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HomeMy WebLinkAboutNC0089371_Regional Office Historical File Pre 2018PAT MCCRORY Goveywor >. DONALD R. VAN DER D ART Water Resources S. JAY ZIMME' ENVWONMENTAL QUAWY June 24, 2016 Michelle Haas City of Charlotte 600`E 4th St Charlotte, NC 28202 Subject: NPDES Electronic Reporting Requirements Lynx Blueline Extension NPDES Permit Number. NCO08937 Dear NPDES Permittee; The U.S. Environmental Protection Agency (EPA) recently published the National Pollutant Discharg Elimination System (NPDES) Electronic Reporting Rule, The rule requires NPDES regulated facilities t+ report information electronically, instead of filing written paper reports. The rule does not change u information is required from facilities. It only changes the method by which information is provided electronic rather than paper -based). EPA is phasing in the requirements of the rule over a 5-year period. The two phases of the rule, and key milestones, are. • Phase 1—Starting on December 21, 2016, regulated entities that are required to submit Discharge Monitoring Reports (DMRs) will begin submitting these reports electronically. If you are currently reporting your DR data electronically using eDM, then you simply need to continue reporting in the same way as you are now. The key change is that, starting on December 21, 2016, electronic reporting of DMRs will be required, instead of voluntary. • Phase 2 -- Starting on December 21, 2020, regulated entities that are required to submit certain other NPDES reports will begin submitting these reports electronically. Reports covered in the second phase include Notices of Intent to discharge in compliance with an NPDES general permit, Sewer Overflow/Bypass Event Reports, and a number of rather NPDES program reports. Incorporating Electronic Reporting Requirements into NPDES Permits The NPDES Electronic Reporting Rule requires authorized NPDES programs to incorporate electronic reporting requirements into NPDES permits beginning December 21, 2015. Under the new rule, the electronic reporting process supersedes the paper reporting process. According to our files, your NPDES permit became effective after November 2013, and should contain the requirement to electronically report your Discharge Monitoring Reports using NC DWR's eDMR system. In addition to requiring permittees to report information electronically, the rule also requires permittees to identify the initial recipient for the NPDES electronic reporting data (see 40 C R 122.41(l)( )j. Initial State of North Carolina j Environmental Quality i Water Resources 1617 Mail Smiee C',enter j Raleigh, North Carolina 27699-1617 919 807 6300 recipient of electronic NPDES inforn for rec submit 18, 20 L.,.::.:.._ AlriPS Y"t^ ___.,. .f.. i_..l C •!^� ;. f• a I t t ay EPA to implement the NP [see 40 CFR 12.2(b)]; Perr tion to the appropriate initi Ash on its web site and in tl recipients by Mate and by NPDES data group Once available, you can use EPA's web site to find out or determine the initial recipient of your; electronic submission. NC DWR has submitted a request to EPA to be the initial recipient for the following NPDES data groups; 1. Discharge Monitoring Reports, 2. General Permit Reports [Notices of Intent to discharge (NOls); Notices of Termination (MOTs)]; 3. Pretreatment Program Reports; and 4. Sewer Overflow/Bypass Event Reports EPA's web site will also kink to the appropriate electronic reporting tool for each type of electronic submission for each state. Instructions on how to access and use the appropriate electronic reporting tool will be available as well. For more information on EPA's NPDES Electronic Reporting Rule, visit http: /ww 2.eoa. ov cc m fiance final-naticanal- cillutant-dischar e-elimination-s stem-n des- electronic-reaort n -rule. For more information on electronic reporting to NC C WR, visit htt' : de 'nc. ov about divisions water -resources edmr rides -electronic -re orti,ng or contact Vanessa Manuel at 19-8 I7-63 2 or via email at Vanessa.Manuel ncdenr. ov. Sincerely, Je,ffre4j 0. P forS. Jay Zimmerman, P.O. Cc. NPDES File Central Files F 4iA RY Governor DONALD R. VAN DER VAART Secretary WaterResources ENVtRONMENTAL QUALITY S. JAY ZIMMERMAN Director March 9, 2016 Mr. David Wolfe Environmental Services 600 East Fourth Street Charlotte, North Carolina 28202 SUBJECT: Compliance Evaluation Inspection Charlotte Area Transit System Construction NPDES Permit NCO089371 Mecklenburg County, NC Dear Mr. Wolfe - On March 1, 2016, Roberto ScKeller, Edward Watson, and Maria Schutte of this Office conducted an inspection at the subject facility. This inspection was conducted as a Compliance Evaluation Inspection (CEI) to insure compliance with permit requirements and conditions. At the time of inspection the treatment facility appeared to be well maintained and operated. We wish to thank you and operating staff for your assistance regarding the inspection. .mow_ - - — - - - �.-- - - � -t- - . questions, please do not hesitate to contact myself of Roberto Sheller at (704) 235- 2204 or roberto,schetter@ncdenr.gov. Sincerely, W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosure.- Inspection Report cc: Joseph P. Nestor, Nesco Environmental, PO Box 78222, Charlotte, NC 28271 Wastewater Branch MSC 1617 — Central files basement State of North Carolina I Enviromental Quality I Water Resources I Water Quality Regional:Operations Mooresville Regional Office( 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 29115 7046631699 (y United States Environmental Protection Agency Form Approved, EPA Washington, tJ C. 20460 Dive No. 2040-0067 Water Compliance Inspection Report Approval expires -31-98 Section A: National Data System Coding (Le., PCS) Transaction Code NPDES yrlmolday Inspection Type Inspector Fee Type C0088371 ( 1 i 2 16/03/01 17 18 I r+ 19 1 1 � 2 15 1, 3 0 LJ Inspection Work. Days Facility Self -Monitoring Evaluation Rating B4 QA ---Reserved---- 671 7013 1 71 L_j72 T 74 Lij T( 0 Section B: Facility Data l Name and Location of Facility Inspected (For Industrial Users discharging to PtOTW, also include Entry Time/Date Permit Effective Date PtOTW name and NPDES permit Number) 11.50AM 1 103101 1 /04101 Lynx Blueline Extension Coltman Acre And Alpha Mill l.n Exit Time/Date Permit Expiration Date 12:32PM 16/03101 17106130 Charlotte NC 28206 Name(s) of Cherie Representative(s)ilittes(s)!Phone and Fax Number(s) (Other Facility Data !11 Joseph Patrick Nestor1 ORC%704-442-13651 Name, Address of Responsible {OfllcialliitletPhone and Fax Number Contacted Gravid Wolfe,600 E Fourth St Charlotte NC 282022844C1704-336-3602J7043364554 No Section C: Arias Evaluated During Inspection (Check only those areas evaluated) Operations & maintenance 11 Records/Reports in Facility Site Review in Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Roberto Schaller MRQ WQ11252- #6-64811 Signature of Management Q A Reviewer Agency/Office/Phone, and Fax Numbers Date W. Carey Basinger MRO WQ11704-235-21 41 EPA Form 366 -3 ev 9-94) Previous editions are obsolete: Page# 1 NF Section D: Summary of Fi Y tnspecttcrr Type M [17 18 I ,w. Permit: NCO089371 Owner • Facility. Lynx Blueline Extension Inspection Dates 0310112016 inspection Type: Compliance Evaluation Record KeeRing Xes Ng CIA N Are records kept and maintained as required by the permit? 