Document 5kQg8bZgYmqK3awOE8Vjx0rr4
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4
ATLANTA FEDERAL CENTER 61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
ELECTRONIC EMAIL CONFIRMATION OF EMAIL RECEIPT REQUESTED
Mr. Jeremy Spires Manager, Environmental Compliance 140 BNA Park Drive, Suite 520 Nashville, Tennessee 37214 Email: jeremy.spires@flynashville.com
Re: Reconnaissance Inspection Report, NPDES Permit No. TN0064041 Metro Nashville Airport Authority, Nashville International Airport
Dear Mr. Spires:
The U.S. Environmental Protection Agency, Region 4 and the Tennesse Department of Environment and Conservation conducted an inspection of the Nashville International Airport's deicing fluid and stormwater runoff treatment system located at One Terminal Drive, Nashville, Tennessee on October 26, 2021. The objective of the inspection was to assess the Metro Nashville Airport Authority's compliance with the National Pollutant Discharge Elimination System (NPDES) Permit and the Clean Water Act and to evaluate the general condition of the facility. The inspection results have been summarized in the enclosed Reconnaissance Inspection Report.
If you have any questions about the inspection report, please contact Dennis Sayre at 404-562-9756 or via email at Sayre.Dennis@epa.gov. Please verify receipt of this letter and attachments to Mr. Sayre.
Sincerely,
JAIRO CASTILLO
Digitally signed by JAIRO CASTILLO Date: 2021.12.16 09:17:56 -05'00'
Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch
Enclosure
cc Jessica Murphy Tennessee Department of Conservation and the Environment
Internet Address (URL) http://www.epa.gov
United States Environmental Protection Agency
Region 4
CV-TN0064041-102621
Reconnaissance Inspection Report
SECTION A: National Data System Coding
NPDES No.
MO/DAY/YR
Inspection-Type
Inspector
TN0064041
10/26/2021
ROS (Reconnaissance Dennis Sayre/Tristan
without Sampling)
Odekirk
SECTION B: Facility Data
Name and Location of Facility Inspected (For industrial users discharging to POTW, Entry Date/Time
also include POTW name and NPDES permit number)
Nashville International Airport One Terminal Drive, Nashville, Tennessee
10/26/2021 9:00 AM Exit Date/Time 10/26/2021 10:45 AM
Names of On-site Representative(s)/Title(s)/Phone and Fax Number(s)
Other Facility Data
On-site representatives are listed in Section D
n/a
Facility-Type Industrial wastewater facility
Permit Effective Date 10/1/2020 Permit Expiration Date 7/31/2025
Name, Address of Responsible Official/Title/Phone and Fax Number
Mr. Jeremy Spires, Manager, Environmental Compliance 140 BNA Park Drive, Suite 520 Nashville, Tennessee 37214 Email: jeremy.spires@flynashville.com 615 275-1444
Contacted
Yes
No
Permit
SECTION C: Areas Evaluated During Inspection (Check only those areas evaluated)
Flow Measurement
Operation &
CSO/SSO (Sewer
Maintenance
Overflow)
Records/Reports
Self-Monitoring Program
Sludge
Handling/Disposal
Pollution Prevention
Facility Site Review Compliance Schedules
Pretreatment
Multimedia
Effluent/Receiving Waters
Laboratory
Storm Water
Other:
SECTION D: Summary of Findings/Comments (Attach additional sheets of narrative and checklists as necessary) Attached below.
Name(s) and Signature(s) of Inspector(s)
DENNIS
Digitally signed by DENNIS SAYRE
SAYRE
Date: 2021.12.16 09:26:25 -05'00'
Dennis Sayre
Signature of Management QA Reviewer
JAIRO
Digitally signed by JAIRO CASTILLO
CASTILLO
Date: 2021.12.16 09:18:24 -05'00'
Jairo Castillo, P.E.
