NC0086517_Regional Office Historical File Pre 2018 (3)

a., RAY COOPER
Governor
MI EL S. dt BAN
S'ecr°etaq
Wafer Resources LINDA C LPEPPER
Environmental`Quality of errrn ;h, ecto
February 05, 201 _ .
Mr. James C. Duncan, Chief Engineering Manager
Cousins Properties, Inc.
00 W. Trade Street, Suite 100
Charlotte, North Carolina 28202
Subject: Compliance Evaluation Inspection`
NPDES Permit NCO08651
Groundwater ltemediation
Mecklenburg County
Dear M•. Duncan:
On February 2, 2018, staff from the Mooresville Regional Office (MRCS) performed a compliance
inspection of the Groundwater Renrediation system at the subject site to determine compliance with the
permit. Enclosed is a copy of the inspection report.
The MRO would like to extendits thanks to you and. Mr. Gary Alexander of Cousins Properties, Mr.
Hunter Dicks and Leanna Muroski of AMEC Foster -Wheeler and Mr. Glen Price of Research'
Analytical Laboratories for their assistance during the site visit.
The system is online and performing at lever consist with the permit for this facility.
Should you have any questions with the site inspection report or the findings list herein, I may be reached
by phone at [phone] or email [e-mail], should you have questions.
Sincerely,
,rK
e .P
w Edward Watson, Ilydroeologist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEC
Attachment: Confpliance Inspection Report
CC Hunter Hicks, AMEN Foster -Wheeler (via email)
Glenn Price, Research & Analytical Laboratories (via -email)
MRO Files
State of North Carolina I Environmental Quality i Water Resources l Water Quality Regional Operations
Mooresville Regional Office 1610 East Center Avenue, Suite 3011 Mooresville, North Carolina 2811
704-663-I699

Ff
United States Environmental Protection Agency Form Approved.
C �,(y Washington, o.G. 20460 OMB o, 2040-0057
G Water Compliance Inspection Report Approval expires 8-3 =58
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/motday inspection Type Inspector Fac Type
1 2 Lj S 1 NCO086517 ill 121 18/02to2 117 18 191 I 20 Li
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CIA --:Reserved
1'o tl NN
1 72 1 73 74 { SQ
Section B: Facility Data 1
Name and Location of Facility Inspected (For Industrial Users discharging to POT, also include Entry Time/Date Permit Effective gate
POTW name and NPDES permit Numbed 10 OOAM 18102102 15/09/01
Gateway Village remediatlon site
..Exit Time/Date permit Expiration Date:
800 W Trade St
11 00AM 18/02102 20/0 /30
Charlotte NC 28202
Names) of Onsite Representative(s)/Titles(s)IPhone and Fax Numbens) - Other Facility Data
Tit
Tenn Fredrick Pri ORC/336.996- 841/
Name, Address of Responsible Officialf title/Phone and Fax Number
Contacted
Randall Miller,800 W Trade St Charlotte" NC 28202/Property anagerf7o4-683-01041
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
in Permit Flow Measurement operations & Maintenance in Records/Reports
Self -Monitoring Program Facility Site Review Effluent/Receiving Waters IN Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(Sae attachment summary)
Name(s) and Signature(s) of Inspectors} Agency/Office/Phone and Fax Numbers Date
Maria Schutie Division of Water Qualityf1704-66 -1699r
Edward Watson -;_. MRO GWIIf ,
Sign a�4,% ent A Reviawer Agency/OfficefPhone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

PCIE yr/molday Inspection Type (Cont.) �
1 NCO0865 t 7 if 1 12 i 8tD2102 17 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On February 2, 2018, a compliance inspection was performed by M O staff. The facility was found to
be in good order.
The facility is able to use some of the treated water for the building HVAC system, However, there is
still a certain amount of effluent water that continues to be discharged to Irwin Creek.
During the site visit, it was mentioned that the treated water may evently all be used for building HVAC
system. However, the permittee will most likely retain the discharge permit as a back-up for overflow
and storm -water events.
This permit has one outfall. The outfall discharge was observed to be clew, free of foam, solids and
odors.
Page# 2

Permit; NCO086517 owner - Facility: Gateway Village remediation site
inspection DaW 022/02/2018 Inspection Type; Compliance Evaluation
Permit
Yes Ng NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
#f Are there any special conditions for the permit?
El
11
C3
El
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
El
El
Comment: This erm#t has nos cial conditions attached. The erm#t was on site Burin
and was
ova#Table for review. i`h#s erlt does net renew until Tuna tl 22.
�k'oit K� i11t
Yes No NA NE
Are records kept and maintained as required by the permit?
9
El
0
El
Is all required information readily available, complete and current?
Are all records maintained for 3 years (tab, reg. required 5 yews)?
El
El
El
0
Are analytical results consistent with data reported on DMRs?
11
El
El
El
Is the chain -of -custody complete?
Coates, times and location of sampling
11
Dame of individual performing the sampling
11
Results of analysis and calibration
Gates of analysis
Name of person performing analyses
`transported COCs
Are DMRs complete. do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
0
0
11
0
(if the facility is = or > 5 MGD permitted flaw) Do they operate 24t7 with a certified operator
C1
El
11
El
on each shift?
Is the ORC visitation log available and current?
11
El
El
El
Is the:ORC certified at grade equal to or higher than the facility classification?
11
El
El
11
Is the backup operator certified at one grade less or greater than the facility classification?
11
®
El
EJ
Is a copy of the current NPDES permit available on site?
11
El
El
El
Facility has copy of previous year's Annual Report on file for review?
11
El
Comment: C?RC lea s were resent and able to bra reviewed. MIC? has ree:elved a co
meter invoice to veri the fletw meter was urcased within the Est ear as
of the flow
evidence
of
flow meter calibration.
C?MR records were eeviewed Burin the site visit.. The records ware found to b in toted
order. ,
Page#

Permit: NCO086517 owner -Facility.. Gateway Village remediation site
Inspection irate. 02102/2018 Inspection Type.. Compliance Evaluation
Record Kee : to Yes Na NA NE
Cabe�ratcl Yes No NA N
Are field parameters performed by certified personnel or laboratory? IN Cl C1
Are all ether paraeters(excluding field; parameters) performed by a certified tab?
# Is the facility using a contract tab?
11
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 11 El
Celsius)?
Incubator (Fecal Colifo; ) set to 44.6 degrees Celsius+/- 0.2 degrees? El
Incubator (BO ) set to 20.0 degrees Celsius +j- 1.0 degrees? E]
Comment, Laboratory regards were reviewed for 2017 during the site visit, The lab records;a ear to
be in order and anal tical anal sis are being erformed as er erit re uirements.
comment was made recrarding making notation that 'sam lea are Dreserved on ice.
0eraflons & Maintenance Yes Nos NA NE
Is the plant generally clean with acceptable housekeeping? IN C1 El
El
Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable El El 11
C1
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The faclit receives roundwiter from the two onsit sum The activated carbon
canisters rovide treatement of the oundwter. &M to indicate the s stem f#ow data
was well documented and a to date. Carbon nister manifests are ke t ofF-site. The t M
to alsrl tracks the dates of when s ent carbon is cyan ed in the vessels.
Page#
4

PA"T` MCCRORY
DONAL D R. VAN TIER VAAR"T
w
aS "G`r.*Fafi'1
WaterResources S. JAY ZIMMERMAN
ENVi RC3Atla 4NTAt_ QUALITY
Director
June 24, 2016
Barbra Harbold
Gateway Village LLG
800 W Trade St
Ste 100
Charlotte, N 82G}2 C'E
Subject: NPDES Electronic Reporting Requirements
Gateway Village; remediation site
NPDES Permit lumber: NCO08651
Dear NPDES Per ittee:
The U.S. Environmental Protection Agency (EPA) recently published the National Pollutant Discharge
Elimination System (NPDES) Electronic Reporting Rule. The rule requires NPDES regulated facilities to
report information electronically, instead of filing written paper reports. The rule does not change what
information is required from facilities. It only changes the method by which information is provided (i.e.,
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 their
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 DIVIR data electronically using eDMR 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 CMRs 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': sub nitting these reports electronically. Reports covered ill 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 other 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.
State of North Carolina I Environmental Quality I water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617

In addition to requiring permitt es to report information electronically, the
PA to be the initial recipient for the following NPDES d
rr
:es of Intent to discharge (N is); Notices of Terminatio
:s; and
Reports
toot will be available as well.
Manuel at 91.9-807- 392 or via email at Vanessa.M nuel ncdenr c�v.
Sincerely,
JeffreAj p. Pi*-f-
forS..layZimmerman, P.G.
c: NPDES File
Central Files

PAT MCCRCRY
Governor
l9ONALD R. VAN DER VAART
Secretary
. JAY ZIMMERMAN
Director'
July 18, 2016
CERTIFIED MAIL 7009 2250 0000 8087 1160
RETURNRECEIPT Q, STED
Mr. David L Edwards
Cousins Properties, hie.
00 W Tracy St, Suite 100
Charlotte, NC, 28202
Subject: Notice of Violation NOV- 016-PC-0274
Failure to Submit Electronic Discharge Monitoring Reports (eDMRS)
Gateway Village, LLC remediation site
NPDES Permit'NCO086517
Mecklenburg County
Dear Mr. Edwards:
Per the terms of your NPDES permit, you were required to register for, and begin using, the eDMR system.
y 5/2 /2016. Our records indicate that as of the date of this letter thn fihnility hn'z n-ty;4 i-'rP'l t,„+ is
not submitting data electronically;
Failure to begin submitting reports electronically is a vi latii
a possible assessment of civil penalties. In order to reduce tl
action, you must complete your registration and submit your
August1, 2016.
The Division has prepared a website devoted to all aspects o
Thank yo-u
cc: NPD S
Central
at 919-807-6307 or erelc.denard(i ncdenr;gov
your cooperation in this matter,
S' ere ,
. Jay i ertnan, PCx.
:Director, Division of Water Resources
WOMMUNWAINUNMOANNOW
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
91-7€?7-9000

6,
Nt
P(
Gt
8C
Name(
x
Htinte
Jamee
I
United States Environmental Protection A
id Location of Facility Inspected (For Industrial Users discharging to POTW, also int:
ame and NPDES Permit Number)
, Village remediation site
rade St
NC 28202
of Onsite Representative(s)/Tities(s)/Phone and Fax Number(s)
Hicks///
Duncan/t/
k MW
;envy
Form Approv
OMB No, 20,
report
Approval exp
Wing (i.e, PCS)
Inspection Type
Inspector
17 18
19
QA --Reserved-
72 I— 1 7.11 1
17A 7.q I I
Entry Time/Oate
Permit Effective Date
11.50AM 16/01127
15/09/01
Exit Time/Date
Permit Expiration Date
01:30PM 16/01/27
20/06/30
Other Facility Data
ted
se areas evaluated)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Edward Watson MRO GW///
On A Tuvia MRO WQ11704-663-1699/
Signature of Management 0 A Reviewer Agency/Office/Phone and Fax Numbers Date
W, Corey Basinger MRO WQ//704-235-21941
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete,
Page#

NPDES YrImo/day Inspection Type
31 NC0086517 Ill 12 16101/27 17 18
1 1 Li
Section D, Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Notes by Ed Watson.
A pattern was identified with regards to the on -site CRAG containers, Lab results indicate Carbon
breakthroughs on an average of 6 month intervals. Manifest for spent carbon has been request to
document disposal of spend Carbon,
There are currently two sumps in place at this site. Only one sump is currently active. The treated
water is discharged into adjacent storm drain as per the NPDES permit therefore no outfall discharge
was able to be viewed.
Page# 2

Or
PermW NCO086517 Owner , Facility. Gateway Village remediation site
Inspection [sate: 01/2712016 inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in months or less). Has the permittee submitted a new 1:1
application?
Is the facility as described in the permit? W E3 E ci
Are there any special conditions for the permit? 0
Is access to the plant site restricted to the general public? 0 El El El
Is the inspector granted access to all areas for inspection? M E El 13
Comment: A copy of the permit is kept on site.
F�ecard Kee[ ing Yes No NA NE
Are records kept and maintained as required by the permit? all 11 1-1
Is all required information readily available, complete and current? 11 M Q
Are all records maintained for 3 years (lab, reg. required 5 years)? M D 0 El
Are analytical results consistent with data reported on DI Rs? 9 El El El
Is the chain -of -custody complete? 8 El 11 El
Dates, times and location of sampling
Blame of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Blame of person performing analyses M
Transported; C1Cs
Are DE Rs complete: do they include all permit parameters? M El 1-3 El
Has the facility submitted its annual compliance report to users and DWQ? El El 0 El
(if the facility is : or > 5 MGD permitted flow) Do they operate 2417 with a certified operator El 0 0 El
on each shift?
Is the 7RC visitation log available and current? 0 W El El
Is the ORC certified at grade equal to or higher than the facility classification? 0 0 El 11
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site? 9 D El El
Facility has copy of previous year's Annual Report on file for review? 0
Comment: No t RC loas kept on site ORZgCjIggs were sent u on request. DMR for the years 201 -
2015 were reviewed. Records were well maintained..
Lat3araatClrj Yes No NA NE
Are field parameters performed by certified personnel or laboratory? W 0 ❑ E]
Page# 3

Pr
Permit: NCO086517 owner - Facility, Gateway Village reme5iation site
Inspection Gate: 01/27/2016 inspection type: Compliance Evaluation
Laboratory Yes No NA NE
Are all other parameters(excluding field parameters) performed by a certified lab? ■ El E3 13
Is the facility using a contract lab? N El 0 El
# Is proper temperatureset for sample storage (kept at less than or equal to 6,0 degrees ■
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? [l El M 13
Incubator (BOD) set to 20,0 degrees Celsius +/-1,0 degrees? 0 El a 0
Comment: Research and Anal tical perform samolinci and testing. PH calibration must e done tier #o
sam lin and calibration to s'need reflect that. Calibration to s for 111191 015 and
/27/2015 indicate PH meter was calibrated after sam lin .
Effluent Sampling Yes No NA N
Is composite sampling flow proportional" El El N 13
Is sample collected below all treatment units?
Is proper volume collected? 1:1
Is the tubing clean? 0
# Is proper temperature set for sample storage (kept at less than or equal to 6.6 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type ■ El ® `
representative)?
Comment: Research and Anal tical perform samolina and testin . Facility has: been approved to do
rub samialina.
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? N ❑ 11
Is flaw meter calibrated annually? ■ C3 13 C1
Is the flow meter operational? M ❑ 1:1
(if units are separated) Does the chart recorder match the flow meter? a Cl 0
Comment: averaae flow of 0.01 MD
C) er ti ns & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex. ML, MIT, Settleable El El ■ 0
Solids, pH, DO, Sludge Judge, .and other that are applicable?
Comment: The site has two sum s. There is ono active sum recelvin round water from the entire
acreacte of the site 4.19 AC. Flow from the sum is Dumped into two carbon filters
connected in series. Carbon in filters is replaced twice ayfeggLby Ha -Meta
Page# 4