11 a ® 11 Is all required information readily available, complete and current? 0 Q Q 11 Are all records maintained for 3 years (lab, reg. required 5 years)? ] Q 11 Are analytical results consistent with data reported on DMRs? 00 Is the chain -of -custody complete? a 0 CIO Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Cates of analysis Name of person performing analyses Transported COCs' Are CMRs complete: do they include all permit parameters? 11 El ©Q Has the facility submitted its annual compliance report to users and DWQ? 0 Q 110 (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator Q 11 ®' on each shift? Is the ORC visitation Cog available and current? 11 0 ©' 11 Is the ORC certified at grade equal to or higher than the facility classification? 0 ® 0 0 Is the backup operator certified at one grade less or greater than the facility classification? Is a dopy of the current NPDES permit available on site? ®11 ❑' Q Facility has copy of previous year"s Annual Report on file for review? © © Q Comment: Facili is a mobile groundwater treatment unit consistina of Dumos. air stri er and carbon filters. 'All re aired paper work is maintained off site. Effluent Pipe 'Yes Ng NA N Is right of way to the outfall properly maintained? 1:1 0 ©;11 Are the receiving water free of foam either than trace amounts: and other debris? ® 0 El Q Is the plant generally clean with acceptable housekeeping? M 0 E 11 Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable 11 0 0 11 Solids, pH, DO, Sludge Judge, and either that are applicable Comment. " If effluent (diffuser pipes are required) are they operating properly? © 0 Q 11 Comment: Page# PAT MCCRORY N DONALD R. VAN DER VAARTSecrvwq, 'at erkesources S. JAY ZIMMERMAN ENVMONMEN'rAL QUALITY Virvetor REC0VE"1?1NCDeNR/DWR February 4, 2016 FEB 5 2016 WORDS Mr. David Wolfe, Environmental Program Manager MOORESVILLF REGIONAL OFFICF- City of Charlotte 600 East 41 Street Charlotte, NC 28202 Subject: Payment Acknowledgement Lynx Blueline Extension WWTP Permit Number.- NCO089371 Case Number: 1,V-2015-0183 Mecklenburg County Dear Mr. Wolfe: This letter is to acknowledge receipt of payment in the amount of $396.97 received from you dated February 3, 2016. This payment satisfies in full the above civil assessment (s) levied against the subject facility, and this case has been closed. Payment of this penalty in no way precludes future action by this Division for additional violations of the applicable Statues, Regulations, or Permits. If you have any questions, please contact Wren Thedford at 919-807-6304. Sincerely, Wre,4A, TktAferd, Wren Thedi"ord Wastewater Branch cc: Central Files NPDES State of'North Carolina I Enviromental QtWity I Water Resources 1617 MA Service Center I Raleigh, North Carolina 27699-1617 Q1Q_1q07.A1nn A . North Carolina Department of Environment and Natural Resources Pat McCrory Donald van der Vaart Governor Secretary September 10, 2015 CERTIFIED MAIL 7015 040 002 9299 3434 RETURN RECEIPT REQUESTED Mr. David Wolfe, Environmental Program Manager City of Charlotte 600 East 0 Street Charlotte, NC 28202 SUBJECT: Notice of Violation and Assessment of Civil Penalty for Violations ofN.C. general Statute 143.215.1(a)(6) and NPDES Pennit No. NCO08 371 Lynx Bl eline Extension WWTP Mecklenburg County Case No. LV-2015-01 3 Dear Mr. Wolfe. This letter transmits a Notice of Violation and assessment of civil penalty in the amount of 36.7 (250 civil penalty + $146.97 enforcement coasts) against the City of Charlotte. This assessment is based upon the following facts: A review has been conducted of the self - monitoring data: reported for October 2014. This review has shown the subject facility to be in violation of the discharge limitations itations found in NPDES PermitNo. NCO08 371 The violations are summarized in Attachment A to this letter. Based upon the above facts, l conclude as a matter of law that the City of Charlotte violated the terms, conditions, or requirements of NPDES Permit No. NCO08 371 and North Carolina General Statute ( .S.) 143-21 .1(a)(6) in the manner and extent shown in Attachment A. A civil penalty may be assessed in accordance with the maximums established by G.S.143-215.6A(a)(2). Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the Secretary of the Department of Environment and Natural Resources and the Director of the Division of Water Resources, 1, Michael L. Parker, Regional Supervisor for the :Mooresville Region, hereby make the following civil penalty assessment against the City of Charlotte. Mooresville Regional Office Location; 610 Fast Center Ave., Suite 301 Mooresviiie, NC 28115 Phone: (704) 663-1699 E Fax. (704) 6 -6040 t Customer Service: 1-77-62 -6748 Internet, h€tp,/Iportal.nodenr,or / ebiwq An Cquai Opportunity t Aiirma#ive Actim Employer -301/6 Reryeled/10% Past Cvnsurner paper $ 250.00 For I of the one (1) violation ofta.S. 143-21 NP ?ES Permit No. No. NCO089371, by d schar i the waters of the State in violation of the permit me effluent limit for total suspended solids. $ 250.00 TOTAL CIVIL PENALTY $ 146.97 Enforcement costs $ 39 .97 TOTAIL MOUNT DUE Pursuant to G.S. 14 -215. A(c), in determining the amount of the penalty I have taken i Findings of Fact and (conclusions of Law and the factors setforth at G.S.' 143B-282.1(b) uality; All! 1111:11 1. Submit payment of the penalty: Payment should be made directly to the order of the Department of Environment and Ne Resources (do not include waiverform). Payment of the penalty will not foreclose fin-ther enforcement action for any continuing or new violation(s). Please submit payment to the attention of. Wastewater Branch Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 OR 2. Submit a written request for remission including a detailed justification for such n Please be aware that a request for remission is limited to consideration of the five factor below as they may relate to the reasonableness of the amount of the penalty assessed. Requesti . . , A - - I I - I . -1 , P - , - 1. - - -1- _A - -- A" - --! - I -, - - - -1 - -t- - - - slim, below. In determining whether a remission request will be approved, the following factors shall be considered: (1) whether one or more of the civil penalty assessment factors in G.S. 143B-282. I (b) were wrongfully applied to the detriment of the petitioner; (2) whether the violator promptly abated continuing environmental damage resulting from the violation; (3) whether the violation was inadvertent or a result of an accident; (4) whether the violator had been assessed civil penalties for any previous violations; or (5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions. Please note that all information presented in support of your request for remission must be submitted in writing. The Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of your remission request. The response will provide details regarding case status, directions for payment, and provision for ftirther appeal of the penalty to the Environmental Management Commission's Committee on