Gast Fork Deep River. Qualitative Monitoring (Visual observations) shall be recorded for all outfall
locations.
c. For purposes of stormwater sampling, all samples shall be collected from a discharge resulting from a
representative stone event. Whether the stormwater runoff is from a typical discharge outlet (pipe/ditch), or
controlled by a detention pond, a grab sample of the discharge shall be collected within the first 30 minutes
of discharge. Previously, if the detention pond discharged only in response to a storm event exceeding a ten-
year design storm, no analytical monitoring was required; however, that provision has been removed from
this renewal permit. The removal was based on the fact that most permittecs misunderstood the provision,
and that semi-annual sampling was appropriate for the reasons previously noted.
f. The renewed permit outlines a tiered response to exceedences of benchmark values (where monitoring is
applicable). These tiers require increased monitoring, increased management actions, increased record
keeping, and/or installation of stormwater BMPs.
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NCS000508 Fact Sheet - NC DENR DWQ February 12, 2010
g. The renewed permit outlines a response commitment based on the permittec's determination that qualitative
monitoring results indicate ineffectiveness of BMPs or other stormwater contamination problems.
4. COMPLIANCE SCHEDULE
The permittee shall comply with the monitoring, controls, and limitations specified for stormwater discharges in
accordance with the following schedule:
Current Activities: The Stormwater Pollution Prevention Plan shall be updated and implemented within
12 months of the effective date of the renewal permit and updated thereafter on an annual basis.
Secondary containment, as specified in Part 11, Section A, Paragraph 2(b) of this permit, shall be
accomplished within 12 months of the effective date of the renewal permit issuance.
Future Expansion: A modified Stormwater Pollution Prevention Plan for expansion shall be developed
and implemented prior to the beginning of discharges from the operation of any additional industrial
activity and be updated thereafter on an annual basis. Secondary containment, as specified in Part 11,
Section A, Paragraph 2(b) of this permit shall be accomplished prior to the beginning of discharges from
the operation of the expanded industrial activity.
5. SPECIAL CONDITIONS WHICH WILL HAVE A SIGNIFICANT IMPACT ON THE
DISCHARGE
The permit contains requirements for the periodic sampling of representative stormwater outfalls and receiving
streams upstream and downstream of stormwater discharges for the parameter acute toxicity performed as a 24-
hour static test on test species Ceriodaphnia dubia. This parameter is retained in the renewal permit for its
continued usefulness as a tool to characterize and measure the toxicity of stormwater discharges related to
deicing activities and based on historical acute toxicity monitoring results. Ceriodnphnio dubin was chosen to
replace Fathead minnow as the test species to collect additional toxicity data on an organism not yet tested to
supplement data collected using Fathead minnows during the previous permit term.
6. BASIS FOR CONTROLS AND LIMITATIONS
The conditions of this renewal permit have been designed using best professional judgment to achieve water
quality protection through compliance with the technology -based standards of the Clean Water Act (Best
Available Technology [BAT] and Best Conventional Pollutant Control Technology [BCT]). Where the Director
determines that a water quality violation is occurring and water quality -based controls or effluent limitations are
required to protect the receiving waters, coverage under the permit shall be terminated and an individual pernnit
will be required. Based on a consideration of the appropriate factors for BAT and BCT requirements, and a
consideration of the factors discussed below in this fact sheet for controlling pollutants in stormwater discharges
associated with the activities as described in Item I (Types of Discharge Covered), this permit retains a set of
requirements for developing and implementing stormwater pollution prevention plans, and specific requirements
for monitoring and reporting on stormwater discharges.
The permit conditions reflect the Environmental Protection Agency's (EPA) and North Carolina's pollution
prevention approach to stormwater permitting. "file quality of the stormwater discharge associated with an
industrial activity will depend on the availability of pollutant sources. This renewal permit still reflect the
Division's position that implementation of Best Management Practices (BMPs) and traditional stormwater
management practices which control the source of pollutants meets the definition of BAT and BCT. The permit
conditions are not numeric effluent limitations, but rather are designed to be flexible requirements for developing
and implementing site specific plans to minimize and control pollutants in the stormwater discharges associated
with the industrial activity.
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NCS000508 Fact Sheet — NC DEN DWQ February 12.2010
Title 40 Code of Federal Regulations (CFR) Part 122.44(k) (2) authorizes the use of BMPs in lieu of numeric
effluent limitations in NPDES permits when the agency finds numeric effluent limitations to be infeasible. The
agency may also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the
Act under the authority of 40 CFR 122.44(k) (3). The conditions of the renewal permit are retained under the
authority of both of these regulatory provisions. The pollution prevention requirements (BMP requirements) in
this permit operate as limitations on effluent discharges that reflect the application of BAT/BCT. The basis is
that the BMPs identified require the use of source control technologies which, in the context of this permit, are
the best available of the technologies economically achievable (or the equivalent BCT finding).
The permittee must prepare, retain, implement, and (at a minimum of annually) update a stormwater pollution
prevention plan. The term "pollution prevention' distinguishes this source reduction approach from traditional
pollution control measures that typically rely on end -of -pipe treatment to remove pollutants in the discharges.
The plan requirements are based primarily on traditional stormwater management, pollution prevention and BMP
concepts, providing a flexible basis for developing site -specific measures to minimize and control the amounts of
pollutants that would otherwise contaminate the stormwater runoff.
The pollution prevention approach adopted in the stormwater pollution prevention plans in this renewal permit
Still focuses on two major objectives: 1) to identify sources of pollution potentially affecting the quality of
stormwater discharges associated with industrial activity from the facility; and 2) to describe and ensure that
practices are implemented to minimize and control pollutants in stormwater discharges associated with industrial
activity from the facility and to ensure compliance with the terms and conditions of the permit.
The Division believes that it is not appropriate, at this time, to require a single set of effluent limitations or a
single design or operational standard for all facilities which discharge stormwater associated with industrial
activity. This permit instead establishes a framework for the development and implementation of site -specific
stormwater pollution prevention plans. This framework provides the necessary flexibility to address the variable
risk for pollutants in stormwater discharges associated with the industrial activities that are addressed by this
permit, while ensuring procedures to prevent stormwater pollution at a given facility are appropriate given the
processes employed, engineering aspects, functions, costs of.controls, location, and age of facility (as discussed
in 40 CFR 125.3). This approach allows flexibility to establish controls which can appropriately address different
sources of pollutants at different facilities.
hi t979, EPA completed a technical survey of industry best management practices (BMPs) which was based on a
review of practices used by industry to control the non -routine discharge of pollutants from non -continuous
sources including runoff, drainage from raw material storage areas, spills, leaks, and sludge or waste disposal.
This review included analysis and assessment of published articles and reports, technical bulletins, and
discussions with industry representatives through telephone contacts, written questionnaires and site visits. The
technical survey identified two classes of pollution control measures.
The first class of controls are those management practices which are generally considered to be essential to the
development of an effective and efficient BMP program, low in cost, and applicable to broad categories of
industries and substances. These controls include the following: developing a Spill Control Committee and
implementing spill reporting, material inventorying and compatibility reviews, employee training, visual
inspections, preventative maintenance programs, good housekeeping, and addressing security issues. These
practices are broadly applicable to all industries and can be implemented by each facility independent of the
category of industry, ancillary sources, specific chemicals used at different sites, and/or plant site locations. The
survey concluded that these controls should be minimum requirements for any effective BMP program.
The second class of controls includes management practices which provide for a second line of defense against
the release of pollutants. These controls include prevention measures, containment measures, mitigation and
cleanup measures and treatment methods. The types of chemicals, industrial operations and various ancillary
sources specify the controls applicable to an individual facility.
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NCS000508 Fact Sheet — NC DENR DWQ February 12, 2010
The EPA and NPDES States have, on a case -by -case basis, imposed BMP requirements in NPDES permits. The
EPA has also continued to review and evaluate case studies involving the use of BMPs and the use of pollution
prevention measures associated with spill prevention and containment measures for oil. The development of the
NPDES permit application requirements for stormwater discharges associated with industrial activity resulted
from the evaluation and identification of the potential contaminants and the resultant water quality impacts of
stormwater discharges from industrial sites. Public comments received during the rule making provided
additional insight regarding stormwater risk assessment, as well as appropriate pollution prevention and control
measures and strategies. During that time EPA again reviewed stormwater control practices and measures.
These experiences have shown the Division that pollution prevention measures such as BMPs can be
appropriately used and that permits containing BMP requirements can effectively reduce pollutant discharges in a
cost-effective manner. BMP requirements are being appropriately imposed in permits in lieu of numeric effluent
limitations pursuant to 40 CFR 122.44(k)(2).
There has been no change to this rationale since the previous permit.
7. REQUESTED VARIANCES OR ALTERNATIVES TO REQUIRED STANDARDS
There are no requested variances or alternatives to required standards.
8. THE ADMINISTRATIVE RECORD
The administrative record, including application, draft permit, fact sheet, public notice, comments received, and
additional information is available by writing to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Centel -
Raleigh, North Carolina 27699-1617
The above documents are available for review and copying at:
Archdale Building
9th Floor
Surface Water Protection Section
Stormwater Permitting Unit
512 N. Salisbury Street
Raleigh, North Carolina
between the hours of 8:00 AM and 5:00 PM Monday through Friday. Copies will be provided at a charge of five
cents per page.
9. STATE CONTACT
Additional information about the draft and final permit may be obtained at the above address between the hours
of 8:00 AM and 5:00 PM Monday through Friday by contacting: Cory Larsen at [phone].
10. SCHEDULE OF PERMIT ISSUANCE
Draft Permit to Public Notice — Notice published January '19, 2010;
Draft available on-line January 19, 2010
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NCS000508 Fact Sheet -NC DENR DWQ February 12, 2010
Anticipated Permit Issue Date —Signed March 5, 2010;.
Effective April 1, 2010
11. PROCEDURE FOR THE FORMULATION OF FINAL DETERMINATIONS
a. Comment Period
The Division of Water Quality proposes to issue the renewal permit for the above described storntwater
discharges subject to the outlined effluent limitations, management practices, and special conditions. These
determinations are open to comment from the public.
Interested persons are invited to submit written comments on the permit application or on the Division of
Water Quality's proposed determinations to the following address:
Storntwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attn: Cory Larsen
All comments received within 30 days following the date of public notice will be considered in the
formulation of final determinations. All such comments and requests regarding this matter should make
reference to draft permit number NCS000508.
b. Public Meeting
The Director of the Division of Water Quality may hold a public meeting if there is a significant degree of
public interest in a proposed permit or group of permits. Public notice of such a meeting would be circulated
in newspapers in the geographical area of the discharge and to those on the Division of Water Quality
mailing list at least 30 days prior to the meeting.
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BROOKS, Pm, RcE, MCLENDON, HIIMPHAEY & LEONAPD, L-L.P.
L.P. MCLENDON, JR,
BRIAN J. MCMILLAN
ATTORNEYS ANll OORNSF.IS.OHS AT LAW
EDGARB. FISHER, JR,
DAVID KUSHNER
F'OITNIJED 1897
W. ERWIN FULLER, JR,
CLINTON R. PINYAN
JAMES T. WILLIAMS, JR.
COE W. RAMSEY
POST OFFICE BOX 26000
WADE H. HARGROVE
ROSERT W. SAUNDERS
M. DANIEL McGINN
MICHAEL D. MEEKER
ELIZABETH V. LAFOLLETTE
GINGER S. SHIELDS
GREENSBORO, NORTH GAROIINA27420
WILLIAM G. MCNAIRY
JENNIFER T. HARROD
TF.L£PRONEI (3:36) 073-8650
EDWARD C. WINSLOW III
CHARLES E. COBLE
HOWARD L. WILLIAMS
CHARLES F. MARSHALL III
t'ACSR, LE: (3:36) 378-1001
GEORGE W. HOUSE
PATRICK J. JOHNSON
WILLIAM P.H. CARY
STEPHEN G. HARTZELL
REID L. PHILLIPS
J. BENJAMIN DAVIS
WWW.BROOILSPH:RUH000M
ROBERT A. SINGER
JULIA C. AMBROSE
JOHN H. SMALL
DARRELL A. FRUTH
RANDALLA. UNDERWOOD
IAIN MACSWEEN
S. LEIGH RODENBOUGH IV
NICOLE A. CRAWFORD
MARKJ.PRAK
ALEXANDER ELKAN
/�
March 2, 2010
JILL R. WILSON
PATRICIAW. GOODSON
MARC D. BISHOP
JESSICA M. MARLIES
JIM W. PHILLIPS. JR.
SARA R, VIZITHUM
MACK SPERLING
JOHN S. BUFORD
JEFFREY E. OLEYNIK
KATHERINE J. CLAYTON
MARK DAVIDSON
KATHLEEN A. GLEASON
JOHN W. ORMAND III
SUSAN M. YOUNG
ROBERT J. KING IN
BENJAMIN R. NORMAN
V. RANDALL TINSLEY
ELIZABETH E. SPAINHOUR
S. KYLE WOOSLEY
PHILLIP J. LONG
FORREST W. CAMPBELL. JR.
ANDREW T. TRIPP
MARCUS W. TRATHEN
JOSEPH A, PONZI
JEAN C, BROOKS
ADAM P.M. TARLETON
JAMES C. ADAMS II
D,J. 0 BRIEN, III
ALLISON M. GRIMM
ERIC M. DAVID
ELIZABETH S. BREWINGTON
CLINT S. NORSE
H. ARTHUR BOLICK II
CHARNANDA T. REID
J. EDWIN TURLINGTON
ELIZABETH S. OSTENDORF
JOHN M. CROSS, JR.
ERIC 0. JOHNSON
JENNIFER K. VAN ZANT
JUSTINE 0 CONNOR PETTS
KEARNS DAVIS
MARY F. PERA
DAVID W. BAR
WESJ. CAMDEN
Via hand delivery and certified mail, return receipt requested
Mr. Cory Larsen
Environmental Engineer, Stormwater Permitting Unit
Division of Water Quality
North Carolina Department Environment and Natural
1617 Mail Service Center
Raleigh, NC 27699-1617
Hand delivery to.
512 North Salisbury Street
Raleigh, NC 27604
Re: Piedmont Triad Airport Authority
Commenis on Draft NPDF_S Storm ,aier Permit, NCS000508
Dear Mr. Larsen:
HENRY E. FRYE
OF COUNSEL
J, LEE LLOYD
PARTNER AND SPECIAL COUNSEL
AUBREY L. BROOKS U872.19881
W.H. HOLDERNESS H904-19661
L.P. MCLENDON (1890-1968)
KENNETH M. BRIM 11898-19791
C.T. LEONARD, JR. 1929-1993I
CLAUDE C, PIERCE n913.19881
THORNTON WEIROOKS11912-19881
G. NEIL DANIELS 11911 -1997)
HUBERTHUMPHREY 1192820031
OFFICE ADDRESS.
20N RENAISSANCE PIAZA
230 NORTH ELM STREET
GREENSBORO, NC, 27401
OFFICE ALSO IN
RALEIGH, NORTH CAROLINA
WRITER S DIRECT DIAL
336-271-3114
ghousdiDi bawksjwrce com
Bill Cooke represents the Piedmont "Triad Airport Authority as general counsel and our
firm represents the Authority as environmental counsel in connection with the renewal of the
Authority's NPDES stormwater permit, NCS000508. This letter provides the Authority's
comments on, and suggested changes to, the draft permit issued by your off ice on January 13).
We appreciate your cooperation in extending the time for our comments and in making your files
available to us.
. Our comments and suggested changes are provided in the table enclosed with this letter.
We appreciate your review and consideration of these comments and suggestions.

Mr. Cory Larsen
Environmental Engineer, Stormwater Permitting Unit
March 2, 2010
Page 2
As you will see, we have a basic legal/technical question about the approach of this
permit with respect to airport operations. Specifically, the tiered response regime has not been
applied in the general permit for air transportation facilities (NCG150000). As far as we are
aware, the regime (at least as currently designed in the draft permit for the Piedmont Triad
Airport Authority) also has not been applied to any other similar (or larger) airport in the state,
including Raleigh -Durham, Charlotte -Douglas, Asheville, or the Global Transpark. Nor is such a
regime required by EPA's MSGP or the proposed effluent guidelines and new source
performance standards for the airport de-icing category (74 FED. REG. 44675, August 29, 2009).
We see no rationale for singling out the Piedmont Triad Airport Authority for different
treatment.
Furthermore, the regime as designed in the draft permit is flawed in our view. It
potentially requires the Authority to make facility changes to qualify for the No -Exposure
Exclusion, even though it would not be physically or financially possible for an airport to meet
the conditions of that exclusion. More basically, the tiered response regime appears to tie
required responses to benchmark exceedences (which, in effect, appear to be equivalent to daily
maximums), whether or not those exceedences result in any violation of' state water quality
standards.
Before the permit is issued in final form, we request a meeting with you to discuss these
issues and any other comments or suggestions in the attached table that are a concern to you.
Once you have had a chance to review this letter and the attached comments/suggestions, we
request that you please call or email any of us to arrange a meeting:
Bill Cooke 336-272-4514
George I -louse 336-271-3114
Kyle Woosley 336-371-3128
wocir a,bcllsouth.net
?hf OLlse a brookspicrce.com
kwoosley n,brookspierce.com
We look forward to meeting and working with you on this permit. Thank you for your
time and your consideration of these comments.
Sincerely,
George W. House
Enclosure: table of comments on draft stormwater permit NCS000508
cc: Kevin Baker, Assistant Director, Piedmont Triad Airport Authority (w/ encl)
Chris Arrington, Michael Baker Engineering, Inc. (w/ encl)

COMMENTS OF PIEDMONT TRIAD AIRPORT AUTHORITY
on draft NPDES stormwater permit, NCS000508
March 2, 2010
Page
Paragraph
Current language
Comment
Proposed change
A
cover
"Hors en Creek'
misspelling
Horsepen Creek p�
B
i
title of Part
"Analytical Monitoring Requirements"
incorrect title in table of
Routine Analytical Monitoring p�
11, Section B
contents
Requirements
C
i
title of Part
"On Site Vehicle Maintenance
incorrect title in table of
De -Icing Event Analytical Monitoring
11, Section D
Monitoring Requirements"
contents
Requirements O Ie
D
Part II,
"Page of 10"
incorrect total number of pages
Page of 13
all page
o!c
nos.
E
Part II,
Section B,
"032" listed as a representative SDO
wrong outfall number listed —
033 is representative outfall, delete 032
p. 5
Table 1
SDO for FedEx pond 42 is 33,
as representative o j
not 32
A(so (!aa-
F
Part II,
Section B,
units for turbidity listed as "ine/L"
incorrect measuring unit listed
insert NTU as units for turbidity, delete 01
p. 6
Table 2
in table
mg/L
G
Part 11,
Section B,
"Grab samples shall be collected within
because of the size of the
Grab sample collection shall begin �
p. 6
Table 2,
the first 30 minutes of discharge."
facility and number of outfalls,
within the first 30 minutes of discharge
footnote 2
it will be impossible to collect
or as soon thereafter as reasonably
possible and shall be completed as
all grab samples within this
expeditiously as practicable:...
short timeframe
H
Part II,
last para.
"... in accordance with the schedule
reference to incorrect table
... in accordance with the schedule
p. 6
under Table
specified below in Table 2."
number
specified below in Table 3. �k
2
PIEDA40A'7, TRIAD A IRPOR7'A UTHORITY COALVENTS ON DRAFT STORAIWA TER PERMIT PERMIT NCS000508 (312110) PAGE I
IM
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I

Page
Paragraph
Current language
Comment
Proposed change
I
Part 11,
first para.,
"... compare monitoring results to the
reference to incorrect table
... compare monitoring results to the 01
P. 8
2d & 3d
benchmark values in Table I The
number
benchmark values in Table 4. The
sentences
benchmark values in Table 3 are not
benchmark values in Table 4 are not
permit limits ..."
permit limits ...
J
Part 11,
first para.,
"Exceedences of benchmark values
(a) sentence is ambiguous, and
Exceedences of benchmark values must
p. 8
4th sentence
require the permittee to increase
(b) does not leave room for
be addressed as provided in and in
accordance with the tiered response
monitoring, increase management__
possibility that inspection and
chart on pate 9 of Part IL ok
actions, increase record keeping, and/or
evaluation reveals no response
install stormwater Best Management
action necessary (see Comment
Practices (BMPs) in a tiered program."
L below)
K
Part 11,
Table 4
routine analytical benchmark values:
no objection to BOD/COD
DELETE BENCHMARKS FOR BOD
P. 8
analytical requirements, but
and COD
BOD benchmark — 30^ L
object to benchmarks for BOD
COD benchmark —;120 mid
and COD because (a) based on
usage volumes at the airport,
MSGP would not impose
analytical requirements or
benchmarks, and (b) past
sampling indicates no
significant correlation between
discharges at the airport and DO
concentrations in receiving
streams
PIEDSIOA'T TRIAD AIRPORT AUTHORIT P COM,HE,\ TS ON DRAFT STOR tll i'ATER PERMIT, PERSIIT NCS000J 08 (312110) PAGE 2

Page
Paragraph
Current language
Comment
Proposed change
L
Part II,
Tier One
"3. Identify potential 'and select the
does not leave room for the
3. Identifv potential source controls,
P. 9
sue`- eCl1lC: source controls, operational
possibility that inspection and
operational controls, or physical
controls, or physical improvements to
evaluation reveals there is no
improvements to reduce concentrations
reduce concentrations of the parameters
response action necessary with
of the parameters of concern, or to bring
of concern, or to bring concentrations
respect to a particular
concentrations within the benchmark
within the benchmark range.
exceedence, perhaps because it
range, and select the specific source
4. Implement the selected actions
was a unique event, or the
controls, operational controls, or
physical improvements, if any, that
within two months of the inspection.
source was offsite, etc.; and
may be necessary -for Dermittee's
5. Record each instance of a Tier One
Tier One (as drafted) could
discharge to compl ith applicable
response in the Stormwater Pollution
require response action
dardsr
Prevention Plan. Include ... the selected
irrespective of whether such
actions, and the date the selected
action is necessary for
4. Implement the selected actions, if anv,
actions were implemented."
permittee's discharge to comply
within two months of the inspection.
with applicable surface water
5. Record each instance of a Tier One
quality standards
uS
response in the Stormwater Pollution
Prevention Plan. Include ... the selected
ctions, if any, and the date the selected
actions were implemented, or, if no
action was implemented, the basis for
that decision.
M
Part II,
last para.
"... if the valid sampling results ...
four consecutive exceedences
if the valid sampling results ... exceed
P. 9
exceed the benchmark value ... on f uo r
should be required, otherwise
the benchmark value ... on four
occasions, ions, the permittee shall ..."
this paragraph can be triggered
consecutive occasions, the permittee
even though Tier Two never
shall ...
becomes applicable
N
Part II,
last para.
"DWQ may but is not limited to:
permit should not require
DWQ may then impose such
P. 9
control measures unless
requirements, if anv, as may beta
necessary for permittee's
necessary for permittee's discharge to
comply with applicable surface water
discharge to comply with
quality standards, including but not
standards- �r...� ...,�
limited to:...
PIEDMONT TRIAD AIRPORT A UTIIORIT➢ COAfME,1'TS ON DRAFT STOR,tfN'ATFR PERMIT, PERM17' NC'S000508 (312110) PAGE 3

� .. 1 f
. if �..
r
,y, �
.0 3' ... `

Page
Paragraph
Current language
Comment
Proposed change
O
Part 11,
P. 9
very last
bullet point
`'require that the permittee implement
site modifications to qualify for the No
Exposure Exclusion."
not possible for an airport to
qualify for this exclusion —
planes and runways cannot be
delete last bullet point entirely and
delete the word "or" in the preceding
bullet point
shielded entirely
P
Part 11.
last box
describes actions DWQ may require if
does not take into account that
ADD SENTENCE AT END OF LAST 6
P. 9
there are four exceedences of a
benchmark value for a specific
an "exceedence" may be false,
may not result from airport
BOX:
parameter at a specific location
discharge, etc.
If the inspection and evaluation of a
particular sampling result under Tier
One or Tier Tworst off the result is not
caused by the permittee's operations
and facilities, it will not be treated as a
benchmark "exceedence" for purposes
of determining whether four
consecutive exceedences have
occurred.
Q
Part 11,
2d para.
"If additional BMPs are needed to
"required level of control' is -
If additional BMPs are needed to achieve
p. 10
achieve the required level of control,
the permittee will ..."
undefined and unclear
D
ap ace wa er qua ifv
standards, the permittee will ...
R
Part 11,
P. 10
Sec. C, 1 st
para.
shall be performed as specified in
Table 4, ..."
reference to incorrect table
number
... s Il be performed as specified in
Table 5.... oil
PIEDMONT TRIAD AIRPORT A U'PH0R7')' COA1,IfE,VTS ON DRAFT STORADVATER PERWIT, PERMIT NCS000508 (312110) PAGP_ 4
I<I
U45* '

Page
Paragraph
Current language
Comment
Proposed change
S
Part 11,
P. 11
Sec. D. last
sentence on
page
"Exceedences of benchmark values
require the permittee to increase
monitoring, increase management
actions, increase record keeping, and ro/
install stormwater Best Management
Practices (BMPs), as provided in Part 11
Section B."
see Comments J and L above;
also, Tier Two (Pt. I[, p. 9)
requires monthly monitoring if
there are two consecutive
benchmark exceedences for the
same parameter at same
location — but monthly
monitoring is not appropriate or
helpful for de-icing activities,
which are irregular and episodic
and do not occur every month
Exceedences of benchmark values must
be addressed as provided in and in
accordance with the tiered response
chart on page 9 of Part 11, except that
paragraph 2 of Tier Two is deleted and
replaced with the following
requirement: Immediately institute
monitoring during one qualifving de -
icing event per month for each
parameter at each outfall where a
sampling result exceeded the
benchmark value for two consecutive
samples. Such monitoring (one per
month) shall continue for each
subsequent month during which a
Qualifying de-icing event occurs for the
remainder of that de-icing season.
T
Part 11,
P. 11
Section D,
Table 6,
footnote 2
"If the stormwater runoff is controlled
by a stormwater detention pond a grab
sample of the discharge from the pond
shall be collected within the first 30
minutes of discharg from the pond."
not possible always to know or
predict when pond discharge
will begin (pond is often dry),
so it is not always possible to
have consultant/ technician at
discharge location in such a
short timeframe
If the stormwater runoff is controlled by
a stormwater detention pond a grab
sample of the discharge from the pond O
shall be collected within the first 30
minutes of discharge from the pond or as
soon thereafter as reasonablv possible.
PIEDMONT TRIAD AIRPORT AUTHORITY C0,11VENTS ON' DRAFT STORAM"ATER PERART, PER,11IT NCS000508 (3/2/10) PAGE 5
ng

Page
Paragraph
Current language
Comment
Proposed change
U
Part I1,
Sec. D, last
"Exceedences of benchmark values
see Comments J and L above;
Exceedences of benchmark values must
p. 12
sentence on
require the permittee to increase
also, Tier Two (Pt. ll, p. 9)
be addressed as provided in and in
accordance with the tiered response
page
monitoring, increase management
requires monthly monitoring if
chart on page 9 of Part 11, except that
actions, increase record keeping, and ro/
there are two consecutive
paragraph 2 of Tier Two is deleted and
install stormwater Best Management
benchmark exceedences for the
replaced with the following
Practices (BMPs), as provided in Part 1I
same parameter at same
Section B."
location — but monthly
requirement: Immediately institute
monitoring during one qualifying deCA
-
monitoring is not appropriate or
icing event per month for each
helpful for de-icing activities,
which are irregular and episodic
parameter at each in -stream sampling
location where a sampling result
and do not occur every month
exceeded the benchmark value for two
consecutive samples. Such monitoring
(one per month) shall continue for
each subsequent month during which a
qualifying de-icing event occurs for the
remainder of that de-icing season.
V
Part I1,
Table 8
anti -icing benchmark values:
see Comment K — no objection
DELETE BENCHMARKS FOR BOD
P. 13
to BOD/COD analytical
and COD
BOD benchmark— 30 mg/1
requirements, but object to
COD benchmark — il20 m L'
benchmarks for BOD and COD
because (a) based on usage
volumes at the airport, MSGP
would not impose analytical
requirements or benchmarks.
and (b) past sampling indicates
no significant correlation
between airport discharges and
DO concentrations in receiving
streams
PIEDMONT TRIAD AIRPORT A UTHORITY CO t f tfEA'TS ON DR.I FT STORMIf'ATER PERMIT, PERMIT NCS000J 08 (312110) PAGE 6

Page
Paragraph
Current language
Comment
Proposed change
W
Part III,
Sec. B,
reference to il43-2153.6
reference is incorrect
correct the reference
p. 3
condition 1
X
Part Ill.
Sec. D,
"All samples shall be taken before the
some samples must be taken in
All outfall samples shall be taken before
p. 5
condition 1
discharge joins or is diluted by any
streams
the discharge joins or is diluted by any
other stream, body of water, or
other stream. body of water, or substance
substance."
Y
Part 111,
Sec. E,
"When no discharge has occurred
(a) "report period" and
revise to clarify
p. 7
condition 1
during the report period. the permittee
"sampling period" ambiguous,
is required to submit a discharge
and (b) "six-month sampling
O%
monitoring report. within 30 days of
period" appears incorrect
the end of the six-month sampling
ep d ...>'
Z
Part IV,
Limitations Reopener
references to some sections of
correct CWA references
P. 1
the CWA seem incorrect
AA
Part VI,
Special
"The parameter code for this test is
incorrect parameter code for
The parameter code for this test is
p. 5
Condition,
TAE6C."
new test organism
TAA313. _ 'tir x-ti �
2d para.
_J_OtE- 39 > Z-Y fFL S74f7 .c 4<-�
BB
Part VI,
Special
"Failure to achieve test conditions ...
immediate retesting not possible
Failure to achieve test conditions ... will
p. 5
Condition,
will require immediate follow-up
if no subsequent deicing event
require immediate follow-up testing to be
testing to be completed no later than 30
end of page
occurs within 30 days
completed no later than 5 "aysiUthe-re_
days."
is_a-qualifyine-dc4cing ev�thh"he
next_3Qdaxs-_ d
PIEDMONT TRIADA/RPORTAUT//ORIT3'Co,tftlr,vrs ON DRA TSTORAIva Tra PF.R,111T, PER ITNCS000508(312110) Pace?

NCDENR
North Carolina Department of Environment and
Division of Water 4uality,,
Beverly �avP,s Perdue Coleen H. Si
Governor- Director
March 15, 2010
Mr. George W. House
Brooks, Pierce, McLendon, Humphrey & Leonard, LLP
PO Box 26000
Greensboro, North Carolina 27420
Dear Mr. House:
Natural Resources
Dee Freeman
Secretary
Subject: Response to Comments on Draft NPDES
Stormwater Permit
Permit No. NCS000508
Piedmont Triad International Airport
Guilford County
DWQ received written comments from your firm, on behalf of PTAA, on draft NPDES Permit
NCS000508 for the subject facility on March 2, 2010 during the extended public comment period.
We appreciate the time and effort reflected in the comments and suggested changes.
The comments have been summarized and classified below as those either: (1) accepted and to be
incorporated into the final permit or (2) fully or partially rejected along with the rationale/basis for
doing so and those requiring further discussion.
Accepted Comments
Comments A-J, O, R, T, and W-BB are accepted and will be incorporated in to the filial permit as is
or with slight wording variances in accordance with our understanding of your intent.
Other Comments
1. t:ornment K: Analytical monitoring parameters for BOD and COD are two of our most common
stormwater pollution indicators, and historical BOD results from the facility have shown levels
of concern both at outfall and in -stream locations. Furthermore, airport deicing compounds are
well known for their ability to exert significant oxygen demand on receiving waters and
negatively impact stream biota. Benchmark concentrations have been incorporated into our
stormwater program consistently since 2007 in most of our general and individual NPDES
permits requiring analytical monitoring. Benchmark concentrations are utilized as triggers to
Wetlands and Stormwater Branch �I1C t
16171dail Service Center, Raleigh, North Carolina 27699-1617 NOCCt1Cal"Otllla
Location:5.8 N. Salisbury St. Rale19-807, North Carolina 27604 �llfll!'ll��lf
Phone: 919$07-63001 FAX: 919$07$4941 Customer Service: 1-877-623-6748 LL 0 `!
Internet: wm.ncwatent uplily. org
An Equal Opportunity\Aftrmapi a Action Employer

f�.
Mr. George W. House
Brooks, Pierce, McLendon, Humphrey & Leonard, LLP
Permit No. NCS000508
alert the permittee to potential problems and to help facilitate prevention of water quality
standard violations. BOD and COD benchmarks will remain in the final permit.
2. Comment L: The proposed change will be incorporated into the final permit with the exception
that your proposed revision of, "surface water quality standards' will be replaced with
"benchmark concentrations".
3. Comment M: The intent of this portion of the permit is to solicit the permittee to address.
multiple benchmark exceedances whether they occur four times in a row or intermittently over
the duration of the permit. In either case, efforts on part of the permitee must be made to
identify and correct the cause and if not resolved, notify the DWQ Regional Office. This
requirement is consistent with other permits issued since 2007 within our program and will
remain in the final permit. Please note that DWQ always has the option when presented with
compelling circumstances or data to reduce, modify or eliminate monitoring for any parameter
when compliance with benchmark concentrations is not feasible or difficult due to offsite,.
sources, unique events, or other significant factors.
4. Comment N: The permittee's discharge must not violatesurface water quality standards
regardless of permit conditions. Benchmark concentrations are used in our stormwater
program as a tool to prevent water quality standard violations. Stormwater control measures
such as structural stormwater controls are one option, among others, available to DWQ after
four benchmark exceedances. Since the adoption of the tiered response system in 2007, DWQ
has rarely required structural stormwater controls as a result of benchmark violations, and it is
our experience that other less -costly options are normally explored prior to installation of
structural control measures. The final permit language will remain unchanged.
5. Comment P: The proposed change or similar language will be incorporated into the final
permit. The permittee is not responsible for benchmark exceedances that occur as a result of
other facilities' operations or discharge. In this type of circumstance, DWQ will engage with the
permittee to relieve them of additional monitoring associated with events beyond their control.
It is anticipated that this type of exceedance would be a rare probability at the subject facility.
6. Comment Q: This sentence will be revised in the final permit to read, "If additional BMPs are
needed to achieve the required level of control as mandated by a TMDL, if any, the permittee
will be required to...". Note that this facility is not named in the TMDL for East Fork Deep
River as a point source, and it is not expected that additional BMPs will be required as a result.
7. Comment S: The proposed change or similar language will be incorporated in the final permit.
Two consecutive benchmark exceedances at outfall locations during deicing event monitoring
will require the permittee to increase monitoring frequency to once per month for the remainder
of the deicing season so long as a qualified deicing event occurs during each month.
8. Comment U: The proposed change or similar language will be incorporated in the final permit.
Two consecutive benchmark exceedances at in -stream locations during deicing event
monitoring will require the permittee to increase monitoring frequency to once per month for
2
i

i George W. I -louse
Brooks, Pierce, McLendon, Humphrey & Leonard, LLP
Permit No. NCS000508
the remainder of the deicing season so long as a qualified deicing event occurs during each
month.
Comment V: See Comment K response. BOD and COD benchmarks will remain in the final
perm t.
10. General Comment (Cover Letter Pg. 2): Your continent on the lack of a tiered response regime in
the General Permit for airport operations, NCG150000; or other individual permits for similar or
':`argei airportsincluding RDU and CLT is noted and understood. Please be aware that
NCG150000 was written primarily to cover small commercial or general aviation airports that
do not conduct routine deicing activities and does not require analytical monitoring; thus a
tiered response approach is not applicable to NCG150000. With regard to the individual
permits for large airport operations, analytical monitoring with benchmark concentrations and
tiers will be put in place if not already when that particular facility's permit comes up for
renewal. Please note that Global Transpark does not currently have permit coverage but it is
anticipated that a more broad -based MS§ permit containing not only industrial requirements
but also additional Phase II requirements will be issued to this facility in time.
Your comments requested a meeting before issuance of the final permit. We would be happy to
discuss your comments and our responses in the near future. Please contact myself [(919)-807-6365
or [e-mail]] or Ken Pickle [(919)-807-6365 or ken.pickle@ncdenr�;ov] once you have
received this response to schedule a meeting if so desired.
Again, we appreciate your input on this draft permit.
Sincerely,
conorsen
Environmental Engineer
Stormwater Permitting Unit
cc: Winston-Salem Regional Office, Corey Basinger
Central Files
Stormwater Permitting Unit

BR00%B, PIERCE, McLENDON, HUMPiTREY Bc LEONA-RD, L-L-P.
L.P. MCLENDON, JR.
EDGAR B. FISHER, JR.
W. ERWIN FULLER, JR.
JAMES T. WILLIAMS. JR.
WADE H. HARGROVE
M. DANIEL McGINN
MICHAEL D. MEEKER
WILLIAM 0 MCNAIRY
EDWARD C. WINSLOW III
HOWARD L. WILLIAMS
GEORGE W. HOUSE
WILLIAM P.H. CARY
REID L. PHILLIPS
ROBERT A. SINGER
JOHN IT SMALL
RANDALL A. UNDERWOOD
S, LEIGH RODENBOUGH IV
MARK J. FRAN
JILL R. WILSON
.ARC D. BISHOP
JIM W. PHILLIPS. JR.
MACK SPERLING
JEFFREY E. OLEYNIK
MARK DAVIDSON
JOHN W. ORMAND III
ROBERT J. KING III
V.RANDALLTINSLEY
S. KYLE WOOSLEY
FORREST W. CAMPBELL, JR.
MARCUS W. TRATHEN
JEAN C. BROOKS
JAMES C. ADAM511
ALLISON M. GRIMM
ELIZABETH 5. BREWINGTON
H. ARTHUR BOLICK 11
J. EDWIN TURLINGTON
JOHN M. CROSS, JR.
JENNIFER K. VAN ZANT
KEARNS DAVIS
DAVID W. BAR
BRIAN J. MCMILUN
DAVID KUSHNER
CLINTON R. PINYAN
COE W. RAMSEY
ROBERT W. SAUNDERS
ELIZABETH V. LAFOLLETTE
GINGER S. SHIELDS
JENNIFER T. HARROD
CHARLES E. COBLE
CHARLES F. MARSHALL III
PATRICK J. JOHN50N
STEPHEN G. HARTZELL
J. BENJAMIN DAVIS
JULIA C. AMBROSE
DARRELL A. FROTH
IAIN MACSWEEN
NICOLE A. CRAWFORD
ALEXANDER ELKAN
PATRICIA W. GOODSON
JESSICA M. MARLIES
SARA R. VIZITHUM
JOHNS. BUFORD
KATHERINE J. CLAYTON
KATHLEEN A. GLEASON
SUSAN .. YOUNG
BENJAMIN R. NORMAN
ELIZABETH E. SPAINHOUR
PHILLIP J. LONG
ANDREW T. TRIPP
JOSEPH A. PONZI
ADAM P.M. TARLETON
D.J.0 BRIEN. III
ERIC M. DAVID
CLINT S. MORSE
CHARNANDA T. REID
ELIZABETH 5. OSTENDORF
ERIC D. JOHNSON
JUSTINE 0 CONNOR-PETTS
MART F. PENA
WESJ.CA.DEN
ATTOItXFYS ATE COUNSELLORS AT LAW
FoiINDEF, 1807
POST OFFICE BOX 26000
GRFENSHORO, NORTH CAROLINA 27420
TELEPHONv_' [phone]
FACS=AC [phone]
w ww.RROOFS'PIERGE.GOH
March 24, 2010
Via e-mail (cory.larsen a nedenr.eov
and ken.niekle(a)ncdenr.aov) and U.S. mail
Mr. Cory Larsen
Environmental Engineer, Stormwater Permitting Unit
Division of Water Quality
North Carolina Department Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Piedmont Triad Airport Authority
Draft NPDES Stormwater Permit, NCS000508
Dear Mr. Larsen:
HENRY E. FRYE
OFCOUNSEL
J. LEE LLOYD
PARTNER AND SPECIAL COUNSEL
AUBREY L BROOKS 11878-1958)
W.H. HOLDERNE55 (1904-1965)
L.P. MCLENDON 11890-1... I
KENNETH M. BRIM U698-197 41
C.T. LEONARD. JR. 11929-19831
CLAUDE G PIERCE 11913-199BI
THORNTON H. BROOKS (1912 .1966)
G. NEIL DANIEIS 11.11.19971
HUSERTHUMPHREY 1192E-2W31
OFFICE ADDRESS:
20Y0 RENAISSANCE PLAZA
"0 NORTH ELM STREET
GREENSBORO. NC. 27401
OFFICE ALSO IN
RALEIGH, NORTH CAROLINA
WRITER'S DIRECT DIAL
336-271-3114
ghouse a brookspierce.com
I V
MAR 267.010 7
We have reviewed your office's responses (dated March 15, 2010) to the comments of
the Piedmont Triad Airport Authority with respect to the referenced draft permit. We appreciate
DWQ's careful review of the Authority's comments.
We believe it would be helpful to meet and discuss the comments and responses,
particularly concerning the issue of the BOD and COD benchmarks. At a minimum, the
following persons will attend the meeting on behalf of the Piedmont Triad Airport Authority: an
official of the Authority (likely Kevin Baker, Assistant Director), Bill Cooke (the Authority's
general counsel), and myself. Kyle Woosley and another Authority official also may attend.

Mr. Cory Larsen
Environmental Engineer, Stormwater Permitting Unit
March 24, 2010
Page 2
We propose to meet next week. We prefer Monday, Tuesday, or Wednesday, but
Thursday is also a possibility if Monday through Wednesday does not work. The meeting
probably should be scheduled for 10:30 a.m. or after to allow for the drive from Greensboro to
Raleigh.
If any of these dates suits you and your staff, would you please schedule the meeting and
let us know the date you have chosen? Or, if other dates are better for you, please tell us. You
can contact me (336-271-3114 or ghouse a brookspierce.com) or Bill Cooke (336-272-4514 or
wocjrQbel!south. net).
Thank you for your time. We look forward to meeting with you.
Sincerely,
eorge W ouse
cc: Kevin Baker, Assistant Director, Piedmont Triad Airport Authority
Chris Arrington, Michael Baker Engineering, Inc.

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COOKE_ & COOKE, L.L.P.
ATTORNEYS AT LAW
FIRST OITTL.IENS DANK BUILDING
100 SOUTH ELM STRIEET
GREENS1n OEO, N.C. 2740]
MAILING ADIlIt155:
ARTIIDR 0. COOKE (1910-1960) P.O. HON 187
WILLIAM OWEN COOKE (ItH11RED) OREENSHOIE). V.O. 27402
DARDEN W. COOKE
WILLIAM 0. WOKE, JR. TELEPHONE (2:10) 272-4514
IAG �3:16)'272-4RIO
April 20, 2010
som y ('t;�•
-o
Division of Water Quality
N.C. Department of Environment and o
Natural Resources
Wetland and Stormwater Branch
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Attn: Mr. Corey Larsen
Dear Mr. Larsen:
The Piedmont Triad Airport Authority greatly appreciated our
meeting on March 29 to discuss the renewal of the Authority's
NPDES stormwater discharge permit. 'The'meeting led to a better
understanding of the DWQ's concerns as well as the issues faced
by the Authority.
Since the meeting, the Authority has been working to prepare
the additional comments and information that we discussed at the
meeting. The Authority has been delayed by the absence of the
Authority consultant who is most familiar with its stormwater
issues, who has been out of the country for the past month, and
the Authority needs additional time to collect the information
that it will present. The Authority should be in a position to
present its ad i.i.t:cnal comments ;.1y i2a;y" 7.
Please let me know if there is anything you need from us in
the meantime.
31l
eereely,
iam 0. Cc e, r.
General Counsel
Piedmont Triad Airport Authority
WOCjr:ge
CC: Edward A. Johnson
Kevin J. Baker
George House

COOKE & COOKE, L.L.P.
ATTORNPYS AT I.AW
FIRST GITIZENS 13ANK 13UYLDING
100 SOUTH ELM STREET
GREI NSBORO- iN.G. 27401
AR I] 1131? O. GOOKF. (1913-1983)
WILLIAM OWEN WOKE (RETIRED)
DARDEN W. COOKE
WILLIAM O. GOOKF, JR.
May 7, 2010
VIA FEDEX OVERNIGHT
Division of Water Quality
N.C. Department of Environment
and Natural Resources
Wetland and Stormwater Branch
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Attention: Mr. Corey Larsen
Re: Draft NPDES Stormwater Permit
Permit No. NCS000508
Piedmont Triad International Airport
Dear Mr. Larsen:
MAILING ADDI217SS:
P.O. BOX 187
GR EENS110110, N.G. 271102
'I'IgJ?PIIONE (390) '272-11r III
FACSIMILE [phone]
The Piedmont Triad Airport Authority ("PTAA") appreciates
this opportunity to offer additional comments concerning the
draft NPDES Permit for the Piedmont Triad International Airport
("PTIA"). These comments take into account DWQ's response to
PTAA's previous written comments as well as the helpful exchange
that occurred at our meeting on March 29.
PTAA proposes modify the draft permit in two respects.
First, PTAA sugges 4modification to the Tiered Response program
appearing on Page 9 of Part II. The proposed changes to the
Tiered Response program are set forth on Exhibit A to this letter.
Second, PTAA proposes tc�)delete the BOD and COD benchmark for de-
icing events from Table 8 of t e ra t permit (but not from Table
4, which specifies the benchmarks for the routine, quarterly test-
ing). PTAA would continue to test for these parameters during de-
icing events, but the benchmark for measuring any glycol impact on
receiving waters would be the in -stream DO value, which would be
retained.
The reasons for the proposed changes are as follows:
�11RqR
MAY 1 0 2010

Division of Water Quality
Attention: Mr. Corey Larsen
Page 2
May 7, 2010
1. The Changes Proposed on Exhibit A Reflect the Function
of the Benchmarks as Management Tools Rather Than Permit
Limits.
As we discussed at our March 29 meeting, PTAA objects
to the implication in the draft permit that a benchmark
exceedence triggers mandatory action on the part of the
permittee to bring its discharge back within the bench-
mark value. This implication can be drawn from Items 3
and 4 of the Tier One response, as outlined on Page 9 of
Part II, which require the permittee to select and im-
plement controls "to bring concentrations within the
benchmark range"; and from the last box of the Tiered
Response program on Page 9, which authorizes DWQ to
mandate storm water control measures, including struc-
tural controls, in the event of four benchmark exceed-
ences at a particular outfall during the term of the
permit.
If the permittee is compelled to bring its discharge
within the benchmark values, then the benchmarks effec-
tively function as permit limits, contrary to the state-
ments in the permit itself, which disclaims any inten-
tion for the benchmarks to have that effect. PTAA would
also object to any use of the benchmarks as mandatory
limits since the benchmarks are, in many instances, more
stringent than the water quality standards adopted by
the EMC or involve parameters for which there are no
numerical limits in the water quality standards.
It is our understanding, based on our meeting, that the
benchmarks are not intended to be mandatory limits, but
are management tools that alert the permittee to poten-
tial water quality issues so that the permittee can
investigate the cause of an exceedence and consider
whether more effective controls are warranted. DWQ
indicated in the March 29 meeting that it would consider
alternative permit language that would address PTAA's
objections and that would more closely express the pur-
pose of the Tiered Response program as explained to us
at the meeting.
The revisions that we are proposing to the Tiered
Response Program, as outlined in Exhibit A, are in
response to your invitation. The revised Tier One

Division of Water Quality
Attention: Mr. Corey Larsen
Page 3
May 7, 2010
response would require PTAA to identify the cause of a
benchmark exceedence. Then PTAA would have to take
action to reduce the exceedence (or variation from the
benchmark range) or it would have to articulate in its
SWPPP why it had determined that no action was neces-
sary. Four exceedences would require notification of
DWQ and an effort to agree upon any action that should
be taken. PTAA could be required to implement more
effective controls if the controls were needed to pre-
vent a violation of a water quality standard.
We believe that
A is consistent
marks to serve
limits. Please
that were alrea
vious comments.
the language we have proposed in Exhibit
with the stated purpose of the bench -
as management tools rather than as permit
note that Exhibit A incorporates changes
3y agreed to in response to PTAA's pre-
2. The BOD/COD Benchmarks Should Be Eliminated for De-icing
Events.
A. Low Volume of Glycol Use at PTIA.
A comparatively small volume of glycol is used at
PTIA. Since our meeting, PTAA has further reviewed
the available information concerning glycol use at
PTIA, which indicates an average annual use of less
than 25,000 gallons of undiluted product, as shown
on Exhibit B. This average is based on purchasing
by the three air carriers that actually take
delivery of glycol at the airport and which supply
themselves and the other major carriers at PTIA.
The volume used at PTIA is comparatively small and
is far below the 100,000 gallon threshold for
imposition of BOD/COD benchmarks in the EPA's
multi -sector airport permit.
PTAA has used purchasing figures for making the
calculation on Exhibit B because the purchased
volumes are easier to verify than reported usage
and should reflect actual usage over time. The
usage that has been reported to PTAA by its air
carriers is actually less. The purchased volumes
have been adjusted by adding 25% to avoid any

Division of Water Quality
Attention: Mr. Corey Larsen
Page 4
May 7, 2010
understatement of the actual use and to allow for
variations from one year to another.
B. Intermittent Use.
De-icing events are not representative of the
typical discharge at PTIA, even during the winter
months. Over the four winter seasons from the
2005-2006 winter season through 2008-2009, there
were only 14 occasions when glycol was detected at
any of the representative outfalls at PTIA in ex-
cess of 100 mg/L, or an average of only 3.5 such
occasions a year. (See Exhibit C, which is a com-
pilation of PTAA's analytical test results under
its existing permit.) The glycol discharge at
PTIA is sporadic, and any impact to the receiving
streams is short-lived.
C. Absence of Correlation between BOD and DO Levels in
the Test Results.
Exhibit C indicates a lack of any correlation
between BOD and DO readings in the five years of
testing under PTAA's existing permit. BOD readings
in excess of 30 mg/L are shown in purple on Exhibit
C. DO readings of 5 mg/L or less are shown in red.
There is no date on which the two coincide. (Gly-
col results in excess of 100 mg/L are also high-
lighted on Exhibit C, as indicated.)
Significantly, the testing dates with low (red) DO
readings in Brush Creek always include a low result
at the In -Stream 1 site, which is upstream from
airport drainage. Similarly, the low DO readings
in Horsepen Creek always include a low DO reading
at the In -Stream 7 site, which is the most upstream
of the Horsepen Creek sampling locations and which
is above any drainage from the aprons where glycol
is applied at PTIA. In several instances, IS-7 is
the only site with a low DO level. The fact that
low DO is always associated with low readings at
the upstream sites indicates that depressed DO is
not the result of glycol runoff but of other
causes. By contrast, the higher (purple) BOD

Division of Water Quality
Attention: Mr. Corey Larsen
Page 5
May 7, 2010
readings coexist with high DO levels, and DO levels
seem to vary independently from the BOD results.
On January 17-19, 2008, PTAA performed hourly DO
testing, following glycol use, at the points at
which Brush and Horsepen Creeks exit the airport
boundary. This testing was continued for 48 hours
and followed the glycol discharge on that date
through its peak and subsequent subsidence.
Significant BOD levels were detected within the
stream. However, during that time, DO levels never
fell below 12 mg/L in Horsepen Creek, nor below 11
mg/L in Brush Creek.
D. Limited Downstream Impact.
Following its exit from the PTIA property, Brush
Creek runs an additional 13,000 feet, falling 31
feet in elevation, until it empties into Lake Hig-
gins; and Horsepen Creek runs an additional 27,330
feet, falling 49 feet in elevation, until it
empties into Lake Brandt. If the velocities in
the two streams were 17 miles per day (the average
velocity that DWQ has estimated for Crabtree Creek,
which is of comparable size), the travel time for
Brush Creek between PTIA and Lake Higgins would be
approximately 3.5 hours and the travel time for
Horsepen Creek between PTIA and Lake Brandt would
be approximately 7.5 hours. If glycol is not
depleting stream oxygen levels within the PTIA
boundary, any glycol that passes downstream is
unlikely to exert a significantly greater impact
over these short time frames.
PTAA has obtained downstream test results for both
streams from the City of Greensboro. These results
are summarized on Exhibit D. Unfortunately, a
comparison of the City's test results with the
glycol application dates on Exhibit C does not
reveal any date on which the City's tests might
indicate whether glycol was having any effect.
However, the City's results do show consistently
high DO levels during the winter months.

