Cleveland­
Hopkins
Airport
Page
1
National
Pollutant
Discharge
Elimination
System
(
NPDES)
Permit
Program
F
A
C
T
S
H
E
E
T
Regarding
an
NPDES
Permit
To
Discharge
to
Waters
of
the
State
of
Ohio
for
Cleveland­
Hopkins
International
Airport
Public
Notice
No.:
OEPA
Permit
No.:
3II00179*
AD
Public
Notice
Date:
Application
No.:
OH0122068
Comment
Period
Ends:

Name
and
Address
of
Facility
Where
Name
and
Address
of
Applicant:
Discharge
Occurs:

Cleveland­
Hopkins
International
Airport
Cleveland­
Hopkins
International
Airport
5300
Riverside
Drive
5300
Riverside
Drive
Cleveland,
Ohio
44135
Cleveland,
Ohio
44135
Cuyahoga
County
Receiving
Water:
Abrams
Creek,
Silver
Creek
Subsequent
and
Rocky
River
Stream
Network:
Rocky
River
and
Lake
Erie
Introduction
Development
of
a
Fact
Sheet
for
NPDES
permits
is
mandated
by
Title
40
of
the
Code
of
Federal
Regulations,
Section
124.8
and
124.56.
This
document
fulfills
the
requirements
established
in
those
regulations
by
providing
the
information
necessary
to
inform
the
public
of
actions
proposed
by
the
Ohio
Environmental
Protection
Agency,
as
well
as
the
methods
by
which
the
public
can
participate
in
the
process
of
finalizing
those
actions.

This
Fact
Sheet
is
prepared
in
order
to
document
the
technical
basis
and
risk
management
decisions
that
are
considered
in
the
determination
of
water
quality
based
NPDES
Permit
effluent
limitations.
The
technical
basis
for
the
Fact
Sheet
may
consist
of
evaluations
of
promulgated
effluent
guidelines,
existing
effluent
quality,
instream
biological,
chemical
and
physical
conditions,
and
the
relative
risk
of
alternative
effluent
limitations.
This
Fact
Sheet
details
the
discretionary
decision­
making
process
empowered
to
the
Director
by
the
Clean
Water
Act
and
Ohio
Water
Pollution
Control
Law
(
ORC
6111).
Decisions
to
award
variances
to
Water
Quality
Standards
or
promulgated
effluent
guidelines
for
economic
or
technological
reasons
will
also
be
justified
in
the
Fact
Sheet
where
necessary.

Procedures
for
Participation
in
the
Formulation
of
Final
Determinations
The
draft
action
shall
be
issued
as
a
final
action
unless
the
Director
revises
the
draft
after
consideration
of
the
record
of
a
public
meeting
or
written
comments,
or
upon
disapproval
by
the
Administrator
of
the
U.
S.
Environmental
Protection
Agency.
Cleveland­
Hopkins
Airport
Page
2
Within
thirty
days
of
the
date
of
the
Public
Notice,
any
person
may
request
or
petition
for
a
public
meeting
for
presentation
of
evidence,
statements
or
opinions.
The
purpose
of
the
public
meeting
is
to
obtain
additional
evidence.
Statements
concerning
the
issues
raised
by
the
party
requesting
the
meeting
are
invited.
Evidence
may
be
presented
by
the
applicant,
the
state,
and
other
parties,
and
following
presentation
of
such
evidence
other
interested
persons
may
present
testimony
of
facts
or
statements
of
opinion.

Requests
for
public
meetings
shall
be
in
writing
and
shall
state
the
action
of
the
Director
objected
to,
the
questions
to
be
considered,
and
the
reasons
the
action
is
contested.
Such
requests
should
be
addressed
to:

Legal
Records
Section
Ohio
Environmental
Protection
Agency
P.
O.
Box
1049
Columbus,
Ohio
43216­
1049
Interested
persons
are
invited
to
submit
written
comments
upon
the
discharge
permit.
Comments
should
be
submitted
in
person
or
by
mail
no
later
than
30
days
after
the
date
of
this
Public
Notice.
Deliver
or
mail
all
comments
to:

Ohio
Environmental
Protection
Agency
Attention:
Division
of
Surface
Water
Water
Resource
Management
Section
P.
O.
Box
1049
Columbus,
Ohio
43216­
1049
The
OEPA
permit
number
and
Public
Notice
numbers
should
appear
on
each
page
of
any
submitted
comments.
All
comments
received
no
later
than
30
days
after
the
date
of
the
Public
Notice
will
be
considered.

The
application,
fact
sheet,
public
notice,
permit
including
effluent
limitations,
special
conditions,
comments
received
and
other
documents
are
available
for
inspection
and
may
be
copied
at
a
cost
of
25
cents
per
page
at
the
Ohio
Environmental
Protection
Agency
at
the
address
shown
above
any
time
between
the
hours
of
8:
00
a.
m.
and
5:
00
p.
m.,
Monday
through
Friday.
Copies
of
the
Public
Notice
are
available
at
no
charge
at
the
same
address.
Cleveland­
Hopkins
Airport
Page
3
Location
of
Discharge/
Receiving
Water
Use
Classification
Cleveland­
Hopkins
International
Airport
discharges
to
Silver
Creek
at
River
Miles
(
RMs)
0.8
(
outfall
001)
and
0.9
(
outfall
002),
to
Abram
Creek
at
RMs
3.15
(
outfall
003),
1.0
(
outfalls
004,
005
and
009)
and
0.6
(
outfall
006),
and
to
the
Rocky
River
at
RMs
10.05
(
outfall
007)
and
9.9
(
outfall
008).
The
approximate
location
of
the
facility
is
shown
in
Figure
1.

Silver
Creek
is
not
presently
designated
in
Ohio's
Water
Quality
Standards
(
WQS).
Undesignated
waterbodies
in
the
Lake
Erie
basin
must
meet
average
aquatic
life
WQS,
non­
drinking
water
WQS
for
human
health
protection,
and
wildlife
protection
WQS.

This
segment
of
Abram
Creek
is
described
by
Ohio
EPA
River
Code:
13­
002,
USEPA
River
Reach
#:
04110001­
NA,
County:
Cuyahoga,
Ecoregion:
Erie­
Ontario
Lake
Plain.
Abram
Creek
is
presently
designated
for
the
following
uses:
Warmwater
Habitat
(
WWH),
Agricultural
Water
Supply
(
AWS),
Industrial
Water
Supply
(
IWS)
and
Primary
Contact
Recreation
(
PCR).

This
segment
of
the
Rocky
River
is
described
by
Ohio
EPA
River
Code:
13­
001,
USEPA
River
Reach
#:
04110001­
007,
County:
Cuyahoga,
Ecoregion:
Erie­
Ontario
Lake
Plain.
The
segment
of
Rocky
River
is
presently
designated
for
the
following
uses:
Warmwater
Habitat
(
WWH),
Agricultural
Water
Supply
(
AWS),
Industrial
Water
Supply
(
IWS),
Primary
Contact
Recreation
(
PCR)
and
State
Resource
Water
(
SRW).

The
Rocky
River
study
area
is
shown
in
Figure
2.

Facility
and
Discharge
Description
Cleveland­
Hopkins
International
Airport
is
main
commercial
airport
for
the
greater
Cleveland
area.
The
Airport
has
three
passenger
concourses,
and
at
least
one
significant
air
freight
operation
on
the
site.

Cleveland­
Hopkins
discharges
storm
water
runoff
and
groundwater
flow
to
Abram
Creek,
Rocky
River
and
the
South
Branch
of
Silver
Creek.
The
storm
water
discharges
from
the
Airport
can
contain
de­
icing
compounds
used
on
aircraft
and
runways.
The
de­
icing
compounds
used
on
aircraft
are
typically
ethylene
glycol
and
propylene
glycol;
the
runway
de­
icing
compounds
used
are
typically
calcium
acetate,
calcium
magnesium
acetate
and
sodium
formate.
The
glycol
compounds
are
toxic
to
aquatic
life
when
water
concentrations
are
sufficiently
high,
and
Ohio
EPA
has
calculated
water
quality
criteria
for
these
compounds.
All
of
the
chemicals
mentioned
above
also
consume
dissolved
oxygen
in
waterbodies,
which
may
impact
aquatic
life.

The
Airport
has
begun
a
best
management
practices
program
(
BMP)
to
minimize
the
discharge
of
aircraft
de­
icing
materials.
The
BMP
steps
implemented
to
date
focus
on
using
sweeper
trucks,
also
called
glycol
recovery
vehicles
to
vacuum
glycol
before
it
runs
off
the
pavement.
The
vacuumed
glycol
is
sent
off­
site
for
recycling
or
treatment.