Civil Please be advised that the Committee cannot consider informati remission request considered by the Director. Therefore, it is v complete and thorough statement in support of your request for issto s lommittee n that nutp art 1• t that yo • 6ulission. In order to request remission, you must complete and submit the enclosed "Waiver of an Administrative Hearing and Stipulation of Facts" form within thirty (3 ) days of receipt o notice. The Division of Water Resources also requests that you complete and submit the enc "Justification for Remission Request." Both forms should be submitted to the fallowing add Wastewater Branch Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 79- 17 OR . File a petition for an administrative hearing with the Office of Administrative In If youwish to contest any statement in the attached assessment document you must f petition for an administrative hearing. You may obtain the petition form from the Office of Administrative .Hearings. You must file the petition' with the Office of Administrative Head "thin thirty (30) days of receipt of this notice. A petition is consideredfiled when it is rec the Office of Administrative Hearings during normal office hours. The Office of A ' inista Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5.00 except for official state holidays. The petition :may be filed by facsimile (fax) or electronic' attached file (with restrictions) - provided the signed original, one (1) copy and a filing fee fee is required by NCGS §150B-23.2) is received in the Office of Administrative Hearings seven (T) business days following the faxed or electronic transmission. You should contac{ Office of Administrative Hearings with all questions regarding the filing fee and/or the det filing process. The mailing address and telephone and fax bers for the Office of Admi Hearings are as follows. Office of Administrative Hearings 6714 Mail Service Center Raleigh, NC 27699-6714 Tel. (919) 431-3000 Fax: (919) 431-3100 One (1) copy of the petition must also be served on DENR as follows: . Sam M. Hayes, General Counsel DENR 1601 Mail Service Center Raleigh, NC 27699-1601 Please indicate the case number (s found on Inge one of this letter) on the petition. Failure to exercise one of the options above within thirty (30) days of receipt of this evidenced by an internal date/time received stamp (not a postmark), will result in this mattt referred to the Attorney General's Office for collection of the penalty through a civil action Please be advised that additional penalties may be assessed for violations that occur after the review period of this assessment. if you have any questions about this civil penalty assessment Please contact staff in the Mooresville Regional Office at { ( } 663-1699. �"'�Z6- ate) Michael I. Parker, Regional Supervisor Water (duality Regional Operations Section Division of Water Resources NC 7 NR ATTACHMENTS cc. Mooresville Regional Office Compliance File w/ attachments Raleigh Compliance/Enforcement File w/ attachments Central Files w1 attachments I ATTACHMENT CASE NO. LV-2015-0183 ©utfall Date Parameter Reported Value Permit Limit 001 14131/2014 TSS 245 m /L 30 xn 1L (Monthly Avg Denotes civil penalty assessment penalty amount. r STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONI AND NATURAL RESOURCES COUNTY OF MECKLENBURG IN THE MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN OF CIVIL PENALTY AGAINST CITY OF CHARLOTTE PERMIT NUMBER NCO089371 of receipt of the notice of assessment. No new allowed after 30 days from the receipt of the no s the day of A PULATION OF FACTS ENO, LV-2015-0183 Lice of assessment. 2 BY I)U S TELEPHONE JUSTIFICATION FOR REMISSION REQU DWR Case Number.- LV- 1 -0183 Assessed Party: City of Charlotte County: ' Mecklenburg Permit Number: NCO08 371 Amount Assessed: $396.97 Please use this form when requesting remission of this civil penalty. "Re nest or Remission Waiver of Ri ' ht to an Administrative Hearij form to request remission of this civil penalty. You should attach support your request and are necessary for the Director to consider is remission. Please be aware that a request for remission is limited to cc listed below as they may relate to the reasonableness of the amount Requesting remission is not the proper procedure for contesting whethi the accuracy of any of the factual statements contained in the civil I Pursuant to N.C.G.S. ' 14-2821(c, remission of a civil penalty ma more of the following five factors applies. Please check each factor tl case and provide a detailed explanation, including copies of support factor applies (attach additional pages as needed). (a) one or more of the civil malt scssment factors in wronafullv aDplied to the detriment of the pgfig2M (th in the civil penalty assessment document); (b) the violator promptly abated coutinW enviro eutal dl violation (i.e., explain the steps that you took to correct future occurrences); (c) the violation: was inadvertent o a result of accident was unavoidable or something you could not prevent or (d) the violator had not been assessed civil penalties for an () payment of the civil penalty will prevent payment for the actions (i.e., explain how payment cr, f the civil penalty wig the activities necessary to achieve compliance). EXPLANATION:, (rase additional al pages as necessary) F - NORTH Violator: City 0 Facility: Lynx � County.. Meek] Case Number: LV-2( DIVISION OF WATER RESOURCES �SSMENT FACTORS vision WWTP rivate property resulting from the violation; o harm has been documented; he duration and gravity of the violation; he TSS monthly average permit limit was exceeded by 278.6% during the month of Octo `he effect on ground or surface water quantity or quality or on air quality, iowering their resist ance to disease, and smothering their eggs. The cost of rectifying the damage; The cost is unknown. The amount of money saved by noncompliance; The amount of money saved by noncompliance is unknown. Whether the violation was committed willfully or intentionally; The Division of Water Resources has no evidence that the violations were committed willfully or intentionally. The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; "MIM- 1MUTIMMUNVIO ) The cast to the State of the enforcement procedures. The cast to the Division of .01 11 t * . Division of Water Resour NORT WATER RESOURCES TORS private property resulting from the violation; No harm has been documented; 2) The duration and gravity of the violation; The TSS monthly average permit limit was exceeded by 278.6% during the month of(October 2 3) The effect on ground or surface water quantity or quality or on air quality; The effect on the receiving stream is unknown. Increased suspended solids (turbidity) increase' water temperature, thus reducing the amount of oxygen in water harming aquatic life. They als( reduce the amount of natural sunlight that penetrates through the water, further decreasing oxyt production and photosynthesis. In addition, high levels of solids can kill fish by clogging their lowering their resistance to disease, and smothering their eggs. 4) The cost of rectifying the damage; The cost is unknown. 