Division of Water Quality
Attention: Mr. Corey Larsen
Page 6
May 7, 2010
As we discussed at our meeting, after the streams
empty into the downstream lakes, any glycol dis-
charge should be diluted to insignificance. Lake
Higgins has a storage volume of approximately 800
million gallons. Assuming the lake is full and the
entire 25,000 gallons of annual glycol use calcu-
lated on Exhibit B were discharged into Lake Hig-
gins at once, the glycol would be diluted by a
factor of over 32,000:1. Similarly, Lake Brandt
has a storage capacity of approximately two billion
gallons, so that if the entire 25,000 gallons were
discharged into Lake Brandt when the lake was at
full capacity, the dilution ratio would be over
80,000:1. Once any glycol discharge reaches the
lakes, any oxygen demand should be entirely
dissipated.
E. Retention of the DO Benchmark as the Appropriate
Measure of Any Impacts.
PTAA accepts the in -stream DO benchmark of 5 mg/L
for de-icing events. Although this benchmark is
higher than the water quality standard for DO
(which allows an instantaneous DO level as low as
4 mg/L), it is an appropriate gauge of any oxygen
depletion in the receiving streams. If there were
a DO result below the benchmark that was attribut-
able to airport runoff (as distinguished from inde-
pendent causes), PTAA would work in cooperation
with DWQ to identify and to correct the shortfall.
3. PTAA Has Already Taken, and Will Continue, Cost -
Effective Steps for Limiting Glycol Discharge.
A. Existing Control Strategy.
PTAA has already undertaken significant steps to
reduce glycol discharge at PTIA, including the
following:
• Carriers have been instructed to conduct
their de-icing operations away from open
drains. PTAA believes that this measure
reduces the entry of deicing agents into the
storm water drainage system especially during

Division of Water Quality
Attention: Mr. Corey Larsen
Page 7
May 7, 2010
non -precipitation (defrosting) events when no
storm water is present to carry the agents
into the drains.
• The personnel who apply glycol to aircraft
have been trained to minimize spillage and
wasted product, consistent with aircraft
safety. Personnel training is supervised by
the carriers in accordance with FAA require-
ments for both initial and annual training,
and is reported to PTAA under PTAA's SWPPP.
• PTAA's Spill Prevention and Response Plan
provides that the notification protocols in
PTAA's Spill Prevention Control and Counter-
measure Plan will apply not only to petroleum
products but also to deicing agents. The
adoption of these protocols for deicing agents
provides for appropriate action to be taken to
deal with accidental spills of de-icing agents
on PTIA grounds.
• The drainage system at the new Federal Express
hub facility captures all de-icing agents from
the de-icing pads on the aircraft aprons. The
runoff is subsequently released into the City
of Greensboro POTW.
B. Cost of Eliminating Discharge from the Application
Sites.
Since our meeting, PTAA has developed a more de-
tailed cost estimate for constructing dedicated de-
icing pads for non-FedEx aircraft at PTIA with a
complete capture of the runoff from the pads. An
itemized estimate is attached to this letter as
Exhibit E, indicating that an initial capital cost
of approximately $12,850,000 to construct a de-
icing pad at each end of Runway 5R/23L (the main
runway serving the terminal area). The pads would
be located at the runway ends rather than at the
aircraft aprons to prevent aircraft from shedding
glycol during taxiing and to allow for re-
application, without return to aircraft gates, in
the event of a delay during departure. The cost of

Division of Water Quality
Attention: Mr. Corey Larsen
Page 8
May 7, 2010
the drainage system and storage tanks is included
in the estimate. This estimate does not include
annual maintenance and operating costs for the
system, any opportunity costs for alternative use
of the sites, or any cost for disposing of the
captured storm water from the containment tanks.
This cost is clearly prohibitive in light of the
limited glycol use at PTIA and the limited impact
of such use on the receiving streams. Although
PTAA would object to the unwarranted cost of a
containment system, PTAA will continue the control
strategies that it has undertaken to date to limit
glycol discharge at PTIA.
4. De -Icing Is Required by the FAA and Is Essential
for Aircraft Safety.
At DWQ's request, we have attached to this letter as
Exhibit F the FAA regulation and Advisory Circular
concerning aircraft de-icing procedures. The safety of
aircraft, passengers and crew is of paramount concern
and cannot be compromised.
*****************************
PTAA respectfully requests that DWQ consider and approve
PTAA's proposed changes to the draft permit, as outlined in this
letter and on Exhibit A. These changes would be in addition to
those that DWQ has already agreed to in response to PTAA's initial
comments, as outlined in your letter of March 15, 2010. Please
let me know if you have any questions out the proposed changes
or need any additional information
Wi1lt&am
WOCjr:ge
Enclosures
CC: Edward A. Johnson
Kevin J. Baker
George House

11
11
11

EXHIBIT A
PROPOSED CHANGES IN TIERED RESPONSE PROGRAM
A. Revise the Tier One Response box (Part II, P. 9) as follows (changes from the original draft
permit are marked for your reference):
If: The first valid sampling results are above a benchmark value, or outside of the
benchmark range, for any parameter at any outfall or in -stream location;
Then: The permittee shall:
Conduct a stormwater management inspection of the facility within two weeks
of receiving sampling results.
2. Identify and evaluate possible causes of the benchmark value exceedence.
3.
mngc-.-_jdentify
potential source controls, operational controls, or physical improvements, if
any, that could reduce the difference between the sampling results and the
benchmark value and select any such corrective measure or combination of
corrective measures that the permittee determines to be appropriate and
warranted, after due consideration of the cause and nature of the exceedence
and the feasibility, cost and effectiveness of such measures.
r
4. hnplementthe_Lny selected actions within two months of the inspection or as
soon thereafter as reasonably possible. 8 ��
5. Record each instance of a Tier One response in the Stormwater Pollution
Prevention Plan. Include the date and value of the benchmark exceedence, the
inspection date, the personnel conducting the inspection, the selected actions, if
any, and the date the selected actions were implemented, or, if no action was
implemented, the basis for that decision.
B. Revise the last box of the Tiered Response Chart (Part II, bottom of P. 9) as follows (changes
from the original draft permit are marked for your reference):

During the term of this permit, if the valid sampling results required for the permit
monitoring periods exceed the benchmark value, or are outside the benchmark range, for
any specific parameter at any specific outfall or in -stream location on four occasions, the
permittee shall notify the DWQ Regional Office Supervisor in writing within 30 days of
receipt of the fourth analytical results. Gcu...� u1 k 0'A7
results and the benchmark
permittee revise, increase, or decrease the monitoring frequency for the remainder of the
permit and may impose such other requirements, if any, as may be necessary to prevent
not limited to:
ce,4-Aa f
require the permittee to install structural stormwater controls; or
require the permittee to implement other stormwater control measures or,
v/e-
If the inspection and evaluation of a particular sampling result under Tier One or Tier qq e" _ _Q
Two show the result is not caused by the permittee's operations and facilities, it will not � "�
be treated as a benchmark exceedence for purposes of determining whether four I 4rcj
consecutive exceedences have occurred.

C
i I &q ) H X3 0
E

Exibit B
Average Glycol Purchasing at PTIA
Source
Continental
USAir
FedEx
Available Data
(years)
2007-2009
2008-2009
2001-2009
Average
Purchasing by
Year (gal)
5478
6361
8036
Note: Data from 2009Includes re -purchasing due to recall of
product.
Total Airport
Purchasing 19875
Total + 25% 24843.75

El

STORMWATER ANALYTICAL RESULTS
glycol greater than •• 'mg/I
BOD Preater than
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
O
o f
a_
c oo
a m E
t C
O
-
O
> E
w o
c m
01 m E
O C
O
-
O
C
N
E
m E
vi
- 0
V (fI
'en
°
o
'm
9
n
m
a
VI
'FeE
o
c
Z
m =
O-
E
r
w r
ry
V '-'
Q
_�
°-
13
o
U
c
v E
°
N
'p
2
r
Date
Sample
12/19/2000
OF-001
ND<10
ND<20
NA
NA
NA
NA
OF-002
ND<10
ND<20
NA
NA
NA
NA
OF-003
ND<50
r
NA
NA
NA
NA
OF-004
ND<10
ND<20
NA
NA
NA
NA
OF-005
ND<10
ND<20
NA
NA
NA
NA
OF-006
ND<10
ND<20
NA
NA
NA
NA
OF-007
ND<10
ND<20
NA
NA
NA
NA
OF-008
NA
NA
NA
INA
I
INA
I
NA
1/26/2001
OF-001
ND<10
ND<20
ND<2
11
6.62
NA
OF-003
ND<10
ND<10
ND<2
ND<5
7.09
NA
OF-005
ND<10
ND<10
ND<3
7
7.17
NA
OF-006
ND<10
ND<10
ND<2
ND<5
7.58
NA
OF-007
ND<10
ND<10
ND<2
ND<5
7.84
NA
OF-008
ND<10
ND<10
ND<2
6
7.4
NA
2/22/2001
OF-001
ND<10
ND<10
2.8
11.5
5.97
NA
OF-003
1001QM
MMJr r
.;.;Gr ,
31.51
6.94
NA
OF-005
ND<10
ND<10
ND<6
11.3
6.791
NA
OF-006
ND<10
ND<10
7.4
13.5
7.06
NA
OF-007
ND<10
ND<10
12.9
67
7.11
NA
OF-008
ND<10
ND<10
NA
NA
NA
NA
3/6/2001
OF-001
ND<10
ND<10
2.2
9.8
6.45
NA
0E-003
ND<10
ND<10
12.3
25
6.35
NA
OF-005
ND<10
ND<10
ND<2
11.3
6.43
NA
OF-006
ND<10
ND<10
4.61
581
6.54
NA
OF-007
ND<10
ND<10
ND<2
9
1 6.931
NA
OF-008
ND<10
ND<10
NA
NA
NA
NA
NA
NA
2/7/2002
OF-001
ND<10
ND<10
3.4
7
6.39
NA
OF-003
ND<10
13.9
13.8
28
6.41
NA
OF-005
ND<10
ND<10
4.0
85
6.99
NA
OF-006
ND<10
ND<10
7.2
38
6.89
NA
OF-007
ND<10
ND<10
3.5
14
7.24
NA
OF -DOS
IND<10
ND<10
NA
INA
INA
NA
NA
NA
NA
12/6/2002
OF-001
ND<10
ND<10
ND<5
5.5
6.7
10.05
OF-003
9W,
ND<10
''. `; r r
2.5
6.7
9.03
OF-005
41.0
ND<10
r
AM
4.5
6.6
9.51
OF-006
W#
ND<10
-'`+,; •r r
4.8
7.2
10.06
OF-007
ND<10
IND<10
5.0
31
7
10.11
OF-008
ND<10
ND<10
NA
NA
NA
10.13
12/12/2002
OF-001
ND<10
ND<10
ND<5
NA
NA
8.89
0E-003
EW�C
NDQO
FM,
NA
NA
7.59
Sheet 1 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' •• 'mg/I
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
0
cw m
W 7
o
o r
cm
.y
°E
O
G
a
c
E
a
E
x
u m
O
'm
v
o
m
a�
vi
O
c
M
o
E
E
cParameter
U ^'
'E
' >
O
V
c
v Im
w E
N
v�
H
z
Date
Sample
OF-005
ND<10
ND<10
13.0
NA
NA
8.93
OF-006
ND<10
ND<10
10.0
NA
NA
9.17
OF-007
ND<10
ND<10
ND<2
NA
NA
9.18
OF-008
84.0
ND<10
t1dME,
NA
NA
8.35
1/20/2003
OF-001
ND<10
ND<10
ND<2
NA
NA
8.54
OF-003
ND<10
ND<10
ND<2
NA
NA
7.53
OF-005
ND<10
ND<10
ND<2
NA
NA
8.69
OF-006
ND<10
ND<10
27.0
NA
I
INA
1
8.92
OF-007
ND<10
ND<10
ND<2
NA
NA
8.73
OF-008
ND<10
991M#
;':*' r r
NA
NA
6.56
1/29/2003
OF-001
ND<10
ND<10
ND<5
NA
NA
10.10
OF-003
ND<10
ND<10
;;;:, r r
NA
NA
8.33
OF-005
ND<10
ND<10
ND<5
NA
NA
10.12
OF-006
ND<10
71.0
.�,AMCO
NA
NA
8.42
OF-007
ND<10
ND<10
6.0
NA
NA
9.89
OF-008
ND<10
r t
._.,;.. : t r
NA
I
INA
8.49
5/28/2003
OF-001
ND<2
ND<2
14.0
18
6.5
8.79
OF-003
ND<2
ND<2
ND<2
4.3
6.2
8.61
OF-005
ND<2
ND<2
ND<2
13
6.6
9.74
OF-006
ND<2
ND<2
ND<2
10
7
9.39
2F-007
N2<2
ND<2
ND<2
7.7
6.7
9.50
OF-008
ND<2
IND<2
ND<2
NA
NA
9.29
12/5/2003
OF-001
ND<50
ND<50
7.0
NA
I
NA
10.49
OF-003
ND<50
r r r
%JCM,
NA
NA
10.16
OF-005
ND<50
t r r
: r
NA
NA
10.36
OF-006
ND<50
' r t
'G".: il
NA
NA
10.64
OF-007
ND<50
60.0
2.0
NA
NA
10.43
OF-008
ND<50
• : r '
iZiMCO
NA
NA
10.25
12/16/2003
0E-001
ND<50
ND<50
3.0
7.5
7.8
11.16
OF-003
ND<50
_ r r
'
24
6.4
9.06
OF-005
ND<50
ND<50
Z&OW#1
121
1 71
10.98
OF-006
ND<50
ND<50
14.0
5.5
7.3
10.66
OF-007
ND<50
ND<50
ND<2
7.2
7.2
10.58
OF-008
ND<50
70.0
l,= ' t O
NA
NA
10.39
1/9/2004
OF-001
ND<50
ND<50
4.0
NA
NA
11.11
0E-003
ND 200
EMMOM
'5`AM,
NA
NA
11.04
OF-005
ND<50
ND<50
ND<2
NA
NA
11.03
OF-006
ND<20011MMMQJEM
e12MEI
NA
NA
11.13
OF-007
ND<50
IND<50
r
NA
NA
10.81
OF-008
ND<100
r r r r
•: r r
NA
NA
10.20
Sheet 2 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' •• 'mg/I
BOD ¢reaterthan I r r .:IBOD-5
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
$E
m
at E
r �
W
CY
Co
o
> E
c° m
u A E
o c
a
a
c
E
E
w
0D ui
O 0
$ m
o
O
'm
o
n
a
i'n
O
H
m
c = ^?
E?
E
«
w t
3 '�"
a'
=
c
.>
r' E
a i
t0
a
v m
v E
>
N17
c
v
Laz
Date
Sample
1/28/2004
OF-001
ND<50
ND<50
5.0
NA
NA
9.40
OF-003
••r t
err r
trr r
NA
NA
8.40
OF-005
ND<50
9W,
i"REM'
NA
NA
8.60
OF-006
ND<50
MMMUM#
;1 ' rrr
NA
NA
7.60
OF-007
ND<50
ND<50
5.0
NA
NA
8.20
OF-008
ND<50
' r r
": W r r r
NA
NA
7.70
1/31/2005
Stream-1
BDL
BDL
7.8
>1009,
7.1
160
7.80
Stream-2
BDL
BDL
9.71
1
>100%
1 7.21
157
7.80
Stream-3
37.0
9.5
W,)M
>100%
7.21
155
7.80
Stream-4
1 r r r
12.0
'i>. `-';
>100%
7.14
131
7.96
Stream-5
BDL
BDL
<2.2
>100%
6.5
92
8.00
Stream-6
65.0
BDL
D:'::MCI
>100%
7.19
130
8.00
Stream-7
BDL
BDL
4.0
>100%
7.47
220
8.00
Stream-8
28.0
22.0
P !tip
>100%
7.56
118
8.00
Stream-9
BDL
8.1
28.0
>100%
7.57
175
8.20
Stream-30
DWI
20.0
EWACK,
>100%
7.57
125
8.00
Stream-11
52.0
9.8
ENIM,
>100%
1 7.61
181
7.80
2/3/2005
OF-004
13.0
r
EIMMO
17
12
>100%
7.3
93
7.70
OF-006
aDKI
73.0
I
54
11
>100%
7.17
55
7.60
OF-014
BDL
BDL
7.2
29
0.39
>100%
6.5
Dry
7.90
OF-024
amcl
r r r
_• r -r
24
NA
>100%
7.21
72
7.70
OF-026
BDL
BDL
15.0
9.7
NA
76.80%
6.97
189
7.80
OF-027
7.2
Mcl
Q"=;'(•}fir
18
0.71
50.20%
6.94
150
7.80
OF-030
BDL
BDL
3.51
371
0.084
77.10%
6.43
101
8.00
Stream-1
11.0
>100%
1 6.981
160
13.80
29
Stream-2
i).11..�rr
>100%
7.11
157
13.70
230
Stream-3
&l �r'
>100%
7.04
155
13.70
146
Stream-4
V,1111MCI
>100%
7.11
131
12.90
220
Stream-5
vJIME
>100°%
7.07
92
12.90
130
Stream-6
E> '-MCI
>100%
6.93
130
14.00
360
Stream-7
4.2
>100%
5.74
220
14.40
67
Stream-8
D?lz Q})rI
>100%
6.22
118
14.801
120
Stream-9
h,
>100%
1 6.471
175
14.20
230
Stream-10
011 • r r
>100%
6.9
125
13.70
280
Stream-11
CNEW,
>100%
6.95
181
13.70
280
3/1/2005
OF-004
23.0
MCI
Calffic,
6
2.4
>100%
7.57
112
7.70
OF-006
21.0
16.0
;;,- r
6
1.4
>100%
7.65
937.80
OF-014
BDL
BDL
3.6
29
0.043
>100%
7.32
Dry
7.70
OF-024
r • r r
• r r
P r Cr
13
NA
>100%
7.4
68
7.60
OF-026
BDL
BDL
1 7.41
5.7
NA
>100%
7.68
160
7.70
Sheet 3 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than „ , 'mg/I
BOD ¢reaterthan I r r IBOD-5
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
E
>
w `o
c m
w m E
«
t C
W J
O
o
o r
_ E
„ `o
c m
01 m E
T«
O
O C
d J
fi
c
n
E
y
c m
m E
>
x
O O
r0
m
�
2
'm
v
o
v
w
G
a
N
>
N
A
p
H
w
m
o
„ Z
'z
m
=
Z
E ....
E
Q
'�
"
a t
U
> N
V •-•
a
_
a
•�
•� E
a
C Y
p
U
c
y
x
0 ^
d E
0
N
O
z
r
Date
Sample
OF-027
BDL
a r r
D MA,
14
0.049
>100%
7.13
117
7.60
OF-030
BDL
BDL
<2
7.7
BDL
>100%
7.66
95
7.80
Stream-1
6.6
>100'%
5.91
160
17.40
5
Stream-2
9.6
>100%
6.76
157
16.70
21
Stream-3
�r
>100%
6.88
155
18.50
57
Stream-4
aQ�r
>100%
6.91
131
17.00
96
Stream-5
Cam'.
>100%
7.24
92
16.80
52
Stream-6
- miI
I
>100% 1
6.91
130
19.101
65
Stream-7
2.2
>100%
7.2
220
18.00
24
Stream-8
MCI
>100%
7.3
118
18.90
18
Stream-9
8.4
>100%
7.04
175
19.99
25
Stream-10
E) 9MC1
>100%
6.74
125
19.20
16
Stream-11
'__MCI
>100%
6.5
181
19.90
41
3/17/2005
OF-004
BDL
9.8
0.92
>100%
7.39
9.5
7.80
OF-006
rrr
r r
D ffix,
25
0.43
>100%
7.22
9.8
8.60
OF-014
BDL
BDL
5.81
7.61
0.53
>100%
1 7.131
NA
8.20
OF-024
: r • r
r r
`.: •.
3.4
NA
>100%
7.5
0
8.30
OF-026
BDL
19.0
21.0
3.8
NA
89.10%
7.41
18.2
8.60
OF-027
BDL
r r r r
D MKI
16
0.031
70.10%
7.2
11.8
8.30
OF-030
BDL
BDL
<4.2
2.8
BDL
>100%
7.53
9.8
8.70
Stream-1
1
5.6
>100%
6.02
1S.2
11.23
12
Stream-2
.MCI
>100%
6.54
0
10.99
148
Stream-3
MCI
>100%
6.65
13.7
10.62
35
Stream-4
D MOL,
I
I
>100%
1 6.621
0
11.861
49
Stream-5
<4.17
>100%
6.48
11.8
12.05
34
Stream-6
9 • r r
>100%
6.61
10.9
11.09
98
Stream-7
4.2
>100%
6.15
17.1
11.50
75
Stream-8
D.- r
>100%
6.08
9.3
12.15
61
Stream-9.'
>100%
5.89
12.9
12.02
91
Stream-10
rrr
>100%
5.83
12.5
12.69
39
Stream-11
D{ r r
>100%
5.53
21.1
12.80
78
8 9 2005
OF-004
3.01
5.7
ND
NA
INA
1 100
NA
INA
OF-006
2.01
13
ND
NA
NA
68
NA
NA
OF-014
9.0
19
ND
NA
NA
NA
NA
OF-024
ND
ND
NA
NA
NA
73
NA
NA
OF-026
3.0
ND
NA
NA
NA
2490
NA
NA
OF-027
ND
ND
ND
NA
NA
160
NA
NA
OF-030
ND
ND
ND
NA
NA
112
NA
NA
Stream-1
NA
NA
NA
NA
7.22
147
8.20
15
Stream-2
NA
NA
NA
INA
1 6.851
134
8.001
13
Sheet 4 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' - _ _ 'mg/I
BOD-5
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
D.O. less than 5.00 mg/I
Parameter
0
J
aci m
L C
w
o y
J
c
o
n
=
O C
G
a
c
E E
C m
0E
xE
O
m
O
O
'm
v
H
~
c
a
Z r
p
c z
E
E
c
Q
c i
U
c
O
%
E0
>
N
0
D
v
a« z
~
Date
Sample
Stream-3
NA
NA
NA
NA
6.7
147
7.60
14
Stream-4
NA
NA
NA
NA
6.5
139
6.50
11
Stream-5
NA
NA
NA
NA
6.58
69
8.40
12
Stream-6
NA
NA
NA
NA
6.81
112
9.50
18
Stream-7
NA
NA
NA
NA
6.86
168
9.80
3
Stream-8
NA
NA
NA
NA
6.83
89
7.40
5
Stream-9
NA
NA
NA
NA
7.17
138
10.00
4
Stream-10
NA
INA
INA
NA
1 7.171
112
9.701
2.3
Stream-11
NA
INA
NA
NA
7.84
142
11.00
22
10/31/2005
OF-004
NA
NA
BRL
BRL
BRL
NA
7.35
13.60
7.2
OF-006
NA
NA
BRL
10
2.9
NA
7.59
15.38
16.7
OF-014
NA
NA
NA
NA
NA
NA
NA
NA
NA
OF-024
NA
NA
NA
NA
NA
NA
NA
NA
NA
OF-026
NA
NA
5.6
16
NA
NA
7.08
11.75
25.8
OF-027
NA
NA
BRL
3.5
BRL
NA
7.21
13.51
3.1
OF-030
NA
NA
BRL
BRL
JBIRL
NA
7.591
12.97
1
Stream-1
NA
NA
NA
NA
7.81
12.75
9.7
Stream-2
NA
NA
NA
NA
7.53
14.24
9.6
Stream-3
NA
NA
NA
NA
7.45
13.18
8.6
Stream-4
NA
NA
NA
NA
7.47
13.87
7.1
Stream-5
NA
NA
NA
NA
7.2
13,031
8.3
Stream-6
NA
NA
NA
NA
7.37
14.84
20.8
Stream-7
NA
NA
NA
NA
7.37
12.71
6
Stream-8
NA
INA
INA
NA
1 7.591
15.38
16.7
Stream-9
NA
NA
NA
NA
7.37
16.20
6.8
Stream-10
NA
NA
NA
NA
7.77
14.73
10.4
Stream-11
NA
NA
NA
NA
7.58
15.94
29.8
11/10/2005
OF-004
NO
NO
5.3
8
BRL
NA
7.46
12.61
10.8
OF-006
NO
NO
BRL
7.2
BRL
NA
7.71
16.111
21.4
OF-014
Dry
Dry
NA
NA
NA
NA
NA
Dry
NA
NA
OF-024
NO
NO
NA
NA
NA
NA
NA
NA
NA
OF-026
NO
NO
14.01
4.61
NA
NA
1 7.121
11.84
20.6
OF-027
NO
ND
,�%C1
7.4
BRL
NA
7.12
13.20
18.6
OF-030
NO
ND
BRL
BRL
BRL
NA
7.42
12.65
11.6
Stream-1
NA
NA
NA
NA
7.3
9.50
32.1
Stream-2
NA
NA
NA
NA
7.3
12.60
62
Stream-3
NA
NA
NA
NA
7.3
12.31
23.8
Stream-4
NA
NA
NA
NA
7.18
9.95
61.1
Stream-5
NA
NA
NA
NA
7.47
1 12A0I
89.8
Stream-6
NA
INA
INA
INA
1 6.381
1 12.211
24.4
Sheet 5 of 30

glycol greater than
STORMWATER ANALYTICAL RESULTS
BOD ereaterthan I KIM IBOD-5
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
u E
w o
w m E
t C
O
o
p u
> E
u `o �,
]01 m E
- a
O C
U
9
C
E
y _
G
e010 E
O � 0
y C]
'm
o
o
'm
s
o
,n
n
N
m
c
c
o'
Z �Zh
=
C Z
E
E
G
o
a t
C
U
G
n
E
v
C Y
(OJ
c
O
w E
>
O
o
'v D
: Z
~
Date
Sample
Stream-7
NA
NA
NA
NA
7.191
12.70
16.7
Stream-8
NA
NA
NA
NA
7.46
14.38
15.2
Stream-9
NA
NA
NA
NA
7.35
12.92
16.7
Stream-10
NA
NA
NA
NA
7.77
11.20
18.8
Stream-11
NA
NA
NA
NA
8.38
13.56
38.7
12/6/2005
OF-004
ND
ND
NA
>100%
7.4
7.60
OF-006
ND
ND
NA
>100%
7.18
7.60
OF-014
ND
ND
NA
I
I
>100%
7.43
7.70
OF-024
ND
ND
NA
>100%
1 7.271
7.70
OF-026
ND
ND
NA
>100%]
7.57
7.60
OF-027
ND
ND
NA
>100%
7.55
7.70
OF-030
ND
ND
NA
>100%
7.63
7.90
Stream-1
INA
NA
BRL
>100%
7.35
0.061
7.60
Stream-2
NA
NA
BRL
>100%
7.42
0.137
7.60
Stream-3
NA
NA
BRL
>100%
7.35
0.294
7.70
Stream-4
NA
NA
BRL
>100%
7.06
0.087
7.40
Stream-5
NA
NA
BRL
>100%
6.391
0.078
7.60
Stream-6
NA
NA
BRL
>100%
7.2
0.117
7.70
Stream-7
NA
NA
BRL
>100%
7.39
0.315
7.80
Stream-8
NA
NA
BRL
>100%
7.33
0.056
7.80
Stream-9
NA
NA
BRL
>100%
7.5
0.178
7.70
Stream-10
NA
NA
BRL
>100%
7.46
0.09
7.70
Stream-11
NA
NA
BRL
>100%
7.47
0.167
7.60
12/9/2005
OF-004
ND
11.8
N/A
>100%
OF-006
ND
ND
N/A
>100%
OF-014
ND
ND
N/A
>100%
OF-024
ND
1'3j&C'
N/A
>100%
OF-026
ND
ND
N/A
61.50%
OF-027
r r
ND
N/A
>100%
OF-030
IND
51.8
N/A
>100%
Stream-1
N/A
N/A
4.3
>100%
Stream-2
N/A
N/A
5.01
1
>100%
Stream-3
N/A
N/A
12.0
>100%
Stream-4
N/A
N/A
15.0
>100%
Stream-5
N/A
N/A
3.3
>100%
Stream-6
N/A
N/A
22.0
>100%
Stream-7
N/A
N/A
3.3
>100%
Stre2m-8
N/A
N/A
5.6
>100%
Stream-9
N/A
N/A
5.1
>100%
Stream-10
I N/A
N/A
15.01
1
>100%
Sheet 6 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than''mg/I
BOD ¢reaterthan I KW IBOD-5
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
E
m
cai io E
O
o
ti
o
= E
c.g
m
O
a
c
m
E
a
0 o
o
m
a
c
c
mz,
E
Q
c
�N
c
o—
u
c
Og m
I
iE
o`
:o Z)
a
?E
f-
Date
Sample
Stream-11
N/A
N/A
12.0
>100%
12/16/2005
OF-004
ND
r
N/A
>100%
OF-006
ND
ND
N/A
>100%
OF-014
ND
ND
N/A
>100%
OF-024
ND
r r r
N/A
>100%
OF-026
IND
ND
N/A
77.10%
OF-027
ND
WC,
N/A
>100%
OF-030
ND
ND
N/A
>100%
Stream-1
N/A
N/A
5.4
>100'%
Stream-2
N/A
N/A
21.0
>100%
Stream-3
N/A
N/A
MCI
>100%
Stream-4
N/A
N/A
r r
>100%
Stream-5
N/A
N/A
D. rO
>100%
Stream-6
N/A
N/A
( MCI
>100%
Stream-7
N/A
N/A
5.0
>100%
Stream-8
N/A
N/A
D-- r O
>100%
Stream-9
N/A
N/A
MCI
>100%
Stream-10
N/A
N/A
DMIZI
>100%
Stream-11
N/A
N/A
MCI
>100%
12/26/2005
OF-004
BDL
BDL
NS
>100%
OF-006
BDL
BDL
NS
>100%
OF-014
N/A
N/A
N/A
N/A
OF-024
BDL
BDL
NS
100%
OF-026
BDL
BDL
NS
I
1
100%
OF-027
BDL
47.0
NS
100%
OF-030
BDL
BDL
NS
100%
Stream-1
NS
NS
4.1
100%
Stream-2
NS
NS
BDL
100%
Stream-3
INS
NS
3.7
100%
Stream-4
NS
NS
3.6
100%
Stream-5
NS
NS
BDL
100%
Stream-6
NS
NS
BDL
100%
Stream-7
NS
NS
BDL
100%
Stream-8
NS
NS
24.0
100%
Stream-9
NS
NS
4.5
100%
Stream-10
NS
NS
5.1
100%
Stream- 11
INS
5.3
100%
1/12/2006
OF-004
ND
ND
>100%
7.04
931
7.90
HOOF-006
IND
IND
>100%
7.03
551
7.90
F-014
IDry,
IDry,
lDry
lDry
lDry,
JDry
Sheet 7 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' _ 'mg/I
BOD ereater than
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.26399
Parameter
0
0p c
u o m
cu m E
t C
W
o
-
o
O c '-'
o m
°1 n E
>
O �
O-
c1
-
a
c
n
E
_
m E
x `^
O o
0
w
G
a
'm
v
a
c N
c
3
N
c
c
a
zx
Z ni
f0 x
.� z
E `.--
E
a
0
w r
v
V N
Q
x
n
'- E
u
i
c a
ip `-
c
o
^' E
>-
N
M:3
a z
H
Date
SampleI
OF-024
ND
ND
>100%
6.91
72
7.80
OF-026
ND
ND
>100%
7.12
189
7.80
OF-027
ND
ND
>100%
6.95
150
7.20
OF-030
ND
ND
>100%
7.35
101
8.30
Stream-1
5.6
>100%
7.19
195
8.00
Stream-2
5.1
>100%
7.22
164
8.10
Stream-3
6.5
>100%
7.22
166
7.90
Stream-4
4.51
1
>100%
1 6.671
131
7.70
Stream-5
BRL
>100%
6.58
70
7.70
Stream-6
BRL
>100%
7.27
122
7.80
Stream-7
BRL
>100%
7.55
189
8.10
Stream-8
4.4
>100%
7.33
101
7.90
Stream-9
BRL
>100%
7.54
139
8.10
Stream-10
BRL
>100%
7.52
116
8.20
Stream-11
BRL
>100%
7.54
138
8.20
1/31/2006
OF-004
BDL
BDL
I
I
>100%
1 7.411
112
7.70
OF-006
BDL
BDL
>100%
7.17
93
7.60
OF-014
Dry
Dry
Dry
Dry
Dry
Dry
OF-024
BDL
BDL
>100%
7.4
68
7.90
OF-026
BDL
BDL
>100%
7.22
160
7.70
OF-027
BDL
BDL
>100%
7.15
117
7.80
OF-030
lBDL
BDL
>100%
7.44
95
8.00
Stream-1
5.3
>100%
7.32
1601
7.80
Stream-2
3.3
>100%
7.671
157
7.90
Stream-3
3.2
>100%
7.6
155
7.80
Stream-4
3.6
>100%
7.25
131
7.90
Stream-5
BDL
>100%
6.69
92
8.00
Stream-6
BDL
>100%
7.47
130
8.10
Stream-7
BDL
>100%
7.71
220
8.20
Stream-8
4.7
>100%
7.56
118
7.90
Stream-9
BDL
>100%
7.8
175
8.00
Stream-10
5.91
1
>100%
1 7.611
125
8.10
Stream-11
4.0
>100%
7.95
181
8.30
2/3/2006
OF-004
ND
ND
7.8
>100%
6.37
9.5
8.06
13.2
OF-006
ND
ND
12.0
>100%
6.4
9.8
8.75
15
OF-014
Dry
Dry
Dry
>100%
NA
NA
NA
NA
OF-024
31.81ND
ME;
>100%
6.64
0
15.29
202
OF-026
ND
ND
5.9
>100%
6.58
2
4
44
ND
ND
23.0
>100%
6.6
1184
4OF-027
OF-030
ND
IND
BRL
I
1>100%
1 6.61
9.81
13.561
21.6
Sheet 8 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' -- . 'mg/I
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
>,
a, m E
"'
7
o
o r
01 m E
a
C
v
C
E
m
c m
px 6
m
'E6
'm
N
v
o
w
1�
A
o
c
m
,,, Z
E Z
E
G
z
3 N
v z
V-
c
v
x
> E
O
0
z
~
Date
Sample
Stream-1
8.9
>100%
6.47
15.2
14.64
24.8
Stream-2
5.2
>100%
6.57
0
14.45
5.9
Stream-3
28.0
>100%
6.65
13.7
14.80
76.7
Stream-4
7.1
>100%
6.66
0
12.98
74.6
Stream-5
5.3
>100%
6.61
11.8
13.63
61.6
Stream-6
7.0
>100%
6.71
10.9
14.54
64.9
Stream-7
6.5
>100%
6.36
17.1
7.97
19
Stream-8
8.91
1
>100%° 1
6.441
9.3
11.301
37.7
Stream-9
5.7
>100%
6.27
12.9
8.86
54.9
Stream-10
7.5
>100%
6.22
12.5
8.81
51.9
Stream-11
7.5
>100%
5.98
21.1
9.50
56.4
2/12/2006
OF-004
ND
: r r
>100%
7.3
100
7.50
OF-006
ND
ND
>100%
7.01
68
7.60
OF-014
Dry
Dry
OF-024
r r
>100%
7.33
73
7.70
OF-026
ND
ND
I
>100%
1 7.571
2490
8.00
OF-027
ND
r
>100%
7.67
160
8.20
OF-030
ND
ND
>100%
7.6
112
8.30
Stream-1
3.2
>100%
7.48
147
8.00
Stream-2
BRL
>100%
7.6
134
8.20
Stream-3
4.8
>100%
7.65
147
7.90
Stream-4
12.0
>100%
7.09
139
7.50
Stream-5
BRL
>100%
7.02
69
7.70
Stream-6
23.01
1
>100%
1 7.441
112
7.80
Stream-7
BRL
>100%
7.76
168
7.70
Stream-8
5.4
>100%
7.36
89
8.20
Stream-9
BRL
>100%°
7.69
138
8.20
Stream-10
8> owl
>100%
7.2
112
8.20
Stream-11
7.1
>100%
7.84
142
8.00
2/23/2006
OF-004
ND
ND
NS
>100%
OF-006
ND
ND
NS
>100%
OF-014
Dry
Dry
Dry
OF-024
ND
ND
NS
>100%
OF-026
ND
ND
NS
>100%
OF-027
ND
ND
NS
>100%
OF-030
ND
ND
NS
>100%
Stream-1
7.1
>100%
Stream-2
5.0
>100%
Stream-3
4.4
>100%
Stream-4
1 4.81
1
1>100%
Sheet of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than kMMMMMMMpqw ; 'mg/I
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
u E
c o m
w m E
O
o
o
= E
c m
^' n E
o
CI
a
c
E
y
m N
O o
m m
U
O
'm
a
o
q N
a
H
p
c
a
o
=
c
O Z
E v
E
Q
o
J
t
a
y N
Q v
n
?\
a 7
O
u
c
w
v m
p1 E
>
O
0
z
3
H
Date
Sample
Stream-5
BRL
>100%
Stream-6
6.0
>100%
Stream-7
3.9
>100%
Stream-8
9.6
>100%
Stream-9
4.9
>100%
1re1m-10
14.0
>100%
Stream-11
6.9
>100%
4/1/2006
OF-004
ND
ND
NS
I
>100%
OF-006
ND
ND
NS
>100%
OF-014
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
OF-024
ND
ND
NS
>100%
OF-026
ND
ND
NS
>100%
OF-027
ND
ND
NS
>100%
OF-030
ND
ND
NS
>100%
Stream-1
4.3
>100%
Stream-2
3.61
1
>100%
Stream-3
8.1
>100%
Stream-4
7.7
>100%
Stream-5
8.5
>100%
Stream-6
7.7
>100%
Stream-7
7.2
>100%
Stream-8
22.0
>100%
Stream-9
7.2
>100%
Stream-10
8.91
1
>100%
Stream-11
8.7
>100%
7 19 2006
OF-004
<2.0
8.33
<.10
OF-006
9.6
68.7
0.124
OF-024
10.2
14.3
NA
OF-026
12.2
10
NA
OF-027
12.3
11.7
0.553
OF-030
<2
<S
0.132
Stream-1
I
1
1 6.931
69
1 77.2
Stream-2
6.97
8.7
181
Stream-3
7.07
9.4
48
Stream-4
6.83
9.6
27.8
Stream-5
6.78
7.1
123
Stream-6
6.75
10.2
23.5
Stream-7
6.3
8.6
26.7
Stream-8
6.4
6.9
63.2
Stream-9
1
1 6.441
7.11
1 142
Sheet 10 of 30

STORMWATER ANALYTICAL RESULTS
rr r
glycol greater thanw
1 M30TTOR
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
D.O. lessthan 5.00 mg/I
Parameter
0
.�
> E
w o
c m
w m E
t
-
o
.-�
G
> E
°' o
c m
``m, E
c
-
a
c
m
E
a _
E
> vi
O
V m
o
'm
G
W
c �^
N
0
a
°
z �i
E-
y
V
c
u ry
_
i
E
>
O
E?
N-
}
Y
:o
i-
r
Date
Sample
Stream-10
6.47
8.8
123
Stream-11
6.74
18.2
8.78
9 13 2006
OF-004
2.4
26
<.0100
OF-006
2.8
12.5
<.0100
OF-014
3.8
7
<.0100
OF-024
<2.0
6
NA
OF-026
<2.0
12
NA
OF-027
<2.0
<5.0
<.0100
OF-030
<2.0
10.3
NA
Stream-1
6.72
0.19
5.40
184
Stream-2
6.71
0.072
5.60
246
Stream-3
6.52
0.088
5.30
35.8
Stream-4
6.46
0.096
5.40
28.1
Stream-5
6.681
0.068
6.201
117
Stream-6
6.38
0.093
5.70
93
Stream-7
6.88
0.078
7.00
29.2
Stream-8
6.61
0.036
5.10
53
Stream-9
6.77
0.047
5.30
148
Stream-10
6.71
0.076
6.00
49.8
Stream-11
6.79
0.052
6.30
224
10/27/2006
OF-004
7.4
ND
>100%
OF-006
ND
ND
>100%
OF-014
>100%
OF-024
7.8
ND
I
I
>100%
OF-026
6.1
ND
100
OF-027
ND
ND
>100%
OF-030
6.4
ND
>100%
Stream-1
4.5
>100%
6.71
0.061
10.00
158
Stream-2
ffll�
>100%
6.6
0.137
10.60
736
Stream-3
2.3
>100%
1 6.681
0.294
10.301
37.7
Stream-4
3.5
>100%
6.54
0.087
9.50
38.6
Stream-5
2.51
1
>100%
6.56
0.078
10.00
58.8
Stream-6
<2
>100%
6.7
0.117
11.00
31.4
Stream-7
4.5
>100%
6.59
0.315
10.20
53.2
Stream-8
6.4
>100%
8.11
0.056
11.50
22.9
Stream-9
5.2
>100%
6.92
0.178
10.50
46.4
Stream-10
21.9
>100%
6.87
0.09
10.20
31.4
Stream-11
<2
>100%
7.18
0.167
12.20
9.18
it 7 2006
OF-004
ND
ND
7.6
12
<.10
>100Ji
OF-006
ND
ND
5.0
76
<.10
>100
Sheet 11 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' -- . 'mg/I
BOD ereaterthan I 9M, IBOD-5
D.O. less than 5.00 =
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
.�
O«
., E
w o
t
O
o
,.
V^
> E
w `o
E
c
O
a
c
A
E
c
m E
O D
�m
o
o
is
-O
N
,�,
n
c
c
m
o
,�, Z
'z ,.;,
=
c Z
E:
E
o
o�
v t
v
Q^�
_
Y
Z E
v
c n
u
c
x
o
d E
>
N
c
:o
Z
~
Date
Sample
OF-014
ND
ND
3.9
27.5
<.10
>100
OF-024
ND
ND
16.5
<5.0
<.10
>100
OF-026
ND
ND
2.1
<5.0
<.10
>100
OF-027
ND
ND
3.1
5.67
<.10
>100
OF-030
6.3
9.1
<2.0
17
<.10
>100
Stream-1
4.2
>100
6.52
0.077
9.70
20.3
Stream-2
7.8
>100
6.44
0.126
10.20
204
Stream-3
2.61
1
>100 1
6.331
0.088
9.901
15.3
Stream-4
2.9
>100
6.45
0.068
11.20
17.3
Stream-5
5.6
>100
6.73
0.085
11.90
40.2
Stream-6
4.1
>100
6.3
0.067
11.70
118
Stream-7
10.1
>100
6.5
0.037
10.60
59.2
Stream-8
5.6
>100
6.15
0.242
10.30
103
Stream-9
4.6
>100
6.33
0.084
10.20
52.4
Stream-10
9.4
>100
6.72
0.048
9.70
16.4
Stream-11
9.7
1
>100
1 6.531
0.089
10.001
49.6
11/22/2006
OF-004
ND
5.3
NS
OF-006
ND
ND
NS
OF-014
ND
ND
OF-024
ND
12.0
NS
OF-026
ND
ND
NS
OF-027
ND
8.1
NS
OF-030
ND
ND
NS
Stream-1
1
1 4.5
1
NS
1 6.31
0.173
12.401
117
Stream-2
10.4
NS
6.34
0.078
13.60
3130
Stream-3
2.1
NS
6.18
0.078
12.50
201
Stream-4
10.8
NS
6.14
0.65
12.70
127
Stream-5
3.3
NS
6.2
0.082
13.20
234
Stream-6
<2.0
NS
5.95
0.186
14.70
129
Stream-7
4.5
NS
5.89
0.2
20.40
63.9
Stream-8
2.2
NS
5.84
0.321
14.40
38.1
Stream-
1
4.31
1
NS
1 6.141
0.302
18.501
219
Stream-10
MCI
NS
6.15
0.08
13.30
34.3
Stream-11
<2.0
NS
6.18
0.378
13.60
157
1/1/2007
OF-004
ND
ND
>100%
OF-006
ND
ND
>100%
OF-014
ND
ND
>100%
OF-024
ND
ND
>100%
OF-026
ND
ND
>100%
OF-027
ND
ND
>100%
Sheet 12 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' 'mg/I
BOD ereaterthan
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
o f
w `o 00
w m E
t c
w
o
o «_
= E
v o
C 00
01 m E
>, ..
o c
d
_
9
C
E
d _
o
m E
N
O o
m m
.E
C
-m
v
o
jn
Vl
n r
v�i
m
0
c
Z
? �,
"=
c Z
E
Q
=�
o�
v t
v
_
u n'
<
T-
'
>
E
V
,
c
c
V
c
o \^
00
0 E
>
O
N
Q
L
:o Z)
Z
3-
Date
Sample
OF-030
ND
ND
>100%
Stream-1
2.1
>100%
7.2
0.085
12.50
27.7
Stream-2
2.5
>100%
7.25
0.373
10.70
4660
Stream-3
4.9
>100%
7.24
0.16
9.90
271
Stream-4
4.8
>100°%
7.03
0.096
9.40
193
Stream-5
EM.
>100%
7.27
0.195
15.30
169
Stream-6
4.7
>100%
6.96
0.116
9.40
391
Stream-7
4.81
1
>100% 1
7.061
0.136
9.901
40.2
Stream-8
6.5
>100%°
6.9
0.068
9.10
31.8
Stream-9
5.4
>100%
6.96
0.329
8.90
60.8
Stream-10
5.8
>100%
7.02
0.458
12.00
41.5
Stream-11
5.2
>100%
6.97
0.079
11.70
75
1/5/2007
OF-004
ND
ND
>100%
OF-006
ND
ND
>100%
OF-014
ND
ND
>100%
OF-024
ND
19.6
>100%
OF-026
ND
ND
>100%
OF-027
ND
ND
>100%
OF-030
ND
ND
>100%
Stream-1
2.0
>100%°
7.08
0.083
11.60
45.6
Stream-2
7.9
>100%
6.95
0.246
10.40
1315
Stream-3
2.0
>100%
7.06
0.07
10.60
96
Stream-4
2.6
>100%
7.14
0.087
10.10
238
Stream-5
7.51
1
>100%
1 7.081
0.08
9.901
130
Stream-6
2.9
>100%
7.03
0.087
10.60
698
Stream-7
3.0
>100%
6.9
0.068
9.60
112
Stream-8
4.4
>100%
6.97
0.104
9.60
94
Stream-9
4.1
>100%
6.94
0.122
9.60
145
Stream-10
i> (
>100%
7.11
0.134
9.80
47.4
Stream-11
6.1
>100%
7.07
0.202
10.60
179
1/18/2007
OF-004
r
r r
OF-006
ND
ND
OF-014
INS
NS
OF-024
19.9
OF-026
ND
7.1
OF-027
15.6
56.2
OF-030
ND
ND
Stream-
1
<2.0
6.83
0.099
12.50
32.6
Stre2m-2
3.1
6.52
0.152
13.00
1580
Stream-3
<2.0
1
1
1
1 6.481
0.1131
12.401
63.6
Sheet 13 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' ... 'mg/I
BOD greaterthan I EM .IBOD-5
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
�4 E
w o
w E
t .�
O
o
o
i. E
m o
2 n E
O. .�
0
U
c
E
u
o
e010 E
p p
N m
V _
o
'm
v
o
"'
v,
a t`.
N
0
r
c
m
o
Z
2 ,.;
.E z
?
E
4
«
o
y N
_
,E,
0
V
c
a
O
c
a S
�-
Date
Sample
Stream-4
-.`,.C'
6.55
0.167
12.50
40.4
Stream-5
3.2
6.45
0.097
13.70
43
Stream-6
5.7
6.8
0.185
13.70
64.8
Streann-7
MIT
7.33
0.179
13.00
129
Stream-8
<2.0
6.96
0.285
11.50
11.9
Stream-9
<2.0
7.7
0.286
16.30
13.1
Stream-10
. awl
6.62
0.136
13.60
9.85
Stream-11
<2.0
1
1 7.54
0.154
18.401
11.7
1/22/2007
OF-004
50.7
84.7
>100%
OF-006
ND
ND
>100%
OF-014
ND
ND
>100%
OF-024
r
>100%
OF-026
ND
ND
>100%
OF-027
27.2
Lr r
>100%
OF-030
IND
ND
I
>100%
Stream-1
<2.0
>100%
8.14
0.126
13.30
26.7
Stream-2
20.2
>100%
6.52
0.08
13.40
140
Stream-3
26.4
>100%
6.34
0.084
13.20
152
Stream-4
24.6
>100%
6.32
0.088
13.30
125
Stream-5
24.0
>100%
6.29
0.091
13.20
137
Stream-6
22.8
>100%
8.59
0.146
13.60
140
Stream-7
2.1
>100%°
6.19
0.119
12.50
31.9
Stream-8
28.4
1
>100%
1 5.861
0.054
12.701
16.4
Stream-9
5.7
>100%
6.32
0.104
13.10
37.9
Stream-10
MCI
>100%
6.37
0.119
12.70
25.1
Stream-11
17.7
>100%
6.37
0.114
13.80
38.2
2/1/2007
OF-004
0.54
OF-006
ND
ND
>100%
OF-014
INS
INS
NS
OF-024
ND
ND
>100%
OF-026
ND
ND
1
0.83
OF-027
ND
ND
>100%
OF-030
ND
ND
>100%
Stream-1
<2.0
>100%
6.63
0.207
12.30
20
Stream-2
11.4
>100%
6.57
0.147
13.10
126
Stream-3
_�;#: '���
>100%
7.21
0.356
14.00
22.4
Stream-4
I
>100%
6.65
0.165
15.50
32
Stream-5
<2.0
>100%
6.64
0.134
14.80
21.1
Stream-6
<2.0
>100%
6.51
0.191
15.10
25.2
Stream-7
5.9
>100%
6.85
0.693
16.30
71
Sheet 14 Df 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' - - 'mg/1
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
E E
m
tww mC Eaa
o
ti
o
> E
c m
2 E
O
a
c
n
E
u
c
>
0
0
N0
. .
'm
v
G
9
Ri
0
m
0
m
E
aao
F
U
Q
U
y
>
o
-Z0
H..-
Date
Sample
Stream-8
<2.0
>100%
6.24
0.118
12.40
15.3
Stream-9
<2.0
>100%
6.55
0.178
14.30
14.8
Stream-10
15.0
>100%
6.44
0.102
13.60
5.87
Stream-11
<2.0
>100%
6.82
0.164
16.60
6.98
2/14/2007
OF-004
ND
ND
>100%
OF-006 IND
ND
>100%
OF-014
ND
ND
>100%
OF-024
ND
ND
>100%
OF-026
ND
ND
>100%
OF-027
ND
ND
>100%
OF-030
ND
ND
>100%
Stream-1
<2.0
>100%
6.4
0.107
12.30
16.4
Stream-2
<2.0
>100%
6.32
0.079
12.30
362
Stream-3
2.7
>100%
6.42
0.116
13.90
516
Stream-4
2.1
>100%
6.59
0.08
13.10
354
Stream-5
<2.0
1
1
>100%
1 6.391
0.164
12.80
340
Stream-6
<2.0
>100%
6.43
0.012
13.70
336
Stream-7
3.1
>100%
4.92
0.114
13.50
69.6
Stream-8
6.0
>100%
6.8
0.108
15.20
40.4
Stream-9
5.0
>100%
6.32
0.273
14.50
69
Stream-10
<2.0
>100%
6.51
0.358
13.80
47.4
Stream-11
1
<2.0
>100%
6.37
0.352
14.001
124
2/26/2007
OF-004
ND
ND
>100°%
OF-006
NS
NS
I
NS
OF-014
ND
ND
>100%
OF-024
ND
ND
>100%
OF-026
ND
ND
>100%
OF-027
ND
ND
>100%
OF-030
IND
ND
>100%
Stream-1
<2.0
>100%
6.49
0.093
10.601
13.87
Stream-2
<2.0
>100%
6.36
0.104
9.90
116
Stream-3
<2.0
1
>100%
6.34
0.118
11.00
125
Stream-4
<2.0
>100%
6.44
0.12
10.90
73.2
Stream-5
<2.0
>100%
6.32
0.087
10.00
87.1
Stream-6
<2.0
>100%
6.77
0.254
11.30
70.4
Stream-7
2.2
>100%
5.78
0.156
10.20
30.1
Stream-8
1
3.3
>100%
5.98
0.077
10.80
23.9
Stream-9
<2.0
>100%
6.64
0.256
11.40
26.3
Stream-10
<2.0
>100%
6.46
0.088
10.20
23.7
Stream-11
<2.0
1
1
1>100%
1 6171
0.1091
11,101
35
Sheet 15 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' .. _ 'mg/I
BCD ¢reater than
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
O
m
w ra E
t C
o
O
c Y m
w m E
y
0 C
Ci
9
C
N
E
_
vi
O o
V (C
a
is
m
N
m
o
v
.0 z
E V
E
a
v
V
Q .r
V V
N
~
Date
Sample
3/2/2007
OF-004
ND
ND
>100%
OF-006
ND
ND
>100%
OF-014
ND
ND
>100%
OF-024
ND
ND
>100%
OF-026
ND
ND
>100%
OF-027
IND
ND
>100%
OF-030
ND
ND
>100%
Stream-1
<2.0
1
1
>100%
1 5.881
0.233
9.701
50.8
Stream-2
3.8
>100%
6.05
0.062
10.30
428
Stream-3
3.9
>100%
6.13
0.064
10.00
450
Stream-4
3.9
>100%
6
0.058
10.00
442
Stream-5
3.2
>100%
6.16
0.06
9.30
436
Stream-6
2.3
>100%
5.91
0.065
9.40
507
Stream-7
3.6
>100%
5.47
0.048
9.20
106
Stream-8
4.2
>100%
5.93
0.032
9.90
42.2
Stream-9
8.01
1
>100%
1 5.761
0.058
9.501
131
Stream-10
5.7
>100%
5.87
0.058
9.70
223
Stream-11
6.3
>100%
5.94
0.13
9.90
164
3/16/2007
OF-004
OF-006
OF-014
OF-024
OF-026
OF-027
OF-030
Stream-1
6.23
0.102
8.70
Stream-2
6.89
0.076
11.60
Stream-3
6.37
0.077
9.70
Stream-4
1
6.3
0.109
9.80
Stream-5
6.2
0.231
10.70
Stream-6
6.24
0.087
10.30
Stream-7
1 5.491
0.058
9.20
Stream-8
6.47
0.059
10.40
Stream-9
5.97
0.069
9.70
Stream-10
6.35
0.088
11.10
Stream-11
6.09
0.094
10.30
3/29/2007
OF-004
ND
ND
OF-006
INS
NS
OF-014
IN
ND
OF-024
ND
ND
Sheet 16 of 30

