TN0064041
­
METRO
NASHVILLE
AIRPORT
AUTHORITY
Previous
Permit
 
Issued:
May
31,
1989
 
COD
limit:
30.0
mg/
l,
1/
Month
sampling
frequency
@
Outfalls
002,
003,
004,
&
005
 
Outfalls
002,
003,
004,
&
005
discharge
from
oil/
water
separators
 
COD
limited
"
according
to
state
maximum
effluent
limitations
(
one
to
one
ratio
with
biochemical
oxygen
demand)."

August,
1989
­
August,
1990
In
violation
of
pH,
Oil
&
Grease,
TSS,
&
COD
a
total
of
67
times
August,
1989
 
In­
stream
biological
survey
conducted
by
NFO
of
Sims
Branch
 
Conclusion
stated
impairment
of
Sims
Branch
aquatic
community
caused
by
discharges
from
MNAA
Agreed
Order
­
September
18,
1991
 
Resolved
appeal
of
Commissioner's
Order
issued
on
January
8,
1991
 
Provisions
included:
1.
Completion
of
a
treatability
study
previously
initiated
by
MNAA
and
submitted
to
DWPC
for
approval.
2.
Completion
of
the
design
of
a
collection
and
treatment
system
and
submitted
to
DWPC
for
approval.
3.
Construction
of
the
approved
treatment
system
design
by
December
31,
1992.
4.
Adoption
of
interim
measures
by
MNAA
to
improve
water
quality
until
the
treatment
system
is
completed.
5.
Full
compliance
by
MNAA
by
March
1,
1993.
(
DWPC
has
approved
a
request
to
extend
the
compliance
date
to
August
1,
1995.)
 
Subsequent
DMRs
showed
continued
high
levels
of
TSS
&
COD
and
occasional
low
pH
New
Permit
 
Issued
April
28,
1995
 
Discharge
from
treatment
system
through
Outfall
002
 
Discussions
prior
to
issuance
with
MNAA
&
Ogden
concerned
the
proper
BOD:
COD
ratio
rather
than
the
30
mg/
l
BOD
limit
mentioned
in
the
previous
permit
rationale
­
Original
draft
had
COD
limit
of
30
mg/
l
(
same
as
previous
permit)
­
Ogden
performed
some
calculations
based
on
the
treatability
study
for
selection
of
the
treatment
system
and
recommended
a
COD
limit
of
315
mg/
l
­
Limit
in
draft
permit
changed
to
BOD
limit
of
30
mg/
l
­
Ogden
suggested
report
only
for
BOD
&
COD
for
one
year,
then
modify
permit
based
on
this
data
to
reflect
COD
limit
equivalent
to
BOD
limit
of
30
mg/
l.
DWPC
proposed
basically
the
same
arrangement
except
COD
limit
of
30
mg/
l
while
data
was
taken.
 
Permit
issued
with
BOD
limit:
30.0
mg/
l,
1/
Month
sampling
frequency
@
Outfall
002
Appeal
of
New
Permit
 
Appealed
on
May
30,
1995.
 
Appealed
limits
for
pH,
TSS,
COD,
&
DO
at
Outfall
002.

Meeting
on
July
26,
1995
 
Meeting
requested
to
resolve
issues
pertaining
to
permit
appeal.
 
Ogden
&
Phil
Simmons
mentioned
that
a
stream
model
was
being
constructed
to
"
calculate"
a
water
quality
BOD/
COD
limit.
 
DWPC
raised
several
issues
that
any
model
should
consider.

Meeting
on
August
21,
1995
 
Meeting
with
Jerry
Schumake
(
Ogden)
and
Phil
Simmons
to
discuss
initial
Ogden/
PS
stream
model
submitted
to
Sherry
Wang
for
critique.
 
Several
deficiencies
were
found
in
the
initial
model:
­
stream
background
for
temperature
and
DO
derived
from
insufficient
data.
­
CBOD
instream
removal
rate
derived
from
treatment
system
treatability
study
data
not
appropriate.
­
If
a
model
was
going
to
be
used,
DWPC
recommended
that:
sufficient
stream
data
be
taken
at
appropriate
locations
to
calculate
a
CBOD
decay
rate,
stream
segments
modeled
should
include
Mill
Creek,
model
runs
conducted
at
average
summer
temperature
and
DO
conditions.

DWPC
Letter
of
November
2,
1995
­
Proposed
Permit
Modification
 
Limits
at
Outfall
002
for
Flow,
pH,
BOD5,
TSS,
DO,
Oil
&
Grease,
Settleable
Solids
to
be
"
Report
Only"
for
two
years.
 
MNAA
to
report
above
parameters
in
influent
to
treatment
system
for
two
years
 
In
order
to
demonstrate
that
water
quality
of
the
receiving
stream
is
adequate,
MNAA
to
conduct
biosurveys
and
DO
profiling
of
Sims
Branch
in
each
year
of
two
year
period.
(
If
a
water
quality
problem
was
revealed
by
biosurveys,
MNAA
would
propose
solution
within
90
days).
 
At
the
end
of
the
two
year
period,
modify
permit
to
incorporate
appropriate
limits
for
Outfall
002
based
on
the
most
stringent
of:
­
Water
quality
limits
based
a
stream
model
consistent
with
DO
profile
data
and
Sherry
Wang's
recommendations.
­
Treatability
limit
based
on
treatment
system
performance
data.
MNAA
Letter
of
December
6,
1995
­
Response
to
Proposed
Permit
Modification
 
Agree
to
30
month
(
instead
of
24
months)
compliance
schedule
for
effluent
from
Outfall
002
from
date
of
first
discharge
from
treatment
system.
 
Agree
to
collection
of
treatment
system
influent
data.
 
Agree
to
DO
profiling
of
receiving
streams.
 
Disagree
with
requirement
for
biosurveys
of
receiving
stream.
MNAA/
Ogden
feels
that
the
deicing
fluids
used
at
the
airport
are
not
toxic
(
based
on
published
test
data)
and,
therefore,
biosurveys
to
assess
toxicity
are
not
needed.
 
Agree
to
permit
modification
to
incorporate
limits
based
on
water
quality
data
(
stream
model).
Letter
implies
that
limits
"
more
stringent
than
needed
are
not
appropriate".

NFO
Comments
on
MNAA
Letter
of
December
6,
1995
 
30
months
is
acceptable
if
it
is
from
permit
modification
issuance
date.
 
Deletion
of
biosurveys
is
not
acceptable:
­
Biosurveys
will
address
DO
concerns
as
well
as
toxicity
issues.
­
DO
profile
data
taken
to
construct
stream
model
will
not
be
available
until
30
months
after
modified
permit
issued.
 
Most
stringent
(
water
quality
or
treatability)
should
be
used.