5) The amount of money saved by noncompliance; The amount of money saved by noncompliance is unknown. 6) Whether the violation was committed willfully or intentionally; The Division of Water Resources has no evidence that the violations were committed willfully intentionally. 7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; There have been no previous CPAs for the Lynx Blueline Extension WWTP. 8) The cast to the State of the enforcement nroceduresa The cost to the Division of Water Resources is $146.97. ,' to Michael L. Parker, !Regional Water Quality Regional Opera Division of Water Resources, V Bell. Wes Frorm. Weaver, Charles Sent: Monday, Decembi To: joe.nestor@hotmz Cc: Hennessy, John; B, Subject: monitoring requin MEAN 015 8:13 AM for NCO089371 )m the system. me. The existence of a valid met. I hope this answers your questions. Let me know if you need additional information. Charles H. Weaver Environmental Specialist N.C. Division of Water Resources N.C. Department of Environmental Quality 919-807-6391 gchharIIes,_,weaverPncdq g DL ov_ (physical address) 512 North Salisbury Street, Raleigh, NC 27604 (mailing address) 1617 Mail Service Center, Raleigh, NC 27699-1617 fc. >^NotNn9 Compares--,,_ Ernail correspomfence to andft0177 this address is subject to the North Carolina PubficFZecords Law and nray be disclosed to third partfic',�s, ' vhat steps need to be taken before discharges may resume. ne, I will draft a letter for the City of Charlotte to sign requesting reactivatior your attention to this matter. larlotte, North Carolina 28271 CITY OF CHARLOTTE ENGINEERING & PROPERTY MANAGEMENT March 31, 201RECE1VED/NCDENR/DWR APR 12015 Ms. Marcia Allocco we is NCDENR, Division. of Water Resources MOORESVILLE REGIONAL OFFICE Mooresville Regional Office 10 East Center Street, Suite 301 .Mooresville, North Carolina 28115 RE. NOV/N — Effluent Limitations Response Tracking Numbers: NOV-2015-LV-0115 and 011 Lynx Blueline Extension NPDES Permit No. NCO089371 Mecklenburg County Dear Ms. Allocco: The City of Charlotte (City) is submitting the attached two responses prepared by the Operator in Responsible Charge (OR ) :for the above mentioned "Notices", NOV-2 1 -LV- 0015 and. 011 . The construction activities have introduced elevated sediment and pH into the treatment systems. The City is working with the contractors and ORC to control the exceedances and has implemented numerous corrective actions. As can be seen from the detailed response, numerous preventive measures have been put forth to control the exceedances. The City requests that the Division of Water Quality consider the actions taken by City to not assess civil penalties in this matter. 1f you have any questions, please contact me directly at (704) 43-212 or dpierotti(ec.charlotten . gv. Sincerely ugl 1'ierotti, LG. Sefor roject Manager City o Charlotte Engineering & Property Management Attachments: Nesco Enviro ental NOV-2015-LV-d115 —NOV/NRE Response NNesco Environmental NOV- 015-LV-011 — Effluent Limitations cc` Michael Parker, NCDENR (via email) Rusty Rozzelle MCWQP (via email) 600 East Fourth Street 1 Charlotte, NC 28202 1 PH: 704336,2291 1FAX: 704,353 047 MIMS" Environmental A Professorial Limited Liability Co y March 24, 2015 Ms. Marcia Allocco North Carolina Department of Environment and Natural Resources Mooresville Regional Bice Division of Water Resources 610 East Center Street Mooresville, North Carolina 2871 Re: Notice of Violation - Effluent Limitations Tracking Number: Nt V- 1-LV-011 Lynx Slueline Extension NPDES Permit No. NCO08937 Mecklenburg County Deer Ms. Allocce: The City of Charlotte (the "City") has received and reviewed the document referenced above (the "Notice". The City does not take the indicated Violation lightly and has taken certain mitigative steps which are documented in this correspondence. The specific violation indicated in the Notice is shown below: DATE PARAMETER REPORTED VALUE PERMIT LIMIT 11/25/2015 pH 10.9 Standard units;(SU) 9.0 SU (daily maximum) Environmental and Geologic Services PO Box 78222 Charlotte, NC 28271 + 2416 River Oaks Drive Waxhaw, NC 28173 Phone 70 -442-°1 6 + Fax 704-243-5024 Email nescoenv@carolina.rr.com Ms. Marcia Allocco CEN March 31, 201 Page The City first became aware of the pH issue can or about November 25, 2014 when pH was measured in the field. Following discovery of the pH issue, the City took steps to confirm that the pH issue existed, determine the source, ;and formulate a solution for pH reduction. The following outlines those steps: 11/24/14 - Several options were mentioned in a telephone discussion between you and Joseph P.'Nestor, P.G., P.E. (operator of responsible charge for the treatment system). 11//1 - The City collected samples from various point and levels of groundwater' dewatering and treatment processes The City discovered that water entering the wastewater treatment system was as high as 12 pH SUs. The City immediately began investigating options to mitigate the pH issue. 11/26/14 - Investigated the option of using municipal water supply to assist with dilution of recovered groundwater. It was determined that the municipal water supply was approximately 9.24 pH SUs. Therefore this would not be a viable option. 12/2/14 - Mr. Nestor was copied on an email from Mr. Steve Reid of your agency to you in which Mr. Reid indicated that the addition of carbon dioxide gas into the waste stream would be an acceptable method of adjusting the pH of the system and would not require reclassification of the treatment system. 12/ /14 through 12/19/14 — Mitigative steps were taken in the field including the collection of caisson slurry water in plastic tanks. The tanks allowed for separation of the slurry prior to the remaining treatment process. The intent was to remove the source which was causing the increase in pH levels. This method did not reduce pH to within permitted limits. 12/19/14 .-. A design and plan was finalized for the dosing of CO2 gas within the waste stream. Specialized components were placed on order to complete fabrication of the dosing system. 12/ 0/14 -- The CO2 dosing system was installed on the system and activated. Effluent samples were also collected and pH was recorded to be within permitted limits. Ms. Marcia Alloccc NCDENR March 31, 201 Page 3 Effluent monitoring performed in December 2014 did not indicate non -compliant conditionswith respect to pH Effluent monitoring performed in .January 2015 after the pH adjustment protocol was implemented did not indicate non -compliant conditions with respect to pH. As indicated by this response, the {amity took prompt actions to mitigate the pH issue once it became aware- of the issue. The actions taken by the City successfully prevented reoccurrence of the violation as indicated by subsequent monitoring data. The City respectfully requests that the Division of Water Resources considers the actions taken by the City' in its determination to not assess civil penalties in this matter. We appreciate your attention to this matter. It you have questions or comments, please contact me at (704) 442-1365. Sincerely, NESCQ ENVIRONMENTAL, P.L.L.C. Joseph P. Nestor, P.0 .; P.E. President cc: Eric Connelly — Harvest Environmental