Permit
No.
IN
0058238
Page
1
Briefing
Memo
August
1997
OWNER
FACILITY
MANAGER
Indianapolis
Airport
Authority
BAA
Indianapolis
LLC
Indianapolis
International
Airport
Box
100
2500
South
High
School
Road
2500
South
High
School
Road
Indianapolis,
IN
46241
Indianapolis,
IN
46241
NPDES
Permit
No.
IN
0058238
Introduction
The
Indianapolis
Airport
Authority
owns
and
has
primary
responsibility
for
the
management
of
the
Indianapolis
International
Airport
at
2500
South
High
School
Road
in
southwestern
Marion
County.
In
October
1995,
BAA
Indianapolis
LLC
was
subcontracted
to
manage
the
facility
on
behalf
of
the
Indianapolis
Airport
Authority
for
a
period
of
ten
(
10)
years.
In
accordance
with
327
IAC
5­
2­
3(
c),
the
owner
of
a
facility
is
responsible
for
applying
for
and
obtaining
a
NPDES
permit,
except
where
the
facility
is
operated
by
a
person
other
than
an
employee
of
the
owner
in
which
case
it
is
the
operator's
duty
to
apply
for
and
obtain
a
NPDES
permit.

BAA
Indianapolis
LLC
and
the
Indianapolis
Airport
Authority
are
applying
for
a
NPDES
permit
to
discharge
storm
water
runoff
from
the
airport.
The
airport
has
several
outfalls
of
storm
water
runoff
associated
with
industrial
activity.
The
airport
was
previously
discharging
the
storm
water
runoff
from
the
Mars
Ditch
and
Seerley
Creek
basins
in
accordance
with
an
Agreed
Order
issued
by
the
Office
of
Enforcement
in
May
of
1995.
Since
the
Agreed
Order
expired
in
May
of
1997,
the
Industrial
NPDES
Permits
Section
will
issue
a
NPDES
for
authorization
to
discharge
the
storm
water
runoff
from
the
airport
prior
to
the
1997­
1998
deicing/
anti­
icing
season.

A
five
year
permit
is
proposed.

Facility
Description
The
Indianapolis
International
Airport
is
a
public
transportation
airport
which
consists
of
approximately
5127
acres.
The
airport
leases
space
and
services
to
airline
companies
and
other
parties
which
provide
support
services.
The
Indianapolis
International
Airport
also
provides
facilities
for
general
aviation.

A
map
showing
the
location
of
the
Indianapolis
International
Airport
is
appended
as
Attachment
I.
Permit
No.
IN
0058238
Page
2
Wastewater
Sources
and
Treatment
Propylene
glycol
(
PG)
based
aircraft
deicing/
anti­
icing
fluids
are
used
at
the
airport.
Potassium
acetate
and
sodium
formate
based
deicers
are
used
to
deice
ramps
and
runways
at
the
airport.
The
deicing/
anti­
icing
chemicals
are
necessary
and
required
for
aircraft
safety
and
are
used
in
the
winter
season
during
the
months
of
November
through
April.
According
to
BAA
Indianapolis
LLC,
246,538
gallons
of
PG
based
aircraft
deicing/
anti­
icing
fluids
were
used
during
the
1996­
1997
deicing/
anti­
icing
season.

The
deicing/
anti­
icing
chemicals
have
the
potential
to
contaminate
runoff
from
the
airport.
In
addition
to
the
deicing/
anti­
icing
chemicals,
runoff
from
the
airport
has
the
potential
to
be
contaminated
by
aviation
fuel,
hydraulic
fluids,
and
lubrication
products
that
are
stored
and
used
at
the
facility.

The
airport
has
two
surface
impoundments
which
collect
contaminated
runoff
and
have
the
potential
to
discharge
to
a
surface
water.
The
basins
are
referred
to
as
the
Mars
Ditch
basin
and
the
Seerley
Creek
basin.
In
an
effort
to
reduce
the
contaminated
runoff
from
the
airport
to
the
basins,
deicing/
anti­
icing
chemicals
are
collected
and
recycled
when
possible.
The
chemicals
that
are
not
collected
drain
into
the
basins.
The
runoff
held
in
the
basins
may
be
either
pumped
to
the
City
of
Indianapolis
sewer
system
or
directly
discharged
to
Seerley
Creek
or
Mars
Ditch.

The
Mars
Ditch
basin
receives
runoff
from
a
140
acre
area
and
has
the
capacity
to
hold
nine
(
9)
million
gallons
of
runoff.
The
Seerley
Creek
basin
receives
runoff
from
a
623
acre
area
and
has
the
capacity
to
hold
twenty­
two
(
22)
million
gallons
of
runoff.
Both
impoundments
are
equipped
with
aerators.
The
basins
are
designed
with
the
discharge
originating
from
the
bottom
of
the
basin.
Standing
water
creates
an
attraction
for
birds
and
is
considered
a
hazard
to
aircraft.
Therefore,
these
two
basins
have
been
designed
so
they
can
be
drained
from
the
bottom
to
minimize
standing
water
near
the
airport.

The
basins
meet
the
definition
of
water
pollution
treatment/
control
facility
in
327
IAC
5­
1­
2(
64).
Therefore,
the
wastewater
treatment
system
has
been
given
a
Class
A­
SO
industrial
wastewater
treatment
plant
classification.

The
Midfield
basin
is
used
for
the
collection
of
glycol
contaminated
runoff
from
the
Midfield
spray
down
area
and
is
also
used
to
deposit
other
glycol
containing
runoff
collected
by
vacuum
trucks
throughout
the
facility.
The
runoff
is
pumped
to
the
City
of
Indianapolis
or
is
land
applied
on­
site
pursuant
to
Land
Application
Permit
No.
INLA000532.
This
basin
does
not
discharge
during
the
deicing/
anti­
icing
season.
When
all
of
the
runoff
has
been
processed,
a
bottom
drain
is
opened
and
summer
storm
water
may
be
allowed
to
discharge.
Permit
No.
IN
0058238
Page
3
The
airport
has
several
additional
discharges
of
runoff
that
have
the
potential
to
be
contaminated
by
deicing/
anti­
icing
chemicals,
fuels,
hydraulic
fluids
and
lubrication
products.
However,
these
outfalls
are
not
collected
prior
to
discharge.