glycol greater than
STORMWATER ANALYTICAL RESULTS
BOD areaterthan I KM IBOD-5
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
w o
c. m
a n E
t c
O
o
21
v o
c m
2 m E
°
O
9
C
E
m E
x
O o
m
°
°
'm
N
v
�n
n r
A
o
f
c
2 M
.� z
E
E
<
o
« a
<
_�
c n
u
c
O
> E
_N
a
v D
?
Date
Sample
OF-026
ND
ND
OF-027
ND
ND
OF-030
ND
ND
Stream-1
3.6
6.41
0.072
10.60
15.84
Stream-2
2.9
6.4
0.144
8.80
64.4
Stream-3
3.5
6.38
0.109
7.60
36.5
Stream-4
4.8
6.31
0.085
7.60
39.4
Stream-5
3.81
1
1 6.221
0.11
8.60
54
Stream-6
3.1
6.23
0.12
7.50
52.8
Stream-7
15.7
5.7
0.094
7.50
119
Stream-8
2.9
6.09
0.112
7.10
11.28
Stream-9
2.5
6.16
0.102
8.40
20
Stream-10
7.2
6.09
0.147
8.30
64
Stream-11
3.5
6.22
0.103
8.401
25.6
6 25 2007
OF-004
6.1
NR
<.0100
OF-006
5.8
NR
<0.100
OF-024
6.5
<5.0
NR
OF-026
6.4
<5.0
NR
OF-027
5.7
NR
<0.100
OF-030
6.8
NR
<0.100
Stream-1
6.89
0.088
3.4
Stream-2
6.64
0.0931
10
Stream-3
6.67
0.112
14.2
Stream-4
1
1
6.56
0.091
15.2
Stream-5
6.73
0.084
17.3
Stream-6
6.56
0.091
106
Stream-7
6.85
0.181
6.8
Stream-8
6.41
0.077
12.2
Stream-9
6.46
0.095
14.4
Stream-10
6.521
0.095
1 8.9
Stream-11
6.56
0.183
21.2
9 14 2007
OF-004
4.41
7.8
<0.100
OF-006
5.7
428.0
<0.100
OF-014
OF-024
OF-026
19.8
238.0
NR
OF-027
4.4
81.0
0.128
OF-030
7.2
99..001
0.347
Stream-1
-
6.76
0.125
6.83
35.00
Stream-2
7.21
0.069
7.73
1130
Sheet 17 of 30

glycol greater than
STORMWATER ANALYTICAL RESULTS
.OD
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
u E
m `0_ c
a+ m E
t C
O
-
o
>.E
w `g c
� y E
a C
0
a`
U
-
O
C
E
o�
°° E
O a
A,
U _
'en
a
o
'm
v
c
a
N
m
o
0
0
z .%,
.E Z
O v
E
E
Q
�-
o
« a
V N
Q V
a
Z
i
O
u
%
c
> E
N
p
a
Z
Date
Sample
Stream-3
7.16
0.093
7.64
18.70
Stream-4
6.76
0.084
6.81
126
Stream-5
6.61
0.082
6.95
175
Stream-6
6.79
0.267
7.61
610
Stream-7
7.03
0.312
4.40
65.2
Stream-8
6.80
0.067
6.78
148
Stream-9
6.90
0.062
7.27
636
Stream-10
1
1 7.041
0.075
7.06
128
Stream-11
7.53
0.236
8.88
30.10
11/15/2007
OF-004
BQL
BQL
4.6
<5.0
<0.100
>0.100
OF-006
BQL
BQL
4.3
10.7
<0.100
>0.100
OF-014
BQL
BQL
3.5
<5.0
<0.100
>0.100
OF-024
BQL
BQL
2.5
<5.0
>0.100
OF-026
BQL
BQL
4.5
<5.0
>0.100
OF-027
BQL
BQL
3.0
31
0.279
>0.100
OF-030
INS
INS
INS
INS
INS
INS
Stream-1
2.3
>0.100
6.95
0.124
10.76
45.81
Stream-2
3.3
>0.100
6.96
-0.080
10.33
106.0
Stream-3
2.4
>0.100
6.85
0.139
12.05
26.72
Stream-4
12.0
>0.100
6.88
0.121
10.03
70.12
5tream-5
4.2
>0.100
6.40
0.920
8.79
54.13
Stream-6
5.4
>0.100
6.18
0.142
6.52
74.33
Stream-7
4.5
>0.100
5.99
0.099
10,001
31.93
Stream-8
5.3
>0.100
1 6.921
0.177
9.85
26.29
Stream-9
3.8
>0.100
6.71
0.134
10.23
98.88
Stream-10
4.1
>0.100
6.71
0.123
9.51
12.31
Stream-11
4.0
>0.100
6.50
0.117
9.41
72.01
11/22/2007
OF-004
<10.0
<10.0
>100%
OF-006
<10.0
<10.0
>100%
OF-014
<10.0
<10.0
>100%
OF-024
<10.0
<10.0
>100%
OF-026
<10.0
<10.0
I
I
>100%
OF-027
<10.0
<10.0W3.4
>100%
OF-030
INS
NSINS
Stream-1
>100%
6.53
0.071
10.24
18.87
Stream-2
>100%
6.41
0.106
8.64
29.78
Stream-3
>100%
6.40
0.085
9.22
22.97
Stream-4
>100%
6.46
0.191
7.92
44.73
Stream-5
>100%
6.21
0.093
8.38
22.36
Stream-6
>100%
6.26
0.396
7.891
62.20
Sheet 18 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than _ 'mg/I
BOD ereaterthan
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
m g
L C
Cr
o
..
o _
w `g c
>. ..
C
7
v
c
n
E
w _
m E
O o
y CI
2
o
'm
6
�n
VI
p
c
w
E
2
E`
E
Q
o
v
V
¢ v
E
7
u
c
O
>
N
o
v D
H
Date
Sample
Stream-7
8.6
>100%
6.07
0.095
8.10
13.19
Stream-8
3.6
>100%
6.24
0.082
7.09
29.70
Stream-9
3.6
>100%
6.22
0.103
9.06
15.99
Stream-10
6.4
>100%
6.22
0.087
7.01
20.09
Stream-11
4.7
>100%
6.30
0.104
9.29
33.57
12/16/2007
OF-004
<10.0
<10.0
>100%
OF-006
<10.0
<10.0
>100%
OF-014
<10.0
<10.0
>100%
OF-024
<10.0
<10.0
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
<10.0
>100%
OF-030
<10.0
<10.0
>100%
Stream-1
2.4
>100%
6.36
0.118
10.81
7.30
Stream-2
2.3
>100%
6.501
0.133
11.50
65.65
Stream-3
8.3
>100%
6.09
0.107
9.56
50.08
Stream-4
3.6
1
>100%
6.16
0.103
10.77
70.16
Stream-5
2.2
>100%
6.32
0.106
10.55
24.37
Stream-6
4.3
>100%
6.18
0.182
10.76
92.26
Stream-7
8.3
>100%
6.15
0.112
9.52
31.72
Stream-8
3.6
>100%
6.49
0.038
10.74
27.91
Stream-9
3.9
>100%
6.28
0.091
12.471
27.33
Stream-10
2.6
>100%
1 6.371
0.276
11.23
9.69
Stream-11
3.9
>100%
6.26
0.131
11.96
35.43
12/21/2007
OF-004
<10.0
49.9
1
>100%
OF-006
<10.0
<10.0
>100%
OF-014
<10.0
<10.0
>100%
OF-024
<10.0
58.3
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
29.0
>100%
OF-030
NS
INS
INS
Stream-1
5.8
>100%
6.38
0.112
12.72
8.81
Stream-2
2.5
>100%
6.26
0.108
13.11
11.71
Stream-3
3.7
>100'%
6.27
0.091
12.90
12.80
Stream-4
5.1
>100%
6.28
0.108
12.14
12.11
Stream-5
13.3
>100%
6.70
0.039
11.90
18.14
Stream-6
13.9
>100%
6.24
0.131
12.391
22.47
Stream-7
2.9
>100%
6.25
0.077
11.171
21.09
Stream-8
20.5
>100%
6.56
0.103
13.99
12.79
Stream-9
2.8
>100Y°
6.33
0.118
13.136
12
26
1477Stream-10
D MR
>100%
6.48
0094
.
116
Sheet 19 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' ----
'mg/I
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
m E
O'
-
o
o
>c
C
U
-
a
c
m
E
w
C m
6
O
m
'co
o
o
'm
o
o
V'
a
a
o
c
m
•z
c
C
E
Jm
�
o
U
c
w
%
> �.E°...
°
c
r
H
ZE
Date
Sample
Stream-11
14.8
>100%
6.31
0.119
10.33
15.90
12/26/2007
OF-004
<10.0
<10.0
>100%
OF-006
<10.0
<10.0
>100%
OF-014
<10.0
<10.0
>100%
OF-024
<10.0
<10.0
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
<10.0
>100%
OF-030
<10.0
<10.0
>100%
Stream-1
3.3
>100%
6.34
0.260
12.47
14.92
Stream-2
3.7
>100%
6.41
0.314
12.15
90.82
Stream-3
<2.0
>100%
6.24
0.106
11.69
28.82
Stream-4
4.6
>100%
6.34
0.111
12.07
26.48
Stream-5
2.2
>100%
6.22
0.116
11.66
73.14
Stream-6
3.7
>100%
6.22
0.088
11.66
15.47
Stream-7
3.9
>100%
6.25
0.109
9.66
41.28
Stream-8
4.31
1
>100%
1 6.531
0.076
10.741
39.42
Stream-9
3.7
>100%
6.34
0.118
11.47
47.49
Stream-10
3.7
>100%
6.40
0.072
11.28
95.58
Stream-11
5.4
>100%
6.33
0.110
12.43
48.79
1/10/2008
OF-004
<10.0
<10.0
>100%
OF-006
<10.0
<10.0
>100%
OF-014
NS
NS
NS
OF-024
<10.0
<10.0
>100%
OF-026
<MO
<10.0
I
I
>100%
OF-027
<10.0
<10.0
>100%
OF-030
NS
NS
NS
Stream-1
7.8
>100%
6.02
0.091
8.22
47.37
Stream-2
4.7
>100%
5.98
0.102
9.54
91.22
Stream-3
4.7
>100%
5.99
0.100
8.001
31.97
Stream-4
4.7
>100%
5.95
0.106
9.53
69.92
Stream-5
<2.0
>100%
6.05
0.121
7.56
43.40
Stream-6
3.11
1
>100%
1 5.911
0.124
10.40
57.64
Stream-7
5.3
>100%
6.16
0.159
9.58
24.57
Stream-8
<2.0
>100%
6.17
0.129
9.54
16.14
Stream-9
3.4
>100%
6.28
0.240
10.53
19.20
Stream-10
10.6
>100%
7.20
0.135
9.32
44.87
Stream-11
1
2.8
>100%
6.18
0.237
11.20
15.41
1/17/2008
OF-004
27.5
r
>100%
OF-006
Q0.0
<10.0
>100%
OF-014
<10.0
<10.0
I
I
I
1>100%
Sheet 20 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' •- . 'mg/I
BOD zreaterthan I 9W IBOD-5
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
O
r
m o
m m E
L C
O
O
a o
I Z.
> ..
O C
O
9
C
10
E
m E
x ,ri
O o
tOi m
'En
°
o
'm
�,
m
a
N
7n
o
C
N
'z ;
=
c z
E
E
e
H
w t
v
y
G
_
�'
'� E
U
a
c
101
C
O
v o�
d E
> -.
N
p
'v
F
a z
�.
~
Date
Sample
OF-024
30.4
r r r
>100%
OF-026
<10.0
<10.0
>100%
OF-027
�
•:r r
>100°%
OF-030
<10.0
<10.0
>100%
Stream-1
<2.0
>100%
7.70
0.231
13.75
55.92
Stream-2
ml
>100%
6.82
0.267
16.36
294.40
Stream-3
9.7
>100%
6.68
0.328
15.62
34.99
Stream-4
Mv
I
>100%
7.481
0.419
15.52
59.84
Stream-5
�fficf
>100%
7.33
0.485
15.15
85.56
Stream-6
<2.0
>100%
6.67
0.115
12.14
23.75
Stream-7
4.0
>100%
6.47
0.184
17.72
97.75
Stream-8
3.2
>100%
6.97
0.056
16.66
75.15
Stream-9
2.4
>100%
7.30
1.753
15.83
21.88
Stream-10
1 i 0
>100%
7.28
0.363
13.071
30.53
Stream-11
<2.0
>100%
6.92
0.240
14.50
6.71
2/1/2008
OF-004
<10.0
24.6
1
>100%
OF-006
<10.0
<10.0
>100%
OF-014
<10.0
<10.0
>100%
OF-024
<10.0
<10.0
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
<10.0
>100%
OF-030
<10.0
<10.0
>100%
Stream-1
<2.0
>100%
5.89
0.352
14.02
47.42
Stream-2
5.11
1
>100%
5.88
0.075
10.75
401.9
Stream-3
7.1
>100%
5.78
0.118
13.40
106.6
Stream-4
6.8
>100%
5.82
0.148
14.13
186.1
Stream-5
5.9
>100%
6.17
0.107
13.71
110.2
Stream-6
7.2
>100%
5.77
0.112
12.22
178.2
Stream-7
2.2
>100%
6.17
0.375
15.68
49.70
Stream-8
6.5
>100%
1 6.111
0.088
15.721
43.07
Stream-9
3.6
>100%
6.04
0.080
15.63
119.9
Stream-10
20.71
1
>100%
6.16
0.780
16.26
106.1
Stream-11
9.4
>100%
6.24
0.136
16.70
146.5
3/5/2008
OF-004
BQL
BQL
>100%
OF-006
BQL
BQL
>100%
OF-014
BQL
BQL
>100%
OF-024
BQL
BQL
>100%
OF-026
BQL
BQL
>100%
OF-027
BQL
12.1
>100%
OF-030
NS
INS
INS
Sheet 21 of 30

glycol greater than
STORMWATER ANALYTICAL RESULTS
BOD ereaterthan I IEW IBOD-5
D.O. less than 5.00 mg/1
7-1
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
$ E
o m
w m E
r
0'
o
o
> E
c moo
v A E
n=
o
U
c
m
E
u
E
> ,,;
0 p
0
m
°
o
m
v
o
v'"i
o
o
r
<
u
`^
_
c z
E
Q
r J
5 N
u
n
o-
U
<
w
a
2
a D
-
r
Date
Sample
Stream-1
<2.0
>100%
6.12
0.116
8.08
43.9
Stream-2
<2.0
>100%
6.08
0.254
9.11
84.9
Stream-3
<2.0
>100%
6.23
0.088
8.67
162.2
Stream-4
<2.0
>100%
6.12
0.087
8.38
125.0
Stream-5
<2.0
>100%
6.03
0.074
7.27
114.1
Stream-6
<2.0
>100%
6.05
0.072
8.01
140.2
Stream-7
<2.0
>100%
5.87
0.125
5.78
96.2
Stream-8
4.61
1
>100%
1 5.951
0.051
7.761
24.7
Stream-9
3.3
>100%
5.95
0.079
10.53
30.8
Stream-10
2.2
>100%
5.91
0.071
11.63
130.1
Stream-11
3.3
>100%
5.99
0.091
11.49
43.9
3 8 2008
OF-004
BQL
BQL
4.1
10.5
1.35
>0.100
OF-006
BQL
BQL
2.9
7
0.24
>0.100
OF-014
BQL
BQL
3.8
22
<0.100
>0.100
OF-024
BQL
BQL
<2.0
<5.0
>0.100
OF-026
BQL
BQL
<2.0
<5.0
1
>0.100
OF-027
BQL
12.1
18.0
17.7
<0.100
>0.100
OF-030
NS
NS
NS
NS
NS
NS
Stream-1
<2.0
>0.100
6.12
0.116
8.08
43.85
Stream-2
<2.0
>0.100
6.08
0.254
9.11
84.91
Stream-3
<2.0
>0.100
6.23
0.088
8.67
162.2
Stream-4
<2.0
>0.100
6.12
0.087
8.38
125.0
Stream-5
<2.0
>0.100
6.03
0.074
7.27
114.1
Stream-6
<2.0
1
1
>0.100
1 6.051
0.072
8.011
140.2
Stream-7
<2.0
>0.100
5.871
0.125
5.78
96.15
Stream-8
4.6
>0.100
5.95
0.051
7.76
24.74
Stream-9
3.3
>0.100
5.95
0.079
10.53
30.84
Stream-10
2.2
>0.100
5.91
0.071
11.63
130.1
Stream-11
1
3.3
>0.100
5.99
0.091
11.49
43.91
8 26 2008
OF-004
3.6
9.0
<0.100
OF-006
No water
OF-014
No water
OF-024
4.0
17.0
NR
OF-026
6.8
7.0
NR
OF-027
2.2
14.6
<0.100
OF-030
1
4.2
24.0
0.232
-
Stream-1
INS
5.89
0.070
3.16
18.74
Stream-2
NS
6.09
0.140
4.42
24.65
Stream-3
NS
5.98
0.077
3.40
5.60
Stream-4
INS
5.48
0.0781
1.881
15.66
Sheet 22 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' - _ 'mg/I
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
J
u r° E
t
-
o
J
w m E
>._
-
a
c
A
E
c
x
O a
O
'm
o.
O
H
c
zZ
=
.c z
E
v
U-
Q
S
c i
u
c
x
>....
N
Z
��-
Date
Sample
Stream-5
NS
6.02
0.135
2.25
16.42
Stream-6
NS
6.41
0.163
2.81
17.03
Stream-7
NS
5.87
0.069
3.51
49.75
Stream-8
NS
6.56
0.197
3.48
17.04
Stream-9
NS
6.30
0.172
3.30
10.49
Stre2m-10
NS
6.01
0.215
3.88
10.66
Stream-11
NS
6.49
0.170
3.15
10.51
11 4 2008
OF-004
BQL
BQL
>100%°
OF-006
BQL
BQL
>100%
OF-014
NS
NS
NS
OF-024
BQL
BQL
>100%
OF-026
BQL
BQL
>100%
OF-027
BQL
BQL
>100%
OF-030
BQL
BQL
>100%
Stream-1
<2.0
>100%
6.41
0.0771
6.91
8.00
Stream-2
<2.0
1
>100%
6.44
0.078
5.15
54.11
Stream-3
<2.0
>100%
6.47
0.081
6.21
23.85
Stream-4
<2.0
>100%
6.28
0.083
6.55
14.26
Stream-5
<2.0
>100%
6.28
0.086
6.56
21.57
Stream-6
<2.0
>100%
6.41
0.172
6.38
13.57
Stream-7
3.5
>100%
6.41
0.164
7.55
67.01
Stream-8
3.5
>100%
6.56
0.178
7.491
11.38
Stream-9
<2.0
>100%
6.63
0.189
7.58
10.79
Stream-30
4.31
1
>100%
6.39
1.104
7.38
8.78
Stream-11
<2.0
>100%
6.83
0.201
7.35
9.64
11/13/2008
OF-004
<10.0
<10.0
>100%
OF-006
<10.0
<10.0
>100%
OF-014
<10.0
<10.0
>100%
OF-024
<10.0
<10.0
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
16.9
>100%
OF-030
<10.0
<10.0
>100%
Stream-1
1
<2.0
>100%
6.09
0.161
4.17
8.24
Stream-2
3.5
>100%
6.00
0.066
4.78
62.90
Stream-3
3.0
>100%
6.15
0.108
5.22
19.01
Stream-4
5.5
>100%
5.96
0.078
5.72
35.18
Stream-5
10.0
>100%
6.09
0.101
5.91
35.64
Stream-6
2.4
>100%
6.03
0.125
5.92
42.10
Stream-7
3.4
>100%
6.14
0.097
6.77
38.19
Stream-8
1 4.01
1
1>100%
1 6.271
0.2481
6.481
26.52
Sheet 23 of 30

glycol greater than
STORMWATER ANALYTICAL RESULTS
M
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
0. E
c o m°
w E
T y
s
o'
o
o r
E
m
2 c E
6
o
C
v
c
m
y
m
x `^
0 a
- O
u m
'en
o
O
'm
o
'�"
o. -
O
'^
m
c
F
ro
°
n "'
'c z
O •--.
E-
E
a
«
~ J
« v
J N
Q
c
i
O --'
u
y
x
-O °�
> E
O
O
a
f-
Date
Sample
Stream-9
3.2
>100%
6.26
0.089
6.84
27.13
Stream-10
2.1
>100%
6.29
0.069
6.13
14.80
Stream-11
3.9
>100%
6.25
0.073
6.01
35.32
11/25/2008
OF-004
<10.0
66.4
>100%
OF-006
<10.0
<10.0
>100%
OF-014
NS
INS
>100%
OF-024
44.7
>100%
OF-026
<10.0
<10.0
>100%OF-027
<10.0
' r r r
>100%
OF-030
INS
INS
>100%
Stream-1
2.4
>100%
6.56
0.064
7.59
13.33
Stream-2
<2.00
>100%
6.26
0.102
8.12
13.53
Stream-3
<2.00
>100%
6.40
0.074
9.46
43.22
Stream-4
17.3
>100%
6.24
0.112
9.82
36.96
Stream-5
IO
>100%
6.40
0.081
8.99
39.53
Stream-6
16.81
1
>100%
1 6.321
0.193
6.141
19.92
Stream-7
2.8
>100%
5.93
0.065
4.67
12.69
Stream-8
€M
>100%
5.94
0.161
5.52
16.43
Stream-9
5.3
>100%
6.15
0.094
6.92
11.32
(Stream-10
ME
>100%
6.17
0.111
7.11
16.99
Stream-11
11.4
>100%
6.23
0.128
8.08
16.35
11/30/2008
OF-004
BQL
BQL
OF-006
BQL
BQL
OF-014
BQL
BQL
OF-024
BQL
BQL
OF-026
BQL
BQL
OF-027
BQL
BQL
OF-030
BQL
BQL
Stream-1
1
5.1
-
5.75
0.081
8.61
19.29
Stream-2
10.8
5.87
0.048
9.13
246.10
Stream-3
8.1
5.89
0.071
9.16
123.40
Stream-4
5.81
1
1 5.941
0.236
8.72
101.40
Stream-5
8.7
6.05
0.043
8.85
72.63
Stream-6
8.1
5.94
0.022
8.23
133.00
Stream-7
5.3
5.97
0.044
5.43
40.21
Stream-8
6.2
6.23
0.031
6.87
53.88
Stream-9
7.1
6.00
0.076
7.12
46.33
Stream-10
9.9
6.06
0.068
7.89
110.20
Stream-11
6.2
6.13
0.026
8.31
63.58
12/11/2008
OF-004
<10.0
<10.0
>100%
Sheet 24 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' -- . 'mg/I
BOD ereaterthan I IEW IBOD-5
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
.y
_E
m `o
c m
w m E
t C
W j
o
i E
m o
c m
01 m E
a C
O
d J
a
c
A
E
c�
m E
vi
p p
N 0
m
'm
�
o
'^
,;,
q '^
n t✓
N
N
N
c
w
m
Z ,,:�
.E =
Z
E
E
o
uz
U
a
_
E
v i
V V
c
m
0
E
O V
n
N
:o
Z
f
Date
Sample
OF-006
<10.0
<10.0
>100%
OF-014
<10.0
<10.0
>100%
OF-024
<10.0
<10.0
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
<10.0
>100%
OF-030
<10.0
<10.0
>100%
Stream-1
<6.0
>100%
6.62
0.081
10.60
36.90
Stream-2
2.91
1
>100% 1
6.521
0.035
9.841
863.30
Stream-3
17.8
>100%°
6,441
0.084
10.41
232.20
Stream-4
2.4
>100%°
6.54
0.089
5.52
318.70
Stream-5
8.0
>100%
5.80
0.083
7.55
203.10
Stream-6
<6.0
>100%
6.21
0.528
8.01
269.30
Stream-7
<6.0
>100%
6.56
0.033
3.66
66.29
Stream-8
<6.0
>100%
6.26
0.283
5.83
77.86
Stream-9
<6.0
>100%
6.55
0.080
8.75
333.60
Stream-10
<6.0
1
1
>100%
6.25
0.760
7.521
87.45
Stream-11
<6.0
>100%
1 6.261
0.071
8.26
58.01
12/16/2008
OF-004
<10.0
<10.0
>100%
OF-006
<10.0
<10.0
>100%
OF-014
<10.0
<10.0
>100%
OF-024
<10.0
<10.0
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
<10.0
>100%
OF-030
<10.0
<10.0
I
>100%
Stream-1
<2
>100'%
6.44
0.081
4.53
19.55
Stream-2
3.0
>100%
1 6.021
0.068
6.25
82.78
Stream-3
3.5
>100%
6.01
0.089
6.36
43.10
Stream-4
4.7
>100%
6.02
0.082
6.25
28.07
Stream-5
18.9
>100%
6.11
0.086
8.42
35.57
Stream-6
4.4
>100%
5.94
0.233
8:17
29.53
Stream-7
2.4
>100%
6.27
0.083
8.62
46.30
Stream-8
<2
1
>100%
6.22
0.122
10.191
50.23
Stream-9
<2
>100%
6.67
0.084
7.79
20.79
Stream-10
6.4
>100%
1 6.281
0.184
7.44
54.40
Stream-11
4.7
>100%
6.27
0.144
7.17
28.96
1/4/2009
OF-004
1BQL
12.8
OF-006
BQL
BQL
OF-014
NS
NS
OF-024
BQL
GL1�iCi
OF-026
BQL
BQL
Sheet 25 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than cO l�w
BOD Rreaterthan I EM IBOD-5
D.O. less than 5.00 =
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
. o
E
d
-
0
7o
0
C
-
c
E
xE
m m
C
o
'm
a
o
c
Z
Eo
Q
15
o
VGE
c
x
N
`Em.
°
o
t-
'vY �ZO
Date
Sample
OF-027
BQL
OF-030
BQL
BQL
Stream-1
*
6.27
0.075
7.97
8.14
Stream-2
*
6.24
0.057
8.36
23.58
Stream-3
*
6.14
0.125
10.49
21.31
Stream-4
*
6.15
0.127
7.53
23.54
Stream-5
*
6.08
0.111
7.68
19.26
Stream-6
1 6,211
0.045
9.54
22.28
Stream-7
*
5.85
0.097
4.90
14.51
Stream-8
*
6.13
0.076
6.63
21.34
Stream-9
*
6.11
0.115
8.15
16.57
Stream-10
*
6.14
0.085
7.93
12.54
Stream-11
*
6.21
0.107
8.64
19.34
1/27/2009
OF-004
<10.0
36.0
>100%
OF-006
<10.0
<10.0
>100%
OF-014
NS
NS
NS
OF-024
<10.0
67.4
>100%
OF-026
<10.0
<10.0
72.62%
OF-027
<10.0
84.7
>100%
OF-030
<10.0
<10.0
>100%
Stream-1
1
2.4
>100%°
5.89
0.108
10.10
18.82
Stream-2
3.9
>100%
7.15
0.343
11.57
119.60
Stream-3
27.6
>100%
7.16
0.925
12.27
34.21
Stream-4
27.01
1
70.71%j
7.011
1.270
10.92
35.33
Stream-5
2.1
>100%
6.47
0.084
14.13
30.97
Stream-6
2.5
>100%
5.58
0.143
7.74
103.50
Stream-7
2.6
>100%
7.32
0.295
13.00
43.78
Stream-8
10.1
>100%
6.74
0.146
10.46
42.65
Stream-9
2.6
>100%
7.23
0.367
12.181
33.21
Stream-lo
�@M
>100%
6.49
0.103
11.83
20.23
Stream-11
18.2
>100%
7.23
0.932
11.93
36.56
2/3/2009
OF-004
<10.0
10.6
1
1
>100%
OF-006
NS
NS
NS
OF-014
NS
NS
NS
OF-024
<10.0
19.1
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
12.6
>100%
OF-030
NS
NS
NS
Stream-1
<2
>100%
6.42
0.097
16.32
10.91
Stream-2
4.71
1
1>100%
1 6.611
0.611
14.341
11.00
Sheet 26 of 30

glycol greater than
STORMWATER ANALYTICAL RESULTS
BOD ¢reaterthan I 1EM IBOD-5
D.O. less than 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
u E
w o
c m
w m E
t c
w
o
o "
>E
l7 -'
a o
c m
°1 m E
o c
d
9
C
E
a
0�
c 00
e010 E
> vi
p o
m
G
'm
o
a
c
a
i'n
_
0
o
Z ,:t
.E =
Z E
E
E
.Y
o
w t
y N
a
n
E
v i
O
u
w
x
O
E
V
.2
O
.�.
:o
3 z
H
Date
Sample
Stream-3
4.1
>100%
6.35
0.107
17.30
22.05
Stream-4
4.5
>100%
6.22
0.126
17.47
20.72
Stream-5
4.8
>100%
6.62
0.502
18.37
17.88
Stream-6
2.7
>100%
6.91
0.104
12.40
37.54
Stream-7
<2
>100%
6.33
0.128
9.30
11.62
Stream-8
3.2
>100%
6.72
0.084
12.40
15.69
Stream-9
<2
>100%
6.62
0.230
16.93
11.78
Stream-10
6.11
1
>100%
1 7.181
0.098
21.601
9.28
Stream-11
<2
>100%
7.23
0.107
16.68
14.04
2/12/2009
OF-004
<10.0
18.3
>100%
OF-006
<10.0
<10.0
>100%
OF-014
NS
NS
NS
OF-024
<10.0
54.7
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
<10.0
>100%
OF-030
<10.0
<10.0
I
I
>100%
Stream-1
2.5
>100%
7.01
0.127
4.66
9.78
Stream-2
2.1
>100%
6.93
0.092
5.99
15.46
Stream-3
2.4
>100%
6.74
0.102
5.22
22.76
Stream-4
3.6
>100%
6.87
0.104
5.02
20.06
Stream-5
2.9
>100%
6.93
0.178
4.031
29.07
Stream-6
3.8
>100%
7.11
0.189
4.55
26.76
Stream-7
<2
>100%
6.71
0.181
3.67
19.12
Stream-8
3.6
>100%6.84
0.107
3.91
16.49
Stream-9
2.2
>100%
7.06
0.187
4.33
14.61
Stream-10
10.7
>100%
6.92
0.102
4.39
13.54
Stream-11
5.6
>100%
7.02
0.114
4.67
19.51
2/18/2009
OF-004
<10.0
<10.0
>100%
OF-006
<10.0
<10.0
>100%
OF-014
<10.0
<10.0
>100%
OF-024
13.7
87.3
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
23.3
>100%
OF-030
Q0.0
<10.0
>100%
Stream-1
2.5
>100%
6.58
0.077
5.58
10.36
Stream-2
5.5
>100%
6.10
0.122
5.95
203.20
Stream-3
8.9
>100%
6.25
0.0951
6.101
117.60
Stream-4
8.0
>100%
6.35
0.105
6.15
87.92
Stream-5
7.3
>100%
6.60
0.250
5.65
104.60
Stream-6
1 4.81
1
1>100%
1 6.601
0.3131
5.791
145.40
Sheet 27 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' -__ . 'mg/I
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
m o
d E
>"
O
-
o �
a o
> E
n
O
-
a
0
m E
O
O
o
'm
0
c V
3
c
r
? M
0-
E-
o
o
ry
_
c Y
0-
u
X
O --.
E?
0
N
u
'v
r
Date
Sample
Stream-7
<2
>100%
6.60
0.382
5.75
34.72
Stream-8
5.9
>100%
7.03
0.055
5.90
28.32
Stream-9
3.8
>100%
6.68
0.094
6.40
33.04
Stream-10
6.2
>100%
6.75
0.102
6.75
42.25
Stream-11
4.3
>100%
6.66
0.094
7.10
60.75
3/2/2009
OF-004
L` `�• �
IMEMEM
>100%
OF-006
<10.0
<10.0
>100%
OF-014
<10.0
<10.0
>100%
OF-024
®'
JIMMERM
>100%
OF-026
<10.0
<10.0
>100%
OF-027
'r r
§§J§r r
>100%
OF-030
<10.0
<10.0
>100%
Stream-1
<2
>100%
6.36
0.146
6.20
22.72
Stream-2
'r: r
>100%
6.22
0.139
6.40
74.16
Stream-3
MCI
>100%
6.80
0.374
6.60
104.20
Stream-4
E
>100%
1 6.651
0.446
6.251
104.60
Stream-5
iffiMf
>100%
6.75
0.470
8.56
112.80
Stream-6
MCI
>100%
6.55
0.680
5.50
74.90
Stream-7
<6
>100%
6.75
0.756
6.55
49.55
Stream-8
- r
>100%
6.02
0.124
5.24
102.00
Stream-9
:i`r
>100%
6.60
0.759
5.56
35.41
Stream-10
MCI
>100%
6.30
0.357
6.74
88.56
Stream-11
r • r
>100%
6.76
1.014
6.44
66.50
3 14 2009
OF-004
BQL
18.7
>100%
OF-006
BQL
BQL
>100%
OF-014
BQL
BQL
>100%
OF-024
BQL
34.1
>100%
OF-026
BQL
BQL
>100%
OF-027
BQL
BQL
>100%
OF-030
BQL
BQL
>100%
Stream-1
4.7
>100%
6.17
0.114
7.80
14.77
Stream-2
M
I
I
>100%
1 6.301
0.066
8.911
158.7
Stream-3
7.3
>100%
8.67
0.230
8.04
53.00
Stream-4
7.3
>100%
6.30
0.206
8.36
64.13
Stream-5
12.3
>100%
6.72
0.364
6.70
51.88
Stream-6
22.6
>100%
6.64
0.272
7.54
69.97
Stream-7
<2.0
>100%
6.20
0.196
6.25
33.57
Stream-8
3.8
>100%
6.20
0.149
6.37
38.52
Stream-9
2.3
>100%°
6.13
0,291
6.59
45.50
Stream-10
5.21
1
1>100%
1 6.181
0.3451
7.801
75.90
Sheet 28 of 30

STORMWATER ANALYTICAL RESULTS
glycol greater than' -- _ 'mg/I
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
Parameter
0
E
a g
c e°
rm m E
W J
0
o
O
E
1 E
a+ q c
c m
°0.
E
e
n J
0'
c
m
E
a
m E
ui
�
00
2
2
'm
v_
c
c
n
10
o
H
c
m
'z ni
E
E
E
a
«
o
a
_
� E
�-
c
m
O'
°
�E
_
in
0
M D
a �z-
Date
Sample
Stream-11
2.9
>100%
6.241
0.595
8.55
43.86
3/26/2009
OF-004
<10.0
<10.0
>100%
OF-006
<10.0
<10.0
>100%
OF-014
OF-024
<10.0
<10.0
>100%
OF-026
<10.0
<10.0
>100%
OF-027
<10.0
<10.0
>100%
OF-030
<10.0
<10.0
>100%
Stream-1
<2
>100%
1 6.221
0.196
7.52
9.57
Stream-2
<2
>100%
6.08
0.091
9.30
27.33
Stream-3
<2
>100%
6.19
0.21
8.10
18.97
Stream-4
<2
>100%
6.09
0.094
7.72
18.19
Stream-5
<2
>100%
6.24
0.117
7.77
22.03
Stream-6
<2
>100%
6.00
0.107
7.95
14.10
Stream-7
<2
>100%
5.43
0.182
3.37
29.07
Stream-8
<2
1
1
>100%
5.81
0.11
4.88
22.66
Stream-9
2.6
>100%
5.941
0.112
7.28
9.35
Stream-10
<2
>100%
6.01
0.113
7.58
7.23
Stream-11
2.8
>100%
6.03
0.111
8.15
13.02
6/ 5 2009
OF-004
4.0
138
<0.10
OF-006
2.7
8.75
<0.10
OF-014
4.4
31.5
<0.10
OF-024
<2.00
5.0
NR
OF-026
<2.00
1 8.51
NR
OF-027
<2.00
7.0
<0.10
OF-030
<2.00
8.5
<0.10
Stream-1
6.36
0.076
2.93
43.82
Stream-2
6.09
0.031
2.351,100+
Stream-3
5.98
0.045
2.63
983.9
Stream-4
5.37
0.099
3.25
454.90
Stream-5
5.50
0.026
3.471
436.70
Stream-6
1
1
6.17
0.201
3.37
635.70
Stream-7
1 6.401
0.045
3.53
62.52
Stream-8
6.46
0.027
3.63
85.14
Stream-9
6.46
0.022
3.78
65.8
Stream-10
6.51
0.052
3.55
103.50
Stream-11
6.39
0.035
3.39
88.2
NOTES:
mg/I = milligrams per liter
Sheet 29 of 30

glycol greater than
STORMWATER ANALYTICAL RESULTS
BOD ereater than I 9 r s IBOD-5
D.O. lessthan 5.00 mg/I
Project Name: Piedmont Triad International Airport
ECS Project Number: 09.16399
v
c
O
O
A
v
_
o .
E
m _
o
c
w
c
u
E
v
Z
.o
'— E
Parameter
°p
m c—
m
N
z
O �v
5
m
c m
x vi
m in
m
2a
v m
a F-
w E
T m E
O a
a r
.c =
a t
v z
> E
Z
V
o
u
E
V
u
W
i?
.o
Q
Q
N
O
O
'm
o
Date Sample
BQL = Below Quantitation Limit
NS = Not Sampled (No discharge)
* Data not available due to laboratory quality control failure
Sheet 30 of 30

n
LJ

HORSEPEN / Old Battleground -- DO

23
'----�µ- 15
91
7
5
- 6f
{- 10
16
17.
-_ -_18
-� 20�0,
16°
7.33 7.6{
�-_-7.54
9.71 7.7
9.92; _7.38
v 12.21 7.42
10.96 7.34i
8.411 7.62i
8.721 7.39
i 7.21. 7.1
9.051 _ 7.14i-
- 7 2 --._
7.266 _ i
8.26 6.6Y
49i 100
� 5-1 481
_ 45
�37_-
42, 87
65 100
_ 461 1.40
_-_- 451 _39
- - 351 �- 90
49, 110
60 130i
46 1201
551 1101
10'
9.35 7.371
521 90�
_ 14
i
8.36 7.22iL.
-
28 _ 70
3
12 .38 7.28
50, 90
15
10.91 _ - 7.521
-� - yw4W-
-130
51
- -� 18
11.7 7.29
- 8.2`7.43.
8.97 7.53
_ 301 78
411 100
33; 40
20'
-
8.144,7.67
W 481 _ 110
_ 23i
_ 23!
8.81', w- 7.22
7.72 7.53
26 90
431 110
23
17'
7.69 7.47
8.93 7.15
50' 120
321! 90!
i 11�
9.91 7.25i
411 looll
6
3
-9
8.81-� 7.23�-�
12.2 7.371
10.23 6.81
451; -� 120i
421 _90!
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10
9.66 7.15
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10.12 7.44
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471 90i
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8.177.52
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-8.5 7.14
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- 53 100
31 60
j 71
10.28{ 7.31
431 80
_
7.12
_
21L- 50

61
10.92
7.13
2611 601
9
9.63
7.651
100!
11
9.3
7.48
37
10
81
8.51
17
8.7
7.33
7.09,
41 70
281 601
231
.46
7.43'1
80'
1
24
24i
7.68
7.711
C5
56! 110
251
7.77
7.43
7.
7.5
541100
531 -Tmm901
13
5,
8.92
10.64
7.7-
7.34
511 90
491 80
5
1075
7.27I
4 90
10.72
7.241
70
5
10.66'
7.16
-38;
5U 100
7
T8
12
7
I
... 8.7
8.38i
7.481
7.08!
5 D! 8
38i 80
7.49
551 1001
6
8-81
7.7
49! 100
20
7.3
7.18
701
231
6.9
7.01,
80
---16
13i
7.7
8.5
7.29
7.33
39 761
47 90
9.9
7.31
491 851
6
6
10.87
10.6
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7.05
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6
12
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9.4
9.3
7.25
7.28
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39, 10
43 80
181
20
8.3
6.081
7.04,
TE,
441 y 86
551 1001
24
5.93
7.15�.
go
22.4
19.7
18
6.64
_mm6.5
5.07
8.31
-i.'3"3
7.19
6.93
7.12
561 100
511 looll
11 oi
7
5
10.1
12.79i
7.05
6.86'
40 go!
Ti
13.31.
17.4
10.3
8.27
7.75
7.051
1.231
6.841
321 go!
471 1 M1

17.91 7.92
23.2 ! 6.21
7.63
7.95
_ 57F 160i
56 125'
-
23.4i 3.35
_ v� 7.73
53! 140
_
22.4!- - 6.651
6.92
221 80.
18.4 6.451
- --- 8.5 8.43
_6.93;
6.93!
41; 110;
-- -- - 1401
9.7; 7.811
11..8..,�. 7.1
,4.619.11i...,„,._.
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6.771
6.66
_ 6.69j
541 145
52! 120i
481 1201
6.8 11.2E
6.78i
- -
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10.1- ----
14.8c 6.31'
--5.961
7.4,
6.89
_
501-135i
-471
_
17
7.04
51� 158�
19, 81
j 22.51 6.5
7.14
7.19
451 122�
521 140
j 24.9j 5.95
'-- - 19.6 -- 6.85!
7.58
7.22
-- 56 - 1391
14.918.24;
8.41 10.77=
7.21
6.43
57, 131,
36! 122
µ2.8�- 12.71
6.56
35; ll8
_ -3.6 12.2-
-� 7.35
_ 45`; 1491
51 - 1601
9.7ai 9.57?
7.38
4.4[ 13.09��
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51 1443
r 12.Sj 10�
13.61 8.01
-_ 7.37
i - - 7.221
55 141�
-� 70 14
24.8 6.061
1 -- - �_.,1
_ 7.48
_
56! - 142�
-46
21.6,
21.6� 6.27E
7.42
132!
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----22.61 6.427.38.-
---7.54
_ __ _
45 i - 135
44 118
16.9! 7.4
7.36j
56 138
7.9, 10.3
7.15
45;' 118
7.31 10.84
7.35
431 110!
5.712.85
_8.3 9-92:
10.6 10.43
-_--
7.04
7.04
- - 7-43
45( 121'
511 145
50i 1371
14.7 9.24;
7.08
30 93�
17.2 7.571
7.12(-
-471 127
712
-56 137
--22.8v----6.43=
_.-__----19.81_ 6.811
236.
_ _7.2L-
� - 7.16�
_
-38i1041
561 143a

--------
_ 16.8
11.2_7.42
6.71--10.47`
-- -
F--m..-...._--
_ 7.79
-9.88
.-_ .,•.•.___1__
_ 7.13
T- 7.08
_ 6.98.-
,--- -`-.__........
36 1 1071
-_ -- -42� 133
- 42!---127�
50 135
_ - 5.6
11.6
6.86
32 _ 113
7.5:
-17.5
10.7;
'�- 6.58
341
10.4
7 .29
29-�133
1616.5
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- -8.51
_..5
6.84
1 ....w
--�95.7j
541 1311
.._.....__.. _,_
- --43i
��19.8`
Y 23.2,
23.1
_ 7.17!
6.97
5.37
7.06
-�� 7.02
6.83
r.
1p11
56` 138
35; 101
23.4
_1_6.2
6.58
-y6.39
--r
7.3
7.43
65' 141
_ 53 --u 122
-- - T---1
_ 611 1471
N.,-_......... 291
---
7.61
8.3
2 3
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9.14
7,
6.91
6.82!
55 1 7
-
_ 361 122�
52 153
4.2;
11.761
_
- 11.6
16.5
10.95j
- 6.05
_ 7.07
- 6.98
7.06
591 146
551 146
62I- 1691
20.8
18.7.
9.04
mM 6.21
6.98�
6.9- 911
61j --
50' 121
25.11
4.58
6.56
44; 1151
21.8
�18.7
5.74
7.48
6.88
7.09
461 103
37 --� 85
10.4
8.64
_ 7.79
62 1501
I 0.7
8.38
7.211
53 140,
4.9�
4.2
- 11.15+
12.151
7.44'
7.16
- 481 _ 138
--- 319
1 13.6
10.8
7.29
_- _46t
50� -163
14;
----_ 7.681
7.13
-_ 521 - 157
16
11.9(mm
_ _Y 7.911
_ 7.171
672
_
561 �m 141;
-_7.84
157
6.5�-
10.71
6.86i
451 131
_ 4.8';
3.9
10.951
+- 11.771
-�
6.87j
6.64
�-6.49
-
60
52 145,
10
9.73'
-11-49,
--_. _.
----- 48'; 152�
7.4
7.19
-�
- 49j �144;
13.9`
8.K
6.46�
50' 1361
_20.4
_,._. 61�
6.651
-� 55L_ �1

--21-Jun-011121.3
31-Jul-Ol
--
16-Aug-Olt
i 21-Sep-Olt,
r -_- 25-Oct-01 i
-_ 29-Nov-011
14-Dec-Ol{ i
29 Jan 02
25-Feb-02�
' 25-Mar-021
16-Apr-02
21
_
23.6
19.9
�- 17.21
15.9
-- 12.81
10.4
7.2j
6.77
-- 6.31-
-
5.37
4.95
1.93
8.82
7.12'
10.34
9.49
_ -_6.77
-- 6.83
6.98:
6.15i
- - 6.28
7.05
7.59--
-7.34
7.64
58i 152
35 102
L._.__
5_3; -mm 144
- _ _-38; 96
70 169
_72
54 129
_- 451 -- 142
0Tf� 153'
r 11.70
20.7
7.28
6.92
_
- 7,761
_ 7.22T-
_-
65i 156
57 139
11-Jul-021
22.6
7^161
43i 134!
r- --
29NAu�02! 1035
--
17.6
6.23j
5.49
_
20� 7
24-Se -02; 123
19.9;
5.57
7.271
_ _
58; 14 _t
_
10-Oct-021
7.251
7.241
1571
- R1451,
26-Nov-021 10511
-_M16.71
8.1i
8.831
6.851
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541 144i
' 09-De Oc 2 - 123?
4.71
11.3t
6.71
371 I601
1 02-Jan-03' 1031
27-Jan-03; 103
1.4
- 1.4
12.17
12.17
7.33
7.33
47'
47
i 24-Feb-031: 1042
6.7
10.43t
7.15
27-Mar-M
14.1
7.31
471
_1036
- 14-Apr-631� 106
- 14.31
_7.99
8.77
6.91
-- - 4�0�
19-May-03� 141
-
14.6�
_7.76
7.07
351 _
j 23-May-031
8.93
7.53
------ 64F 1481
r 05-Jun-03 ----v117
_13.41-
20.1�
6.28
6.89
45' _
_
-__ M_
-- 20-Jun-03I
11-Ju 0
�- _21-Jul-031 1254
-
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22.6
23 8
3.15
6.231
_.-,_ 5.7mm 5j�
7.34
7.16
7.33
_- 65!� 15111
4311 1341
5
._ - 71
19-Au -03
-16-Sep-03 -210
�_..23.2
21.1
6.24i
6.52
7.04
w 6.71
42
57�
14-Oct-03i_ _ 1308
0_4-Nov73� 1222
- 18.6'
-^ 15.61
--6.02
8.31
--Y 6.91
58i
_
11-Dec-031 1235
8.5;
9.49
_ �6.92
6.771
_
49
_ 02-Feb-044 120
-
2.7
- _- 11.12
7.1j
- 59
- 26-Feb-04i- - _ 916
23-Mar-041 139
22-Apr-Apr123
7.3
9.4
20.6
9.17.
9.681
5.68,-
_ 7.181
6.761
6.81j_-_
621:
56
57
---
-- ,
_.----_ _ _
--
17-May-04 138
21.3,
5.54r
6.9411
561
24-Jun-04i _ 1056
27-Jul-041 122
- 22.91
24
4.981
6.311
-- 6.91
6.52
58!
- 28

16-Aug-04; 100�
_ 20.6�
6.49
-� 7.01
-�
23-Sep-041 124
28-Oct-041 1222
13.4
16
7.18
5.43
7.01
6.9'
---7.21
52
- - -
30-Nov-04 121
11.4!
8.13
50
1 09-Dec-04 1112
16.8
7.86
7.28
T
- 57E
3 1 -Jan-051 135
6
_ - 11.3
6.74
m 49�
21-Feb-OS 1521
9.5
9.06
7.17�
- 7
55
01_Mar-05 158
7.6!
10.171
33,
-
j 21-Apr-OSj 1231
18.21,
7.85'
7.13
--_� 66
i 26-May_05! 116
- _.�_._._....103 23-Jun-O51; 3
17.8
21.1
10,381
7.17
-
_ 621
-- v
21 Jul-051 118'
26.2
4.09
7
45t
29-Aug-051 11421
23.1
4.91
7.08
57?
- _29-Sep05 203E
20.7
--
5.021
7.02
801
27-Oct-051 1100
9.81
7.061
591
10-Nov-05. 1134
_ -----
13-Dec-05 1.1441
15.3:
6.6
_7,95
- _ 5.25
9.56
6.99i
6.97
641
451
OS-Jan-06 1030-�
`- 9,
_
9.48
_- 7.03
46
21-Feb-06 1226
7.9'
9.33,
-- 6.83
_-- 53
27-Mar-06; - 11321
14.8
8.38
6.99
_-- 43
_+-- -------- --
I 27-Apr-061 _ 11421
1 1281
---
9.8
19.11
� 10.13E
5.781
- - -7.44�
7.421
_
-- -- 58,
561
25-May-06
-
15-Jun-06, 1033
20.51
6.49-
t 7.03'
40
27-Jul-06i 1059
-24.8:
5.681
7.251
461
31-Aug-0 6; 1129
- 20-Sep-06� 954
3]-Oct-061 _ 138
-28-Nov-06! - -1226
22.9
20.4�
mm14.5�-��7.Si-��-
7.06
6.996.99
-M
- _6.9711
7.2
7.36
�_ 39
_45
521
.-..--19-Dec-06?
� 9.3
9.88
v _7.3
_ 541
102
9.8;
9.84E
7.49
671
1_ 08-Jan-07l _ 1119,
J 22-Feb-07 1047;
_ - 11.81
10.41
9.59
-9.11
7.29
7.39
_- 38'
_
29-Mar-07 11121
mT -•-�--�1225:+�-
16.3
� 7.03
-7.48
58
u---���
j 26-Apr-07
20�--�-
6����-R•..12
7.39
59
-- -a
i 24-May-07 1111
18.8
6.11
7.39
-
- 71j
12-Jun-07i, 11241
I--
�
21.3
23.3
5.86:
-- 5.71E
7.56
�7_1
30-Jul-071, 11021--
7.15
_33
_ 28-Aug-071 1056
1 24-Sep-0 106
_ 24.2?
23.9
4.11
- 4.73i
7.32
- - -- 7.38
_701
-__ 70
29-Oct-07s 135;
_ --_ 13.5
_ - 8.73i
7.21�
40;