Services, Inc. (via e-mail) (donneiil@harvestenvironmental.com 1 Doug Pierotti — City of Charlotte (via e-mail) (d �erotti d ci.charlotte.r�c,us� JPNtjpni20150331 Krams" A Pr*"*MW UmfW LVW* Coff*Wy Ms. Marcia Allocco North Carolina Department of Environment and Natural Resources Mooresville Regional Office Division of Water Resources 610 East Center Street Mooresville, North Carolina 28271 Re: Notice of Violation and Notice of Recommendation for Enforcement Tracking Number: NOV-2015-LV-01 15 Lynx Blueline Extension NPDES Permit No. NCO089371 Mecklenburg County Dear Ms. Allocco- FDA PARAMETER REPORTED VALUE PERMIT LIMIT 10/3112014 Total suspended solids 245.0 milligrams per liter 30.0 mg/I JSS) (mg/1) (monthly average) En PO Box 78222 Charlotte, Phone 704- Email 0m, 3s ive Waxhaw, NC 28173 Ms. Marcia Allocco NCDENR March 31, 2015 Page 2 The City first became aware of the TSS issue on or about October 27, 2014 when it received copies of the analytical results from the commercial laboratory which performed chemical analyses of effluent samples collected on October 22, 2014. The City arranged for an additional effluent sample to be collected on October 29, 2014 in order to confirm/refute the results for the October 22, 2014 sample. The following outlines our mitigative response: Please note that all ground water from the site first entered a 25 cubic yard roll -off sediment separator that was outfitted with two (2) 100 micron non -woven filter liners. This separator was used to capture "bulk" sediment from onsite dewatering prior to treatment within the existing system. • 10/29/14 — All sediment within the separator was removed and new filter liners were installed. Approximately 9.64 tons of sediment was transported off site for proper disposal. • 10/29/14 — The metals exchange vessels and activated carbon vessels were backwashed. • 10/29/14 — Additional effluent samples were collected to confirm the effectiveness of prior system maintenance. • 11/7/14 — The media in both metals exchange vessels was removed and transported off site for proper disposal. This yielded approximately 2.64 of waste — primarily due to sediment loading. The vessels were then reloaded with 4,000 pounds of virgin media. • 11/10/14 — The media in both activated vessels was removed and transported off site for proper disposal. This yielded approximately 2.14 tons of waste — primarily due to sediment loading. The vessels were then reloaded with 2,000 pounds of virgin media. * 11/12/14 — An 18,000 gallon weir tank was mobilized to the site in order to provide greater detention time and efficiency for sediment removal. Ms. Marcia Allocco NCIENR March 31, 2015 Page 3 • 11/20/14 -- All sediment within the separator was removed. Approximately 23.97 tans of sediment was transported off site for proper disposal. • 11/25/14 — Effluent samples were collected. Analytical results indicated TSS concentration "Below Detection Limits". Subsequent monitoring of effluent samples collected in December 2014 and January 215 indicated that TSS concentrations did not exceed permit limits. As indicated by this response, the City tools immediate actions to mitigate the TSS issue once it became aware of the issue. The actions taken by the City successfully prevented reoccurrence of the violation as indicated by subsequent monitoring data. The City respectfully requests that the Division of Water Resources considers the actions taken by the City in its determination to not assess civil penalties in this matter. e appreciate your attention to this matter. If you have questions or comments, please contact me at (704) 442-1355: Sincerely,, NESCO ENVIRONMENTAL, P.I_.I_.C. Joseph P. Nestor, P.G., P.E. President cc: Eric Donnelly — Harvest Environmental Services, Inc. (via e-mail) (donne!! harvestenvironmental.com ! Doug Pierotti — City of Charlotte (via e-mail) (d 'ierotti ci.cnarlotte.nc.us} JPNlipnW150331 NWE"M North Carolina Department of Environment and Natural Resources Pat McCrory Donald van de Govemor Se March 12, 2015 CERTIFIED MAIL #7011 0110 0000 9960 7792 RETURN RECEIPT REQUESTED Mr. David Wolfe Environmental Program Manager City of Charlotte 600 East 0 Street Charlotte, North Carolina 28202 Subject- Notice of Violation and Notice of Recommendation for Enforcement Tracking Number: NOV-2015-Lei-01 15 Lynx Blueline Extension NPDES Permit No. NCO089371 Mecklenburg County Dear Mr, Wolfe. A review of the October 2014 self -monitoring report for the subject facility revealed a violation of the following parameter at Outfall 001 1 1+ Uate r-ararnleter F%t;JJ%J1 tu U%; us I I I #it 10/31115 Total suspended solids 245,0 mg/L 30.0 mg/L (Monthly average) A Notice of Violation and Notice of Recommendation for Enforcement (NOVINRE) is being issu for the noted violations of North Carolina General Statute (G.S,) 143-215. 1 and NPDES Permit NCO089371. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousan dollars ($25,000.00) may be assessed against any person who violates or fails to act in accord, with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215,1 ish To provide addit I I I ent may be prepared. - 11 1- __ ffIce within the 10- Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NG 28115 Phone: (704) 663-1699 k Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 lnternet: http1/portal,ncdonr,org/web1wq L NOV-2015-L:V-0115, Page Remedial actions, if not already implemented, should be taken to correctany problems, of Water Resources may pursue enforcement actions for this and any additional violatior violations are of a continuing nature, not related to operation and/or maintenance probler anticipate remedial construction activities, there you may wish to consider applying for a w by Consent. If you have questions concerning this matter, please do not hesitate to contact M. Marc myself at (70) 3-1 i99. incerely, K Michael L Parker, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDENR cc` R. Roelle, MCWQP Wastewater Branch MSC 1617 -- Central Files Basement -------------- CITY Of ENGINEERING & PROPERTY CHAMOTM. July 31, 2015 Mr. John Hennesy Division of Water Resources WQ Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 RE: Request to Make Permit Inactive City of Charlotte Charlotte Area Transit System Construction Charlotte, Mecklenburg County NPDES Permit No, NCO089371 Dear Mr. Hennesy, igency and there is I stem. .......... #0 9 If you have questions or comments, please contact me at (704) 432-5212 or dDierottico),charlottrc.gov. Sincerely, TH FIT RLOTTE ti' P.G. G y 1 7 1 u a Pierotti, P.G. Se '1i r roject Manager www.charmeek.org 1 600 East Fourth Straet Charlotte, NC 28202 PH 704M6A554 1 FAX: 704336.6586 North Carolina Depar Pat McCrory Donald R, Governor August 5, 2015 RECENEM Mr. Douglas Pierotti AUG City of Charlotte 600 E Fourth St Charlotte, NC 28202 MOORESVILLE Subject: Waiver of Monthly Reporting RE NPDE a Permit NCt08371 LYNX'Blueline Extension dewy Mecklenburg County Dear Mr. Pierotti: The Division has reviewed your request to suspend submission of monthly Discharge Monitori (DMR,$). t • t t s t o t t t ire eats for operator visitation, monitoring and reporting are being waived, you a 1617 Mail Service