NC0090123_Fact Sheet_20230412

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NCDEQ/DWR/NPDES
FACT SHEET - NPDES PERMIT DEVELOPMENT
NEW NPDES Permit NCO090123
Joe R. Corporon,P.G.,Expedited Permitting and Compliance Unit 12A r2023
Table 1 --Facility Information—Private Ownership
Applicant/Facility Morehead Tryon Land LP/Queensbridge Collection
Name
Applicant Address 150North Riverside Plaza, Suite 1800, Chicago,Illinois 60606
Applicant/Facility Anthony Scacco/William O. Frazier,P.G. [[e-mail]]
Contact Jason Anderson VP, [e-mail]] 312-788-1816
Facility Address I I I I South Trion Street, Charlotte,28202,Mecklenburg County
Project Location Charlotte Cit. b�between South Tryon/Morehead Square Drive&
East Morehead Street/East Carson Blvd; Total—2.74 acres
Terracon Consultants,Inc. M.Neal McElveen,P.E.,Principal Environmental
EAA Preparer Manager,2701 Westport Road Charlotte,NC 28208,Phone: [phone]
Fax: [phone] Email: neal.mcelveen(iDterracon.com;
Will Frazier,P.G. Project Geologist cell 336-409-0772 .
Applicant concludes that a discharge to surface-water is the most
EAA Cost Analyses viable discharge alternative based on cost. [Batch and Haul=
$275,000 and Discharge to Surface Waters=$30,661.]
EAA approved 03Dec2022. [see below, 6.01
Treatment Operator Terracon Consultants,Inc.,William Frazier,P.G.,Project Geologist
Permitted Flow(MGD) 0.075 MGD
Type of Waste Treated Groundwater(excavation dewatering)
Facility Class Physical/Chemical PC/NC County Mecklenburg
Facility Status NEW Regional Office MRO
Stream Characteristics
Receiving Stream UT to Little Sugar Creek Stream C
Classification
Stream Segment 11-137-8 Drainage basin Catawba River Basin
Summer 7Q10 (cfs) 1.5 Subbasin 03-08-34
Winter 7Q 10 (cfs) 2.3 Use Supporting No
30Q2 (cfs) 4.0 303(d)Listed? yes [2018]: DO; Fecal
Coliform; Turbidity; copper
Average Flow(cfs) — State Grid G15NE
Instream Waste IWC= 100%
Concentration [discharge to storm-sewer USGS Topo Quad Charlotte East
(1WC) % inlet="zero-flow"
conditions]
1.0 PROJECT DESCRIPTION
Morehead Tryon Land LP (Morehead Tryon or the Applicant)proposes to construct three (3)high-
rise, mixed-use towers with 2- or 3-story underground parking structures advanced below the local
groundwater table; Parcels include Nos. 123-012-02, 123-012-03, 123-012-05, 123-012-06, 123-
012-07 and 123-0140-01 located between S. Trion St/Morehead Square Dr&E. Morehead St/E.
Carson Blvd. The Applicant proposes to discharge at 0.075 GPD (estimated groundwater recovery
at 112 gpm). This is herein designated as the permitted effluent flow rate, not to exceed.
Fact Sheet--NEW NPDES Permit NCO090123
Morehead Tryon Land LP—Queensbridge Collection
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The Applicant proposes to pre-treat groundwater(est. recovery rate 112 gpm) dewatered while
excavating sub-grade concrete parking structures, to include pilons and a proposed slab located 2 ft
below the groundwater surface (est. slab area 153,900 ft2). Treated effluent is approved to discharge to
an existing stormsewer inlet by Charlotte-Mecklenburg Stormwater Services (letter dated June 6,
2022). This stormsewer inlet is designated Outfall 001 located at LAT/LONG= 35°, 13' 11"N/ 80°,
51', 04"W. Ultimately, treated effluent reaches surface waters at Little Sugar Creek, LAT/LONG=
350, 13' 2.4"N/ 800, 50', 42.3"W, as approved under this NPDES permit.
2.0 BACKGROUND
The Applicant's site-assessment identified"limited groundwater impacts" at the site, apparently
the result of petroleum release(s) from former underground storage tanks located adjacent to the
existing Uptown Cabaret, a building in the northern corner of the site.