Agency/Division/Phone and Fax Number EPA/ECAD/(404) 562-9756
Agency/Division/Phone and Fax Number EPA/ECAD/(404) 562-9257
Date 12/16/2021
Date 12/16/2021
United States Environmental Protection Agency Region 4
Reconnaissance Inspection Report
Project No. CV-TN0064041-102621
Section D: Summary of Findings / Comments
On October 26, 2021, the U.S. Environmental Protection Agency, Region 4 and the Tennessee Department of Environment and Conservation (TDEC) conducted a Reconnaissance Inspection (RI) on the Nashville International Airport deicing and storm water treatment system (the "Facility") located on One Terminal Drive, Nashville, Tennessee. The Facility is owned and operated by the Nashville Metro Airport Authority (NMAA). The inspection was conducted under the authority of Section 308 of the Clean Water Act (CWA), as amended. This report presents the results of the inspection.
I. PARTICIPANTS
Dennis Sayre Tristan Odekirk Jordan Fey Christina Cagle Jenny Strobel Ted Morrissey Jeremy Spires Brandin Price
EPA Region 4 EPA Region 4 TDEC TDEC TDEC MNAA MNAA MNAA
Sayre.Dennis@epa.gov Odekirk.Tristan@epa.gov Jordan.Fey@tn.gov Christina.Cagle@tn.gov Jenny.Strobel@tn.gov Ted.Morrissey@flynashville.com Jeremy.Spires@flynashville.com Brandin.Price@flynashville.com
II. FACILITY DESCRIPTION
The Facility is an industrial aerated lagoon treatment system that is designed to treat storm water runoff from various locations that are contaminated with glycol based deicing fluids and storm water runoff from the airport fuel farm area. Refer to the Facility flow diagram shown in Figure 1 for storm water collection areas and treatment units.
Figure 1. Facility flow diagram.
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United States Environmental Protection Agency Region 4
Reconnaissance Inspection Report
Project No. CV-TN0064041-102621
III. INSPECTION PROCEDURES
The objective of this RI was to evaluate the condition of the Facility's aerated lagoon system and the permittee's self-monitoring program. Specific tasks included conducting an opening conference, interviewing Facility staff, reviewing Discharge Monitoring Reports (DMRs) and other records, conducting a site visit to the lagoon and the receiving waters, and conducting a closing conference. This inspection focused only on Outfall 002 and the aerated lagoon system for the purposes of the site visit.
IV. PERMIT
The Facility is permitted to discharge through various outfalls shown in Figure 2. All outfalls shown in Figure 2 are included in NMAA's National Pollutant Discharge Elimination System (NPDES) Permit, which became effective on October 1, 2020. Outfall 002 is used to discharge treated storm water that is contaminated with deicing fluid and from the airport fuel farm that is transmitted to the aerated lagoon during the deicing season. The NPDES Permit defines the deicing season as any month, October through April, in which deicing material is applied at Nashville International Airport at least once during that month. The lagoon is placed in lay-up generally from May 1 through November 1. Outfalls 003 and 004 are used to discharge storm water from the oil-water separators during periods where deicing operations are not conducted. Storm water discharging from Outfalls SW1 through SW7 do not enter the Facility for treatment.
Figure 2. Outfall location map.
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United States Environmental Protection Agency Region 4
Reconnaissance Inspection Report
Project No. CV-TN0064041-102621
The NPDES Permit stipulates that all outfalls be monitored throughout the entire year. V. RECORDS AND REPORTS Attachment 2 shows NMAA's three-year compliance history as recorded in EPA's Integrated Compliance Information System (ICIS). ICIS records show that since February 2019, MNAA has submitted their Discharge Monitoring Report (DMR) either past the due date and/or failed to collect or analyze samples. ICIS records also show that MNAA exceeded effluent limits for Ammonia (as Nitrogen), Carbonaceous Biochemical Oxygen Demand (5 day), Total Suspended Solids, and pH as shown in Attachment 2. TDEC issued Notices of Violation (informal enforcement actions) on 06/13/2019, 02/31/2020, and 07/06/2021. No formal enforcement action is recorded for the past five years. VI. OPERATIONS AND MAINTENANCE
(Refer to Attachment 1 - Photographs for photo citations)
SITE VISIT OBSERVATIONS The site visit during the inspection only included the Aerated Lagoon area of the system and
Outfall 002, as shown in Figure 2.