15-Nov-07; 134 13.7:1 8.331_ 7.48 60
11-Dec-07 - _ 1024 11 8.11: 7.32 _ 691
29-Jan-081 1055 5.6 10.79i __-- �7W45I _5.771
2� 5-Feb 08` 10 5!3 - 7.4 9.81 7.51; 52�
13-Mar-08i 1042 13.3 9.23 7.43 - 451
14-Apr-08j 10�121-m_12.3i- 8.41 7.53'
07-May-081 - 1018+ 18- 9. 6.831 7.08 -�
19-Jun-081! 1461 21 4.8 7.42 51
1-Jul-08 12381 24.6 4.2 736� 55
_ 12-Aug-081 1242, 20.8 4.581 7.481 59j
29-S2-08! 1056 19.1, 6.83r 7.61
1049 ^11.7 7.89 7.27 _ 6@
I _ 19-Nov-08! 1141I 5 13.16! 7.36 57;
r_-_ ......_.._ ,-
02-Dec-08 1225 6.41 13.03! 7.27 361
29-Jan-09* 1048; 12.41 11.941 Y 7.61 35
75812-Feb-09 084 521
09-Mar-091103 149 9.73 7.611 511
27Ar .. _-145 558__
6
7.71 _
!- 28-May-091 123 211 6.14 --7.5561 56!
! 17-Jun-091: 958 21.21 6.75 7.26 411
14-Jul-09; 110221.3 5.79 7.57 ____
25-Aup-09 11051 22.6 4.7 mm 7.44
-15-Se�09 11321
-12-Oct-09 11000�
_ 26.9
-� 16.7
6.141.
8.19
7.62
7.27
54
41
r 25-Nov-091 104
11.71
7.14
46
i 14-Dec-09 1039
5.%
_8.82
11.58�
-7.13
- 34
- 27-Jan-101165
_-
6;
11.99�
- -- -- 7.24
--- - 4.3
16-Feb-101 1113)
- - w3.4j-
_1_-_
12.37____�
7.41��
-36

wr %
Foground
Latitude
360 8' 19.69" N
:Horaepen Creek
Longitude
790 51' 35.34" W
Date
9/15/1999
12/10/1999
3/16/2000
6/18/2000
8/18/2000
12/16/2000
Time
8:20
17:00
16:20
19:20
16:50
8:09
Grab
Ammonia -Nitrogen
0.5
0.5
0.5
0.5
0.5
0.5
BOD
4.4
9.2
7.5
2
9.8
2.6
COD
60.7
20
20
55.9
62.9
20
Nitrate+Nitrite-Nitrogen
0.10
0.10
0.10
58.00
0.34
0.45
Total IGeldahl Nitrogen
0.5
0.6
1.2
1.4
1.2
0.5
pH
6.36
6.11
8.18
nt
7.16
7.27
DO
nt
7.52
6.74
12.65
8.25
13.35
Conductivity
112
135
173
nt
141
140
Turbidity
780
24.5
35.5
151
156
26.9
Chloride
nt
nt
14.8
nt
nt
nt
Composite
Ammonia -Nitrogen
0.5
0.5
0.5
0.6
0.5
0.5
SOD
4.6
6.4
8.1
17.3
30.5
3.3
Ndmte+Nitdte-nitrogen
0.10
0.10
0.10
3.83
0.34
0.43
Total lgeldahl Nitrogen
0.5
0.5
1.8
4.6
0.8
0.5
pH
nt
6.42
7.95
nt
7.34
7.44
DO
9.3
9.56
7.91
9.83
8.62
13.2E
Conductivity
77
128
164
nt
171
153.
Rain at start
0.45
nd
0.32
0.06
0.46
0.43
Rain at end
0.87
0.19
0.96
0.06
0.46
0.43
FLOW (crs)
1
196
520
107
55
64
81
2
260
590
120
96
67
104
3
291
612
131
101
77
.126
4
316
608
137
94
110
138
5
345
588
136
219
136
141
6
361
564
157
393
139
141
7
366
540
216
458
130
138
8
369
.521
254
446
117
139
9
375
581
281
390
107
152
average 320 569
Values in Bold and Italics = "<^ or below detection omit.
Values in Bold and Underlined = ">" the value listed.
nt = not tested
n1a - data not available
-See hard copy for explanation of value
171 250 105 129
HORSEPEN / Battleground -- wet weather

2/25/2001
11:00
6/1/2001
15:04
811112001
5:30
12/10/2001
19:06
3/212002
16:46
5I2/2002
5:14
7/1112002
2:54
11/5/2002
17:48
1/2912003
17:09
0.5
0.5
0.5
0.19
0.25
0.1
0.3
0.1
0.1
8
3.8
10.4
7.9
4.3
8.4
5
2.0
4.0
46.7
20
42.2
32.2
20
63
29.3
21.2
21
0.52
2.00
0.57
0.27
1.60
0.47
-0.5
0.30
4.2
1.1
0.6
1.6
0.8
0.8
1.2
0.9
0.5
0.6
6.65
6.61
7.11
7.67
6.63
7.01
7.19
7.5
7.55
17.14
13.13
8.52
10.76
11.3
8.98
7.75
9.9
11.03
269
131
104
110
134
153
125
124
237
50.6
28.1
264
59.1
25.7
135
130
18
24.8
26.8
nt
nt
nt
0.1
nt
nt
nt
35
0.5
0.5
0.5
0.18
0.18
0.1
0.1
0.1
0.1
33.0
5.9
12.6
5.2
38.9
6.9
4.5
2.0
n/a
0.40
0.95
0.62
0.24
123
0.50
0.54
0.30
4.40
1.2
0.8
0.3
1.2
1.1
1.3
1.0
0.5
0.7
6.78
6.86
7.11
7.7
6.83
7.16
7.35
7.53
7.63
15.98
9.97
8.33
10.5
11.2
6.35
7.71
10.2
10.83
211
42
75
83
103
188
126
117
301
0.42
0.4
2.93
0.61
0.48"
0.14
0.3
0.42
0.23
0.68
0.59
4.28
'1.5
0.90"
0.14
0.3
1.29
0.65
118
45
41
40
38
119
67
75
67
139
66
161
56
63
141
94
95
73
176
80
181
72
95
136
106
144
80
228
87
175
88
129
121
109
191
89
252
90
265
100
181
104
.106
229
96
258
96
292
110
245
90
114
266
100
314
107
253
126
277
79
158
99
415
135
204
151
316
69
195
96
479
167
166
191
364
51
203
92
264
97
193
104
190
102
128
167
88

4/262003
8/23/2003
11/19/2003
3/6/2004
4126/2004
9/17/2004
11/4/2004
2282005
612/2005
8:20
23:23
10:10
11:14
15:01
12:40
2:52
1:55
2:51
0.1
0.18
0.1
0.66
0.24
0.1
0.1
0.1
0.1
5.7
2.9
20
7.0
8
2.0
2
2.0
3.75
21
20
20
20
28
20
31
14
12
0.36
0.44
0.20
1.0
0.49
0.10
0.16
0.05
0.05
0.5
1.1
0.3
1.4
1.36
0.5
0.5
0.2
0.507
8.34
7.08
8.44
7.48
7.33
7.33
7.34
7.33
7.54
11.56
7.54
8.83
8.63
8.79
6.73
8.79
10.18
7.76
112.
104
143
234
152
136
159
155
137
24.9
83.6
11.5
21
46.7
36.1
11.9
15.6
26.3
nt
nt
nt
35
nt
nt
14
nt
0.1
0.24
0.18
0.53
0.25
0.1
0.14
0.1
0.1
4.7
3.0
5.2
6
16
2
8
2.01
4.25
0.33
0.49
0.25
0.35
0.51
0.10
0.22
0.05
0.05
0.5
0.8
1.0
0.57
1.83
1.5
1.7
0.2
0.44
8.39
6.97
8.03
7.64
7.3
7.32
7.61
7.3
7.66
11.52
7.42
8.5
8.67
8.31
6.96
9.54
9.95
7.62
112
95
97
205
133
83
105
158
132
0.38
0.84
0.53
0.24
0.47
0.62
0.89'
0.33
0.42
0.39
0.84
0.80
0.25
0.63
1.07
1.06'
0.33
0.52
245
102
307
76
51
100.4
226
159
81
337
114
400
79
71
293
367
167
84
384
112
465
76
97
355
436
173
89
382
111
607
70
129
406
520
187
95
363
117
823
81
132
491
575
224
107
352
115
998
121
118
711
573
268
124
376
100
1162
155
105
921
571
304
140
478
81
1562
167
100
1012
660
332
149
584
65
2126
164
121
1025
774
358
150
389
102
939
110
103
590
522
241
113

10/6/2005
11/16/2005
2/23/2006
4/26/2006
W30/2006
10/17/2006
2/13/2007
5/6/2007
7/17/2007
23:00
8:00
2:30
19:55
17:07
13:42
20:35
2:36
23:10
0.1
0.1
0.10
0.197
0.1
0.1
0.173
0.10
0.102
2.86
5.91
2.0
6.08
2.0
2.04
2.0
2.0
4.03
6
10
11.0
22
12
9
5.0
15.0
20.0
0.297
0.05
0.116
0.224
0.322
0.215
0.649
0.411
0.406
0.502
0.809
0.1
0.71
0.331
0.516
0.392
0.149
0.614
7.3
7.52
7.47
7.62
7.28
7.56
9.25
7.92
7.27
8.3
10.99
6.26
6.92
8.49
12.34
12.16
8.93
7.39
134
174
138
132
144
0.103
216
136
98
22.1
12.26
9.29
37.2
30.9
13.6
34.3
12.9
26.6
nt
nt
8.42
nt
nt
nt
42.0
nt
nt
0.1
0.1
0.10
0.253
0.12
0.1
0.137
0.108
0.1
2.76
6.76
2.0
5.54
7.31
2
4.57
2.0
3.63
0.309
0.05
0.191
0.243
0.584
0.183
0.634
0.405
0.420
0.565
0.979
0.167
0.69
1.75D
0.525
1.62
0.173
0.484
7.43
7.48
7.35
7.08
7.27
7.59
9.42
7.76
7.37
8.46
10.39
7.23
8.30
8.25
11.9
11.66
8.68
7.89
120
169
143
142
70
0.1 D4
94
138
112
0.89
0.26
0.37
0.32
0.50
0.45
0.44
0.47
0.41
1.08
0.27
0.37
0.34
2.14
0.8
1.38
0.47
0.42
33
58
91
86
96
113
104
83
76
35
65
101
100
588
140
150
94
75
36
75
108
105
1179
153
207
100
69
38
83
112
104
1445
158
281
99
62
40
83
114
100
1518
160
360
97
58
40
78
113
95
1515
162
469
93
55
39
74
111
89
1497
168
654
89
68
39
93
107
84
1483
184
925
85
102
44
131
103
79
1468
204
1213
81
124
38
82
107
94
1199
160
485
91
77

1
10/24/2007 1/17/2008 6/122008 9/26/2008 11/5/2008
7:11 11:52 16:40 5:07 4:42
0.100
0.10
0.31
0.10
0.100
mgA
2.90
3.18
10.6
2.56
200
m9A
22.0
5.0
29.0
5.0
5.0
mg/I
0.08
0.157
0.334
0.186
0.218
mgA
0.31
0.467
1.91
0.576
0.357
mgA
7.17
6.51
6.71
7.25
7.64
su
8.50
13.26
8.29
8.62
1.74
mg/I
148
727
81
135
145
pmhos/cm
14.2
27.8
168.0
28.6
5.9
NTU
nt
86.0
nt
nt
nt
m9/1
0.1
0.10
0.224
0.118
0.1
mgA
2.80
2.01
10.9
2.76
2.00
mg/I
0.050
0.132
0.89
0.455
0.103
mg/I
0.423
0.511
1.06
0.767
0.318
mgA
7.28
7.51
6.56
7.18
7.63
su
7.94
14.07
9.48
7.17
1.90
mg/1
145
296
86
104
150
pmhos/cm
0.21
0.35
0.83
0.44
0.32
inches
0.21
0.5
0.84
0.57
0.33
inches
74
413
494
81
77
cfs
76
469
450
110
81
cfs
77
520
371
123
81
cfs
75
580
316
127
80
cfs
74
621
276
130
77
cis
71
648
246
142
75
cfs
70
717
217
165
72
cfs
67
896
192
199
69
cfs
65
1100
166
227
66
cfs
72
663
303
145
75
cfs

HORSEPEN / Battleground -- dry weather
Summary Data - City
of Greensboro AmblentWater Quality
Site
Stream
Date
BOD (mg/1)
COD (mgA)-
Nitrate-N (mg/I)
Nitrite-N (mg/I)
TKN (mg/1)
Temp, rC)
DO (mqn)
DO (%)
Battleground Ave.
Horsepen Cr.
7/21/1999
2.0
20.0
0.34
0.10
1.3
24.6
6.40
na
Battleground Ave.
Horsepen Cr,
9/14/1999
2.3
20.0
0.24
0.10
0.5
19.2
6.23
66
Battleground Ave.
Horsepen Cr.
11/9/1999
2.0
20.0
0.11
0.10
0.5
10.3
8.92
78
Battleground Ave.
Horsepen Cr.
1/142000
2.0
20.0
0.46
0.10
0.7
4.6
11.40
88
Battleground Ave.
Horsepen Cr.
3/142000
2.0
20.0
0.51
0.10
0.5
11.1
10.06
85
Battleground Ave.
Horsepen Cr.
5192000
2.0
20.0
0.42
0.10
0.5
- 19.1
5.87
64
Battleground Ave.
Horsepen Cr.
7/112000
2.0
20.0
0.38
0.10
0.5
23.8
6.35
77
Battleground Ave.
Horsepen Cr..
9/112000
2.0
20.0
0.20
0.10
0.5
20.7
5.96
68
Battleground Ave.
Horsepen Cr.
12/52000
2.0
20.0
0.32
0.10
0.5
1.5
13.57
98
Battleground Ave.
Horsepen Cr.
1/112D01
2.0
20.0
0.43
0.10
0.2
2.8
13.07
101
Battleground Ave.
Horsepen Cr.
3/192001
3.7
20.0
0.41
0.10
0.3
9.6
10.00
95
Battleground Ave.
Horsepen Cr.
52/2001
2.5
20.0
0.34
0.10
0.5
17.4
9.13
98
Battleground Ave.
Horsepen Cr.
7/172001
1.8
20.0
0.22
0.10
0.3
22.3
5.80
66
Battleground Ave.
Horsepen Cr.
9/17/2001
2.8
20.0
0.23
0.10
0.2
15.9
8.49
87
Battleground Ave.
Horsepen Cr.
11/52001
2.1
20.0
0.10
0.10
0.1
10.6
6.91
63
Battleground Ave.
Horsepen Cr.
1/16/2002
2.0
21.3
0.40
0.10
0.4
3.7
11.90
93
Battleground Ave.
Horsepen Cr.
325/2002
2
20
0.1
0.1
0.5
13.1
10.2
97
Battleground Ave.
Horsepen Cr.
5/132002
2.0
23.5
028
0.10
0.6
21.6
6.45
75
Battleground Ave.
Horsepen Cr.
7/92002
2
20
0.29
0.1
0.5
23.2
5.61
67
Battleground Ave.
Horsepen Cr.
9152002
2.0
21.2
0.10
0.10
0.4
21.7
6.45
76
Battleground Ave.
Horsepen Cr.
1122/2002
2
20
0.5
0.5
0.5
10.2
8.62
79
Battleground Ave.
Horsepen Cr.
1/82003
2
20
0.5
0.1
0.2
4.1
11.7
92
Battleground Ave.
Horsepen Cr.
3/112003
2
20
0.5
0.1
0.5
7
10.07
65
Battleground Ave.
Horsepen Cr.
5/13/2003
2
20
0.5
0.1
0.3
16.9
7.45
79
Battleground Ave.
Horsepen Cr.
7282003
2
20
0.5
0.1
,0.2
23.6
.6.33
79
Battleground Ave.
Horsepen Cr.
9/122003
2
20
0.5
0.1
0.3
18
6.27
68
Battleground Ave.
Horsepen Cr.
11/11/2003
2
20
0.5
0.1
0.3
9.7
9.3
84
Battleground Ave.
Horsepen Cr.
1/142004
7
27
0.27
0.05
0.1
3.8
10.6
83
Battleground Ave.
Horsepen Cr.
3/232004
2
20
0.3
0.1
0.9
9.2
10.44
93
Battleground Ave.
Horsepen Cr.
5/62004
2
20
0.37
0.1
0.6
15.8
7.6
79

Battleground Ave.
Horsepen Cr.
7172004
2
25
0.19
0.1
0.5
23.9
5.72
70
Battleground Ave.
Horsepen Cr.
9/13/2004
2
25
0.1
0.1
0.5
20.3
7.51
84
Battleground Ave.
Horsepen Cr.
11/8/2004
2
20
0.1
0.1
0.5
12
5.94
57
Battleground Ave.
Horsepen Cr.
1/52005
.2
25
0.4
0.1
0.5
11.6
8.69
79
Battleground Ave.
Horsepen Cr.
321/2005
2
5
0.05
0.01
0.2
10
10.44
95
Battleground Ave.
Horsepen Cr.
7/112005
2.9
12
0.05
0.01
0.1
23.2
4.37
63
Battleground Ave.
Horsepen Cr.
9/72005
2
5
0.05
0.01
0.4
19.2
4.68
54
Battleground Ave.
Horsepen Cr.
11/32005
2
5
0.24
0.01 -
0.1
9.5
8.18
66
Battleground Ave.
Horsepen Cr.
1/172006
2
5
0.36
0.01
0.7
8.6
10
88
Battleground Ave.
Horsepen Cr.
3/7/2006
2
11
0.17
0.01
0.3
7.8
11.31
96
Battleground Ave.
Horsepen Cr.
5132006
2
5
0.13
0.01
0.6
16.1
6.93
73
Battleground Ave.
Horsepen Cr.
7/122006
2
5
0.21
0.01
0.4
23.3
6.28
74
Battleground Ave.
Horsepen Cr.
9/11/2006
2
22
0.07
0.01
0.4
21.2
7.68
86
Battleground Ave.
Horsepen Cr.
11I62006
2.1
11
0.08
0.01
0.1
7.3
15.1
126
Battleground Ave.
Horsepen Cr.
1142007
2
5
0.288
0.01
0.21
113
8.59
12
Battleground Ave.
Horsepen Cr.
3/62007
2.0
7.0
0.348
0.010
0.43
7.83
9.98
84.3
Battleground Ave.
Horsepen Cr.
5A52007
2.0
36.0
0.244
0.010
0.316
16.4
8.88
90.7
Battleground Ave.
Horsepen Cr.
7/16/2007
2.0
12.0
0.295
0.010
0.397
23.12
5.93
68.6
Battleground Ave.
Horsepen Cr.
9/62007
2.0
.14.0
0.240
0.013
0.256
22.23
4.77
55
Battleground Ave.
Horsepen Cr.
11/72007
2.0
12.0
0.157
0.010
0.246
8.2
10.16
85.6
Battleground Ave.
Horsepen Cr.
1/15/2008
2.0
5.0
0.162
0.01
0.215
4.2
12.12
97.3
Battleground Ave.
Horsepen Cr.
3/42008.
2.0
5.0
0.206
0.01
0.1
12.39
9.79
91.7
Battleground Ave.
Horsepen Cr.
5/6/2008
2
5
0.158
0.01
0.234
16.84
9.53
98.3
Battleground Ave.
Horsepen Cr.
7/162008
2
5
0.304
0.01
0.579
22.35
6.06
69.6
Battleground Ave.
Horsepen Cr.
9/192008
2.06
3
0.311
0.01
0.234
18.74
5.93
63.6
Battleground Ave.
Horsepen Cr.
11/112008
2
5
0.05
0.01
0.166
7.98
10.12
85.5
Battleground
ISM:Horsepen Creek

Station name
Date
Time
BOD
COD
Nitrate
Nitrogen
Nitrite
Nitrogen
TKN
Temp
DO
DO°%
pH
Battleground Ave.
3/16/2009
11:10
2
6
0.358
0.01
0.427
9.8
11.01
97.1
6.87
Battleground Ave.
4/15/2009
10:37
2
5
0.148
0.01
0.465
13.42
10.54
101
7.27
Battleground Ave.
5202D09
10:45
2
12
0.151
0.014
0.456
14.59
10.95
107.7
7.39
Battleground Ave. -
6/172009
10:50
2.13
11
0.208
0.01
0.673
20.99
14.29
160.3
6.78
Battleground Ave.
7/152009
10:25
2
5
0.239
0.01
0.311
2095.
8.76
75.8
7.18
Battleg round Ave.
8/192009
23:25:00
2
5
0.197
0.010
0.172
23.6
10.34
122
6.78
Battleground Ave.
9/142009
10:50:00
2
5
0.07
0.01
0.21
20.17
9.68
106.8
7.34
Battleground Ave.
1021/2009
10:32:00
2
7
0.317
0.01
0.616
10.12
16.73
148.7
6.97
Battleground Ave.
11/182009
12:30:00
2
17
0.3
0.01
0.498
11.45
9.80
90.3
7.03
Battleground Ave.
12292009
10:25:00
2
8
0.32
0.01
0.38
3.53
16.14
121.6
6.49
Battleground Ave.
1202010
10:25:00
2
7
0.317
0.01
0.492
6.45
12.14
98.7
7.14
Battleground Ave.
2/172010
10:15:00
<2.00
9
0.599
<0.010
1.53
2.45
13.2
96.7
6.77
Units
mg/I
mg/I
mg/l
mg/I
mg/I
Celsius
mg/l
%
su
Battleground
Latitude
360 8' 19.69" N
ISM:Horsepen Creek
Longitude
79° 51' 35.34" W
HORSEPEN
/ Battleground -
fixed interval

a'
HORSEPEN / Old Oak Ridge -- dry weather
Latitude Longitude
36° 6' 23.12" N 79" 54' 14.94" W
BOD,
COD,
Nitrogen,
Nitrogen,
TKN,
.Temp,
Waterbody
Site
Date
mg/I
mg/l
mg/l
mgll
mg/I
pH, su
Celsius
DO,mg/I
DO sat
Horsepen Creek
Old Oak Ridge Rd.
721/1999
2.0
20.0
0.56
0.10
0.6
6.65
24.5
6.27
Horsepen Creek
Old Oak Ridge Rd.
9/14/1999
2.0
20.0 ,
0.5
3.4
0.5
6.21
18.6
6.1
64.6
Horsepen Creek
Old Oak Ridge Rd.
11/9/1999
2.8
20.0
0.10
0.10
0.5
6.63
10.3
9.1
83.3
Horsepen Creek
Old Oak Ridge Rd.
1/142000
2
20
0.63
0.1
0.7
7.41
3.5
11.61
88.4
Horsepen Creek
Old Oak Ridge Rd.
3/142000
6.1
20.0
0.10
0.10
0.5
7.38
8.8
11.2
93.6
Horsepen Creek
Old Oak Ridge Rd.
5/92000
3.1
41.0
0.60
0.10
0.5
7.76
20.6
5.9
62.4
Horsepen Creek
Old Oak Ridge Rd.
07/11/00
2
20.0
0.40-
0.10
0.5
7.34
23.75
4.76
57.7
Horsepen Creek
Old Oak Ridge Rd.
09/11/00
2.0
20.0
0.3
0.10
0.5
7.35
20.3
6.43
71.4
Horsepen Creek
Old Oak Ridge Rd.
12/05/00
2
20
0.57
0.1
0.5
7.6
1.39
13.76
100.3
Horsepen Creek
Old Oak Ridge Rd.
01/11/01
2
20
0.63
0.1
0.1
7.14
2.73
13.44
101.9
Horsepen Creek
Old Oak Ridge Rd.
03/19/01
1.3
20
0.55
0.1
0.29
7.04
8.93
10
95
Horsepen Creek
Old Oak Ridge Rd.
05/02/01
2.1
23.3
0.44
0.1
0.5
Us
17.37
8.12
86.6
Horsepen Creek
Old Oak Ridge Rd.
07/17/01
2.3
20
0.2
0.1
0.4
8.17
22.71
4.9
57.2
Horsepen Creek
Old Oak Ridge Rd.
09/17/01
4.2
20
0.26
0.1
0.2
7.23
15.68
7.29
74.1
Horsepen Creek
Old Oak Ridge Rd.
11/05/01
2
20
0.1
0.1
0.1
7.34
10,71
5.73
53.1
Horsepen Creek
Old Oak Ridge Rd.
01/16/02
2
20
0.67
0.1
0.7
7.58
3.75
11.57
90.2
Horsepen Creek
Old Oak Ridge Rd.
0325/02
2
20
0.12
0.1
0.2
7.87
14.3
11.5
112A
Horsepen Creek
Old Oak Ridge Rd.
05/13/02
2
20
0.34
0.1
0.5
6.88
20.95
5.6
64.5
Horsepen Creek
Old Oak Ridge Rd.
07/09/02
2
20
0.4
0.1
0.5
6.72
23.47
5.42
66.3
Horsepen Creek
Old Oak Ridge Rd.
09/05/02
2
32.1
0.1
0.1
0.7
7.4
21.48
6.05
70
Horsepen Creek
Old Oak Ridge Rd.
1122/02
2
34.8
0.5
0.5
0.5
7.44
10.18
9.17
83.9
Horsepen Creek
Old Oak Ridge Rd.
01/08/03
2
20
0.5
0.1
0.2
7.58
4.64
11.79
94.1
Horsepen Creek
Old Oak Ridge Rd.
03/11/03
2
20
0.75
0.1
0.5
7.58
6.33
10.73
89.6
Horsepen Creek
Old Oak Ridge Rd.
05/13/03
2
20
0.63
0.1
0.34
6.84
15.6
7.6
78.3
Horsepen Creek
Old Oak Ridge Rd.
0728/03
2
20
0.54
0.1
0.33
7.27
23.05
5.62
65.3
Horsepen Creek
Old Oak Ridge Rd.
09/12/03
2
20
0.56
0.1
0.3
.7.42
17.22
6.9
62.5

V
Horsepen Creek
Old Oak Ridge Rd.
11/11/03
2
20
0.5
0.1
0.3
7.27
9.13
10.19
90.9
Horsepen Creek
Old Oak Ridge Rd.
01/14/04
13
45
0.34
0.05
0.1
7.46
3.81
10.4
81.3
Horsepen Creek
Old Oak Ridge Rd.
03/23104
2
25
0.56
0.1
1.4
7.78
8.3
12
104.4
Horsepen Creek
Old Oak Ridge Rd.
05/06/04
2
20
0.67
0.1
0.76
8.37
15.59
7.44
76.8
Horsepen Creek
Old Oak Ridge Rd.
7/7/04
2
25
0.26
0.10
0.50
7.33
23.52
4.93
58.7
Horsepen Creek
Old Oak Ridge Rd.
9/13/2004
2
25
0.2
0.1
0.64
7.54
19.66
7.55
- 84.2
Horsepen Creek
Old Oak Ridge Rd.
11/08/04
2
20
0.25
0.1
0.5
7.24
11.95
6.72
63.9
Horsepen Creek
Old Oak Ridge Rd.
1/5105
2
25
0.3
0.1
0.5
7.43
12.45
9.15
87
Horsepen Creek
Old Oak Ridge Rd.
321105
2
5
0.05
0.01
0.127
6.73
9.93
11.91
108.1
Horsepen Creek
Old Oak Ridge Rd.
5152005
2
5
0.05
0.02
0.287
7.41
13.09
7.73
74.3
Horsepen Creek
Old Oak Ridge Rd.
7/112005
2.09
5
0.05
0.01
0.288
7.39
23.54
5.2
61.9
Horsepen Creek
Old Oak Ridge Rd.
977/2005
2
5
0.178
0.01
0.153
7.46
18.96
5.95
66.5
Horsepen Creek
Old Oak Ridge Rd.
11/32005
2
5
0.252
0.01
0.175
7.39
9.66
7.86
69.7
Horsepen Creek
Old Oak Ridge Rd.
1/17/2006
2
5
0.414
0.01
0.219
7.39
9.73
10.84
96:5
Horsepen Creek
Old Oak Ridge Rd.
3772006
2
5
0.224
0.01
0.199
7.74
7.88
12.35.
106.5
Horsepen Creek
Old Oak Ridge Rd.
5/32006
2
8
0.16
0.01
0.507
7.28
16.49
6.72
72
Horsepen Creek
Old Oak Ridge Rd.
7/122006
2.0
5.0
0.265
0.01
0.578
7.38
24.11
6.08
72.4
Horsepen Creek
Old Oak Ridge Rd.
9/112D06
20
21.0
0.216
0.01
0.286
7.42
20.34
8.09
89.7
Horsepen Creek
Old Oak Ridge Rd.
11/62008
2.0
5.0
0.215
0.01
0.1
7.35
- 7.08
15.63
129.1
Horsepen Creek
Old Oak Ridge Rd.
114/2007
2.64
5
0.564
0.01
0.132
7.27
9.4
12.77
110.8
Horsepen Creek
Old Oak Ridge Rd.
3/6/2007
2.0
8.0
0.633
0.010
0.137
7.32
7.61
10.71
89.7
Horsepen Creek
Old Oak Ridge Rd.
5/152007
4.2 .
21.0
0.361
0.010
0.12
7.63
16.89
9.54
98.5
Horsepen Creek
Old Oak Ridge Rd.
7/162007
2.0
5.0
0.135
0.010
0.262
7.62
23.56
6.51
75.6
Horsepen Creek
Old Oak Ridge Rd.
9/62007 .
2.0
9.0
0.133
0.010
0.372
7.28
22.83
4.1
48
Horsepen Creek
Old Oak Ridge Rd.
11772007
2.0
19.0
0.174
0.010
1.01
7.44
8.72
10.09
88.6
Horsepen Creek
Old Oak Ridge Rd.
1/152008
2.0
5.0
0.268
0.01
0.118
7.65
3.66
14
106
Horsepen Creek
Old Oak Ridge Rd.
3/4/2008
20
5.0
0.235
0.012
0.163
7.27
12.75
9.35
88.3
Horsepen Creek
Old Oak Ridge Rd.
5/62008
2
5
0.237
0.01
0.367
7.62
16.6
10
102.6
Horsepen Creek
Old Oak Ridge Rd.
7/162008
2
17
0.305
0.053
1.15
7.1
23.35
4.92
57.7
Horsepen Creek
Old Oak Ridge Rd.
9/192008
2
5
0.189
0.01
0.321
6.92
18.17
6
63.6
Horsepen Creek
Old Oak Ridge Rd.
11/11/2008
2
5
0.05
0.01
0.269
7.9
9.61
10.71
94.1

Station name I Date Time BOD COD Nitrate Nitrogen Nitrite Nitrogen TKN Temp DO DO%
Old Oak Ridge Rd.
1/21/2009
12:35
2.0
Old Oak Ridge Rd.
2/182009
11:40
6.97
Old Oak Ridge Rd.
3118/2009
12:40
2.35
Old Oak Ridge Rd.
4/15/2009
11:40
2
Old Oak Ridge Rd.
5/20/2009
11:52
2
Old Oak Ridge Rd.
6/172009
11:45
2
Old Oak Ridge Rd.
7/152009
11:15
2
Old Oak Ridge Rd.
8/192009
12:25:00
2
Old Oak Ridge Rd.
9/14/2009
11:45:00
2
Old Oak Ridge Rd.
10/21/2009
11:25:00
2
Old Oak Ridge Rd.
11/18/2009
IL-30:00
2
Old Oak Ridge Rd.
12/29/2009
11:24:00
2
Old Oak Ridge Rd.
1/20/2010
11:15:00
- 2
Old Oak Ridge Rd.
2/17/2010
Units
Latitude
Longitude
36° 6' 23.12" N
79° 64' 14.94" W
5 0A56
0.01
0.479
83
15.4
107.6
24 0.203
0.01
0.853
6.11
12,09
97.4
8 0.484
0.01
0.743
10.66
11.88
106.8
24 0.271
0.01
0.149
13.47
11.21
107.6
5 0.26
0.013
0.487
13.79
10.82
104.6
10 0.297
0.01
0.578
20.59
14.47
161.1
5 0.289
0.01
0.254
21.72
6.77
- 77.1
10 0.109
0.010
0.157
24.99
10.97
132.8
7 OAS
0.01
0.103
10.61
10.06
112
6 0.288
0.01
0.794
11.24
17.38
158.6
5 0.249
0.01
0.181
11,57
10.88
100
8 0.409
0.01
0.609
3.36
16.7
125.3
5 032
0.01
0.411
6.63
12.95
105.7
6 0.724
0.023
1.39
2.3
13.42
97.9
mg/l mg/I mg/I mgn mg/I Celsius mg/1 %
HORSEPEN / Old Oak Ridge - fixed interval

Latitude Longitude
3608' 22.06" N 79054' 52.63" W
Site
BRUSH -- dry weather
Alkalinity, BOD, COD,m Nitrate
Date Time I mall mall aA Nitrooen.n
Nitrite TKN,m Temperature, DO,m
ogen,mgll pill pH,su Celsius all DO sat
Brush Creek
Flemming Ridge
7/21/1999
12:55
32.7
2.0
20.0
0.17
0.10
0.6
6.3
27.4
9.0
Brush Creek
Flemming Ridge
9/14/1999
11:02
28.4
2.4
20.0
0.22
0.10
0.6
6.65
20
6.6
72.0
Brush Creek
Flemming Ridge
11/9/1999
10:47
33.2
3.5
20.0
0.10
0.10
0.5
6.49
11.4
8.4
76.3
Brush Creek
Flemming Ridge
1/1412000
11:05
56.1
2
20
0.31
0.1
0.7
7.18
3.8
13.3
103.1
Brush Creek
Flemming Ridge
3/14/2000
11:15
35.8
6.7
20.0
0.80
0.10
0.5
T2
11.3
11.4
97.5
Brush Creek
Flemming Ridge
5/912000
11:35
54.4
2.7
20.0
0.25
0.10
0.5
7.21
23
7.3
79.2
Brush Creek
Fleming Rd.
07/11/00
11:30
38
2
20.0
0.27
0.10
0.5
7.3
25.4
7.1
91.6
Brush Creek
Fleming Rd.
09/11/00
11:08
29.0
2.0
20.0
0.2
0.10
0.5
T2
20.6
7.4
84.4
Brush Creek
Fleming Rd.
12/05/00
11:55
33.7
2
20
0.17
0.1
0.5
7.3
3.74
12.78
99.2
Brush Creek
Fleming Rd.
01/11/01
3:00
35.5
2
20
0.22
0.1
0.3
6.96
6.3
11.7
97.4
Brush Creek
Fleming Rd,
03/19/01
1:55
21
1.4
20
0.21
0.1
0.26
6.72
13.93
10
95
Brush Creek
Fleming Rd.
05102JOl
11:55
39
2.9
20
0.22
0.1
0.5
6.73
19.78
11.79
132.7
Brush Creek
Fleming Rd.
07/17/01
12:40
36
2
20
0.24
0.1
0.4
8.15
24.47
6.15
72.6
Brush Creek -
Fleming Rd.
09/17/01
1:30
32
4
20
0.24
0.1
02
7.02
19.8
9.14
101.4
Brush Creek
Fleming Rd.
11/05/01
11:30
44
2.8
20
0.1
0.1
0.1
7.16
10.44
6.51
59.8
Brush Creek
Fleming Rd.
01/16/02
12:30
53
2.6
20
0.24
0.12
0.5
6.91
6.13
11.55
95.6
Brush Creek
Fleming Rd.
03/25/02
12:48
36
2
20
0.1
0.1
0.2
7.29
18.1
11.44
-121.4
Brush Creek
Fleming Rd.
05/13/02
2:00
20
2
20
0.34
0.1
3.9
6.69
26.15
6.95
88.2
Brush Creek
Fleming Rd.
07/09/02
2:00
36
2
20
0.23
0.1
0.5
6.48
27.77
6.84
89.5
Brush Creek
Fleming Rd.
09/05102
11:20
32
2
20
0.1
0.1
0.6
6.97
21.73
5.95
69.5
Brush Creek
Fleming Rd.
11/22/02
11:30
27
2
20
0.5
0.5
0.5
7.07
10.94
8.71
81.1
Brush Creek
Fleming Rd.
01/08/03
11:25
24
2
20
0.5
0.1
0.5
7.2
5.25
11.69
94.8
Brush Creek
Fleming Rd.
03/11/03
12:20
26
2
20
0.5
0.1
0.5
7.29
7.3
10.28
87.6
Brush Creek
Fleming Rd.
05/13/03
11:30
34
2
20
0.5
0.1
0.45
6.8
18.73
8.29
91.2
Brush Creek
Fleming Rd.
07/28/03
12:25
37
2
20
0.5
0.1
0.29
7A7
26.19
8.2
104.6
Brush Creek
Fleming Rd.
09/12/03
11:45
38
2
20
0.5
0.1
0.3
6.98
18.6
7.93
87.4
Brush Creek
Fleming Rd. _
111/11103
10:45
40
2
20
0.5
0.1
0.3
6.83
10.84
9.73
90.4
Brush Creek
Fleming Rd.
01/14/04
11:55
41
9
30
0.2
0.05
0.1
7.11
4.85
11.18
89.8
Brush Creek
Fleming Rd.
03/23/04
12:45
35
2
20
0.11
0.1-
0.87
7.58
12.22
10.51
100.9

Brush Creek
Fleming Rd.
05IM04
10:50
34
2
20
0.24
0.1
0.63
7.65
18.56
8.22
90.1
Brush Creek
Fleming Rd.
MIN
11:05
43
2
25
0.17
0.10
0.50
7.19
25.39
7.39
92.7
Brush Creek
Fleming Rd.
9/13/2004
12:00
32
2
.25
0.1
0.1
0.5
7.02
22.13
8.08
92.9
Brush Creek
Fleming Rd.
11/OB/04
12:10
37
2
83
0.1
0.1
0.5
6.9
14.53
7.21
70
Brush Creek
Fleming Rd.
1/5105
11:25
39
2
25
0.53
0.1
0.5
6.88
12.26
9.34
89.2
Brush Creek
Fleming Rd.
3/21/05
11:25
33
4.29
10
0.05
0.01
0.148
6.31
13.22
10.74
106.3
Brush Creek
Fleming Rd.
5/5/2005
11:25
33
2
5
0.063
0.01
0.254
7.13
14.84
8.92
90.5
Brush Creek
Fleming Rd.
7/11/2005
12:55
42
2.0
7
0.05
0.01
0.1
7.15
22.98
7.94
92.5
Brush Creek
Fleming Rd.
9!7/2005
11:10
53
2
5
0.201
0.01
0.16
7.29
18.18
7.74
84.1
Brush Creek
Fleming Rd.
11/3/2005
11:00
49.5
2
5
0.263
- 0.01
0.121
7.24
10.16
9.74
88.9
Brush Creek
Fleming Rd.
1/17/2006
2:50
34.1
2
5
0.506
0.01
0.423
6.9
10.2
10.87
98.6
Brush Creek
Fleming Rd.
3/7/2006
12:45
39.9
2
5
0.135
0.01
0.147
7.34
11.55
13.26
122.7
Brush Creek
Fleming Rd.
5/3/2006
11:35
42
2
5
0.092
0.01
0.289
7.09
17
7.73
82.6
Brush Creek
Fleming Rd.
7/122006
11:29
35.7
2.0
5.0
0.197
0.01
0.358
6.98
23.26
7.68
89.9
Brush Creek
Fleming Rd.
9/11/2006
12:42
40.4
2.0
15.0
0.078
0.01
0.254
7.15
20.19
9.17
1012
Brush Creek
Fleming Rd.
11/62006
11:57
42.8
2.0
5.0
0.069
0.01
0.1
7.03
8.64
14.43
123.8
Brush Creek
Fleming Rd.
1/42007
11:30
33.6
2
5
0.206
0.01
0.315
6.9
9.59
11.81
103.5
Brush Creek
Fleming Rd.
3/62007
12:05
30
2.0
5.0
0.397
0.010
0.152
7.03
9.03
10.61
92.1
Brush Creek
Fleming Rd.
5/15/2007
12:08
41
2.9
20.0
0.201
0.010
0.349
7.26
18.11
10.02
106.1
Brush Creek
Muifield Rd.
7/16/2007
13:05
64
2.0
5.0
0.112
0.010
0.152
7.39
23.92
8.91
105.7
Brush Creek
Muifield Rd.
9/62007
11:45
60 -
2.0
6.0
0.058
0.010
0.168
7.23
21.86
7.78
88.7
Brush Creek
Muifield Rd.
11/7/2007
11:20
43.1
2.0
12.0
0.119
0.010
0.10
7.51
8.57
11.67
97.1
Brush Creek
Muifield Rd.
1/15/2008
-12:08
40.7
2.0
5.0
0.178
0.01
0.237
7.55
4.91
13.58
106.7 '
Brush Creek
Muifield Rd.
3/42008
10:23
45.1
2.0
5.0
0.185
0.01
0.2
7
12.64
10.24
96.4
Brush Creek
Winfield Rd.
5/62008
12:20:00
39.6
2
5
0.224
0.01
0.203
6.51
17.91
10.45
110.2
Brush Creek
Winfield Rd.
7/162008
11:37:00
59.4
2
5
0.179
0.01
0.346
6.93
21.43
7.25
82
Brush Creek
Muifield Rd.
9/19/2008
10:40:00
36.3
2.06
5
0.149
0.01
0.163
6.88
18.12
6.07
64.2
Brush Creek
Muifield Rd.
11/112008
11:35:00
52.8
2
5
0.05
0.01
0.236
7.18
8.33
11.03
93.9

Station name
Date
Time
BOD
COD
Nitrate
Nitrogen
Nitrite
Nitrogen
TKN
Temp
DO
DO%
pH
Level
Flow
Muirfield Rd.
3/182009
11:55
2
8
0.233
0.01
0.56
10.99
11.03
99.9
6.64
2.64
4.7
Muirfield Rd.
4/15/2009
11:20
2
5
0.196
0.01
0.139
13.65
10.92
105.2
7.17
2.57
3.6
MUIReid Rd.
5202009
11:30
2
14
0.067
0.016
0.481
14.51
10.67
104.8
6.97
2.35
1.3
Muirfield Rd.
6117/2009
11:30
2
13
0.161
0.01
0.551
20.33
14
155
6.74
Muirfield Rd.
7/15/2009
11:0U
2
5
0.233
0.01
0.236
19.62
7.41
80.9
7.07
Muirfield Rd.
8/192009
12:30:00
1
9
0.145
0.010
0.125
23.33
13.27
155.7
7.44
2.22
0.46
Muirfield Rd.
9/14/2009
11:20.00
2
5
0.069
0.01
0.16
19.13
1059
114.5
7.31
Muirfield Rd.
1021/2009
11,11:00
2
5
0.208
0.01
0.451
10.98
19.4
175.9
6.81
2.24
0.97
Muirfield Rd.
11/182009
11:10:00
2
6
0.138
0.01
0.321
11.6
11
101.1
7.05
2.58
3.9
Muirfield Rd.
12292009
11:10:00
2
11
0.239
0.01
0.218
3.96
16.67
127.1
6.58
2.63
5.5
Muirfield Rd.
120/2010
11:00:00
2
5
0.211
0.01
0.357
7.16
11.94
98.9
6.75
2.62
5.3
Muirfield Rd.
2/172010
11,00:00
8
16
0.315
<0.010
0.301
3.79
12.37
919
6.87
2.56
4.6
Units
mg/I
mg/l
mg/l
mg/I
mg/I
Celsius
mg/l
%
su
feet
cfs
Latitude
Longitude
36° 8' 22.06' N
79° 54' 52.63" W
BRUSH -- fixed interval

Nitrate
Nitrite
Station name
Date
Time
BOD
COD
Nitrogen
Nitrogen
TKN
Temp
DO
DO%
pH
Level
Flow
Muirfield Rd.
3/18/2009
11:55
2
8
0.233
0.01
0.56
10.99
11.03
99.9
6.64
2.64
4.7
Muirfield Rd.
4/15/2009
11,20
2
5
0.195
0.01
0.139
13.65
10.92
105.2
7.17
2.57
3.6
Muirfield Rd.
5202009
11:30
2
14
0.067
0.016
0.481
14.51
10.67
104.8
6.97
2.35
1.3
Muirfield Rd.
6/17/2009
11:30
2
13
0.161
0.01
0.551
20.33
14
155
6.74
Mulrfield Rd.
7/15/2009
11:00
2
5
0.233
0.01
0.236
19.62
7.41
80.9
7.07
Muirfield Rd.
8/192009
12:10:00
2
9
0.145
0.010
0.125
23.33
13.27
155.7
7.44
2.22
0.46
Muirfield Rd.
9/14/2009
11:20:00
2
5
0.069
0.01
0.16
19.13
10.59
114.5
7.31
Muirfield Rd,
1021/2009
11:11:00
2
5
0.208
0.01
0.451
10.98
19.4
175.9
6.81
2.24
0.97
Muirfield Rd.
11/18/2009
11:10:00
2
6
0.138
0.01
0.321
11.6
11
101.1
Z05
2.58
3.8
Muirfield Rd.
12/292009
11:10:00
2
11
0.239
0.01
0.218
3.96
16.67
127.1
6.58
2.63
5.5
Muirfield Rd.
120/2010
11:00:00
2
5
0.211
0.01
0.357
7.16
11.94
98.9
6.75
2.62
5.3
Muirfield Rd.
2/172010
11:00!00
8
16
0.315
<0.010
0.301
3.79
12.37
93.9
6.87
2.56
4.6
Units
mg/I
mg/I
mg/I
mg/I
mgll
Celsius
mg/l
%
su
feet
cfs
Latitude Longitude
36° 8' 22.06" N 790 54' 52.63" W
BRUSH -- fixed interval

0
5
c5

Deicing Pads
Description
Miscellaneous Demolition
Clearing and Grubbing
Unclassified Excavation
Deicing Pad Pavement
Trench Drains
24" RCP Class V
42' RCP Class V
250,000 Gal Storage Tank
Control Factlity/Eguipmerd/Piping/Misc
Perimeter Road Paving/Misc.
Relocated/New Fence
Pavement Marking
Seeding and Mulching
Airfield ElecticaltSignage
Deicing Pad Area Lighting
Erosion and Sedimentation Control
Construction Subtotal
Contigency @25%
Construction Total
Design/Administration 010%
mated
antity
Unit
Unit Price
Extended
Total
1
LS
$400,000.00
$400.000
1
LS
$100,000.00
$100.000
4
AC
$10,000.D0
$40.000
50,000
CY
$15.00
$750,000
32,400
SY
$150.00
$4,860,000
2,DD0
LF
$175.00
$350.000
1,D00
LF
$105.00
$105,000
4,100
LF
$125.00
$512.500
2
EA
$400.000.00
$800,000
2
FA
$100,000.00
$200.000
2.700
SY
$75.00
$202,500
500
LF
$30.00
$15.000
1
LS
$25.000.00
$25.000
1
LS
$50.000.00
$50.000
1
LS
$350,000.00
$350.000
1
LS
$80,000.00
$80.000
1
LS
$500,000.00
$500,000
$9.340.000
E2,335,000
$11,675,000
E1,167,500

n
U
C�
C]

Page 1 of 3
[Code of Federal Regulations]
[Title 14, Volume 31
[Revised as of January 1, 20091
From the U.S. Government Printing Office via GPO Access
[CITE: 14CFR121.6291 f
[Page 180-182]
TITLE 14--AERONAUTICS AND SPACE
i
CHAPTER I --FEDERAL AVIATION ADMINISTRATION, DEPARTMENT OF TRANSPORTATION
(CONTINUED)
PART 121_OPERATING REQUIREMENTS: DOMESTIC, FLAG, AND SUPPLEMENTAL OPERATIONS--
i
Subpart U_Dispatching and Flight Release Rules
Sec. 121.629 Operationjin icing conditions.
(a) No person may dispatch or release an aircraft, continue to
operate an aircraft en route, or land an aircraft when in the opinion of
the pilot in command orlaircraft dispatcher (domestic and flag
operations only), icinglconditions are expected or met that might
adversely affect the safety of the flight.
(b) No person may take off an aircraft when frost, ice, or snow is
adhering to the wings, control surfaces, propellers, engine inlets, or
other critical
[[Page 181]]
surfaces of the aircraft or when the takeoff would not be in compliance
with paragraph (c) of tkis section. Takeoffs with frost under the wing
in the area of the fuelltanks may be authorized by the Administrator.
(c) Except as provided in paragraph (d) of this section, no person
may dispatch, release, or take off an aircraft any time conditions are
such that frost, ice, or, snow may reasonably be expected to adhere to
the aircraft, unless the certificate holder has an approved ground
deicing/anti-icing program in its operations specifications and unless
the dispatch, release, and takeoff comply with that program. The
approved ground deicing/anti-icing program must include at least the
following items:
(1) A detailed description of--
(i) How the certificate holder determines that conditions are such
that frost, ice, or snow may reasonably be expected to adhere to the
aircraft and that ground deicing/anti-icing operational procedures must
be in effect;
(ii) Who is responsible for deciding that ground deicing/anti-icing
operational procedures must be in effect;
(iii) The procedures: for implementing ground deicing/anti-icing
operational procedures;
(iv) The specific duities and responsibilities of each operational
position or group responsible for getting the aircraft safely airborne
while ground deicing/anti-icing operational procedures are in effect.
(2) Initial and annual recurrent ground training and testing for
flight crewmembers and qualification for all other affected personnel
(e.g., aircraft dispatchers, ground crews, contract personnel)
concerning the specific requirements of the approved program and each
person's responsibilities and duties under the approved program,
specifically covering the following areas:
(i) The use of holdover times.
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f .. k
Page 2 of 3
(ii) Aircraft deicing/anti-icing procedures, including inspection
and check procedures and responsibilities.
(iii) Communications procedures.
(iv) Aircraft surface contamination (i.e., adherence of frost, ice,
or snow) and critical area identification, and how contamination
adversely affects aircraft performance and flight characteristics.
.(v) Types and characteristics of deicing/anti-icing fluids.
(vi) Cold weather preflight inspection procedures;
(vii) Techniques for recognizing contamination on the aircraft.
(3) The certificate;holder's holdover timetables and the procedures
for the use of these tables by the certificate holder's personnel.
Holdover time is the estimated time deicing/anti-icing fluid will
prevent the formation of frost or ice and the accumulation of snow on
the protected surfaces of an aircraft. Holdover time begins when the
final application of deicing/anti-icing fluid commences and expires when
the deicing/anti-icing fluid applied to the aircraft loses its
effectiveness. The holdover times must be supported by data acceptable
to the Administrator. The certificate holder's program must include
procedures for flight crewmembers to increase or decrease the determined
holdover time in changing conditions. The program must provide that
takeoff after exceedinglany maximum holdover time in the certificate
holder's holdover timetable is permitted only when at least one of the
following conditions exists:
(i) A pretakeoff contamination check, as defined in paragraph (c)(4)
of this section, determines that the wings, control surfaces, and other
critical surfaces, as defined in the certificate holder's program, are
free of frost, ice, or snow.
(ii) It is otherwise determined by an alternate procedure approved
by the Administrator in I accordance with the certificate holder's
approved program that the wings, control surfaces, and other critical
surfaces, as defined in the certificate holder's program, are free of
frost, ice, or snow.
(iii) The wings, control surfaces, and other critical surfaces are
redeiced and a new holdover time is determined.
(4) Aircraft deicing/anti-icing procedures and responsibilities,
pretakeoff check procedures and responsibilities, and pretakeoff
contamination check procedures and responsibilities. A pretakeoff check
is a check of the aircraft's wings or representative aircraft surfaces
for frost, ice, or snow within
[[Page 182]]
the aircraft's holdoveritime. A pretakeoff contamination check is a
check to make sure the wings, control surfaces, and other critical
surfaces, as defined inithe certificate holder's program, are free of
frost, ice, and snow. It must be conducted within five minutes prior to
beginning take off. This check must be accomplished from outside the
aircraft unless the program specifies otherwise.
(d) A certificate holder may continue to operate under this section
without a program as required in paragraph (c) of this section, if it
includes in its operations specifications a requirement that, any time
conditions are such that frost, ice, or snow may reasonably be expected
to adhere to the aircraft, no aircraft will take off unless it has been
checked to ensure that the wings, control surfaces, and other critical
surfaces are free of frost, ice, and snow. The check must occur within
five minutes prior to be takeoff. This check must be accomplished
from outside the aircraft.
i
[Doc. No. 6258, 29 FR 19222, Dec. 31, 1964, as amended by Amdt. 121-231,
57 FR 44942, Sept. 29, 1992; Amdt. 121-253, 61 FR 2615, Jan. 26, 1996]
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1

e.
'A
Page 3 of 3
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5/3/2010

Q Advisory
U S. Department
of Transportation
Federal Aviation Circular
Administration
i
Subject: GROUND DEICING AND Date: 12/20/04 AC No: 120-60B
ANTI -ICING PROGRAM Initiated By: AFS-220 Change:
i
I
1. PURPOSE. This advisory circular (AC) has been updated to reflect current industry
practices and to standardize the application process and training programs associated with
ground deicing/anti-icing. It provides an industry -wide standard means for obtaining approval of
a Ground Deicing /Anti -Icing Program in accordance with Title 14 of the Code of Federal
Regulations (14 CFR) part 121, section 121.629. In addition, it provides a means acceptable to
the Administrator for a certificate holder to deice/anti-ice aircraft using another certificate
holder's personnel and pi ocedures or contract personnel who have been trained by the other
certificate holder.
2. CANCELLATION. I AC 120-60A, Ground Deicing and Ant -Icing Program, dated
August 30, 2004, is canceled.
3. DEFINITIONS.
a. Anti -icing. A procedure used to provide protection against the formation of frost or ice
and accumulation of snow or slush on clean surfaces of the aircraft for a limited period of time
(holdover time). Anti -icing fluids are normally applied unheated on clean aircraft surfaces, but
may be applied heated, and include:
(1) SAE Type I fluid
(2) Concentrates or mixtures of water and SAE Type I fluid.
(3) Concentrates or mixtures of water and SAE Type II fluid.
(4) Concentrates ;of SAE Type III fluid.
i
(5) Concentrates or mixtures of water and SAE Type IV fluid.
b. Deicing. A procedure used to remove frost, ice, slush, or snow from the aircraft in order
to provide clean surfaces The procedure can be accomplished using fluids, infrared energy,