Receiving
Streams
The
drainage
from
Drexel
Run,
Mars
Ditch,
Davis
Creek
and
Seerley
Creek
is
considered
the
headwaters
for
their
respective
watersheds.
These
discharges
are
to
zero
flow
(
0.0
cfs)
streams
and
do
not
provide
any
dilution
with
respect
to
effluent
limitations.
They
ultimately
drain
to
the
White
River
in
Marion
County.

The
drainage
from
Center
Creek,
North
Collector
Channel,
North
Taxiway
Channel,
Sterling
Run
Channel,
and
U.
S.
40
West
is
to
the
East
Fork
of
White
Lick
Creek
in
Hendricks
County.
The
Q7,10
low
flow
for
the
East
Fork
of
White
Lick
Creek
is
0.56
cfs.
All
of
the
receiving
streams
are
covered
under
327
IAC
2­
1,
and
are
classified
for
general
use
and
should
be
able
to
support
a
warm
water
aquatic
community.

A
map
showing
the
location
of
the
storm
water
outfalls
at
the
Indianapolis
International
Airport
is
appended
as
Attachment
II.

Effluent
Limitations
Rationale
Pursuant
to
the
Clean
Water
Act
(
CWA),
the
U.
S.
Environmental
Protection
Agency
(
EPA),
or
an
EPA­
approved
State,
is
authorized
to
issue
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permits
for
the
discharge
of
"
pollutants"
from
any
"
point
source"
into
"
waters
of
the
United
States."
CWA
301(
b)
requires
all
point
sources
that
discharge
directly
to
the
waters
of
the
U.
S.
to
meet
technology­
based
effluent
limitations
and
State
water
quality
standards
for
the
discharge
of
pollutants.

EPA
has
determined
technology­
based
effluent
limitations
through
the
development
of
national
effluent
limitations
guidelines
for
many
specific
categories
of
industries.
However,
effluent
guidelines
have
not
been
promulgated
for
wastewater
discharges
resulting
from
aircraft
transportation
and
related
activities.
In
instances
where
the
EPA
has
not
promulgated
effluent
limitations
for
a
particular
industry,
the
permit
writer
shall
use
best
professional
judgement
(
BPJ)
to
develop
limits
based
on
technology­
based
treatment
requirements.
327
IAC
5­
5­
2(
b)(
2)
states
that
technology­
based
treatment
requirements
may
be
imposed
on
a
case­
by­
case
basis
under
section
402(
a)(
1)
of
the
CWA,
to
the
extent
that
EPA­
promulgated
effluent
limitations
are
unavailable.
Consequently,
the
effluent
limits
are
based
upon
Indiana
Water
Quality
Standards
and
the
permit
writer's
BPJ.
Permit
No.
IN
0058238
Page
4
Effluent
limitations
for
the
Mars
Ditch
and
Seerley
Creek
Basin
Outfalls
are
based
on
current
aircraft
deicing/
anti­
icing
and
pavement
deicing
practices
occurring
throughout
the
Mars
Ditch
and
Seerley
Creek
watersheds.
Current
aircraft
deicing/
anti­
icing
practices
allow
the
deicing/
antiicing
fluids
to
drip
onto
the
pavement
after
application.
The
specific
chemicals
considered
in
the
limitations
are
propylene
glycol
based
aircraft
deicing/
anti­
icing
fluids
and
potassium
acetate
and
sodium
formate
based
pavement
deicers.

1.
During
the
period
beginning
on
the
effective
date
of
this
permit
and
lasting
until
the
expiration
date,
the
permittee
is
authorized
to
discharge
from:
Outfall
002
Mars
Ditch
Outfall
004
Seerley
Creek
Such
discharge
shall
be
limited
and
monitored
by
the
permittee
as
specified
below:

Discharge
Limitations
[
1][
2]

Quantity
or
Loading
Quality
or
Concentration
Monitoring
Requirements
Monthly
Daily
Monthly
Daily
Measurement
Sample
Parameter
Average
Maximum
Units
Average
Maximum
Units
Frequency
Type
Flow
Report
Report
MGD
­­­­­
­­­­­
­­­­­
[
3]
24­
Hr
Total
Ammonia
(
as
N)[
4]
­­­­­
­­­­­
­­­­­
­­­­­
4.4
mg/
l
[
3]
Composite[
5]
Propylene
Glycol[
4]
­­­­­
­­­­­
­­­­­
­­­­­
200
mg/
l
[
3]
Composite
Potassium
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
3]
Composite
Sodium
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
3]
Composite
TSS
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
3]
Composite
Oil
&
Grease
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
3]
Grab[
6]
T.
Cyanide
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
3]
Grab[
7]
Forecasted
Air
Temperature
­­­­­
­­­­­
­­­­­
Report
oF
[
3]
[
8]
Actual
Air
Temperature
­­­­­
­­­­­
­­­­­
­­­­­
Report
oF
[
3]
[
9]

Forecasted
Air
temperature
of
45
oF
and
below:
CBOD5[
4]
­­­­­
­­­­­
­­­­­
­­­­­
325
mg/
l
[
3]
Composite
COD
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
3]
Composite
Forecasted
Air
temperature
from
above
45
oF
to
55
oF:
CBOD5
­­­­­
­­­­­
­­­­­
­­­­­
100
mg/
l
[
3]
Composite
COD
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
3]
Composite
Forecasted
Air
temperature
above
55
oF:
CBOD5
­­­­­
­­­­­
­­­­­
­­­­­
40
mg/
l
[
3]
Composite
COD
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
3]
Composite
Permit
No.
IN
0058238
Page
5
Quality
or
Concentration
Monitoring
Requirements
Daily
Daily
Measurement
Sample
Parameter
Minimum
Maximum
Units
Frequency
Type
Dissolved
Oxygen
Report
Report
mg/
l
[
3]
Grab[
10]

[
1]
Development
and
implementation
of
a
Storm
Water
Pollution
Prevention
Plan
as
described
in
Part
I.
C.
of
this
permit.