:i
United States Environmental Protection Agency Form Approved,
EPA Washington, D-C. 20460 OMB No. 2040-0057
Water Compliance Inspection Report Approval expires 8-31 -98
Section A� National Data System Coding (Le,, PCS)
Transaction Code NPDES yr/molday Inspection Type Inspector Fac Type
2 3 NCO086517 Ill 121 16/01/27 117 18( 19 201 f
Li
211 1 1 1 1 1 1 1 1 1 11 -Li..LLLLf 6
Inspection Work Days Facility Self -Monitoring Evaluation Rating Elf QA -Reserved-
6711,0 7014 j 1 71 IN
L--j 1 72 1 N 1 731 1 174 7
80
L ---
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date
POT W name and NPDES oermit Number) 11:50AM 16101/27 15109/01
Gateway Village remediation site
800 W Trade St Exit Time/Date Permit Expiration Date
Charlotte NC 28202 01.30PM 16/01127 20/06/30
Name(s) of Onsite, Represervtafive(s)/Tities(s)/Phone and Fax Numbers) Other Facility Data
/11
Hunter Hicksffl
James Duncan///
Name, Address of Responsible OfficialtTitlellohone and Fax Number
Contacted
Randall Miller,800 W Trade St Charlotte NC 28202/Property Manageo'704-683-01041
No
Section C. Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenanec Records/Deports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
I Laboratory t
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Namels) and Signature(s) of Inspectorls) Agency/Officiellotione and Fax Numbers Date
Edward Watson MRO GW///
Or! A Tuvia MRO WQ/1704-663-1699/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger MRO WQ//704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yrlmotday Inspection Type 1
3 N oosrsl7 12 18101/27 117 18 Li
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Notes by Ed Watson.
A pattern was identified with regards to the ors' -site GAC containers. Lab results indicate Cron
breakthroughs on an average of 6 month intervals. Manifest for spent carbon has been request to
document disposal of spend Carbon.
There are currently two sumps in place at this site. Only one sump is currently active. The treated
water is discharged into adjacent storm drain as per the NPDES permit therefore no outfall discharge
was able to be viewed.
Page#

Pr
Permit: NC0086517 Owner - Facility; Gateway Village remediation site
Inspection Date. 01127/2216 Inspection Type: Compliance Evaluation
Permit Yes No NA N
{if the present permit expires in 6 months or less}. Has the permittee submitted a new [l El M El
application?
Is the facility as described in the permit? a 0 11 0
Are there any special conditions for the permit"? E 0 El El
Is access to the plant site restricted to the general public? a D 1 Cl'
Is the inspector granted access to all areas for inspection?
Comment: A CODV of the Kermit is ikept on site.
Re tx d Kee in Yes No NA NE
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg, required 5 yearn? 8 El 11 El
Are analytical results consistent with data reported on DMRs? M El El El
Is the chain-of=custody complete? 0 El El 0
Bates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Crates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters? 1:1 El
Has the: facility submitted its annual compliance report to users and l3WQ? El El 0 13
(tf the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator El 0 ■ El
on each shift?
Is the ORC visitation log available and current? ( (
Is the CRC certified at grade equal to or higher than the facility classification? El
Is the backup operator certified at one grade less or greater than the facility classification? M El 0 El
Is a copy of the current NPDES permit available on site?
Facility has copy of previous years Annual Report on file for review? 11 C1 ■ El
Comment: No {SRC leas kept can site ORC locis were sent upon re nest. DMIR for the eggs 2 1 -
2015 were reviewed. Records were well maintained:.
LAhREMcrr Yes No NA NE
Are field parameters performed by certified personnel or laboratory? M El 11 E]
Page# 3

FV
Fermi; NC008517 Owner - Facility: Gateway Uiiiee remediation Site
inspection Hate. 01/27/2016 Inspection Type: compliance Evaluation
LatgratcrrY Yes No NA NE
Are all other parameter (excluding field; parameters) performed by a certified lab? ■ El El
## Is the facility using a contract lab? N El 0'®
Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees M 0
Celsius)?
Incubator (Feel Coliform) set to 44,5 degrees Celsius+/- 0.2 degrees? 11 El 0 El
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? 13 0 0 13
Comment, Research and Analvitical perform samDlina and testiri . PH calibration must be done ricar to
sampling, and calibration logs need reflect that. Calibratio lci s foot "111"lgl2tl15 acid
2/27/2015 indicate PH meter was calibrated after sam lin
Effluent Sampling Yes No NA NE
Is composite sampling flaw proportional? 1:1
Is sample collected below all treatment units? M El 1 13
Is proper volume collected? M El E 13
Is the tubing clean?
Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment: Research and a
rub sa lino .
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting?
Is flow meter calibrated annually? N El ® E3
Is the flow meter operational' 0 13 E3
(If units are separated) Does the chart recorder match the flow meter? a El El ,
Comment: average flow cif Cl.c}1 MGD
paeraticin s & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ® 0 El 13
Does the facility analyze process control parameters, for ex. MLSS, MCRT, Settleable [l
Solids, pH, DO, Sludge ,fudge;; and other that are applicable?
Comment: The site has two sumDs. There is one active surnD receiving round water from the entire
acreacie of the site, 4.19 AC. Flow from the surno is Dumped into two carbon filters
connected in series. Qarbion b filters is re laced twice a ear Hai -Met:
Page# 4

PAT DUICCROStY
:° +K
N *,A9'N DER '
. 0-W`W
Water Resoarces S. JAY ZIMMERMAN
February 3, 201
Mr; James C. Duncan, thief Engineer Manager
Cousins Properties Inc.
800 W. Trade Street, Suite 100
Charlotte, NC 28202
Subject: Compliance Evaluation Inspection
Gateway tillage
Ground water remediaton
NPDES Permit No NCO08 517`
Mecklenburg County,
Clear Mr. Duncan:
Enclosed is a copy of the Compliance Evaluation Inspection for the Inspection conducted at
the subject facility on January 27, 201E by ©ri Tuvia and Ed Watson. Your cooperation during the
site visit was much appreciated. Please advise the staff involved with this NPDES Permit by
forwarding a copy of the enclosed report,`
As was discussed on site please have QRC logs available for inspection during future
inspections.
Additionally, PH calibration must be done prior to sampling, and calibration logs need
reflect that. Calibration logs for 11/19/2015 and 2/27/2015 indicate PH meter was calibrated after
sampling.
The report should be self-explanatory; however, should you have any questions concerning
this report, please do not hesitate to contact (ri Tuvia at [phone], or at
o>ri.tuvta ncdenr, ov
Sincerely,
Carl Tuvia, Environmental Engineer
Mooresville Regional Office
Division of Water Resources, DEQ
Cc. NPDS (Derek Denard)
MRO Files
Hunter Hicks, PE (E-Copy)
Mooresville Regional Office
Wallow 610 East Center Ave., Suite 301 Mooresville, NC 28115
Pha n: [phone] \ Fax, (704) 6 3-6040 \ Customer SeMoe:1-877-623- 748

NPDFS yr/mo/day Inspecton Type
NCO088517 11 12 16/01127 17 18
Nc
A pattern was identified with regards to the on -site UAC containers. Lao results inatcate Qaroon
breakthroughs on an average of 6 month intervals. Manifest for spent carbon has been request to
document disposal of spend Carbon.
There are currently two sumps in place at this site. Only one sump is currently active. The treated
water is discharged into adjacent storm drain as per the NPDES permit therefore no outfall discharge
was able to be viewed.
Page# 2

Permit: NCO086517 Owner - Facility: Gateway Village rernadlation site
Inspection Clete: 01/27/2016 Inspection Type. Compliance Earalustlon
Lab=tor Yes Nor L46Nt
Are all other parameters(excluding field parameters) performed by a certified lab? 11 0
# Is the facility using a contract tab? 11 0 ® Q
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 Q 1113
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? 13 ❑ IN 11
Incubator (BOO) set to 20.0 degrees Celsius +/-1.0 degrees? © El 11 d
Comment: Research and Lnglytical ogrforml gam2fing and to tint . PH calibration mint a donne Prior to
semolina. and calibration loos need reflect that. Calibration loos for 11/19/2015 and
2t27/2O15 indicate PH meter was calibrated after sampling,
Effluent SgMpfing' Yes No NA NE
Is composite sampling flow proportional? © [ 0 El
Is sample collected below all treatment units? 11 0 El 0
Is proper volume collected? 11 ® © El
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 60 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type N 0 El 0
representative)?
Comment: Research and AnahttiCal Derform samplingand testing. Facility has been aoDroved to do
rub sampling.
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(if units are separated) Does the chant recorder match the flow meter? 11 ® 0
Comment: avers a flow of 0.01MGD
Qgerplion§ & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 11 © El El
Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The site has two sum s. There is one active SUMD receiving, round water from the entire
scree e of the site .19 A. Flow from the SUM2 is 2UMged into fwo 2arbon filters
connected in serlea. Carbon} in filters is replaced twice a year by Haz-Met.
Page#' 4

OT
b
q
cord
Pips No., Month e r:
bons
ar.
1
�- t .�

y '
Permit N .O086r517
a
x
PART
A. (I.) EFFLUENT ITA ." S AND MONITORINGS
[I5A NCAC 02B.0400 et seq., 02B .0500 et seq.]
Luring the; period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge treated groundwater via Clutfall 001. Such discharges shall be limited, monitored and
reported' by the Permittee as specified below.
777
7777777777777
EVIF T L eJ . i 1 fJ $ �Os �Tz
s
rAI
t
� �
Ai�et.. l'ax�nrii�
�t"d✓C�i�t'iI1C'� ,
', �.rtDCtl�id
Flow 2 (MGD) 50050 0.05 MGU
Weekly
Instantaneous 2 Effluent
Total Suspended Solids `0530 30.0 mg/L 45. m L
Monthly
Grab Effluent
(T ) Mg/L)
pH (su) 00400 Not < 6.0 or > 9.0 standard units
Monthly
Grab Effluent
Tetrachloro thene (l'CE) ` 78389 3.3 pg/l, 3.3 µg/L
Monthly
Grab Effluent
1,2-cis-dichloroethene 3,4 81574 720 p /L 720 l 1L '
Monthly
Grab Effluent
Chloroform 3,4 (ttgfL) 32106
Quarterly
Grab Effluent
1,2-dichloroethane 3,4 32103
Quarterly
grab Effluent
Trtchloroethene (TCE) 314 7831
Quarterly
Grab Effluent
\Oil
anbd Gy,r(eyyas��e^^qq(mv.n/L) 00556
Quarterly
Grab Effluent
�
.0 .:S�`atAPod.A6V"#rIV A" tvA _
Total Copper 4 qt ) 01042
Quarterly
Grab Effluent
Total Lead 4(pgfL) _ 01051
Quarterly
Grab Effluent
Total Zrac 4 (pgfL) 010
Quarterly
Grab :Effluent
Total 1,ron 4 (µg/L); 01045
Quarterly
Grab Effluent
Total Manganese ([tg1L) 01055
Quarterly
Grab Effluent
P3B
Chronic Toxicity 5
Quarterly
.grab Effluent
i.H B
Footnotes:
t
2.
i ion's eDMR application system [see A. (3.)
•d.
luarterly;Acute Toxicity.
Conditions:
• There shall be no discharge of floating solids or foam.
• Discharge shall show no evidence as a source for oily film or sheen on the receiving stream.
Page 3 of 6

NPI)ES PERMIT NO.: NCO086517 PERMIT VERSION: 4.0
FACILITY NAME: Gateway Village remediation site CLASS: PC-1
OWNER NAME: Gateway Village LLC ORC: Glenn Fredrick Price
GRADE: PC-1 ORC HAS CHANGED: No
eDMR PERIOD: 07-2016 (July 2016) VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Mecklenburg
ORC CERT NUMBER: 29858--0—Q?ECMVED/NCDENR/rJWR
, U
STATUS: Processed A I It 3 {
WaPlos
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NODISCHAtift4�'-�NoEr-",!-(,�'��OKAl..Olf�!
ex
m
z
0
0
%;ac
0
6
z 9
50050
00400
C0530
32103
32106
THP38
77093
01042
01045
Weekly
Monthly
Monthly
Quarterly
2.1tefly
EoL�Ilhly
Monthly
--ftelly
Quarterly
Quarterly
FLOW
Grab
pH
Grab
Tss - Conc
Grab
1,2-DCU
Grab
CHLRFORM
Composite
CER7DCHV
_Grab
C-1,213CE
Grab
COPPER
firab
[RON
71-400
clock
Hrs_
1400 clock
Firs
Y/B/N
1
0.0013
2
L1,00 13
0.0013
4
0n013
W 5ec
=71!
5
0.0013
0.0013
#I.--
—0(w
—25
0,0013
t
C',
I
0
y
0,00 1
4- - �F
aa_
LI-100,
10
0t)007
12
0,0007
13
0846
0.25
y
0.0007
14
4-5—
0.0011
17
0,0011
18
0,0011
19
1120
0.50
y
0.0011
< 5
11
1
<1
1060
49
20
0.00085
.681
21
0.0008,
22
23
—2-00015
24
25
0.00085
26
0,00085
27
0954
0.25
B
�) 0008� 0085
28
000011
29—
0.00011
— 0.0001
-.221111
31
Monthly Average Limit.
0.00011
0
it)
720
—
Monthly Average:
—
0,000895
—
—
0
—
0
1
0
1060
49
Daily Maximums
Daily Minimum
On013
10,00011
6.81
0
0
1
-------
0
0
1060
49
**** No Reporting Reason: ENFRUSE = No Flow-Reuse/Recycle; ENVWTHR No Visitation - Adverse Weather; NOFL,OW = No Flow; HOLIDAY = No Visitation Holiday

