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3 ANALYSIS OF FEDERAL LAWS, REGULATIONS, CASE LAW, AND SURVEY OF EXISTING AIRPORT NPDES PERMITS REGARDING TENANT–OPERATOR RESPONSIBILITIES UNDER NPDES AND STORMWATER MANAGEMENT BMPS UNDER OWNER/AIRPORT'S OPERATING PERMITS By CDM Smith in collaboration with Barg Coffin Lewis and Trapp, LLP RESEARCH OVERVIEW The objective of this research project is to clarify and document responsibility for implementation, and liability for enforcement of alleged violations, in connection with maintaining and executing National Pollutant Discharge Elimination System (NPDES) stormwater permit requirements, practices, and reporting at airports.
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4 State Legal Authority for Regulating Stormwater Discharges Associated with Industrial Activity Each of the states reviewed has the authority to implement the provisions of the Clean Water Act. The independent state legal authorities related to industrial stormwater discharges are as follows: • In California, the regulation of water quality and the implementation of the Clean Water Act, including the issuance of discharge permits, is governed by the Porter-Cologne Water Quality Control Act.1 • New York's general state law governing water quality control is the New York Environmental Conservation Law (NY ECL)
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5 cleaning operations, or deicing operations, where such activities are likely to generate pollutants that could be or are discharged with stormwater, would be considered an operator. EPA's regulations governing applications for individual permits contain a provision recognizing that there may be a distinction between a facility owner and operator.
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6 limited to discharges from vehicle maintenance, equipment cleaning, and airport deicing.19 The TX GP prohibits the discharge of wastewater associated with washing aircraft, ground vehicles, runways, or equipment, and dry weather discharge of deicing chemicals.20 Monitoring Benchmarks or Effluent Limitations at Air Transportation Facilities and Any Associated Corrective Action Requirements Monitoring Benchmarks For airports that use more than 100,000 gallons of glycol-based deicing chemicals or 100 tons or more of urea on an average annual basis: Permit pH 5-day Biochemical Oxygen Demand (BOD5) Chemical Oxygen Demand (COD)
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7 Effluent Limitations Existing and new primary airports with 1,000 or more annual jet departures that discharge wastewater associated with airfield pavement deicing that contains urea commingled with stormwater: Ammonia as Nitrogen Permit Daily Maximum EPA 2013 MSGP1 14.7 mg/L CA 2015 GP2 14.7 mg/L 1. Part 8, Subpart S, § 8.S.7.1.22 2.
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8 Corrective Action Requirements Pollutant benchmark concentrations are not effluent limitations. A benchmark exceedance is not a permit violation but an indication of the overall effectiveness of BMPs and indicates that BMPs for that pollutant should be reviewed to determine if modifications are necessary.
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9 • Aircraft, ground vehicle, and equipment maintenance, cleaning, and storage areas. • Material storage areas.
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10 A Port Authority representative discussed the BMPs and other steps taken to reduce impacts of deicing on Jamaica Bay. Two of the issues in dispute were that 1)
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11 • Whether the permit's failure to establish numeric water quality-based effluent limitations is invalid.44 • PCHB found that Ecology reasonably determined that application of BMPs would be effective in achieving compliance with water quality standards after performing a generalized reasonable potential analysis on industrial stormwater discharges. Having made this determination, PCHB found that Ecology was not required to develop numeric effluent limitations, except for discharges to impaired water bodies, as required under Washington Revised Code Section 90.48.555(7)
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From page 11... ...
12 Some of the strategies employed by airport authorities for tenant implementation of SWPPPs include: • Airport authority prepares the SWPPP, and all tenants must comply with its provisions. • Airport authority prepares an SWPPP, and all tenants must comply with its provisions or they are allowed to prepare their own, provided it meets the minimum requirements of the airport's plan.
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