[
2]
The
discharge
limitations
are
based
on
the
specific
types
of
deicing/
anti­
icing
practices
currently
being
conducted
and
chemicals
currently
being
used
in
the
respective
watersheds.
In
the
event
that
deicing/
anti­
icing
activities
change
or
additional
or
alternative
chemicals
are
used,
the
permittee
shall
notify
the
Indiana
Department
of
Environmental
Management
as
required
by
Part
II.
C.
1.
of
this
permit.

[
3]
Samples
will
be
taken
during
every
discharge
beginning
with
the
first
application
of
chemicals
during
the
deicing/
anti­
icing
season
in
the
respective
watershed.
Upon
completion
of
deicing/
anti­
icing
for
the
season
in
the
respective
watershed,
sampling
may
be
discontinued
after
the
propylene
glycol
concentration
is
reported
as
nondetectable.

[
4]
Refer
to
the
Schedule
of
Compliance
described
in
Part
I.
D.
of
this
permit.

[
5]
Composite
samples
will
consist
of
flow­
weighted
samples
taken
at
a
maximum
interval
of
one
(
1)
hour
during
the
first
four
(
4)
hours
of
the
discharge.
The
first
sample
shall
be
taken
within
the
first
thirty
(
30)
minutes,
or
as
soon
thereafter
as
practicable,
of
the
discharge.

[
6]
The
grab
sample
shall
be
taken
within
the
first
thirty
(
30)
minutes,
or
as
soon
thereafter
as
practicable,
of
the
discharge.

[
7]
Cyanide
shall
be
measured
and
reported
as
Total
Cyanide.
The
maximum
holding
time
for
cyanide
(
CN)
is
24
hours
when
sulfide
is
present
and
14
days
when
sulfide
is
absent,
according
to
40
CFR
136.3,
Table
II.
Therefore,
CN
is
to
be
monitored
by
collecting
a
representative
grab
sample
and
analyzing
it
within
24
hours.
Alternatively,
if
the
permittee
can
demonstrate
the
wastewater
contains
no
sulfide,
the
permittee
may
collect
a
composite
sample
and
analyze
it
within
14
days.
Permit
No.
IN
0058238
Page
6
[
8]
The
forecasted
air
temperatures
reported
will
be
the
forecasted
maximum
air
temperature
during
the
time
period
beginning
with
the
onset
of
the
discharge
and
ending
thirty­
six
(
36)
hours
after
the
onset
of
the
discharge.
Forecasted
air
temperature
will
be
obtained
from
the
National
Weather
Service
located
at
the
Indianapolis
International
Airport.

[
9]
The
air
temperatures
reported
will
be
the
maximum
air
temperature
during
the
time
period
beginning
with
the
onset
of
the
discharge
and
ending
thirty­
six
(
36)
hours
after
the
onset
of
the
discharge.
Air
temperature
will
be
obtained
from
the
National
Weather
Service
located
at
the
Indianapolis
International
Airport.

[
10]
A
grab
sample
shall
be
taken
at
the
beginning
and
end
of
the
composite
sampling
period.

Ammonia
(
as
N)

The
daily
maximum
limit
is
twice
the
chronic
aquatic
criterion
at
a
pH
of
7.7
s.
u.
and
a
temperature
of
10
oC.
No
dilution
was
given
in
the
development
of
the
limit.
Only
a
daily
maximum
limit
is
given
due
to
the
intermittent
nature
of
the
discharge.
Ammonia
(
as
N)
will
be
limited
based
on
its
past
use
as
a
pavement
deicer,
UREA,
and
on
monitoring
data
collected
during
the
1996­
1997
deicing/
anti­
icing
season
which
showed
that
there
is
reasonable
potential
to
exceed
water
quality
standards.

Propylene
Glycol
The
limit
for
propylene
glycol
was
developed
from
a
toxicity
test
of
Seerley
Creek
basin
water
spiked
with
a
solution
containing
88%
Type
I
propylene
glycol
based
aircraft
deicing
fluid
and
12%
Type
II
propylene
glycol
based
aircraft
anti­
icing
fluid.
The
percentages
of
deicer
and
antiicer
are
based
on
usage
during
a
heavy
snow
event
in
January
1997.
The
concentration
of
propylene
glycol
in
the
mixed
test
solution
was
410
mg/
l
and
the
resulting
no
observed
effect
concentration
(
NOEC)
was
50%
with
fathead
minnow
as
the
sensitive
species.
The
96
hour
LC10
(
lethal
concentration
for
10%
of
the
test
species)
for
fathead
minnow
was
less
than
100%,
but
greater
than
50%.
The
test
was
done
to
ensure
that
aquatic
life
are
protected
from
the
effects
of
whole
effluent
toxicity.
The
influence
of
the
additives
is
apparent
when
the
test
results
are
compared
to
a
chronic
aquatic
criterion
(
CAC)
of
1,405
mg/
l
and
an
acute
aquatic
criterion
(
AAC)
of
1,834
mg/
l
for
pure
propylene
glycol.
Permit
No.
IN
0058238
Page
7
The
daily
maximum
value
for
propylene
glycol
will
protect
aquatic
life
from
both
the
acute
and
chronic
effects
of
the
formulated
deicer
and
anti­
icer.
No
dilution
was
given
in
the
development
of
the
limit.
Only
a
daily
maximum
limit
is
given
due
to
the
intermittent
nature
of
the
discharge.
The
parameter
will
be
limited
based
its
use
as
an
aircraft
deicer/
anti­
icer
and
on
monitoring
data
collected
during
the
1996­
1997
deicing/
anti­
icing
season
that
showed
there
is
reasonable
potential
to
exceed
water
quality
standards.