The
groundwater
on
parts
of
the
Cleveland­
Hopkins
site
appear
to
contain
residual
pollutants
from
past
deicing
practices,
particularly
ammonia­
nitrogen
from
the
past
use
of
urea
to
de­
ice
runways.
There
also
may
be
discharges
of
trace
chemicals
from
fuels
that
may
have
spilled
in
the
past,
or
otherwise
escaped
collection/
treatment.
Cleveland­
Hopkins
Airport
Page
4
The
Airport
has
several
oil/
water
separators
to
treat
runoff
from
areas
of
the
airport
where
fuel
is
stored,
where
aircraft
are
fueled,
or
where
pollutants
from
fuel
or
oil
may
be
present.

Receiving
Water
Quality
/
Environmental
Hazard
Assessment
An
assessment
of
the
impact
of
a
permitted
point
source
on
the
immediate
receiving
waters
includes
an
evaluation
of
the
available
chemical/
physical
(
water
column,
effluents,
sediment,
flows),
biological
(
fish
and
macroinvertebrate
assemblages),
and
habitat
data
which
have
been
collected
by
Ohio
EPA
pursuant
to
the
Five­
Year
Basin
Approach
for
Monitoring
and
NPDES
Reissuance.
Other
data
may
be
used
provided
it
was
collected
in
accordance
with
Ohio
EPA
methods
and
protocols
as
specified
by
the
Ohio
Water
Quality
Standards
and
Ohio
EPA
guidance
documents.
Other
information
which
may
be
evaluated
includes,
but
is
not
limited
to,
NPDES
permittee
self­
monitoring
data
and
effluent
and
mixing
zone
bioassays
conducted
by
Ohio
EPA,
the
permittee,
or
U.
S.
EPA.

Ohio
EPA
relies
on
a
tiered
approach
in
attempting
to
link
administrative
activity
indicators
(
i.
e.,
permitting,
grants,
enforcement)
with
true
environmental
indicators
(
i.
e.,
stressor,
exposure,
and
response
indicators).
Stressor
indicators
generally
include
activities
which
have
the
potential
to
degrade
the
aquatic
environment
such
as
pollutant
discharges
(
permitted
and
unpermitted),
land
use
effects,
and
habitat
modifications.
Exposure
indicators
include
whole
effluent
toxicity
tests,
tissue
residues,
and
biomarkers,
each
of
which
provides
evidence
of
biological
exposure
to
stressor
or
bioaccumulative
agents.
Response
indicators
include
the
more
direct
measures
of
community
and
population
response
and
are
represented
here
by
the
biological
indices
which
comprise
Ohio
EPA's
biological
criteria.
The
key
is
in
using
the
different
types
of
indicators
within
the
roles
which
are
the
most
appropriate
for
each.
Describing
the
causes
and
sources
associated
with
observed
impairments
relies
on
an
interpretation
of
multiple
lines
of
evidence
including
the
water
chemistry
data,
sediment
data,
habitat
data,
effluent
data,
biomonitoring
results,
land
use
data,
and
biological
response
signatures
within
the
biological
data
itself.
Thus
the
assignment
of
principal
causes
and
sources
of
impairment
represents
the
association
of
impairments
(
defined
by
response
indicators)
with
stressor
and
exposure
indicators.
Cleveland­
Hopkins
Airport
Page
5
Use
attainment
is
a
term
which
describes
the
degree
to
which
environmental
indicators
are
either
above
or
below
criteria
specified
by
the
Ohio
Water
Quality
Standards
(
WQS;
Ohio
Administrative
Code
3745­
1).
Assessing
use
attainment
status
for
aquatic
life
uses
involves
a
primary
reliance
on
the
Ohio
EPA
biological
criteria
(
OAC
3745­
1­
07;
Table
7­
17).
These
are
confined
to
ambient
assessments
and
apply
to
rivers
and
streams
outside
of
mixing
zones.
Numerical
biological
criteria
are
based
on
multimetric
biological
indices
which
include
the
Index
of
Biotic
Integrity
(
IBI)
and
modified
Index
of
Well­
Being
(
MIwb),
which
indicate
the
response
of
the
fish
community,
and
the
Invertebrate
Community
Index
(
ICI),
which
indicates
the
response
of
the
macroinvertebrate
community.
Numerical
endpoints
are
stratified
by
ecoregion,
use
designation,
and
stream
or
river
size.
Three
attainment
status
results
are
possible
at
each
sampling
location
­
full,
partial,
or
non­
attainment.
Full
attainment
means
that
all
of
the
applicable
indices
meet
the
biocriteria.
Partial
attainment
means
that
one
or
more
of
the
applicable
indices
fails
to
meet
the
biocriteria.
Non­
attainment
means
that
none
of
the
applicable
indices
meet
the
biocriteria
or
one
of
the
organism
groups
reflects
poor
or
very
poor
performance.
An
aquatic
life
use
attainment
table
(
see
Table
1)
is
constructed
based
on
the
sampling
results
and
is
arranged
from
upstream
to
downstream
and
includes
the
sampling
locations
indicated
by
river
mile,
the
applicable
biological
indices,
the
use
attainment
status
(
i.
e.,
full,
partial,
or
non),
the
Qualitative
Habitat
Evaluation
Index
(
QHEI),
and
comments
and
observations
for
each
sampling
location.

Cleveland
Hopkins
International
Airport
The
City
of
Cleveland
owns
and
operates
the
Cleveland
Hopkins
International
Airport
(
CHIA).
In
early
1987,
the
Ohio
EPA
first
became
aware
of
potential
illegal
discharges
of
sanitary
waste,
fuel
and
degreasing
solvents,
and
deicing
chemicals
from
the
airport
via
a
number
of
storm
sewers
in
violation
of
Ohio
Revised
Code
(
ORC)
6111.04
and
Section
402
of
the
Federal
Water
Pollution
Control
Act.
These
discharges
were
entering
the
Rocky
River
mainstem,
Abram
Creek
and
Silver
Creek
.

On
August
6,
1987,
the
US
EPA
Region
V,
issued
Findings
of
Violation
and
Order
of
Compliance
against
the
City
of
Cleveland
to
investigate
the
discharge
of
stormwater
from
the
airport
property,
after
finding
that
the
airport
discharges
sanitary
waste,
and
contaminated
stormwater
without
an
issued
NPDES
permit.

On
August
11,
1992
a
Consent
Order
was
issued
by
the
Cuyahoga
County
Court
of
Common
Pleas
against
the
City
of
Cleveland
and
Executive
Hangers,
Inc.
for
activities
conducted
at
the
Cleveland
Hopkins
International
Airport
in
violation
of
ORC
6111.
On
June
16,
1995,
Ohio
EPA
approved
of
the
Stormwater
Pollution
Prevention
Study
that
was
conducted
in
1994
in
fulfillment
of
the
Consent
Order.
At
the
request
of
Ohio
EPA,
the
Cleveland
Hopkins
Airport
submitted
an
NPDES
permit
application
to
the
Ohio
EPA
on
August
17,
1995
addressing
stormwater
runoff
from
eight
outfalls
that
drain
from
the
Cleveland
Hopkins
Airport.
As
of
April
1998,
the
draft
NPDES
permit
has
not
been
issued.
On
October
2,
1996
the
Ohio
EPA
received
a
report
conducted
by
the
city
of
Cleveland
consultants,
Malcolm
Pirnie,
Inc.,
on
the
aquatic
life
use
attainment
of
Abram
Creek.
The
Ohio
EPA,
Division
of
Emergency
and
Remedial
Response
(
DERR)
is
working
with
the
city
and
CHIA
at
six
sites
as
part
of
the
Voluntary
Action
Program
(
VAP)
initiative.
The
Hopkins
Airport
also
has
old
foundry
sand
solid
waste
sites
on
their
property
near
Abram
Creek
that
fall
under
Rule
13
of
the
Ohio
EPA
solid
waste
regulations.
Cleveland­
Hopkins
Airport
Page
6
The
fate
of
stormwater
from
Cleveland
Hopkins
International
Airport
is
confusing
and
not
completely
understood
at
this
time.
Stormwater
outfalls
from
CHIA
discharge
to
a
number
of
NASA­
Lewis
Research
Center
outfalls.
Cleveland
Hopkins
outfall
006
discharges
to
NASA
008
outfall,
which
enters
Abram
Creek.
Cleveland
Hopkins
007
and
008
outfalls
enter
NASA
017
and
015
outfalls
respectively,
both
of
which
discharge
directly
to
the
Rocky
River.
Cleveland
Hopkins
Airport
outfall
003
enters
Abram
Creek
upstream
from
RM
1.9.
CHIA
outfall
005
and
004
form
a
small
tributary
to
Abram
Creek
that
confluences
with
the
creek
upstream
from
Cedar
Point
Rd.
(
RM
0.85).
Recently,
the
airport
discovered
that
this
unnamed
tributary
also
receives
drainage
from
either
outfall
areas
006
or
007,
or
both
via
NASA
outfall
031
(
also
designated
CHIA
outfall
009).
CHIA
001
and
002
outfalls
discharge
to
Silver
Creek
The
following
summary
was
compiled
from
information
in
Biological
and
Water
Quality
Study
of
the
Rocky
River
and
Selected
Tributaries,
Ohio
EPA
Technical
Report
MAS/
1998­
12­
3
and
Ohio
EPA
files.
As
part
of
the
above
referenced
study,
chemical
and
biological
sampling
was
conducted
at
4
sites
in
Abram
Creek
during
June­
October
1997.
Similar
sampling
was
also
conducted
by
the
Ohio
EPA
during
1981
and
1992.