3.0 RECEIVING-STREAM EVALUATION
Little Sugar Creek and its UTs by association are currently classified C waterbodies located within
the Catawba River Basin. Little Sugar Creek is listed by the Division as impaired [2018 North
Carolina 303 (d) List]. Established total maximum daily loads (TMDLs) include:
• Fecal Coliform
• Turbidity limit [< 50 NTU].
• Dissolved Oxygen [daily average not< 5 mg/L; instantaneous value
not<4 mg/L during 7Q10 stream-flow conditions.
In accord with statewide NPDES permitting guidance, any discharge to a storm-sewer inlet is
deemed zero flow and therefore may afford no dilution to the effluent [15A NCAC 0213.0206 (d)],
see 4.0 DWR Evaluation of Proposed Discharge.
4.0 DWR EVALUATION of PROPOSED DISCHARGE
Contaminants of Concern (COCs). The Division considered a list of COCs as site-assessment data
provided by the Applicant as analytes "believed to be present" [see EPA applications, table
Summary of Analytical results and details provided by Pace Analytical Services, LLC,page 4 of
38]. DWR has added monitoring Weekly for these organic and inorganic analytes (see permit
Section A. (L)]. Metals require effluent monitoring for Total Hardness to established compliance
with EPA guidelines for metals in dissolved fraction [see below, 9.0].
In addition to analytes "believed to be present,"DWR has added Monthly monitoring for suites of
analytes as a comprehensive spot-check for organic compounds:
• Total Purgeable Organic Compounds, EPA 624
• Base-Neutral Acids (Semi-Volatile Organics), EPA Method 625
• Total PAHs, EPA Method 8270
While site-assessment soil and groundwater analyses provide potential COCs, there are no treated
effluent data to date. Table A. (1) includes a footnote allowing the Permittee to petition to alter
parameters and/or monitoring frequency, as future data may warrant [see permit section A. (L)].
Fact Sheet
Morehead Tryon Land LP--NEW NPDES Permit NC0090123
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5.0 ESTABLISHING COMPLIANCE & PERMIT LIMITS
The Applicant proposes to discharge from an onsite Groundwater Treatment System to an established
storm-sewer inlet adjacent SE to the site on Morehead Drive. Because this outfall discharges to a
storm-sewer inlet, the Division will assume zero flow receiving-stream conditions offering no
dilution,per NPDES permitting guidance statewide. Permit limits therefore reflect Contaminants of
Concern (COCs)based on analytes identified by the Applicant as "known to be present" [See EPA
Application form 2D]. If an analyte has an established surface water quality standard, DWR has
applied this standard as "limited"both as acute and chronic [see section A. (1.)].
Reasonable Potential Analyses (RPAs) -- Current databases reflect site-assessment from
monitoring wells and soil borings only. Therefore, in the absence of treated discharge data, no
RPA was conducted.
Whole Effluent Toxicity(WET) Testing -- This facility applies granular activated carbon (GAC)
filters as a final treatment to polish its effluent. Data show that these filters likely render the effluent too
clean to support aquatic life, a portent to WET-test failure [Cindy Moore,Aquatic Toxicology Branch
(DEQ/ATB)]. Therefore,consistent with current permitting guidance,WET testing of this proposed
discharge is not required.
6.0 ENGINEERING ALTERNATIVES ANALYSIS (EAA)
The Applicant's Engineering Alternatives Analysis (EAA)notes that a"positive streamflow"
historically exists for mainstem Little Sugar Creek(see Table 1 above), but they further assert that
its "unnamed tributaries (UTs) are similarly therefore not subject to zero flow stream restrictions."
Morehead Tryon appears to assume thereby that their proposed effluent at Outfall 001 may be
afforded dilution [see EAA Terracon, Step 1., 02Jun2022]. This is an incorrect assumption(see
above section 3.0).
The application includes supporting documents from local permitting Authorities. As required of
new discharges, the Applicant has presented an Engineering Alternatives Analysis (EAA),. The
EAA considered:
• land application
• connecting to an existing WWTP
• installing infiltration galleries
• wastewater reuse
• off-site disposal via vacuum truck, and
• direct discharge to surface waters including an
evaluation of potential impacted species.
Morehead Tryon concludes that"off-site disposal via vacuum truck," and "direct discharge to
surface waters"remain as the only alternatives due to a restrictively dense urban environment
surrounding the site, and further that groundwater(treated or otherwise) is unacceptable to local
wastewater treatment plants (WWTPs). Thus, discharge alternatives are restricted to two viable
options only.