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TYPICAL PROPERTIES Safety Mate. tinder certain conditions, some compounds may
!¢¢LLxx,,oxidize, decompose or polymerize in the presence of activated
Ul*"w' $M1`l5hr# f4
Para silt
carbon causing a carbon bed temperature rise that is sufficient
z a r to cause ignition, Particular care must be exercised when
C Coconut Coconut Coconut Carbon Type compounds that have a peroxide -forming tendency are being
Shed Shell Shut
w S isle s(' f r " x 4 g + x y s adsorbed. In addition the adsorption of VOCs will lead to the
T . generation of heat within a carbon bed. These heats of reaction
Effective Size, MM 0.8 -1.1 0,6 M o.85 ` 0,55 - 015 and adsorption need to be properly dissipated in order to fully
rU
tta�if bait( ffrr.; i d assure the safe operation of the bad.
'� .. A.
3P k D a y 9
(Net activated carbon readily adsorbs atmospheric oxygen,
Iodine No, rog C 1g 1100 1100 1100 Dangerously low oxygen levels may exist in closed vessels
it 7
s` ,.5¢.
Her le k Nit f� ` or poorly ventilated storage areas, Workers should follow all
a, . .. ._.a
Abrsisn o { Wt. B5 B5 applicable state and federal safety guidelines for entering
r a i oxygen depleted areas.
�Al�t��rei1 ahsif� gl�e ;i�ft�f4 Q^rili�2 046 fk5�2k
Water 5uluble itsh, t °� 2 2'
Downflow Pressure Drop Through Downflow Pressure Drop Through
A Backwash d and Stratified Bed A Backwashed and Stratified Bed
LL �
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0 p
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Superficial Velocity, GPN11F?
Superficial Velodty, GPtFr
—°"� AquaCerbO 1230C AquaCarb(10830C-55"
AquaCariile 1230C — AquaCarbv $30C-701 '° AquseCada"3240C-5S"F AquaCaeb"124OC-70'F
Percent Beef Expansion During Backwash Percent Bed Expansion During Backwash
60- to
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4b
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10 ID
0 CA" ti
0 is B 90 1 14 16 iB 2ti 0 2 4 6 8 10 12
Supertleiui Velocity, GPWFT2 j
— AquaCa t 1230C -- AquaCarb* 830C -55° superficial Velocity. GPMIFT}
*"w- AquaCarlill 1230C — AquaCarbO 830C -70" "` AquaCarb*1240C-SS"F .*- AquaCatb*1240C-70°F
I'
` 181 thorn Hill (toad, Warrendale, PA IS086
voQUA +1(866) 926.8420 (toll -free) [phone] (tell) wrism eYCdqLii't..Ct` m
WATER TECHNOLOGIES
AquaCab and S4eestatcs are trademarks of Evoqua, its subsidiaries of affiliates, in some countries.
All iaformatiter presented herein is ueldeved rehablc and in accordance with accentederagirioormg otacticas, boqua makes rio
waerantits as to the completeness of this informal on. Users are resporivine for evaluating individual product suitability fur
specific applications. Evoqua assumes no liability whatsoever for any spa, at, indirect or consequential damages arising, your :he
,. Salt. resales or imause of its product's.
2015 Evoqua Water Technologies t„LC Sublect to change without notice WS-AQt2-05-0815-

Carillon Groundwater remediation
system
JANUARY 27., 2016 SITE VISIT AND SYSTEM INSPECTION
ffid
oundw
Travis met us at the office and we reviewed the rernediation system. The waste carbon is extracted
through an extraction port that is connected to the top of the Carbon canister to allow for easy
extraction of the spent Carbon. The system is set up as an in -line two canister system which allows one
tank to perform extraction of solids and the second tank to act as a polishing tank. The system is
reversible to allow for the tanks to be reversed to allow for extraction of the spent Carbon in the lead
tank making the second tank the primary tank. The system has sample ports that allow for mid -point
sampling which helps with monitoring breakthrough of constituents in the activated Carbon in the
vessels. A copy of the spent Carbo Manifest was provided to see the spent Carbon was being properly
disposed of by Evoqua and a copy of the 10/28/2015 manifest was provided. The files were up to date
and in order. Samples are able to be extracted at the mid -point of the in -line tanks and at the end of the
treatment. Because the travel distance of the system drain line, we were not able to view out -flow that
empties into the n-named tributary to Klein's Creek,

Gaway Villaae
On January 27, 2016 during inspection, NCDEQ requested linear -footage of piping system. This was decided to be 75% of parcel
acreage.
Parcel 078-124-02 has 5.586 AC listed for land area (75% being 4.19 AQ
IMP
011
Nk
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IN, A4,
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00)

r
NCDIWR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
June 3, 2015
r. David L. Edwards
Cousins Properties, Inc.
00 West Trade St, Suite 100
Charlotte, NC 2820
Subject. Draft NPDES Permit NCO086 17
Gateway Village, LLC
Gateway Village Groundwater Remediation'
80 block of West Trade Street, Charlotte 202
Mecklenburg County
Dear Mr. Edwards:
In response to your request to renew the subject NPDES permit, the Division of Water Resources (DWR or the
Division) hereby transmits this draft for your review and comment. Please review this document to assure your
understanding of the permit limits and monitoring conditions, and to correct errors, if any.
The Division understands that you have made no significant changes to your facility the last permit renewal. We
have made the following updates to your previous permit:
• added updates to facility map, outfall locations and parameter codes
• updated Tetrachloroethene (PCE) limit to 3.3 Ig/L in accordance with current human health standards
• updated 1, -cis-dichloroethene limit to 720 µg/L in accordance with current human health standards
• for Oil & Grease, please note that [0055 ] remains the same for submitting DMR/eDMR, but use test EPA
method 1664 (GT-HEM) with results in mg/L.
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that,
if a state does not establish a system to receive such submittals, then prmittees must submit DMRs'electronically to
the Environinental, Protection Agency (EPA). The Division anticipates that these regulations will be adopted and is
beginning implementation:
The requirement to begin reporting discharge monitoring data electronically using the NC D 's Electronic
Discharge Monitoring Report (eDMR) internet application has been added to your NPDES permit. [See Special
Condition A. (.)] For information on eDMR, registering for eDMR and obtaining an eDMR user account, please
visit the following web page:
htt :// ortal.nedenr.or web/w /admin/bo i u/edmr.
For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the following web site:
htt ://www2.e a. ov/com UAncel ro used-n des-electronic-r ortin -rule.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone]nternet: vxsvcN.ncwaterquality,or
Are Equal Opportunity i Affirmative Action Employer - Made in, part by recycled paper

r. Edwards
June 3, 201
Page 2 of 2
Concurrent with this noti
newspapers Having crcu'
provide your comments, `
on will solicit public comment on this draft by publishing a notice in
I Mecklenburg County area, as required by the NPDES>Program. Please
nail [derek,denard@ncdenr gov] or write to my attention care of LENR /
DWR / NPDES Program no later than July 10, 2015. Your written comments are welcome but not mandatory.
Following the mandatory 30-clay public comment period, the Division will review all 'pertinent comments on your
permit draft, and take appropriate action prior to issuing your NpDES permit final. If you have questions concerning
this draft, please e-mail me or call my direct line (919) 07-6307.
Sincerely,
Derek Denard, Environmental Specialist
Division of Water Resources, NCDENR:
Enclosure': NPDES Permit NCO08 517 (renewal DRAFT)
he: NPDES Program Files [draft permit and Fact. Sheet]
ec: MRO /Michael Parker;[ icha l.par er(a ncdenr,gov] [draft permit, Fact Sheet]
MRO / Wes Bell [wes.bell c(�}r,ncdenr.gov] [draft permit, Fact Sheet]
Richard Farmer [Richard.farmer@meekienb r county c.gov] [draft permit, Fact Sheet]
'Wastewater Operator Certification Croup / Steve Reid [steve.re d c@+ ncdenr.gov] [draft permit, Fact Sheet]
Aquatic Toxicology Unit/ Susan Meadows [susan.meadows [e-mail]] [draft permit; Fact Sheet]
[e-mail]
[e-mail]

Permit NCO086517
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER. RESOURCES
RECEIVED/NMENWOWR
PERMIT JUN 9 2015
WOROS
MOORrESVILLE REGIONAL OFFICE
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE E ELIMINATION SYSTEM
( DES)
In compliance with the provisions of North Carolina; Caen -215.1, other lawful standards
and regulations promulgated and adopted by the North., ental Management
Commission, and the Federal Water Pollution Comr, U � t ,' as ende�� ;
�Rh
1 Yi
Gateway ge, L � �
z✓' rt
G E•� i
is hereby authorized to 3 urge waste w a facility located j <the
3N� `
�s�r�ll
Gateway ���g�4�,� site
Ct bl st�catte 222
�h ��
� ��.
s IOU }
�`�ti`stu
to re oivin e "` as a ec � kJnna ed Tributary to Irwin Creek in the
Catawba t .
Basin in ac ce �� ffihent lr tzons, monitoring requirements, and other
conditions s h in Parts I,' 1. an F ereof.
The permit shall bccorr cti e 2015.
This permit and the authc r ati o discharge shall expire at midnight on June 30, 2020.
Signed this day , 2015.
..lay Zimmerman, Director
Division of rater Resources
By Authority of the Environmental Management Commission
Page I of

Permit NCO08 51 i
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises under the permit
conditions, requirements, terms, and provisions described herein.
Gateway Village, LLB'
is hereby authorized to. 1. ,
4
1. continue operating a 0.05 MGD groundwater remedaa � i ift includes the following
components;
y; t
..s��,�zzi
• 1200 gallon collection tank with .amp t L � o-g
Ite
• two (2) bag filters
« two (2) 1000 lb activated carbon canisters ��erres} ,4
­1
• effluent meter with recorder yz,rt 010, � `'
ffia
00
located at the Gateway Village rem � -'Ri
s=, fe, a b '` of West Trade Street, Charlotte, in
I'M111
v 5 t s
Mecklenburg County, and
L4
WOM
. discharge from said treat `" wo _,t utfall' at a location specified on the attached map, into
are unnarxa� to lr Se` ttt 11-171 currently a Class C waterbody
within �n {7S1C� awba River basin
s
�iI
n
q�tW,
l
is On,
t t1i�Lw A�2 �ti:
a
has;
Page 2 of

Permit NCO08651 i
ART
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[ t 5A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge treated groundwater via. C utfall 001. Such discharges shall be limited, monitored and
reported' by the Permittee as specified below:
r f Y S tit` tr
Flow 2 (MGD) 500.50 0.05 MOD ,������ ��� € ekly Instantaneous Effluent
Total Suspend
(TSS) (m1L) ed Solids C0530 3t).0 mglL L Mori Gran Effluent
3„} ,
p (su) 00400 Not < 6,0 or > ,�f, .. lord units Ivtonth1v � � Grab Effluent
Tetrachloroethene (1'CE)3, 7133r49 ltf/L}'/L x monthly Grab Effluent
1,2-cis-dichloroethene3, 8157��� 72Q }�Y Monthly t`rrab Effluent
). ... �.,1
{ i 3t f ini.4i
Chloroform 3(Irk)
,4 L 3210E ' tY r} Quarterly Grab Effluent
,a
12-dichloroet ane 3,4 _ to
3��i�t{ rly Grab Effluent
14111
Trichlorooethene (TCE) 3,4 �f � � 2001 n
83133 ,€ U�arterly grab Effluent
Oil and Grease ( g/L)%W „ Quarterly Grab Effluent
IT n. hd..s4 —A 144A Qtl.'r LIVIId7 t3a.a,., ,,
TotalCopper 4LtjAffi,'��r #>01Y�� Quarterly Grab Effluent
z z
�;€� t}51i Quarterly Grab Effluent
Total Lead �� Le�t'h Ord s f
Total Zinc
Quarterly Grab Effluent
Total Iron f {lig��. i.{f 01tf � Quarterly Grab Effluent
Total Manganese ` {' 01055 112�� ,., Quarterly Grab Effluent
cm
Chronic Toxicity ` €� TG1'3f313 h^ P313 Quartrly Grab Effluent
s
TF1z�sf ;,
Footnotes: { 4
I. No later than 270 days froctive date of this permit, the permittee shall begin submitting discharge
monitoring reports electronically using the Division's eDMR. application system [see A ;(3.)]
. Flow must be determined by an effluent meter.
3. A minimum detection limit of l .O g/l is required.
4. This sample to be collected concurrently with quarterly Acute "Toxicity.
5. Chronic' Toxicity (C r aphnia) limit at 90% with testing in January, April, July and October [see A. (2)],
Conditions:
• There shall be no discharge of floating solids or foam.
• Discharge shall show no evidence as a source for oily film or sheers on the receiving stream.
Page 3 of 6

Permit NCO086517
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
[I 5A NCAC 02B .0500 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubid at an effluent concentration of 90%.
The permit holder shall perform at a minimum, qyqLterl y monitoring using test procedures outlined in the"North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions
or "North Carolina Phase 11 Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 20 10) or
subsequent versions. The tests will be performed during the months of January, April, July and October.
These months signify the first month of each three-month toxicity testing quarter assigned to the facility.
Effluent sampling for this testing must be obtained during representativj�,cent discharge and shall be
performed at the NFIDES permitted final effluent discharge below alIxA,
rent processes.
Ad
�s -s
Nif;tcW It in a failure or ChV below the
If the test procedure performed as the first test of any smj1,!4Wf g s
permit limit, then multiple -concentration testing shall pil formed in each of the two
g
Chronic Who following months as described in "North Carolina P] NVI, uent Toxicity Test
Procedure" (Revised -December 2010) or subseque 'ions
All toxicity testing results required as part of this permit n wjj,,,,,,'1 ntered on ti�ftr cent Discharge
n" Wi code TGP3B for
Monitoring Form (DMR-1) for the months * 11which tests
J#4�4 , ich wen ' d, using the para
the pass/fail results and THP311 for the ChA,i kdditim.
iRye. Wit Form AT-3 (original) is to be sent to
the following address:
um
in
t
Attention: Divis ,,,,,,,,rth i o �,aWwater Resources
Sci tion/ .... . . .. .... Toxicology Branch
14 aior
Role-1623 Caro 7699
"No
Completed Aquatic Toxicity e iled i e Iater Sciences Section no later than 30 days after
the end of the rea rind 4,
""
g
Test data A, ' complete, all so hernical/physical measurements and all
concentratici once data, Aa laboratory 'supervisor and ORC or approved designate signature.
u
Total residual ne of the effl, ci le must be measured and reported if chlorine is employed for
w
W,
disinfection o e stream.
f the am, 11111\1 P
OR b"
Should there be no disc of flow f, the facility during a month in which toxicity monitoring is required,
the permittee will corriple .,into located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit no r, county, and the month/year of the report with the notation of "No
Flow" in the comment area of The report shall be submitted to the Water Sciences Section at the
address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month. Assessment of toxicity compliance is based on the toxicity testing quarter,
which is the three month time interval that begins on the first day of the month in which toxicity testing is
required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include afterriate monitoring requirements or limits.
Page 4 of 6