Aquatic
life
use
attainment
status
in
Abram
Creek
has
been
severely
impaired
since
initial
sampling
in
1981.
This
is
despite
the
elimination
of
two
WWTPs
in
the
upper
watershed
in
1992
and
subsequent
reductions
in
loadings
of
oxygen
demanding
wastes
and
ammonia­
N
(
Table
1).
Index
of
Biotic
Integrity
(
IBI)
scores
were
in
the
Very
Poor
range
at
all
sampled
locations
in
1997.
Invertebrate
Community
Index
scores
(
ICI)
were
in
the
Fair
range.

Abram
Creek
is
a
headwater
tributary
of
the
Rocky
River
mainstem,
with
a
drainage
area
of
10.1
square
miles.
The
entire
Abram
Creek
watershed
is
urbanized.
The
upper
most
sampling
location
(
RM
3.2)
was
previously
channelized
and
lacked
warmwater
habitat
attributes.
Downstream,
urban
stormwater
runoff
contributed
embedding
sediment
and
reduced
sinuosity
and
channel
development.
High
gradient
in
the
lower
two
mile
reach
minimized
some
of
the
impact
from
urbanization.
There,
the
stream
contained
a
higher
proportion
of
warmwater
habitat
attributes.
The
substrates
and
riffles
were
less
embedded
than
upstream,
more
cover
was
present,
and
substrate
quality
was
better.
Although
collectively
the
habitat
in
Abram
Creek
is
marginally
suited
to
supporting
a
warmwater
assemblage
of
fish
(
mean
QHEI
=
54.5
±
8.3
SD),
the
habitat
in
the
lower
reach
is
fully
capable
of
supporting
a
warmwater
stream
fauna.

Dissolved
oxygen
recorded
as
part
of
the
1997
survey
of
Abram
Creek,
showed
an
improvement
between
1992
and
1997
at
RM
1.9,
with
about
a
1.5
mg/
l
increase
in
minimum
oxygen
concentration.
The
lowest
dissolved
oxygen
measurement
at
RM
1.9
in
1997
was
6.0
mg/
l,
which
is
well
above
the
minimum
dissolved
oxygen
criterion
for
a
WWH
stream.
During
the
1997
survey,
low
dissolved
oxygen
(
4.4
mg/
l)
was
found
at
the
most
upstream
station
at
RM
3.9
(
Sheldon
Road),
most
likely
due
to
the
low
flow
and
limited
reaeration
potential.
Upstream
from
Klothoff
Road
(
RM
2.85),
most
of
Abram
Creek
has
been
channelized
and
has
a
low
gradient.
Also
during
the
1997
survey,
exceedences
of
water
quality
standards
for
fecal
coliform
bacteria
were
found
at
all
stations
on
Abram
Creek
especially
after
rain
runoff,
which
suggests
non­
point
sources
of
bacteria
remain
in
the
urban
watershed.

Malcolm
Pirnie,
in
their
1996
study
of
Abram
Creek
for
the
city
of
Cleveland,
documented
elevated
ammonia­
N
in
samples
collected
on
January
19,
1996
near
Sheldon
Road
(
2.75
and
2.28
mg/
l),
at
the
same
time
that
elevated
ammonia­
N
was
found
at
Klothoff
Road
at
RM
2.85
(
2.10
and
2.17
mg/
l).
However,
this
winter
sample
was
collected
when
TSS
levels
were
extremely
elevated
(
range
of
values
from
73
to
103
mg/
l),
which
indicates
that
they
were
taken
after
a
significant
rain
event
and
would
not
represent
normal
Cleveland­
Hopkins
Airport
Page
7
base
flow
conditions
in
Abrams
Creek.
Thus,
the
upstream
"
source"
of
ammonia­
N
reported
by
Malcolm
Pirnie
was
most
likely
ammonia­
N
attached
to
sediment
organic
particles,
and
not
ammonia­
N
that
would
be
dissolved
in
the
water
under
base
flow
conditions.
Any
potential
seepage
of
ammonia­
N
from
the
Cleveland
Hopkins
Airport
storm
sewers
located
above
Klothoff
Road
would
have
been
diluted
by
the
high
stream
flow.
However,
an
earlier
sample
collected
during
normal
base
flow
conditions
on
July
24,
1995
showed
relatively
low
levels
of
ammonia­
N
at
Klothoff
Road
(
0.56
mg/
l),
and
further
upstream
(
0.46
and
0.39
mg/
l),
indicating
that
chronic
sources
of
ammonia­
N
do
not
exist
in
Abram
Creek
at
locations
upstream
from
the
Cleveland
Hopkins
Airport
storm
sewers
near
Klothoff
Road.
Data
collected
by
Ohio
EPA
at
the
upstream
stations
during
the
1997
survey
also
show
low
levels
of
ammonia­
N
in
Abrams
Creek
above
the
Cleveland
Hopkins
004
and
005
outfall
during
normal
base
flow
stream
conditions.

The
sampled
reach
of
Abram
Creek
(
RM
3.2
to
RM
0.2)
was
in
NON
attainment
of
the
WWH
biological
criteria
(
Table
1).
Fish
and
macroinvertebrate
communities
in
Abram
Creek
near
Eastland
Rd
(
RM
3.2)
appeared
to
be
negatively
impacted
by
habitat
alteration
and
polluted
storm
water
runoff.
However,
this
location
did
support
adult
fish
and
numerous
young
of
the
year
fathead
minnows
were
observed
in
the
electrofishing
field
suggesting
that
water
quality
was
not
as
severely
degraded,
or
episodic
toxicity
as
frequent,
as
downstream.
Elimination
of
discharges
from
the
Middleburg
Heights
(
RM
4.0)
and
Brookpark
WWTPs
(
RM
3.7)
in
1993
resulted
in
significantly
improved
chemical
water
quality
and
limited
improvement
in
macroinvertebrate
community
condition
at
RMs
1.9
and
0.2.
ICI
scores
were
in
the
poor
range
in
1992
but
improved
to
the
fair
range
in
1997.