Present-Value Costs were thereby estimated for Batch and Haul= $275,000 and for Discharge to
Surface Waters= $30,661. The Applicant concludes that a surface-water discharge is the most
viable discharge alternative based on cost (see Permittee's EAA Present Value Cost, Memorandum
Step 5.). DWR concurs with this conclusion.
Fact Sheet
Morehead Tryon Land LP--NEW NPDES Permit NC0090123
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7.0 PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice: 14Feb2023
Permit Scheduled to Issue: 15Mar2023 (est.)
Effective Date O1May2023 (est.)
8.0 NPDES DIVISION CONTACT
If you have questions a ut ny of above information, or on the attached permit, please email Joe R. Corporon,
P.G. Uoe.corporon@nc enr ov].
NAME: DATE: 12APR2023
Joe R. Co poron,PG
9.0 EPA METALS EVALUATION— for TOTAL HARDNESS
NPDES Implementation of Instream Dissolved Metals Standards—Freshwater Standards
The NC 2007-2015 Water Quality Standard(WQS) Triennial Review was approved by the NC
Environmental Management Commission(EMC) on November 13, 2014. The US EPA
subsequently approved the WQS revisions on April 6, 2016, with some exceptions. Therefore,
metal limits in draft permits out to public notice after April 6, 2016 must be calculated to protect
the new standards - as approved.
Tablel. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter Acute FW, µg/l Chronic FW, µg/l Acute SW, µg/l Chronic SW, µg/l
(Dissolved) (Dissolved) (Dissolved) (Dissolved)
Arsenic 340 150 69 36
Beryllium 65 6.5 --- ---
Cadmium Calculation Calculation 40 8.8
Chromium III Calculation Calculation --- ---
Chromium VI 16 11 1100 50
Copper Calculation Calculation 4.8 3.1
Lead Calculation Calculation 210 8.1
Nickel Calculation Calculation 74 8.2
Silver Calculation 0.06 1.9 0.1
Zinc Calculation Calculation 90 81
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Table 2 Notes:
1. FW=Freshwater, SW= Saltwater
2. Calculatioj=Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life
standards for Mercury and selenium are still expressed as Total Recoverable Metals due to
bioaccumulative concerns (as are all human health standards for all metals). It is still
necessary to evaluate total recoverable aquatic life and human health standards listed in
15A NCAC 213.0200 (e.g., arsenic at 10 µg/l for human health protection; cyanide at 5
µg/L and fluoride at 1.8 mg/L for aquatic life protection).
Table 3. Dissolved Freshwater Standards for Hardness-Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph (11)(d)
Metal NC Dissolved Standard, /l
Cadmium,Acute WER*{1.136672-[ln hardness](0.041838)} •e^10.9151 [In hardness]-3.14851
Cadmium,Acute Trout waters WER*{1.136672-[ln hardness](0.041838)} •e^{0.9151[In hardness]-3.62361
Cadmium,Chronic WER*{1.101672-[1n hardness](0.041838)} •e^{0.7998[ln hardness]-4.445 11
Chromium III,Acute WER*0.316 e^{o.8190[ln hardness]+3.7256)
Chromium III,Chronic WER*0.860 e^{o.8190[ln hardness]+0.6848)
Copper,Acute WER*0.960 e^{0.9422[ln hardness]-1.7001
Copper,Chronic WER*0.960 e^{0.8545[ln hardness]-1.7021
Lead,Acute WER*{1.46203-[ln hardness](0.145712)) •e All.273[In hardness]-1.4601
Lead,Chronic WER*{1.46203-[ln hardness](0.145712)} • e All.273[In hardness]-4.705}
Nickel,Acute WER*0.998 e^{0.8460[ln hardness]+2.255}
Nickel,Chronic WER*0.997 e^{0.8460[ln hardness]+0.0584}
Silver,Acute WER*0.85 •e^{1.72[ln hardness]-6.59}
Silver,Chronic Not applicable
Zinc,Acute WER*0.978 e^{0.8473[In hardness]+0.8 841
Zinc,Chronic WER*0.986 e^{0.8473[ln hardness]+0.884}
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However,
application of the dissolved and hardness-dependent standards requires additional consideration in
order to establish the numeric standard for each metal of concern of each individual discharge.