Permit NCO086517
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum: control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month ofthe initial monitoring.
A. (3.) ELECTRONIC: REPORTING OF DISCHARGE MONITORING
REPORTS G.S. 1-215.1(b) ]
Proposed federal regulations rewire electronic submittal of all discharge monitoring reports (DMRs)
and specify that, if a state does not establish a system to receive s submittals, then permittees must
submit DMRs electronically to the Environmental ;Protection (EPA}. The Division anticipates
that these regulations will be adapted and is beginning amply Lion in late 2013.
211
ern
-RI
NOTE: This special condition supplements or supers tic follows $ ; ections within Part 11 of this
permit (Standard Conditions' for NPDE ` Permits) $k '
3
• Section B. (11.) Signatory Requirements w {
+� Section D. (2.) Reporting t ��
Section D. (6.) Records Reten
• Section E. (5.) Monitoring Re
p�
1. Revortin2 ISuversedes Section a,
Beginning no later th rom the city s pehat, theperrnittee shall begin
reporting discharge oring �eltront the ` t�UR s Electronic Discharge
Monitoring Report (e } intern% ppltcatio ti*.yV Sup. 6
NQ
Monitorius m (s) shall be summarized for each month and
submitt fob ;� sing R. Tl em allows permitted facilities to enter
monit TMF I"IRWronica "ing the internet. Until such time that the state'
eDMR anon is com' t wzi" s Cross -Media Electronic Reporting Regulation
(CR( MEertnittees wi g requi ���� a submit all discharge monitoring; data to the state
electronically' eIMR an c 'O p y printing,
11 be re � ° trod to complete the eDMR submission b
signing, and sub tag one sag 5\; original and a copy of the computer printed eDMR to the
following address'` `
NC DENR t DWR I Info a Processing Unit
ATTENTION: Central Fit ,S eDMR
1617 Mail Service Center
Raleigh, North Carolina 27 -1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR fo s (MR 1, 1. 1, 2, 3) or
alternative forms approved by the Director. Duplicate signed copies shall be submitted to the
mailing address above.
Page 5 of 6

Pe it NCO 865 i
Requests for temporary waivers from the NPDES electronic reporting requirements must be
submitted in writing to the Division for written approval at least sixty (60) days prior to the date the
facility would be required under this permit to begin using eDMR. Temporary waivers shall be valid
for twelve (1) months and shall thereupon expire. At such time, DMRs shall be submitted
electronically to the Division: unless the permittee re -applies for and is granted a new temporary
waiver by the Division.
Information on eDMR and application for a temporary waiver from the NPDES electronic reporting
requirements is found on the following web page.
hit l/ ortal.ncdenr.or web/ /admin/bo /i a/edmr
gmg
Regardless of the submission method, the first DMR is dU 125 e last day of the month following
the issuance of the permit or in the case of a new facili ; last day of the month following the
commencement of discharge. f rF
. Signatory Re uire gents I'Supplements Sect' }e try 11. b and sut'' edes Section B. 1. d
32
All eDMRs submitted to the permit issuing aut o shall be signed by on described in Part II
Section B. (11.)(a) or by a duly authorized represU e of 1person as € tbed in Part Il,
Section B. (I 1.)(b). A person, and npl g position, m` s ated signatory ority for eDMR
reporting purposes.
�F
For eDMR submissions, the person sign ari ' itttmust obtain an eDMR user
account and login credenll��to access the `N�MR ` For�s,z� info anon on Forth
��
Carolina's eDMR syst18111Ong for e��R'an an R user account, please visit
the following web p
r i c
htt .// ortal.ncdenr.or / la o 1i u/c s
Certific � A �� sub ng an c R using the Mates eDMR system shall make
the to r g certifi t U C 22 2]r 2 THER STATEMENTS OF CERTIFICATION
WILL i`�CEPTED
a f �iti
%� 4
I
ert , urn �ualiy lcrw, t this Kument and all attachments were prepared under y
direction or sup i .an its ace � nce with a system designed to assure that quaked p rsonnel
properly gather an c� z uate t farmativu submitted Based ern rrty inquiry o the person or
persons who manage t sr thaw persons directly responsible for gathering the information,
the information submitted _� the best of my knowledge ana"beliej,' true, accurate, and complete. 1
am aware that there are si,gnt tcantpenalties for submittin gJalse in/brmation, including the
passibility cif fines and imprisonmentfir knowing violations,
s."
. Records Retention [Supplements Section D. jj.A
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records'or copies shall be maintained for a period of at least'3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
Page 6 of 6

a��„
.; ,,.a " mow:" n� ,
v
� � �s,
r
ro

DENR / D / NPDES
EXPEDITED FACT SIAEET - NPDES PERMIT DEVELOPMENT
PDES Permit NCO08 517
Derek Denard, Compliance & Expedited Permitting Unit / 919-807-6307 04Jun2015
Gateway Village, LL,G —
�`` }' j Gateway Village. Groundwater Remediation
�%
800 West Trade St, Suite 100, Charlotte, NC 28202
800 block of West Trade Street, Charlotte 28202
0.05 MGD
wmz
100% Industrial Groundwater Remediation Discharge
,x"—.. ,.zu..x„u .i<S, .,,,J .., ,.,L .x:v x.:x
01
t kl , ' PC-1 Mecklenburg
r 3 w Renewal MRCS
lY � i', 4 b , tF \•,?� 7 t Y �\ ixa t S 1v `' ,.i L t '., U 4
t � r
. i. ! 'asii� , �} i { 4 £ r S
Y £ U'r to Irwin Creek � C
,4 [11-137-1] Catawba
��.{a 0 b�., .0 k� x�'a4 0a08-34
�
„ ,+ �uY �r � s, } Y Impatred. Fish
ep t.
tissue .3 i s 1ish
0 { community poor,
y �' b y'''+� t
�l1 �',. F.0 Jr Y \ ✓ }Tf� �� 4�L1 6 � { n i� V 1..r4i,
,. ., Y ..,.. u . ,., x v, �•. . vt t� 1 �`�'r,t~h? c ,r , .., '.
0 G1NE
{
100% Charlotte East,NC
Facility Summacy
This facility is an industrial (flaw <1 MGD) groundwater remediation system. The design capacity of the
treatment system is 0.050 MGD. There are no significant changes to this facility since the last permit
renewal. The facility consists of the fallowing wastewater treatment units.
• 1200 gallon collection tank with pump
• two () bag filters
• two (2) 1000 lb activated carbon canisters (in series)
• effluent meter with recorder.'
Monthly avera e FLOW MGD) — Last 36 months ar201-Feb2015: '
[Ave 0.010 MGD; Maximum, Monthly average flow = 0.029 MGD;
Minimum, Monthly average flow = 0:002]
T xici - _ Chronic Toxicity (Ceriodaphnia) limit at'90% with testing in January, April, July and October
[TGP3B/ THP3 1 [see A. (2)]= Testing over the past three years: GP313 - P/F STATRE 7Day Chr
Ceriodaphnia indicated four (4) failures out of twelve (12) quarterly samples; TCA313- /F STAT 48hf
cu Ceriodaphnia indicated one (1) failure out of four (4) tests; and one (1) THP3l3 - CHV STATRE 7Day
CHR Ceriodaphnia test gave 45% mortality [see attached toxicity data].

Conimliance History — The facility had four limit violations for 1,2-cis-dichloro-ethylene [permit limit is 4.9
gig/L] which included one monthly and one daily in February 2012 and April 2014. For 1,2-cis-dichloro-
ethylene the human health standard is 720 4g/L and the water supply standard is 60 4g/L The stream is an
unnamed tributary that is considered to have a 7QI0 of zero. The stream is classified C waters; therefore,
the human health standard is applicable. The previous permit limit [4.9 gg/L] was more restrictive than the
applicable human health.
For Renewal — This permit reflects discharge at Outiall 001. DWR updated the following:
• for Oil & Grease [00556] remains the same for submitting DMR/eDMR, but uses test EPA method
1664 (SGT-HEM) with results in mg/L for Outfalls 006 & 007
• added Electronic Reporting - Discharge Monitoring Reports page Section A. (3.).
• added updates to facility map, outfall locations and parameter codes
• updated Tetrachloroethene (PCE) limit to 3.3 gg/L in accordance with current human health standards
• updated 1, 2-cis-dichloroethene limit to 720 gg/L in accordance with current human health standards.
Strearn — Discharge from WWTP for Outfall 001 is into an unnamed tributary to Irwin Creek [Stream
Segment 11-137-11. The segment is listed as "impaired" for Hg in Fish tissue, poor fish community, Zn,
Pb and Cu in the 2014 North, Carolina Integrated report and 303(d) list.
RPA — A Reasonable Potential Analysis (RPA) was conducted on copper, lead, zinc, iron, tetrachloroethene,
1, 2-cis-dichloroethene, chloroform, trichloroethene and 1,2-dichloroethane because Discharge Monitoring
Reports (DMRs) reported concentration above method -detection levels (MDLs) for the past three years and
one month (37 months) [Jan`22012-F62015] of data. [See attached RPA summary sheets.]
* 1, 2-cis-dichloroethene limit was removed because the RPA did not show reasonable potential to
exceed the human health standard (HH) of 720 Itg&
* Tetrachloroethene (PCE) showed reasonable potential to exceed the human health standard of limit
(HH) of 3.3 lig1L. The limit was updated to 3.3 Iig/L based on this standard.
I "act �,ShQel
Rcnewal 20 1 -- NIII)FIS N010M517
Paw

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
RECEIVED1NCD9NR10WFt
March 26, 2015
Hunter M. Hicks WOROS
Gateway Village, LLC MOORESVILLS REGIONAL OFFICE
800 West Trade Street
Charlotte, NC 28202
Subject: Acknowledgement of Permit Renewal
Permit NCO086517
Mecklenburg County
Dear Per mittee:
The NP<DES Unit received your permit renewal application on March 26, 2015. A member of the
IDES gait will ;review your application. They will contact you if additional information is required to
compete your permit renewal. You should expect to receive a draft permit approximately 30-45 days
before your existing pet mit expires.
If you have any additional questions concerning renewal of the subject permit, please contact Eton
Berry (919) 807-63 6.
Sincerely,
r
Wren Thedford
Wastewater Branch
cc: ventral Niles
NPDES Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone. 91U07- 0M Fax: [phone]Custo er Servim 1-877-6 3 6746
Internet:. www.ncwateng
An Equal OpportunityL4ffirmative Action Ernpioyer

Y 1
NPDES PERMIT APPLICATION - SHORT FORM C - G
For discharges associated with groundwater treatment facilities.
Mail the complete application to:
N. C.Department of Environment ent and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-161
WOROS
NPDES Permit Number _ MOORESVILLE REGIONAL OFFICE
If you are completing thisform in computer use the TAB kept or the u - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or tape.
1. Contact Information:
RECEIVEDIDENRIDWR
Owner Name Gateway Village, LLC 1
Facility Name Gateway Village
Mailing Address 800 West Trade Street Permifting Section
City Charlotte
State / Zip Cade NC 28202
Telephone Number (704)350-620
Fax Number (714)350-62C►
e-mail Address. [e-mail]
[e-mail]
. Location of facility producing discharge':
Check here if same as above
Street Address or State Road.
City
State / Zip Code
County
. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ?RC)
Name Cousins' Properties, Inc.
Mailing Address 800 West Trade Street
City Charlotte
State / Zip Code NC 28202
Telephone Number (704 )350-62Q0
Fax Number (704 )350-6201
4$ Ownership Status.
Pape l of C-G 03/0

NPDES PERMIT APPLICATION - SHORT FORM GW
-
For discharges associated with groundwater treatment facilities.
Federal State © Private Public
. Products recovered:
Gasoline Diesel fuel M] Solvents {ether
6. Number of separate discharge points:
Outfall Identification number(s) 001
7, Frequency of discharge: Continuous El Intermittent
If intermittent:
Days per weep discharge occurs. 7 Durations Varies'
S. Treatment Sto Design flow 0,05 MGD
9. Name of receiving stream(s) (provide a map showing the exact location of each outfall, including
latitude and longitude):
Irwin Creek
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
Granulated Carlson
11. Is this facility located on Indian country? (check one)
Yes [] No
12. Additional Information
All applicants (including renewals);
> A US GS topographical map (or copy of the relevant portion) which shows all outfalls
v A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only;
> Engineering Alternative Analysis
> Description of remediat on treatment system components, capacities, and removal efficiency
for detected compounds.
> if the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the server.
> A list of any chemicals found in detectable amounts at the site., with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prier to the date of this application)
> For petroleum -contaminated sites - Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed.
> For sites contaminated with solvents or other contaminants -IPA Method 624/625
analysis should be performed:
Page 2 of 3 C-GW 03/05

t ` �
NPDES PERMIT APPLICATION - SHORT FORM C - G `
For discharges associated with groundwater treatment facilities,
13 Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of myknowledge and elief such information is trine, complete, and accurate.
c tom, t 2
Hunter M. Hicks P.E 1 Senior En `Weer
Printed name of Person SigningTitle
N ,a
Signature of Applicant Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan., or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method irequired to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article., shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both,(18 U.S.C, Section
1001 provides a punishment by a fine of not more than $2 ,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 3 of -GW 03105

'A.,
„ Analy cd/Process Consulfations
�'�F+�tt►est�
March; 5, 2015
A.MEC
2801 Yorkmont Read
Charlotte, NC 28208
Attention: Hunter Hicks
Chemical Anal is for Selected Parameters and Sampling Location Identified as Gatewa Villag e
Miscellaneous Effluent
]Parameters unit Results
TSS m /L <5.0
RAL Sample Number; 1373-01
Bate +collected. 02/2711
Time Collected: 0955
mg/L = milligrams per Liter = parts per million a Less than or Below Detection Limit

* �``itierrrrr,r�#
Analytic tl,/Prcc ss Consultations �� ca, •
*'+rxcrrrrrre�"
Chemical Analysis or Selected Parameters and Water Sample Identified s Gateway V711age
A' A 1EC-Charlotte 1 T act collected 27 Februa 2015
L Volatile Organics Quantitation Effluent
EPA Method 601 Limit
Parameter m ILA m G�
"Tetrachloroethene 0.001 BQL
Cis 1,-Dichloroethene 0.001 BQL
Dilution Factor l
Sample Number 1373-1
Sample Date > 02/27/15
Sample Time (hrs) 0355
anal. milligrams per Liter= parts per million (pp) BQL = Below Qaandtatiaan Limits

lw
mum
MEN
NO
No
NO NO
NOW NO
=01
0
NOUN
ME
mass
NNI
001 am
an
-a NOUNS
NUUMN

Allocco, Marcia
From: Mitchell, Jeffery G. <Jeffery.Mitch ll@m cklen urgcountync. ov>
Sent. Thursday, November 07, 2013 10:47 AM
To. Allocco, Marcia
Subject: RE: Cousins
I appreciate it. I spoke with a Mr. David Edwards of Cousins Properties and was referred to Hunter M, Hicks of AMEC.
have sent Mr. Dicks an ernail requesting the inspection date to be set for November 19 2013
Contact Information:
David Edwards
[e-mail]
(704) 3 0- 203
Hunter M. Hicks
Huntg,[e-mail]
(704) 357-55 4
From. Allocco, Marcia ma ilto.mrcia.allocco ncdenr. ov
Sent. Thursday, November 07, 2013 9.39 AM
To: Mitchell, Jeffery G.
Subject. Cousins
21