AC 120-60B
12/20/04
mechanical means, or by heating the aircraft. Deicing fluid is usually applied heated to assure
maximum deicing efficiency and includes:
(1) Heated water.
(2) SAE Type I•fluid.
1
(3) Heated concentrates or mixtures of water and SAE Type I fluid.
1
(4) Heated concentrates or mixtures of water and SAE Type II fluid.
I
(5) Heated concentrates or mixtures of water and SAE Type III fluid.
(6) Heated cone IImrates or mixtures of water and SAE Type IV fluid.
c. Frozen Contaminants. As used in this AC, frozen contaminants include light freezing
rain, freezing rain, freezing drizzle, frost, ice, ice pellets, snow, snow grains, and slush.
d. Holdover Time (HOT). The estimated time that deicing/anti-icing fluid will prevent the
formation of frost or ice and the accumulation of snow on the critical surfaces of an aircraft.
HOT begins when the final application of deicing/anti-icing fluid commences and expires when
the deicing/anti-icing fluid loses its effectiveness.
e. Pretakeoff Check A check of the aircraft's wings or representative aircraft surfaces for
frozen contaminants. This check is conducted within the aircraft's HOT and may be made by
observing representative surfaces from the flight deck, cabin, or outside the aircraft, depending
on the type of aircraft andi operator's FAA -approved program.
I
f. Pretakeoff Contamination Check. A check (conducted after the aircraft's HOT has been
exceeded) to ensure the aiicraft's wings, control surfaces, and other critical surfaces, as defined
in the certificate holder's program, are free of all frozen contaminants. This check must be
completed within 5 minutes before beginning takeoff and from outside the aircraft, unless the
certificate holder's FAA -approved program specifies otherwise .
g. Post Deicing Check. A check, after deicing application, to ensure all aircraft surfaces are
free of frozen contaminants.
i
I
4. RELATED READING MATERIAL. The following material is useful in developing
training program subject material and instructions, and procedures for incorporation in the
certificate holder's manuals:
a. Publications of the United States Government.
,i
(1) AC 20-117, Hazards Following Ground Deicing and Ground Operations in
Conditions Conducive to Aircraft Icing.
Page 2 Par 3

12/20/04 1 AC 120-60B
(2) AC 120-58,1 Pilot Guide for Large Aircraft Ground Deicing.
(3) FAA publication, Winter Operations Guidance for Air Carriers and other Adverse
Weather Topics.
(4) The annual Flight Standards Information Bulletin (FSAT) on ground de-icing.
NOTE: The FAA publication may be obtained from the U.S. Department of
Transportation, Subsequent Distribution Office, Ardmore East Business Center,
3341 Q 75th Ave., Landover, MD, 20785. The ACs are located on the FAA Web site
at httn://www.airweb.faa.gov/rgl.
I
The FSAT is located on the FAA Web site at htta://www.faa.gov/avr/afs/fsat/fsati.htm
b. Publications of the Society of Automotive Engineers (SAE). Copies of the following
documents may be obtained by writing to the Society of Automotive Engineers, 400
Commonwealth Drive, Warrendale, Pennsylvania, 15096-0001.
(1) Aerospace Materials Specification (AMS) 1424, Deicing/Anti-Icing, Fluid, Aircraft,
SAE Type 1.
(2) Aerospace Materials Specification (AMS) 1428, Deicing/Anti-Icing, Fluid, Aircraft,
Non -Newtonian, Pseudo, -Plastic, SAE Type II, III & IV.
1
(3) Aerospace Recommended Practice (ARP) 4737, Aircraft Deicing/Anti-Icing
Methods.
(4) Aerospace Recommended Practice (ARP) 5149, Training Program Guidelines for
Deicing/Anti-icing of Aircraft on Ground.
I
c. Publications of the International Standards Organization (ISO). Copies of the
following documents may be obtained from the American National Standards Institute,
11 West 42"d Street, New York, New York, 10036, [phone].
i
(1) ISO 11075, Aerospace -Aircraft Deicing/Anti-Icing Newtonian Fluids ISO Type I.
1
(2) ISO 11076, Aerospace -Aircraft Deicing/Anti-Icing Methods with Fluids.
i
(3) ISO 11078, Aerospace -Aircraft Deicing/Anti-Icing Non -Newtonian Fluids ISO
Type II.
d. Publications of the Association of European Airlines(AEA).
AEA Recommendations for Deicing/Anti-icing of Aircraft on the Ground. This publication can
be found on the following Web site: http://www.aea.be. Select "publications" then click on
"deicing/anti-icing".
Par 4

AC 120-60B 1 12/20/04
5. CONTENT. This AC provides guidelines for acceptable program elements for incorporation
in the certificate holder's approved ground deicing and anti -icing program. Also, a certificate
holder, with a ground deicing and anti -icing program approved in accordance with this AC, may
deice and anti -ice aircraft using another certificate holder's ground deicing and anti -icing
program that is approved in accordance with this AC.
6. PROGRAM ELEMENTS. Section 121.629(c) requires a certificate holder's ground deicing
and anti -icing program to include the following elements:
a. Management Plan (Section 121.629(c)(1)). In order to properly exercise operational
control (when condition's are such that frost, ice, snow, or slush may reasonably be expected to
adhere to an aircraft), the certificate holder should develop, coordinate with other affected
parties, implement, and use a management plan for proper execution of its approved deicing/anti-
icing program. A plan encompassing the following elements is acceptable:
(1) Responsibility. At each airport where operations are expected to be conducted in
conditions conducive tol ground icing, determine who is responsible for deciding when ground
deicing/anti-icing procedures are in effect.
(2) Implementation. At each airport, determine who is responsible for implementation
of the ground deicing/an'ti-icing procedures, including adequate qualified personnel and
equipment.
(3) Incorporation In Manuals. A detailed description of the deicing/anti-icing program
should be incorporated in the certificate holder's manuals for flight crewmembers, dispatchers or
flight followers, ground operations personnel, and management personnel to use when
conducting operations under ground icing conditions. This description should include the
functions, duties, responsibilities, instructions, and procedures to be used.
(4) Coordination. At each airport, a winter operations plan should be developed to
include coordination with ATC and the appropriate airport authorities.
b. Application Procedures. In an appropriate manual, certificate holders shall specify the
deicing and anti -icing fluid procedures for each type of aircraft operated. Ground personnel
trained and qualified to apply deicing and anti -icing fluid, in accordance with a certificate
holder's AC 120-60 (current edition) program, do not require additional training and
qualification to deice and anti -ice similar aircraft operated by another certificate holder with a
deicing and anti -icing program also approved in accordance with the current edition of
AC 120-60. However, specific training is needed for an operator's deicing personnel to deice
aircraft with different configurations (e.g., turboprop with t-tail).
c. HOT Tables and Procedures for Their Use. Section 121.629(c)(3) requires that the
deicing/anti-icing program include HOT tables and the procedures for the use of these tables by
the certificate holder's personnel. The following elements should be included in the approved
program:
Page 4 1 Par 5

12/20/04 AC 120-60B
i
(1) Responsibilities and Procedures. The certificate holder's program should define
operational responsibilities and contain procedures for the flightcrew, aircraft dispatchers, flight
followers, and maintenance and ground personnel that apply to the use of HOTS and resultant
actions if the determined HOT is exceeded.
I
(a) Procedures should be developed to address deicing operations at specific deicing
locations (e.g., gate, remote, or centralized facilities).
i
(b) Procedures should be developed for ground crew and flightcrew to communicate:
1 During aircraft positioning (if required).
2 Other pertinent information regarding the deicing/anti-icing process.
3 Start of the HOT.
4 The aircraft departure process.
5 Equipment clear/job done — safe to start taxiing.
I
(c) In addition, procedures should be developed for the flightcrew's use of the
pertinent HOT tables, coordination with dispatchers or flight followers and coordination with
ATC
1
(2) FAA HOT Tables. Except as provided in section 121.629(d), each certificate holder
is required under section 121.629(c)(3) to implement HOT tables for use by its personnel. The
FAA develops HOT tables for Type I deice/anti-ice fluid and generic Type II and IV anti -ice
fluid in accordance withlSAE ARP 4737, Aircraft Deicing/Anti-Icing Methods, and ISO 11076,
Aerospace Aircraft Deicing/Anti-Icing Methods with Fluids. HOTS that exceed those specified
in the current editions of the FAA and manufacturer's specific HOT of approved fluids are not
acceptable. However, the certificate holder may require the use of more conservative times than
those specified in the FAA tables. Tables 1 and 2 of Appendix 1 are samples of HOT tables.
(3) Use of HOT IITables. HOT ranges are an estimate of the time that deicing/anti-icing
fluid will prevent the formation of frost or ice and the accumulation of snow on the unprotected
surfaces of an aircraft. HOT begins when the final application of deicing/anti-icing fluid
commences and expires when the deicing/anti-icing fluid applied to the aircraft loses its
effectiveness (e.g., whenl ice begins to form on or in the fluid). HOTS vary with weather
conditions. The effectiveness of deicing/anti-icing fluids is based on a number of variables (e.g.,
temperature, moisture content of the precipitation, wind, and the aircraft skin temperature). The
HOT tables are to be used for departure planning and in conjunction with pretakeoff check
procedures.
d. Frozen Contaminants on the Aircraft. Per section 121.629(b), the aircraft must be free
of all frozen contaminants adhering to the wings, control surfaces, propellers, engine inlets, or
other critical surfaces before takeoff.
Par 6 1Page 5

AC 120-60B
12/20/04
NOTE: The Administrator may authorize "Takeoff' with frost under the
wing in the area of the fuel tanks, if it can be shown that there is minimal
degradation of aircraft performance due to these accumulations. However,
under -wing frost that degrades airplane performance beyond a minimal
amount is acceptable if the appropriate performance information is
provided in the AFM.
i
(1) Identification of Critical Aircraft Surfaces. The critical aircraft surfaces, which
must be clear of contaminants before takeoff should be described in the aircraft manufacturer's
maintenance manual or other manufacturer -developed documents, such as service or operations
bulletins.
(a) Generally, the following should be considered to be critical aircraft surfaces, if
the aircraft manufacturer's information is not available:
1 Pitot heads, static ports, ram -air intakes for engine control and flight instruments,
other kinds of instrument sensor pickup points, fuel vents, propellers, and engine inlets.
2 Wings; empennage, and control surfaces.
l 3 Fuselage upper surfaces on aircraft with center mounted engine(s).
(b) Certificate holders should list in the flight manual or the operations manual, for
each type of aircraft used in their operations, the critical surfaces that should be checked on
flight-crewmember-conducted preflight inspections, pretakeoff checks, and pretakeoff
contamination checks. '
(c) Critical surfaces should be defined for the use of ground personnel for conducting
the check following the deicing/anti-icing process and for any pretakeoff contamination checks
that may be accomplished by ground personnel.
(2) Identification of Representative Aircraft Surfaces (for use in conducting
pretakeoff checks only). For each type of aircraft operated, certificate holders should list, in an
appropriate manual, the representative surfaces that may be checked while conducting pretakeoff
checks. Some aircraft manufacturers have identified certain aircraft surfaces that the flightcrew
can readily observe to determine whether or not frozen contaminants are accumulating or
forming on that surface and, by using it as a representative surface, can make a reasoned
judgment regarding whether or not frozen contaminants are adhering to other aircraft surfaces.
When identifying a representative aircraft surface, the following guidelines should be
considered: i
(a) The surface can be seen clearly to determine whether or not frozen contaminants
are forming or accumulating on the surface.
(b) The surface should be unheated.
Page 6 Par 6

12/20/04
I
(c) During the deicing/anti-icing procedure,
of the first surfaces treated with deicing/anti-icing fluid.
representative surfaces is not limited to treated surfaces.
AC 120-60B
the representative surface should be one
However, the designation of
(3) Recognition Techniques. Certificate holder's Initial, Transition, Recurrent,
Upgrade, or Advanced Qualification Program (AQP) and Continuing Qualification training
curricula should include aircraft type -specific techniques for use by the flightcrew and other
personnel for recognizing contamination on aircraft surfaces. The flightcrew and other personnel
should use these type -specific techniques while conducting preflight aircraft icing checks,
pretakeoff checks, and pretakeoff contamination checks. Frozen contaminants can take the form
of ice, frost, snow, or sl6sh.
NOTE: The formation of clear ice may be difficult to detect visually.
Therefore, specific techniques for identification of clear ice should be
included in all training programs.
e. Types of Icing Checks. Section 121.629(c)(4) identifies pretakeoff and pretakeoff
contamination checks that, when applicable, are required to be accomplished under an operator's
approved deicing/anti-icing program. The aircraft deicing/anti-icing procedure also includes a
post deicing/anti icing check of all aircraft surfaces.
(1) Pretakeoff Check (within the HOT). This check is required under section
121.629(c)(3) anytime procedures for the use of HOT are required. The FAA recommends that
only the flightcrew accomplish the pretakeoff check. The flightcrew must accomplish the check
within the HOT. The flightcrew should check the aircraft's wings or representative aircraft
surfaces for frozen contamination. The surfaces to be checked are determined by manufacturer's
data or guidance contained in this AC. The pretakeoff check is integral to the use of HOTS.
Because of the limitations and cautions associated with the use of HOTS, the flightcrew must
assess the current weather and other situational conditions that affect the aircraft's condition and
not rely on the use of HOTS as the sole determinant that the aircraft is free of contaminants.
Several pretakeoff checks may be required during the HOT period based on factors that include
the length of the HOT range, weather, or other conditions. The flightcrew should maintain a
continued awareness of the condition of the aircraft and accomplish a pretakeoff check just
before taking the active runway for departure. When conducting the pretakeoff check, the
flightcrew must factor in'the application sequence (i.e., where on the aircraft the deicing process
began).
(2) Pretakeoff Contamination Check (when HOT has been exceeded). Section
121.629(c)(3)(i) states that completing a pretakeoff contamination check is one of the conditions
that allows a takeoff after a HOT has been exceeded. When a HOT has been exceeded,
certificate holders must have appropriate pretakeoff contamination check procedures for the
flightcrew's and/or otherlqualified ground personnel's use to ensure that the aircraft's critical
surfaces remain free of frozen contaminants. Flighterews and/or other qualified ground
personnel must completelthe pretakeoff contamination check within 5 minutes before beginning
takeoff. This check must be accomplished from outside the aircraft unless the certificate
Par 6

AC 120-60B 12/20/04
holder's program specifies otherwise. If any doubt exists concerning the aircraft's condition
after completing this &ck, the aircraft cannot takeoff unless it is deiced again and a new HOT is
determined. The following should be considered while developing procedures for this check:
(a) Unless otherwise authorized in the certificate holder's approved program,
certificate holders who operate hard -wing (wings without moveable leading edge lift devices)
aircraft with aft, fuselage -mounted, turbine -powered engines should conduct pretakeoff
contamination checks from outside the airplane. The pretakeoff contamination check for these
aircraft should include a method, approved by the Administrator; to determine that all aircraft
surfaces are free of contaminants.
(b) Operators of aircraft other than those addressed in paragraph (a) above, should
conduct this check from outside the aircraft unless they can show that the check can be
adequately accomplished from inside the aircraft, as specified in the certificate holder's program
The program must detail procedures and requirements for this check. When developing a
program for conductingjthe pretakeoff contamination check from inside the aircraft, certificate
holders should considerlif crewmembers are able to see enough of the wings, control surfaces,
and other surfaces to determine whether or not they are free of contaminants. When making this
determination, consider 'the aircraft type, the method of conducting the check (from the cockpit
or cabin), and other factors, such as aircraft lighting and ambient conditions.
(3) Post Deicing/Anti-Icing Check. This multi -part check is an integral part of the
deicing/anti-icing process. The check ensures that:
(a) All criticI al surfaces are free of adhering frozen contaminants after deicing.
(b) All critical surfaces are free of frozen contaminants before the application of any
anti -icing fluid. i
(c) All critical surfaces are free of frozen contaminants before pushback or taxi
NOTE: Certificate holders should have procedures that require that
qualified ground personnel conduct this check. Communication procedures
should be established to relay pertinent deicing/anti icing information and
the results of this check to the PIC.
f. Communications! Communication between ground personnel and the flightcrew prior to
commencing deicing/anti-icing operations is critical. Upon completion of deicing/anti-icing
operations, ground personnel should communicate with the flightcrew to determine the start of
the HOT. The particular', HOT the flightcrew uses is also critical. Since many deicers service
multiple carriers, the FAA recommends that all approved programs include the following flow
sequence and information to provide standardized phraseology:
(1) Before commencing deicing/anti-icing operations, ground personnel and the
flightcrew should review the following (as applicable):
Page 8 Par 6

12/20/04 AC 120-60B
(a) Deicing/anti-icing prior to crew arrival.
(b) Gate or emote deicing/anti-icing procedures.
(c) Aircraft specific procedures.
(d) Communications between ground personnel and the flightcrew.
(2) Just before commencing the application of deicing/anti-icing fluid, ground personnel
should confirm with the; flightcrew that the aircraft is properly configured for deicing, as follows:
Example: "Captain, is your aircraft ready for deicing/anti-icing?"
I
(3) Upon completion of deicing/anti-icing, provide the flightcrew with the following
elements:
A: Fluid type (e.g., Type I, Type II, Type III or Type IV) Fluid product name
optional for each type of fluid if fluid meets product on -wing viscosity requirements.
B: Fluid/water mix ratio by volume of Types II, III, and IV. Reporting the
concentration of Type I fluid is not required..
I
C: Specify, in local time (hours and minutes) the beginning of the final fluid
application (e.g. 1330).
D: Post application check accomplished. Specify date (day, written month, year).
NOTE: Element D.is required for recordkeeping, optional for crew notification.
NOTE: Transmission of elements A-C to the flightcrew confirms that a post deicing/anti-
icing check was completed and the aircraft is clean.
Examples of the ground/flightcrew communication sequence for the one and two-step
processes follow:
One Step Process with Type I or other approved deicing fluid: "Captain, I
am your designated deicer. Your aircraft has been deiced with Type I fluid.
Your fluid application began at 1430."
Two Step Process with Types I1, Ill, or IV: Captain, I am your designated
deicer. Your aircraft has been deiced with Type I fluid and anti -iced with
Type IV. An anti -ice fluid mixture of 75 was used. Your anti -ice fluid
application began at 1645.
1
g. Initial/RecurrentI Ground Training and Qualification. Per section 121.629(c)(2), only
exclusively trained and qualified personnel may carry out deicing/anti-icing procedures.
(1) Each certificate holder's approved program must consist of the following:
Par 6 1 Page 9

AC 120-60B 1 12/20/04
I
(a) Certificate holders must conduct initial and annual recurrent training for
flightcrews, dispatchers) and ground personnel and should ensure that all such crews obtain and
retain a thorough knowledge of aircraft ground deicing/anti-icing policies and procedures,
including required procedures and lessons learned.
(b) Flightcrew, dispatcher, and ground personnel training programs must include a
detailed description of in and annual recurrent ground training and qualification concerning
the specific requirements of the program and the duties, responsibilities, and functions detailed in
the program.
(e) Flightcrew, dispatcher, and ground personnel training programs should have a
Quality Assurance Program to monitor and maintain a high level of competence. An ongoing
review plan is advisable to evaluate the effectiveness of the deicing/anti-icing training received.
(d) The program should have a tracking system that records all required personnel
have been satisfactorily trained. Certificate holders shall maintain records of personnel training
and qualification (see Appendix 2) for proof of qualification.
(e) Personnel must be able to adequately read, speak, and understand English in order
to follow written and oral procedures applicable to the deicing/anti-icing program.
I
(f) When the anti -icing fluids are used, the flightcrews should be made aware of any
unusual flying qualities, such as the need for additional takeoff rotation stick -force.
(2) Certificate holders should train and qualify flightcrew, dispatcher, and ground
personnel on at least the following subjects, identified as Flightcrew (F), Dispatcher (D), or
Ground Personnel (G):
I
(a) Effects of Frozen Contaminants on Aircraft Surfaces. Provide an
understanding of the critical effect the presence of minute amounts of frost, ice, or snow has on
flight surfaces. This discussion should include, but is not limited to:
1 Loss of lift.
2 Increasedldrag and weight.
I
3 Decreased control.
4 Tendency for rapid pitch -up and roll -off during rotation (F/D only).
i
5 Stall occurs at lower -than -normal angle of attack (F/D only).
6 Buffet or stall occurs before activation of stall warning (F/D only).
7 Aircraft specific areas:
Page 10 Par 6

12/20/04 AC 120-60B
(aa) Engine foreign object damage potential.
(bb) I am air intakes.
(cc) Instrument pickup points.
(dd) Leading edge device (LED) aircraft (aircraft that have slats or leading
edge flaps) and non -LED aircraft.
I
(cc) Airworthiness Directives/Specific inspections.
(ff) Winglets.
(b) Aircraft Ground Icing Conditions. Describe conditions that cause
implementation of deicing/anti-icing procedures (F/D/G).
I In-flight Ice Accumulation. Certificate holders should have procedures for
flightcrews on arriving flights to report occurrences of in-flight icing to the personnel responsible
for executing the certificate holder's deicing/anti-icing program. In-flight ice accumulation
could result in a ground -deicing situation when flights are scheduled for short turnaround times
(i.e., for 30 minutes or less and when ambient temperatures on the ground are at or below
freezing). j
2 Frost, including hoarfrost.
3 Freezing (precipitation (snow, freezing rain, freezing drizzle, or hail, which
could adhere to aircraft surfaces).
1
4 Freezing fog.
i
1
5 Rain or high humidity on cold soaked wing.
6 Rain or high humidity on cold soaked wing fuel tanks.
i
7 Under -wing frost (may not require deicing/anti-icing within certain limits).
8 Fluid failure identification.
(e) Location speIcific deicing/anti-icing procedures (F/D and/or G, as appropriate).
I
(d) Communications procedures between the flightcrew, ground personnel, ATC,
and company station personnel (F/D/G).
NOTE: Use caution when exercising 3-way communication. They may be
confusing, misleading, or misdirected. Communication procedures must
include ground crew, confirmation to the flightcrew after the deicing and
i
Par 6 Page 11

AC 120-60B
12/20/04
anti -icing process is completed that all personnel and equipment are clear
before reconfiguring or moving the aircraft.
(e) Means foI r obtaining most current weather information (F/D/G).
(f) Characteristics and capabilities of fluids used (F/D/G).
I General fluid descriptions.
2 Composition and appearance.
3 Differenlces between Type I and Type II/IV deicing/anti-icing fluids.
4 Purpose, for each type.
5 Deicingifluids.
I
6 Anti -icing fluids.
i
7 De/anti-icing fluids capabilities.
8 Approved deicing/anti-icing fluids for use (SAE, ISO, etc.).
9 Fluid -specific information provided by fluid or aircraft manufacturer (F/D
and/or G as appropriate).
10 Fluid temperature requirements (Hot vs. Cold).
11 Properties associated with infrared deicing/anti-icing.
(g) Fluid Storage and Handling (G).
1 Fluid storage.
2 Fluid handling.
3 Fluid sampling.
4 Fluid testiig.
(h) Deicing/Anti,-icing Facilities and Equipment Operation Procedures (G). An
understanding of the capabilities of the deicing equipment and the qualifications for operation.
The equipment portion of the training program should include the following:
1 Description of Various Equipment Types:
I
Page 12 Par 6

12/20/04
(aa) Deicing vehicles.
(bb) Infrared facilities.
(cc) Hard stands.
2 OperatiI on of the equipment.
3 Emergency procedures.
(i) Health, Safety, and First Aid (F/D/G).
AC 120-60B
(j) Environmental Considerations (G).
(k) Fluid Selelction (F/D/G).
i
(1) Contractor Deicing/Anti-icing (F/D/G). Train -the -trainer (per the approved
program).
(m) Methods/Procedures (F/D/G).
1 Inspection of critical surfaces.
2 Clear ice precautions.
3 Flightcrew/groundcrew preflight check requirement.
4 Deicing/anti-ice determination.
5 Deicing/anti-ice location.
6 Communication before deicing/anti-icing.
7 General deicing/anti-ice precautions.
8 Aircraft specific requirements.
9 Deicing:
I
(aa) Requirements.
(bb) Effective removal of frost, snow, and ice (G).
I
10 Anti -icing:
(aa)
Par 6

AC 120-60B
(bb) !Preventative anti -icing (G).
(cc) Application (G).
11 Deicing/anti-icing:
(aa) One step.
(bb) Two step.
I
12 Guidelines for the application of deicing/anti-icing fluids.
1
13 Post deicing/anti-icing checks requirement.
I
14 Flight control check.
i
15 Communications after deicing/anti-icing.
16 Use of the deicing/anti-icing log (Appendix 3).
(n) Use of HOTS (F/D/G).
12/20/04
1 Definition of HOT.
2 When HOT begins and ends.
1
3 Limitations and cautions associated with the use of HOTs.
4 Source of HOT data.
I
5 Relationship of HOT to particular fluid concentrations and for different types
of fluids.
i
6 Precipitation category (e.g., fog, drizzle, rain, or snow).
7 Precipitation intensity.
8 How to determine a specific HOT from the HOT range that accounts for
moderate or light weather conditions (F/D).
2 Adjusting HOT for changing weather conditions (F/D).
NOTE: Ground I personnel should receive familiarization training on
determining a specific HOT from the HOT range and adjusting the HOT for
changing weather conditions.
Page 14 Par 6

12/20/04 1 AC 120-60B
(o) Pretakeoff Check Requirement (F/D). Identification of representative surfaces.
(p) Pretakeoff Contamination Check Requirement (F/D/G). Communications.
I
(q) Aircraft Surface Contamination Recognition (F/D/G).
7. OPERATIONS IN LIEU OF AN APPROVED DEICING/ANTI-ICING PROGRAM.
Per section 121.629(d), a certificate holder may continue to operate without an approved ground
deicing/anti-icing program if it has approved procedures and properly trained personnel for
conducting a pretakeoff contamination check. The certificate holder's operations specifications
must contain the authorization for conducting this check in lieu of an approved program. As
stated in section 121.629(d), this check is accomplished when conditions are such that frost, ice,
or snow may reasonably be expected to adhere to the aircraft. The check must be completed
within 5 minutes before beginning takeoff and from outside the aircraft. Certificate holder's
manuals and training programs should detail procedures for accomplishing this check.
I
/s/ Chester B. Dalbey, for
James J. Ballough
Director, Flight Standards Service
Par 6 Page 15

APPENDIX 1. SAMPLE HOLDOVER TIME TABLES
FAA TYPE I HOLDOVER TIME GUIDELINE
TABLE 1. GUIDELINE FOR HOLDOVER TIMES ANTICIPATED FOR SAE TYPE I FLUID MIXTURE AS A FUNCTION OF WEATHER
CONDITIONS AND OAT.
CAUTION: THIS TABLE IS FOR USE IN DEPARTURE PLANING ONLY AND SHOULD BE USED IN CONJUNCTION WITH PRE -TAKEOFF CHECK PROCEDURES.
Approximate Holdover Times Under Various Weather Conditions
OAT
(hour :minutes)
°C
OF
Frost`
Freezing
Light
-Drizzle Freezin9
Light
Freezing.
on
--Other*- -
Snow"
__
_ --
- --Soaked
WinRain
g-
_---
--Snow—**
Rain
above
above
CAUTION:
0:45
0:11-0:17
0:11-0:16
0:06-0:11
0:09-0:13
0:02-0:05
0:02-0:05
No
3
27
holdover
CAUTION:
time
-3 to -6
27 to 21
0:45
0:08 - 0:14
0:08 - 0:13
0:05 - 0:08
0:07 - 0:10
0:02 - 0:05
Clear ice may
require touch
guidelines
exist
-7 to -10
20 to 14
0:45
0:06 - 0:10
0:06 - 0:10
0:04 - 0:06
0:05 - 0:08
0:02 - 0:05
for confirmation
below
below 14
4� v
-10
0:45
0:05-0:09
0:04-0:06
0:02-0:04
,-ys
°C = Degrees Celsius
OF = Degrees Fahrenheit
OAT = Outside Air Temperature
FP = Freezing Point
THE RESPONSIBILITY FOR THE APPLICATION OF THESE DATA REMAINS WITH THE USER.
During conditions that apply to aircraft protection for ACTIVE FROST
Use light freezing rain holdover times if positive identification of freezing drizzle is not possible
$ Heavy snow, snow pellets, ice pellets, moderate and heavy freezing rain, hail
•• TO USE THESE TIMES, THE FLUID MUST BE HEATED TO A MINIMUM TEMPERATURE OF 60°C (140°F) AT THE NOZZLE AND AT
LEAST 1 LITER/M' (= 2 GALS/100FT2) MUST BE APPLIED TO DEICED SURFACES
SAE Type I fluid/water mixture is selected so that the FP of the mixture is at least 10 °C (18 °F) below OAT.
CAUTIONS:
• THE TIME OF PROTECTION WILL BE SHORTENED IN HEAVY WEATHER CONDITIONS. HEAVY PRECIPITATION RATES OR HIGH MOISTURE CONTENT, HIGH
WIND VELOCITY OR JET BLAST WILL REDUCE HOLDOVER TIME BELOW THE LOWEST TIME STATED IN THE RANGE. HOLDOVER TIME MAY BE REDUCED
WHEN AIRCRAFT SKIN TEMPERATURE IS LOWER THAN OAT.
• SAE TYPE I FLUID USED DURING GROUND DEICING/ANTI-ICING IS NOT INTENDED FOR AND DOES NOT PROVIDE PROTECTION DURING FLIGHT.
Effective: October 1, 2002

o
a
c
M
APPENDIX 1. SAMPLE HOLDOVER TIME TABLES (CON'T)
FAA TYPE II HOLDOVER TIME GUIDELINE
TABLE 2 - Guideline for Holdover Times Anticipated for SAE Type II Fluid Mixtures as a Function of Weather Conditions and OAT
CAUTION: THIS TABLE IS FOR USE IN DEPARTURE PLANNING ONLY, AND IT SHOULD BE USED IN CONJUNCTION WITH PRE -TAKEOFF CHECK PROCEDURES.
OAT
SAE Type II Fluid
Concentration
Approximate Holdover Times under Various Weather Conditions (hours: minutes)
°C
°F
Frost*
Freezing Fog
Snow*
Freezing
Light Freezing
Rain on Cold
Others
Neat-Fluid/Water
Drizzle***
Rain
Soaked Wing
ol.YNol. h
100/0
12:00
0:35-1:30
0:20-0:55
0:30-0:55
0:150:30
0:05-0:40. _
CAUTION: --
above 0
above 32-
75/25 --
- -6:00- -
- 025-1:00
0:15-0:40
0:20-0:45
0,10-025
0:05-0:25
No holdover
_
50/50
4:00
0:15-0:30
0:05-0:15
0:05-0:15
0:05-0:10
CAUTION:
Clear ice
time guidelines
exist
100/0
8:00
0:35-1:30
0:20-0:45
0:30-0:55
0:15-0:30
0 to -3
32 to 27
75125
5:00
0:25-1:00
0:15-0:30
0:20-0:45
0:10.0:25
may require
50/50
3:00
0:15-0:30
0:05-0:15
0:05-0:15
0:05-0,10
touch for
confirmation
below
below
10010
8:00
0:20-1:05
0:15-0:35
••0:15-0:45
'•0:10-0:25
75125
5:00
0:20-0:55
0:15-0:25
•'0:15-0:30
••0:10-0:20
-3 to -14
27 to 7
g.-1
below
below
10010
8:00
0:15-0:20
0:15-0 30
-14 to-25
7 to-13
AE Type II fluid maybe used below -25 °C (-13 °F) provided the freezing point of the fluid is at least 7 °C (13 °F) below the OAT
below
below
100/0
nd the aerodynamic acceptance criteria are met. Consider use of SAE Type I when SAE Type II fluid cannot be used.
-25
-13
°C = Degrees Celsius OAT = Outside Air Temperature
°F = Degrees Fahrenheit VOL = Volume
THE RESPONSIBILITY FOR THE APPLICATION OF THESE DATA REMAINS WITH THE USER.
During conditions that apply to aircraft protection for ACTIVE FROST
No holdover time guidelines exist for this condition below -10 'C (14 °F)
Use light freezing rain holdover times if positive identification of freezing drizzle is not possible
Snow pellets, ice pellets, heavy snow, moderate and heavy freezing rain, hail
Snow includes snow grains
CAUTIONS:
THE TIME OF PROTECTION WILL BE SHORTENED IN HEAVY WEATHER CONDITIONS. HEAVY PRECIPITATION RATES OR HIGH MOISTURE
CONTENT, HIGH WIND VELOCITY OR JET BLAST MAY REDUCE HOLDOVER TIME BELOW THE LOWEST TIME STATED IN THE RANGE. HOLDOVER
TIME MAY BE REDUCED WHEN AIRCRAFT SKIN TEMPERATURE IS LOWER THAN OAT.
• SAE TYPE 11 FLUID USED DURING GROUND DEICING/ANTI-ICING IS NOT INTENDED FOR AND DOES NOT PROVIDE PROTECTION DURING FLIGHT.
NOTE: Type III fluids are no longer used in the United States. Therefore, Table 3 is currently not offered.
v n
a. o
X tT
E9
N
tJ
O
O
A

APPENDIX 1. SAMPLE HOLDOVER TIME TABLES (CON'T)
FAA TYPE IV HOLDOVER TIME GUIDELINE
TABLE 4 - Guideline for Holdover Times Anticipated for SAE Type IV Fluid Mixtures as a Function of Weather Conditions and OAT.
CAUTION: THIS TABLE IS FOR USE IN DEPARTURE PLANNING ONLY, AND IT SHOULD BE USED IN CONJUNCTION WITH PRE -TAKEOFF CHECK PROCEDURES.
OAT
SAE Type IV Fluid
Concentration Neat-
kpproximateHoldover Times under Various Weather Conditions (hours: minutes)
'C
T
Frost*
Freezing Fog
Snow*
Freezing
Light Freezing
Rain on Cold
Other'
Fluid/Water
Drizzle—
Rain
Soaked Wing
(Vol. %Not. %)
100/0
18:00
1:05-2:15
0:35-1:05
0:40.1:10
0:25-0:40
0:10-0:50
. above 0-
-above 32 -
- —-75/25- -
6:00-
1.05-1:45
0:30-1:05
0:35-0:50
0:15-0:30
0:05-0:35
CAUTION:
50/50
400
0:15-0:35
0:05-0:20
0:10-0:20
0:05-0:10
CAUTION:
Clear ice
No holdover
time guidelines
100/0
12:00
1:05-2:15
0:30-0:55
0:40-1:10
0:25-0:40
75/25
5:00
1:05-1:45
0:25-0:50
0:35-0:50
0:15-0:30
0 to -3
32 to 27
may require
exist
50/50
3:00
0:15-0:35
0:05-0:15
0:10-0:20
0:05-0:10
touch for
confirmation
below
below
10010
12:00
0:20-1:20
0:20-0:40
"0:20-0:45
"0:10-0:25
75/25
5:00
0:25-0:50
0:15-0:25
"0:15-0:30
--0:10-0:20
-3 to -14
27 to 7
below
below
100/0
12:00
0:15-0:40
0:15-0:30
-
- Fesvy
,nr'fg�
-14 to-25
7 to-13
Y r='
- - -
below -25
below -13
10010
SAE Type IV fluid maybe used below -25'C (-13 "F) provided the freezing point of the fluid is at least 7 °C(13 °F) below
he OAT and the aerodynamic acceptance criteria are met. Consider use of SAE Type I when SAE Type IV fluid cannot
e used.
'C = Degrees Celsius OAT = Outside Air Temperature
`F = Degrees Fahrenheit VOL = Volume
THE RESPONSIBILITY FOR THE APPLICATION OF THESE DATA REMAINS WITH THE USER.
During conditions that apply to aircraft protection for ACTIVE FROST
No holdover time guidelines exist for this condition below -10 'C (14 'F)
Use light freezing rain holdover times if positive identification of freezing drizzle is not possible
$ Snow pellets, ice pellets, heavy snow, moderate and heavy freezing rain, hail
Snow includes snow grains
CAUTIONS:
• THE TIME OF PROTECTION WILL BE SHORTENED IN HEAVY WEATHER CONDITIONS. HEAVY PRECIPITATION RATES OR HIGH MOISTURE CONTENT,
HIGH WIND VELOCITY OR JET BLAST MAY REDUCE HOLDOVER TIME BELOW THE LOWEST TIME STATED IN THE RANGE. HOLDOVER TIME MAY BE
REDUCED WHEN AIRCRAFT SKIN TEMPERATURE IS LOWER THAN OAT.
• SAE TYPE IV FLUID USED DURING GROUND DEICING/ANTI-ICING IS NOT INTENDED FOR AND DOES NOT PROVIDE PROTECTION DURING FLIGHT.
Effective: Octoberl, 2002
Ma
r

12/20/04 AC 120-60B
Appendix 2
APPENDIX 2. AIRCRAFT DEICING/ANTI-ICING TRAINING ROSTER
i
AIRCNAFTDEICINGIANTNCING TRAINING ROSTER.
LOCATION =. - :COURSENUMBER,: -
MINT) ClA55fftUg7dfi
a
k
NAME,
SIGNAWOEt 9GHATUL ..
EMVLCIYEE't UMBER ... . EWLafEE WINGER .. ..
Page 1 (and 2)

12/20/04
APPENDIX 3. STATION DEICING/ANTI-ICING FORM
STATION DEICINGIANT14CING FORM
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AC 120-60B
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THE DgFOR67am BV COW MHStY1TH BOLD OVTUNE MIKT BE COMMUNICATEDTOFLWAff CREW
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Page 1 (and 2)

9/8/2008
AC 150/5320-15A
CHAPTER 8. MANAGEMENT OF DE/ANTI-ICING CHEMICAL WASTES
8.1. GENERAL GUIDANCE. The Airport Cooperative Research Program (ACRP) funded by the
FAA, developed ARCP Report #11, Managing Runoff from Aircraft and Airfield Deicing and Anti -
Icing Operations, in response to a need the airport industry identified for planning guidelines to assist
airport and aircraft operators in identifying and selecting best management practices (BMPs) for
controlling aircraft and airfield deicing runoff. Aircraft operators are included in this target audience
because of their role as key, participants and stakeholders in any decisions that may affect aircraft safety
or operations. This introductory section presents background on the origins and drivers behind this
research project, describes the purpose and objectives of this document, and explains the structure of the
planning guidance. Subsequent sections present guidelines for developing integrated deicing runoff
management systems (Section 2), guidance for evaluating and selecting individual BMPs (Section 3), and
fact sheets describing each of the BMPs (Section 4). ACRP Project Report #11 is available at -
http: //www.trb.org/news/blurb_browse. asp? i d=13 6.
8.2. AIRCRAFT DEICING FACILITIES. The operation of off -gate aircraft deicing facilities is a
proven effective means for managing sprayed aircraft deicing/anti-icing fluids that do not remain on the
aircraft. In general, aircraft deicing facilities consist of a two or more deicing pads, a drainage collection
system, and a wastewater storage facility. At some airport locations, airport operators employ the use of
infra -red technology to reduce the qualities of ADFs sprayed to deice aircraft. It is noted that infra -red is
only used during the deicing phase. The anti -icing of any aircraft still requires the spraying of an
appropriate aircraft anti -icing fluid. For design of traditional and infra -red facilities, please see AC
150/5300-14, Design ofAircraft Deicing Facilities.
8.3. RUNWAY SURFACE CONDITION MONITORING SYSTEMS One effective mean of
preventing unnecessary application of pavement deicing/anti-icing agents is using runway surface
condition monitoring systems. These devices measure the change in pavement temperature with some
units providing surface condition and atmospheric weather conditions. By enabling airport maintenance
staff to monitor continuously runway surface conditions, maintenance staff can predict freezing
conditions by tracking changes in pavement temperature and apply new or additional pavement deicers in
a timely manner. See AC 150/5200-30 for surface condition sensor specifications.
8.4. LAGOONS AND RETENTION PONDS. Conversion of suitable unused airport land into
lagoons or retention ponds pe6its collection of large volumes of glycol -based fluid waste from pavement
surface runoff.
8.4.1. Capacity. The minimum design capacity handles at least the surface runoffs for winter months
because microbial activity needed for biodegradation decreases during the winter season, plus incorporate
additional capacity for the thawing periods. Required oxygen could be provided by mechanical aeration
or photosynthesis, although there would also be a decrease in algal growth during cold weather. Capacity
requirements can be reduced by continuous aeration that allows for faster biodegradation and, thus, earlier
release of glycol -based fluid waste. Additionally, lagoons of this type could also stabilize and pre -treat
glycol -based fluid waste prior to discharge to a wastewater treatment plant.
8.4.2. Configuration. An 'acceptable configuration for any retention basin is one that is easily
defensible from a wildlife standpoint. Square or circular retention basins are not recommended as they
are attractive to birds, and waterfowl will seek the safety of a pond's center to escape harassment
activities. Hence, linear retention basins are recommended since they facilitate wildlife harassment and, if
21

AC 150/5320-15A
9/8/2008
necessary, permit easier covering of the basin. As concentrated glycol is toxic to wildlife, covering may
be necessary to prohibit any wildlife use. Fencing is recommended whenever potentially hazardous
compounds are stored in open areas.
22

S n10 tT P P r�e d,-L
From: Basinger, Carey
Sent: Friday, May 14, 2010 8:27 AM r
To: Larsen, Cory
Cc: Pickle. Ken
Subject RE: PTIA Final Permit
I am on board with your draft permit language.
Advise if it changes again.
Thanks for the update.
CB
Corey Basinger, Environmental Engineer
[e-mail]
NC DENR Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
[phone]
Fax [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Larsen, Cory
Sent: Thursday, May 13, 2010 4:23 PM
To: Basinger, Corey
Cc: Pickle, Ken
Subject: PTIA Final Permit
Corey,
I wanted to give you a chance to read through PTAA's response/additional information letter to the last meeting we had
in March and make sure you are onboard with the structure of the final permit.
In short, Ken and I have agreed to their rewrite of Tiers but rejected their request to eliminate BOD/COD benchmarks.
We think the first action takes care of the second request primarily because we've tied DWQ's heavy hitting (requiring
structural controls, $12M containment pads, etc) to WQS violations rather than benchmark exceedances and we know
there is no BOD or COD WQS and weidon't foresee DO WQS violations based on what we've seen so far
We'll be responding to their arguments for BOD/COD removal in the permit issuance letter but none were compelling
enough to go that route. We think MIS is a fair compromise. What are your thoughts? '
Cory Larsen
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NCI 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax:[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

L N// prtA Atry-
From:
Bill Cooke [wocilbelisouth,netp
Sent:
Sunday, May 30, 20,0 9:05 PM
To:
Larsen, Cory
Subject:
Re: Piedmont Tried Airport AutboI nty- NPCES Stormwater Permit NCS000508
Thanks Cory. I'll check with the otheri s on our end and get back in touch with you on Tuesday about setting up a call.
Bill
----- Original Message -----
From: Larsen, Cory
To: Bill Cooke
Cc: Pickle, Ken ; Basinger, Corey; Bennett, Bradley
Sent: Friday, May 28, 2010 2:29 PM
Subject: RE: Piedmont Triad Airport Authority - NPDES Stormwater Permit NCS000508
■M
Thanks for your comments. We really appreciate your clarity on the arguments under consideration, and the
professional and straightforward approach that PTAA and their support team have taken with us in the development of
the draft permit. We're encouraged that our dialogue continues and specifically request a voice -to -voice discussion
with you (and any others that wish to participate) on Tuesday or soon thereafter in response to your email. In the
mean time, please see our underlineI d responses inserted into your email below in parentheses
Cory
From: Bill Cooke [mailto:[e-mail]]
Sent: Thursday, May 27, 2010 5:01 PM
To: Larsen, Cory
Cc: [e-mail]; Kevin Baker; Mickie Elmore; [e-mail]; [e-mail]
Subject: Piedmont Triad Airport Authority - NPDES Stormwater Permit NCS000508
Cory,
We have discussed the revised permit on our end and have a few additional comments.
On the issue of whether BOD/COD bl nchmarks should be retained, we think there may have been a misunderstanding.
Your letter suggests that PTAA proposes to eliminate BOD/COD monitoring in addition to the elimination of the
BOD/COD benchmarks.
in bur
However, as we staled in our most recent letter, PTAA has no objection to the BOD/COD monitoring.
(We understand. Our apologies for inadvertently obscuring the issue.)
Our only objection is to the establishment of the benchmark values that would require PTAA to proceed with the tiered
response steps when it appears that an exceedence of the proposed BOD/COD benchmarks has no correlation with any
violation of the DO standard in the receiving streams.

We contend that the discharge of pollutants above benchmark levels should still be a prompt for PTAA to investigate
economically feasible and environmentally effective responses to reducing the pollutant discharge whether there is a
water quality standard violation, or not. Please note, North Carolina environmental law and rules have not established
water quality standards for many, many common pollutants including BOD and COD We do not consider that the
absence of an established water quality standard allows the unregulated discharge of pollutants Further, we have
agreed to substantially accommodate PTAA already on the closely related point of the language in the Tiered boxes and
stated concern was the potential for inappropriate heavy-handedness by DWQ in requiring extraordinarily costly and
infeasible, and environmentally inconsequential remedial measures based on BOD/COD benchmark exceedances As
you requested, we specifically accepted your re -write of the key language on this point to satisfy your concerns It
remains difficult for us to get past the characterization of "Yes we're discharging BOD/COD pollution above the
benchmark levels applicable to other sites in North Carolina no we don't want to have a numerical benchmark that
might help our management ascertain at what level/concentration economicaliv feasible, non-structural response
actions should be investigated.'
As you recognized in your response to our letter, the governing standard is the DO level.
We have not recognized this principle that DO governs. More accurately, and consistent with our intent verball
expressed in our face-to-face meeting with you and with the permittee we have accommodated PTAA by accepting
your re -write of the permit language to address PTAA's expressed concern that DWQ might inappropriately require
economically infeasible and environmentally inconsequential responses to BOD/COD benchmark exceedances At your
request, we have adopted your language that specifically ties the potential for costly structural control measures to a
violation of the DO water quality standard, and not to any BOD/COD benchmark exceedance )
This standard is enforced through the DO benchmark. For all the reasons stated in our letter, there does not appear to be
any necessity for adding the BOD/COD benchmarks which, in the absence of any DO violation, would cause a false
alarm;
(Again, we contend that a benchmark associated with the BOD/COD testing (that you are already agreeable to) is a
necessary reference point. Without a benchmark, how else will there be any prod or basis for the permittee to
investigate, based on monitoring results, whether there are any economically feasible response actions available to the
permittee? A benchmark is a necessary adjunct to the testing. You're agreeable to the testing; in accepting your re-
write of the Tiered boxes language we have de -coupled any potential BOD/COD benchmark exceedances from what
PTAA may consider the infeasible costly structural controls that you have reported as your primary concern. By our
acceptance of your re -write of the Tier language, it seems to us that your client has his assurance already that DWQ
will not irresponsibly seek an economically infeasible and environmentally inconsequential response action based on
BOD and COD exceedances.)
and if there is a violation, would add nothing to the action that would have to be taken anyway if PTAA has either caused
or contributed to the problem.
(In the context of this discussion, if there is a water quality violation we expect it will be for violation of the DO water
quality standard. On the presumed occasion of that DO violation PTAA would be expected to consider feasible options
including the potentially very costly structural responses that have been identified as only appropriate in the event of a
DO violation (i.e., not triggered by a BOD/COD benchmark exceedance.) Assuming that a winter -time DO water quality
standard violation might one day occur, wouldn't it have been better to have avoided those costly structural measures
by implementing the cheaper, economically feasible, non-structural measures that might have been identified and
implemented as part of prior BOD/COD response actions? It seems to us that the implementation of relatively low-cost
management responses to BOD and COD might help PTAA avoid substantially greater costs that might be indicated in
response to a DO water quality standard violation.)

