It's dull, miserably hot work, and Crites is becoming peevish. Chewing gum furiously with a frown on his face, Crites has reason -- besides the heat -- for his growing irritation. He and his guests have arrived at Trigg Lake.
Stagnant, blackish, about the size of four football fields, and wholly unappealing, the lake at the airport's southeast corner is nevertheless protected by the same pollution regulations that apply to rivers and lakes elsewhere. So last February, when an anonymous tipster told state inspectors about the dead fish, airport officials knew trouble was brewing.
In a letter to the airport board, Texas Natural Resource Conservation Commission inspectors wrote that they had found some 150 dead fish of all sizes -- bass, crappie, and catfish among them. Those still alive "were swimming on their sides and flopping intermittently." The lake smelled like sewage, and "a sewage-like substance [was] lining the northwest shore...A type of sewage mold was observed," inspectors reported.
What, they wanted to know, had the airport allowed into the lake?
Airport officials told them that a few weeks earlier a sewer line had broken outside a building about a mile from the lake, at the site of a company that prepares food for airlines.
Sewage from a place that makes airplane food certainly would explain the elevated levels of fecal material in the lake. But how, the inspectors asked, did jet fuel and chemicals used to keep ice off jets' wings make it into other nearby bodies of water they tested?
All told, the TNRCC says it is investigating eight alleged unauthorized discharges of pollutants at various lakes and streams on DFW property.
Because of the apparent seriousness of these violations, enforcement action has been initiated, Samuel Barrett, the TNRCC's waste section manager in the Arlington regional office, wrote to the airport board in June. Regulators asked the airport board to investigate the cause of the discharges so the state and airport can iron out an agreement to prevent them.
But dirty water at the airport has drawn the attention of others. Last October, the U.S. Environmental Protection Agency told the airport board that the EPA was investigating possible environmental law violations. Such a review could lead to criminal charges, though an EPA spokesman says the agency never comments if that kind of probe is taking place. Six months earlier, an EPA field officer observed water flowing from 17 airport storm sewers and found all sorts of industrial waste -- road material, jet fuel, and car-wash runoff among it.
"These fish probably shouldn't be here to begin with," Crites says as he scowls at the dark water of Trigg Lake. Fish attract birds. Birds and airplane safety don't mix. Some airports intentionally lace surrounding bodies of water with chemicals to eliminate fish.
But the dead fish at DFW weren't part of a coherent game plan. Instead, they reflect a troubling lack of planning.
According to DFW's own documents and sources inside and outside the airport, DFW officials have long known -- or should have known -- about severe inadequacies in the airport's system for containing and cleaning water pollution. An antiquated, overburdened drainage system has been allowed to overflow, sending potentially hazardous pollutants flowing into nearby lakes and streams. In the long run, TNRCC's Barrett says, the discharges could further taint the already dirty Trinity River or, in the case of jet fuel, result in explosions at the airport.
Fundamentally, the airport's industrial-waste system is too small and too old to provide properly for the needs of DFW, among the busiest airports in the world. (The more than 2,000 daily flights from DFW consume 798 million gallons of fuel annually.)
Built shortly before the airport opened in 1974, the industrial-wastewater system is similar to one that might be found at a truck stop. Buried beneath at least 17 inches of concrete, it consists of a series of drainage pipes that capture rain rolling off the runways and aprons and carry the water to streams, lakes, and fields surrounding the airport.
Theoretically, the system has mechanisms to remove spilled jet fuel, de-icing chemicals, and other pollutants. Dozens of containers called diversion boxes capture the water, allowing industrial waste to settle. The waste is sent down separate lines to the airport's pre-treatment plant, cleaned, then transported through the sewage system to the Trinity River Authority's central wastewater treatment plant in Grand Prairie for further cleaning. Other outlets in the diversion boxes discharge the remainder of the supposedly cleaner rainwater to the nearest creek, stream, or lake on the airport's 18,000 acres.
But the system does not work as smoothly as anticipated by its original designers, who created it when the airport was half the size it is today.
For starters, it backs up. According to a half-dozen internal airport board documents as well as one former and one current airport employee, the drainage pipes are too small to carry the volume of water from a sizable rainstorm. Consequently, the system overflows, the diversion boxes fill, manhole covers fly off, and contaminated water spreads over the surface and into the storm sewers. Within an hour of a storm at DFW, industrial waste could easily be on its way to lakes and streams. Compounding the problem, many of the aircraft-maintenance hangars built in the early '70s have floor and trench drains tied directly into this inadequate system.
The introduction of de-icing fluids has also taxed the system. The fluids are typically made with ethylene glycol or propylene glycol, which mix with water, defying the design of the diversion boxes.