Figure 2. Overhead view of the Aeration Lagoon area. The Clarifier and the north end of the lagoon was empty and appeared to be in good
condition. The Facility was still in lay-up at the time of inspection and was scheduled to be
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United States Environmental Protection Agency Region 4
Reconnaissance Inspection Report
Project No. CV-TN0064041-102621
on-line starting November 1, 2021. The south end of the pond is full and in start-up operations (Photos 1, 2 and 3). Flow is measured from a Parshall flume located next to the Clarifier. The Clarifier was still in lay-up condition and therefore no flow was present in the flume (Photo 4). Flow is conveyed to Outfall 002 from the Clarifier in an open channel concrete conveyance ditch. The water present in the conveyance ditch is storm water or ground water seepage originating from the PVC pipe (Photos 5 and 6). Outfall 002 has a sign posted at the outfall to Sims Branch creek as required by the NPDES Permit (Photo 7). The conveyance ditch ends approximately 20 to 25 feet from the creek. The section of the conveyance ditch, where water pools at the termination of the concrete ditch, has been used for collecting samples for Outfall 002 discharges. Dirt and other solids were accumulated at this location (Photo 8).
VII. EFFLUENT AND RECEIVING WATERS
The Facility was not discharging from the Clarifier during the inspection. The storm water that was present in the conveyance ditch, shown in Photo 5, was clear and the flow was negligible. The creek water at Outfall 002 was clear.
VII. DISCUSSION
MNAA's NPDES Permit states in Section B.1 (Representative Sampling) that "Samples and measurements taken in compliance with the monitoring requirements specified herein shall be representative of the volume and nature of the monitored discharge and shall be taken after treatment and prior to mixing with uncontaminated storm water runoff or the receiving stream. Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges."
NPDES Permit Section A stipulates that samples are to be collected for "External Outfall 002, Effluent Gross, All Year."
NMAA's representative stated that effluent samples are taken at the end of the concrete conveyance ditch for Outfall 002. Flow from the Clarifier is measured at the Parshall flume located next to the Clarifier. Samples collected at the stated sampling point are not representative of the discharge from the Clarifier because the open conveyance ditch allows for the introduction of storm water runoff prior to the flow entering the creek. Since the NPDES Permit requires year around monitoring of each outfall, NMAA should be sampling discharges from the location marked as Outfall 002, including any storm water discharge, regardless whether the treatment system is in lay-up, if a discharge is present.
A more appropriate location for Outfall 002 would be just after the flow leaves the Parshall flume. If Outfall 002 were located after the flume, samples would be representative of discharges from the
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United States Environmental Protection Agency Region 4
Reconnaissance Inspection Report
Project No. CV-TN0064041-102621
treatment system and free from impacts of storm water runoff in the conveyance ditch. Also, any flow reported on the DMR as "no discharge" would be accurate. VIII. ATTACHMENTS
1. Photographs 2. Three-year Compliance History
End of Report
Page 6 of 6
Attachment 1 - Photographs Nashville International Airport Project No. CV-TN0064041-102621
Photo 1. Aerated Lagoon, north section.
Photo 2. Aerated Lagoon, south section.
Photo 3. Clarifier tank.
Photo 4. Parshall flume.
Photo 5. Open channel ditch from the Clarifier (in the background) to Sims Creek/Outfall 002.
Photo 6. Open channel ditch to Outfall 002.
Attachment 1 - Photographs Nashville International Airport Project No. CV-TN0064041-102621
Photo 7. Outfall 002 at Sims Creek.
Photo 8. The end of the open channel ditch and sampling location for Outfall 002.
