IN AND OUT OF HOT WATER: A CASE STUDY OF DFW AIRPORT'S RECENT DEICING AND WATER QUALITY HISTORY

In March 2000, DFW Airport learned that it was the subject of a criminal investigation conducted jointly by the FBI, DOJ, DPS, EPA, TNRCC, U. S. Fish & Wildlife, and Texas Parks & Wildlife for alleged violations of the environmental laws. Shortly thereafter, DFW received a Notice of Enforcement from the TNRCC for alleged discharges of industrial waste from stormwater outfalls and surface impoundments. In August 2000, earlier alleged releases of jet fuel and sewage resulted in DFW's entering into an Agreed Order with the TNRCC. In September 2000, DFW learned it had been sued by a former Environmental Affairs Department employee claiming that DFW had misrepresented the state of its stormwater and industrial waste systems in order to obtain federal monies used to build the Airport. In January 2002, another Agreed Order was entered resolving alleged discharges of anti-icing and deicing fluid into waters in the State of Texas. The criminal investigation, the Notice of Enforcement, one of the Agreed Orders, and the qui tam lawsuit all shared two common elements: deicing fluids and their effects on water quality.Tremendous progress has been made by DFW. As of the date of this abstract: The criminal investigation has been closed with no finding of culpability. The two Agreed Orders are being implemented. The former employee's qui tam suit is on hold while the Court awaits a ruling from the U. S. Supreme Court in a similar case. During the 2001-2002 winter deicing season,neither the EPA nor the TNRCC (now TCEQ) issued any notices of violation or notices of enforcement to DFW related to deicing or glycol.The manuscript and presentation will describe the events and regulatory drivers leading to the various actions brought against DFW, and how DFW has surmounted those challenges. Specific examples of structural improvements, BMPs, and other waste water and storm water initiatives at DFW will be given.The presentation is designed to be given immediately prior to, and in conjunction with, the presentation proposed by Dr. Enos Stover under separate cover. Stover & Associates was hired by DFW at the initiative of co-author Dan Bergman to design aerators for Trigg Lake, an onairport water body, as one of the many measures DFW has employed to maintain and improve water quality. In combination with other efforts made by the Airport, the aerators helped DFW improve and maintain water quality during an entire deicing season.