RECEIVEI)
c�
IL
j P' ,l
NCDENR
North Carolina Department of Environment and Natural e l° SV
Division dater Quality
Beverly Eaves Perdue Charles Wakild P. E, Dee Freeman
Governor Director Secretary
September 14, 2012
CERTIFIED IL` 7007 1490 0004 5533 6868
RETURN CEIP LIESTED
r. David Edwards <
Group Engineering Manager
Gateway Village, LLC
800 W Trade St.
Suite 100
Charlotte, NC 2820
SUBJECT: Assessment of Civil Penalty for Violations of NC General Statute '14-215.1(a)(6) and
NP ES Permit Not. NCO086517
Gateway Village Remedation Site
Meeklenbrg County
TX 012-0006
Dear Mr. Edwards:
This letter transmits a Civil, Penalty assessment against Gateway Village Retne iation Site in the amount of
( civil penalty enforcement costs).
This assessment is Based upon the following facts. A review 'ofthe facility's toxicity self - monitoring data from June,
2012 has been conducted. The review has shown Gateway Village Remedi tion Site to be in violation of the 90.0 %
chronic toxicity effluent discharge limitation found in NPDES Permit No. NCO08651.7. The facility's toxicity 'self -
monitoring reports for April through June 2012 ` revealed the fallowing effluent toxicity hermit limit violations.
April 10, 2012 fail (7 day P F) aeon -compliant
May 15, 2012 45.0 % (7 clay chronic value) non -compliant
June 19, 2012 <45.0 % (7 day chronic value) non -compliant
Environmental Sciences Section
4621 Mail Service Center, Raleigh, North Carolina 27599,1621 3itc
Location:4401 Reedy Creek Road, Ralei t , North Carolina 27607 I e "CJ.�I.I it
Dhow 919-74 -84001 FAX: [phone] Customer Service: 1- 77- 2 -6748
Internet, littp:Ifh2o.enrstate.nc.usle bl Nahara,14y
An Equal Opportunity t Affinnaave Action Employer

3 the terms, conditions or requirements of a permit required by N.C.G.S. 143-' ,
Moore, Supervisor, Aquatic Toxicology Unit, hereby make the following civil penalty assessment a�
Village Remediation Site
For of violation(s) of G.S. 143-215. 1 (a)
Permit N 17, by discharging waste into the i
violation of the facility's permit effluent limit for chron
10,2012.
For of violation(s) of GS. 143-215, 1 (a),
Permit No. NCO086517, by discharging waste into the i
violation of the facility's permit effluent limit for chron
May 15, 2012.
3
$
For of violation(s) of G.S. 143-215.1(a)i
—No.
Permit NC6-0-86517, by discharging waste into the)
violation of the facility's permit effluent limit for chron
,19,2012.
$
Enforcement costs.
$
TOTAL AMOUNT DUE
(1) The degree and extent of ha n-n to the natural resources of the State, to the public health, or to priv,
resulting from the violation;
(2) The duration and gravity of the violation;
Environmental Sciences Section
1621 Mail Service Center, Rafefgh, North Carolina 27699-1621 One
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 NorthCa
Phone: [phone] \ FAX: [phone] N Customer Service: 1-877-623-6748
Internet hftp://h2o,enr.state,nc.us/esb/ Natut
An Equal opportunity 1 Affinnative Action Employer

ppppp�
(3) The effect on ground or surface water quantity or duality or can air quality;
(4) The cost of rectifying the damage;
() The amount of money saved by noncompliance,
(6) Whether the violation was committed willfully or 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; and
() The cost to the State of the enforcement procedures.
Within thirty days receipt of this notice, you must do one of the following;
1. Submit payment of the penalty:
Payment should be made directly to the Department of Environment and Natural Resources (do not include
woriv r orm)m Payment of the penalty will not foreclose enforcement action :for any continuing or new
violation(s).
Please submit payment to the attention of;
Point Source Branch
Division of Water Quality
1 h 17Mail Service Center
Raleigh, North Carolina 27699-1617
O
2. Submit a written request for remission or mitigation including a detailed justification for such request.
Please be aware that a request for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission, is not the proper procedure for contesting whether the violation(s) occurred
or the accuracy of any of the factual statements contained in the civil penalty assessment
document. 'Because a remission request forecloses the option of an administrative hearing, such a
request must be accompanied y a waiver of your right to an administrative hearing and
stipulation and agreement that no factual or legal issues are in dispute. Please prepare a detailed
statement that establishes why you believe the civil penalty should be remitted, and submit it to the
Division, of Water Quality at the address listed. below. In determining whether a remission request
will be approved, the following factors shall be considered;
(1) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b) were wrongfully
applied to the detriment of the petitioner;
() the violator promptly abated continuing environmental damage resulting from the violation,
() the violation was inadvertent or a result of an accident;
Environmental Sciences Section
1621 Mail Service Center, Rale h, North Carolina 27 99-1621
Location:4401 Reedy Greek Road, Ralegt , North Carolina 27507 One
Phone, 919-74 - 4001 FAX; 919.74 -8517 t Customer Servim1-877- 2- 748 orth aro inn
Internet: hftp,.Ifh2o,enr.state,nc.us/esbI t 4
An Equal (opportunity 1 Affirma ive Action Employer

Ity Remission$ (Committee). Please be advised that the Committee cannot consi
and thorough statement in support of your request for remission.
remission, you must complete and submit the enclosed "Request for Remission of
an Administrative Hearing and Stipulation of Facts" fortir within thirty (30) days
44Y-1-
Kemission Kequest.
Environmental Sciences Section
Division of Water Quality
1621 Mail Service Center
Raleigh, NC 27699-1621
OR
The original and one (1) copy of the petition must be filed with the Office of Administrative Hearings. TI
be faxed - provided the original and one copy of the document is received in the, Office of Administrative
five (5) business days following the faxed transmission. The mailing address for the Office of Administn
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621 One
Location; 4401 Reedy Creek Road, Raleigh, North Carolina 27607 NorthG
Rhone; 919-743-8400 \ FAX: [phone] \ Customer Serviw 1-877-62M748
Internet http,,/lh2o,enr.state,no,us/esb/ Adm
Aq Equal Opportunity kAffirmative Action Employer

pppp",
Office of Administrative Hearing
6714 Mail Service Center:
Raleigh, NC 27699-671
Telephone [phone] Facsimile: [phone]
A copy of the petition must also be served on D NR as follows:
Mr. William Cary, General Counsel
Department of Environment and Natural Resources
1601 Mail Service'Center
Raleigh, NC 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition,
Failure to exercise one of the options above within thir-ty (30) days of receipt of this letter, as evidenced by an rote a
date/tithe received stamp (tot a postmark), will result in this matter being 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.
Please be advised that any continuing violation(s) maybe the subject of new enforcement action, including an additional
penalty, If you have any questions about this civil penalty assessment, please contact Mr. John Giorgino at 919-743- 441
or me at 919-743-8442.
Date ACindycore
Supervisor, Aquatic Toxicology Unit
ATTACHMENTS
cc: Rob Krebs- Mooresville Regional Office /attachments
Poi=ourc=Bra!"chFi1e vv/attachments
John Gio gino -Aquatic Toxicology Unit w attach gents
Central Pales w/attachments
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621 One
2
Locatim 4401 Reedy reek Road, Raleigh, North Caroline 27607 �L ne �i�C� l
Phone: [phone] t FAX: [phone] t customer Service: /- 77- -67
Internet: http:l/li2o.enr tate,nc,us/esb/ u
rally
An 6quai Oppodunity t Affirmative Action Employer

POP7ATE ORTH OLI A DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY TY OF MECKLENBURG }
IN THE MATTER OF ASSESSMENT ) 'WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE TIVE HEARING AND
STIPULATION OF FACTS
GATEWAY VILLAGE REMEDIATION SITE }
NPDES PERMIT NO. NCO086517 }
FILE NO. TX-2012-0006
Having been assessed civil penalties totaling for violation(s) set
forth in the assessment document of the Director of the Division of Water Quality dated
, the undersigned, desiring to seek remission of the civil penalties, does hereby waive the right to an
ch i istrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands ds that all evidence presented in support of remission
of this civil penalty must be submitted to the Director of the Division of Water Quality thin 30 days of receipt;
of the notice of assessment. No new evidence in support of a remission request will be allowed after 30 days
from the receipt of the notice of assessment.
This the day of , 2012.
EIS
ADDRESS

JUSTIFICATION N ISSIC)N 1FST
DWQ Cuss Number: T - 0 2- 00 County: Mecklenburg
Assessed Party: Gateway Village Remediation Site
Permit No (if applicable): i C O08 51'7 Amount Assessed: 5
Please use this form when requesting rescission of this civil penalty. You must also complete the
" nest For Remission Waiver ci Ri fat to an Administrative Hearin and �S"ti ulation a
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the 'reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure ;for
contesting whether the violation(s) occurred or; the accuracy of any of the factual statements
contained in the 'civil penalty assessment document. Pursuant to, N.C. I.S. § 14 1 -2 2.1(c),
remission of a civil penalty may be granted only; when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor applies (attach
additional pages, as needed).
(a) one or more of the civil malt `assess ent factors in NaC.Cr.S, 141-2g b
were wronglIbIlly a lied. to the detriment of the petitioner (the assessmentfactors are listed in
the civil penalty assessment document);
(b) the violator rci tl abated continuin environmental d a e resultin fro the
violation (i.e., explain the :steps that you took to correct the violation and prevent ,future
occurrences);
(c) the violation was inadvertent or a result of an accident (i, e., explain why the
violation was unavoidable or somethin -you could notprevent car prepare.for)
(d) the violator had not been assessed' civil enalties for n revious violations;
(e) Dayment' of the civil malt l revert a ' ent for the re ainin recess
remedial actions (Le., explain how payment of"tire civil penalty u#fill prevent you f om performing
the activities necessary to achieve compliance),
EXPLANATION:

North Carolina DepartmE
Div
Beverly Eaves Perdue
Governor
In
Mr, David Edwards
Cousins Property, Inc.
800 West Trade Street, Suite 100
Charlotte, North Carolina 28202
Subject: Notice
Trackir
Gatewz
NPIDEE
Mecklei
Dear Mr. Edwards,
Date
4/18/12
4/30/12
ante
Cor
If vc
Report
hene 5.5
hene 5.5
FILE,01-A
it and Natural Resources
11ity
Dee Freeman
Secretary
02
# #
•
ie subject facility revealed violations of the
Aue Permit Limit
4.9 lig/L (I
49 pLg/L (N
Marcia Alloco at (704) 235-22C4.
Sincerely,
Robert B. Krebs
Surface Water Protection, Regional Supervisor
cc: Point Source Branch
R, Rozzelle, MCWQP
MA
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One
Phorie: [phone] t Fax: [phone] \ Customer Service: 1-877-623-6748 NorthCarofina
Internet: httpi/portal,ncdenr.org/web/wq
An Equal Opportunity i Affirmative Action Employer - 30% Ra:yded,110% Post Consumer paper Natimally

A &
J FAA
irciDEN1
North Carolina Department of Environr
Division of Water I
Beverly Eaves Perdue Charles Wakild, F
Governor Director
June 22, 2
Mr. David Edwards
Cousins Property, Inc.
800 West Trade Street, Suite 100
Charlotte, North Carolina 28202
Subject: Notice of'
Tracking I
Gateway'v
NPDES PE
Mecklenbu
Dear Mr, Edwards,
A review of the February 2012 self -monitoring report (DM
the following parameter at Outfall 001:
Date Parameter Reported
2/28/12 Cis 1,2 dichloroethene 5.5 u�
211-2/29 Cis 1,2 dichloroethene 5.5 µ�
Remedial actions, if not already implemented, should be t
Division of Water Oualitv may oursue enforcement action;
F E, I L
xnt and Natural Resources
ality
Dee Freeman
Secretary
2
)Iation — Effluent Limitation
4OV-2012-LV-0309
age Groundwater Remediation System
tit No. NCO086517
County
for the subject facility revealed violations of
clue Permit Limit
4.9 Itg/L (Daily maximum)
4.9 g/l- (Monthly average)
the head of the cis 1,2 dichloroethene column on the facility's DMRs to 81574 from 81328 on all future
submissions.
If you have questions concerning this matter or to apply for a SOC, please do not hesitate to contact M.
Marcia Allocco at [phone].
Sincerely,
1 C-e-, 4 Iz--
Robert B. Krebs
Surface Water Protection, Regional Supervisor
cc* Point Source Branch
R. Rozzell e, MCWQP
MA
Mooresville Regional Office
Locatiom 610 East Center Ave., Suite 301 Mooresville, NC 28115 One
Phone: [phone] k Fax: [phone] Customer Service: 1-877-623-6748 NN o Carolina
Internet: http:ltportal,ncdenrorgtwebAivq
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X-rYWA
* x7ja
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 24, 2011 RECEIVED
DIVISION OF WATER OUALITY
CERTIFIED MAIL 7009 1680 0002 2464 9525
RETURN RECEIPT REQUESTED
Mr. Randall Miller S W P S N
Cousins Properties, Inc M00RESV1L,.,2 REUONAL. OFFICE
800 W. Trade Street; Ste. 100
Charlotte, NC 28202
SUBJECT: NOTICE OF VIOLATION: NOV-2011-1LR-0045
Cousins Real Estate — Gateway Village, LLC
NPDES Permit Number NCO086517
Mecklenburg County
Dear Mr. Miller -
This is to inform you that the Division of Water Quality has not received your discharge monitoring report
(DMR) for April 2011. Water quality regulations require that monthly monitoring reports shall be filed no later
than 30 days after the end of the reporting period for which the report is made. Failure to submit reports as
required will subject the violator to the assessment of a civil penalty of up to $25,000 per violation.
To prevent further action, please submit the report to the Division's Central Files office at the letterhead address
within 15 days or notify this office as to any problem preventing their timely receipt. You will be considered
noncompliant with the self -monitoring requirements of your NPDES permit until the report has been submitted.
Additional action, including the assessment of civil penalties, may be taken if the report is not submitted within
the time frame specified above.
This letter additionally provides notice that this office will recommend the assessment of civil penalties if future
reports are not received within the required time frame during the next twelve (12) reporting months. The
Division must take these steps because timely submittal of discharge monitoring reports is essential to the
efficient operation of our water quality programs. We appreciate your assistance in this matter. If you have any
questions about this letter or discharge monitoring reports, please contact Bob Sledge at [phone] or via e-
mail at bob.sledgeCa)ncdenrgov.
Sincerely,
o
bl/ John E. Hennessy, Supervisor
Compliance & Expedited Permits Unit
cc: NPDES Enforcement File
_Jfice
Central Files
Mecklenburg County Water Quality Program
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
Location: 512 N. Salisbury St, Raleigh, North Carolina 27604
Phone: [phone] \ FAX: [phone] Customer Service: 1-877-623.6748 Nora hCaro fina
Internet www.ncwaterquality.org
An Equal Opportunity \ Affirmative Action Employer Naturallil,