Total
Suspended
Solids
(
TSS)

This
parameter
is
required
to
be
reported
based
on
monitoring
data
collected
during
the
1996­
1997
deicing/
anti­
icing
season
that
showed
its
presence
in
discharges.
The
reporting
requirement
will
allow
further
data
to
be
gathered
to
determine
if
there
is
reasonable
potential
to
exceed
water
quality
standards.

The
Mars
Ditch
and
Seerley
Creek
basins
are
designed
with
the
discharge
originating
from
the
bottom
of
the
basin.
Most
basins
are
designed
with
the
discharge
point
located
near
the
top
of
the
basin.
This
allows
the
suspended
solids
to
settle
with
time
and
will
reduce
the
discharge
of
suspended
solids.
However,
the
bottom
drains
that
are
used
to
empty
the
basins
will
also
contribute
to
the
suspended
solids
being
discharged
into
the
respective
receiving
streams.

Potassium
and
Sodium
These
parameters
are
required
to
be
reported
based
on
their
use
in
pavement
deicers
and
the
need
to
determine
the
amount
of
pavement
deicers
being
discharged.
The
reporting
requirement
will
allow
further
data
to
be
gathered
to
determine
if
there
is
reasonable
potential
to
exceed
water
quality
standards.

Oil
and
Grease
This
parameter
is
required
to
be
reported
based
on
the
potential
for
the
runoff
from
the
airport
to
be
contaminated
by
fuels,
hydraulic
fluids,
and
lubrication
products.
The
reporting
requirement
will
allow
further
data
to
be
gathered
to
determine
if
there
is
reasonable
potential
to
exceed
water
quality
standards.

Total
Cyanide
Mars
Ditch
and
State
Ditch
are
included
on
the
1996
303(
d)
list
for
water
quality
standards
violations
due
to
cyanide.
The
reporting
requirements
will
allow
for
further
data
to
be
gathered
to
determine
the
source
of
cyanide
and
determine
if
there
is
reasonable
potential
to
exceed
water
quality
standards.
Permit
No.
IN
0058238
Page
8
Dissolved
Oxygen
This
parameter
will
be
limited
based
on
the
need
to
maintain
a
minimum
daily
average
dissolved
oxygen
concentration
in
the
stream
of
5.0
mg/
l.
The
value
was
determined
from
stream
dissolved
oxygen
modeling.

Air
Temperature
This
parameter
will
be
reported
in
conjunction
with
CBOD5.
Air
temperature
was
chosen,
as
opposed
to
basin
water
temperature,
based
on
data
that
showed
the
water
temperature
in
State
Ditch
near
its
confluence
with
White
River
approached
the
air
temperature
after
discharge.
Should
a
site­
specific
study
determine
that
using
basin
water
temperature
instead
of
air
temperature
is
a
more
effective
means
of
controlling
the
discharge
of
CBOD5
and
its
impact
in
State
Ditch,
basin
water
temperature
may
be
reported
in
accordance
with
the
reopening
clause
found
in
Part
I.
E.
of
the
permit.

CBOD5
Temperature
dependent
limits
for
CBOD5
were
derived
from
a
combination
of
best
professional
judgment
and
stream
dissolved
oxygen
(
DO)
modeling
using
the
USEPA
Simplified
Method
with
site­
specific
stream
hydraulic
and
CBOD
decay
data.
The
CBOD
decay
rate
of
Seerley
Creek
basin
water
spiked
with
aircraft
deicing/
anti­
icing
fluids
was
measured
in
the
lab
at
temperatures
from
45
to
60

F.
The
decay
rate
of
potassium
acetate
based
pavement
deicer
at
68

F
was
obtained
from
its
manufacturer.
Using
the
site­
specific
data,
CBOD5
loadings
that
maintain
the
instream
DO
standard
in
Mars
Ditch,
Seerley
Creek,
State
Ditch
and
the
White
River
were
calculated
for
different
temperatures.
The
DO
modeling
showed
that
the
limiting
stream
segments
were
State
Ditch
near
its
confluence
with
the
White
River
and
the
White
River.
The
use
of
temperature
dependent
limits
will
allow
for
higher
loadings
when
deicer/
anti­
icer
usage
is
typically
heavy.
Only
daily
maximum
limits
are
given
due
to
the
intermittent
nature
of
the
discharge.
This
parameter
will
be
limited
based
on
monitoring
data
collected
during
the
1996­
1997
deicing/
antiicing
season
that
showed
there
is
reasonable
potential
to
exceed
water
quality
standards.

COD
Currently
this
parameter
is
limited
on
a
report
only
basis.
However,
should
further
study
determine
that
COD
is
a
more
effective
means
of
controlling
the
discharge,
COD
may
be
limited
in
place
of
CBOD5
in
accordance
with
the
reopening
clause
found
in
Part
I.
E.
of
the
permit.
Permit
No.
IN
0058238
Page
9
Effluent
limitations
for
the
following
outfalls
are
based
on
pavement
deicing
occurring
throughout
the
watersheds
of
all
five
outfalls,
aircraft
deicing/
anti­
icing
fluids
being
sheared
from
aircraft
in
the
Center
Creek,
North
Collector
Channel,
North
Taxiway
Channel
and
Sterling
Run
Channel
outfall
watersheds
and
only
propylene
glycol
based
aircraft
deicing/
anti­
icing
fluids
and
potassium
acetate
and
sodium
formate
based
pavement
deicers
being
used.