Attachment 2. Three-year Compliance History. Project No. CV-TN0064041-102621
Violation Type
DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation
Outfall
Violation Information
002 002 '004 '004 '004 '004 '004 '004 '002 '002 '004 '004 '004 '004 '004 '004 '004 SW1 SW1 SW1 SW1 SW1 SW1 SW2 SW2 SW2 SW2 SW2 SW2 SW7 SW7 SW7 SW7 SW7 SW7 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 004 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002 '002
G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:2 C2 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:2 C3 G 50050 Flow, in conduit or thru treatment plant Effluent Gross Season ID:0 Q2 G 00340 Oxygen demand, chem. [high level] [COD] Effluent Gross Season ID:0 C3 G 00400 pH Effluent Gross Season ID:0 C3 G 00530 Solids, total suspended Effluent Gross Season ID:0 C3 G 00556 Oil & Grease Effluent Gross Season ID:0 C3 G 80082 BOD, carbonaceous [5 day, 20 C] Effluent Gross Season ID:0 C3 G 00061 stream flow, instantaneous Instream Monitoring Season ID:0 Q1 G 00061 stream flow, instantaneous Instream Monitoring Season ID:0 Q2 G 00400 pH Effluent Gross Season ID:0 C3 G 00340 Oxygen demand, chem. [high level] [COD] Effluent Gross Season ID:0 C3 G 00400 pH Effluent Gross Season ID:0 C3 G 00530 Solids, total suspended Effluent Gross Season ID:0 C3 G 00556 Oil & Grease Effluent Gross Season ID:0 C3 G 50050 Flow, in conduit or thru treatment plant Effluent Gross Season ID:0 Q2 G 80082 BOD, carbonaceous [5 day, 20 C] Effluent Gross Season ID:0 C3 B 00310 BOD, 5-day, 20 deg. C Effluent Gross Season ID:0 C3 B 00340 Oxygen demand, chem. [high level] [COD] Effluent Gross Season ID:0 C3 B 00400 pH Effluent Gross Season ID:0 C3 B 00530 Solids, total suspended Effluent Gross Season ID:0 C3 B 00556 Oil & Grease Effluent Gross Season ID:0 C3 B 50050 Flow, in conduit or thru treatment plant Effluent Gross Season ID:0 Q2 B 00310 BOD, 5-day, 20 deg. C Effluent Gross Season ID:0 C3 B 00340 Oxygen demand, chem. [high level] [COD] Effluent Gross Season ID:0 C3 B 00400 pH Effluent Gross Season ID:0 C3 B 00530 Solids, total suspended Effluent Gross Season ID:0 C3 B 00556 Oil & Grease Effluent Gross Season ID:0 C3 B 50050 Flow, in conduit or thru treatment plant Effluent Gross Season ID:0 Q2 B 00310 BOD, 5-day, 20 deg. C Effluent Gross Season ID:0 C3 B 00340 Oxygen demand, chem. [high level] [COD] Effluent Gross Season ID:0 C3 B 00400 pH Effluent Gross Season ID:0 C3 B 00530 Solids, total suspended Effluent Gross Season ID:0 C3 B 00556 Oil & Grease Effluent Gross Season ID:0 C3 B 50050 Flow, in conduit or thru treatment plant Effluent Gross Season ID:0 Q2 G 00061 stream flow, instantaneous Instream Monitoring Season ID:0 Q1 G 00061 stream flow, instantaneous Instream Monitoring Season ID:0 Q2 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:2 C2 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:2 C3 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:2 C2 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:2 C3 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:2 C2 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:2 C3 G TAA3B LC50 Static 48Hr Acute Ceriodaphnia Effluent Gross Season ID:0 C1 G TAA6C LC50 Static 48Hr Acute Pimephales Effluent Gross Season ID:0 C1 G 00061 stream flow, instantaneous Instream Monitoring Season ID:0 Q1 G 00061 stream flow, instantaneous Instream Monitoring Season ID:0 Q2 G 00340 Oxygen demand, chem. [high level] [COD] Effluent Gross Season ID:0 C3 G 00010 Temperature, water deg. centigrade Effluent Gross Season