F I L
i!C&DERR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Govemor Director Secretary
June 21, 2012
Mr. David Edwards
Cousins Property, Inc.
800 West Trade Street, Suite 100
Charlotte, North Carolina 28202
Subject: Notice of Violation — Monitoring Violation
Tracking #: NOV-2012-MV-0041
Gateway Village Groundwater Remediation
NPDES Permit No. NCO086517
Mecklenburg County
Dear Mr. Edwards:
A review of the January 2012 self -monitoring report for the subject facility revealed monitoring
violation(s) of the following parameter(s) at Outfall 001'.
Date Parameter Reported Value Monitoring Requirement
1/1 -1/7 Flow None 1 x/week
Remedial actions, if not already implemented, should be taken to correct any problems, The Division
of Water Quality may pursue enforcement actions for this and any additional violations. If the
violations are due to a transcription error (data left off the DMR) please submit an amended DMR
(two copies) to this Office along with a cover letter asking for rescission of the Notice of Violation.
Please address your correspondence to M. Marcia Alloccro, at the letterhead address.
If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at
704/663-1699,
Sincerely,
Robert B. Krebs
Surface Water Protection
Regional Supervisor
cc: Point Source Branch
R. Rozzelle, MCWQP
MA
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NG 28115 One
Phone: [phone] k Fax: [phone] k Customer Service: 1-877-623-6748 NofthCarohiia
Internet: http://podal.ncdenr.org/webtwq
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A&E
North Carolina Department of Envil
Division of W
Beverly Eaves Perdue Charles Wal
Governer [direct
April25,
CERTIFIED MAIL 7010 2780 0003 4825 5628
RETURN RECEIPT REQUESTED
Mr. David L. Edwards
Cousins Property, Inc.
00 hest Trade Strut, Suite 100
Charlotte, NC 28202
SUBJECT: NOTICE OF VIOLATION: NCI -20 2-
gateway Village Groundwater Remedial
NPDES Permit Number NCO0 6517
Mecklenburg County
Dear Mr. Edwards:
)ove.
this office wil'
and Natural Resources
Dee Freeman
Secretary
QUALITY
t uc navtt� cavvuc uttta to att a caa ua�4ttna c tttvtl"i'mr, asatlVt L>, Ftt a'w' %w tttCC44 I'Ivu olvugv 4L k7i7) Uv t'U.770 UA Vi U-
mai l at [e-mail].
Sincerely,
11 e— i 02� -62-1V
John E. Hennessy, Supervisor
Compliance & Expedited Permits Unit
cc: NPDES Enforcement File
gS
rent"rai"es
Mecklenburg County Water Quality Program
1617 Mall Service Center, Raleigh, North Carolina 27699-1617 ���
Location: 512 N. Salisbury St, Rale�h, North Carolina' 7 �C) Carol
( c
Phone: 919 w.ncwate 1 ualq 919�07-649 � ML
Internet: wrww.ncwaterquality.arg
An Equal Opportunity t Affirmatnte Action Employer

DWO Point Source Fax:[phone] Jun 4 2010 9:51 P.01
ocousins 1
i
i
t Bradley Bennett # s l u 1
North CarolinaDepartment of
Environment and natural ltesc?urces
Division of Water Quality �
Stormwater Pennitting Unit
1617 Mail Service Center E
Raleigh., North Carolina 27699-1 6,17
t Notice Of Intent to .Allow NPOES Permit it to Expire
NPI)ESPerwit NCO0 651"7 2
010
Gateway Village
Oa West Trade Street
Charlotte, Mecklenburg County, North Carol' 2 20
MACTEC Project: 2, -0 6 i
Dear ivfr. Bennett
Ga v y Village, LLC care of Cousins 'es; Jaa ., intends' to allow th ' cent ICES
pe iuit �l'�'0086 17 to ex i! ..6n'May 1,`270 O ' d does not request renew
Gateway "pillage,- LLC was antlaofized to ioperat6 a 0.05 MGD dewa ering Itreatm nt;system at the
site in Jttly 2001 The dewatering trey t ' cyst as . designed to,at-petroleum-
oontaminated groundwater. Treated water from the treatment system would dis barge into Irwin
Creels (via storm sewer), which is classified C water, in the Catawba River Basin. The current
NPDES Perrmit (N OO 6 17) was effective on June 1 2005 and will expire o� May 31, 2010.
Due to prolonged dewatering system inactivity (no flow), a permit modification suspending flow
meter calibration requii=erds was issued on April 21, 2005. The last compliance inspection was
conducted by l s. Erin Call of the Mecklenburg County Water Quality Program on December er 28,
2008 as part of a cooperative working agreement betvvicen Mecklenburg County and tie rivi ion
of Water Quality.
�4ACTEC Engineering and Consulting, Inc. C Cf, on behalf of GateW4 Village,; LLC,
designed and supervised construction of the dewatering treatment system,! has performed
operations and maintenance of the treat went system., provided an Operator in Responsible Charge
(ORC) to supervise system operations, d prepared monthly l isebarge Monitoring Reports
(U s) since 2001. f
Since Novexnber 2002, there has been no flaw through the treatment system except for a release
in e rly June 200.3 due to a pump failure not associated with the treataitent tee. Concrete
slurrywalls poured, around the pe " of the y Village complex development
have effectively prevented groundwater- fTom rising to the level required. for stein operation-
Si'xtce, no fioWbas Been cur er veel at'the site'fofoverr severs years a.nd;" • anticipa e that s c
controls at the site (i.e_ t.a'sl wails, separate pip` ss ; s) will continue t e ttificaent'to
maintain no flow, Gatrway Village, LLC: no longer requires a NPDES Permit. p
800 West`Sradc Strect . Suite loo - ChAftortc, NortIA Carolina28.202 * Iv ain. (704 5t1-6 00 f Fax. [phone]
g .cousinsproperries.coxn

DWO Point Source Fax:[phone] Jun 4 2010 9:5
Notice OfInient to Allow NPDES Permil NCON651 7 to,&Vire
Gateway P-714qe
Charlove, MeCkImbuyg County, North Carallmn
If YOU have quest iOus Or COMments regarding this request, please coutact DI
ff ...... T-- - 1`1A A% rt'l --T9'. -- - -y - . . I --- . -- . - .1
Sincerely,
Cousins Properties, Inc.
ux�
David L. Edwards
cc: Rob Foster, MACTEC Fa&eeting and ConsWting, Inc.

ATAtA..
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Sdcretar
October 21, 200
. Randall Miller
Cousins Real Estate
101 N 'Tryon St
Charlotte, NC 28246
Subject: :Renewal :Notice
NPDES Prrnit NCO086517
Charlotte Gateway pillage, LL
Mecklenburg County;
Dear Permittee-
Your NPDES permit expires on May 31, 2010. Federal (40 CFR 122.41) and North Carolina (15A
AC 21=1.0105 (e)) regulations ns state that permit renewal applications must be filed at least 180 days prior
to expiration of the current permit. If you have already mailed your renewalapplication you may
disregard this notice.
Your renewal package must be sent to the Division postmarked no later than December 2, 2009.
Failure to request renewal by this date may result in a civil penalty assessment. Larger; penalties may be
assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after May 31, 2010, the current permit must be renewed.
Discharge of wastewater without a valid permit would violate + North' Carolina General Statute 143-21 .1;
unpermitted discharges of wastewater may be assessed civil penalties of up to $25,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact
me at the telephone number or address listed below.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you
must submit with the permit renewal application.. If you have any questions, please contact me at the
telephone number or email address listed. below.
Sincerely,
Charles R. Weaver, Jr.
NPDES Unit
cc Central Files
V'DFS Mie
1617 bail Service Center, Raleigh, North Carolina 7699-1617 One
512 North Salisbury Street, Raleigh, North Carolina 27604 NorthCarofin
Phone: [phone] / FAX [phone] / chades,[e-mail] ncdenr.gov Aah"Vily
An Equal OpportunifylAftirmafive Action Employer — 50% Recycled1l0% Post Consumer Paper

original and two copies.
inch

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Ccleen H. Sullins Dee Freeman
Governor Director Secretary
February 11 200
Mr. David Edwards, Director of Engineering
Gateway tewa Village, LLB
800 W. Trade Street, Suite 100
Charlotte, NC" 2802
SUBJECT: Compliance Evaluation Inspection
Gateway Village, LLC
NPDES Permit No. NCO086+5 T
Mecklenburg County, NC:'
Bear Mr. Edwards.
Can December 8, 2008, GIs. Erin hall of the Mecklenburg g County Water Quality Program
(MCW QP) conducted an inspection at the subject facility. This inspection was conducted as part
of a cooperative working agreement between Mecklenburg County and the Division of Water
Quality. The enclosed report should be self-explanatory.
If you have any questions concerning this report or any;other matters, please do not
hesitate to call Ms. Marcia Allocco or nee at this Office.
Sincerely,
or Robert B. Krebs
Regional Supervisor
Surface Water Protection
Enclosure
cc: Rusty Rozzelle, MCWcQQ
Kerry Reed, P.E.
Mctec Engineering and Consulting, Inc.
2801 Yorkmont Rd., Suite 100
Charlotte, NC 2808
Mooresville Regional Office
Locati= 6'10 East Center Ave., Suite 301 Mooresville; NO 28115 One
Phone: [phone]' 1 Fax: [phone] Customer ervice:1-877-623-6748 NC ilh ` r lira
Internet, www,ncwaterquality.org p
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United ,�4tAtl?C Fn irAnMPnta l Prnt-i-f; Sn Aaan�nt' ')AA4A
Cade NPDES Permit
5 NCO086517
Inspec
k Days Facility Self-M
lo. Y O/DAY It
08/12/08
Remarks:
itor ng Evaluation Rating
4
Name and Location of Facility Inspected. Entl
Gateway Village GWRS 2:00
800 Block of W. Trade street Exit
Charlotte, NC 28202 2:30
Datt
Dect
Name(s) of On -Site Representatives _-_....--Title( )_—__., Phone o(s)a
Matt Gustis - Operator in Responsible Charge - (704) 33 - 1 3
Name and Address of Responsible Official:
Mr. David Edwards
Gateway Village, LLC
800 W. Trade Street, Suite 100
Charlotte, NC 28202
Si natures) of Inspector( ):
Erin E. Lull
tion Type Inspector
C
1i�y Pro.: ram
QA .Rest
N
inie•
mi rmit xpi
May 3l, 201f
ber 8, 2008
azz U.l:GlllVILU 1..V IdtlUllb Gk' iYli uncnanc
: LJ
fitoring Program ® Sludge Handling/Disposal
Of
ice Schedules [] Pretreatment Program
( It
(704)4324870
EPA Form 3560-3 (Revised 3-85) Previous Editions are Obsolete
2
-dia
Date:
December 31;
De
Regional Office February 10,

GENERAL: -
The facility was last inspected by MCW(P on September 6, 2006. A Compliance
Evaluation Inspection report was issued on September 20, 2006.
PERMIT:
A permit to operate the Gateway Village groundwater're e iatio system (CsWR ) was
issued to Cousins Real Estate Corporation on July I, 2001 l expired on Mky 31, 2005. A new
permit to operate this facility was issued to Gateway Village, LLC can June 1, 2005 and will be
effective until May 31, 2010. Due to prolonged system inactivity, a permit odification
suspending; flow meter calibration requirements was issued on April 21, 2005. However, the
flow meter calibration requirement will be automatically reinstated upon restart of the GWRS
The facility is designed to treat petroleum -contaminated groundwater through a
groundwater re€ ediation system, The treatmentsystem consists of a surge/transfer tank-, dual
particulate (bag) filters, dual liquid -phase granular activated carbon vessels, a flow totalizer
metering device, a control panel, two transfer/sump pumps and all related piping and
appurtenances, The permit appears to properly describe the facility. The facility` appears to be
adequate for the waste stream being treated.
Mactec, Inc. of Charlotte, NC operates the facility under contract for Gateway Village,
LLCM. The certification classification for NCO086517 requires that the facility have an operator
in responsible charge (O C) with a Grade 1 Physical Chemical Water Pollution Control System
(PC-1) certification. The facility is staffed (OR.0 and back-up) with personnel that possess the
appropriate operator certification.
RECORDS/REPORTS:
.Discharge Monitoring Reports (DMRs) were reviewed: for the period June 2007 through
May 2008. Self -monitoring records and operator visitation/maintenance were readily available
during the inspection.
FACILITY SITEREVIEW:
All of the major components of the treatment works were in place, but not operating
during the inspection. according to the tR. C, concrete slurry walls poured around the perimeter
of the Gateway Village complex during development have effectively prevented groundwater
from rising to the level required for system operations.'
o major maintenance has been conducted at this facility since the system was shut
clown.. The CRC reports that routine maintenance items, including carbon media and particulate
(bag) filter'change-out would be required prior to restarting the treatment system.

FLOW MEASURMENT:
2008.
LABORATORY:
The permittee contracts with Pace Analytical Laboratories (NC Cert
and 4633) to perform all chemical analyses specified in the permit. Pace Ai
was not evaluated during this inspection.
EFFLUENT/RECEIVING WATERS:
The facility is permitted to discharge to the municipal storni sewer s
conveys the effluent to Irwin Creek, a Class C water, in the Catawba River
was not discharging at the time of inspection.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (DMRs) were reviewed for the perio+
May 2008. The reports indicate that the facility has not discharged any trea
approximately three years.
OPERATIONS AND MAINTENANCE:
The facility and site appear to be adequately maintained, consideriq
not currently in service., The facility is being maintained in "stand-by" of
and/or foundation de -watering become necessary. The overall operating is
appears acceptable for the size and type of the facility utilized in this capac:
maintenance activities will be required prior to system restart, including fits
carbon media change -out, and particulate (bag) filter replacement. The OR
requirements.