The airport board has been fully aware of the last problem, thanks to complaints from the Trinity River Authority and state regulators concerned about the flow of de-icing fluids into the TRA's treatment system. Under pressure from both agencies, the airport board built large tanks in the mid-'90s to capture much of the de-icing fluids.
But the airport continued to allow whatever made it through the diversion boxes to discharge into its lakes and streams. Only this summer did the airport board, facing revised regulations from the EPA, begin a $17 million project to build eight underground tanks and de-icing stations to prevent ethylene glycol or propylene glycol from entering the drainage systems. By January, Crites and others at the airport board say, the new de-icing project will be ready for operation.
The board, however, has taken no such costly steps to solve the other serious systemic problems with the drainage system. Instead, the airport's executives, who manage an area that is larger than Manhattan and that has its own public water supply, governing board, and security force, don't even concede a problem exists -- at least not one they have known about.
"There has been a lot of change in personnel," says airport executive director Jeffrey Fegan when asked about the record of problems with the drainage system during an interview last week. Kevin Cox, a lawyer who serves as first deputy executive director, quickly jumps in. "That's not meant as an excuse," he says. "We don't want you to think we don't know what went on."
Crites, the operations director, appears to resent the implication that the airport has moved to fix the problems, such as with the de-icing fluids, only because of external pressure.
"Do you think the only reason is that there was a gun to our head?" he asks.
Given the airport board's lethargic reaction to the wastewater system's past failures, a cannon might be more appropriate to persuade the board to spend the kind of money it would take to solve the wastewater problems at DFW. An airport professional familiar with the problems, who asked to remain anonymous, says that at a 1997 meeting on the system's inadequacies, Fegan asked whether the airport could fight critics or would need an "open checkbook."
Asked about the documents the Dallas Observer had collected and the agency reports of problems with the airport's storm and industrial-waste drainage systems, DFW deputy director Cox had a ready answer.
"It has been fixed," he says. It was only the airport's de-icing pollution, he and others contend, that troubled the regulatory agencies, consultants, and employees who raised questions about DFW's dirty water. Problems with other pollutants were isolated accidents, and the airport has undertaken a $17 million solution for the de-icing leaks.
But others at the airport, as well as the regulators, don't share Cox's confidence.
There wasn't much to see. Jim Crites, DFW's environmental affairs director Dr. Estela De La Fuente, and environmental affairs supervisor Rick Reeter were gathered around an 8-foot concrete pipe jutting into a ditch, one of 17 that discharge from the airport's wastewater system. A small amount of water was visible around the ditch.
The three were there for show and tell with a reporter: Look, no jet fuel spewing out here, though an airport professional would later tell the Observer that Reeter had asked his staff to select for the tour a pipe that had nothing flowing from it. The three had indeed driven a circuitous route to get to this particular pipe, passing some that were closer.
A worker at the airport says fluids have recently flowed from that drainpipe as well as from 16 others, despite nearly two months of rainless weather.
State investigators have not always been allowed to see drains where the flows of industrial wastewater are heaviest. When TNRCC inspector David Robertson toured the airport last winter, according to his supervisor Barrett, he was told that Federal Aviation Administration rules require that he undergo a background check to have access to certain areas where pipes discharge. In his report for the TNRCC, Robertson wrote that the drainage "cannot be reached without an escort and was not observed during this inspection." The airport employee, however, claims that no such FAA rule applied: Airport officials concocted the scheme to prevent Robertson from seeing those problematic drains.
"It is a mischaracterization," counters DFW's Cox, "to say that anyone at the airport has been anything but up-front."
Yet plenty of evidence exists to suggest that airport officials have not gone out of their way to notify, alert, or leave any obvious trail for the outside world about its drainage woes. A DFW employee says that Donna Atwood, a lawyer for the city of Dallas who is assigned to work on airport matters (Dallas shares governance of the airport with Fort Worth), told board personnel two years ago that they should never discuss the problems in writing. Atwood did not return repeated calls for this story.
As long ago as May 1994, airport board employees were learning to keep their mouths shut around regulators. Jim Lee, former director of environmental services, wrote a memo outlining how employees should handle themselves should environmental issues arise:
"Question: What should occur if an Airport Maintenance staff person observes what they believe to be a violation of environmental laws or rules...?
"Answer: The employee should notify his supervisor...The EPA or other regulatory agencies should not be notified directly by the employee since often what might be perceived to be a violation is not, especially due to the complexity of environmental laws and regulations...
"Question: What should an employee do should regulatory agency personnel arrive on site and ask questions or demand assistance?
"Answer: First, ask for identification and, if possible, a business card from the agency representatives. Be polite, but DO NOT provide information or answer questions. Board employees should advise the regulatory agency personnel that the Board has a department for handling interface and coordination with environmental regulatory personnel, then the Board employee should immediately notify the supervisor..."