2.
During
the
period
beginning
on
the
effective
date
of
this
permit
and
lasting
until
the
expiration
date,
the
permittee
is
authorized
to
discharge
from:
Outfall
003
Davis
Creek
Outfall
005
Center
Creek
Outfall
006A
North
Collector
Channel
Outfall
006B
North
Taxiway
Channel
Outfall
007
Sterling
Run
Channel
Such
discharge
shall
be
monitored
by
the
permittee
as
specified
below:

Discharge
Limitations[
1]

Quantity
or
Loading
Quality
or
Concentration
Monitoring
Requirements
Monthly
Daily
Monthly
Daily
Measurement
Sample
Parameter
Average
Maximum
Units
Average
Maximum
Units
Frequency
Type
Flow
Report
Report
MGD
­­­­­
­­­­­
­­­­­
[
2]
[
3]
CBOD5
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
2]
Composite[
4]
COD
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
2]
Composite
Ammonia
(
as
N)
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
2]
Composite
Propylene
Glycol
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
2]
Composite
Potassium[
5]
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
2]
Composite
Sodium[
6]
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
2]
Composite
TSS
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
2]
Composite
Oil
&
Grease
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
2]
Grab[
7]

[
1]
The
discharge
limitations
are
based
on
the
specific
types
of
deicing/
anti­
icing
practices
currently
being
conducted
and
chemicals
currently
being
used
in
the
respective
watersheds.
In
the
event
that
deicing/
anti­
icing
activities
change
or
additional
or
alternative
chemicals
are
used,
the
permittee
shall
notify
the
Indiana
Department
of
Environmental
Management
as
required
by
Part
II.
C.
1.
of
this
permit.

[
2]
Sampling
will
begin
after
the
first
application
of
pavement
deicers
during
the
deicing/
anti­
icing
season
in
the
respective
watershed.
Samples
will
be
required
during
rain
events
of
0.1
inch
or
greater
following
each
application
of
pavement
deicer
up
to
a
maximum
of
two
(
2)
rain
events
per
month.
Sampling
may
be
suspended
after
the
last
pavement
deicer
application
and
qualifying
rain
event
of
the
deicing/
anti­
icing
season.
Permit
No.
IN
0058238
Page
10
[
3]
Flow
will
be
measured
each
hour
during
the
composite
sampling
period
and
be
reported
as
the
average
of
the
measured
values.

[
4]
Composite
samples
will
consist
of
flow­
weighted
samples
taken
at
a
maximum
interval
of
one
(
1)
hour
during
the
first
one
and
one­
half
(
1.5)
hours
of
the
discharge
for
the
Davis
Creek
and
Center
Creek
outfalls
and
the
first
three
(
3)
hours
for
the
North
Collector
Channel,
North
Taxiway
Channel
and
Sterling
Run
Channel
outfalls.
The
first
sample
shall
be
taken
within
the
first
thirty
(
30)
minutes,
or
as
soon
thereafter
as
practicable,
of
the
discharge.

[
5]
Sample
only
when
potassium
acetate
based
pavement
deicer
is
used
in
the
outfall's
watershed.

[
6]
Sample
only
when
sodium
formate
based
pavement
deicer
is
used
in
the
outfall's
watershed.

[
7]
The
grab
sample
shall
be
taken
within
the
first
thirty
(
30)
minutes,
or
as
soon
thereafter
as
practicable,
of
the
discharge.

Ammonia­
N,
Propylene
Glycol,
CBOD5,
COD
and
TSS
These
parameters
are
required
to
be
reported
based
on
monitoring
data
collected
during
the
1996­
1997
deicing/
anti­
icing
season
that
showed
their
presence
in
discharges.
The
reporting
requirement
will
allow
further
data
to
be
gathered
to
determine
if
there
is
reasonable
potential
to
exceed
water
quality
standards.

Potassium
and
Sodium
These
parameters
are
required
to
be
reported
based
on
their
use
in
pavement
deicers
and
the
need
to
determine
the
amount
of
pavement
deicer
being
discharged.
The
reporting
requirement
will
allow
further
data
to
be
gathered
to
determine
if
there
is
reasonable
potential
to
exceed
water
quality
standards.
Permit
No.
IN
0058238
Page
11
Effluent
limitations
for
the
following
outfalls
from
the
Postal
Hub
deicing
pad
storm
water
catch
basins
are
based
on
aircraft
deicing/
anti­
icing
fluids
dripping
onto
the
pavement
after
application.
The
specific
chemicals
considered
in
the
limitations
are
propylene
glycol
based
aircraft
deicing/
anti­
icing
fluids.

3.
During
the
period
beginning
on
the
effective
date
of
this
permit
and
lasting
until
the
expiration
date,
the
permittee
is
authorized
to
discharge
from:
Postal
Hub
Outfall
601,
602,
603,
604
North
Taxiway
Channel
Postal
Hub
Outfall
701,
702,
703
Sterling
Run
Channel
Such
discharge
shall
be
monitored
by
the
permittee
as
specified
below:

Discharge
Limitations[
1]

Quantity
or
Loading
Quality
or
Concentration
Monitoring
Requirements
Monthly
Daily
Monthly
Daily
Measurement
Sample
Parameter
Average
Maximum
Units
Average
Maximum
Units
Frequency
Type
Flow
Report
Report
MGD
­­­­­
­­­­­
­­­­­
[
2]
[
3]
Propylene
Glycol
­­­­­
­­­­­
­­­­­
­­­­­
Report
mg/
l
[
2]
Composite[
4]

[
1]
The
discharge
limitations
are
based
on
the
specific
types
of
deicing/
anti­
icing
practices
currently
being
conducted
and
chemicals
currently
being
used
in
the
respective
watersheds.
In
the
event
that
deicing/
anti­
icing
activities
change
or
additional
or
alternative
chemicals
are
used,
the
permittee
shall
notify
the
Indiana
Department
of
Environmental
Management
as
required
by
Part
II.
C.
1.
of
this
permit.

[
2]
Samples
will
be
taken
during
every
discharge
that
causes
measurable
flow
in
the
channel
beginning
with
the
first
application
of
chemicals
during
the
deicing/
antiicing
season
at
the
Postal
Hub
deicing
pad.
Once
the
propylene
glycol
concentration
in
the
discharge
is
reported
as
nondetectable,
sampling
may
be
suspended
until
the
next
use
of
aircraft
deicing/
anti­
icing
fluids.