I
PTAA continues to believe that the BOD/COD benchmarks proposed in the draft permit are unwarranted, but never
meant to suggest theat BOD/COD monitoring should be eliminated from the permit.
(We understand. And again, we apologize for inadvertently obscuring the issue.)
1
In this respect, the treatment of BOD/COD during de-icing events would be the same as propylene glycol - the levels
would be monitored but no benchmarks would be set in the permit that could potentially require PTAA to work through
the tiered response program when no DO problem exists.
written the permit text language to allow us the freedom of relieving the permittee's extra sampling burden, whether
were anal ous.
6
Three other comments:
i
(Thanks Bill for the clean-up. We will make these changes below.)
I
Footnote 2 of Table 3: We would suggest substituting the term "representative storm event" for "discharge." We assume
this is what DWQ intends.
PART II, Sect A, 1(e): In the second to, last sentence, change "Paragraph 5" to "Paragraph 3."
PART II, Sect A, 7: Same, last sentence.
i
Given the thorough exchange of viewslthat has already taken place, we see no need for a further telephone conference
tomorrow morning and will not plan to call unless I hear from you. We appreciate DWQ's consideration of our comments
to date and ask for your favorable consideration of our final comments, as set forth above.
(Please consider this written response our refreshed request for a voice -to -voice communication on the key issue of
benchmarks for BOD and COD.)
Regards,
:31u

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Larsen, Cory
From: Bill Cooke [[e-mail]]
Sent: Thursday, May 27, 2010 5,01 PM
To: Larsen, Cory i
Cc: Ted@gsoaioorg; Kevin Baker; Mickie Elmore; GHOUSE@brookspierce. com; [e-mail]
Subject Piedmont Triad Airport Authority - NPDES Stormwater Permit NCS000508
Cory,
We have discussed the revised permit on our end and have a few additional comments.
On the issue of whether BOD/COD benchmarks should be retained, we think there may have been a misunderstanding.
Your letter suggests that PTAA proposes to eliminate BOD/COD monitoring in addition to the elimination of the BOD/COD
benchmarks. However, as we stated in our most recent letter, PTAA has no objection to the BOD/COD monitoring. Our
only objection is to the establishment of the benchmark values that would require PTAA to proceed with the tiered
response steps when it appears that an exceedence of the proposed BOD/COD benchmarks has no correlation with any
violation of the DO standard in the receiving streams. As you recognized in your response to our letter, the governing
standard is the DO level. This standard is enforced through the DO benchmark. For all the reasons stated in our letter,
there does not appear to be any necessity for adding the BOD/COD benchmarks which, in the absence of any DO
violation, would cause a false alarm; and if there is a violation, would add nothing to the action that would have to be
taken anyway if PTAA has either caused or contributed to the problem.
PTAA continues to believe that the BOD/COD benchmarks proposed in the draft permit are unwarranted, but never meant
to suggest theat BOD/COD monitoring should be eliminated from the permit. In this respect, the treatment of BOD/COD
during de-icing events would be the same as propylene glycol - the levels would be monitored but no benchmarks would
be set in the permit that could potentially require PTAA to work through the tiered response program when no DO problem
exists.
Three other comments:
Footnote 2 of Table 3: We would suggest substituting the term "representative storm event" for "discharge." We assume
this is what DWQ intends.
PART II, Sect A, 1(e): In the second to last sentence, change "Paragraph 5" to "Paragraph 3."
PART II, Sect A, 7: Same, last sentence.
Given the thorough exchange of views that has already taken place, we see no need for a further telephone conference
tomorrow morning and will not plan to call unless I hear from you. We appreciate DWQ's consideration of our comments
to date and ask for your favorable consideration of our final comments, as set forth above.
Regards,
Bill

Larsen, Cory
From: BIII Cooke [[e-mail]
Sent: Monday, May 24, 2010 4:13 PM
To: Lersen, Cory
Subject: Re: Final Permit ReNew - PTM - NCS000508
9 AM is fine for us. What number should we call?
----- Original Message -----
From: Larsen, Cory
To: Bill Cooke
Sent: Monday, May 24, 2010 2108 PM
Subject: RE: Final Permit Review - PTAA - NCS000508
Bill, we can do 9am on Friday.
Cory
From: Bill Cooke [mailto:[e-mail]]
Sent: Monday, May 24, 2010 12:47 PM
To: Larsen, Cory
Subject: Re: Final Permit Review - PTAA - NC5000508
Cory,
The only date I can get everyone together on our end is Fri. If that works on your end, please let me know what time
would be convenient for you.
Thanks
Bill
----- Original Message -----
From: Larsen. Cory
To: wocirCQbellsouth.net
Sent: Thursday, May 20, 2010 3:45 PM
Subject: RE: Final Permit Review - PTAA - NCS000508
an
Got your message regarding tomorrow. Next week we have Mon, Tues, Wed and Fri mornings available. I'll assume
Monday morning is no good based on your message so let me know which of the remaining days works best for you
and we'll set it up then.
Cory
From: Larsen, Cory
Sent: Wednesday, May 19, 2010 4:03 PM
To: 'wocirCalbellsouth.net'
Cc: Pickle, Ken; Bennett, Bradley
Subject: Final Permit Review - PTAA - NCS000508
Dear Mr. Cooke:
Please find attached an advance Draft copy of the final permit and issuance letter for your review. We plan on issuing
the final permit shortly and would like to offer you an opportunity to review and provide feedback before final

issuance. We're available this Friday morning if you'd like to have a telephone conversation regarding the changes.
Please let me know if 10 am or another time would be convenient for you.
Cory Larsen
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, INC 27699-1617
512 N. Salisbury St, Raleigh, INC 27604
Phone: [phone]
Fax:[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

NCS000508
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUA �
/P S�
TO DISCHARGE STORMWATER.UNDER THE
In compliance with the provisi6ns,ofNorth Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission,
%and,,tfid-FeehrahWater Pollution Control Act, as amended,
(� ))V"
PIEDMONT'TRIAD AIRPORT AUTHORITY
is hereby authorized to discharge stormwater from a facility located at
Piedmont Triad International Airport
6415 Bryan Blvd.
Greensboro, NC
Guilford County
to receiving waters designated as Brush Creek, Horsepen Creek, and East Fork Deep River, class
WS-II1; NSW and WS-IV streams in the Cape Fear River Basin, in accordance with the
discharge limitations, monitoring requirements, and other conditions set forth in Parts I, 11, III,
IV, V and VI hereof.
This permit shall become effective June I, 2010.
This permit and the authorization to discharge shall expire at midnight on May 31, 2015.
Signed this day, May 21, 2010.
for Coleen H. Sullins Director
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit No. NCS000508
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B: Routine Analytical Monitoring Requirements
Section C: Qualitative Monitoring Requirements
Section D: De -Icing Event Analytical Monitoring Requirements
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL
PERMITS
Section A: Compliance and Liability
1. Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
5. Oil and Hazardous Substance Liability
6. Property Rights
7. Severability
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
Section B: General Conditions
1. Individual Permit Expiration
2. Transfers
0

Permit No. NCS000508
3. Signatory Requirements
4. Individual Permit Modification, Revocation and Reissuance, or
Tennination
5. Permit Actions
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
1.
Representative Sampling
2.
Recording Results
3.
Flow Measurements
4.
Test Procedures
5.
Representative Outfall
6.
Records Retention
7.
Inspection and Entry
Section E: Reporting
Requirements
1.
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
5.
Planned Changes
6.
Anticipated Noncompliance
7.
Spills
8.
Bypass
9.
Twenty-four Hour Reporting
10.
Other Noncompliance
11.
Other Information
PART IV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS and SPECIAL CONDITIONS
ii

Permit No. NCS000508
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee and co-permittees listed on the following page are authorized to discharge stormwater
associated with industrial activity. Such discharges shall be controlled, limited and monitored as
specified in this permit. Discharges covered in this permit are the stormwater discharges from
the current airport operations (001 through 066) as well as additional stormwater discharge
points that may be created by further modification or expansion of airport operations.
Current discharges 001 through 012 and 038 through 040 discharge to Horsepen Creek. Current
discharges 013 through 019 discharge to East Fork Deep River. Current discharges 020 through
037 and 041 through 066 discharge to Brush Creek.
SECTION B: PERMITTED ACTIVITIES
Until this permit expires or is modified or revoked, the permittee and co-permitees are authorized
to discharge stormwater to the surface waters of North Carolina or separate storm sewer system
that has been adequately treated and managed in accordance with the terms and conditions of this
individual permit. All stormwater discharges shall be in accordance with the conditions of this
permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization, or approval.
Stormwater discharges allowed by this individual permit shall not cause or contribute to
violations of Water Quality Standards.
This permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
Part I Page 1 of 2

Permit No. NCS000508
Co-Permittees
Alamo/National Car Rental
Jetstream Ground Services, Inc.
Allegiant Air
Koury Aviation
American Eagle
Landmark Aviation
Atlantic Aero
Lincoln Financial
Aviation Repair Technologies
Marriot Hotel
Avis Rent A Car
Northwest Airlines
Budget Rent a Car
Piedmont Triad Airport Authority
Carolina Aircraft
Piedmont Triad ARFF Station/Command Ctr.
Cessna Citation Service Center
Premier Transportation
Champion Cartage
Prime Flight Services
Chatauqua Airlines
Quantem Aviation Services, Inc.
COMAIR Hangar
Quickflight Services
Continental Airlines
Smartecarte
Delta Airlines
TIMCO
Delta Global Services
Tradewinds
DHL
Triad Transportation
Dollar/Thrifty Rental Car
United Express
Enterprise Rental Car
United Parcel Service
FAA
US Airways
FedEx
US Postal Service
GTCC Aviation Center
USA Parking Valet
Hertz Rent A Car
VF Corporation
Honda Aircraft Company
Worldwide Flight Services
Jetstream Air, LLC
Part I Page 2 of 2

SECTION C: LOCATION MAP Permit No. NCS000508
NCS000508
Map Scale 1:30,000
Piedmont Triad Airport Authority
Piedmont Triad International Airport
Lab tude: 360 06' 24" N
Longitude: 790 56' 31" W
County: Guilford
Receiving Streams: Horsepen Cr, Brush Cr, E Fork Deep
Stream Class: WS-III; NSW, WS-III; NSW, WS-IV
Sub -basin: 03-06-02 (Cape Fear River Bagn)
U6I +r 'l
/
rsa �+�ty.
Facility Location

Permit No. NCS000508
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The Permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part Ill, Standard
Conditions, Section E, Paragraph 3 of this individual permit. The Plan shall include, at a
minimum, the following items:
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
stormwater discharges. The site plan shall contain the following:
(a) 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, the name of the receiving water(s) to which the stormwater
outfall(s) discharges, or 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. The general location
map (or alternatively the site map) shall identify whether each receiving water is
impaired (on the state's 303(d) list of impaired waters) or is located in a
watershed for which a TMDL has been established, and what the parameter(s)
of concern are.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices. A narrative description of the potential pollutants which
could be expected to be present in the stormwater discharge from each outfall.
(c) A site map drawn to scale (including a distance legend) showing: the site property
boundary, the stormwater discharge outfalls, all on -site and adjacent surface
waters and wetlands, industrial activity areas (including storage of materials,
disposal areas, process areas, loading and unloading areas, and haul roads), site.
topography, all drainage features and structures, drainage areas for each outfall,
direction of flow in each drainage area, industrial activities occurring in each
drainage area, buildings, existing BMPs, and impervious surfaces. The site map
must indicate the percentage of each drainage area that is impervious.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the three (3) previous years and any corrective actions taken to mitigate
spill impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
Pan 11 Page 1 of 13

Permit No. NCS000508
accordance with the requirements found in Part III, Standard Conditions, Section
B, Paragraph 5. The permittee shall re -certify annually that the stormwater
outfalls have been evaluated for the presence of non-stormwater discharges.
2. Stormwater Management Plan. The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
nonstructural measures. The stormwater management plan, at a minimum, shall
incorporate the following:
(a) Feasibility Study. A review of 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 practical, the permittee shall
prevent exposure of all storage areas, material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is
not practical, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
(b) Secondary Containment Requirements and Records. Secondary containment is
required for: bulk storage of liquid materials; storage in any amount of Section
313 of Title III of the Superfund Amendments and Reauthorization Act (SARA)
water priority chemicals; and storage in any amount of hazardous substances, in
order to prevent leaks and spills from contaminating stormwater runoff. A table
or summary of all such tanks and stored materials and their associated secondary
containment areas shall be maintained. If the secondary containment devices are
connected to stormwater conveyance systems, the connection shall be controlled
by manually activated valves or other similar devices (which shall be secured
closed with a locking mechanism), and any stormwater that accumulates in the
containment area shall be at a minimum visually observed for color, foam, outfall
staining, visible sheens and dry weather flow, prior to release of the accumulated
stormwater. Accumulated stormwater shall be released if found to be
uncontaminated by any material. 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.
(c) BMP Summary. A listing of site structural and non-structural Best Management
Practices (BMP) shall be provided. The installation and implementation of BMPs
shall be based on the assessment of the potential for sources to contribute
significant quantities of pollutants to stormwater discharges and data collected
through monitoring of stormwater discharges. The BMP Summary shall include a
written record of the specific rationale for installation and implementation of the
selected site BMPs. The BMP Summary shall be reviewed and updated annually.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or the team) responsible for implementing
Part 11 Page 2 of 13

Permit No. NCS000508
the SPRP shall be identified in a written list incorporated into the SPRP and signed and
dated by each individual acknowledging their responsibilities for 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, an oil Spill
Prevention Control and Countermeasure plan (SPCC) 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 SPCC with the SPRP may be incorporated by reference into the
SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance and good housekeeping program shall be developed. The program shall list
all stormwater control systems, stormwater discharge outfalls, all on -site and adjacent
surface waters and wetlands, industrial activity areas (including material storage areas,
material handling areas, disposal areas, process areas, loading and unloading areas, and
haul roads), all drainage features and structures, and existing structural BMPs. The
program shall establish schedules of inspections, maintenance, and housekeeping
activities of stormwater control systems, as well as facility equipment, facility areas, and
facility systems that present a potential for stormwater exposure or stormwater pollution.
Inspection of material handling areas and regular cleaning schedules of these areas shall
be incorporated into the program. Timely compliance with the established schedules for
inspections, maintenance, and housekeeping shall be recorded in writing and maintained
in the SPPP.
5. Employee Training. Training programs shall be developed and training provided at a
minimum on an annual basis for facility personnel with responsibilities for: spill response
and cleanup, preventative maintenance activities, and for any of the facility's operations
that have the potential to contaminate stormwater runoff. Facility personnel (or team)
responsible for implementing the training shall be identified, and their annual training
shall be documented by the signature of each employee trained.
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s) responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
7. Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance which has a significant effect on the
potential for the discharge of pollutants to surface waters. All aspects of the
Stormwater Pollution Prevention Plan shall be reviewed and updated on an annual
basis. The annual update shall include an updated list of significant spills or leaks of
pollutants for the previous three years, or the notation that no spills have occurred. The
annual update shall include written re -certification that the stormwater outfalls have been
evaluated for the presence of non-stormwater discharges. Each annual update shall
include a documented re-evaluation of the effectiveness of the BMPs listed in the BMP
Summary of the Stormwater Management Plan.
Part 11 Page 3 of 13

Permit No. NCS000508
The Director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part Ill, Standard Conditions, Section B, Paragraph 5) to the Director that the changes
have been made.
8. Facility Inspections. Inspections of the facility and all stormwater systems shall occur as
part of the Preventative Maintenance and Good Housekeeping Program at a minimum on
a semi-annual schedule, once during the first half of the year (January to June), and once
during the second half (July to December), with at least 60 days separating inspection
dates (unless performed more frequently than semi-annually). These facility inspections
are different from, and in addition to, the stormwater discharge characteristic monitoring
required in Part II B and C of this permit.
9. Implementation. The permittee shall implement the Plan. Implementation of the Plan
shall include documentation of all monitoring, measurements, inspections, maintenance
activities, and training provided to employees, including the log of the sampling data and
of actions taken to implement BMPs associated with the industrial activities, including
vehicle maintenance activities. Such documentation shall be kept on -site for a period of
five years and made available to the Director or the Director's authorized representative
immediately upon request.
Part 11 Page 4 of 13

Permit No. NCS000508
SECTION B: ROUNTINE ANALYTICAL MONITORING REQUIREMENTS
Routine analytical monitoring of stormwater discharges shall be performed at each selected
representative stormwater discharge outfall (SDO), as noted in Table 1, and as specified in
Table 2. All routine analytical monitoring shall be performed during a representative storm
event.
Table 1. Representative Outfall Identification
Representative SDO
Re 'resentative of Outfalfs:
004
003, 004, 005, 008, 013, 017, 018, 019, 020, 038, 039
006
006, 007, 016
016A
009, 010, 011, 012, 014, 015, 016A, 021, 022, 023
024 and 026
001, 002, 024, 025, 026
027
027,028
030
029, 030, 031, 062, 063, 064, 065, 066
033
032, 033, 034, 035, 036, 037
A representative storm event is a storm event that measures greater than 0.1 inches of rainfall. The time
between this storm event and the previous storm event measuring greater than 0.1 inches must be at least
72 hours. A single storm event may have a period of no precipitation of up to 10 hours. For example, if
it rains but stops before producing any collectable discharge, a sample may be collected if the next rain
producing a discharge begins within 10 hours.
Part It Page 5 of 13

Permit No. NCS000508
Table 2. Routine Analvtical Monitoring Requirements at Representative Outfalls
Discharge
Characteristics
Units
Measurement Frequency]
Sample
TypC2
Sample
Location3
Total Suspended Solids
m L
Quarterly
Grab
SDO
Biochemical Oxygen Demand
mg/L
Quarterly
Grab
SDO
Chemical Oxygen Demand
mg/L
Quarterly
Grab
SDO
TPH / Non -polar Oil & Grease
[EPA Method 1664 (SGT-FIEM)
mg/L
Quarterly
Q Y
Grab
SDO
Detergents (MBAS)
mg/L
Quarterly
Grab
SDO
Turbidity
NTU
Quarterly
Grab
SDO
NH3—Nitrogen
mg/L
Quarterly
Grab
SDO
NO3+NO2—Nitro ren
mg/L
I Quarterly
Grab
SDO
Phosphorus, Total
mg/L
Quarterly
Grab
SDO
H
standard
Quarterly
Grab
SDO
Total Rainfal14
inches
Quarterly
Ptain Gauge
Footnotes:
I Measurement Frequency: Four times per year (once per quarter) during a representative storm event.
2 Grab sample collection shall begin within the first 30 minutes of discharge or as soon thereafter as reasonably possible
and shall be completed as expeditiously as practicable.
3 Sample Location: Samples shall be collected at each representative stormwater discharge outfall (SDO) as specified in
Table I.
4 For each sampled representative storm event the total precipitation must be recorded. An on -site rain gauge or local rain
gauge reading must be recorded.
The permittee shall complete the minimum twenty (20) analytical samplings in accordance with
the schedule specified below in Table 3. A minimum of 30 days must separate sample dates
unless monthly monitoring has been instituted under a Tier Two response.
Part II Page 6 of 13

Permit No, NCS000508
Table 3. Monitoring Schedule
Monitoring period1'2
Sample Number
Start
End
Year 1 - Period 1
I
June I, 2010
August 30, 2010
Year I - Period 2
2
September I, 2010
November 30, 2010
Year I - Period 3
3
December 1, 2010
February 28, 2011
Year I - Period 4
4
March 1, 2011
May 31, 2011
Year 2 -Period l
5
June I, 2011
August 30, 2011
Year 2 - Period 2
6
September I, 2011
November 30, 2011
Year 2 - Period 3
7
December 1, 2011
February 29, 2012
Year 2 - Period 4
8
March 1, 2012
May 31, 2012
Year 3 - Period 1
9
June 1, 2012
August 30, 2012
Year 3 - Period 2
10
September 1, 2012
November 30, 2012
Year 3 - Period 3
11
December 1, 2012
February 28, 2013
Year 3 - Period 4
12
March 1, 2013
May 31, 2013
Year 4 -Period 1
13
June 1, 2013
August 30, 2013
Year 4 - Period 2
14
September 1, 2013
November 30, 2013
Year 4 - Period 3
15
December 1, 2013
February 28, 2014
Year 4 - Period 4
16
March 1, 2014
May 31, 2014
Year 5 - Period 1
17
June 1, 2014
August 30, 2014
Year 5 - Period 2
I8
September 1, 2014
November 30, 2014
Year 5 - Period 3
19
December 1, 2014
February 28, 2015
Year 5 - Period 4
20
March 1, 2015
May 31, 2015
Footnotes
1 Maintain quarterly monitoring during permit renewal process. If at the expiration of the Individual Permit,
the permittee has submitted an application for renewal of coverage before the submittal deadline, the
permittee will be considered for renewed coverage. The applicant must continue quarterly monitoring until
the renewed permit is issued.
2 If no discharge occurs during the sampling period, the permittee must submit a monitoring report indicating
"No Flow" within 30 days of the end of the sampling period.
Part 11 Page 7 of 13

Permit No. NCS000508
The permittee shall report the analytical results from the first sample with valid results within the
monitoring period. The permittee shall compare monitoring results to the benchmark values in
Table 4. The benchmark values in Table 4 are not permit limits but should be used as guidelines for
the permittee's Stormwater Pollution Prevention Plan (SPPP). Exceedances of benchmark values
must be addressed as provided in and in accordance with the tiered response chart on page 9 of Part
II.
Table 4. Benchmark Values for Routine Analytical Monitoring at Representative
Outfalls
Discharge Characteristics
Units
Benchmark
Total Suspended Solids
mg/L
100
Biochemical Oxygen Demand
mg/L
30
Chemical Oxygen Demand
mg/L
120
TPH / Non -polar Oil & Grease
mg/L
15
Detergents (MBAS)
mg/L
0.5
Turbidity'
NTU
50
NH3—Nitrogen
mg/L
7.2
NO3+NO2—Nitrogen
mg/L
10
Phosphorus, Total
mg/L
2
PH
standard
6-9
Footnotes:
I Turbidity: The turbidity benchmark value will become effective beginning in Year 2 of this permit following the
completion of airport runway construction activities.
Part II Page 8 of 13

Permit No. NCS000508
`,'Tier One .
If: The first valid sampling results are above a benchmark value, or outside of the benchmark range, for any
parameter at any outfall or in -stream location;
Then: The permittee shall:
1. Conduct a stormwater management inspection of the facility within two weeks of receiving
sampling results.
2. Identify and evaluate possible causes of the benchmark value exceedance.
3. Identify potential source controls, operational controls, or physical improvements, if any, that could
reduce the difference between the sampling results and the benchmark value and select any such
corrective measure or combination of corrective measures that the permittee determines to be
appropriate and warranted, after due consideration of the cause and nature of the exceedance and the
feasibility, cost and effectiveness of such measures.
4. Implement the selected actions, if any, within two months of the inspection, or as soon thereafter
as reasonably possible.
5. Record each instance of a Tier One response in the Stortwater Pollution Prevention Plan. Include
the date and value of the benchmark exceedance, the inspection date, the personnel conducting the
inspection, the selected actions, if any, and the date the selected actions were implemented, or, if no
action was implemented, the basis for that decision.
Tier Two
If: During the term of this permit, the first valid sampling results from two consecutive monitoring periods are
above the benchmark values, or outside of the benchmark range, for any specific parameter at a specific
outfall or in -stream location;
Then: The permittee shall:
1. Repeat all the required actions outlined above in Tier One.
2. Immediately institute monthly monitoring for each parameter at each outfall where a sampling result
exceeded the benchmark value for two consecutive samples. Monthly (analytical and qualitative)
monitoring shall continue until three consecutive sample results are below the benchmark values or
within the benchmark range.
3. If no discharge occurs during the sampling period, the permittee is required to submit a monthly
monitoring report indicating "No Flow" to comply with reporting requirements.
4. Maintain a record of the Tier Two response in the Stormwater Pollution Prevention Plan.
During the term of this permit, if the valid sampling results required for the permit monitoring periods exceed
the benchmark value, or are outside the benchmark range, for any specific parameter at any specific outfall or
in -stream location on four occasions, the permittee shall notify the DWQ Regional Office Supervisor in
writing within 30 days of receipt of the fourth analytical results.
The permittee will then consult with DWQ about feasible, practical, and cost-effective measures that the
permittee could undertake to reduce the difference between the sampling results and the benchmark value and
to avoid causing or contributing to any violation of water quality standards. After consultation with the
permittee, DWQ may require that the permittee revise, increase, or decrease the monitoring frequency for the
remainder of the permit and may impose such other requirements, if any, as may be necessary to prevent the
Part 11 Page 9 of 13

Permit No. NCS000508
from causing or contributing to any violation of water quality standards, including but
not limited to:
require the permittee to install structural controls; or
require the permittee to implement other stormwatcr control measures.
If the inspection and evaluation of a particular sampling result under Tier One or Tier Two show that the
result is not caused by the permittee's operations or facilities, it will not be treated as a benchmark
exceedance for purposes of determining whether four consecutive excecdanccs have occurred.
This site discharges to a segment of the East Fork Deep River with an approved Total Maximum
Daily Load (TMDL) for turbidity and fecal colifonn. The Division will consider monitoring
results in detennining whether additional BMPs are needed to control the pollutant(s) of concern
to the maximum extent practicable.
If additional BMPs are needed to achieve the required level of control as mandated by the
TMDL, if any, the permittee will be required to (1) develop a strategy for implementing
appropriate BMPs, and (2) submit a timetable for incorporation of those BMPs into the permitted
Stormwater Pollution Prevention Plan.
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stotmwater outfall regardless of
representative outfall status and shall be performed as specified in Table 5, during the analytical
monitoring event. Qualitative monitoring is for the purpose of evaluating the effectiveness of the
Stormwater Pollution Prevention Plan (SPPP) and assessing new sources of stormwater pollution.
In the event an atypical condition is noted at a stonmwater discharge outfall, the permittee shall
document the suspected cause of the condition and any actions taken in response to the
discovery. This documentation will be maintained with the SPPP.
Table 5. Qualitative Monitoring Requirements at All Outfalls
Discharge Characteristics
Frequencyt
Monitoring
Location2
Color
Quarterly
SDO
Odor
Quarterly
SDO
Clarity
Quarterly
SDO
Floating Solids
Quarterly
SDO
Suspended Solids
Quarterly
SDO
Foam
Quarterly
SDO
Oil Sheen
Quarterly
SDO
Erosion or deposition at the outfall
Quarterly
SDO
Other obvious indicators
of stormwater pollution
Quarterly
SDO
Part 11 Page 10 of 13

Permit No. NCS000508
Footnotes:
I Measurement Frequency: Four times per year (once per quarter) during a representative storm event, for each
year until either another permit is issued for this facility or until this permit is revoked or rescinded. If at the end
of this permitting cycle the permittee has submitted the appropriate paperwork for a renewal permit before the
submittal deadline, the permittee will be considered for a renewal application. The applicant must continue
quarterly monitoring until the renewed permit is issued. See Table 3 for schedule of monitoring periods through
the end of this permitting cycle.
2 Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall (SDO)
regardless of representative outfall status.
SECTION D: DE-ICING EVENT ANALYTICAL MONITORING REQUIREMENTS
De-icing event analytical monitoring of stormwater discharges shall be performed at selected
representative SDOs as specified in Table 6. De-icing event analytical monitoring shall be
performed four (4) times per year during qualifying de-icing events resulting in the use of at least
100 gallons of glycol in any concentration. Each monitoring event shall be conducted during a
discharge event at the time of de-icing activities, or during the next separate discharge event, up
to 72 hours following de-icing activities.
Table 6. De-icing Event Analytical Monitoring Requirements for Representative
Outfalls
Discharge Characteristics
Units
Measurement
' Fre uenc t
Sample
T e2
Sample'
Location3
Ethylene Glycol
m L
4X/yr
Grab
SDO
Propylene Glycol
m L
4X/yr
Grab
SDO
Biochemical Oxygen Demand
m L
4X/yr
Grab
SDO
Chemical Oxygen Demand
m > L
4X/yr
Grab
SDO
NH3—Nitrogen
mg/L
4X/yr
Grab
SDO
H
standard
4X/yr
Grab
SDO
Acute Toxicity`
%
4X/yr
Grab
SDO
Total Glycol Applied
I gal
4X/yr
Estimate
Total Rainfall
I inches
I 4X/yr
Rain gauge
Footnotes:
I Measurement Frequency: Four times per year during qualifying de-icing events as described above.
2 If the stormwater runoff is controlled by a stormwater detention pond a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge from the pond or as soon thereafter as reasonably
possible.
3 Sample Location: Samples shall be collected at each representative stormwater discharge outfall (SDO) as specified in
Table 1.
4 Acute Toxicity shall be performed in accordance with the Special Conditions page at the end of this permit.
Part 11 Page I I of 13

Permit No. NCS000508
Monitoring results shall be compared to the benchmark values in Table 8. The benchmark
values in Table 8 are not permit limits but should be used as guidelines for the permittee's
Stonnwater Pollution Prevention Plan (SPPP). Exceedances of benchmark values must be
addressed as provided in and in accordance with the tiered response chart on page 9 of Part II
except that item 2 of Tier Two is deleted and replaced with the following requirement:
2. Immediately institute monitoring during one qualifying de-icing event per month for each
parameter at each outfall where a sampling result exceeded the benchmark value for two
consecutive samples. Such monitoring (one per month) shall continue for the remainder of the
de-icing season so long as a qualified de-icing event occurs during each subsequent month.
In -stream analytical monitoring shall be performed concurrently with each of the four (4)
monitored de-icing events per year. Each monitoring event shall be conducted during a
discharge event at the time of de-icing activities, or during the next separate discharge event, up
to 72 hours following de-icing activities. In -stream analytical monitoring shall be performed at
selected stream sites as specified in Table 7.
Table 7
De-icingEvent Analytical Monitorin Y Requirements for In -stream Sampling
Parameter.
Units
Measurement
Sample
Sample
Fre uenc l
Type
Location2
IS#1 through IS#2,
Dissolved Oxygen
mg/L
4X/yr
Grab
IS#5 through IS#8,
IS#10 through IS#1 I
IS#I through IS#2,
Turbidity
NTU
4X/yr
Grab
IS#5 through IS#8,
IS#10 throu i IS#I1
IS#1 through IS#2,
pH
standard
4X/yr
Grab
IS#5 through IS#8,
IS#10 throu r IS#11
IS#I through IS#2,
Acute Toxicity;
%
4X/yr
Grab
IS#5 through IS#8,
IS#10 through IS#1 l
Footnotes:
I Measurement Frequency: Pour times per year during qualifying de-icing events as described above.
2 Sample Location: Samples shall be collected at each identified in -stream location named above.
3 Acute Toxicity shall be performed in accordance with the Special Conditions page at the end of this permit.
Part 11 Page 12 of 13

Permit No. NCS000508
Monitoring results shall be compared to the benchmark values in Table 8. The benchmark
values in Table 8 are not permit limits but should be used as guidelines for the permittee's
Stormwater Pollution Prevention Plan (SPPP). ). Exceedances of benchmark values must be
addressed as provided in and in accordance with the tiered response chart on page 9 of Part 11
except that item 2 of Tier Two is deleted and replaced with the following requirement:
2. Immediately institute monitoring during one qualifying de-icing event per month for each
parameter at each in -stream location where a sampling result exceeded the benchmark value for
two consecutive samples. Such monitoring (one per month) shall continue for the remainder of
the de-icing season so long as a qualified de-icing event occurs during each subsequent month.
Table 8. Benchmark Values for De-icing Event Analytical Monitoring for
Representative Outfalls and In -Stream Sampling
Discharge Characteristics
Units
Benchmark
Ethylene Glycol
mg/L
14,000
Propylene Glycol
mg/L
N/A
Biochemical Oxygen Demand
mg/L
30
Chemical Oxygen Demand
mg/L,
120
NH3—Nitrogen
mg/L
7.2
PH
Standard units
6-9
Acute Toxicity
%
>100%
Dissolved Oxygen
mg/L
5
Turbidity
NTU
50
Footnotes:
1 Acute Toxicity: For monitoring purposes, any result with a value of less than > 100% would constitute a
benchmark exceedance.
2 Dissolved Oxygen: For monitoring purposes, any result with a value of less than 5 mg/L would constitute a
benchmark exceedance.
3 Turbidity: The turbidity benchmark value will become effective beginning in Year 2 of this permit following the
completion of airport runway construction activities.
Part 11 Page 13 of 13

Permit No. NCS000508
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities already operating but applying for permit coverage for the first time: The Stormwater
Pollution Prevention Plan shall be developed and implemented within 12 months of the effective date of the
initial permit and updated thereafter on an annual basis. Secondary containment, as specified in Part II,
Section A, Paragraph 2(b) of this permit, shall be accomplished within 12 months of the effective date of
the initial permit issuance.
New Facilities applying for coverage for the first time and existing facilities previously permitted and
applying for renewal under this permit: The Stormwater Pollution Prevention Plan shall be developed and
implemented prior to the beginning of discharges from the operation of the industrial activity and be
updated thereafter on an annual basis. Secondary containment, as specified in Part 11, Section A, Paragraph
2(b) of this permit shall be accomplished prior to the beginning of discharges from the operation of the
industrial activity.
Duty to Comply
The permittee must comply with all conditions of this individual permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal application.
The permittee shall comply with standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants within the time provided in the regulations that establish
these standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement.
b. The Clean Water Act provides that any person who violates a permit condition is subject to a civil
penalty not to exceed $25,000 per day for each violation. Any person who negligently violates any
permit condition is subject to criminal penalties of $2,500 to 25,000 per day of violation, or
imprisonment for not more than I year, or both. Any person who knowingly violates permit
conditions is subject to criminal penalties of $5,000 to $50,000 per day of violation, or
imprisonment for not more than 3 years, or both. Also, any person who violates a permit
condition may be assessed an administrative penalty not to exceed $10,000 per violation with the
maximum amount not to exceed $125,000. [Ref: Section 309 of the Federal Act 33 USC 1319 and
40 CFR 122.41(a).]
C. Under state law, a daily civil penalty of not more than ten thousand dollars ($10,000) per violation
may be assessed against any person who violates or fails to act in accordance with the terms,
conditions, or requirements of a permit. [Ref: NC General Statutes 143-215.6A].
d. Any person may be assessed an administrative penalty by the Director for violating section 301,
302, 306, 307, 308, 318 or 405 of the Act, or any permit condition or limitation implementing any
of such sections in a permit issued under section 402 of the Act. Administrative penalties for Class
I violations are not to exceed $10,000 per violation, with the maximum amount of any Class I
penalty assessed not to exceed $25,000. Penalties for Class II violations are not to exceed
Part III Page 1 of 8

Permit No. NCS000508
$10,000 per day for each day during which the violation continues, with the maximum amount of
any Class 11 penalty not to exceed $125,000.
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
individual permit which has a reasonable likelihood of adversely affecting human health or the
environment.
Civil and Criminal Liability
Except as provided in Part 111, Section C of this permit regarding bypassing of stormwater control facilities,
nothing in this individual permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6A, 143-215.613, 143-
215.6C or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Oil and Hazardous Substance Liability
Nothing in this individual permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject
to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
6, Property Rights
The issuance of this individual permit does not convey any properly rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State or local laws or regulations.
Severability
The provisions of this individual permit are severable, and if any provision of this individual permit, or the
application of any provision of this individual permit to any circumstances, is held invalid, the application
of such provision to other circumstances, and the remainder of this individual permit, shall not be affected
thereby.
8. Duty to Provide Information
The permittee shall furnish to the Director, within a reasonable time, any information which the Director
may request to determine whether cause exists for modifying, revoking and reissuing, or terminating the
permit issued pursuant to this individual permit or to determine compliance with this individual permit.
The per uittee shall also furnish to the Director upon request, copies of records required to be kept by this
individual permit.
Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders
inaccurate, any monitoring device or method required to be maintained under this individual permit shall,
upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not
more than two years per violation, or by both. If a conviction of a person is for a violation committed after
a first conviction of such person under this paragraph, punishment is a fine of not more than $20,000 per
day of violation, or by imprisonment of not more than 4 years, or both.
Part III Page 2 of 8

Permit No. NCS000508
10. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation,
or certification in any record or other document submitted or required to be maintained under this
individual permit, including monitoring reports or reports of compliance or noncompliance shall, upon
conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more
than two years per violation, or by both.
SECTION B: GENERAL CONDITIONS
1. Individual Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as are
required by the agency authorized to issue permits no later than I80 days prior to the expiration date. Any
permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will
be subjected to enforcement procedures as provided in NCGS § 143-215.36 and 33 USC 1251 et. seq.
2. Transfers
This permit is not transferable to any person except after notice to and approval by the Director. The
Director may require modification or revocation and reissuance of the permit to change the name and
incorporate such other requirements as may be necessary under the Clean Water Act. The Permittee is
required to notify the Division in writing in the event the permitted facility is sold or closed.
Sienatory Reouirements
All applications, reports, or information submitted to the Director shall be signed and certified
a. All applications to be covered under this individual permit shall be signed as follows:
(1) In the case of a corporation: by a principal executive officer of at least the level of vice-
president, or his duly authorized representative, if such representative is responsible for
the overall operation of the facility from which the discharge described in the permit
application form originates;
(2) In the case of a partnership or limited partnership: by a general partner;
(3) In the case of a sole proprietorship: by the proprietor;
(4) In the case of a municipal, state, or other public entity: by a principal executive officer,
ranking elected official, or other duly authorized employee.
b. All reports required by the individual permit and other information requested by the Director shall
be signed by a person described above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
Part III Page 3 of 8

Permit No. NCS000508
responsibility, or an individual or position having overall responsibility for environmental
matters for the company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Director.
C. Any person signing a document under paragraphs a. or b. of this section shall snake the following
certification:
"1 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
4. Individual Permit Modification. Revocation and Reissuance, or Termination
The issuance of this individual permit does not prohibit the Director from reopening and modifying the
individual permit, revoking and reissuing the individual permit, or terminating the individual permit as
allowed by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122
and 123; Title 15A of the North Carolina Administrative Code, Subchapter 21I .0100; and North Carolina
General Statute 143-215.1 et al.
5. Permit Actions
The permit may be modified, revoked and reissued, or terminated for cause. The notification of planned
changes or anticipated noncompliance does not stay any individual permit condition.
SECTION Cr OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment and
control (and related appurtenances) which are installed or used by the permittee to achieve compliance with
the conditions of this individual permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the operation of
back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation
is necessary to achieve compliance with the conditions of this individual permit.
2. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt
or reduce the permitted activity in order to maintain compliance with the condition of this individual
permit.
3. Bvpassint of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
Part III Page 4 of 8

Permit No. NCS000508
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of stormwater or maintenance during normal periods of equipment downtime or dry
weather. This condition is not satisfied if adequate backup controls should have been installed in
the exercise of reasonable engineering judgment to prevent a bypass which occurred during
normal periods of equipment downtime or preventive maintenance; and
C. The permittee submitted notices as required under, Part III, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may approve an
anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and
nature of the permitted discharge. Analytical sampling shall be performed during a representative storm
event. Samples shall be taken on a day and time that is characteristic of the discharge. All outfall samples
shall be taken before the discharge joins or is diluted by any other waste stream, body of water, or
substance. Monitoring points as specified in this permit shall not be changed without notification to and
approval of the Director.
2. Recording Results
For each measurement, sample, inspection or maintenance activity performed or collected pursuant to the
requirements of this individual permit, the permillee shall record the following information:
a. The date, exact place, and time of sampling, measurements, inspection or maintenance activity;
b. The individual(s) who performed the sampling, measurements, inspection or maintenance activity
C. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of
monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published pursuant to
NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations published pursuant
to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as Amended, and Regulation
40 CFR 136.
Part III Page 5 of 8

Permit No. NCS000508
To meet the intent of the monitoring required by this individual permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the minimum
detection or lower reporting level of the procedure.
5. Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that are
required to be sampled, the permittee may petition the Director for representative outfall status. If it is
established that the stormwater discharges are substantially identical and the permittee is granted
representative outfall status, then sampling requirements may be performed at a reduced number of outfalls.
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the Stormwater
Pollution Prevention Plan. Copies of analytical monitoring results shall also be maintained on -site. The
permittee shall retain records of all monitoring information, including all calibration and maintenance
records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all
reports required by this individual permit for a period of at least 5 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time.
Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized contractor
acting as a representative of the Director), or in the case of a facility which discharges through a municipal
separate storm sewer system, an authorized representative of a municipal operator or the separate storm
sewer system receiving the discharge, upon the presentation of credentials and other documents as may be
required by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or conducted,
or where records must be kept under the conditions of this individual permit
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions
of this individual permit
C. Inspect at reasonable limes any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this individual permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring individual permit compliance
or as otherwise authorized by the Clean Water Act, any substances or parameters at any location.
SECTION E: REPORTING REQUIREMENTS
1. Discharge Monitoring Reports
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report forms provided by the Director. Submittals shall be delivered to the Division
no later than 30 days from the date the facility receives the sampling results from the laboratory.
The permittee shall submit an Annual Summary Data Monitoring Report to the appropriate DWQ Regional
Office in February of each year. The submittal shall be on forms supplied by the Division.
Part III Page 6 of 8

Permit No. NCS000508
If no discharge has occurred from the facility during a monitoring period, the permittee is required to
submit a discharge monitoring report, within 30 days of the end of the monitoring period, giving all
required information and indicating "NO FLOW" as per NCAC T15A 02B .0506.
The permittee shall record the required qualitative monitoring observations on the SDO Qualitative
Monitoring Report form provided by the Division, and shall retain the completed forms on site. Visual
monitoring results should not be submitted to the Division, except upon DWQ's specific requirement to do
so.
Submitting Reports
Two signed copies of Discharge Monitoring Reports (DMRs) shall be submitted to:
Central Files
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
In addition, a separate signed Annual Summary DMR copy shall be submitted to the local DWQ Regional
Office (RO) by March I of each year.
Addresses for each RO and the counties covered by each RO can be found here:
http://wN,iy.cnr.state.nc.us/html/regionaloffices.htmi. The permittee shall retain the completed originals
on site. Visual monitoring results should not be submitted to the Regional Offices or Central Files unless
specifically requested by DWQ.
3. Availability of Reports
Except for data determined to be confidential under NCGS 143-2I5.3(a)(2) or Section 308 of the Federal
Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for public inspection
at the offices of the Division of Water Quality. As required by the Act, analytical data shall not be
considered confidential. Knowingly making any false statement on any such report may result in the
imposition of criminal penalties as provided for in NCGS 143-215.6B or in Section 309 of the Federal Act.
4. Non-Stormwater Discharges
If the storm event monitored in accordance with this Individual Permit coincides with a non-stormwater
discharge, the permittee shall separately monitor all parameters as required under the non-stormwater
discharge permit and provide this information with the stormwater discharge monitoring report.
5. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which could significantly alter the nature or quantity of pollutants discharged. This notification
requirement includes pollutants which are not specifically listed in the Individual Permit or subject to
notification requirements under 40 CFR Part 122.42 (a).
6. Anticipated Noncompliance
The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which may result in noncompliance with the Individual Permit requirements.
Part III Page 7 of 8

Permit No. NCS000508
The permittee shall report to the local DWQ Regional Office, within 24 hours, all significant spills as
defined in Part VI of this permit. Additionally, the permittee shall report spills including: any oil spill of 25
gallons or more, any spill regardless of amount that causes a sheen on surface waters, any oil spill
regardless of amount occurring within 100 feet of surface waters, and any oil spill less than 25 gallons that
cannot be cleaned up within 24 hours.
8. [amass
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of an
unanticipated bypass.
9. Twenty-four Hour Reporting
The permittee shall report to the central office or the appropriate regional office any noncompliance which
may endanger health or the environment. Any information shall be provided orally within 24 hours from
the time the permittee became aware of the circumstances. A written submission shall also be provided
within 5 days of the time the permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes; the period of
noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the
anticipated time compliance is expected to continue; and steps taken or planned to reduce, eliminate, and
prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case -by -case basis if the oral report has been received
within 24 hours.
10. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour reporting at the time
monitoring reports are submitted.
11. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in a Notice of Intent to be
covered under this Individual Permit or in any report to the Director, it shall promptly submit such facts or
information.
Part III Page 8 of 8

NCS000508
PART IV LIMITATIONS REOPENER
This individual permit shall be modified or alternatively,
effluent guideline or water quality standard issued or app
effluent guideline or water quality standard so issued or t
Contains different conditions or is otherwise more
permit; or /
to
tly with any applicable
Clean Water Act, if the
any effluent limitation in the individual
b. Controls any pollutant not limited in the in�dividhu�afpermit'
The individual permit as modified or reissued,unde" jr his paragraph shall also contain any other requirements in the
Act then applicable.
PART V jADMINISTERING AND COMPLIANCE MONITORING FEE
/ I �) REQUIREMENTS
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days after being billed
by the Division. Failure to pay the fee in timely manner in accordance with 15A NCAC 2H .0105(b)(4) may cause
this Division to initiate action to revoke the Individual Permit.
PART VI DEFINITIONS
Act
See Clean Water Act.
Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Non-stormwater discharges which shall be allowed in the
stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
(b) Uncontaminated groundwater, foundation drains, air -conditioner condensate without added
chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from footing drains, flows from riparian habitats and wetlands.
(c) Discharges resulting from fire -fighting or fire -fighting training.
3. Best Management Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs may take the
form of a process, activity, or physical structure. More information on BMPs can be found at:
http://cfpub.cpa.gov/npdes/stormwater/menuofbmps/index.cfm.
4. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility including
the collection system, which is not a designed or established operating mode for the facility.
5. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above ground
storage container having a capacity of greater than 660 gallons or with multiple above ground storage
containers located in close proximity to each other having a total combined storage capacity of greater than
1,320 gallons.
Parts IV, V and VI Page 1 of

Permit No. NCS000508
6. Certificate of Coverage
The Certificate of Coverage (COC) is the cover sheet which accompanies the Individual Permit upon
issuance and lists the facility name, location, receiving stream, river basin, effective date of coverage under
the permit and is signed by the Director.
7. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC
1251, et. seq.
8. Division or DWO
The Division of Water Quality, Department of Environment and Natural Resources.
9. Director
The Director of the Division of Water Quality, the permit issuing authority.
10. EMC
The North Carolina Environmental Management Commission.
11. Grab Sample
An individual sample collected instantaneously. Grab samples that will be analyzed (quantitatively or
qualitatively) must be taken within the first 30 minutes of discharge.
12. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
13. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and which is not a land
treatment facility, a surface impoundment, an injection well, a hazardous waste long-term storage facility or
a surface storage facility.
14. Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such as a city or town.
15. No Exposure
A condition of no exposure means that all industrial materials and activities are protected by a storm
resistant shelter or acceptable storage containers to prevent exposure to rain, snow, snowmelt, or runoff.
Industrial materials or activities include, but are not limited to, material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
DWQ may grant a No Exposure Exclusion from NPDES Stormwater Permitting requirements only if a
facility complies with the terms and conditions described in 40 CPR § 122.26(g)
16. Notice of Intent
The state application form which, when submitted to the Division, officially indicates the facility's notice of
intent to seek coverage under an Individual Permit.
17. Permtttee
The owner or operator issued a certificate of coverage pursuant to this Individual Permit.
18. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe,
ditch, channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be discharged to
waters of the state.
Part VI Page 2 of 5 Pages

Permit No. NCS000508
19. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall. The time between this storm event and the previous
storm event measuring greater than 0.1 inches must be at least 72 hours. A single storm event may have a period of
no precipitation of up to 10 hours. For example, if it rains but stops before producing any collectable discharge, a
sample may be collected if the next rain producing a discharge begins within 10 hours.
20. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall
status allows the permittee to perform analytical monitoring at a reduced number of outfalls.
21. Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure plus sufficient
freeboard to allow for the 25-year, 24-hour storm event.
22. Section 313 Water Priority Chemical
A chemical or chemical category which:
a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act (SARA) of 1986, also titled the Emergency Planning and Community Right -
to -Know Act of 1986;
b. Is present at or above threshold levels at a facility subject to SARA title III, Section 313 reporting
requirements; and
C. Meets at least one of the following criteria:
(1) Is listed in appendix D of 40 CFR part 122 on Table II (organic priority pollutants), "fable
III (certain metals, cyanides, and phenols) or Table IV (certain toxic pollutants and
hazardous substances);
(2) Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of the CWA at 40
CFR 116.4; or
(3) Is a pollutant for which EPA has published acute or chronic water quality criteria.
23. Severe Prooertv Damage
Means substantial physical damage to property, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused
by delays in production.
24. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or production;
hazardous substances designated under section 101(14) of CERCLA; any chemical the facility is required
to report pursuant to section 313 of Title III of SARA; fertilizers; pesticides; and waste products such as
ashes, slag and sludge that have the potential to be released with stormwater discharges.
25. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable quantities
under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and CFR 117.21) or section 102 of
CERCLA (Ref: 40 CFR 302.4).
26. Stormwater Discharge Outfall (SDO)
The point of departure of stormwater from a discernible, confined, or discrete conveyance, including but
not limited to, storm sewer pipes, drainage ditches, channels, spillways, or channelized collection areas,
from which stormwater (lows directly or indirectly into waters of the State of North Carolina.
Part VI Page 3 of 5 Pages

Permit No. NCS000508
27. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall or as a
result of snowmelt.
28. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and which is
directly related to manufacturing, processing or raw material storage areas at an industrial site. Facilities
considered to be engaged in "industrial activities" include those activities defined in 40 CFR 122.26(b)(14).
The term does not include discharges from facilities or activities excluded from the NPDGS program.
29. Stormwater Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce Stormwater pollution
and is based on an evaluation of the pollution potential of the site.
30. Total Maximum Daily Load (TMDL)
TMDLs are written plans for attaining and maintaining water quality standards, in all seasons, for a specific
water body and pollutant. (A list of approved TMDLs for the state of North Carolina can be found at
h t t p://h2 o. e n r. s t a t e. n c. a s/ t m d In
31. Toxic Pollutant
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
32. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations, or
airport de-icing operations.
33. Visible Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being transported by water, air,
gravity, or ice from its site of origin which can be seen with the unaided eye.
34. 25-year, 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once in 25
years.
Part VI Page 4 of 5 Pages

Permit No. NCS000508
SUPPLEMENT TO MONITORING, CONTROLS AND LIMITATIONS FOR PERMITTED
DISCHARGES
SPECIAL CONDITIONS
ACUTE TOXICITY MONITORING De-icing Events (Outfalls 004, 006, 016A, 024, 026,
027, 030, 033)
The permitter shall conduct acute toxicity tests on discharges occurring from four (4) qualifying
de-icing events 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 Ceriodaphnia dubia 24-hour static test.
The parameter code for this test is TAE313. All toxicity testing results required as part of this
permit condition will be entered on the Discharge Monitoring Report form for the month in
which it was performed, using the appropriate parameter code. Test results shall be sent to DWQ
in accordance with Part III Section E #2. Submitting Reports.
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 during the next qualified de-icing
event following the permittee's receipt of laboratory results.
Part VI Page 5 of 5 Pages

Tennant
*Denotes Probable Co-Permittee
360 Communications American Tower
Alamo/National Car Rental
Allegiant Air
American Eagle.
ARC Ventures, INC
Atlantic Aero
Aviation Repair Technologies
* "
Avis Rent A Car
Big Daddy Detailing
c
Boingo Wireless Company
Budget Rent A Car
Carolina Aircraft
Cessna Citation Service Center
Champion Cartage
Chatauqua Airlines
Clear Channellnterspace Airports
Colonial Vending
COMAIR Hanger
Continental Airlines
Delta Airlines
* '
Delta Global Services
DHL
Dillion's Aviation Flight School
Dollar/Thrifty Rental Car
Enterprise Rental Car
Expresss000 Massagework
FAA
FAA Flight Standards Office
FAA Airways Facility
FAA Control Tower
Federal Aviation Administration
FedEX
Federal Express
Federal Express Corp
FEDEX World Service Center
FEDEX Aministration Building
FEDEX Security Building
GTCC Aviation Center
GTL
Hertz Rent A Car
Honda Aircraft Company
Jetstream Air, LLC
Jetstream Ground Services, INC
Koury Aviation
Landmark Aviation

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Level 3 Communications, Inc
Lincoln Financial
Marriott Hotel
Nation Weather Services
National Transportation & Safety Board
Paradies-Triad LLC Gift Shops
Piedmont Triad Airport Auhthority
Piedmont Triad ARFF Station/Command Center
Preferred Building Maintenance
Premier Transportation
Prime Flight Services
Quantem Aviation Services, INC
Quickflight Services
Select Service Partner
Shoe Shine Parlor
Smartecarte
TIMCO
Total Comfort Insulation, LLC
Tradewinds
Transportation Security Adminstration
Triad Transportation
Truliant Federal Credit Union
United Express
United Parcel Service
US Airways
US Customs and Border Protection
US Postal Service
USA Parking Valet
VF Corporation
Wachovia Bank, NA
Wildlife
Worldwide Flight Services

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USED ONCE OR TWICE A YEAR FOR
UNUSUALLY HIGH FORAGE
SC4LF IN FEET
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EXISTING TAHWAYXRUNWAY LIGHTS TREATED
WITH HERBICIDE 2 TO J TIMES PER YEAR

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surrounamg upianos. ivtost occur in the rieumont. morrow mo
theme, but representation in the parks system is otherwise absent.
Coastal Plain Nonalluvial Mineral Wetlands
Nonalluvial. mineral wetlands occur on flat, poorly drained areas of the outer Coastal Plain and occasionally in
shallow depressions such as Carolina bays. The soils in these sites are saturated in the wetter seasons and may
have shallow standing water. Vegetation is dominated by cypress, black gum, or other wetland hardwoods. In
the state parks system, this theme is represented only at Dismal Swamp.
.y
ly Pentland Pocosins
Patlands occur on nearly flat, poorly drained areas ofthe outer Coastal Plain and in large shallow depressions
such as Carolina bays. Peat deposits develop where the soil is saturated for long enough periods that organic
matter cannot completely decompose. The peat acts as a sponge, raising water levels in the soil, which is
extremely infertile and acidic. Vegetation includes stunted pond pines and low shrubs, often with areas of
sphagnum and pitcher plants. Pocosins are represented in the parks system at Dismal Swamp, Pettigrew, and
several of the Carolina bay parks.
C3D7

Date of Deicing
Fluid Appled
Event
(Gal)
Precip (In.)
2006-2007
10/27/2006
30
0.76
11/712006
220
0.82
11/22/2006
45
0.8
12/2212006
195
0,53
1/l/2007
312
0,56
1/5/2007
507
0.5
1/18/2007
15
0.19
1/22/2007
862
0 02
2/1/2007
735
0.14
2/1412007
45
0.05
2/26/2007
250
0
312/2007
230
0.81
316/2007
380
0
3/18/2007
120
0
W2912007
643
0.28
0 Eligible sample events (100 gal, discharge wTin 3 days)
2007-2008
11/15/2007
474
0.46
11/2212007
65
0.19
12/1612007
90
0.15
12/21/2D07
230
0.14
12/26/2007
30
0.37
1110/2D08
157
0.12
111712008
1231
0.56
2/1/2008
1074
1.1
215/2008
226
0
2113/2008
45
0.41
2/14/2008
1355
0
2125/2008
483
0
3/5/2008
110
0
3/16/2008
147
0
3/29/2008
316
0.22
4/201200B
60
0.97
5/9/2008
15
0.03
/f Eligible sample events (100 gal, discharge
w/in 3 days)
2008-2009
11/4/2008
75
0.24
11/13/2008
45
0.21
11/25/2008
1228
0.02
11/30/2008
15
0.9
12/1112008
90
1.03
12/16/2008
15
0.2
114/2009
30
0.18
1/27/2009
700
0.23
213/2009
230
0.02
2/12/2009
100
0
2/18/2009
344
0.59
3/2/2009
620
0.09
3/14/2009
120
0.63
3/26/2009
25
0.07
a Eligible sample events (100 gal, discharge
w/in 3 days)
2009-2010
1 ill 1/2009
125
2A9
12/212009
322
0.98
12/912009
643
0.65
12/20/2009
4945
0
4 Eligible sample events (100 gal, discharge
w/in 3 days)
MIN
15
MEDIAN
208
AVERAGE
407
MAX
4,945
ST DEV
742
Precip >/= 0.1" If N, Next Precip
(YIN) Event>/= 0.1" No. Days Later
Y
Y
Y
Y
Y
Y
V
N 21112007 10
Y
N 2/25/2007 11
N 3/1/2007 3
Y
N 3/1512007 10
N 3/2912007 11
Y
8
Y
Y
Y
Y
Y
Y
Y
Y
N
2/12/2008 7
Y
N
2/2412008 10
N
2/20/2008 1
N
317/2008 2
N
3/19/2008 3
Y
Y
N
5/11/2008 2
9
Y
Y
N 11/3012008 5
Y
Y
Y
Y
Y
N 2/11/2009 8
N 2/18/2009 6
Y
N 3/1412009 12
Y
N 3/27/2009 1
3
Y
Y
Y
N 12/25/2009 5
3
Glycol Usage Summary
N eligible events
200.3
100.7
100-3
2006-2007
7
8
8
2007-2008
5
10
9
2008-2009
2
5
3
2009-Dec 2010
2
4
3
�l