Yet while the airport's administrators have tried to keep mum on the water pollution problems, the airport's own consultants and employees have been more voluble.
In January 1993, Chiang, Patel, and Associates Inc., an engineering consulting firm, painted a broad picture of the headaches the DFW drainage system could cause. In a report sent to the director for airport development, the consultants recommended switching to a different plan for disposing of industrial waste "since the current system is not designed to handle all the industrial waste at DFW Airport." They noted that additions being built at that time might not handle the load. "If the IW system currently under construction does not utilize a pipe system capable of zero leakage," the engineers wrote, "the system should be either repaired or...replaced."
Without specifically saying the airport was violating the environmental laws, the report concluded: "The system is currently designed to transport ethylene glycol, fuel spillage, and storm water contaminated with fuel, oil, and grease. Therefore, the system should be designed to prevent these contaminants from entering the environment."
Later that year, B.G. Yow, an assistant director of airport maintenance, made the same point in simpler language in a memo to Lee. "It would appear the designers anticipated the main line would not carry the flow during heavy rains, after future construction was in place," Yow wrote.
A month later, airport board employees knew the problem was obvious even to passersby. Earlier in 1993, American Airlines constructed a hangar that had pipes that drained from the floor to the storm-water system. The American runoff had made the manholes, which were "visible to the general public from the south service road," one worker at the airport says, overflow during storms. The airport telephoned the Texas Water Quality Commission (the predecessor of the TNRCC) and asked whether they could create a bypass to relieve the system.
That bypass would allow the wastewater from American's hangar to go unheeded into the storm-water system all the time, not just during rain. The state agency responded that such "bypassing is illegal," according to a letter from Millard Bruce, an environmental services employee. Bruce's letter makes it clear that industrial waste could flow into the storm-water system regardless.
"There can be no question that water flowing from the top of the industrial-waste manhole reaches the storm ditch the same as it would by flowing from a piped bypass near the bottom of the manhole," he wrote. "Either way, it is held to be an illegal discharge. Perhaps the question that we should be addressing is how we may fix the bypass problem."
The letter suggests that no one at the airport wanted to attract further attention from the state regulators who had put the airport under surveillance and stricter guidelines the prior year because of more dead fish in Trigg Lake.
"Since we are under TWC enforcement order regarding Trigg Lake," Bruce wrote, "this is perhaps not the time to...provid[e] a 'planned' bypass during heavy rain and storm flow conditions..."
DFW administrators never installed the planned bypass, nor have they fixed the problem, which they contend doesn't exist.
In another study produced by the engineers Garcia & Associates in 1998, the consultants spelled out when the combined industrial waste and storm-water system would fail. "After 42 minutes of a rainfall event, where the first 0.5 inches has fallen," the engineers calculated, manhole 512 [the one visible from the south side service road] will begin to surcharge." In other words, during even a moderate rain, the manhole would spew contaminated water to the surface.
Garcia & Associates advised DFW to make changes -- big ones.
"For the future growth of DFW International Airport and its tenant customers, the current infrastructure adequacy was designed for a runoff contribution approximately half of what it is today," the engineers wrote. "The [pre-treatment system] is not adequate."
Under state and federal rules, if the airport continues to allow contaminated discharges from its storm-water system into creeks and streams, according to the EPA, the board must apply for a pollution permit to discharge chemicals at the 17 main drains. The TNRCC would conduct a public hearing for such a permit, inviting the public to learn about what kind of industrial fluids DFW wanted to wash out into nearby streams. The prospect of such a politically charged spectacle, according to one professional at the airport, is so off-putting that the board wouldn't consider it.
One way that the airport board has been able to avoid some attention from the public and regulatory agencies in the past is by carefully selecting where to take their samples for water tests. Airport employees were instructed to take samples at the edge of the airport's property lines, rather than directly under where the storm-water drains discharge.
In a September 1997 report by KJR & Associates, the consultants said that must stop. "Monitoring of storm-water discharges associated with industrial activity within the creek at the property line is...incorrect," they wrote. Airport board employees now take their samples directly under the outfall's location.
The KJR consultants concurred with those who had written in the past about the flaws in the storm and wastewater systems. "The current DFW airport practice of incorporating the creeks as drainage ditches and part of the airport storm sewer system is incorrect," the report states.
In a November report the same year, the KJR consultants elaborated. "DFW personnel have observed some of these diversion boxes directly discharging to a water body during dry weather," they wrote. The consultants also warned the airport board employees that they were in for a rough ride should these issues be raised publicly. "The general public will most likely perceive the airport as 'bad neighbors,'" they wrote.
When the airport received its most recent permit in 1996 from the TNRCC for its storm-water drainage system, the board did not seek the state's OK to discharge de-icing chemicals. "It is not known why [those two potential pollutants] are omitted from the 1996 TNRCC permit application," the KJR consultants wrote.