A Michael F. Easley, Governor ( i
t
William Cr. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Writer Quality
September 20, 2006
Mr. David Edwards, Director of Engineering
Gateway Village,'LLC
800 W. Trade Street, Suite 100
Charlotte, NC 2802
SUBJECT: Compliance Evaluation Inspection
Gateway Village, LLC
DES Permit No. NCO086517
Mecklenburg County, NC
Dear Mr. Edwards:
On September 6 2006 Ms. Olivia Hutchins of the Mecklenburg County Water Quality
Program (MCWQP) conducted an inspection at the subject facility. This inspection was
conducted as part of a cooperative working agreement between Mecklenburg County and the
Division of Water Quality. The enclosed report should be self-explanatory.
If you have any questions concerning this report or any other matters, please do not
hesitate to call Ms. Marcia Allocco or me at this Office.
Sincerely,
m
D. Rex Gleason, P. E.
Water Quality Regional Supervisor
Enclosure
cc. Rusty Rozelle, MCWQP
Jimmy Jordan, P.G.
Mactee Engineering and Consulting, Inc'.
2801 Yorkmont Rd., Suite 100
Charlotte, NC 28208
DRGIoj A
File: GatewayWillage.0086517.0906.doc
eci �thCarcr ina
NCdENR 0 ,(ra"V �
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet. 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone] 3-6748
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GENERAL:
The facility was 'last inspected by MCtP on June 2, 2005. A Compliance Evaluation
Inspection report was issued on June'22, 2005.
PERMIT:
A permit to operate the Gateway Village GWRS was issued to Cousins Real Estate
Corporation on July 1, 2001 and expired on May 31, 2005. A new permit to operate this facility
was issued to Gateway Village, LLC on June 1, 2005 and will be effective until May 31, 2010.
Due to prolonged system inactivity, a pen -nit modification suspending flow meter calibration
requirements was issued on April 21, 2005. however, the flow meter calibration requirement
will be automatically reinstated upon restart of the ,groundwater remediation system.
Both the expired and the new permit appear to properly describe the facility. The facility
appears to be adequate for the waste stream being treated..
The facility is designed to treat petroleum -contaminated groundwater through a
groundwater remediation system (G S). The treatment system consists of a surge/transfer
tank, dual particulate (bag) filters, dual liquid -phase granular activated carbon vessels, a flow
totalizer metering device, a control panel, two transfer/sump pumps and all related piping and
appurtenances.
lactec, Inc. of Charlotte, NC operates the facility under contract for Gateway Village;
LLC, The certification classification for NCO086 17 requires that the facility have an operator
in responsible charge (ORC) with a Grade 1 Physical Chemical Water Pollution Control System
(PC-1) certification. The facility is staffed ((SRC and back-up) with personnel that possess the
appropriate' operator certification,
RECORDS/REPORTS:
Discharge Monitoring Reports (DMRs) were reviewed for the period May 2005 through
June 2006. Self -monitoring records and operator visitation/maintenance were readily available
during the inspection.
FACILITY SITE VIEW
All of the major components of the treatment works were in place, but not operating
during the inspection. According to the ORC, concrete slurry walls poured around the perimeter
of the Gateway Village complex during development have effectively prevented groundwater
from rising to the level required for system operations: Consequently, this system has not treated
y groundwater since June 9, 2003.
o major maintenance has been conducted at this facility since the system was shut
down:. The ORC reports that routine maintenance items, including carbon media and particulate
(bag) filter change -out would be required prior to restarting the treatment system.

FLOW MEASURMENT:
LABORATORY:
Pace Analytical Laboratories perfortris analysis of effluent samples. Pace Analyti4
certified by the State of North Carolina to perform analysis on all parameters specified in
permit. Pace was not evaluated during this inspection.
EFFLUENT/RECEIVING WATERS:
The facility is permitted to discharge to the municipal storm sewer system, which
conveys the effluent to Irwin Creek, a Class C water in the Catawba River Basin, The fac
was not discharging at the time of inspection, and according to records, has not discharge(
June 2003,
SELF -MONITORING PROGRAM:
approximately 3-years.
OPERATIONS AND MAIINTENANCIE:
The fhe.ilitvnnil Tito nTvn,-Ar tn by tk,- f!
requirements.

ppppp"
NCDENR
North Carolina Department of Environment'and Natural Resources
Division of Water'Quali
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Alan W. Klimek, P ., Director
June 22, '005
. David Edwards, Director of Engineering
Gateway Village, LLC
800 W. Trade Street, Suite 100
Charlotte, NC :80
SUBJECT: Compliance Evaluation Inspection
Gateway Village, LLC
ICES Permit No. NCO0 651"
Mecklenburg County, NC
Dear Mr. Edwards:
On June 2, 2005, Mr. Jeff Price of the Mecklenburg County Water Quality Program
(MCWQP) conducted an inspection at the subject facilityThis inspection was conducted as part
of'a cooperative working agreement between Mecklenburg County ty the Division of Water
Quality. enclosed report should be self-explanatory.
call Mr. Richard Bridgeman or me at this Office.'
Sincerely,
D. Rex Gleason, P. E.
Surface Water Protection Regional u
cc: Rusty Rozzelle, MCWQP
Jimmy Jordan, P.G.
Mactec Engineering and Consi
2801 Yorkmont Rd., Suite 10C
Charlotte, NC 28208
1trljsp
Fire: Gate"yWillage.0086517.0605.doc
Mooresville Regional Office We
616 East Center Avenue, Sue 301, Mootesville, North Carolina 26115 MWffiCarohna
Phone., 7 63-16 91 Fa: 04-66 -60d ! inteme#: h o.enr state.no:us
An Equal Opportunfty/Aftmafive Action Employer — 50% Recycle-00% Post Consumer raper

No. YR/MO/DAY
111/06102
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
... ....... Reserved ............
1.0 4 N N
Section 11: Facility Data
Name and Location of Facility Inspected: Entry Time:
-Permit Eff five Date:
ec
Gateway Village GWRS 10:30 am
June 1, 2005
800 Block of W. Trade Street Exit Time:
Charlotte, NC 28202 11:15 am
Permit Expiration Date:
Date:
May 31, 2010
1yune 2, 2005
Name(s) of On -Site Representatives Titles) Phone No(s):
Mr. Matt Gustis (Mactec, Inc.) - Operator in Responsible Charge - [phone]
Name and Address of Responsible Official: Title:
Mr. David Edwards Director of Engineering
Gateway Village, LLC
800 W. Trade Street Suite 100 Phone No.
Contacted?
Charlotte, NC 28202 [phone]
No
1
Section C:•
Areas Evaluated During Inspection
Flow Measurement i peratio Maintenance
Sewer Ovefflow
Records/Reports Self -Monitoring Program El Sludge Handling/Disposal
0 Pollution Prevention
Facility Site Review Q Compliance Schedules E] Pretreatment Program
El Multimedia
Effluent/keceivigg Waters
Other.
Section D: Summary of Findings/Comments
AN areas are rated satisfactory unless otherwise indicated. See Attached Sheet(s) for Summary
Signature(s) of Inspector(s): Agency/Office/Telephone:
Date:
Jeff Price MCWQP/[phone]
June 9, 2005
Signature of Reviewer: AgencylClffice
Date
EPA Form 3560-3 (Revised 3-85) Previous Editions are Obsolete

GENERAL:
The facility was last inspected by MCWQP on June 30, 2004. A Compliance Evaluation
Inspection report was issued on July 13, 2004.
PE
permit to operate the Gateway Village GWRS was issued to Cousins Real Estate
Corporation on July 1, 2001 and expired on May 31, 2005. due to prolonged system inactivity;
a permit modification suspending flow ;meter calibration requirements was issued on April 21,
2005. A new permit to operate ate this facility was issue. to Gateway Village, LLC onJune 1 2005
d will be effective until May 31, 2010. The facility operated under the requirements of the
previous permit throughout the entire period of review.
Both the expired and the new permit appear to properly describe the facility: The facility
appears to be adequate for the waste stream being treated.
The facility is designed to treat petroleum -contaminated groundwater oug a
groundwater remediation system. (G WR . The treatment system consists of a surge/transfer
tank, dual particulate (bag) filters, dual liquid -please granular activated carbon vessels, a flow
totalizer metering device, a control panel, two transfor/sump puntps and all related piping and
appurtenances.
Mactec, Inc. of Charlotte, NC operates the facility under contract for Gateway Village,
LL,C. Mr. Matt Gustis is the Operator in Responsible Charge (ORC) for the facility. Mr. Gustis
is a:NC Certified Grade I Operator, PC Certificate # 986275.
RECORDS/REPORTS:
Discharge Monitoring Reports (I e reviewed for the period June 2004 through
.April 2005. Self -monitoring records were readily available during the inspection. Maintenance
logs were not available during the inspection, but were reportedly in the possession of the Project
Manager, Mr. Jimmy Jordan (Mactec). Mr. Jordan was not present during the inspection.
FACILITY SITE
.All of the mayor components of the treatment works were in place, but not operating
during the inspection; According to the ORC, concrete slurry wails poured around the perimeter
of the Gateway Village complex during development have effectively prevented groundwater
from rising to the level required for system operations. Consequently, this system has not treater(
any groundwater since June 9, 2003.
No major maintenance has been conducted at this facility since the system was shut
down. The ORC reports that routine maintenance items, including carbon media and particulate
(bag) filter change -out would be required prior to restarting the treatment system.

st
$.-......,....m......®.. ..e... . ... ..._. .......«® ..-.......aw».wwry msw.wa.u.� w:u4T MAf.#�.d A✓%d4AGL#.s
EFFLUENTIRECEIVING WATERS:
The facility is permitted to discharge to the municipal storm sewer system, which
conveys the effluent to Irwin Creep, a Class C water in the Catawba River Basin. The facility
was not discharging at the time ofinspection, and according to records, has not discharged since
June 2003.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (I were reviewed for the period June 2004 through
April 2005. The reports indicate that the facility has not discharged any treated waste in
approximately -years.
OPERATIONS AND MAINTENANCE:
e facility and site appear to be adequately maintained, considering that the facility is
not currently in service. The facility is being maintained in "stand-by" mode, should treatment/
foundation de -watering became necessary. The overall operating strategy of the site appears
acceptable for the size and type ofthe facility utilized in this capacity. Some maintenance
activities will be required prior to system restart, including flow meter calibration, carbon media
change -out and particulate (bag) filter replacement. The ORC is aware of'these considerations.

Michael F. Easley
y ,Qrl Governor
NCDE R William G. Ross, Jr., Secretary
� North Carolina Department of Environment and Natural resources
Alan W. Klimek, P.E.; Director
Division of Water Quality
September 9, 2004
RandallMiller
Cousins Real Estate
800 West Trade Street, Suite 100
Charlotte, NC 28202
Subject, Renewal Notice
DES Permit NC O086517
Charlotte Gateway Village, I..f.,C
Mecklenburg County
Dear Permittee:
Your NPDES permit expires on May 31, 2005. Federal (40 CFR 122.41) and North Carolina (1 A. N C 2I-I.0105(e))
regulations require that permit renewal applications must be filed at least 180 days prior to expiration of the current permit. If
you have already mailed your renewal application, you may disregard this notice.
To satisfy this requirement, your renewal package must be sent to the Division postmarked no later than December 2,
2004. Failure to request renewal by this date may result in a civil assessment of at least $500.00. Larger penalties may be assessedi
depending upon the delinquency of the request.
If any wastewater discharge will occur after May 31, 2005, the current permit must be renewed. Discharge of wastewater
without a valid pen -nit would violate North Carolina General Statute 143-215.1, unpermitted discharges of wastewater maybe
assessed civil penalties of up to $25,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact me at the telephone
number or address listed below. You may also contact the Mooresville Regional Office at [phone] to begin the rescission
process.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must submit with
the permit renewal application. If you have any questions, please contact me at the telephone number or e-mail address listed
below.
Sincerely,
OFENMRONSOff
aa. w
Charles H Weaver, Jr.
NPDES Unit
CC: Central Hies
DES File
t,, a
1617 Mail Service Center, Raleigh, North Carolina 27699-1 17 919 7 3.5083, extension 511 (fax) 919 33-0719
VISIT US ON THE «rrtRNET @ http:ffh o.enr. tafe.r c.usfNP e-mail: chades,[e-mail]

NPUES Permit NCO086517
rl to n Ar.11 LLC:
age,
Mecklenburg County
hrYti i` tY err. rc .rti.w m.rw•. wrn � d` YY Y 1
anauscnax lacmues cia suiea as rrunaryinausines ksee tippenct ces H-u to Lrue tv or cne k--o ze or reaerai
Regulations, :fart 122 and ALL Municipal facilities with a pennitted flog > 1.4 MGD must submit
Priority Pollutant Analysis (PPA) in accordance with 40 CFR Part 122.2 1.
Tbe,above,wquhrment does NOTapply to privately owned faeilitres hraftng 100%
domestic wastewater, orfacrftr'es which discAiige non-p eess wastew2ter (cooling
water, fx'lterbackwash etc.)
PLEASE NCB
Due to a change in fees effective January 1, 1999, there is no renewal fee required th your
application package.
Send the completed renewal package to:
Mr. vies H. Weaver, Jr.
NC DENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617

3 09:23 ER LAW ENGINEERING ENVIR7
V-NiT Air I
�37 TO 97046636040 P.01
, �& 10 'doft, Now*&.'& Arrw—"
Date: Number of pages including cover sheet:
TO 0 FROW
j�r^Al e,- /tr
MAGI E & C
Phone: Phone: (704) 357- Y, k-oo
Fax- 70 0 */0 Fax: (704):357-
CC-
REMARKS:
If this is not received in good condition or if you have any questions, please call 704-357-8600
Thanks and have a good day!
Mailing /Shipping Address:
MACTEC Engineering and Consulting of Georgia, Inc.
2801 Yorkmont Road, Suite 100
Charlotte, North Carolina 28208