Center, Raleigh, North Carolina=27699-1617 512- North Salisbury Street, Raleigh, North Carolina 27604 Phone: 919 807-6300 J FAX 919 807-64891 Internet: www.nowaterquality.org An Equal Opportunity/Affirmative Action Employer- 50% Recycledt10% Post Consumer Paper 090ryw, IC'RR' North Carolina Department of Environment and Natural Resources Pat McCrory Donald van d Governor sl March 12, 2015 Mr. David Wolfe Environmental Program Manager City of Charlotte 600 East 4th Street Charlotte, North Carolina 28202 Subject: Notice of Violation — Effluent Limitation Tracking Number: NOV-2015-LV-01 16 Lynx Blueline Extension NPIDES Permit No. NCO089371 Mecklenburg County Dear Mr. Wolfe: A review of the November 2014 self -monitoring report for the subject facility revealed a violatiot the following parameter at Outfall 001: Date Parameter Reported Value Permit Limit 11/25/14 pH 109 SU 9,0 SU (Daily maximum) Remedial actions, if not already implemented, should be taken to correct the noted any problen The Division of Water Resources may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenar problems, and you anticipate remedial construction activities, then you may wish to consider a� for a Special Order by Consent (SOC), If you have questions concerning this matter or to apply for a SOC, please do not hesitate to c( Ms, Marcia Allocco or myself at (704) 663-1699. Sincerely, Michael L. Parker, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDENR cc: R. Rozzelle, MCWQP Wastewater Branch Central Files (MSC 1617-basement) Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 \ Fax: (704) 663-6040 k Customer Service: 1-877-623-6748 internal: http://podaLncdenr,org/webAvq An FmAl OnnnOtin1tv 1 Affifrmfivp, Anfinn Fmninvpr — 30% RPrvn1pd/100% PoRt C',nn%urnAr nanpr From: Reid, Steve Sent: Tuesday, December 02,2014 1:02 PM To: Allocco, Marcia Cc: Joseph P. Nestor, Sifford, Barbara; Berry, on Subject: RE: Classification Question Marcia - Pursuant to our telephone conversation yesterday afternoon, I have spoken with Ron Berry in NPDES Permitting, We (MR , Op Cert and NPDES) are all in agreement to leave the classification for the Lynx Blue Line permit (NCO089371) at its current level of Physical/Chemical Grade 1, Although the strictest interpretation of the Rule would warrant going to Grade 2 P/C, we are all in agreement that for this case, there is no need to elevate the classification, Also, as discussed, we do reserve the right to revisit the classification based on operations over the next few months. Hopefully, there will be no need to do so. If there are any questions, please feel free to contact me. Thanks! Steve Reid Supervisor, NC Operator Certification Program NCDENR / Division of Water Resources PH: 919.707,9108 FX:919,715<2726 steve.Leid �ncde�nr.ov htto://aartaLncdenr.orZLweb Lw admin taco or ncwater.or cent g/ww Office: 1209 - G (Archdale Bldg) Moil. 1618 Mail Service Ctr, Raleigh NC 27699-1618 Physical address; 512 M Salisbury St., Raleigh NC 27601 Emoil ce and this address is ct to the North Carohno Public Records Law and rna be disclosed to third pgrbes unless the content -------------------------------i-s--e--e--Lp--2--L-0---,-,�-C-q--tq--t-_e-,-,K-�-L---------------l-i-p-- 1-1 From:------------------------------------------------------------------ Allocco, Marcia Sent: Tuesday, November 25, 2014 8:42 AM To: Reid, Steve Cc: Joseph P. Nestor; Sifford, Barbara Subject: Classification Question Importance: High Steve, NCO089371 is a minor NPDES permit issued for the discharge of treated groundwater from clewatering activities generated through the construction of the Lynx Blue line light rail from Uptown to the University area in Charlotte. The 1 system is currently classified as a PC-1 and has air strippers, granulated activated carbon, and ion exchange noted as process treatment units to comply with chlorinated VOCs and metals permit limits before discharge to the receiving stream. Their consultant called yesterday and asked what the best foot forward would be for elevated pH characteristics that have been added to the dewatered groundwater from the boring process during construction. MR0 staff yesterday discussed and agreed with the consultant that carbon dioxide (CO2) bubbling would be the best method to adjust the pH to meet permit limits before discharge. Not all generated water would have elevated pH (highest noted was pH of 11 SU) so this would be an intermittent treatment process. Would the addition of the CO2 change the classification of the system to a PC-2? The dewatering activities are to be short-term (—6months—1 year). Could you please make a formal determination regarding the classification and issue a letter to the permittee and copy the consultant (Mr. Nestor copied on this e-mail)? I'll be in the field today on inspections (back late this afternoon) and out the rest of the week on vacation/holiday. Thanks for your assistance, Marcia .Divisionof Wow Resources Marcia Allocco, MS — Senior Environmental Specialist NC Dept. of Environment & Natural Resources (NCDENR) Division of Water Resources - Water Quality Regional Operations 610 East Center Ave., Suite 301, Mooresville, NC 28115 Phone: (704) 235-2204 Fax: (704) 663-6040 marcia.allocco@ncdenr.gov www.ncwaterquality.orq Please note that effective Oct. 15, 2013, the MRO copy fee is $0.05/page. This applies to all copies; the first 25 pages are no longer free. E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. 2 x Marcia Berry, Ron Wednesday, November 05, 2014 1:08 PM Joselyn Harriger Matt Bramblett, Allocco, Marcia; Parker, Michael; Sledge, Bob RE: City of Charlotte NPDES Permit No. NCO089371 with the legal US EPA requirements, the purpose of an NPDES permit is to provide limits and requirements )tect the surface water quality based on wastewater characteristics and the maximum discharge rate you J, and then for the Perm tree to design the necessary treatment equipment required to meet the issued NPDES i this case, the original NPDES application as defined was for a single universal mobile treatment system to be with two specific wastewater characteristics and two specific discharge locations with a maximum discharge of It was understood the treatment design would be able to handle the NPDES permit requirements at either and either wastewater characteristics. The recent approval by the Division to allow the treatment facility to be th all treated wastewater going to Little Sugar Creek is a compliance issue which should and was addressed U db di I Illeod I UlbUldlIse UI db f IV[ I-1-Ul I 1pildIlLe WILF I tft� jbbut�,u ivruca ptn ma.. ewater characteristics is a justification for the Permittee to apply for a NPDES perm permit limits as defined at Outfall 002, which are protective of the water quality standards at Outfall 001, and a and cost to obtain a modified permit would be prohibited, ory citations: Federal Clean Water Act and subsequent amendments NC Administrative code: 15A NCAC 2 B .0206 15A NCAC 2H .0100 ,ry, Engineer I of Water Resources/NCDENR (919) 807 - 6396 on. err ncdenr.