Abram
Creek
was
nearly
devoid
of
fish
at
the
three
downstream
sampling
locations.
As
few
as
1
juvenile
green
sunfish
and
3
young
of
the
year
white
suckers
were
collected
from
RM
0.6
on
one
pass,
and
fewer
than
17
fish
were
collected
on
all
other
passes
at
each
location.
The
near
complete
absence
of
fish
in
Abram
Creek
demonstrates
frequent
acute
water
column
toxicity.
Fish
sampling
at
RM
2.8
was
presumed
to
be
upstream
from
Cleveland
Hopkins
International
Airport
stormwater
outfalls,
however,
a
storm
sewer
draining
the
IX
center
and
part
of
the
airport
enters
the
creek
upstream
from
Klothoff
Road.
Other
potential
sources
of
pollutants
to
Abram
Creek
between
Klothoff
Road
(
RM
2.9)
and
Grayton
Rd.
(
RM
1.9)
are
disposal
sites
for
foundry
sand,
fly
ash,
construction
landfill
wastes
and
urban
runoff.
Cleveland­
Hopkins
Airport
Page
8
A
primary
cause
of
low
biological
performance
in
Abram
Creek
downstream
from
Grayton
Rd.
(
RM
1.9)
to
the
mouth
was
elevated
ammonia
concentrations
originating
from
deicing
operations
at
CHIA.
Urea
based
chemicals
are
used
for
runway
deicing.
These
compounds
readily
decompose
into
ammonia­
N
when
dissolved
in
water.
Sampling
of
various
storm
sewer
outfalls
since
1987
by
Ohio
EPA,
US
EPA,
and
consultants
for
the
Cleveland
Hopkins
Airport
indicate
a
long
history
of
discharge
of
very
elevated
levels
of
ammonia­
N
(
concentrations
greater
than
100
mg/
l)
and
pH
values
above
9.5
S.
U.
No
long
term
NPDES
sampling
data
from
the
Cleveland
Hopkins
storm
sewers
are
available
since
the
NPDES
permit
has
not
been
issued.
During
the
summer
of
1997,
the
highest
ammonia­
N
recorded
at
Grayton
Rd.
was
0.47
mg/
l.
Additional
winter
sampling
by
Ohio
EPA
district
staff
on
January
26,
1998
at
RM
1.9
showed
elevated
ammonia­
N
(
1.48
mg/
l).
These
data
suggest
that
seasonal
toxicity
due
to
ammonia­
N
runoff
from
the
CHIA
likely
affected
the
performance
of
biological
communities
at
RM
1.9.
Samples
collected
at
Cedar
Point
Rd.,
downstream
from
two
large
storm
sewer
outlets
that
drain
the
CHIA
(
outfalls
005,
004
and/
or
006
and
007)
and
NASA
(
outfalls
031
and
030),
yielded
highly
elevated
ammonia­
N
ranging
from
1.71
to
5.49
mg/
l.
These
values
exceed
OMZA
(
outside
mixing
zone
average)
water
quality
criteria
for
chronic
toxicity.
It
is
significant
that
four
of
the
five
samples
were
collected
during
dry
periods
with
low
base
flow
conditions,
which
indicates
daily
chronic
ammonia­
N
toxicity
in
Abram
Creek
at
RM
0.85.
The
source
of
elevated
ammonia­
N
during
summer
low
flow
conditions
is
probably
shallow
ground
water
that
has
been
contaminated
by
airport
deicing
operations.

Additional
sampling
by
NEDO
staff
on
January
6,
1998
of
the
tributary
formed
by
the
Cleveland
Hopkins
004
and
005
outfalls
yielded
an
ammonia­
N
concentration
of
149
mg/
l;
a
value
more
than
10
times
the
acute
toxicity
water
quality
standard.
On
March
10,
1998,
a
sample
collected
by
Ohio
EPA
from
a
Cleveland
Hopkins
storm
sewer
that
discharges
to
NASA
outfall
031
had
an
ammonia­
N
concentration
of
28
mg/
l.
An
ammonia­
N
concentration
of
43
mg/
l
was
recorded
in
a
sample
collected
from
Cleveland
Hopkins
005
discharge
on
the
same
day.
In
April,
1998,
a
fish
kill
of
about
20
white
suckers,
which
had
entered
the
stream
to
spawn,
was
reported
from
Abram
Creek
at
five
locations
between
Cedar
Point
Road
(
RM
0.85)
and
West
Area
Road
near
the
mouth.

Development
of
Water­
Quality
Based
Effluent
Limits
Toxic
concentrations
of
ammonia­
N
resulting
from
deicing
operations
at
the
Cleveland
Hopkins
International
Airport
are
severely
impacting
biological
communities
in
Abram
Creek.
Limiting
ammonia­
N
to
levels
that
do
not
exceed
WQS
will
likely
allow
attainment
of
the
biological
criterion
in
the
macroinvertebrate
community
downstream
from
Grayton
Rd.
In
addition,
concentrations
of
glycol
compounds
in
airport
runoff
also
exceed
water
quality
criteria
at
times.
Limiting
these
discharges
to
levels
that
meet
WQ
criteria
will
also
help
attain
biological
criteria
downstream
from
the
discharges.

Because
CHIA's
discharge
events
occur
primarily
during
precipitation,
water
quality
modeling
for
D.
O.
can
only
be
approximated
using
available
data
and
references.
CHIA's
Master
Drainage
Report,
received
by
Ohio
EPA
in
August
2000,
is
being
reviewed
to
determine
whether
more
detailed
information
exists
in
this
document
to
more
fully
develop
flow
relationships
and
modeled
effluent
limits.

Ohio
EPA
has
conducted
an
analysis
of
the
appropriate
waste
loads
for
ammonia
nitrogen
(
NH3­
N)
and
glycols
for
the
NPDES
permit
for
Cleveland
Hopkins
International
Airport
(
CHIA).
The
analysis
was
done
using
the
information
contained
in
Ohio
EPA's
January
1999
water
quality
analysis
(
Tables
1­
4
of
this
fact
sheet),
and
some
of
the
information
from
CHIA's
Master
Drainage
Report.
Cleveland­
Hopkins
Airport
Page
9
The
critical
issue
surrounding
the
development
of
adequate
permit
limits
for
the
CHIA
outfalls
is
the
selection
of
appropriate
flow
scenarios
for
storm
water
discharges
under
critical
low
flow
conditions
which
will
be
both
reasonable
worst
case
estimates
while
being
protective
of
downstream
water
quality.

The
standard
methodology
for
developing
waste
loads
is
provided
in
OAC
3745­
2­
05
and
3745­
2­
10.
This
procedure
uses
of
the
mass
balance
equation:

WLA
=
WQC
(
Qeff
+
Q
up)
­
Qup
(
WQup)
Qeff
where:
Qup
=
upstream
flow
(
critical
low
flow
values
required
by
rule)
Qeff
=
effluent
flow
WQC
=
water
quality
criteria
as
listed
in
OAC
Chapter
3745­
1
and
WQup
=
upstream
water
quality
The
following
is
a
step­
by­
step
explanation
of
the
methodology
used
to
develop
a
set
of
reasonable
worst
case
water
quality­
based
limits
for
the
outfalls
that
protect
downstream
water
quality:

Upstream
Flow
(
Qup):

To
estimate
Qup,
the
PSD
utilized
critical
low
flow
estimates
for
Abram
Creek
and
Silver
Creek
which
were
calculated
by
correcting
values
from
the
nearest
USGS
gage
(
Rocky
River
at
Berea,
Sta.
04201500)
for
watershed
area.
Low
flow
values
from
the
period
of
1979­
1988
(
Attachment
1)
were
used
as
published
by
the
USGS
(
Johnson
and
Metzker,
1981).
The
same
low
flow
values
were
used
to
estimate
upstream
flows
in
the
Rocky
River,
but
these
flows
were
augmented
by
adding
10.83
cfs
to
the
critical
low
flow
estimates
at
the
Rocky
River
gage
to
account
for
the
10.83
cfs
(
7
mgd)
design
flow
of
the
North
Olmsted
WWTP
which
is
located
upstream
of
the
airport
discharges
and
downstream
of
the
gage.
The
updated
estimates
of
Qup
are
provided
on
page
1
of
Attachment
2.

Storm
Water
Flow
(
Qeff):

The
most
difficult
estimate
to
construct
is
that
of
the
flows
from
the
CHIA
outfalls.
Data
regarding
flows
to
date
have
primarily
been
collected
during
the
wintertime
periods,
and
are
of
limited
duration
to
establish
reasonable
worst
case
assumptions
with
respect
to
critical
low
flow
conditions
in
the
stream.