Cox conceded he didn't know why either, although environmental affairs director De La Fuente later explained the airport had not sought a permit because the de-icing discharges were not "planned."
For a long time, however, the runoff from de-icing was not something airport board representatives wanted to talk about. That's because until recently the airport board had sidestepped the growing problem of de-icing runoff, although the TNRCC and the Trinity River Authority had both pressured DFW to take action.
Earlier this month, about half a dozen older-model vehicles sat outside a huge hole on the airport grounds, not far from the southeast holding pad, where airplanes wait for takeoff. Construction workers ate their lunches near a lean-to. Fegan, Cox, Crites, and De La Fuente stood nearby, happy to show a reporter their newest pride and joy: a de-icing fluid holding tank.
Inside the pit is an immense concrete container capable of holding 350,000 gallons. One of eight under construction at the airport, the underground tank is part of the new system DFW is spending $17 million to build to fix the problem with de-icing fluids.
Layers of ice on a plane's wings can affect aerodynamics, sometimes with disastrous results. The Air Florida crash in Washington, D.C., in 1980 that killed 74 was caused by ice. To prevent similar tragedies, the FAA has required airlines to use de-icing fluids more frequently.
Often, one plane will be de-iced two or three times before take-off. "We are seeing larger volumes being consumed," Crites says.
Compared with snowy cities such as Chicago, DFW is a piker when it comes to the use of de-icing fluids. But in some ways, that puts the airport at an economic disadvantage. Other airports can capture and recycle the chemicals and resell them. DFW doesn't generate enough volume to justify that kind of program.
But the amount of de-icing fluids is by no means negligible. The TNRCC report shows that the airport discharged about 339,592 pounds of ethylene glycol and 4,596 pounds of propylene glycol between January 1998 and January 1999. As pollutants go, according the TNRCC, the two chemicals are relatively mild. But the de-icing fluids also contain toxins such as rust inhibitors.
Crites says the airport board didn't have to spend the $17 million to solve its de-icing problem. "We had a choice. We could continue to use the existing system and keep battling it, or we could find a solution as clean as possible," he says.
The new system, expected to be completed by January, will segregate runoff from de-icings into the underground tanks. The fluids will not go to the storm-water system or the pre-treatment plant. Airplane crews will perform their de-icing tasks at locations that will operate much like a shower stall, with the fluid flowing down drains directly into one of the tanks. The airport board has budgeted $1.3 million annually to dispose of the fluids. With the tanks, DFW will be able to ensure the chemicals reach the Trinity River Authority treatment plant at acceptable levels. Isolating the fluid for a time allows some of the pollutants to degenerate by mixing with the oxygen in the water. In 1996, DFW built two large retention ponds to measure de-icing fluids that made it through the drainage system to the pre-treatment plant. The airport did not, however, have equipment in place to check the fluids that flowed into the storm sewers and out into streams.
Having a solution for its de-icing runoff problem in sight, airport officials still must face the other industrial waste escaping into the storm system. State and federal regulators have made it clear they intend to make the DFW board reveal why inspectors keep finding industrial and sanitary waste in surrounding waters.
In its October report, the EPA stated that DFW must have a special permit for its existing 17 storm-water outfalls if the airport is to continue discharging processed wastewater. The federal regulators seemed particularly unhappy in their report that DFW administrators had failed to provide any documentation for a study that airport officials said was under way about how to fix the problems. The EPA received only some of DFW's documents although it had asked for all.
"There were several concerns noted during the inspection of the Dallas/Fort Worth Airport," the EPA report states. "DFWA does not have permit coverage for any of its wastewater or storm-water discharges...even if [it] did have storm-water coverage, they would not be compliant based on the description of the makeup of the discharges currently being discharged from the storm-water outfalls.
DFW officials dismiss the EPA report. They note that the investigator did only a sight inspection and failed to do any lab testing, which scientifically undercut his conclusions.
But state regulators don't seem any more content than their federal counterparts with the airport's handling of industrial wastewater.
"DFW is going to have to determine the source," says TNRCC's Barrett. "DFW will have to investigate."
It's not as if airport board executives will have problems finding the trouble spots. Much of the documentation exists in their files. Given their level of frankness in the past, the question remains how much of that they will share with regulators -- particularly since they could face the prospect of $25,000 daily administrative fines and, if they are found to have knowingly violated the environmental rules, possible criminal penalties. There is also the question of what they have told the FAA in the past when they have sought grants to expand the airport. Did they check the standard boxes that said they were complying with environmental laws?
"I have a tendency to believe what people tell me," concedes the TNRCC's Barrett, "but if I find out you didn't tell me the truth, then I'm careful the next time."
Says DFW's Cox, "We are going to encounter some environmental hiccups. That is why we have an environmental affairs department."