The hardness-based standards require some knowledge of the effluent and instream(upstream)
hardness and so must be calculated case-by-case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR
122.45(c). The discharge-specific standards must be converted to the equivalent total values for
use in the RPA calculations. We will generally rely on default translator values developed for each
metal (more on that below),but it is also possible to consider case-specific translators developed in
accordance with established methodology.
Fact Sheet
Morehead Tryon Land LP--NEW NPDES Permit NC0090123
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RPA Permitting Guidance/WQBELs for Hardness-Dependent Metals -Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of
concern,based on recent effluent data, and calculate the allowable effluent concentrations, based
on applicable standards and the critical low-flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the
discharge has reasonable potential to exceed the standard, which warrants a permit limit in most
cases. If monitoring for a particular pollutant indicates that the pollutant is not present(i.e.
consistently below detection level), then the Division may remove the monitoring requirement in
the reissued permit.
1. To perform a RPA on the Freshwater hardness-dependent metals the Permit Writer
compiles the following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically
calculates the 1 Q 10 using the formula 1 Q 10 =0.843 (s7Q 10, cfs) 0.993
• Effluent hardness and upstream hardness, site-specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness-dependent metal of concern
and for each individual discharge, the Permit Writer must first determine what effluent and
instream (upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for
any hardness data and contacts the Permittee to see if any additional data is available for
instream hardness values,upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation
using a default hardness of 25 mg/L (CaCO3 or(Ca+Mg)). Minimum and maximum
limits on the hardness value used for water quality calculations are 25 mg/L and 400 mg/L,
respectively.
If the use of a default hardness value results in a hardness-dependent metal showing
reasonable potential, the permit writer contacts the Permittee and requests 5 site-specific
effluent and upstream hardness samples over a period of one week. The RPA is rerun using
the new data.
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic) _
(Permitted Flow, cfs *Avg.Effluent Hardness,mg/L)x(s7Q10,cfs *Avg.Upstream Hardness,mg/L)
(Permitted Flow, cfs+s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the IQ 10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total
recoverable metal, using the EPA Default Partition Coefficients (DPCs) or site-specific
translators, if any have been developed using federally approved methodology.
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EPA default partition coefficients or the"Fraction Dissolved"converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in-stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996)and the
equation:
Cdiss_- 1
Ctotal 1 + { [Kpo] [ss(1+a)] [10-1] }
Where:
ss=in-stream suspended solids concentration [mg/1],minimum of 10 mg/L used,
and Kpo and a=constants that express the equilibrium relationship between
dissolved and adsorbed forms of metals. A list of constants used for each hardness-
dependent metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition
coefficient(or site-specific translator) to obtain a Total Recoverable Metal at ambient
conditions.
In some cases, where an EPA default partition coefficient translator does not exist(ie.
silver), the dissolved numeric standard for each metal of concern is divided by the EPA
conversion factor to obtain a Total Recoverable Metal at ambient conditions. This method
presumes that the metal is dissolved to the same extent as it was during EPA's criteria
development for metals. For more information on conversion factors see the June, 1996
EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable
concentration (permit limits) for each pollutant using the following equation:
Ca= (s7Q10+ Qw) (Cwgs)-s7Q10) (Cb)
QW
Where: Ca=allowable effluent concentration (µg/L or mg/L)
Cwqs =NC Water Quality Standard or federal criteria(µg/L or mg/L)
Cb=background concentration: assume zero for all toxicants except NH3* (µg/L or
mg/L)
Qw=permitted effluent flow(cfs, match s7Q10)
s7Q10= summer low flow used to protect aquatic life from chronic toxicity and
human health through the consumption of water, fish, and shellfish from
noncarcinogens (cfs)
* Discussions are on-going with EPA on how best to address background
concentrations
Flows other than s7Q 10 may be incorporated as applicable:
IQ 10 =used in the equation to protect aquatic life from acute toxicity
QA=used in the equation to protect human health through the consumption of
water, fish, and shellfish from carcinogens
30Q2 =used in the equation to protect aesthetic quality
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6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of
concern. Data entered must have been taken within four and one-half years prior to the date
of the permit application (40 CFR 122.21). The RPA spreadsheet estimates the 95th
percentile upper concentration of each pollutant. The Predicted Max concentrations are
compared to the Total allowable concentrations to determine if a permit limit is necessary.