To
estimate
a
set
of
reasonable
worst
case
scenarios
for
discharges
from
the
airport,
Ohio
EPA
utilized
a
USDA­
SCS
publication
for
estimating
runoff
in
small
watersheds
(
USDA­
SCS,
1986).
This
protocol
utilizes
land
cover
and
soils
characteristics
to
estimate
runoff
from
small
watersheds
by
estimating
a
runoff
curve.
Drainage
areas
for
each
outfall
and
land
use
were
obtained
from
the
CHIA
Master
Drainage
Plan
(
Malcolm
Pirnie,
Inc.,
1999),
and
soils
composition
for
each
drainage
area
was
estimated
from
the
soils
survey
map.
Worst
case
average
outfall
flow
conditions
were
approximated
by
assuming
an
annualized
average
runoff
from
the
airport
property.
This
was
calculated
by
dividing
the
average
total
rainfall
for
the
area
(
34.1")
to
obtain
an
average
daily
precipitation
value.
High
flow
conditions
for
calculating
impacts
of
maximum
effluent
concentrations
were
estimated
by
calculating
flow
volumes
for
two
cases:
an
average
storm
event
(
0.5"
in
11.2
hours),
and
the
5
year
24
hour
storm
(
2.93"
in
24
hours)
(
rainfall
estimates
based
upon
NOAA
data
for
northeast
Ohio
and
Cleveland
Hopkins
Intl.
Airport)
.
The
5
year
24
hour
storm
event
was
chosen
since
this
is
the
design
criteria
required
of
airports
by
the
FAA
(
Malcolm
Pirnie,
Inc.,
Cleveland­
Hopkins
Airport
Page
10
1999).
Volumes
for
precipitation
were
then
calculated
for
each
outfall
within
the
airport
by
correcting
for
drainage
area.
Volumes
generated
in
the
outfall
under
the
three
conditions
were
then
calculated
using
the
SCS
runoff
equation
(
USDA­
SCS,
1986)
to
develop
estimates
for
Qeff.
Components
of
the
calculations
are
provided
on
page
2
of
Attachment
2.
For
comparison
purposes,
a
summary
of
the
flow
monitoring
data
provided
from
storm
events
monitored
by
CHIA
from
1999
on
the
Master
Drainage
Plan
CD­
ROM
is
provided
on
page
3
of
Attachment
2.
It
appears
that
the
flow
values
calculated
in
the
analysis
are
reasonable
worst
case
estimates
which
can
be
used
for
calculating
waste
loads.

Abram
Creek
and
Silver
Creek
both
have
multiple
outfalls.
Since
the
outfalls
within
these
streams
are
located
very
closely
together,
the
total
flows
in
each
outfall
for
these
streams
were
combined
for
modeling
purposes.
In
addition,
the
two
Rocky
River
outfalls
were
also
combined
for
the
same
reason.
The
estimated
combined
flows
for
each
stream
are
listed
on
page
3
of
Attachment
2.

The
Water
Quality
criteria
used
in
the
analysis
are
listed
in
Table
2.
The
background
water
quality
assumptions
and
model
inputs
are
listed
in
Table
3.

Wasteload
Allocation:

As
a
first
step,
an
initial
set
of
proposed
permit
limits
(
WQS
end­
of­
pipe
for
Abrams
and
Silver
Creek
discharges,
and
inside­
mixing­
zone
maximum
WQS
for
Rocky
River
discharges)
were
used
to
calculate
the
impact
of
the
storm
water
discharges
from
the
CHIA
outfalls
on
downstream
water
quality
using
the
flow
estimations
for
the
average
discharge
case
and
the
two
high
flow
discharges
cases
(
average
storm
event
and
5
year
24
hour
storm).
In­
stream
water
quality
was
estimated
for
Abram
Creek
downstream
of
outfall
006,
in
Silver
Creek
at
the
mouth,
and
for
the
Rocky
River
downstream
of
Silver
Creek.
In
estimating
downstream
conditions
in
the
Rocky
River,
loadings
from
Abram
Creek
and
Silver
Creek
were
assumed
to
be
those
resulting
from
discharge
concentrations
mimicking
those
being
evaluated
for
the
Rocky
River
outfalls
(
i.
e.
the
concentration
in
each
outfall
was
at
the
permit
limit
concentration
under
the
same
flow
condition
being
modeled).

The
results
of
the
analysis
are
provided
on
page
5
of
Attachment
2.
Use
of
the
stream/
discharge
flow
ratio
following
the
criteria
set
in
OAC
3745­
2­
05
(
A)(
2)
found
that
100
percent
of
the
stream
design
flow
should
be
used
to
calculate
waste
loads
for
NH3­
N
(
average
and
maximum)
and
for
maximum
glycol
limits.
Twenty­
five
percent
of
the
stream
design
flow
was
used
for
calculating
the
impacts
and
waste
loads
for
glycols
as
required
by
OAC
3745­
2­
05
(
A)(
2)(
d)(
i).
The
analysis
revealed
that
if
the
initial
set
of
limits
were
used,
violations
of
the
OMZM
water
quality
criteria
could
be
expected
in
the
Rocky
River
for
NH3­
N
and
glycols
under
the
5
year
24
hour
storm
high
flow
case.
In
addition,
violations
of
the
summer
OMZA
water
quality
criteria
for
NH3­
N
in
the
Rocky
River
would
be
expected
under
the
average
daily
flow
(
base
flow)
scenario.
The
impact
analysis
also
indicated
that
upstream
dilution
may
allow
for
higher
30
day
average
NH3­
N
concentrations
in
winter
for
discharges
to
Silver
Creek
and
Abram
Creek
than
those
in
the
initial
set
of
limits.

Results
for
the
computations
used
to
calculate
appropriate
water
quality
based
effluent
limits
(
WQBEL's)
for
NH3­
N
and
glycols
in
outfalls
007
and
008
to
meet
downstream
water
quality
criteria
in
the
Rocky
River
are
provided
on
pages
6
and
7
of
Attachment
2.
For
the
Rocky
River
outfalls,
discharges
from
Abram
Creek
were
considered
to
be
interactive.
Upstream
dilution
was
assumed
to
be
25%
of
the
upstream
flow,
plus
that
of
Abram
Creek
with
Abram
Creek
outfall
flows
calculated
under
the
same
flow
condition.
Water
quality
upstream
from
the
Rocky
River
outfalls
was
first
calculated
using
the
mass
Cleveland­
Hopkins
Airport
Page
11
balance
equation
to
incorporate
loads
from
Abram
Creek.
Resulting
WQBELs
were
then
calculated.

Because
the
underlying
flow
assumptions
for
the
outfalls
changes
with
the
cases
modeled,
the
WLA
analysis
found
that
the
allowable
effluent
concentration
for
NH3­
N
in
the
Rocky
River
outfalls
(
007
and
008)
could
be
much
higher
under
the
average
case
than
under
the
high
flow
condition
and
still
be
protective
of
downstream
water
quality.
In
addition,
it
was
also
clear
that
the
concentration
in
the
discharges
from
the
Abram
Creek
outfalls
had
a
much
greater
impact
on
concentrations
in
the
Rocky
River
under
high
flow
conditions
from
the
airport.
Therefore,
in
order
to
provide
for
workable
effluent
limitations
for
the
Rocky
River
outfalls
under
both
average
and
worst
case
conditions,
the
wintertime
maximum
limits
for
NH3­
N
for
the
Abram
Creek
outfalls
was
adjusted
down
to
4.5
mg/
l.
This
adjustment
resulted
in
effluent
limitations
in
the
Rocky
River
outfalls
equal
to
the
IMZM,
but
which
meet
the
downstream
water
quality
criteria
in
the
Rocky
River.
Reduced
maximum
NH3­
N
concentrations
in
Abram
Creek
will
also
be
beneficial
to
the
stream
by
reducing
the
potential
for
toxic
impacts
in
the
smaller
stream.

Results
for
the
WQBEL
analysis
for
wintertime
average
NH3­
N
concentrations
in
Silver
Creek
and
Abram
Creek
outfalls
is
provided
on
page
8
of
Attachment
2.
These
changes
do
not
affect
the
allocation
results
for
the
Rocky
River
outfalls.

Effluent
limits
necessary
to
protect
downstream
water
quality
are
summarized
in
Table
4.
In
the
absence
of
more
sophisticated
modeling
data
which
can
further
refine
the
relationship
of
storm
water
flow
from
the
airport
with
stream
flow,
this
analysis
and
the
resulting
permit
limits
are
protective
of
water
quality
standards
for
toxic
materials,
and
should
be
used
to
establish
permit
limitations
in
the
CHIA
industrial
storm
water
permit.

The
analysis
did
not
address
limits
for
oxygen
demanding
compounds
to
protect
water
quality
for
acceptable
concentrations
of
dissolved
oxygen
downstream
of
CHIA.
The
modeling
found
in
the
1999
Master
Drainage
Plan
indicates
that
the
potential
exists
for
violations
of
the
water
quality
criteria
for
dissolved
oxygen
in
both
Abram
Creek
and
the
Rocky
River
under
current
conditions.
Further
elaboration
of
the
information
found
in
the
Master
Drainage
Plan
is
needed
from
CHIA
to
provide
the
necessary
data
to
establish
protective
limits
for
CBOD
and
COD
which
are
protective
of
the
downstream
water
quality
for
dissolved
oxygen.
Literature
Cited
Johnson,
D.
P.,
and
K.
D.
Metzker
(
1981).
Low­
Flow
Characteristics
of
Ohio
Streams.
U.
S.
Geological
Survey
Open­
file
Report
81­
1195.
Columbus,
Ohio.