GENERAI,.PERMIT NO. NCG090000
CERTIFICATE\OF COVERAGE NO. NCG09n> ar
FACILITY NAMEk)Q
PERSON COLLECTING
CERTIFIED LABORAT(
Part A: Specific Monitoring Requirements
STORMWATER DISCHARGE OUTFALL (SDO)
MONITORING REPORT
SAMPLES COLLECTED DURING CALENDAR YEAR:
(This monitoring report is due at the Division no later th 30 days from
the date the facility receives the sampling results from,the laboratory.)
COUNTY Oe)'ion/11
PHONE NO. (704 ) QQC)-&1 `%3 _
PLEASE SIGN ON
Outfall
No.
;Date,
Sample Collected,
`01027'
01034.,
OlOSf. .
• ` Total Cadmium,
" .Total Chr'omlum,`
u
eeid -'
.. u
Benchmark
7
1000 :.
; ; 33
of
io 1P,
k L\
L_
Z L
Note: It you report a sampled value in excess of the benchmark value, you must implement Tier I or Tier 2 responses. See General Permit text.
Did this facility perform Vehicle Maintenance Activities using more than 55 gallo�f new motor per month? _ yes �(no
(if yes, complete Part B) \
Part B: Vehicle Maintenance Avtiviry Mnnitarina Renniremenr�
Outfalh.
No.
Date , ':,
Sample Collected;
mo%dd/'
;.... r 00556
'i00530 • ,
00400 ,. `
_
Owand,Grease, _ "..
Tdtal'Suspeaded SOHde,-,
pH,
Standard units
New Motor 0il Usage,
uel avers a allmo
Benchmark
30
100 .'
6.0 _ 9a0
t
Note: it you report a sampled
See General Permit text. i
STORM EVENT
in excess of the benchmark value, or outside the benchmark range for pH, you must implement Tier I or Tier 2
Date ' 7017101 (first event sampled)
+I otal Event Precipitation (inches):
Date (list each additional event sampled this reporting period, and rainfall amount)
Total Event Precipitation (inches):
Mail Original and one copy i
Division of Water Quality
Attn: DWQ Central Files
1617 Mail Service Center
Raleigh, North Carolina 2769. .
S W U-255-102107
Page 1 of 2

3/1412009
OF-004
BQL
183
>100%
',_r +
"•' "
" i
OF-006
BQL
BQL
>100%
'
OF-014
BQL
BQL
.',a
:'rat
a"
>100%
OF-024
BQL
341
-.'t r i
Mtn-"rw-,"tit
9„i•. k,r ,
>100%
OF-026
BQL
BQL
i&41
>100%
, ; ti,,
�y-•
r.=,,�.
OF-027
BQL
BQL
>100%
OF-030
BQL
BQL,.,,,:.,,
- - "".
>100%
'.
Stream-1
-
4.67
_
>100%
6.17
0.114
7.80
14.77
Stream-2
>100%
6.30
0,066
8.91
158.7
Stream-3
7.27
>100%
8.67
0.230
8.04
53.00
Stream-4
7.3
>100%
6.30
0.206
8.36
64.13
Stream-5
12.3
-
>100%
6.72
0.364
6.70
51.88
Stream-6
22.6
>100%
6.64
0,272
7.54
69.97
Stream-7
-
<2.0
>100%
6.20
0,196
6,25
33.57
Stream-8
3.77
""r"
>100%
6.20
0.149
6.37
38.52
Stream-9
2.26
>100%
6.13
0.291
6.59
45.50
Stream-10
-
5.22
, • -'"
>100%
6.18
0.345
7.80
75.90
Stream-11
2.86
a tiyw '
'°
>100%
1 6.24
0.595
8.55
43.86
6/5/2009
OF-004
3.98
0161,38M
<0.10`-
OF-006
2.74
8.75
<0.10
OF-014
4.38
31.5
<0.10
_
.t
=•r
OF-024
<2.00
5.0
NR
OF-026
-
<2.00
8.5
NR
OF-027
-
<2.00
7.0
<0.10
OF-030
<2.00
8.5
<0.10
Stream-1
6.36
0.076
2.93
43.82
Stream-2
6.09
0.031
2.35
1100.0
Stream-3
-
r
t ,
5.98M20
2.63
983.9
Stream-4
' t.
< ". ,.
ffi 14,
't=�.
:?�`,
5.373.25
454.90
Stream-5
£-e
"""'
5.503.47
436.70
Stream-6
_ . ,« ° :'
% .ram '
-Lr'-.r ,'
:i. uar
�} "•3ri^'*�'
6.173.37
635.70
Stream-7
,
•N..,%. "�:§
^�`k:^=Mn.R
�a ,ay`i'?..:'>~-ys
6.403.53
62.52
Stream-8
:,,-x
i, _ 44
4
'�w.Tn
*'" .r
.� "`•
6.463.63
85.14
Stream-9
:,,....,'�
�=�
rb�v'� ° �'
�- v�sa72
i
^,��"a:
6.463.78
65.8
Stream-10
�.,
°�' z','�
,"' •a s
E`t:Y'1
1�.;a;:,;w;
6.51.510Stream-11
r ,{ ,
, ` ;js-
t,,..,.ta;;a
t+_-• "-%-
6.393.39
88.2
Total # Samples Gollecteo
lib
121
121
121
121
# WQS Violations
0
12
N/A
21
52
% WQS Violations
0%
10%
N/A
17%
43%
Ethylene
Propylene
Acute
Parameter Glycol
Glycol
BOD TSS NH3-N
Toxicity
pH
Conductivity
DO
Turbidity
Benchmark 14000
N/A
30 100 7.2
N/A
6 to 9
N/A
N/A
50
1074%
2510%
MAX 6.26 "34.1 - 30.4 428 1.35 >100% 8.67 2490 18.2 1130 1 3229%
MIN 6.26 9.09 2 5 0.124 >100% 5.37 -0.04 " 1.88 121 132%
MEDIAN 6.26 15.4 4.51 12.25 :0.236 >100%6.49 0.091 7.49 43.82 485%
NOTES:
mg/I = milligrams per liter
BQL = Below Quantitation Limit
NS = Not Sampled (No discharge)
Data not available due to laboratory quality control failure

TABLE 1 ' 1 15 o D f C. /6 U- -/ C%;,V-6
3/2/2009
OF-004
281
1,310
^ -_.' 9'k
'',{„''-`:3k..':3iA�LLiU
>100%
ILI �
'S_i
e,-�:,,*°..^' ,.�_
t^+•*�;.�"x:
OF-006
<10.0
<10.0
fokt:<.'A"e"
>100%
a�:a�
_•..... StiiM'
sf
1'w-3"•.1'?a`�
OF-014
<10.0
<10.0
•ki`-; wit iT
.i .Z.0
killiswhE
>100%
- •,
,". '
tio'aiET±. L'•w'3t
g'ssvn ,,ti.
OF-024
594
3,220
-
>100%
M7,A
MARAW4i
dxttk t",:;rd,1e„+°r
OF-026
<10.0
<10 0
>100%3`-
OF-027
1,390
8,510
;'ar
ea a,s:;
>100%
„%x..u'*•cs3a
!,^:"
OF-030
<10.0
<10.0
>;«
.
e +
>100%
Stream-1
`"
?' '
<2
r.; ,,: ,.k
'�,''"'
>100%
6.36
0.146
6.20
22.72
Stream-2
908
>100%
6.22
0.139
6.40
74.16
Stream-3
156
ti,
'-„':
>100%
6.80
0.374
6.60
104.20
Stream-4
.�,.:,
232
,. T„;:
>100%
6.65
0.446
6.25
104.60
Stream-5
"
�,•t,.^
286
, ."t,t4»k"":?"�..
>100%
6.75
0.470
8.56
112.80
Stream-6
_ t
•;,;.
358
.. t
5n'•P .-
>100%
6.55
0,680
5.50
74.90
Stream-7
<6
a r ^; w
k `t ""*>
>100%
6.75
0.756
6.55
49,55
Stream-8
;,?z
196
-, ..,,',r,
e«":°"'°1
>100%
6.02
0.124
5.24
102.00
Stream-9
52.0
>100%
6.60
0.759
5.56
35.41
Stream-10
951
>100%
6.30
0.357
6.74
88.56
Stream-11
506
>100%
6.76
1.014
6.44
66.50
3126/2009
OF-004
<10.0
<10.0
>100%
OF-006
<10.0
<10.0
>100%
OF-014
OF-024
<10.0
<10.0
-
>100%
i
OF-026
<10.0
<10 0
''
>100%
''
_. •r
OF-027
<10.0
t10.0;:-'.
..-:°..-
>100%
OF-030
<10.0
<10.0
'r'
'•
>100%
`9.57
Stream-1
- - •
<2
>100%
6.22
0.196
7.52
Stream-2
<2
>100%
6.08
0.091
9.30
27.33
Stream-3
''
<2
>100%
6.19
0.21
8.10
18.97
Stream-4
<2
':
>100%
6.09
0.094
7.72
18.19
Stream-5
<2
='
>100%
6.24
0.117
7.77
22.03
Stream-6
"'
<2
>100%
6.00
0.107
7.95
14.10
Stream-7
<2
;K'-"'-"
>100%
5.43
0.182
3.37
1 29.07
Stream-8
_
<2
` c''
>100%
5.81
0.1
4.88
22.66
Stream-9
2.62
-;
•` z9
>100%
5.94
0.112
7.28
9.35
Stream-10
<2
>100%
6.01
0.113
7.58
7.23
Stream-11
2.82
,. •''
>100%
6.03
0.111
8.15
13.02
Total # Samples Collected
610
484
462
484
418
# WQS Violations
27
55
N/A
4
174
%WQS Violations
4%
11%
N/A
1%
42%
Ethylene Propylene
Acute
Parameter Glycol Glycol BOD TSS NH3-N
Toxicity
pH
Conductivity
DO
Turbidity
326%
286%
Benchmark
14000
N/A
30
100
7.2
N/A
6 to 9
N/A
N/A
50
MAX
1170000
3580000
1540
54
12
100
8.59
220
21.6
4660
16823%
MIN
6.05
5.29
2.03
2.8
0.031
0.502
4.92.
-0.08
3.37
5
24%
MEDIAN
52
101
5.3
9.9
0.53
1
6.47
0.122
10
39.865
525%
NOTES:
mg/I = milligrams per liter
BOIL = Below Quantitation Limit
INS = Not Sampled (No discharge)
Data not available due to laboratory quality control failure

IN -STREAM RESULTS - QUARTERLY
ll # Samples Collected
# WQS Violations
% WQS Violations
at IS#1 at IS#2
pH Conductivity DO Turbidity (for turbidity) (for turbidity)
121
121
121
121
11
11
12
N/A
1 21
52
2
8
10%
N/A
1 17%
43%
18%
73%
IN -STREAM RESULTS - EPISODIC/DE-ICING
ll # Samples Collected
# WQS Violations
% WQS Violations
pH Conductivity DO
at IS#1 at IS#2
Turbidity (for turbidity) (for turbidity)
484
462
484
418
38
38
55
N/A
4
174
4
28
11%
N/A
1%
42%
11%
74%
Notes:
Data collected from January 2005 - present.
WQS = water quality standard
pH WQS Violation = <6 s.u. or> 9 s.u.
DO WQS Violation = < 4 mg/L instantaneous measurement
Turbidity WQS Violation = > 50 nlu

776 Appendix
TABLE A.2 Dissolved Oxygen Saturation Concentrations,' mg/L
Temperature
Chloride concentration, mg/L
°C
0
5 000
10 000 .
15 000
20 000
25 000
0
14.621
13.728
12.888
12.097
11.355
10.657
1
14.216
13.356
_ 12.545
11.783
11.066
10.392
2
13.829
13.000
12.218
11.483
10.790
10.319
3
13.460
12.660
11.906
11.195
10526
9.897
4
13.107
12.335
11.607
10.920
10.273
9.664
¢tom F 5
12.770
12.024
11.320
10.656
10.031
9.441
6
12.447
11.727
11.046
10.404
9.799
9.228
7
12.139
11,442
10.783
10.162
9.576
9.023
8
11.843
11.169
10.531
9.930
9.362
8.826
9
11.559
10.907
10.290
9.707
9 '.56
8.636
50oc
10
11.288
10.656
10.058
9.493
8.959
8.454
_
11
11.027
10.415
9.835
9.287
8.769
8.279
12
10.777
10.183
9.621
9.089
8.586
8.111
13
10.537
9.961
9.416
8.899
8.411
7.949
14
10.306
9.747
9.218
8.716
8.242
7.792
59'F
15
10.084
9.541
9.027
8.540
8.079
7.642
16
9.870
9.344
8.844
8.370
7.922
7.496
17
9,665
9.153
8.667
8.207
7.770
7.356
18
9.467
8.969
8.497
8.049
7.624
7.221
19
9.276
8.792
8.333
7.896
7.483
7.090
....',�
20
9.092
8.621
8.174
7.749
7.346
6.964
-
21
8.915
8.456
8.021
7.607
7.214
6.842
22
8.743
8.297
7.873
7.470
7.087
6.723
23
8.578
8.143
7.730
7.337
6.963
6.609
24
8.418
7.994
7.591
7.208
6.844
6.498
770;
25
8.263
7.850
7.457
.7.083
6.728
6.390
26
8.113
7.711
7.327
6.962
6.615
6.285
27
7.968
7.575
7.201
6.845
6.506
6.184
28
7.827
7.444
7.079
6.731
6.400
6.085
29
7.691
7.317
6.961
6.621
6.297
5.990
„-�°}=
30
7.559
7.194
6.845
6.513
6.197
5.896
35
6.950
6.624
6.314
6.017
5.734
5,464
-04°C
40
6.412
6.121
5.842
5.576
5.321
5.078
45
5.927
5.665 _
5.414
5.174
4.944
4.724
50
5.477
5.242
5.016
4.799
4.591
4.392
'From .Standard :Lethods for the. Examination of Water and Wastewater, 18th ed., copyright 1992 by APHA,
AWWA, and WEF. American Public Health Association, Washington, DC. Reprinted with permission.
TABLE A.3 Chemicals Used in Water and Wastewater
Agent
Bulk density
g/100 mL
Chelating Agents
_
Na,EDTA (liq)
127-131
Na,EDTA - 4H20 (dry)
78
_
Nitrilotriacetic acid (dry)
89
Coagulants and Flocculants
Al2(SO,), - 14H2O (dry)
90-115
Ali (SO4)1. 14H2O (liq)
134
FeCl, (liq)
137
-
FeC12 (liq)
118-132
$
Fe2(SO4)1 (50% soln)
149
;.
Polymers"
...; 110-140
r,
Oxidants and Disinfectants
-.r
BrClt (mixture of Brz, Cl,,
232
}
and BrC12)
Ca(OCI)2 (dry)
80-98
s
C12 (liq)
1.47 (0°C)
H2O,
90-129
KMnO,
138-160
NaHSO, (liq)
133
NaOCI (liq)
122
is
Other
CaO (dry)
96
1a
Ca(OH)2 (dry)
48
CuSO, (dry)
120-144
H2SO4
170-182
t
H,PO,
157-169
=
H2SiF6 (fluositicic acid)
123
Greensand
136
-_
KCI (dry)
103
NaCl (dry)
105-121
k
Na2CO3 (dry)
253
NaF (dry)
144-168
NaOH (liq)
153-170
NH,OH (liq)
90
_
'From E. W. Flick (1991), Water Treatment Chemicals: An Industrial Guidt
NJ, and S. Kawamura (1991), Integrated Design of Water Treatment Facili
"M W: 2 000-60 000.

RONALD L. DROSTE
4�
John Wiley & Sons, Inc.
New Y:;-k • Chichester • Brisbane • Toronto • Singapore

Baker and Associates
A Und of Michael Baker Corporation
7800 Airport Center Drive, Suite 100
Greensboro, NC 27409
[phone]
FAX [phone]
To: NC Division of Water Quality
Stormwater Permitting Unit
512 N. Salisbury St.
Raleigh, NC 276604
Attn: Mr. Ken Pickle
Letter of Transmittal
S.O. No.: 104066
Project: Piedmont Triad International Airport
NPDES Permit NCS000508
Date: June 30, 2006
We are forwarding the following: ® Attached ❑ Under Separate Cover ❑ Other
NO.
COPIES
TITLE OR DESCRIPTION
COMMENTS
01
1
2006 Update to the Water Quality Management Plan for
update specified in the
Deicing Agents
Initial Plan submitted
June 22, 2005
THESE ARE TRANSMITTED as checked below:
❑ As requested ❑ No exception taken ❑ Revise and resubmit
❑ For review and comment ❑ Rejected - See remarks ❑ Submit specified items
® For your information ❑ Proceed subject to corrections noted ❑ Other
GENERAL COMMENTS:
Submitted on behalf of the Piedmont Triad Airport Authority.
Please do not hesitate to contact me regarding this Plan update.
cc: Mickie Elmore
Bill Cooke
Baker and Associates
By: Richard B. Darling
Title: Environmental Manager
Page: 1 of 1
ChallengeUz.

PIEDMONT TRIAD AIRPORT AUTHORITY
(PTAA)
WATER QUALITY MANAGEMENT PLAN FOR DEICING AGENTS
2006 UPDATE
INTRODUCTION
on July 22, 2005, PTAA submitted to the North Carolina De-
partment of Environment and Natural Resources its initial Water
Quality Management Plan for Deicing Agents' (the "Initial Plan")
at the Piedmont Triad International Airport (the "Airport").
The Initial Plan was submitted under Section E of NPDES Permit
NCS000508 (the "Permit"), which was issued to PTAA effective
February 1, 2005. The Plan specified some immediate steps that
PTAA proposed to take to better assess and control the use of
deicing agents at the Airport. The Plan also outlined a supple-
mental testing program for PTAA to conduct during the 2005-2006
winter season, in addition to the regular monitoring required
under Part II of the Permit, to determine the need for any more
specific measures that might be required for compliance with
applicable Water Quality Standards.
PTAA proceeded with the planned measures for the 2005-2006
winter season and attempted to complete the supplemental testing
program described in the Initial Plan. However, as discussed
below, the unusually mild winter weather prevented PTAA from
completing all of the tests that had been planned for the supple-
mental program. While certain conclusions can be drawn from the
results that were obtained, both from the regular NPDES monitor-
ing and supplemental testing, PTAA still lacks critical informa-
tion to fully analyze stream impacts resulting from the use of
deicing agents at the Airport and to assess the need for any
additional Best Management Practices (BMP's).
This update will describe the actions that PTAA has already
taken under the Initial Plan and the results of PTAA's monitoring
and testing programs to date. It will also propose additional
'"Deicing agents," which are used to remove ice and snow
that have already accumulated on aircraft, are sometimes distin-
guished from "anti -icing agents," which are applied to aircraft
surfaces to prevent further icing prior to take off. As in the
case of the Initial Plan, the term "deicing agent" will be used
in this Update to refer to both deicing and anti -icing agents,
and the term "deicing" will refer both to deicing and anti -icing
operations.

tests for the upcoming (2006-2007) winter season to obtain the
information that is still required for the development of a final
plan.
IMPLEMENTATION OF THE PLAN TO DATE
I. Measures Already Adopted by PTAA
PTAA has taken the following steps to date in accordance
with the Initial Plan:
A. Information from Airport Tenants.
PTAA sought information from Airport tenants as
follows:
• PTAA submitted a form to its tenants for them to
report the volume and type of deicing chemicals they
are using at the Airport, where the deicing agents
are applied and the contractor (if other than the
tenant) performing such application. PTAA also
asked its tenants to comment on their experiences
and proposals for minimizing the impact of such
agents.
• Tenants were asked before the beginning of the 2005-
2006 season to state the volume of deicing agents
they had on hand, the type of product, and the
amount of each product they expected to use in the
2005-2006 season.
• Tenants were asked to use Exhibit 5 of the Initial
Plan ("Deicing Report") to record and report all
glycol applications.
These inquiries have provided more complete information
concerning the sources, types, and volumes of deicing
agents in use within the various drainage areas at the
Airport.
B. Avoidance of Open Drains.
During the 2005-2006 winter season, PTAA requested that
aircraft operators conduct deicing activities as far
away as operationally possible from storm drain inlets.
- 2 -

It is believed that the avoidance of deicing over open
drains reduces, or prevents entirely, the entry of
deicing agents into the storm water drainage system
during non -precipitation (defrosting) events since no
storm water is present to carry the agents into the
drains and evaporation occurs on the dry pavement. It
is also believed that this measure reduces the entry of
deicing agents into the system when precipitation is
occurring.
C. Inclusion of Deicing Agents in the SPRP.
PTAA has now adopted its Storm Water Pollution Preven-
tion Plan (SWPPP) required by the NPDES Permit. The
Spill Prevention and Response Plan (SPRP) included in
the SWPPP specifically provides that the spill preven-
tion and response notification protocols in the PTAA
Spill Prevention Control and Countermeasure Plan will
apply not only to petroleum products, but also to non -
petroleum products, including deicing agents. Contain-
ment and cleanup are to be determined on a case by case
basis by the spill response team and PTAA emergency
coordinator. The inclusion of deicing agents in the
SPRP will provide for appropriate action to be taken to
deal with accidental spills of deicing agents on Air-
port grounds.
II. Description of the 2005-2006 Testing.
PTAA undertook two analytical testing programs during the
2005-2006 winter season. The first set of tests was con-
ducted in compliance with the monitoring protocols set out
in Part II of the NPDES permit, including the quarterly
analytical tests for the winter season required under Tables
1-7 of the Permit, as well as the episodic tests required
after each deicing event under Tables 8 and 9 of the Permit.
The second set of tests was the supplemental program pro-
posed in the Initial Plan for the 2005-2006 season, which
was specially designed by PTAA. As originally planned by
PTAA, this supplemental testing was to include 29-hour in -
stream sampling for glycol and BOD after representative
deicing events (two precipitation events and two non -
precipitation events). The purpose of these additional
tests was to yield further information that is needed to
understand the impact of deicing agents on the receiving
- 3 -

streams at the Airport and to develop a final plan for
compliance with Water Quality Standards.
Table 1 below summarizes the analytical tests that were
performed over the course of the winter under both of the
testing programs.
Table 1 Summary of 2005-2006 Monitoring for Deicing Agents
SAMPLE DATE
EVENT
REPORT
SUBMITTED
12/06/2005
Episodic
01/19/2006
12/09/2005
12/15/2005
02/06/2006
12/26/2005
01/12/2006
01/31/2006
04/13/2006
02/03/2006
Quarterly
05/09/2006
02/12/2006
Episodic
04/13/2006
02/23/2006
06/07/2006
03/22/2006
24-Hour
Exhibit 1
03/27/2006
04/01/2006
Episodic
05/09/2006
The 2005-2006 season was abnormally warm and dry, with few
instances of freezing precipitation, and this unusual
weather limited the occasions for testing and the data that
was collected. Only 1.3 inches of snowfall was recorded
over the entire winter at the National Weather Service sta-
tion at the Airport. The volume of deicing agents used by
one of the FBO's at the Airport illustrates the deviation
from normal conditions. Over an average winter, this FBO
uses approximately 700 gallons of deicing agent. This past
winter, it only used 118 gallons.
As a result of the unusual weather, PTAA was unable to com-
plete the 24-hour in -stream tests that had been planned for
precipitation events when glycol was in use. There were no
such events after the arrangements were completed for the
testing. PTAA was able to complete 24-hour testing for two
non -precipitation events when glycol was in use, these
occurring on 3/22/06 and 3/27/06, as shown on Table 1.
In addition to the sampling summarized on Table 1, PTAA
installed flow meters, in accordance with the Initial Plan,
- 4 -

at each of the outfalls that had discharged glycol the pre-
vious winter (Outfalls 4, 6, 24, 26, and 27). These flow
meters enabled PTAA to monitor runoff volumes at each of
those outfalls as contemplated in the Initial Plan.
As indicated on Table 1, the data from the regular testing
program have previously been submitted to the North Carolina
Division of Water Quality through PTAA's NPDES Compliance
Reports. Summaries of the results from the 24-hour testing
following the two non -precipitation events are attached as
Exhibit 1. In spite of the unusual weather, some useful
results were obtained from the testing program, and from
the monitoring of the flow meters, as set forth below.
III. Analysis of the Test Results.
A. No Demonstrable Correlation between Deicing Agents and
Toxicity.
Based on the data from the 2004-2005 winter season, the
Initial Plan concluded that there was no reliable cor-
relation between concentrations of deicing agents and
acute toxicity. This conclusion is reinforced by the
testing that was done during the 2005-2006 winter sea-
son. Across the 2005-2006 sampling events, concentra-
tions of propylene glycol at the representative out -
falls ranged from 11.8 mg/L to a high of 3,580 mg/L.
Three instances of ethylene glycol were detected, with
the highest concentration at 1,170 mg/L. Without ex-
ception, the samples with reportable concentrations of
either propylene or ethylene glycol had a 24-hour LC50
value of more than 100%, which indicates the absence of
acute toxicity.' By contrast, in the two samples with
observable toxicity (both at Outfall 26), glycol was
below the detection limits. (Detection limits are 12
mg/L for propylene glycol and 2 mg/L for ethylene
glycol.)
'The 24-hour "Lethal Concentration" 50 (or LC50) is the
percent of the total sample collected (in dilution water) that
is estimated to produce mortality in 50% of the test organism
(Fathead minnow, Pimephales promelas) population in a 24-hour
period. A result of greater than 100% indicates that in the
undiluted sample no significant mortality was observed over the
test period.
- 5 -

In short, the outfalls where glycol was detected did
not exhibit acute toxicity; and where acute toxicity
was detected, there was no glycol.
As in the case of the 2004-2005 season, no toxicity was
observed at any of the 11 in -stream sampling locations
at any time during the 2005-2006 season. The cumula-
tive results from the past two years indicate an ab-
sence of in -stream toxicity, whether from glycol or
any other cause.
Table 2 below summarizes the glycol and toxicity re-
sults for the 2005-2006 season at the representative
outfalls under the NPDES Permit. Glycol was detected
at Outfalls 4, 24, 21 and 30 as shown on Table 2. As
stated above, no glycol was detected at any time during
the winter at Outfall 26, the single location where
acute toxicity was observed, nor was any detected at
Outfalls 6 or 14.
Summary of 2005-2006 Significant Results
Table 2
DATE
OUTFALL
PROPYLENE
GLYCOL
(m /L)
ETHYLENE
GLYCOL
(m /L)
ACUTE
TOXICITY
(24-hr.LC,,)
12/09/2005
4
11.8
-
>100%
24
178
-
>100%
26
-
-
61.50%
27
-
1170
>100%
30
31.8
-
>100%
12/15/2005
4
1 370
-
>100%
24
1,020
-
>100%
26
-
-
77.10%
27
237
-
>100%
12/26/2005
27
47
-
>100%
02/03/2006
24
-
31.8
>100%
02/12/2006
4
3 580
-
>100%
24
474
840
>100%
27
536
-
>100%
The data summarized in Table 2, along with the data
from the previous winter, suggest that there is no
correlation between the presence of glycol in the
storm water and acute toxicity.
- 6 -

B. Absence of In -Stream Impacts from Non -Precipitation
Events.
As indicated above, the supplemental 24-hour testing
was conducted in accordance with the Initial Plan on
two occasions (3/22/06 and 3/27/06) when deicing agents
were applied during non -precipitation (defrosting)
events. Samples were drawn at one -hour intervals at
the approximate points where Brush Creek and Horsepen
Creek depart the Airport Property. No glycol (either
propylene or ethylene) was detected in any of these
samples. (See Exhibit 1.) These results suggest that
deicing agents are not being discharged during non -
precipitation events at all, or at least not in suffi-
cient quantities to be detectable in the receiving
streams.
C. Verification of Expected Runoff Volumes.
The flow meters installed at the five selected out -
falls (4, 6, 24, 26 and 27) enabled PTAA to monitor
the volume of storm water discharged from the outfalls
after rainfall. (There was no significant freezing
precipitation after installation of the monitors.) The
actual storm water volumes, as measured by the flow
meters, were then compared to the runoff volumes that
would have been estimated by PTAA for comparable storm
events based on PTAA's previous calculations of the
total area draining to the various outfalls and the
runoff coefficients for each area. This comparison
confirmed the actual results from the flow meters
closely matched the estimated volumes. Therefore it
appears that PTAA has correctly identified the areas
contributing runoff to each of the outfalls as well
as the applicable runoff coefficients and that these
values can be used to calculate reliable estimates of
runoff volumes in the future.
- 7 -

MEASURES FOR UPCOMING (2006-2007) WINTER SEASON
I. Continuation of Current Measures.
During the 2006-2007 winter season, PTAA will continue the
measures that were previously adopted in Section III of the
Initial Plan, including the following:
• Continued consultation with tenants regarding their use
of deicing agents and their proposals for reducing the
impact of such use;
• Requesting tenants to report the volume and type of
deicing agent that they have on hand at the beginning of
the season and their expected use;
• Requesting that tenants report each application of
deicing agents using Exhibit 5 of the Initial Plan; and
• Avoidance of deicing over the storm water drains in the
aircraft aprons.
II. Testing Program for the 2006-2007 Winter Season.
To obtain the additional information needed for PTAA to
assess the impact of deicing agents at the Airport and to
finalize its plan for deicing agents, PTAA will undertake
the following tests during the 2006-2007 winter season, in
addition to the monitoring required under Part II of the
NPDES Permit:
A. 24-Hour Testing at Stream Exit Points.
Weather permitting, PTAA will perform the 24-hour test-
ing program described in the Initial Plan after two
precipitation events, selected by PTAA, when deicing
agents are used at the Airport. The tests will be
performed at the points previously selected where Brush
Creek and Horsepen Creek depart the Airport Property.
Test samples will be drawn at one -hour intervals, and
will be analyzed for propylene and ethylene glycol and
for Biological Oxygen Demand (BOD), as called for in
the Initial Plan. In addition, Dissolved Oxygen (DO)
levels (including water temperature, depth, and flow
observations) will be measured at one -hour intervals to
- 8 -

obtain both instantaneous DO values and a daily aver-
age. If the samples from the first testing event indi-
cate that glycol persists in measurable quantities for
more than 24 hours, the hourly sampling for the second
event will be lengthened appropriately.
These tests will enable PTAA to complete the testing
program that it had planned for last year but was un-
able to accomplish due to the abnormal weather condi-
tions. The data from these tests will be used to
calculate (i) how glycol moves through the system, and
the peak and duration of glycol concentrations, (ii)
how long BOD persists in the receiving streams and at
what levels, (iii) the extent of any correlation
between glycol concentrations and BOD, and (iv) whether
glycol is contributing to any exceedence of the appli-
cable Water Quality Standards.
B. Further Investigation of Toxicity.
As indicated above, there appears to be a lack of cor-
relation between glycol concentrations and acute tox-
icity results. This conclusion will be further exam-
ined by comparing the glycol and toxicity results
during the course of the 2006-2007 season to determine
if the pattern observed in the past two seasons is
repeated.
C. Dry Event Testing.
Given the absence of deicing agents in the 24-hour
samples that were taken last winter after non -
precipitation events, PTAA does not propose to repeat
24-hour testing for non -precipitation events in the
upcoming winter.
D. Flow Meters.
The flow meters installed at outfalls by PTAA were
removed at the end of the season. Since the data
from the flow meters verified the factors that PTAA
would use to estimate runoff volumes (drainage areas
and runoff coefficients), PTAA appears to have a reli-
able means of making such estimates in the future and
does not propose to reinstall the flow meters at the
outfalls.
- 9 -

FINAL PLAN
PTAA does not have sufficient information at this time to
determine whether any exceedence of Water Quality Standards is
resulting from the use of deicing agents at the Airport and, if
so, the additional measures that would be appropriate to achieve
compliance with Water Quality Standards. PTAA will submit an
update to this Plan to DWQ by July 1, 2007 with the status of the
measures taken to date and the results of the testing during the
2006-2007 season. If sufficient information has been obtained by
then to finalize the Plan, the update will include a final set of
measures to be undertaken by PTAA under the Plan as well as a
timetable for implementation.
- 10 -

Exhibit 1 Summary of 2005-2006 24-Hour Monitoring Results

Report ofNPDE.S Permit C'nnipllanre Sampling - Mnrch 11, 1006 Event
PTIA, Greensboro. NC
,tIACJeC Project 6262-05-0939 Task Oa. 01
TABLL 3
NPDES Permit Compliance Sampling Results
K
E
�
�
T
Parameter
K O
~'
u
O q
v
u
T
'r
O
a,
0
W
a
0
CO
Client
Date
Collect Time
mg/I
u8/1
UB/1
Sample ID
Collected
(24-hours)
Stream-6A ir
3/22/2006
10:05
5.0
ND
ND
Stream-6B
3/22/2006
I1:00
BRL
ND
ND
Stream-6C
3/22/2006
12:00
3.6
ND
ND
,Stream-6D
3/22/2006
13:00
3.2
ND
ND
Stream-6E
3/22/2006
14:00
BRL
ND
ND
Stream-6r
30212006
15:00
HRL
ND
ND
Stream-60
3/22/2006
16:00
BRL
ND
ND
Stream-6H
3/22/2006
17:00
3.7
ND
ND
Stream-61
3/22/2006
18:00
3.5
ND
ND
Stream-6J
3/22/2006
19:00
BIZL
ND
ND
Stream-6K
3/22/2006
20:00
BRL
ND
ND
Stream -61.
3/22/2006
21:00
BRL
ND
ND
Stream-6M
3/22/2006
22:00
8.4
ND
ND
Stream-6N
3/22/2006
23:00
33
ND
ND
Stream-60
3/23/2006
0:00
BRL
ND
ND
Stream-6P
3123/2006
1 1:05
BRL
ND
ND
Stream -6Q
3/23/2006
2:00
4.8
ND
ND
Stream-6R
3/23/200G
3:00
BRI,
ND
ND
Stream-6S
3/23/2006
4:00
BRL
ND
ND
Stream-6-f
3/23/2006
5:00
BRL
ND
ND
Stream-6U
3/23/2006
6:00
3.5
ND
ND
Stream-6V
1 3/23/2006
7:00
BRL
ND
ND
Strcam-
3/23/2006
8:00
BRI-
ND
ND
Stream-6a
3/23/2006
'J:00
3.4
ND
ND
NOTES:
mg/I - milligrams per liter
ug/l - micrograms per liter
BRL= Below Reporting Limit
ND -Not Detectul
April 2006
Prepared by: � jLry Date: G6
Checked by:!? I Dmc:_ e[
Exhibit 1 - 2 -

Repon ofSPOES Permit Compliance Sampling - bla rh 22. 2006 Emir
P77A. Crcembow, NC
MAMC Prefect 6262-05.0939+nsk 04. 01 TABLE 3
(continued)
NPDES Permit Compliance Sampling Results
ti
C
Client Sample ID
x O
g
V_
C
0
0
Client Sample
Dale
Collect Time
mg/I
ug/I
ug/I
II)
Collected
(24-hours)
Stream -I IA
3/22/2006
9:28
3.8
ND
ND
Stream-IIB
3/22/2006
10:30
3.9
ND
ND
Stream-11C
3/22/2006
11:30
BRL
ND
ND
Stream-IID
V22/2006
12:30
3.3
ND
ND
Stream-11B
3/22/2006
13:30
BRL
ND
ND
Stream-1IF
3/22/2006
14:30
3.5
ND
ND
Stream -IIC
3/22/2006
15:30
3.9
ND
ND
Stream -I I
3/22/2006
16:30
4.0
ND
ND
Stream-I11
3/22/2006
17:30
BRL
ND
ND
Stream -IIJ
3/22/2006
18:30
BRI,
ND
ND
Stream -IIK
3/22/2006
19:30
BRL
ND
ND
Stream - I IL
3/22/2006
20:30
BRL
ND
ND
Stream -I1 W*
3/22/2006
21:30
7.3
ND
ND
Stream -I IN
3/22/2006
22:30
11
ND
ND
Stream-I1O
3/22/2006
23:30
12
ND
ND
Stream -IIP
3/23/2006
0:30
5.2
ND
ND
Stream -1I
3/23/2006
1:30
3.4
ND
ND
Stream -IIR
3/23/2006
2:30
BRL.
ND
ND
Stream-IIS
3/23/2006
3:30
4.9
ND
ND E
Stream-111'
3/23/2006
4:30
3.9
ND
ND
Stream-11U
3/23/2006
5:30
BRL
ND
ND
Stream-IlV
>/23/2006
6:30
4.3
ND
ND
Stream-1IM14*
3/23/2006
7:30
4.1
ND
ND
t Stream-IIX
3/23/2006
3:30
3.2
ND
ND
NOTES:
mg/I - milligrams per liter
ug71- nucrogmuns per liter
BRL= Below Reporting Limie
ND -Not Detected
* sample ID label not in
alphanumeric sequence
April 2006
Prepared by: '- Dale: �% of
Checked by: f Date _Ylaa
Exhibit 1 - 3 -

Report of NPD&S Permit Corriplinnce .Sampling— March 27, 2006 F-rrw
PT/A, Greensboro, NC
MACTEC Project 6262-05-0939 task 04.02
TABLE3
NPDES Permit Compliance Sampling Results
c
n-_
U
T
T
co q
C�
Parameter
O Om
la
r
T
Q
W
a
O
ro
Client
Date
Collect Time
mg/I
ug/l
ug/I
Sample 11)
Collected
(24-hours)
Stream -6A
3/27/2006
10:10
BRL
ND
ND
Stream-6B
3/27/2006
11:05
BRL
ND
ND
Stream-6C
3/27/2006
12:05
BRL
ND
ND
Stream -6D
3/27/2006
13:05
2.7
ND
ND
Stream-6E
3/27/2006
14:05
BRL
ND
ND
Stream-6F
3/27/2006
15:05
BRL
ND
ND
Stream-6G
3/27/2006
16:05
BRL
ND
ND
Stream -611
3/27/2006
17:05
2.8
ND
ND
Stream-61
3/27/2006
18:05
2.7
ND
ND
Stream -6J
3/27/2006
19:05
2.7
NI)
ND
Stream-6K
3/27/2006
20:05
BRL
ND
ND
Stream-6L
3/27/2006
2L05
BRL
ND
ND
Stream-6M
3/27/2006
22:05
BRI,
ND
ND
Stream -6N
3/27/2006
23:05
BRL
ND
ND
Stream-60
3/28/2006
0:05
BRL
ND
ND
Stream -61'
3/28/2006
L05
BRL
ND
ND
Stream-6R'
3/28/2006
2:05
BRI-
ND
ND
Stream-6 "
3/28/2006NTO
BRL
ND
ND
Stream-6S
328/2006BRL
ND
ND
Stream-6T
3/28/2006BRL
ND
ND
Stream-6U
3/28/2006BRL
ND
ND
Stream-6V
3/28/2006
BRL
ND
ND
Stream-6W
3/28/2006
8:05
BRI,
ND
ND
Stream-6X
3/282006
9:05
BRI.
ND
ND
NOTES:
mg/I - milligrams per liter
uy9 - micrograms per liter
BRI. - Below Reporting Limit
ND=Not Detected
April 2006
Prepared by: Date:
Checked by: r/N/ Date. o'/Oi
Exhibit 1 - 4 -

Repon ofATI)ES Permit Compliance Smnpiing -,March 27, 2006 Even
Plld, (:rceruGnm, NC
A1AC XPrnjccr 6262.05-0939tmk04-01 TABLE
(continued)
NPDES Permit Compliance Sampling Results
c
m
v
Q
O
T
_T
Client Sample lU
09 Q
o 00
u
v
n
V
rJ'
O
.O
_O
m
Client Sample
Date
Collect Time
nrg/l
ug/I
ug/l
Ill
Collected
(24-hours)
Stream -MA
3/27/2006
9:45
3.1
ND
ND
Stream -IIB
3/27/2006
10:45
3.1
ND
ND
Stream -IIC
3/27/2006
11:45
2.7
NO
ND
Stream -I ID
3/27/2006
12:45
BRL
ND
ND
Stream -IIE
3/27/2006
13:45
BRL
ND
ND
Stream -IIP
3/27/2006
1445
BRL
ND
ND
Stream -IIG
3/27/2006
15:45
BRL
ND
ND
Stream-111'1
3/27/2006
16:45
BRL
ND
ND
Stream -111
3/2712006
17:45
2.7
ND
ND
Stream -111
3/27/2006
18:45
3.3
ND
ND
Stream -1IK
3/27/2006
19:45
BRL
ND
ND
Stream -111,
3/27/2006
20:45
BRI,
ND
ND
Stream -IIM
3/27/2006
21:45
BRL
ND
ND
Stream -IIN
3/27/2006
22:45
BRL
ND
ND
Stream -I10
3/27/2006
23:45
BRL
ND
ND
Stream -IIP
3/2S/2006
0:45
BRL
ND
ND
Stream -1IR"
3/28/2006
1:45
BRL
ND
ND
Stream -1IQ*
3/28/2006
2:45
BRL
ND
ND
Stream -11S
3/28/2006
3:45
BRL
ND
ND
Stream -I IT
3/28/2006
4:45
1310.
ND
ND
Stream -IIU
3/23/2006
5:45
BRL
ND
ND
Stream-IIV
3/23/2006i
6:45
BRL
ND
ND
Stream-11W
3/28/2006
7:45
BRI-
NO
ND
Stream-IIX
3/278/2006
j 9:45 -
13RL
ND
ND
mg/1 - milligmms per h1cr
ug/l - micrograms per liter
BRL- Below Reposing Limit
ND=Not Dctcacd
3/28/2006
Ayr it 2006
Prepared by: _ Date: 1 °6
Checked by: cl//! Datc; JuL
Exhibit 1 - 5 -

i map:/Iken.pickle°h40d wq.denr. ncmail. net @ ems. ncmai I.net:143/fete...
Subject: Re: TMDL language
From: Bobby Blowe <[e-mail]>
Date: Wed, 05 Jan 2005 11:23:38 -0500
To: Ken Pickle <[e-mail]>
THANKS Ken, that works for me.
Ken Pickle wrote:
Bobby,
If it's accurate to paraphrase the commenter's concern with TMDLs this way, "The
receiving streams are impaired, and DWQ has been delinquent in not establishing a
TMDL, and any permit issued should require monitoring and limits on the pollutants
identified in a TMDL.", then I would comment as follows.
a) Some future protection of the receiving water might be achieved by inclusion of
language similar to the TMDL language that we use in general permits, in the event
that a future TMDL is ever established, and if the permittee is ever identified as
a contributing source. For now, we could still require monitoring for suspect
parameters, even in the absence of a TMDL. Even when we require monitoring in a
stormwater permit, we don't ususally have limits on the parameter.
b) It is not part of the permitting function to establish TMDLs. So, we can't
really rectify the complaint that DWQ has been delinquent in establishing a TMDL in
the airport receiving waters, if indeed that is part of the commenter's issue.
c) I've contacted Raj (Narayan Rajbhandari) in the TMDL unit, and he'll let me
know if they're planning any near -term TMDLS for Horsepen Creek, Brush Creek, or
the Deep River. I'll let you know as soon as I know.
d) As to skirting whether or not a TMDL might be imminent, I'm not sure how to
address it. It seems to risky to make too much of any response that Raj provides.
Not that I doubt him, or his response, it's just that what weight should we give in
a permit recommendation to some presumed future regulatory action?
Ken
Bobby Blowe wrote:
Thanks Ken. That addresses part of the problem, but do you know if there is any
plan to develop a TMDL? or should I skirt that one?
Ken Pickle wrote:
Bobby,
Sorry for the delay. Here's the type of thing we could use for a permit TMDL
provision.
Ken
Construct .on Grants f. Loans Section
1633 Mail Service Center
Raleigh, NC 27699-1633
Phone: [phone]
Fay.: (919) '715-6229
I of 1 1/5/2005 11:31 AM

Michael F. Easley, Governor
co r
� Y
MEMORANDUM:
William G. Ross Jr., secretary
North Carolina Department of Environment and Natural Resources
January 6, 2005
To: Alan W. Klimek, P.E., Director
Division of Water Quality
Through: Coleen Sullins, Deputy Director
From: John R. Blowe, P.E., Chief
Construction Grants and Loan ct n
Subject: Report and Recommendations
Draft Stormwater NPDES Permit # NCS000508
Piedmont Triad Airport Authority
Alan W. Klimek, P.E. Director
Division of Water Quality
As you requested,) served as Hearing Officer for a public hearing to obtain comments
concerning the draft NPDES stormwater permit for the Piedmont Triad Airport Authority. The
hearing was held at 7:00 p.m. on September 28, 2004 at the Greensboro Coliseum Special Events
Center in Greensboro, North Carolina. The purpose of the hearing was to provide an opportunity
to obtain all pertinent public comment on whether to issue the permit as drafted or issue a
modified version of the draft permit.
BACKGROUND
A copy of the draft permit and a Fact Sheet prepared by the Division of Water Quality's
Stormwater Permitting Unit are can be found in Attachment 1. The Fact Sheet provides an
excellent explanation of the permit as well as its unique features. Some of the most important
components of this permit are the special conditions linking it to certain conditions contained in
a previously issued 401 Water Quality Certification. These conditions address stormwater
management, the minimization of de-icing material in stormwater discharges, and additional
sampling requirements.
PUBLIC HEARING
The public hearing was well attended by approximately forty people. Mr. Bradley Bennett of the
Division of Water Quality's Stormwater Permitting Unit gave a brief presentation on the
background and history of the Division's stormwater permitting program and the issues
surrounding the draft permit for this facility. His presentation is contained in Attachment 2.
Thirteen of those attending provided oral comments. Folks wishing to augment their oral
comments as well as some who did not attend the hearing provided a total of fourteen sets of
written comments within the public comment period ending October 12, 2004. A copy of the
registration list and a'summary of the written comments received is contained in Attachments 3
& 4.
Construction Grants and Loans Section
1633 Mail Service Center Raleigh NC 27699-1633 T�iOne 1
Phone: [phone] / FAX: [phone] / Internet: www.nccgl.net 1 V OI�thCarolina
An Equal Oppodunity/Affirmative Action Employer- 50% Recycled/10°/ Post Consumer Paper Allt mallf

Many of the oral comments were in the form of questions related to ongoing activities at the
airport, rather than the specifics of this particular permit. Those comments centered around
requests for existing homeowner wells to be tested / monitored for the presence of antifreeze
compounds; the slate's role in addressing alleged current water quality violations in the streams
due to erosion and deicing activities; and the potential for greater downstream flooding due to
airport expansion activities. Mr. Steve Mauney and several other staff members of the Winston-
Salem Regional Office were in attendance and offered to field those questions after the hearing.
Other pertinent oral comments focused on the quality of the airport's stormwater runoff
ultimately flowing into Class WS411 waters; whether or not the PTAA should receive a NPDES
'permit for industrial wastewater, and the water quality problems currently being experienced by
a downstream resident during periods of heavy deicing activities at the airport. A more detailed
account of most of these concerns is presented in the written comments.
One of the recurring issues raised by several folks in both the oral and written comments is
whether the stormwater discharged from the Piedmont Triad International Airport (PTIA) should
be classified as industrial wastewater or as stormwater from an industrial activity. There has
been much discussion on the distinction between these two classifications on previous permitting
decisions. DENR and the Division of Water Quality have determined that airports are
considered industrial activities requiring a NPDES permit for managing stormwater discharges. I
have found nothing in either the oral or written comments which would lead me to believe that
this determination should be revised or further debated.
Several commenters, including Mr. Curry Jones of EPA -Region 4, have asserted that the
receiving streams are impaired, and that DWQ has been delinquent in not establishing a Total
Maximum Daily Load or TMDL. Some also feel that any permit issued should require
monitoring and limits on the pollutants identified in a TMDL. According to folks in the
Division's Modeling and TMDL Unit, the identified water bodies, Horsepen Creek, Brush Creek;
and Deep River, are identified as impaired due to biological impairment. A TMDL for the
biological impairment for the three water bodies will be developed, but an anticipated date for
the TMDL development has not yet decided. The Division continues to monitor the water bodies
for more information needed to develop the TMDL.
In addition to the biological impairment, the Deep River is also identified as impaired due to
fecal coliform bacteria. Fecal Coliform TMDL for the river has already been submitted to the
US EPA for approval. The TMDL suggests to reduce fecal coliform by 75% in the river.
Other commenters, including Ms. Christine Peeler of the Piedmont Quality of Life Coalition, are
concerned that the draft permit does not:
a) contain numeric effluent limitations for the PTIA
b) include groundwater protection measures
c) include a requirement for in -stream glycol testing
d) require monthly inspections during the cold weather months
The North Carolina Wildlife Resources Commission (NCWRC) is also concerned about
groundwater impacts from deicing compounds and recommends that treatment of aircraft deicing
fluid be implemented as soon as possible. They also recommend that BOD and TSS monitoring
be performed at least quarterly during the first year. Streambank erosion is also a concern and the
NCWRC suggests that appropriate stormwater quantity and quality control measures be
implemented to prevent further degradation.

RESPONSE
By letter dated November 10, 2003, the Division of Water Quality issued 401 Water Quality
Certification # 3428 to the PTIA for the proposed Runway 5U23R, proposed New Overnight
Express Air Cargo Sorting and Distribution Facility, and associated developments. A copy of
this certification is contained in Attachment 5.
Section D, page 13 of 21 of the draft Stormwater.NPDES Permit #NC000508, which is the
subject of this report, incorporates conditions 8, 9, 10, and 11 of the 401 Certification as a
binding component of that Permit. Those conditions require, among other things, that a) a retrofit
stonnwater control plan as necessary to meet Water Quality Standards for the entire PITA be
submitted within one year, b) the design of stormwater control measures to maintain streambank
stability must be approved before any of the facilities are occupied, c) an additional stomiwater
management plan (including a spill containment and treatment failure plan) to ensure that Water
Quality Standards are not violated as the result of runoff contamination by deicing and/or similar
agents be submitted and approved within one year, and d) any increase in duration of discharges
in excess of the pre -construction discharge be evaluated to prevent additional stream bed or bank
erosion.
Documentation in support of Conditions # 8 and 10 of the 401 Certification has been submitted
and approved by the Division of Water Quality's 401 Oversight/Express Permitting Unit in
November, 2004. Excerpts from the approved document are contained in Attachment 6.
The incorporation of the 401 Water Quality Certification conditions into the Draft Stormwater
NPDES Permit and the subsequent approval of the documents submitted in response to
Conditions # 8 and 10 appear to have addressed most of the key concerns expressed by die
commenters. The PTAA has adopted a plan to ensure that Surface Water Quality Standards are
not violated as a result of runoff containing deicing fluids from both new and existing facilities
covered by the 401 Certification. The FedEx facility in particular will be required to construct a
valved diversion chamber capable of diverting runoff containing deicing fluids into a specific
pond or completely retaining the runoff if necessary. In the event deicing agents in the runoff
from the FedEx premises contribute to a violation of Surface Water Quality Standards, FedEx
will have the option to either recover, recycle, treat onsite or discharge into the city of
Greensboro's sanitary sewer system if proper permits are obtained. Similar conditions will be
placed on other new tenants. The PTAA has also adopted a plan for its existing facilities. Under
that plan, the PTAA will conduct tests in addition to those contained in the Draft Stormwater
permit. Those tests will include sampling for BOD and toxicity at various locations in the
receiving streams to establish baseline data and testing again following deicing events.
Flowmeters will also be installed at representative outfalls to measure total runoff volume.
The one major issue that does not seem to be adequately addressed in the draft permit concerns
the possibility for groundwater and/or well contamination from the deicing fluids. The
stormwater management ponds receiving runoff containing deicing fluids are not required to be
lined with an impervious liner. Consequently the plans submitted for the ponds to serve the
proposed FedEx facility do not indicate a liner nor the construction of groundwater monitoring
wells.