If the predicted max exceeds the acute or chronic Total allowable concentrations, the
discharge is considered to show reasonable potential to violate the water quality standard,
and a permit limit (Total allowable concentration) is included in the permit in accordance
with the U.S. EPA Technical Support Document for Water Quality-Based Toxics Control
published in 1991.
7. When appropriate,permit writers develop facility specific compliance schedules in
accordance with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to
Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium
data results may be used as a conservative surrogate in cases where there are no analytical
results based on chromium III or VI. In these cases, the projected maximum concentration
(95th%) for total chromium will be compared against water quality standards for
chromium III and chromium VI.
9. Effluent hardness sampling and instream hardness sampling,upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness-dependent metals to ensure
the accuracy of the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit
included:
Table 4
Parameter Value Comments (Data Source)
Average Effluent Hardness (mg/L) TBD
[Total as, CaCO3 or(Ca+Mg)]
Average Upstream Hardness (mg/L) TBD
[Total as, CaCO3 or(Ca+Mg)]
7Q 10 summer(cfs) 0.0 Discharge to storm sewer
l Q l 0 (cfs) 0.0 "
Permitted Flow(MGD) 0.075 Outfall 001 (per permit)
Fact Sheet
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AFFIDAVIT OF PUBLICATION
Account# Order Number Identification Order PO Amount Cols Depth
28386 379245 Print Legal Ad-IPL01084550-IPLO108455 $61450 2 24 L
Attention: Wren Thedford North Carolina } SS
NCDENR/DWO/POINT SOURCE Mecklenburg County }
1617 MAIL SERVICE CENTER Before the undersigned,a Notary Public of said
RALEIGH,NC 276991677 County and State,duly authorized to administer
oaths affirmations,etc.,personally appeared,
being duly sworn or affirmed according to law,
--- -Public Notice cloth depose and say that he/she is a
North Carolina Environmental Management Commission/NPDES Unit representative of The Charlotte Observer
1617 Mail Service Center
Raleigh,NC 27699-1617 Publishing Company,a corporation organized and
Notice of Intent to Issue a NPDES Wastewater Permit NCOM123 Queensbridge doing business under the laws of the State of
Collective The North Carolina Environmental Management Commission propos-
es to issue a NPDES wastewater discharge permit to the persons)listed below. Delaware,and publishing a newspaper known as
Written comments regarding the proposed permit will be accepted until 30 days
after the publish date of this notice.The Director of the NC Division of Water Re- The Charlotte Observer In the city of Charlotte,
sources(DWR)may hold a public hearing should there be a significant degree of County of Mecklenburg,and State of North
public interest.Please mail comments and/or information requests to DWR at the
above address.Interested persons may visit the DWR at 512 N.Salisbury street, Carolina and that as such he/she is familiar with
Raleigh,NC 27604 to review the information on file. Additional information on
NPDES permits and this notice may be found on our websfte:httpsl/deq.nc.gov/ the books,records,files,and business of said
public-notices-hearings,or by calling [phone]. Morehead Tryon land Corporation and by reference to the files of said
LP applied for NPDES permit NCO090123 for discharge of treated excavation
dewatering for proposed construction of habitable structures located between publication,the attached advertisement was
E.Morehead St.,E.Carson Blvd.and S.Tyon Drive.Charlotte.The following
parameters are water-quality limited:Total Lead,Total Barium,Acetone,Ben- inserted.The following is correctly copied from
zene,Toluene, Ethylbenzene,Total Xylenes,Methyl Chloride. Naphthalene,1,2 the books and files of the aforesaid Corporation
dichloroethane,Chloroform,and 12 dichlorobenzene.This discharge may affect
future wasteload allocations to the receiving stream, and Publication.
IPL0108455
Feb 52023 1 insertion(s)published on:
02/05/23
In Testimony Whereof I have hereunto set my hand
and affixed my seal on the 6th day of February,2023
NotaryPublic in an or the state o Texas,residing in
S
Dallas County
• '' STEPHANIE WATCHER
My Notary 10#13MYA06
b�
e Manua 14 2026
T'%irk �r S ry
Extra charge for lost or duplicate affidavits.
Legal document please do not destroy.