Malcolm
Pirnie,
Inc.
(
1994).
Storm
Water
Pollution
Prevention
Study,
Cleveland
Hopkins
International
Airport.
Project
0233­
005­
2B0,
July
1994.

Malcolm
Pirnie,
Inc.
(
1999).
Master
Drainage
Plan
for
City
of
Cleveland
Department
of
Port
Control,
Cleveland
Hopkins
International
Airport,
Cleveland,
Ohio.
Malcolm
Pirnie,
Inc.,
0233­
015,
September,
1999.

USDA­
SCS
(
1986).
Urban
Hydrology
for
Small
Watersheds.
USDA
Soil
Conservation
Service
Technical
Release
55.
210­
VI­
TR­
55,
Second
Ed.,
June
1986.

Effluent
Limits/
Hazard
Management
Decisions
Cleveland­
Hopkins
Airport
Page
12
After
appropriate
effluent
limits
are
calculated,
the
reasonable
potential
of
the
discharger
to
violate
the
WLA
(
and
the
WQS)
must
be
determined.
In
this
case,
reasonable
potential
has
been
determined
by
comparing
field
survey
results
to
the
wasteload
allocation,
when
survey
data
is
available
for
the
pollutant
parameter.
If
the
survey
data
are
greater
than
the
allocation,
limits
are
needed.
If
survey
data
was
not
available
or
very
scant,
limits
were
established
based
on
the
pollutants
expected
to
be
discharged,
knowing
the
operations
at
CHIA
or
at
airports
in
general.

Limits
proposed
for
pH
and
dissolved
oxygen
are
based
on
Water
Quality
Standards
(
OAC
3745­
1).

Limits
for
oil
and
grease
are
based
on
the
treatment
capability
of
common
oil/
water
separators
used
for
storm
runoff.

As
previously
stated,
the
effluent
limits
for
ammonia­
nitrogen
and
glycols
are
based
on
the
wasteload
allocation.
Where
ammonia­
N
limits
for
the
Rocky
River
outfalls
are
based
on
inside­
mixing­
zone
maximum
standards,
these
standards
are
calculated
by
multiplying
the
maximum
ambient
water
quality
standards
from
OAC
Rule
3745­
1­
07,
Table
7­
2
by
a
factor
of
two.
This
multiplier
is
used
to
convert
virtually
all
ambient
maximum
criteria
to
inside­
mixing
zone
maximum
criteria
(
and
vice­
versa);
it
is
found
in
the
aquatic
life
criteria
calculation
procedures
for
the
Lake
Erie
basin
(
OAC
3745­
1­
36(
A)(
3)(
m)).

In
response
to
a
CHIA
request,
Ohio
EPA
has
applied
the
glycol
toxicity
WQS
as
Chemical
Oxygen
Demand
(
COD)
concentrations.
As
part
of
the
Master
Drainage
Plan
Report,
Cleveland
submitted
discharge
data
which
shows
a
correlation
between
glycol
and
COD
concentrations
(
Master
Drainage
Plan
Report
­
Appendix
E).
This
relationship
is
shown
in
Attachment
3
to
this
fact
sheet.
Using
COD
as
an
indicator
pollutant
for
glycol
allows
a
less
expensive
test
method
to
be
used
for
monitoring
compliance,
allowing
compliance
sampling
to
be
done
more
frequently.
Limits
for
ethylene
and
propylene
glycol
are
listed
in
the
permit,
at
a
reduced
monitoring
frequency,
to
ensure
that
WQS
are
attained.
The
monitoring
requirement
for
glycols
also
serves
as
a
continuing
check
on
the
COD/
glycol
correlation.

For
example,
the
maximum
propylene
glycol
WQ
value
is
640
mg/
l.
Using
the
1.68
multiplier
to
convert
glycol
to
COD
results
in
a
maximum
COD
limit
of
1075
mg/
l.

Monitoring
for
glycol
compounds
and
CBOD5
is
being
required
to
check
the
continued
applicability
of
the
glycol/
COD
and
CBOD/
COD
relationships.
Monitoring
for
benzene,
toluene,
ethylbenzene,
xylenes,
1,2,4­
trimethylbenzene
and
naphthalene
is
being
required
to
monitor
trace
pollutants
associated
with
fuels
to
detect
spills,
releases
or
other
contamination
in
the
discharges.
Cleveland­
Hopkins
Airport
Page
13
Figure
1.
Approximate
location
of
the
Cleveland­
Hopkins
International
Airport.
Cleveland­
Hopkins
Airport
Page
14
Abram
Creek
Rocky
River
Silver
Creek
N
^

003
004,
005,
009
006
Cleveland­
Hopkins
International
Airport
007
008
001,
002
RM
10.38
RM
9.66
Figure
2.
Rocky
River
/
Abram
Creek
Study
Area.
Cleveland­
Hopkins
Airport
Page
15
Table
1.
Summary
of
the
aquatic
life
use
attainment
status
for
the
Warmwater
Habitat
use
designation
in
Abram
Creek
based
on
data
collected
by
the
Ohio
EPA.

RIVER
MILE
Mod.
Use
Attain­
Fish/
Macro.
IBI
Iwb
ICI
QHEI
Ment
Status
Comments
Abram
Creek
(
1997)
Erie
Ontario
Lake
Plain:
WWH
(
existing)
3.2/
3.4
16*
NA
18*
42.5
NON
Eastland
Rd.
2.8/
­
12*
NA
­
52.5
(
NON)
Klothoff
Rd.
1.9
/
1.9
12*
NA
28*
65.5
NON
Grayton
Rd.
0.6/
0.2
12*
NA
26*
57.5
NON
West
Area
Rd.
Abram
Creek
(
1992)
1.9/
2.0
12*
NA
4*
73.0
NON
Ust.
Grayton
Rd.
0.4/
0.3
17*
NA
8*
59.0
NON
West
Area
Rd.
Abram
Creek
(
1981)
4.6/
­
16*
NA
­
43.0
(
NON)
3.7/
­
17*
NA
­
52.5
(
NON)
Ust.
Sheldon
Rd.
2.8/
­
15*
NA
­
51.5
(
NON)
Klothoff
Rd.
0.9/
­
24*
NA
­
67.0
(
NON)
Ust.
West
Area
Rd.
______________________________________________________________________________

Ecoregional
Biological
Criteria:
Erie­
Ontario
Lake
Plain
(
EOLP)
INDEX­
Site
Type
WWH
MWHb
IBI
­
Headwaters
40
24
ICI
34
22
*
­
Significant
departure
from
biocriteria
(>
4
IBI
or
ICI
units;
>
0.5
MIwb
units).
Underlined
scores
are
in
the
Poor
or
Very
Poor
range.
ns
­
Nonsignificant
departure
from
biocriteria
(

4
IBI
or
ICI
units;

0.5
MIwb
units).
a
­
Attainment
status
based
on
one
organism
group
is
parenthetically
expressed.
NA
­
Headwater
site;
MIwb
is
not
applicable
to
streams
with
drainage
areas
less
than
20
mi2.
b
­
Channel
modified
Cleveland­
Hopkins
Airport
Page
16
Table
2.
Water
Quality
Criteria
in
the
Study
Area
Outside
Mixing
Zone
Criteria
Inside
Average
Maximum
Mixing
Human
Agri­
Aquatic
Aquatic
Zone
Parameter
Units
Health
A
Wildlife
culture
Life
A
Life
A
Maximum
A
Rocky
River
Ammonia
mg/
l
007
&
008
summer
­­
­­
­­
0.8
5.6
11.8
winter
­­
­­
­­
1.9
5.2
10.4
Abram
Creek
Ammonia
mg/
l
003
summer
­­
­­
­­
0.6
4.7
9.4
winter
­­
­­
­­
2.3
6.5
13.0
004,
005,
summer
­­
­­
­­
0.6
4.7
9.4
006
&
009
winter
­­
­­
­­
2.3
6.5
13.0
Silver
Creek
Ammonia
mg/
l
001
&
002
summer
­­
­­
­­
0.3
2.2
4.4
winter
­­
­­
­­
0.5
1.1
2.2
All
Streams
Ethylene
Glycol
mg/
l
4500
B
B
140
1300
2600
Propylene
Glycol
mg/
l
B
B
B
71
640
1400
A
Human
Health
and
Aquatic
Life
criteria
are
Tier
I
except
for
ethylene
and
propylene
glycol
criteria,
which
are
Tier
II
values.
Cleveland­
Hopkins
Airport
Page
17
Table
3.
Instream
Conditions
and
Discharger
Flow
Parameter
Units
Value
Basis
Rocky
River
30Q10
cfs
summer
14.03
USGS
gage
#
04201500,
1923­
97
data
cfs
winter
39.83
USGS
gage
#
04201500,
1923­
97
data
7Q10
cfs
annual
12.63
USGS
gage
#
04201500,
1923­
97
data
cfs
summer
12.63
USGS
gage
#
04201500,
1923­
97
data
cfs
winter
26.83
USGS
gage
#
04201500,
1923­
97
data
1Q10
cfs
annual
20.6
USGS
gage
#
04201500,
1923­
97
data
Instream
Temperature
oC
summer
22.1
Storet;
18
values,
1992­
97
winter
3.0
BWQR*