&ov _ n Address - Archdale Building, Office 925Y 3alibury St. NC 27699 Address - Archdale Building, NCDENR/DWR ail Service Center , NC 27669-1617 orrespondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to ties, 1 t Good afternoon, Ron — the CA I truck wa", your inpC 001). Chu utilized. stringent compour Avenue Cutfll of 002 the e; sire; uti us to etf than suc mat !r@harthickmn.com] w9 PM it No. NCO089371 rice between the C. RC for the treatment system associated with the CATS NPDE es ille Regional Office (MRC ). As you know, the treatment system (originally L.._..y.L Ad—L— —1. ._ml J .Al._..,._...... x......... ——L*...I.. .m..._ atfall OO1. We are asking for your comment on this o the more stringent Outfall 002 effluent criteria at Cullman Avenue for constituents ICE and TCE. Matt and I would be happy to follow up with a phone call to discuss, but would also appreciate a response in writing. Thank you for your assistance. Have a great afternoon! Jocelyn Harriger, PG, Senior Project Geologist Furl & Hickman, PC 2923 South Tryon Street, Suite 190 1 Charlotte, NC 28203 Main 70 -5 6-0007 Direct 704-887-4612 1 Mobile-682-439 www,harthickman,corn From: Joseph P. Nestor [mailto:nescoenv carolina.rr.comI Sent* Thursday, October 30, 2014 8:40 AM To: Joselyn Harrigr Cc: Eric C. Connelly; Doug Pierotti; 'Rick Harrison' Subject: Re: City of Charlotte - CATS line dewatering - DMRs for September 2014 Folks, 2 Garcia alloco of nednr this morning. She said she has consulted with her superiors a] it we need to use the most restrictive effluent limits on the DMR. She indicated th dge who was the Compliance Officer for NCDENR for some time. I said I did not It the treatment system meeting the more restrictive standards for PCE and TCP n ,Toe Nestor Allocco, Marcia From: Joseph P. Nestor <nescoenv@carolina,rrcom> Sent: Wednesday, October 29, 2014 12:05 PM To: Allocco, Marcia Cc: 'Eric Donnelly'; 'Pierotti, Doug; 'Rick Harmon'; JHarriger@harthickman.com Subject: RE: Permit NCO089371 - City od Charlotte Construction Dewatering Marcia As I indicated on the voice mail message I just left you, I spoke with you last week regarding the discharges related to the Charlotte light rail dewatering project. When I spoke to you last week, I misspoke and inadvertently indicated that Outfall 001 was at Alpha Mills Drive and Outfall 002 was at Cullman Avenue. I had it backwards - Outfall 001 is at Cullman Avenue and Outfall 002 is at Alpha Mills Drive, I had thought the discharge at Cullman Avenue has the more restrictive effluent limits of these two Outfalls and suggested that we should report the most stringent effluent limits on DMRs. This is what was done for the September DMR, The effluent limits at Alpha Mills Drive are the more restrictive for the two outfalls. At the present time, extracted ground water continues to be trucked to the Cullman Avenue site from the Alpha Mills Drive site and introduced is to the waste treatment stream at Cullman Avenue. In addition, a limited amount of extracted ground water from the Cullman Avenue site is also being treated. I suggest that going forward and as long as the co -mingling of ground water from the two sites continues and is discharged at Cullman Avenue that we use permit effluent limits for Cullman Avenue (Outfall 001) for tetrachlonsethene (46 ug/1) and trichloroethene (417 ug/1) and L VTT Idt I Ildve PFPVI uj orrow morning. : you for your attention to this matter, )h R Nestor, RG., P.E. o Environmental, P.L.L.C. ox 78222 otte, North Carolina 28271 42 1365 (Office) '37 4046 (Mobile) )env @carolina.rr,com Joseph P. Nestor [mailto:nescoenv@carolina.rr.com] Friday, October 24, 2014 9:36 AM iarcia.allocco@ncdenr.gov' -ic Donnelly'; 'Pierotti, Doug'; 'Rick Harmon'; 'JHarriger@harthickman.com' ct: Permit NCO089371 - City od Charlotte Construction Dewatering Joseph P. Nestor <nescoenv@carolina.rr.com> Friday, October 24, 2014 9:36 AM Allocco, Marcia 'Eric Donnelly',- 'Pierotti, Doug';'Rick Harmon'; JHarriger@harthickman.com Permit NCO089371 - City od Charlotte Construction Dewatering Iments: 2014-09-12 Eamil regarding NCDENR OK to discharge Alpha Mills wastewater into Cullman Avenue outfall..pdf you for speaking with me this morning regarding clarification on completing DMR for this permit. ur request, I have attached a copy of email correspondence in which NCDENR provided the OK for the City of tte to transport extracted ground water from the Alpha Mills site to the treatment system which is presently J at Cullman Avenue. ,rmit lists two outfalls — 001 at Alpha Mills and 002 at Cullman Avenue. Originally, the plan was to perform ering at the Cullman Avenue site, treat this water and discharge it into Outfall 002 AND then move the treatment i (it is in a trailer) to Alpha Mills where dewatering would occur with treated water being discharged into Outfall The permit lists some of the same parameters for each outfall and also some different parameters for each . The discharge concentrations limits vary between the Outfalls an has been modified due to construction scheduling changes. In September 2014, clewatering occurred at Alpha nd extracted water was moved to the Cullman Avenue site by truck where it was treated and discharged into 1002. At one point in time, there was consideration given to moving the treatment system trailer to the Alpha ite. However, construction and dewatering moved forward and it was not possible to receive an electrical permit Mecklenburg County before dewatering activities began. I understand that since clewatering has begun, a permit struct has been issued and an electrical power drop has been installed at the Alpha Mills site. )ur conversation, I understand that I should list Outfall 002 on the DMR with flow data and analytical data which as parameters for both outfalls. I also understand that I should use the most stringent concentration limits from site on the DMR. As I indicated, I will also complete a DIVIR for Outfall 001 indicating no flow. I will also prepared r letter for the two DMR which explains this situation. s I mentioned, clewatering activities have also begun at the Cullman Avenue site earlier this week. I understand )me limited amount of water from the Cullman Avenue site has been introduced into the wastewater treatment i. Extracted ground water from the Alpha Mills site continues to be transported to Cullman Avenue for rent. The discharge during October 2104 therefore includes wastewater from both sites and is discharged into 1002. Effluent samples have been collected earlier this week. As I indicated in our conversation, I intend to -e a DMR for Outfall 002 for October 2014 which lists the parameters for both sites and lists the most stringent From either site. think I need to complete the DMR in another manner than I have indicated, please let me know. 6 P. Nestor, P.G., P.E. ) Environmental, P.L.L.C. :)x 78222 Dtte, North Carolina 28271 704 442 1365 (Office) 704 737 4045 (Mobile) nescoeny c rr lin.rr.c m 2 Rick Harmon <harmonenv@yahoo.com> Tuesday, October 21, 2014 10:51 AM Joseph P. Nestor act: Fw: NPDES Permit NCO089371 - CATS BLE (Light Rail) ird Harmon, P.G. ion Environmental, PA 3ruse Thomas Road roe, NC 28112 1764-5694 Phone & Fax f.harmonenvironmental.com Forwarded Message ----- i: Joselyn Harriger <JHarriger@harthickman,com> isommer@bbiius,com <jsommer@bbiius.com>; "adeforges@blythedevelopment.com" fora es0blvthedevelonment.com>: 'Eric Donneltv'<edonnetiv(o)harvestenvironmeat al,com> , September 12, 2014 1:37 PM t NPDES Permit NCO089371 - CATS BLE (Light Rail) )on, All — ,land work will begin Monday morning (9/15) at the Alpha Mill property. as encountered, from this excavation and haul it to the Cullman Avenue treatment system for treatment. Then haul the treated water back to Alpha Mill for discharge. However, H&H was able to gain DEN R approval to discharge treated groundwater water from the Alpha Mill property at the Cullman Avenue discharge point. The following email chain is the documentation of these approvals. Please note, if water is hauled from Alpha Mill to Cullman, the effluent sampling at Cullman will have to meet the effluent criteria specified for Alpha Mill in the permit. H&H will coordinate sampling with Harvest as needed. I will be at the Alpha Mill site Monday morning to answer questions if needed. Please let us know if need anything in the meantime. I hope this helps! Thank you, Joselyn Harriger, PG, Senior Project Geologist Hart & Hickman, PC 2923 South Tryon Street, Suite 100 1 Charlotte, NC 28203 Main 704-586-0007 1Direct 704-887-4612 1 Mobile"704-682-4394 www.harthickman.com hart icy are W, WAVM 09AWMANIA, From: Parker, Michael Sent- Thursday, September 11, 2014 9:35 AM To: Matt Bramblett Subject: RE: NPDES Permit NC O089371 - CATS BLE (Light Rail) Matt, The hauling of this non -domestic wastewater is acceptable provided all the terms and conditior thn e� lhi'a Michael P Michael P North Car Division o Water Qu 610 East Mooresvil Direct Lin E-mail coi Law andi r From: Matt Sent: Wedr To: Parker, Cc: Joselyn Subject: Rl Michael, arker NAW Itokwc" arker — Regional Supervisor arker@ncdepi.gov olina Dept. of Environment & Natural Resources f Water Resources alit? Regional Operations Section enter Avenue, Suite 301 le, NC 28115 e: (704) 235-2194 Fax: (704) 663-6040 5 unless the cor rthickman.coLm] W kTS BILE (Light Rail) lecords ulation. Per our discussion this morning, I understand that the DENR Mooresville Regional Office does not have a concern with the pumping and hauling of water from Alpha Mills to Cullman Avenue as long as the treatment and discharge of the water is in accordance with the NPDES permit referenced above. The source of this water is from construction dewatering. No domestic sewage will be hauled. I would appreciate it if you would confirm this understanding by email reply. Thanks, Matt Matt ram left, PE, Principal Hart & Hickman, PC 12923 South Tryon Street, Suite 100 1 Charlotte, NC 28203 2 'AAA '04-887-4620 1 Mobile 704-560-8009 1 Main 704-586-0007 arthickman.com 1* hickman Berry, Ron mailto-[mailto*ron. berry@ ncdenr, ov Friday, September 05, 2014 11-26 AM att Brambleft arker, Michael ,ct: RE: PDES Permit NCO089371 - CATS ISLE (Light Rail) ) confirm as far as the NPIDES permit requirements I see no issue. But as we discussed you to contact the Mooresville Regional Office about a pump & haul permit. Matt Bramblett [Mailto;MBrambleff0hartKtckman.com =riday, September 05, 2014 10:27 AM rry, Ron 3elyn Harriger -t: NPDES Permit NCO089371 - CATS BLE (Light Rail) (s, for your time this morning. Per our discussion, there are two outfall locations specified on the x permit. The contractor for the above project has asked if they can haul water via tanker from )cation (Alpha Mills) to the other location (Cullman Ave), treat the water at Cullman Ave, and arge the water to the stream via our NPDES permit. I understand that that the discharge )n is acceptable as far as the permit is concerned. However, I also understand that the DENR be approved. Please confirm my understanding and forward my email to the Regional get their take on the hauling part. ve any questions, let me know. iblett, PE, Principal kman, PC 12923 South Tryon Street, Suite 1001 Charlotte, NC 28203 -887-4620 1 Mobile 704-560-8009 1 Main 704-586-0007 tickman.com hickman *WALS="ON 3 Ac E R North Carolina Department of Environment and �I Pat McCrory Governor lyn l- arriger, Senior Project Geologist a£ & Hickman, PC:,` 3 South Tryon Street, Suite 100o rlotte NC 2203 iect: Classification of Water Pollution Control System Charlotte Fight Rail Project —'NCO0 9371 r Ms. Tarn er: ccordance with North Carolina General Statute § 90A-3' , the Water Pollution Control System rators Certification Commission is required to classify all water pollution control systems. Commission has determined that the subject facility is classified as a Grade 1 Physical - rmical Water Pollution Control Treatment System. -equired by 1 A NCAC 8G .0202 and your permit, you must designate a trade t or Higher 3ical Chemical Operator in Responsible Charge (C RC) and at least one Back-up Operator with rade I Physical - Chemical certification. Please corn lete`and return the enclosed CRC i nation Form to this office via LISPS or email to ccrtadi-ninr�r�nc lenr..yov. m have any questions concerning this classification or the designation of operators, please act me at 919.707 9108, or via email at stevexeid c ncdenr.gov. crely, nsion'Education & Training Specialist rator'Certification Program Mooresville Regional Office — B ifford via. email File 1618 Mail Service Center, Raleigh, NC 27699-1618 Location: 512 N. Sairshrory St, Raleigh, North Carolina 27888 Telephone (19) 807- 3SS Fax (919) 715-3726 Internet: http:#port 6 €ndenr orq/web/ q/&i in/taco An Equal Oproavity+' ffiarnafive AcAtonEmployer- 50�,; Pegdedi t`}%, Poi C sufn..r Parper Joselyn Harriger <JHarriger@harthickman.com> Tuesday, June 10, 2014 957 AM Reid, Steve Sifford, Barbara; Berry, Ron RE Classification of NCO089371 you, Stevel let the ORC Designation Form submitted ASAP. Thank YOU! ,n Harriger, PG, Senior Project Geologist Hickman, PC 1 292 3 South "Tryon Street, Suite 100 1 Charlotte, NC 28203 04-586-0007 1 Direct 704-887-4612 1 Mobile 704-682-4394 arthickman,com Reid, Steve [mailto:steve,reirina nrripnr,---,] Tuesday, June 10, 2014 9:47 AM 3elyn Harriger ford, Barbara; Berry, Ron ct: Classification of NCO089371 0 Ysations with the Mooresville Regional Office staff and the permit writer for the subject permit indicate we have L classified the facility. see the attached letter classifying the facility as PhysicalI Chemical Grade 1. This classification requires an ORC ation Form (attached) be submitted indicating the ORC and Back -'up ORC(s) for the permit. contact me if you have questions regarding this process and I will be happy to discuss further. s! ve Reid :)n Education & Training Specialist R / Division of Water Resources / Operator Certification Program V07.9108 FX:919.715.2726 !id2ncdenr.ggv Lortal.ncdenror web admin taco zLwqLI 1209 - G (Archdale Bldg) 518 Mail Service Ctr, Raleigh NC 27699-1618 1 address: 512 N. Salisbury St., Raleigh NC 27601 -------------------------------------------------------------------------------------------------------------------------------------- ond rn this addrfxs t() the North , sirolims Pub/ic. Records Lowand mov be disclosed to third unless tht, content is'exe(ylpt. t,�y,,F quite or otherrequta, tion. l----"--,-,---,--�--,--,,---,--",-,,-,--- ! _ �_tc ­ - _ I