ID:0 C3 G 00061 stream flow, instantaneous Instream Monitoring Season ID:0 Q1 G 00061 stream flow, instantaneous Instream Monitoring Season ID:0 Q2 G 00300 Oxygen, dissolved [DO] Effluent Gross Season ID:0 C1 G 00340 Oxygen demand, chem. [high level] [COD] Effluent Gross Season ID:0 C3 G 00400 pH Effluent Gross Season ID:0 C1 G 00400 pH Effluent Gross Season ID:0 C3 G 00530 Solids, total suspended Effluent Gross Season ID:0 C2 G 00530 Solids, total suspended Effluent Gross Season ID:0 C3 G 00556 Oil & Grease Effluent Gross Season ID:0 C2 G 00556 Oil & Grease Effluent Gross Season ID:0 C3 G 00610 Nitrogen, ammonia total [as N] Effluent Gross Season ID:0 C2 G 00610 Nitrogen, ammonia total [as N] Effluent Gross Season ID:0 C3 G 50050 Flow, in conduit or thru treatment plant Effluent Gross Season ID:0 Q1 G 50050 Flow, in conduit or thru treatment plant Effluent Gross Season ID:0 Q2 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:1 C2 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:1 C3 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:1 C2
Violation Code
D90 D90 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D80 D90 D90 D90 D90 D90 D80 D90 D90 D80 D80 D80 D80 D80 D80 D90 D80 D90 D90 D90 D80 D90 D90 D90 D90 D80 D80 D90 D90 D90
Violation Date
2/28/2019 2/28/2019 7/31/2019 8/31/2019 8/31/2019 8/31/2019 8/31/2019 8/31/2019 11/30/2019 11/30/2019 11/30/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 2/29/2020 2/29/2020 2/29/2020 2/29/2020 2/29/2020 2/29/2020 2/29/2020 2/29/2020 2/29/2020 2/29/2020 3/31/2020 3/31/2020 4/30/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020 7/31/2020
RNC Detection Code-Date
N-04/15/2019 K-04/15/2019 K-09/15/2019 K-10/16/2019 K-10/16/2019 K-10/16/2019 K-10/16/2019 K-10/16/2019 N-01/15/2020 K-01/15/2020 K-01/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 K-02/15/2020 N-04/15/2020 K-04/15/2020 N-04/15/2020 K-04/15/2020 N-04/15/2020 K-04/15/2020 N-04/15/2020 K-04/15/2020
N-05/16/2020 K-05/16/2020 K-06/15/2020 K-09/15/2020 N-09/15/2020 K-09/15/2020
K-09/15/2020
K-09/15/2020 N-09/15/2020 K-09/15/2020 N-09/15/2020 K-09/15/2020 N-09/15/2020 K-09/15/2020 N-09/15/2020 K-09/15/2020 N-09/15/2020 K-09/15/2020 N-09/15/2020
RNC Resolution Code-Date
Violation cause
2-04/26/2019 2-04/26/2019 0-09/15/2021 0-10/16/2021 0-10/16/2021 0-10/16/2021 0-10/16/2021 0-10/16/2021 1-01/15/2020 1-01/15/2020 1-01/15/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 6-03/31/2020 1-04/15/2020 1-04/15/2020 2-05/26/2020 2-05/26/2020 2-05/26/2020 2-05/26/2020 2-05/26/2020 2-05/26/2020
1-05/16/2020 1-05/16/2020 1-06/15/2020 2-09/23/2020 2-09/23/2020 2-09/23/2020
2-09/23/2020
2-09/23/2020 2-09/23/2020 2-09/23/2020 2-09/23/2020 2-09/23/2020 2-09/23/2020 2-09/23/2020 2-09/23/2020 2-09/23/2020 2-09/23/2020 2-09/23/2020 2-09/23/2020
Insufficient flow for sampling Insufficient flow for sampling Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Sample equipment Failure Sample equipment Failure Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Failed to Sample/Required Analysis Not Conducted Conditional Monitoring - Not Required This Period Conditional Monitoring - Not Required This Period Conditional Monitoring - Not Required This Period Conditional Monitoring - Not Required This Period Conditional Monitoring - Not Required This Period Conditional Monitoring - Not Required This Period Conditional Monitoring - Not Required This Period Conditional Monitoring - Not Required This Period Lost Sample/Data Not Available Lost Sample/Data Not Available Failed to Sample/Required Analysis Not Conducted No discharge No discharge No discharge No discharge No discharge No discharge No discharge No discharge No discharge Below Detection Limit/No Detection Below Detection Limit/No Detection No discharge No discharge No discharge No discharge No discharge No discharge No discharge