Instream
pH
S.
U.
summer
8.2
Storet;
18
values,
1992­
97
winter
8.3
CHIA­
SWPP
Study,
2
values,
1994
Abram
Cr.
30Q10
cfs
summer
0.122
USGS
gage
#
04201500,
1923­
97
data
winter
1.102
USGS
gage
#
04201500,
1923­
97
data
7Q10
cfs
annual
0.068
USGS
gage
#
04201500,
1923­
97
data
cfs
summer
0.068
USGS
gage
#
04201500,
1923­
97
data
cfs
winter
0.608
USGS
gage
#
04201500,
1923­
97
data
1Q10
cfs
annual
0.046
USGS
gage
#
04201500,
1923­
97
data
Instream
Temperature
oC
summer
22.0
District
Data;
5
values,
1997
winter
3.0
BWQR
Instream
pH
S.
U.
summer
8.3
District
Data;
5
values,
1997
winter
8.2
CHIA­
SWPP
Study,
2
values,
1994
Cleveland­
Hopkins
Airport
Page
18
Table
3.
Instream
Conditions
and
Discharger
Flow
(
cont.)

Parameter
Units
Value
Basis
Silver
Cr.
30Q10
cfs
summer
0.013
USGS
gage
#
04201500,
1923­
97
data
winter
0.116
USGS
gage
#
04201500,
1923­
97
data
7Q10
cfs
annual
0.007
USGS
gage
#
04201500,
1923­
97
data
cfs
summer
0.007
USGS
gage
#
04201500,
1923­
97
data
cfs
winter
0.064
USGS
gage
#
04201500,
1923­
97
data
1Q10
cfs
annual
0.005
USGS
gage
#
04201500,
1923­
97
data
Instream
Temperature
oC
summer
24.0
BWQR
winter
3.0
BWQR
Instream
pH
S.
U.
summer
8.68
Master
Drainage
Plan,
20
values,
1999
winter
9.1
CHIA­
SWPP
Study,
4
values,
1994
Mixing
Assumption
%
average
100
Chronic
criteria
default
for
ammonia
%
average
25
Chronic
criteria
default
for
toxics
%
maximum
100
Stream­
to­
discharge
ratio
___________________________________________________________________________________
*
BWQR
=
OEPA's
Background
Water
Quality
Report
(
Analysis
of
Unimpacted
Stream
Data
for
the
state
of
Ohio)
Cleveland­
Hopkins
Airport
Page
19
___________________________________________________________________________________

Table
4.
Summary
of
Effluent
Limits
to
Maintain
Applicable
Water
Quality
Criteria
Average
Maximum
Inside
Human
Wild­
Agri
Aquatic
Aquatic
Mixing
Zone
Parameter
Units
Health
life
Supply
Life
Life
Maximum
Rocky
River
Ammonia
mg/
l
007
&
008
summer
­­
­­
­­
9.1
10.9
11.8
combined
winter
­­
­­
­­
59
10.4
10.4
(
interactive)
Ethylene
Glycol
mg/
l
B
B
B
536
1738
2600
Propylene
Glycol
mg/
l
B
B
B
245
843
1400
Abram
Creek
Ammonia
mg/
l
003
summer
­­
­­
­­
0.9
4.7
­­
winter
­­
­­
­­
3.0
4.5
­­

004,
005,
summer
­­
­­
­­
0.9
4.7
­­
006
&
009
winter
­­
­­
­­
2.3
4.5
­­
combined
(
interactive)
Ethylene
Glycol
mg/
l
4500
B
B
140
1300
NA
Propylene
Glycol
mg/
l
B
B
B
71
640
NA
Silver
Creek
Ammonia
mg/
l
001
&
002
summer
­­
­­
­­
1.0
9.1
­­
combined
winter
­­
­­
­­
0.6
2.7
­­
(
interactive)
Ethylene
Glycol
mg/
l
4500
B
B
140
1300
NA
Propylene
Glycol
mg/
l
B
B
B
71
640
NA
Cleveland­
Hopkins
Airport
Page
20
Table
5.
Final
effluent
limits
and
monitoring
requirements
for
Cleveland­
Hopkins
International
Airport
outfalls
3II00179001
and
3II00179002
and
the
basis
for
their
recommendation.

Effluent
Limits
Concentration
Loading
(
kg/
day)
a
30
Day
Daily
30
Day
Daily
Parameter
Units
Average
Maximum
Average
Maximum
Basisb
Flow
MGD
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Dissolved
Oxygen
mg/
l
5.0
4.0
(
min.)
B
B
WQS
CBOD5
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
COD
mg/
l
119
1075
B
B
WQSd
Dissolved
Solids
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Suspended
Solids
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Ammonia­
N
mg/
l
Summer
1.0
9.1
­­
­­
WQS
Winter
0.6
2.7
B
B
WQS
Oil
and
Grease
mg/
l
15
20
B
B
BPJ
pH
S.
U.
­
­
­
­
­
­
­
­
­
­
­
­
­
6.5
to
9.0
­
­
­
­
­
­
­
­
­
­
­
­
WQS
Benzene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Toluene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Ethylbenzene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Xylene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
1,2,4­
Trimethyl­
benzene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Naphthalene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Ethylene
Glycol
µ
g/
l
140,000
1,300,000
B
B
WQS
Propylene
Glycol
µ
g/
l
71,000
640,000
B
B
WQS
a
Effluent
loadings
based
on
average
design
discharge
flow
of
NA
MGD.

b
Definitions:
ABS
=
Antibacksliding
Rule
(
OAC
3745­
33­
05(
E)
and
40
CFR
Part
122.44(
l));
AD
=
Antidegradation
(
OAC
3745­
1­
05);
BPJ
=
Best
Professional
Judgment;
M
=
Monitoring;
WLA
=
Wasteload
Allocation
procedures
(
OAC
3745­
2);
WQS
=
Ohio
Water
Quality
Standards
(
OAC
3745­
1).

c
Monitoring
of
flow
and
other
indicator
parameters
is
specified
to
assist
in
the
evaluation
of
effluent
quality
and
treatment
plant
performance.

d
WQS
limits
for
COD
are
based
on
propylene
glycol
Tier
II
values
x
1.68
multiplier
from
CHIA
Master
Drainage
Plan,
1999.
Cleveland­
Hopkins
Airport
Page
21
Table
6.
Final
effluent
limits
and
monitoring
requirements
for
Cleveland­
Hopkins
International
Airport
outfalls
3II00179003,
3II00179005,
3II00179006
and
3II00179009
and
the
basis
for
their
recommendation.