[
3]
Flow
in
the
channel
attributable
to
the
Postal
Hub
deicing
pad
will
be
measured
each
hour
during
the
composite
sampling
period
and
be
reported
as
the
average
of
the
measured
values.

[
4]
Composite
samples
for
each
channel
will
consist
of
flow­
weighted
samples
taken
at
each
channel
outfall
at
a
maximum
interval
of
one
(
1)
hour
during
the
first
one
and
one­
half
(
1.5)
hours
of
the
discharge.
The
first
sample
shall
be
taken
within
the
first
thirty
(
30)
minutes,
or
as
soon
thereafter
as
practicable,
of
the
discharge.
Only
one
composite
sample
per
channel
is
required.
Permit
No.
IN
0058238
Page
12
Propylene
Glycol
This
parameter
is
required
to
be
reported
based
on
the
need
to
gather
data
to
determine
if
there
is
reasonable
potential
to
exceed
water
quality
standards.
Permit
No.
IN
0058238
Page
13
The
following
outfalls
have
been
identified
as
consisting
of
storm
water
run­
off
associated
with
industrial
activity.
There
is
a
low
potential
for
contamination
in
the
storm
water
from
these
outfalls.
Therefore,
they
will
be
monitored
for
two
years
with
the
possibility
of
being
removed
after
the
sampling
period.

4.
During
the
period
beginning
on
the
effective
date
of
this
permit
and
lasting
until
the
expiration
date,
the
permittee
is
authorized
to
discharge
from:
Outfall
001
Drexel
Run
Outfall
009
U.
S.
40
West
Such
discharge
shall
be
monitored
by
the
permittee
as
specified
below:

Discharge
Limitations
Quality
or
Concentration
Monitoring
Requirements
Maximum
Average
Measurement
Sample
Parameter
Grab
Composite
Units
Frequency
Type
Flow
Report
Report
MGD
Annually[
1]
24­
Hr.
Total
Oil
&
Grease
Report
­­­­­
mg/
l
Annually
Grab
CBOD5
Report
Report
mg/
l
Annually
Grab
&
Composite
COD
Report
Report
mg/
l
Annually
Grab
&
Composite
Total
Suspended
Solids
Report
Report
mg/
l
Annually
Grab
&
Composite
Total
Kjeldahl
Nitrogen
Report
Report
mg/
l
Annually
Grab
&
Composite
Nitrate
plus
Nitrite
Nitrogen
Report
Report
mg/
l
Annually
Grab
&
Composite
Total
Phosphorus
Report
Report
mg/
l
Annually
Grab
&
Composite
pH
Report
­­­­­
s.
u.
Annually
Grab
[
1]
The
above
listed
parameters
are
to
be
monitored
to
determine
whether
or
not
they
are
present
in
significant
quantities.
At
the
end
of
a
two
(
2)
year
sampling
period,
the
permittee
may
request,
in
writing,
a
review
of
these
requirements.
Upon
review
by
the
IDEM,
the
permit
may
be
modified,
after
public
notice
and
opportunity
for
hearing,
to
delete
the
monitoring
requirements.
Permit
No.
IN
0058238
Page
14
5.
Special
Reporting
[
1]
The
permittee
shall
submit
a
monthly
report
to
the
Indiana
Department
of
Environmental
Management
during
the
deicing/
anti­
icing
season
which
contains
the
following:

a.
The
date
and
time
composite
samples
were
initiated
and
the
total
rainfall
during
the
composite
sampling
period
for
the
composite
samples
required
in
Part
I.
A.
2.

b.
The
date
and
time
the
composite
samples
required
in
Part
I.
A.
3.
were
initiated.
Indicate
the
reason
for
the
discharge
from
the
Postal
Hub
outfalls
(
e.
g.
rainfall
or
snowmelt).

c.
Reported
climatological
data
from
the
National
Weather
Service
station
at
the
Indianapolis
International
Airport.

d.
The
approximate
total
weight
or
volume
of
each
type
of
pavement
deicer
used
in
each
watershed.

e.
The
approximate
total
volume
of
aircraft
deicer
and
anti­
icer
used
in
each
watershed.

f.
Date
and
location
of
remote
areas
used
for
aircraft
deicing/
anti­
icing.
Example:
P
pad
area,
J
pad
area,
D­
9
deice
area,
and
A­
12
deice
area.

g.
Location
of
snow
containing
propylene
glycol
that
is
moved
outside
of
the
Mars
Ditch,
Seerley
Creek,
and
Postal
Hub
deicing
pad
watershed
areas.

The
monthly
report
shall
be
submitted
to
the
IDEM
along
with
the
discharge
monitoring
report.
Permit
No.
IN
0058238
Page
15
Storm
Water
Pollution
Prevention
Plan
The
Indianapolis
International
Airport
operates
under
the
Standard
Industrial
Classification
(
SIC)
code
4581.
According
to
40
CFR
122.26(
b)(
14)(
viii),
transportation
facilities
classified
as
SIC
45
which
have
vehicle
maintenance
shops,
equipment
cleaning
operations,
or
airport
deicing
operations
are
considered
to
be
engaging
in
"
industrial
activity"
for
purposes
of
40
CFR
122.26(
b).
Therefore,
the
Indianapolis
International
Airport
is
required
to
have
all
storm
water
discharges
associated
with
industrial
activity
permitted.
Treatment
for
storm
water
discharges
associated
with
industrial
activity
are
required
to
meet,
at
a
minimum,
BAT/
BCT
requirements.
Development
and
implementation
of
a
Storm
Water
Pollution
Prevention
Plan
(
SWPPP)
is
required
to
meet
BAT/
BCT.

The
SWPPP
shall
identify
potential
sources
of
pollution
which
may
reasonably
be
expected
to
affect
the
quality
of
storm
water
discharges
associated
with
industrial
activity
from
the
facility.
In
addition,
the
SWPPP
shall
describe
and
ensure
the
implementation
of
practices
that
are
to
be
used
to
reduce
the
pollutants
in
storm
water
discharges
associated
with
industrial
activity
and
to
assure
compliance
with
the
terms
and
conditions
of
this
permit.