As for the TMDL issue, some future protection of the receiving waters might be achieved by
inclusion of language similar to the TMDL language that we use in general permits, in the event
that a future TMDL is ever established, and if the permittee is ever identified as a contributing
source. Numeric limits could then be imposed if warranted.
RECOMMENDATIONS
It is my understanding from discussions with staff of the Division's Stormwater Permitting Unit
that the Qualitative Monitoring frequency contained in the draft permit is twice that which is
usually required. However, due to the sensitive nature of the receiving waters downstream of the
stormwater discharges covered by this permit, and in order to more accurately gage the
effectiveness of the Best Management Practices employed onsite, it is recommended that
additional Analytical Monitoring requirements be imposed. More specifically:
1) The receiving stream analytical monitoring and frequency as outlined in
the approved PTIA Stormwater Management Plan for Deicing Agents
should be incorporated into the NPDES permit. This would include BOD
and Toxicity testing following deicing events at the same stream locations
used to establish the baseline data.
2) The Outfall Analytical Monitoring frequency for Propylene and Ethylene
Glycol should also be increased to include sampling following each
deicing event.
3) The monitoring frequency for all parameters should be increased to no less
than quarterly throughout the life of the permit.
In addition, it is recommended that any stormwater management ponds receiving runoff
containing deicing fluids be lined with a synthetic liner to protect groundwater resources. In lieu .
of a liner, strategically located groundwater monitoring wells should be installed to ensure that
no contaminants are impacting the groundwater.
1'd like to thank the staff of the NPDES Stormwater Permitting Unit for their assistance in this
effort and commend them for developing a very thorough and comprehensive permit. I'll be glad
to meet with you to discuss any of these recommendations at your convenience.

i map:Hkcn.picklc%40dwq.denr.ncmail. net @ cros.ncmai l.net:143/fete...
Subject: Re: A question about near term TMDLs
From: Bobby Blowe <[e-mail]>
Date: Thu, 06 Jan 2005 08:35:55 -0500
To: Ken Pickle <[e-mail]>
Thanks Ken. I added it.
Ken Pickle wrote:
Raj,
Thanks for your quick response
Ken
Narayan Rajbhandari wrote:
Dear Ken,
I believe this will be helpful for Bobby. Thanks.
The identified water bodies, Horsepen Creek, Brush Creek, and Deep River, are
identified as impaired due to biological impairment. TMDL for the biological
impairment for the three water bodies will be developed, but anticipated date for
the TMDL development is not yet decided. The NC DWQ is still monitoring the water
bodies for more information needed to develop the TMDL.
In addition to the biological impairment, the Deep River is also identified as
impaired due to fecal coliform bacteria. Fecal Coliform TMDL for the river has
already been submitted to the US EPA for approval. The TMDL suggests to reduce
fecal coliform by 75% in the river. You can download the TMDL document from the
DWQ website, http://h2o.enr.state.nc.us/tmdl/TMDL_list.htm#Draft_TMDLS.
I hope I addressed all your concerns
available anytime. Thanks.
With regards,
Raj
Ken Pickle wrote:
If you need further information, I am
Raj,
Thanks for your help. Our unit has put on public notice a draft permit to
discharge stormwater from the Piedmont Triad International Airport. A public
hearing has been held, and the hearing officer is considering public comments
received to date in preparation for his recommendation to the Director. My
hearing officer (Bobby Blowe) is asking if I know of any plans for a TMDL that
would affect the Piedmont Triad International Airport in Greensboro. As I
understand it, the airport drains to Horsepen Creek, Brush Creek, and the Deep
River, all in the Cape Fear River Basin.
Do we have plans for issuing TMDLs on any of these receiving waters? In what
time frame? For what parameters? Is there any other relevant information that
I should relay to the hearing officer?
Ken
Construction Grants & Loans Section
1 of 2 1/6/2005 9:45 AM

Piedmont Triad Airport
Subject: Piedmont Triad Airport
From: [e-mail]
Date: Mon, 10 Jan 2005 13:50:56 -0500
To: brad [e-mail]
Bradley:
Based on our comments and review of the resultant permit, we feel that
the Piedmont Triad Permit meet our requirements.
Mike Mitchell
1 of 1 1/10/2005 2:55 PM

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P. E., Director
January 10, 2005
Edward A. Johnson, Executive Director
Piedmont Triad Airport Authority
POB 35445
Greensboro, North Carolina 27425
1�
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Permit No. NCS000508
Piedmont Triad International Airport
Guilford County
Dear Mr. Johnson:
In accordance with your application for a stormwater discharge permit received on April 16,
2004, we are forwarding herewith the subject state - NPDES permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215 A and the Memorandum of Agreement
between North Carolina and the US Environmental Protection agency dated May 9, 1994
(or as subsequently amended).
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, Post Office Drawer 27447, Raleigh, North Carolina 27611 -7447. Unless
such demand is made, this decision shall be final and binding.
Please take notice this permit is not transferable. Part III, B.2. addresses the requirements to be
followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be required
by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act
or any other federal, state, or local governmental permit that may be required.
If you have any questions concerning this permit, please contact Ken Pickle at telephone number
919/733-5083 ext. 584.
Sincerely;
00, K "
Alan W. Klimek, P. E.
cc: Mr. Mike Mitchell, EPA Region IV
Winston-Salem Regional Office
DWQ Central Files
Stormwater Permitting Unit Files
6Y 1 I&MR61I1f.11'
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

NCSOD0508
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELUVE NATION SYSTEM
In compliance with the provisions 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,
Piedmont Triad Airport Authority
is hereby authorized to discharge stormwatet from facility located at
Piedmont Triad International Airport
Greensboro, NC. ..
Guilford County
to receiving waters designated as Brush Creek, Deep River, Horsepen Creek, and their tributaries
in the Cape Fear River Basin in accordance with the discharge limitations, monitoring
requirements, and other conditions set forth in Parts I, II,111, IV, V and VI hereof.
This permit shall become effective February 1, 2005.
This permit and the authorization to discharge shall expire at midnight on January 31, 2010.
Signed this day January 10, 2005.
Alan Klimek, PE, Director
Division of. Water Quality
By the Authority of the Environmental Management Commission

Permit No. NCS000508
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B:. Permitted Activities .
Section C: Location Map
PART H MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B: Analytical Monitoring Requirements
Section C: Qualitative Monitoring Requirements
Section D: Stormwater Management Requirements from the Water Quality Certification .
Section E: Minimization of De-icing Materials in Stormwater.
PART III STANDARD CONDITIONS
Section A: Compliance and Liability
1. Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
5. Oil and Hazardous Substance Liability
6. Property Rights_
7. . Severability
8. Duty to Provide Information
9. Penalties for Tampering
10.. Penalties for Falsification of Reports
Section B: General Conditions
1. Individual Permit Expiration

imap://ken.picklc%40d wq.denr.nemail. net @ cros.ncnmi I.net:143/fete...
. ..1i
Subject: PTI must monitor pollutants
From: Susan Massengale <[e-mail]>
Date: Tue, 11 Jan 2005 09:50:14 -0500
To: DWQ Clips<[e-mail]>, Ken Pickle <[e-mail]>,
Bradley Bennett <[e-mail]>
From the Greensboro News -Record
PTI must monitor pollutants
1-11-05
By Amy Dominello Staff Writer
News & Record
Pollutants from Piedmont Triad International Airport flowing into nearby streams will now be disclosed
to the state as part of a storm -water permit issued Monday.
The five-year permit, issued by the N.C. Division of Water Quality, will allow the airport to continue to
discharge storm -water runoff into the nearby Deep River and Brush and Horsepen creeks, but with
greater restrictions and monitoring. It also requires the airport to disclose to the state for the first time
what pollutants may be running into the waterways.
The permit, required by federal law and implemented by the state, applies to storm -water runoff from
existing operations and any expansions, such as the overnight FedEx hub. The hub is under construction
and expected to open in 2009.
PTI has been operating under a federal pollution -runoff permit issued in the mid-1990s. But opponents
of the FedEx hub have pushed PTI to apply for the state permit, saying the airport is violating state and
federal law by not having it. The state says PTI has not violated any laws, but airport officials were
encouraged to apply for the permit since 2002.
Regulations in the permit include strict monitoring of chemicals used for de-icing planes, said Susan
Massengale, a spokeswoman for the Division of Water Quality. Monitoring of those chemicals will be
required for every storm they are used.
Depending on weather, that could be more stringent than the permits issued for the state's two other
major airports in Charlotte and Raleigh, said Massengale. Charlotte is required to monitor five situations
a year in which de-icing chemicals are used; Raleigh must monitor the chemicals three times a year.
The airport must also develop a management plan for de-icing materials within six months of the Feb.
effective date of the permit.
The state decided to beef up requirements around de-icing materials from a July draft of the permit
based on comments they heard at a September public hearing, Massengale said. About 40 people
attended and many at the hearing felt the waterways near the airport were already polluted.
Specific storm -water pollution and prevention plans surrounding other chemicals are also outlined in the
permit.
l of 2 1/13/2005 8:24 AM

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ASrport officials were pleased the permit was issued, but had not seen a copy of it late Monday, said
George House, an attorney for PTI.
In July, PTI officials agreed to comply with additional storm -water control measures outlined in the
draft permit. PTI can challenge regulations in the permit, but must do so within 30 days of receiving it.
David M. Clark, a lawyer for opponents of the FedEx hub, could not be reached for comment late
Monday, but has said he is waiting to see what type of storm -water controls will be required of the
airport. Opponents have challenged in court other permits for the FedEx hub.
While opponents had not seen the permit late Monday, they said it likely did not go far enough in
protecting waterways near the airport.
Without on -site monitoring, "it isn't adequate to protect our drinking water," said Chris Peeler, president
of the Piedmont Quality of Life.
Opponents have also questioned why the state's other two major airports, in Charlotte and Raleigh, have
had their permits for much longer and why those two airports have industrial wastewater controls
included in their permits. Monday's permit for PTI doesn't include wastewater.
Results of the monitoring and storm -water plans will be public record, Massengale said.
Contact Amy Dominello at 883-4422, Ext. 248, or [e-mail]
375 7o9i
2 of 2 1/13/2005 8:24 AM

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Subject: Re: [Fwd: PTIA meeting]
From: Bradley Bennett <[e-mail]>
Date: Mon, 24 Jan 2005 10:53:05 -0506
To: Tom Reeder <[e-mail]>
CC: Ken Pickle <[e-mail]>
Tom
I agree that we would not be inclined to change the permit at this point. The rules
do allow that some monitoring changes can be made as minor modifications. A request
may be more appropriate after they have implemented the permit for a while and have
been able to document reasonable modifications to the permit.
BB
Tom Reeder wrote:
I do not think that we have very much flexibility in amending the permit after it
has been signed by Alan and posted. Bradley - Is that correct? Thanks.
Ken Pickle wrote:,
Tom,
Mickie Elmore has suggested a meeting time of 11:00 instead of 9:00 this Friday.
Same location, same participants. -
They have identified two issues for discussion:
a) They're concerned about the permit requirement to monitor and sample after
every de-icing event. For instance, Mickie reports that in December 2004 there
were nine de-icing events during that rather mild month. In part because
operators sometimes de-ice even for frost, not accompanied by precipitation. So,
there would be no runoff after these events. Consequently, I get the impression
that they will want to effectively relax the requirement for sampling after every
de-icing event , and probably they will want some form of written clarification
from us on our intent/our interpretation of the permit requirement. I was not
aware that there were de-icing events not associated with precipitation, and I
don't think that figured into our development of the permit conditions. Going
into the meeting I'm inclined to make some accomodation on this point.
b) They want to talk about the large number of samples and the large cost
associated with the sampling requirements that appeared in the final version of
the permit.
Ken
-------- Original Message
Subject: PTIA meeting
Date: Mon, 24 Jan 2005 08:38:10 -0500
From: Ken Pickle <[e-mail]> <mailto:[e-mail]>
To: Tom Reeder <[e-mail]> <mailto:[e-mail]>
CC: Bradley Bennett <[e-mail]>
<mailto:[e-mail]>
Tom,
We're scheduled to use the small 12fcr at 9:00, Friday, Janury 28, 2005.
Mickie Elmore (PTAA), Van Noah and Kevin Baker (consultants) are the identified
participants. They want to talk about the monitoring, if I understand their voice
message correctly. I'm waiting on a return call from them to confirm the time on
Friday.
Ken
I of 2 2/2/2005 7:39 AM

f
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
MEMO
January 25, 2005
To: Bradley Bennett
From: Ken Pickle
Subject: Public comment period questions from J. R. Black about NCS000508, PTIA
Background
As I understand it, Mr. Black has complained that he has received no answers to questions
posed to the DWQ during the public comment period. I recall that Bobby Blowe, the hearing
officer, clarified during the public hearing that DWQ would not provide a response to
individual questioners for questions raised verbally during the hearing. Bobby further
clarified that DWQ would be glad to respond to written questions received during the public
comment period.
Review of correspondence from J. R. Black
1. The working project file contains two instances of correspondence with Mr. Black.
2. The first piece of correspondence begins "J. Richard Black — Comments presented at
the Public Hearing 28 September 2004, regarding Draft NPDES Stormwater Permit to
PTAA for Stormwater Discharge from PTIA." It contains several questions as follows.
3. "Who is responsible for the violation of the lack of a NPDES Permit required by a
Federal Government Agency and administered by the State? And, seemingly
continuing on the same point, "A permit.that was required in 1992, but was only
applied for earlier this year of 2004... some 12 years later, and after numerous
reminders by the State?"
4. "Where has the Federal Environmental Protection Agency, the EPA, been in
monitoring the lack compliance with its Federal Clean Water Act for these many
years?"
5. "Why has the NPDES Unit of DWQ not upheld the requirements of the EPA's Federal
Clean Water Act by enforcing the requirement that Piedmont Triad Airport Authority,
(PTAA), acquire an individual NPDES Permit, on a timely basis, for the operation of
Piedmont Triad International Airport, (PTIA), under Phase 1 of the NPDES as is
stipulated for Airports?"
"But again, we must ask the question — who is responsible for enforcing a violation
of the lack of a NPDES Permit required by the federal government and administered
by the state?"
s:►`Ar
NCDENR -
Customer Service
1 800 623-7748
Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]

Bradley Bennett
Page 2 of 3
January 25, 2005
N
7. "Why is DWQ, at this late time, belatedly trying to just issue a State Stormwater
Permit for PTIA to discharge "'lust„ Stormwater instead of the National NPDES
Wastewater and Stormwater Permit when PTIA Airport operations are currently
discharging both Industrial Wastewater and Industrial Stormwater into WS-III
drinking waters and into streams classified as 303(d) impaired streams?"
8. "How can DWQ issue this Draft NPDES Permit for Current Operations For 5 years,
When this is their first Permit, albet only 12 years late?"
9. "How can DWQ issue this Draft NPDES Permit For current operations and expansion
operations When the current operations have not yet been verified and established?
When the unknown operational expansions are not taking place for 5 years?"
10.In addition to the above complaints in the form of rhetorical questions, Mr. Black's
comments of 9/28/04 can be interpreted to provide the following comments
specifically responding to the stated purpose of the public hearing, i.e. to hear
comments on whether to issue the permit as drafted, whether to revise the draft
permit, or whether to not issue the permit to PTIA: The permit term should be
reduced to less than 5 years; PTIA's permit should be a combined wastewater and
stormwater permit; the permit should not cover future expansions of the airport.
11. Summarizing all the issues raised in Mr. Black's public hearing comments on
9/28/04:
• DWQ and EPA failed to enforce the requirement for an NPDES permit for PTIA for 12
years.
• Stormwater discharges from airports were specifically required to have a permit in
1992, and PTIA delayed applying for one until 2004.
• The Charlotte airport and RDU have been protecting their neighbors and receiving
waters via the required permits to discharge stormwater and wastewater and have
undergone at least one permit renewal cycle since 1992.
• None of the other airports has a stormwater only permit, as proposed for PTIA. The
other airports have wastewater and stormwater permits, and so should PTIA.
• PTIA is discharging industrial wastewater and industrial activity stormwater into WS-
III drinking waters and 303(d) impaired waters and so a stormwater only permit is
inappropriate.
• Since this is PTIA's first permit, the permit term should be reduced to less than 5
years.
• The permit should not be issued for future expansions of airport activities.
12. The second piece of correspondence is an October 5, 2004 email from Jean & Richard
Black to Bobby Blowe, the hearing officer. The text of the email contained no
questions, although another copy of Mr. Black's September 28, 2004 written
comments was attached. Mr. Black's comments may be summarized as follows.
• The draft permit should not be issued.
• Because the application should have been for the discharge of both stormwater and
industrial wastewater, and it was not.
• And, because the application did not contain an Engineering Alternatives Analysis, as
is required in wastewater discharge applications.

1
Bradley Bennett
Page 3 of 3
January 25, 2005
• And, because the application should have been processed by DWQ's wastewater
Unit, not DWQ's stormwater Unit.
Ken

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Subject: Mtg about PTIA SW Permit this Fri
From: Tom Reeder <[e-mail]>
Date: Mon, 31 Jan 2005 15:22:41 -0500
To: Alan Klimek <[e-mail]>, Coleen Sullins <[e-mail]>, Bobby
Blowe <[e-mail]>, Paul Rawls <[e-mail]>, Bradley Bennett
<[e-mail]>, Ken Pickle <[e-mail]>
Last week Ken and I met with reps from PTAA about their newly issued stormwater
permit. Specifically and primarily they requested clarification of this sentence
regarding the de-icing monitoring:
"The permittee shall monitor and sample each representative outfall for every
de-icing/anti-icing event."
They wanted to know if we interpreted that sentence to mean that they only had to
sample those outfalls that were associated / could contain the glycol. They said
that only 3 or 4, at most, of their outfalls could contain the glycol run-off. If
they are required to sample more than that the cost may become prohibitive (according
to them the sampling costs could run into $500k to $lM per winter if they have to
sample more than these 3 or 4 outfalls).
In addition, they said they may formally request some other modifications to the
monitoring plan this summer and wanted to know if those changes would require another
public hearing.
As a result, I have scheduled a meeting for this Friday at 9:00 am in Alan's office
so we can discuss these items. It should take no longer than 30 minutes.
Thanks.
I of 1 2/2/2005 7:50 AM

i map://ken.pickle%40dwq.denr.ncmai l.net @ cros.ncmail. net:143/fete...
Subject: PTIA schedule
From: Ken Pickle <[e-mail]>
Date: Wed, 16 Mar 2005 15:53:26 -0500
To: Bradley Bennett <[e-mail]>
Bradley,
The PTIA permit, NCS000508, was transmitted by letter to the PTIA on January 10, 2005 with an
effective permit period of February 1, 2005 through January 31, 2010. The following timely actions are
noted in the permit and transmittal letter.
a) Written request for an adjudicatory hearing within 30 days of receipt of the letter, estimate that date as
February 11, 2005. Not an issue.
b) Facility inspections of all stormwater systems on a quarterly basis, once in the period Jan - March.
So, I would expect an on -site record of the inspection required by the end of this month. This
inspection must be during/after a de-icing event, if one ocurred in the quarter. Records should be on -site
soon, if not already.
c) Quarterly sampling during the Feb - April quarter should be accomplished at 7 representative
outfalls. We're getting close to the probable due date for data submittal, I suspect.
d) In -stream monitoring should be accomplished during the Feb - April quarter at locations approved by
the DWQ's regional office. Ditto.
e) Monitoring after every de-icing event should be accomplished at every representative outfall. I would
expect that there would be several data sets available now. Ditto.
f) In -stream monitoring after every de-icing event is required. I would expect that there would be
several data sets available now. Ditto.
g) Quarterly qualitative monitoring for the period Jan - Mar should be available by the end of this month
at all 32 outfalls. The permit does not make it clear if these results must be submitted to us.
h) A plan for the minimization of de-icing materials in stormwater and an implementation timetable
must be submitted to DWQ within six months of the issuance of the permit. So, it's not due yet.
i) A SPPP must be developed and implemented within 12 months of the effective date of the permit, ie.,
by February 1, 2006, and updated annually thereafter. Secondary containment shall be shall be
accomplished by February 1, 2006. So, the SPPP is not yet due.
j) A modified SPPP must be developed prior to the beginning of discharges from any expansion area
operations. Secondary containment shall similarly be accomplished prior to discharges from operations
in any expansion area. So, it's not yet due.
k) Permittee is obligated to operate and maintain control systems at all times. But, no submittal is
required.
1) Sample results are due to the DWQ nit 30 days from the date the facility receives the sampling results.
I suspect that we're getting close to the due date. .
So, it seems that they are getting close to the time when we should be seeing some results, especially
since they are obligated to send us sampling results within 30 days of receiving the results from the lab.
My check today in DWQ Central files did not turn up any monitoring reports.
Ken
/�. ck- on 6,0 e/p� STd.T /o LNage �l-,;, /14
I of 1 3/17/2005 7:52 AM

Mr. Mickie Elmore, Director of Development
Piedmont Triad Airport Authority
PO Box 35445
Greensboro, NC 27425
SUBJECT`. Piedmont Triad International Airport
In -stream sampling sites
NPDES Permit NCS000508
Guilford County
Dear Mr. Elmore:
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
6 May 2005
a0wrMEM9
MAY 0 9 7(W5
DENR - WATER QUALITY
WETtANQS ANO STORMWATER BRANCR
The Division of Water Quality's Winston-Salem Regional Office has received and reviewed your
correspondence dated April 15, 2005 regarding the in -stream sampling sites required by NDPES
Permit NCS000508. This letter serves as the Winston-Salem Regional Office's approval for the in -
stream sampling sites noted below:
In stream Site Number
Latitude
Longitude
1
360 06'
22.8"
790
57'
18.3"
2
360 06'
19.7"
790
56'
37.7"
3
360 06'
34.7"
790
56'
23.4"
4
360 06'
41.3"
790
56'
11.9"
5
360 06'
57.2"
790
55'
53.3"
6
360 07'
26.5"
790
55'
36.1"
7
360 05'
14.1"
790
55'
49.2"
8
360 05'
44.6"
790
55'
49.1"
9
360 05'
53.9"
790
55'
08.0"
10
360 06'
05.2"
790
55'
02.5"
11
360 06'
02.3"
790
54'
51.4"
Should you have any questions or comments, please contact this Office at 9336) 771-4600.
Sincerely,
Steve W. Tedder
Water Quality Supervisor
Cc: Guilford County Health Dept.
NPDES;Stormwater Unit No"`hcarorna
Central Fdes WSRO dVWurally
North Carolina Division of Water Quality 585 Waughtovm Street Winston-Salem, NC 27107 Phone [phone] Fax [phone]
Internet: h2o.enrstate.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Regcled110% Post Consumer Paper

IN&EN
PIEDMONT
TRIAD
AIRPORT AUTHORITY®
July 22, 2005
Mr. Ken Pickle
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Water Quality Management Plan for Deicing Agents
Dear Mr. Pickle:
JUL 2 5 2005
In accordance with the requirements of NPDES Permit No. NCS000508, we are
submitting to you the subject plan.
As always, you or any member of your staff may contact me at any time (336-665-5600)
regarding this document. We look forward to meeting with you in early August. '
Sincerely,
TRIAD AIRPORT AUTHORITY
Mickielk, Elmore
Director of Development
MLE:ge
Enclosure
cc: L.Elmore
K.Baker
W.Cooke
For 8//9 m�
Pe n •t rev IeJ
7-hi.r c/ocu-e-'
pock N10 Claf&-
Piedmont Triad International Airport
Post Office Box 35445 • Greensboro, North Carolina 27425
Greensboro, [phone] • High Point [phone] • Winston-Salem [phone]
FAX: [phone]

2@199d
JUL 2 5 2005
PIEDMONT TRIAD AIRPORT AUTHORITY
' (PTAA)
WATER QUALITY MANAGEMENT PLAN FOR DEICING AGENTS
INTRODUCTION
Section E of NPDES Permit No. NCS000508, which was issued
to PTAA effective February 1, 2005, requires the development of
a storm water management plan for deicing agents.' Section E of
the Permit provides as follows:
"The permittee shall produce and implement a plan for the
minimization of the release of materials used for de-icing
into the stormwater system. This plan shall address, as'a
minimum:
c
1. The current use and practices employed at the
airport for the control and minimization of entry
of the de-icing materials into the stormwater
system;
2. The means that may be practicable for modifying
current use and practices to collect the runoff
that occurs during and following the application
of the de-icing materials; and
e
3. A means to treat the pollutants in runoff to
levels that comply with Surface Water Quality
Standards.
F
4. The plan shall include a synthetic liner to pro-
tect groundwater for all stormwater management
ponds that may receive de-icing/anti-icing fluids.
In lieu of liners, the permittee may install
'"Deicing agents," which are used to remove ice and snow
that have already accumulated on.aircraft, are sometimes distin-
guished from "anti -icing agents," which are applied to aircraft
surfaces to prevent further icing prior to take off. For con-
venience, the term "deicing agent" as used in this Plan will be
used to refer to both deicing and anti -icing agents, and the term
"deicing" will refer both to deicing and anti -icing operations.

©'
groundwater monitoring wells down gradient of
the ponds. If the permittee chooses to install
groundwater monitoring wells, then the permittee
® must obtain approval from the DNv, Sion of water
Quality for the number of wells;` the location of
Q wells, the sampling parameters, and the frequency
of sampling. Q nn ©IP.
The plan must include the rocedur` p p design plans and
Q specifications necessary to achieve compliance with water
Quality Standards and a timetablEgfor the implementation.
The plan and the timetable must be prepared and submitted to
the Division withir&ix months of the issuance of this Per-
mit for approval. The plan must be implemented in accor-
dance with the approved timetable."
This Plan is submitted by PTAA in response to the foregoing
requirements. It covers the following subjects:
• The current practices at the Airport regarding the use
of deicing agents.
The results of the testing that was performed by PTAA
during the winter of 2004-2005 to assess storm water
discharges following deicing events.
The steps that PTAA will undertake, prior to and during
the upcoming winter season, to help control discharges
of deicing agents and to assist PTAA in future planning.
7 • A testing program that PTAA will undertake during the
upcoming winter season for a more thorough assessment
of the use of deicing agents at the Airport.
• The final plan that PTAA will develop with respect to
deicing agents, based on the additional data gained
during the upcoming winter, to ensure compliance with
all of the applicable Water Quality Standards.
• Spill prevention and containment for deicing agents.
The Plan consists of two volumes. This volume (Volume I)
includes the text of the plan and the exhibits referred to in
the text. Volume II contains the results of the analytical
testing that was completed by PTAA in the winter of 2004-2005.
- 2 -

I
EXISTING AIRPORT FACILITIES
Current Use of Deicing Agents.
A. General.
Deicing agents are used at the Airport when required by
weather conditions during the winter months, beginning
in November of most years and ending the following
March.
The most prevalent deicing activity is "defrosting",
which is employed to remove light layers of frost that
have accumulated on aircraft that have remained over-
night at the Airport. Defrosting often occurs in the
absence of any precipitation. A much lower volume of
deicing agent is needed to remove frost as compared
with frozen precipitation, and in many cases it is not
necessary to defrost aircraft that arrive and depart
from the Airport after the early morning hours.
Overspray and dripping material from defrosting will
often evaporate before entering a drainage conveyance.
Deicing agents are used in greater volume during pre-
cipitation events that are accompanied by temperatures
at or below freezing. In these instances, the deicing
agents mix with runoff from melting precipitation.
Each tenant at the Airport independently selects the
type of deicing agent that it uses, consisting of
either ethylene or propylene glycol. Due to the ab-
sence of any Surface Water Quality Standards for either
ethylene or propylene glycol as such, there are cur-
rently no regulations at the Airport limiting the use
of either of these materials or the manner in which
they are applied, other than FAA safety regulations.
B. Use by Passenger Airlines.
As of the date of this Plan, there are seven passenger
airlines providing service at the Airport, either
through their own operations or through affiliated
regional and commuter airlines; and there are approx-
imately 100 scheduled flights per day, although a much
- 3 -

smaller number depart from the Airport during the early
morning hours when deicing agents are more commonly in
use. Furthermore, the number of flights is often re-
duced during inclement weather due to cancellations.
The airlines operating at the Airport all board passen-
gers at the Airport Terminal Building, which has two
concourses with 17 passenger gates. In January, 2006,
PTAA will complete an expansion of the north concourse
of the Terminal Building, which will add six to seven
new gates, although not all of the gates will be occu-
pied immediately. (See Exhibit 1 for a diagram of the
Terminal Building and surrounding aircraft aprons.)
Three of the airlines (Continental, United and US Air)
maintain glycol storage tanks at the Airport from which
they draw their own supply and from which they also
sell glycol to the other airlines. Glycol is applied
by each of the airlines through the use of its own
trucks and personnel, or with trucks and personnel
supplied by contractors. The trucks are equipped with
a tank and spraying equipment mounted on a boom.
Training for the operators is provided by their
employers.
✓ Typically, glycol is applied to the aircraft in their
"push back" position on the apron surrounding the con-
course. On occasion, depending on the temperature and
the length of time an aircraft is held on the ground
prior to departure, secondary deicing may occur near
the runway ends prior to takeoff for safety reasons.
C. Use by Other Aircraft Operators.
In addition to the passenger carriers, there are five
cargo airlines now operating at the Airport. These
carriers deice, when necessary, on the aircraft ramps
adjacent to their leased facilities. There are also
two fixed based operators at the Airport, which occa-
sionally provide deicing for private aircraft at their
leased facilities. The cargo carriers and fixed base
operators use glycol stored at their facilities and
apply the glycol through truck -mounted booms, as in the
case of the passenger airlines. Exhibit 2 shows the
location of the aircraft ramps used by the cargo car-
riers and fixed based operators. As in the case of the
passenger airlines, secondary deicing may be provided
- 4 -

for the non -passenger aircraft when needed for safety
reasons.
II. Test Results from 2004-2005.
A. Description of the Tests and Test Reports.
PTAA conducted water quality tests on two separate
occasions during 2004-2005 winter season prior to the
effective date of the NPDES Permit. These tests were
conducted pursuant to the Storm Water Plan for Deicing
Agents that PTAA adopted in connection with its §401
Certification (No. 3428) issued by DWQ. One set of
tests was conducted on November 22, 2004 at 11 in -
stream locations approved by DWQ along Brush Creek,
Horsepen Creek and tributaries of Horsepen Creek.
(See Exhibit 3 for the locations of the in -stream
sites.) The purpose of this first set of tests was
to provide baseline information on stream conditions
when no deicing was occurring. Testing was performed
for BOD and toxicity. A second set of tests was con-
ducted at the in -stream sites on January 31, 2005 after
deicing had occurred. On this occasion, the samples
were analyzed not only for BOD and toxicity, but also
for ethylene and propylene glycol.
Following the effective date of the NPDES Permit, test-
ing continued in accordance with its terms not only at
the in -stream locations but also at the seven represen-
tative outfalls designated in the NPDES Permit (Out -
falls 4, 6, 14, 24, 26, 27 and 30 - See Exhibit 3).
The PTAA staff monitored glycol use at the Airport and
alerted its testing contractor whenever glycol was used
at the Airport. Testing was conducted on three sepa-
rate occasions - February 3, 2005, March 1, 2005 and
March 17, 2005. All of the tests were associated with
¢e-ic everts d00 precipitation events. The NPDES tests covered BOD,
2 toxicity, ethylene glycol and propylene glycol (as well
as ammonia nitrogen and suspended solids, which were
also required to be tested under the permit).
The tables at Exhibit 4 summarize the results of the
testing during the 2004-2005 winter season. Table 4A
presents the results according to the various constitu-
ents that were the subject of the tests, and Table 4B
presents the results by the date of the tests. The
- 5 -

detailed results for all of the tests appear in Volume
II of this Plan.
B. Analysis of the Test Results.
The NPDES Permit was issued mid -winter, following the
month of January, in which the most severe winter
weather is normally experienced. In addition, the
winter was unusually mild and there were relatively
few deicing events during the remainder of the winter
season. A few preliminary observations can be made
regarding the data that was collected:
The outfalls exhibiting a significant discharge of
glycol (either ethylene or propylene) are OF-4,
OF-6, OF-24 and OF-27. Propylene glycol was
detected on one occasion at OF-26, but only at a
level of 19 mg/l. No glycol was detected in any
of the tests at OF-14 or OF-30.
With regard to toxicity, of the 55 in -stream sam-
ples that were taken over the course of the 2004-
2005 winter season, none showed an LC-50 result at
less than 100% concentration.
The tests fail to indicate any reliable correla-
tion between glycol levels and acute toxicity.
Although two of the five toxicity tests with an
LC-50 below 100% coincided with an elevated level
of glycol (both of these at OF-27), two occurred
at outfalls that were not discharging any glycol
at all and one at an outfall with a glycol concen-
tration (propylene only) of only 19 mg/l. (See
Exhibit 4A.). Correspondingly, there were numer-
ous samples with detectable levels of glycol
(either ethylene, propylene or a combination of
the two) that did not indicate toxicity, including
most of the samples with higher glycol readings.
The tests results suggest areas for further study.
However, due to the infrequency of glycol use during
the past winter, the tests do not provide sufficient
information either for evaluating the current discharge
of deicing agents into the storm water system at the
Airport or for designing any specific measures that may
be needed to control the discharge of such agents.
- 6 -

PTAA will therefore proceed with the steps that can be
taken at this stage, as well as the additional testing
that will be needed this winter for development of a
final plan.
III. Current Steps to Be Taken by PTAA.
PTAA will implement the following steps prior to and during
the 2005-2006 Winter Season:
PTAA will continue its consultation with its tenants
concerning (i) their current use of deicing agents at
the Airport, including the volume and chemical composi-
tion of the deicing agents used by them and their cur-
rent practices regarding such agents and (ii) their
experience and proposals, if any, for minimizing the
impact of such agents, such as source reduction strate-
gies, alternative deicing methods and agents and other
best management practices. Aircraft safety will con-
tinue to be the paramount concern in all such
discussions.
Tenants will also be asked, before the beginning of the
winter season, to state the volume of deicing agent, and
type of product, that they have on hand and the amount
of each type of product that they expect to use this
winter.
• Beginning with the upcoming winter season, PTAA will re-
quest that each of its tenants that uses deicing agents
report such use on the form appearing at Exhibit 5.
• Beginning with the upcoming winter season, aircraft
operators will be requested not to conduct deicing op-
erations over any drains in the aircraft aprons (i.e.
no part of the aircraft that is being deiced, or the
deicing equipment, maybe be situated on or immediately
above a drain). The purpose of this measure is to re-
duce, or prevent entirely, the entry of deicing agents
con e'Pfi into the storm water drainage system during non -
precipitation events and to help reduce the entry of
such agents into the system when precipitation is
occurring. PTAA will study the results of this measure
to determine whether it is effective in reducing the
discharge of deicing agents and whether it would be
practical to continue this measure in the future.
- 7 -

IV. Testing Program for 2005-2006 Winter Season.
To provide more definitive and comprehensive information
concerning discharges of deicing agents at the Airport,
PTAA will undertake the following testing program during
the winter of 2005-2006:
•
In addition to the testing that will be required by DWQ
under the NPDES Permit, PTAA will perform a more inten-
sive study of glycol (both ethylene and propylene) and
BOD concentrations, following deicing events, at the
,,14,c-A is ✓hc,e on
points where Brush Creek and Horsepen Creek depart the
E rh,b fi 3 7
Airport property. The testing will be performed follow-
ing two precipitation events and two non -precipitation
events during the course of the winter, as selected by
diecre�e
PTAA. In each case, (samples will be drawn at hourly in-
SaN ��e5
tervals for 24 hours, beginning as soon as possible
after glycol applications begin. If, for either type of
event (i.e. precipitation or non -precipitation) the
S sefs oJ7
first set of samples indicates that glycol persists in
�a es
measurable quantities for more than 24 hours, the hourly
sampling for the second such event will be lengthened to
48 hours.
The foregoing tests will allow PTAA to understand how
glycol moves through the system, and the peak and the
�o yow �y e1 fAs
duration of the glycol concentrations. This information
will determine more definitely the volume of deicing
uM./l.svP�o� a
agents that are being carried in the receiving streams
de as iv ��ycL
any effect that deicing events are having on downstream
water quality.
//
•
Flow will be measured at the various outfalls where the
2004-2005 data indicated the presence of glycol. These
meters produce a constant record of the runoff volume
being discharged from the outfalls. This data will be
used by PTAA for a number of purposes including (i) cor-
relating total runoff volumes with the results of the
analytical tests required by the NPDES Permit (ii)
establishing the total runoff that occurs during deicing
events (iii) predicting glycol concentrations in the
runoff and (iv) verifying whether PTAA has correctly
identified all of the areas that are contributing runoff
to a particular outfall. The flow data will also be
used to help determine the required capacity of any
structural BMP's that may be needed to comply with
Water Quality Standards.
- 8 -

V. Final Plan.
Various measures have been employed at other airports
to control, collect and treat deicing agents in storm
water runoff, such as:
Source reduction strategies, including strategies
to reduce total glycol use or the concentration of
glycol in a particular application, better training
for employees applying glycol, more careful appli-
cation methods, improved application equipment, and
conversion from ethylene glycol to propylene glycol
when appropriate and helpful.
Collection of runoff containing deicing agents in
a storm water management pond or other containment
structure followed by pumping and removal, treat-
ment on site, discharge into a sanitary sewer sys-
tem or delayed release into receiving streams.
Other best management practices, both structural
and operational.
Based on PTAA's experience during the upcoming winter
and the information assembled under Items III and IV
above, PTAA will update this Plan with an analysis of
the new testing results and any more specific measures
that may be needed at this Airport to ensure that the
discharge of deicing agents will be in full compliance
with all applicable Water Quality Standards. The Plan
update will be completed and submitted to DWQ for ap-
proval by July 1, 2006. If any storm water ponds are
included in the Plan, such ponds will be equipped with
a synthetic liner or, at the option of PTAA, ground-
water monitoring wells will be installed downgradient
from the ponds, as required by Section E of the NPDES
Permit.
VI. Spill Prevention and Containment.
The NPDES Permit includes a requirement that PTAA adopt a
SPRP (Spill Prevention and Response Plan) as part of its
SWPPP (Storm Water Pollution Prevention Plan). The SPRP
must include an assessment of potential pollution sources
based on a materials inventory at the Airport, must identify
the PTAA personnel who will be responsible for implementing
- 9 -

the SPRP and must be site specific. PTAA will include in
its SPRP appropriate provisions regarding spill containment
and treatment of deicing agents, and these provisions will
become a part of its SWPPP.
- 10 -

EXA ,6;f /
Terminal Area Plan

TERMINAL AREA PLAN
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Sampling Locations

LEGEND
O
REPRESENTATIVE OUTFALL
O
EXISTING OUTFALL
0
IN -STREAM LOCATION
WATERSHED (BREAKLINE)
WATERSHED (SUB AREA)
DELINEATED WETLANDS
n
EXISTING INLET
e
EXISTING MANHOLE
--------
EXISTING STORM SEWER
Q
W
CO.
I
z
0
z
Q
U)
Q
H
O
U)
uw
0
n
z
600 0 600 1200
SCALE IN FEET
-XA 3

NPDES Test Result
Summaries
Ex h • 6.fs 4,4 pB

NPDES PERMIT
COMPLIANCE SAMPLING RESULTS
(Results by Constituent)
Propylene Glycol
Ethylene Glycol
Biological Oxy en Demand (BOD)
Antonia
Sus ended Solids
Acute Toxicih"t "
2/3/2005
3/l/2005
3/17/2005
2/3/2005
3/1/2005
3/17/2005
2/3/2005
3/1/2005
3/17/2005
2/3/2005
3/1/2005
3/17/2005
2/3/2005
1 3/1/2005
3/17/2005
2/3/2005
3/l/2005
3/17/2005
mg!I
mg/I
mg%I
mg%I
mg%1
me%I
mgil
mg/I
mg/I
mg/I
mg/1
mg/I
m_/I
mg%I
mg%I
96
%
Sample ID
OF-4
270
2t0
1500
13
23
BDL
>62
>37
190
23
1 >37
2.4
17
6
9.8
100&L
100%
1009u
OF-6
73
16
1100
100
21
410
>57
56
>200
21
56
1.4
54
6
25
100%
100%
100%
OF-14
BDL
BDL
BDL
BDL
BDL
BDL
7.2
3.6
5.8
BDL
3.6
0.043
29
29
T6
100%
1000.10
1000/0
OF-24
1700
590
3700
180
140
1800
>60
>220
210
140
>220
N/A
24
13
3.4
100%
100%
t00%
OF-26
BDL
BDL
19
BDL
BDL
BDL
15
7.4
21
BDL
7.4
N/A
9.7
5.7
3.8
76.8%
100016
89.14/u
OF-27
420
110
2000
7.2
1 BDL
BDL
>61
>220
>200
BDL
>220
0.049
18
14
16
50.290
100%
70.1%
OF-30
BDL
BDL
BDL
BDL
BDL
BDL
3.5
<2.0
<4.2
BDL -
- -/ <2.0
BDL
37
7.7
2.8
77.1%
100%
100%
Stream-1
N/A
N/A
N/A
N/A
N/A
N/A
II
6.6
5.6
N/A
/ 6.6
N/A
N/A
N/A
N/A
100%
100%
100%
Stream -2
N/A
N/A
N/A
N/A
N/A
N/A
>59
9.6
73
N/A
9.6
N/A
N/A
N/A
N/A
100%
100%
100%
Stream -3
N/A
N/A
N/A
N/A
N/A
N/A
>62
61
52
N/A
61
N/A
N/A
N/A
N/A
1 100%
100%
1004/6
Stream -4
N/A
N/A
N/A
N/A
N/A
N/A
>60
56
>230
N/A
56
N/A
N/A
N/A
N/A
100%
100%
100%
Stream -5
N/A
N/A
N/A
N/A
N/A
N/A
>60
49
<4.17
N/A
49
N/A
N/A
N/A
N/A
100%
100%
100%
Stream -6
N/A
N/A
N/A
N/A
N/A
N/A
>59
41
190
N/A
41
N/A
N/A
N/A
N/A
100%
100°i
100%
Stream -7
N/A
N/A
N/A
N/A
N/A
N/A
4.2
2.2
4.2
NA
2.2
N/A
N/A
N/A
N/A
100%
100%
100%
Stream -8
N/A
N/A
N/A
N/A
N/A
NIA I
>58
56
>210
NA
56
N/A
N/A
N/A
NIA
100%
100%
10001u _
Stream -9
N/A
N/A
N/A
N/A
N/A
N/A 1
52 1
8.4
65
N/A
I 1.4
N/A
N/A
N/A
N/A
100%
100%
100%
Stream -10
N/A
N/A
NIA
N/A
N/.A
N/A
>60
>220
200
N/A
>2T
N/A
N/A
N/A
N/A
'100%
10090
100%
Stream -II
N/A
N/A
N/A
N/A
N/A
N/A
>57
31
>210
NIA
I 31
N/A
N/A
N/A
N!A
1009'0
100%
1002L
NOTES: f6 D L
All results in milligrams per liter (mg/L)
N/A = Not Analyzed
BDL = Below Detection Limit
'= An estimate of the concentration of effluent which is lethal to 50% of the test organisms in 24 hours.
Exhibit 4A
l
7

NPDES PER -MIT
COMPLIANCE SAMPLING RESULTS
(Results by Event Date)
February 3, 2005
March
1, 2005
March'17, 2005
O U
C
C
�. .�
C j
J
J '/
T
C_
i
ci G G
F
Ort
mgA
mal
mg/I
mg/1
me/I
%
mgfl
mI
mg/I
mg/I
m�/l
°/�
mil
mg/l
mil
mo/I
mgil
Collect
Analytical Data Results
Collect
Analytical Data Results
Collect
Analytical Data Results
Sample ID
Time
Time
I
Time
OF-4
16:00
270
13
>62
12
17
100%11:00
210
23
>37
2.4
6
100%
11:00
1500
BDL
190
0.92
"9.8
10000
OF-6
12:45
73
t00
>57
Il
54
100010
11:30
16
21
56
1.4
6
100%
11:30
1100
410
>200
0.43
25
IOII°%
OF-14
11:45
BDL
BDL
'72
0.39
29
100%
12:50
BDL
BDL
3.6
0.043
29
100°0
12:50
BDL
BDL
5.8
0.53
7.6
100%
OF-24
11:58
1700
180
>60
N/A
24
100%
13:20
590
140
>220
N/A
13
100%
13:20
3700
1800
210
N/A
1.4
100%
OF-26
12:25
BDL
BDL
15
N/A
9.7
76.80,0
16:25
BDL
BDL
7.4
NIA
5.7
100%
16,25
19
BDL
21
N/A -
3.8
89.1°%
OF-27
12:21
420
7.2
>61
0.71
18
50.2%
16:10
Ho
BDL
>220
0.049
14
100°0
16:10
2000
BDL
>200
0.031
16
70.1%
OF-30
12:08
BDL
BDL
3.5
0.084
37
77.1%
15:45
BDL
BDL
<2.0
BDL
7.7
100%
15:45
BDL
BDL
<4.2
BDL
2.8
100%
Stream -1
16:35
N/A
NIA
I I
N/A
N/A
100%
13:00
N/A
N/A
6.6
N/A
N/A
1 100%
13:00
N/A
N/A
5.6
NA
N/A
100%
Stream -2
16:40
N/A
N/A
'>59
N/A
N/A
100%
13:30
N/A
NA
9.6
N/A
N/A
100°%
13:30
N/A
NA
73
N/A
:' N/A
100%
Stream -3
16:45
N/A
N/A
>62
N/A
NIA
100%
13:40
N/A
N/A
61
NIA
N./.A
100%
13:40
N/A
N/A
52
N/A
N/A
100%
Stream -4
16:56
N/A
N/A
>60
N/A
N/A
t00%
13:50
N/A
NIA
56
NIA
NIA
100%
13:50
N/A
N/A
>230
N/A
MIA
100%
Stream-5
17:00
NIA
N/A
>60
N/A
N/A
100%
14:00
NIA
N/A
49
N/A
N/A
100%
14:00
N/A
NIA
<4AT,
N/A
N/A
100%
Stream -6
17:25
N/A
NIA
>59
N/A
N/A
100%
15:15
N/A
NIA
41
NIA
N/A
100%
15:15
NIA
NIA
190
N/A
N/A
100%
Stream -7
15:00
N/A
N/A
42
N/A
N/A
100%
12:25
N/A
N/A
2.2
N/A
N/A
100%
12:25
N/A
N/A
4.2
N/A
N/A
100%
Strum -8
15:13
N/A
N/A
>58
N/A
NIA
100%
11:30
NIA
N/A
1 56
1 N/A
N/A
100%
11:30
NIA
NIA
>210
N/A
N/A
100%
Stream-9
15:28
NIA
N'A
52
NiA
N.'A
100%
10:30
N/.4
NIA
8.4
NIA
NIA
100%
10,30
N/A
NIA
65
N/A
N/A
100%
Stream -10
15:30
N/A
NIA
>60
N/A
N/A
100%
10:10
NIA
NA
>220
N/A
N/A
100°/�
10:10
N/A
NIA
200
NIA
NIA
100"0
Stream A 1
15:45
N/A
N/A
>57
N/A
N/A
100%
10:00
N/A
NIA
31
N/A
I NIA
100°%
10:00
N/A
NIA
>210
N/A
N/A
100%
NOTES:
All results in milligrams per liter (mg/L)
N/A = Not Analyzed
BDL = Below Detection Limit
*= An estimate of the concentration of effluent which is lethal to 50% of the test organisms in 24 hours.
1 XIMI -M R

\l ` %l iL (Anil 0 1\V�IVl lll�g
Form

Ilk
1
W
Piedmont Triad Airport Authority
Deicing Report
Airline OR
User
<
Flight No.
'
Date
MMIDDIYY
Aircraft Type
Gate
Number
-
•
Type Fluid
_ % Glycol
Mix
Local Time
fluid
application
began
Gallons of
ADF used
Current Weather
1-Frost
2-Freezing Fog
3-Freezing Drizzle
4-Light Freezing Rain
5-Light Snow
6-Moderated Snow
7-Heavy Snow
8-Cold Soaked
9-No Precipitation
Enter the signature and
employee no. of the person
responsible for the deicing of
the aircraft.
Reviewed by:

PTAA meeting
Subject: PTAA meeting
From: Ken Pickle <[e-mail]>
Date: Thu, 28 Jul 2005 09:47:41 -0400
To: Steve Tedder <[e-mail]>, Tom Reeder <[e-mail]>, Bradley
Bennett <[e-mail]> •
We 'uns,
Just a reminder that there is a meeting scheduled with PTAA and their consultants on
Tuesday, August 2nd. We will be meeting in the Archdale 12th floor small conference
room at 1:00.
They have asked for the meeting, and as I understand their agenda, they want to
review the data collected so far. I expect their objective is to get our reaction to
the data, and to come to some agreement on the interpretation of the data collected
so far.
I received two volumes from PTAA this past Monday, 7/25/05. The first volume is the
"Water Quality Management Plan for Deicing Agents", which PTAA was required by Part
II Section E of the permit to develop within six months of permit issuance (February
1, 2005). The second volume is a 3" binder of analytical back up for four sampling
events conducted between January and March 2005. I'll look over both volumes, but if
we think an in-depth technical review of the lab data is in order, I'll need to get
some help. Unless my first cursory review turns up something of note, I'm inclined
to avoid an in-depth technical review of the lab data. Contrary opinions?
Ken
I of 1 7/28/2005 9:48 AM

Re: NCS000508 PTI airport
Subject Re: NCS000508 PTI airport
From: Ken Pickle <[e-mail]>
Date: Wed, 01 Feb 2006 08:23:47 -0500
To: Corey Basinger <Corey.Basinger n ncinail.net>, Bradley Bennett <[e-mail]>
Corey - - - Let's ask the reporter to come here. I'm uncomfortable letting our
single copy out of the office. That's not a comment on my trust in you or your
office, it's just a recognition that "stuff happens." Do you want the 120 page
version, anyway, for your file on the permittee?
Bradley - - - We may be getting a visit from a reporter about PTIA testing results.
MUM
Corey Basinger wrote:
Ken,
Having someone copy that many pages would be a nightmare. Therefore we have two
option: (1) I can refer the reporter to the Central Office for review of all the
documents or (2) you can loan WSRO the document until the reporter has a chance to
review it. Your calla
Thanks'
Corey
On 2/l/2006 7:49 AM, Ken Pickle wrote:
Corey,
The Volume 2 covers five sampling events in the winter 2004-2005. With
individual backup lab data sheets, QA/QC information, and chain of custody
pages, the Volume 2 is about 450 pages. With just transmittal letters, summary
of findings, and summary tables, it's about 120 pages. We're happy to copy
the whole Volume 2 and send it. If you don't want that much paper around, we
can send you the smaller package. Let me know.
Ken
Corey Basinger wrote:
Ken,
Thanks for forwarding to me the compliance samping reports for PTI Airport.
You asked on one of you yellow postit notes wheter or not I needed a copy of
"Volume 2 - Analytical Testing results winster 2004-2005". I would like a
copy of that if you'd be so kind. I've had two (2) calls about it already
this week. One was an N&O reporter who is coming by on Friday to review the
file.
Thanks in advance for sending out this information.
Corey
I of 1 2/1/2006 8:26 AM

RE: PTIA stormwater permit
Subject: RE: PTIA stormwater permit
From: Amy Dominello <[e-mail]>
Date: Tue, 14 Feb 2006 10:36:54 -0500
To: "'Ken Pickle"' <[e-mail]>
Thanks, Ken.
I'm going to look over some of the stuff I photocopied yesterday before I left and give you a call later this afternoon
or tomorrow.
Thanks for your help.
Amy
-----Original Message -----
From: Ken Pickle lmailto:ken.pickle(r�ncmail.netl
Sent: Tuesday, February 14, 2006 9:03 AM
To: Amy Dominello
Subject: PTIA stormwater permit
Amy,
I apologize for leaving you without assistance yesterday afternoon.
had two doctor's appointments that were unscheduled until Monday
morning. If you have additional questions, please contact me, I'll be
glad to respond.
Ken Pickle
DWQ Stormwater Permitting Unit
[phone]x584
of 1 2/14/2006 11:05 AM

Re: PTIA stormwater permit
Subject: Re: P,rlA stormwater permit
From: Ken Pickle <[e-mail]>
Date: Wed, 22 Feb 2006 14:20:42 -0500
To: Amy Dominello <[e-mail]>
Amy
Sure, right now the only things on my calendar for next week are 10:00 meetings
Monday, Wednesday, and Friday. I'll be glad to be available other times. Or, you
may not necessarily need me to accomplish your goal. The file materials can be
available even when I'm not here. Just let me know when.
Ken
Amy Dominello wrote:
Hi Ken,
In the meantime, I've been pulled on to another story. It never stops.
Any chance I could catch up with you next week?
Amy
-----Original Message -----
From: Ken Pickle [mailto:[e-mail]]
Sent: Wednesday, February 22, 2006 7:25 AM
To: Amy Dominello
Subject: Re: PTIA stormwater permit
Amy,
I'm back in the office today, Wednesday, after a long weekend vacation. I'll be in
on Thursday, but out on Friday.
Ken
Amy Dominello wrote:
> Ken,
> I'm sorry to not get back to you sooner. I've been out sick for much
> of the week. Is it OK if I give you a call next week?
> Amy
> -----Original Message-----
• From: Ken Pickle [mailto:[e-mail]]
> Sent: Tuesday, February 14, 2006 9:03 AM
> To: Amy Dominello
> Subject: PTIA stormwater permit
> Amy,
> I apologize for leaving you without assistance yesterday afternoon.
> had two doctor's appointments that were unscheduled until Monday
> morning. If you have additional questions, please contact me, I'll
> glad to respond.
> Ken Pickle
> DWQ Stormwater Permitting Unit
> [phone]x584
I
be
I of 1 2/22/2006 2:49 I'M

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