Effluent
Limits
Concentration
Loading
(
kg/
day)
a
30
Day
Daily
30
Day
Daily
Parameter
Units
Average
Maximum
Average
Maximum
Basisb
Flow
MGD
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Dissolved
Oxygen
mg/
l
5.0
4.0
(
min.)
B
B
WQS
CBOD5
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
COD
mg/
l
119
1075
B
B
WQSe
Dissolved
Solids
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Suspended
Solids
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Ammonia­
N
mg/
l
Summer
0.9
4.7
­­
­­
WQS
Winter
3.0
4.5c
B
B
WQS,
WLA
Oil
and
Grease
mg/
l
15
20
B
B
BPJ
pH
S.
U.
­
­
­
­
­
­
­
­
­
­
­
­
­
6.5
to
9.0
­
­
­
­
­
­
­
­
­
­
­
­
WQS
Benzene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Md
Toluene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Md
Ethylbenzene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Md
Xylene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Md
1,2,4­
Trimethyl­
benzene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Md
Naphthalene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Md
Ethylene
Glycol
µ
g/
l
140,000
1,300,000
B
B
WQS
Propylene
Glycol
µ
g/
l
71,000
640,000
B
B
WQS
a
Effluent
loadings
based
on
average
design
discharge
flow
of
NA
MGD.

b
Definitions:
ABS
=
Antibacksliding
Rule
(
OAC
3745­
33­
05(
E)
and
40
CFR
Part
122.44(
l));
AD
=
Antidegradation
(
OAC
3745­
1­
05);
BPJ
=
Best
Professional
Judgment;
M
=
Monitoring;
WLA
=
Wasteload
Allocation
procedures
(
OAC
3745­
2);
WQS
=
Ohio
Water
Quality
Standards
(
OAC
3745­
1).
c
Limit
necessary
to
protect
water
quality
in
the
Rocky
River.

d
Monitoring
of
flow
and
other
indicator
parameters
is
specified
to
assist
in
the
evaluation
of
effluent
quality
and
treatment
plant
performance.

e
WQS
limits
for
COD
are
based
on
propylene
glycol
Tier
II
values
x
1.68
multiplier
from
CHIA
Master
Drainage
Plan,
1999.
Cleveland­
Hopkins
Airport
Page
22
Table
7.
Final
effluent
limits
and
monitoring
requirements
for
Cleveland­
Hopkins
International
Airport
outfall
3II00179004
and
the
basis
for
their
recommendation.

Effluent
Limits
Concentration
Loading
(
kg/
day)
a
30
Day
Daily
30
Day
Daily
Parameter
Units
Average
Maximum
Average
Maximum
Basisb
Flow
MGD
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Dissolved
Oxygen
mg/
l
5.0
4.0
(
min.)
B
B
WQS
CBOD5
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
COD
mg/
l
119
1075
B
B
WQSe
Dissolved
Solids
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Suspended
Solids
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Ammonia­
N
mg/
l
Summer
0.9
4.7
­­
­­
WQS
Winter
3.0
4.5c
B
B
WQS,
WLA
Oil
and
Grease
mg/
l
15
20
B
B
BPJ
pH
S.
U.
­
­
­
­
­
­
­
­
­
­
­
­
­
6.5
to
9.0
­
­
­
­
­
­
­
­
­
­
­
­
WQS
Ethylene
Glycol
µ
g/
l
140,000
1,300,000
B
B
WQS
Propylene
Glycol
µ
g/
l
71,000
640,000
B
B
WQS
a
Effluent
loadings
based
on
average
design
discharge
flow
of
NA
MGD.

b
Definitions:
ABS
=
Antibacksliding
Rule
(
OAC
3745­
33­
05(
E)
and
40
CFR
Part
122.44(
l));
AD
=
Antidegradation
(
OAC
3745­
1­
05);
BPJ
=
Best
Professional
Judgment;
M
=
Monitoring;
WLA
=
Wasteload
Allocation
procedures
(
OAC
3745­
2);
WQS
=
Ohio
Water
Quality
Standards
(
OAC
3745­
1).
c
Limit
necessary
to
protect
water
quality
in
the
Rocky
River.

d
Monitoring
of
flow
and
other
indicator
parameters
is
specified
to
assist
in
the
evaluation
of
effluent
quality
and
treatment
plant
performance.

e
WQS
limits
for
COD
are
based
on
propylene
glycol
Tier
II
values
x
1.68
multiplier
from
CHIA
Master
Drainage
Plan,
1999.
Cleveland­
Hopkins
Airport
Page
23
Table
8.
Final
effluent
limits
and
monitoring
requirements
for
Cleveland­
Hopkins
International
Airport
outfall
3II00179007
and
the
basis
for
their
recommendation.

Effluent
Limits
Concentration
Loading
(
kg/
day)
a
30
Day
Daily
30
Day
Daily
Parameter
Units
Average
Maximum
Average
Maximum
Basisb
Flow
MGD
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Dissolved
Oxygen
mg/
l
5.0
4.0
(
min.)
B
B
WQS
CBOD5
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
COD
mg/
l
412
1416
B
B
WLAd
Dissolved
Solids
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Suspended
Solids
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Ammonia­
N
mg/
l
Summer
9.1
10.9
B
B
WLA
Winter
B
10.4
B
B
WLA
Oil
and
Grease
mg/
l
15
20
B
B
BPJ
pH
S.
U.
­
­
­
­
­
­
­
­
­
­
­
­
­
6.5
to
9.0
­
­
­
­
­
­
­
­
­
­
­
­
WQS
Benzene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Toluene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Ethylbenzene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Xylene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
1,2,4­
Trimethyl­
benzene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Naphthalene
µ
g/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Ethylene
Glycol
µ
g/
l
536,000
1,738,000
B
B
WLA
Propylene
Glycol
µ
g/
l
245,000
843,000
B
B
WLA
a
Effluent
loadings
based
on
average
design
discharge
flow
of
NA
MGD.

b
Definitions:
ABS
=
Antibacksliding
Rule
(
OAC
3745­
33­
05(
E)
and
40
CFR
Part
122.44(
l));
AD
=
Antidegradation
(
OAC
3745­
1­
05);
BPJ
=
Best
Professional
Judgment;
M
=
Monitoring;
WLA
=
Wasteload
Allocation
procedures
(
OAC
3745­
2);
WQS
=
Ohio
Water
Quality
Standards
(
OAC
3745­
1).

c
Monitoring
of
flow
and
other
indicator
parameters
is
specified
to
assist
in
the
evaluation
of
effluent
quality
and
treatment
plant
performance.

d
Permit
limits
for
COD
are
based
on
WLA
derived
from
propylene
glycol
Tier
II
WQS
values
x
1.68
multiplier
from
CHIA
Master
Drainage
Plan,
1999.
Cleveland­
Hopkins
Airport
Page
24
Table
9.
Final
effluent
limits
and
monitoring
requirements
for
Cleveland­
Hopkins
International
Airport
outfall
3II00179008
and
the
basis
for
their
recommendation.

Effluent
Limits
Concentration
Loading
(
kg/
day)
a
30
Day
Daily
30
Day
Daily
Parameter
Units
Average
Maximum
Average
Maximum
Basisb
Flow
MGD
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Dissolved
Oxygen
mg/
l
5.0
4.0
(
min.)
B
B
WQS
CBOD5
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
COD
mg/
l
412
1416
B
B
WLAd
Dissolved
Solids
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Suspended
Solids
mg/
l
­
­
­
­
­
­
­
­
­
­
­
­
Monitor
­
­
­
­
­
­
­
­
­
­
­
­
­
­
­
Mc
Ammonia­
N
mg/
l
Summer
9.1
10.9
B
B
WLA
Winter
B
10.4
B
B
WLA
Oil
and
Grease
mg/
l
15
20
B
B
BPJ
pH
S.
U.
­
­
­
­
­
­
­
­
­
­
­
­
­
6.5
to
9.0
­
­
­
­
­
­
­
­
­
­
­
­
WQS
Ethylene
Glycol
µ
g/
l
536,000
1,738,000
B
B
WLA
Propylene
Glycol
µ
g/
l
245,000
843,000
B
B
WLA
a
Effluent
loadings
based
on
average
design
discharge
flow
of
NA
MGD.

b
Definitions:
ABS
=
Antibacksliding
Rule
(
OAC
3745­
33­
05(
E)
and
40
CFR
Part
122.44(
l));
AD
=
Antidegradation
(
OAC
3745­
1­
05);
BPJ
=
Best
Professional
Judgment;
M
=
Monitoring;
WLA
=
Wasteload
Allocation
procedures
(
OAC
3745­
2);
WQS
=
Ohio
Water
Quality
Standards
(
OAC
3745­
1).

c
Monitoring
of
flow
and
other
indicator
parameters
is
specified
to
assist
in
the
evaluation
of
effluent
quality
and
treatment
plant
performance.

d
Permit
limits
for
COD
are
based
on
WLA
derived
from
propylene
glycol
Tier
II
WQS
values
x
1.68
multiplier
from
CHIA
Master
Drainage
Plan,
1999.
Cleveland­
Hopkins
Airport
Page
25
Attachment
1
­
USGS
Flow
Gage
Data
Used
to
Establish
Upstream
Flows
Cleveland­
Hopkins
Airport
Page
26
Attachment
2
­
Wasteload
Allocation
Tables
Cleveland­
Hopkins
Airport
Page
27
Attachment
3
­
COD/
Glycol
Correlation
from
CHIA
Master
Drainage
Plan