Attachment 2. Three-year compliance history. Project No. CV-TN0064041-102621
DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation DMR Non-Receipt Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation Effluent Violation
'002 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:1 C3 '002 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:1 C2 '002 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:1 C3 '002 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:1 C2 '002 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:1 C3 '002 G TAA3B LC50 Static 48Hr Acute Ceriodaphnia Effluent Gross Season ID:0 C1 002 G TAA6C LC50 Static 48Hr Acute Pimephales Effluent Gross Season ID:0 C1 004 G 00340 Oxygen demand, chem. [high level] [COD] Effluent Gross Season ID:0 C3 '004 G 00400 pH Effluent Gross Season ID:0 C3 '004 G 00530 Solids, total suspended Effluent Gross Season ID:0 C3 '004 G 00556 Oil & Grease Effluent Gross Season ID:0 C3 '004 G 50050 Flow, in conduit or thru treatment plant Effluent Gross Season ID:0 Q2 '004 G 80082 BOD, carbonaceous [5 day, 20 C] Effluent Gross Season ID:0 C3 003A G 52290 Total Petroleum Hydrocarbons - Diesel Internal Monitoring Point Season ID:0 C1 '002 G 00610 Nitrogen, ammonia total [as N] Effluent Gross Season ID:0 C2 '002 G 00610 Nitrogen, ammonia total [as N] Effluent Gross Season ID:0 C3 '002 G 00610 Nitrogen, ammonia total [as N] Effluent Gross Season ID:0 C2 '002 G 00610 Nitrogen, ammonia total [as N] Effluent Gross Season ID:0 C3 '002 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:2 C2 '002 G 80082 BOD, carbonaceous [5 day, 20 C] See Comments Season ID:2 C3 '002 G 00530 Solids, total suspended Effluent Gross Season ID:0 C2 '002 G 00400 pH Effluent Gross Season ID:0 C1 '002 G 00610 Nitrogen, ammonia total [as N] Effluent Gross Season ID:0 C2 '002 G 00610 Nitrogen, ammonia total [as N] Effluent Gross Season ID:0 C3 '002 G 00610 Nitrogen, ammonia total [as N] Effluent Gross Season ID:0 C2 '002 G 00610 Nitrogen, ammonia total [as N] Effluent Gross Season ID:0 C3
For the purposes of this permit, the deicing season shall include any month, October through April, in which deicing material is applied at Nashville International Airport at least once during that month
D90 7/31/2020 K-09/15/2020 2-09/23/2020 No discharge
D90 7/31/2020 N-09/15/2020 2-09/23/2020 No discharge
D90 7/31/2020 K-09/15/2020 2-09/23/2020 No discharge
D80 7/31/2020 N-09/15/2020 2-09/23/2020 No discharge
D80 7/31/2020 K-09/15/2020 2-09/23/2020 No discharge
D90 7/31/2020
No discharge
D90 7/31/2020
No discharge
D80 7/31/2020 K-09/15/2020 2-09/23/2020 No discharge
D80 7/31/2020 K-09/15/2020 2-09/23/2020 No discharge
D80 7/31/2020 K-09/15/2020 2-09/23/2020 No discharge
D80 7/31/2020 K-09/15/2020 2-09/23/2020 No discharge
D80 7/31/2020 K-09/15/2020 2-09/23/2020 No discharge
D80 7/31/2020 K-09/15/2020 2-09/23/2020 No discharge
D80 10/31/2020 K-12/16/2020 1-12/16/2020 Failed to Sample/Required Analysis Not Conducted
E90 2/28/2019 T-03/31/2019 2-08/31/2019
E90 2/28/2019
E90 3/31/2019 T-03/31/2019 2-08/31/2019
E90 3/31/2019
E90 11/30/2019
E90 11/30/2019
E90 12/31/2020
E90 2/28/2021
E90 2/28/2021 T-04/30/2021 2-08/31/2021
E90 2/28/2021
E90 4/30/2021 T-04/30/2021 2-08/31/2021
E90 4/30/2021