Schedule
of
Compliance
327
IAC
5­
2­
12
states
that
where
appropriate,
a
permit
shall
contain
a
schedule
of
compliance
requiring
the
permittee
to
take
specific
steps
to
achieve
expeditious
compliance
with
applicable
standards,
limitations,
and
other
requirements.
Therefore,
the
permittee
will
be
given
a
three
(
3)
year
schedule
of
compliance
to
meet
effluent
limitations
for
Ammonia
(
as
N),
Propylene
Glycol,
and
CBOD5.

Other
Considerations
A
fire
training
facility
is
located
off
of
Hanna
Avenue
south
of
I­
70
and
is
property
of
the
Indianapolis
Airport
Authority.
The
facility
has
a
burn
pit
with
a
synthetic
liner
and
an
oil
water
separator.
Fuel
oils
are
used
as
an
ignition
source
and
water
and
fire
suppressant
chemicals
are
used
for
fire
training.
All
water
and
chemicals
generated
as
a
result
of
the
fire
training
are
recycled
or
are
taken
off­
site
for
disposal.
Storm
water
from
other
areas
of
the
property
flow
into
Pound
Creek
and
then
into
the
North
Collector
Channel.

Prepared
by:
Christina
Lowry,
August
1997
Attachment
I
Attachment
II
Permit
No.
IN
0058238
Page
18
Post
Public
Notice
Addendum
­
November
1997
The
following
is
a
summary
of
the
comments
that
were
received
regarding
the
draft
NPDES
permit:

Comment
In
Part
I
Section
A.(
1).
Effluent
Limitations
and
Monitoring
Requirements
for
Mars
Ditch
(
Outfall
002)
and
Seerley
Creek
(
Outfall
004)
three
(
3)
different
limits
are
presented
for
the
CBOD5
parameter.
What
is
the
rational
behind
this?
Commentor:
USAir
Response
Carbonaceous
biological
oxygen
demand,
CBOD5,
is
limited
to
maintain
instream
dissolved
oxygen
standards.
As
propylene
glycol
degrades
in
the
stream,
it
consumes
oxygen.
The
degradation
rate
of
propylene
glycol
is
temperature
dependent.
The
rate
of
degradation
decreases
as
temperature
decreases.
Therefore,
at
lower
temperatures,
CBOD5
limits
can
be
higher
without
causing
adverse
impacts
in
the
receiving
stream.

Comment
Why
are
grab
samples
required
at
the
beginning
and
end
of
each
composite
sample
(
6)?
Commentor:
USAir.

Response
Several
of
the
parameters
listed
in
the
permit
are
required
to
be
collected
by
a
composite
sampling
method.
An
explanation
of
the
composite
sample
to
be
collected
for
a
particular
parameter
is
contained
in
the
footnote
associated
with
the
sample
type.
Dissolved
oxygen
is
to
be
collected
by
a
grab
sample.
Two
(
2)
grab
samples
will
be
collected
during
each
discharge
and
analyzed
for
dissolved
oxygen.

The
first
grab
sample
for
dissolved
oxygen
will
be
collected
during
the
first
thirty
(
30)
minutes,
or
as
soon
thereafter
as
practicable,
of
the
discharge.
The
second
grab
sample
for
dissolved
oxygen
will
be
collected
after
the
first
four
(
4)
hours
of
the
discharge
or
when
the
discharge
ceases,
which
ever
occurs
first.
Therefore,
grab
samples
for
dissolved
oxygen
shall
be
taken
at
the
beginning
and
end
of
the
composite
sampling
period.
Dissolved
oxygen
concentration
is
reported
based
on
the
need
to
maintain
a
minimum
instream
daily
average
of
5.0
mg/
l.
Permit
No.
IN
0058238
Page
19
Comment
The
discharge
from
Mars
Ditch,
Seerley
Creek,
Davis
Creek
and
Drexel
Run
is
considered
the
headwaters
for
their
respective
watersheds.
These
discharges
are
to
a
zero
flow
streams.
Why
is
the
airport
not
being
issued
discharge
limits
based
on
the
White
River
as
its
receiving
waters
since
the
discharge
travels
from
Seerley
Creek
to
White
River
in
4.17
hours?
Commentor:
USAir.

Response
The
storm
water
runoff
from
the
Indianapolis
International
Airport
must
flow
through
approximately
five
(
5)
miles
of
zero
flow
streams
before
it
enters
White
River.
These
zero
flow
streams
are
considered
waters
of
the
state
and
are
to
be
protected.
Therefore,
the
effluent
limitations
contained
in
the
NPDES
permit
are
based
on
zero
flow
streams.

Comment
In
Part
I
Section
A
(
2)
it
states
that
sampling
will
be
required
during
rain
events
of
0.1
inch
or
greater
(
2).
This
is
not
consistent
with
the
Mars
Ditch/
Seerely
Creek
sampling
requirements.
Why?
Commentor:
USAir.

Response
Storm
water
runoff
from
the
runways
enters
waters
of
the
state
during
every
rain
event.
However,
storm
water
from
several
rain
events
may
be
collected
in
the
Mars
and
Seerley
basins
before
being
discharged
to
waters
of
the
state.

Comment
Include
the
Indianapolis
Airport
Authority
along
with
BAA
Indianapolis
LLC
as
authorized
to
discharge
from
a
public
transportation
facility.
The
Indianapolis
Airport
Authority
is
the
owner,
and
all
tenant
contracts
are
with
the
owner.
Commentor:
BAA
Indianapolis
LLC
Response
The
IDEM
agrees
with
this
comment
and
the
change
has
been
made
in
the
final
permit.
Permit
No.
IN
0058238
Page
20
Comment
We
believe
a
grab
sample
should
be
required
for
oil
and
grease
rather
than
a
composite
sample.
327
IAC
15­
6­
7
d.(
1)
lists
the
sample
type
for
oil
and
grease
as
grab.
Composite
sampling
is
listed
for
the
following
outfalls:
Outfall
002
Outfall
004
Outfall
003
Outfall
005
Outfall
006A
Outfall
006B
Outfall
007
Commentor:
BAA
Indianapolis
LLC
Response
IDEM
agrees
with
this
comment.
The
sample
type
for
oil
and
grease
at
the
above
mentioned
Outfalls
will
be
changed
from
composite
to
grab.
The
grab
samples
are
to
be
collected
within
the
first
thirty
(
30)
minutes,
or
as
soon
thereafter
as
practicable,
of
the
discharge.

Comment
Under
the
reopening
clause
on
p.
25,
E.
3.,
suggest
the
following
rewording:

"
This
permit
may
be
modified,
or
alternately,
revoked
and
reissued
to
modify
monitoring
requirements/
effluent
limitations
to:

1)
incorporate
any
future
information
which
more
accurately
predicts
the
impacts
of
discharges,
i.
e.
using
water
temperature
versus
forecasted
air
temperature
2)
reflect
facility
improvements
which
deem
any
existing
monitoring
requirements/
effluent
limitations
to
no
longer
be
representative
(
see
below)

If
IND
constructs
improvements
that
minimize
the
transport
of
aircraft
deicing
fluid
to
storm
water
runoff,
some
effluent
limits
contained
in
the
current
version
of
the
permit
will
no
longer
be
applicable.
The
CBOD5
limit
calculations
were
based
upon
majority
contribution
from
propylene
glycol
(
PG).
Permit
No.
IN
0058238
Page
21
Also,
IND
may
not
be
able
to
meet
the
warm
temperature
CBOD5
limits
even
if
PG
is
all
but
removed
from
storm
water
runoff
or
the
"
first
flush"
is
captured
until
levels
drop
to
below
200
mg/
L
PG.
Organic
constituents
will
always
be
present
in
IND
runoff
independent
of
whether
or
not
any
deicing
chemicals
are
contained
in
it.
Therefore
if
IND
can
demonstrate
the
improvements
essentially
remove
deicing
chemicals
from
runoff,
the
suspension/
modification
of
limits
such
as
CBOD5
would
be
requested.
Commentor:
BAA
Indianapolis
LLC
Response
It
is
the
decision
of
IDEM
that
the
third
reopening
clause
on
Page
25
adequately
addresses
the
first
part
of
the
above
mentioned
comment.
As
for
the
second
part
of
the
comment,
Part
II.
C.
1.
of
the
permit,
Page
33,
requires
the
permittee
to
give
advance
notice
to
the
Commissioner
of
any
anticipated
facility
expansions,
production
increases,
or
process
modifications
which
will
result
in
new,
different,
or
increased
discharges
of
pollutants.
The
provision
further
states
that
following
such
notice,
the
permit
may
be
modified
to
revise
existing
pollutant
limitations
and/
or
to
specify
and
limit
any
pollutants
not
previously
limited.
Therefore,
no
changes
will
be
made
to
the
reopening
clauses.

Comment
On
p.
34,
C.
4.
d.,
CBOD5
is
obviously
not
listed
as
a
pollutant
to
be
reported
within
24
hours
of
violation
since
the
parameter
takes
5
days
to
measure.
The
5
day
report
may
also
not
contain
this
parameter's
value.
Therefore,
violation
of
this
parameter
must
be
reported
in
a
period
of
approximately
6
days.
Commentor:
BAA
Indianapolis
LLC
Response
The
twenty­
four
hour
reporting
provision
requires
that
the
types
of
noncompliance
listed
in
a.
­
d.
shall
be
orally
reported
to
the
commissioner
within
24
hours
from
the
time
the
permittee
becomes
aware
of
the
noncompliance.
Therefore,
if
laboratory
results
reveal
a
violation
of
a
maximum
daily
discharge
limitation,
the
permittee
is
to
orally
report
the
violation
within
24
hours
from
the
time
the
laboratory
results
are
received.
The
written
report
shall
be
submitted
within
5
days
of
the
time
the
permittee
becomes
aware
of
the
noncompliance.
Permit
No.
IN
0058238
Page
22
Comment
I
urge
IDEM
to
allow
the
use
of
either
ethylene
glycol
or
propylene
glycol
based
deicing
and
antiicing
fluids
by
revising
the
permit
to
the
state
standards
for
glycols,
rather
than
for
propylene
glycol
only.
This
change
is
consistent
with
the
approach
that
EPA
has
taken
in
its
multi­
sector
permit
initiative,
thus
allowing
us,
as
a
user
of
deicing
and
anti­
icing
fluids,
to
be
free
to
choose
the
deicing/
anti­
icing
fluid
that
best
meets
our
needs.
Commentor:
American
Airlines
and
Union
Carbide
Corporation.

Response
The
discharge
limitations
contained
in
the
NPDES
permit
are
based
on
the
specific
types
of
deicing/
anti­
icing
practices
currently
being
conducted
and
chemicals
currently
being
used
in
the
respective
watersheds
at
the
Indianapolis
International
Airport.
Extensive
data
collection
and
analytical
testing
of
the
storm
water
runoff
from
the
Indianapolis
International
Airport
was
conducted.
Storm
water
toxicity
and
biochemical
degradation
studies
were
also
conducted.
All
this
information
was
used
to
determine
specific
effluent
limitations
for
the
Indianapolis
International
Airport.

The
NPDES
permit
specifically
states
that
in
the
event
that
deicing/
anti­
icing
practices
change
or
additional
or
alternative
chemicals
are
used
at
the
Indianapolis
International
Airport,
the
permittee
shall
notify
the
IDEM.
After
such
notification
the
NPDES
permit
will
be
modified
accordingly.
This
provision
allows
the
Indianapolis
International
Airport
the
opportunity
to
use
the
chemicals
it
feels
necessary
to
ensure
public
health
and
safety.
Therefore,
the
effluent
limitations
will
not
be
changed.