03 09:23 FR LAW ENGINEERING ENUIR7 357 8637 TO 97046636040 P.02/02
August 15, 2003
Mr, Richard Bridgeman (VIA FACSIMILE)
Division of Water Quality
North Carolina Department of Environment and
Natural Resources
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina
Subject: Gateway Village - Charlotte, North Carolina
Notice of Violation — Compliance Evaluation Inspection
NPICES Permit No. NCO086517
Dear Mr. Bridgeman.
MACTEC Engineering and Consulting, Inc. (MACTEC) on behalf of Gateway is submitting this
letter in response to the referenced Notice of Violation concerning the recently completed
vy "A"Wukr, %_Vulity
Water Quality Protection as the designee of the Division of Water Quality. The inspection
identified two issues deemed to be critical.
The first of these involves the lack of filing of Discharge Monitoring Reports and the completed
Aquatic Toxicology forms with the state. These forms have been completed by the operator in
accordance with the perntit, however since there had not been any flow, the forms were
mistakenly not submitted to the state, The completed forms, both the DMR k and the AT- I will
be sent out under separate transmittal within 5-days of this correspondence,
The second issue involves the flow monitoring provision cited in the inspection report. The
system has a flow totalizer that includes an instantaneous flow indicator. Instantaneous flow rate
is obtainable by timing the flow rate (in gallons) as indicated on the meter, This method of
monitoring is more than adequate and in complete compliance with the method specified in our
permit application. This also the accepted method for flow measurement for the state-wide
general NPICES permit for petroleum contaminated ground water remedl L arion. Regarding the
calibration of the flow meter itself, since flow through the system only occurred for a period of
six months, the flow meter is not due for calibration. Should flow through the system retilm, the
flow meter will be calibrated in accordance with the permit requirements
If you have any questions on this letter, do not hesitate to contact the undersigned,
Sincerely,
MACTEC ENGINEERING AND CONSULTING, INC,
Bruce D. Reilly, P.E.
Principal Engineer
Cc: Rusty Rozelle, Mecklenburg County
Jeff McClanahan, Gateway
MACTEC Engineering and Consulting, Inc,
2801 Yorkrnont Road
Suite 100 - Charlotte, NC 2ezoi3
704-357.8600 - Fax: [phone]
Serving the Charlotte area for over 50 years
TOTAL PACE .02

, r i 7 to ia'o r tet . Cita star
VVillaunt G. FtcawJr- %ecrutury
North C nraelanu i)craruomt or linvitontoctu unct htntu l 1-1,cmutroes
y { Alain Vt". 1 1 l', r. Dowor
lie°i�ety cal"Vttrresaxl5t£
Coleco o l-i %utlots, Dcputy Director
t tivision cam'ut r Quality
July 13, 2004
. Jeff McClanahan, Assistant Chief Engineer
Cousins Real Estate?Corp.
800 W. Trade Street, Suite 100
Charlotte, NC 2821
SUBJECT: T: Compliance Evaluation Inspection
Charlotte Gateway Village, LLC
NP DES Perthit No. NCO086 1'
Mecklenburg County, NCB
Dear Mr.McClanahan:
On June 30, 2004, Mr. David Rimer of the Mecklenburg County Water Quality Program
(MCWQP) conducted an inspection at the subject facility. This inspection was conducted as part
of a cooperative working agreement between Mecklenburg County and'the Division of Water
Quality. The enclosed report should be self-explanatory.
If you have any questions concerning this report or any other matters, please do not
hesitate to call Mr.laic d Bridgeman or me at this Office.
Sincerely,
D. Rex Gleason, P. E.
'water Quality Regional Supervisor
Enclosure
cc: Rusty Rozzelle, MC"WQP
IRCrldjr
File: WQ C*mwayCousins.0W517,0Wdoc
AMA
11.,C,ajmartulr n;ry st nc8z rcl}63Service
-
5- 77- 3-6 8

United ;tags Environmental Protection Agency. Washington . DC 20460 Farm i����z���ved
NPDES Compliance Inspection Report � 31AC MP, No, 2040-0003
Northpppp� t�arolina Depart cut ofEnvironment and Natural Keso roes Approval Expires
Division of Water Quality, Mooresville Regional Office NCDENR
Section Am National Tiata Svste t odi
Transaction Code NPDES Permit No: i' O/DA ' Inspection "Type Inspector Facility T use
NCO086517 04/061-10 C C
Remarks:
lustre tor: Meck-lenb Coun Water ualitrPro r
Inspection Work: Days Facility Self -Monitoring Evaluation Rating lei QA .Reserved_ .........
0) 8 3 N
Section R Facility Data
Name and Location of Facility Inspected. Entry Time: Permit Effective Date:
Gateway Village CWR 10:00 am July 1, 2001
800 Block W. "Trade Street Exit Time.
Charlotte, NC 28202 10:25 am Permit Expiration bate:
Bate. May 31, 2005
June 0, C)CCl
Name(s) of On -Site Representatives ` 'Title(s)----- -Thane No(s):
r. Matt Gustis (Mactee, Inc.) Operator in Responsible Charge (7044) 7-5565
Name and Address of Responsible Official: "Title.
Mr. Jeff' McClanahan Assistant Chief Engineer
Cousins Deal Estate Corp. Phone Na. Contacted?
00 W. Trade Street, Suite 1C�C1
Charlotte, NC 22C12 (70) o 3-C1 ?1
Section C".
Ar
eas Evaluated in In cation I)
Pe t Flow Measurement Operations & Maintenance [Se -Sewer Overflow
Records/Reports Self -Monitoring Program [] Sludge Handling/Disposal D Pollution Prevention
Facility Site Review El Compliance Schedules El Pretreatment Program Multimedia
Effluent/Receiving Waters Laboratory
oratory [1 Sto water F� other-
s) of Inspector(s). Agency/Office
i uer MC"WQP/(704
A Reviewer. Agency/Office
L::::
EPA Forn
. See Attached Sheet(s) for Summary
telephone: Date.
336-5500 June 30, 2004
Date.

GENE
The facility was last inspected by MCWQP on June 30, 2003..A Notice of
Violation/Compliance Evaluation Inspection report was issued to Cousins Real Estate Corp. on `
July 25, 2003.
PERMIT:
The current permit properly describes the facility and appears adequate for the waste
stream being treated.`
e facility treats petroleum -contaminated groundwater u a groundwater
remediation system. G ) that consists of a surge/transfer kdual bag fitters, dual liquid -
phase ul activated carbon vessels,flow metering device, control panel, andtransfer/surnp
pumps.
Mactec, Inc. of Charlotte, NC operates the facility. Mr.:Matt Ca is is the Operator in
Responsible Charge (ORC) for the facility.
RECORDS/REPORTS:,
Discharge Monitoring Reparts were reviewed for the period June 2003 through
May 2004. All self - monitoring ~or d maintenance lags were readily available and in
proper order.
FACILITY SITE
e facility is permitted to discharge to the municipal storm water collection system'
which discharges to Irwin Creek, a Class C water within the Catawba River
l of the major components of facility were in ee but not operating at the time
of inspectiom When Gateway Village was developed, slurry is were installed around the
perimeter of the complex. These slurry walls have effectively prevented groundwater from
rising to the level required for system operations.
FLOW MEASURMENT:
Flow measurement is accomplished using a continuous recording flow meter. This
method is acceptable per permit requirements. e flow meter is scheduled to be calibrated in
July 2004. "

PPPP"'_ I
LABORATORY: "
Prism Laboratories, Inc. and ETT Environmental perform analysis of cflluent samples.
Prism Laboratories ETT Envirorimental, Inc. are certified by the State of North Carolina to
perform analysis on all parameters specified in the permit. Prism Laboratories and ETT
Environmental were not evaluated during this inspection.
EFFLUENURECEIVING ATE
The facility is permitted to discharge to the municipal storm sewer sys eru, which
conveys the effluent to Irwin Creek. The facility was not discharging at the time of inspection.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (D were reviewed for the period June 2003 through
y 2004. The reports indicate that the facility was in compliance with permit effluent its
and monitoring requirements during this period..
OPERATIONS AND MAINTENANCE:
e facility and siteappear to be adequately maintained. The current overall operating
strategy of the site operator appears acceptable for the size and type of the facility.

Michael F, East(
William G. Ross J
North Carolina Department of Environment and Nature
Alan W. Klimek, I
Division of V
>
1/7/04
Alehris Corbitt
MACTEC
2801 Yorkmont. Road NC OFPi OF FWno
Suite 100
Charlotte, NC 28208
SUBJECT: Payment Acknowledgment JAN
Civil Penalty Assessment
Charlotte Gateway Village. LLC
First Union Commons
Mecklenburg County
Permit No: NCO086517
LT-2003-0301 & LT-2003-0302
Deal- Mr.Corbitt:
This letter is to acknowledge receipt ol'check No. 297893 in the amount of $17,000.00 receivi
the subiect facilities and these cases have been closed. Payment of thes pe
es future action by this Division for additional violations of the applicable
cons, or Permits,
iave any questions, please call Kevin Bowden at (919) 733 — 2136.
Sincerely,
r
Y
dr
For Coleen Sullins, Deputy Director
Division of Water Quality
cc: Enforcement File #: LT-2003-0301
Enforcement File #: LT-2(X)3-0302
Mooresville Regional Office Supervisor
Central Files
1617i Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service 1 800 623-7748

VJ A
Michael F. Easley, Govemor
William G. Ross Jr,, Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
5-
%8 . . . . . . . . . .
Division of Water Quality
----------- "I'll,
wc oEPT. OF OMRONMeff
DEC 1 0 2003 ANt)IIATUM;tEWURCES
600VtESvW M"AL OFFICE
!CERTIFIED MAIL 7000 1530 0002 2100 7224 DEC 2 5 2003
RETURN RECEIPT REQUSTED
Mr. Robert N. Speice, Jr.
Charlotte Gateway Village, LLC WA19WW,, SECT!�
8W W. TRADE ST; STE 100
CHARLOTrE. NC 28202
Subject: Remission Request of Civil Penalty Assessment
NPDES Permit Number NC(1t)86517
Charlotte Gateway Village, LLC
Mecklenburg County
Case Number LT-2003-0301
Dear Mr. Speice:
I have considered the information submitted in support of your request for remission in
accordance with G.S. 143-215.6A(t) and have decided to modify the initial civil penalty
assessment of $10,000.00 to the total amount of $8,000.00,
If you choose to pay the modified penalty, send payment to me at the letterhead address within
thirty (30) days of receipt of this letter. Please make your check payable to the Department of
Environment and Natural Resources (DENR),
If payment is not received within thirty (30) days of receipt of this letter, in accordance with
be delivered to the North Carolina Environmental Nianagement Commission's (EMC)
Committee On Civil Penalty Remissions (Committee) for final agency decision.
If you desire to make an oral presentation to the Committee on why your request for remission
meets one or more of the five statutory factors you were asked to address, you must complete
and return the attached form within thirty (30) days of receipt of this letter. Please mail the
completed form to the attention of Bob Sledge at the following address:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Al
IME-
IN 1 IIERR
Customer Service Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617
1800 623-7748 [phone] Fax: [phone]

can cne wrILLen r corn.

:STATE OF NORTH CARCLINA DEPARTMENT OF ENVIRONMENT
('`�
COUNTYOF 4r ,
i3±v ,� =YF ':~ t,4.ys ht }T,tt 2%�4t SrtE.zt�2�3CYktiaiy�2i'�}n s.. k�
t 1 1 ti�1i �,�;1•'i Cjt??ski S���j �� � 1 r��#1 ?i )s �. '7t`J�t3 st} �2
KLENBUR
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
`ty tati;�t{ s t�3tt4wf fE Z icy
CHARLOTTE GATEWAYVILLAGE,
ILLAEy LC\t IY }1)h #£Y4 ?,sttyT�}tt ltSl'3i�rF��`:4ky':t}1�.'1`i���t\l�t��1�`�\�,sl�•.���'�9` ��������i�� �l'i�a��`� ZY�f ..
F t t}{( .}?y k:I SiFi 1t'� �� S�Si r �Y�� EZ ����• �i\\S � `r�` ������h"�14? '� `�`. ��
r { 5 ✓t rsSi yqe t �jst, }�)\ � a., �s��yit t#���ip ��� ��1t``,
APDE%x.�'
q�+t `��`�hh PERMIT NO. NCO08 51'7
PILE NO.
5 tit Cc hSt � iZ t�s ? �s�tt .�'11�1`t31 �tia1:'',. ti`•1�tF�';,'t`��
Having been assessed civil penalties totaling
forth in the assessment document of the Director of the Division of"""',,""!;
ion of the civil ert';
the undersigned; desiringto seek remiss P .�
administrative hearing in the move -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission
of this civil penalty must be submitted to the Director for of the Division of Water Quality within 30 days of receipt
of the notice of assessment. No new evidence in support of a remission request will be allowed after 30 days
from the receipt of the notice of assessment.
This the day of 2001
Y
ADDRESS
SS
Mid rid n l try 1 >
e44 ' er `A4-1/10 6.10ACi m Vt 710 GAG
too
r
�r00 A3
TELEPHONE

NC DEPT, ()FFNfV1RONMFWTA\
ANr�,!v
IJRC
,IFFICE
01 C 111" 2 1.3 2003
"ION

JA74'
..4 Michael F. Easley, (governor
William C. Ross Jr., Secretary
r C7epartment of Environment and Natural Resources
Alan W. Klimek, P.E„ Director
Division of Water Quality
October 3, 2,
Mr. Robert Speice
Charlotte gateway Village, LLC
Sti WEST TRADE STREET t
CHARLO E, NC 28202
Subject: Remission Request of Civil Penalty Assessment
Charlotte Gateway Village, LLC Treatment Facility
yES Permit NC(X)86517
Mecklenburg County
Case Number .,"T-200 -0.301
Bear Mr. Speice:
The Division of Water Quality is in receipt of your request for remission of the civil penalty;
assessed in the matter of the case noted above (submitted on your behalf by M.ACTEC
Engineering and Consulting, Inc.). Unfortunately, we did not find a completed form waiving
your right to an administrative hearing along with your letter when it arrived in this office. As
this is a necessary part of the remission request, we respectfully ask that you complete the
attached waiver form and return it to the attention of Bob Sledge at the letterhead address. Once
the completed waiver form is received, we can continue with the processing of your request.
Your request will be placed on the agenda of the Director's next scheduled enforcement
conference and you will be notified of the result.
If you have any questions about this matter, please contact nee at 91 ) 733-5 i 3, extension 547.
Sincerely,
Bob Sledge, Environmental Specialist
Point Source Compliance/Enforcement Unit
cc: /attachments
Enforcement/Compliance wloriginal
Central Files wattachments
Enforcement File wl3 attachments
Aquatic Toxicology Unit — Kevin Bowden
MACTEC
'4f
1.
Customer Service [Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617
1 $00 623-7746 (919) 733-701 Fax: [phone]

September 10, 2003 #MACTEC
geAlan W. Klimek, Director
int Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Via: Certified Mail -01 Nil I W
Subject: Notice of Violation and Assessment of
Reporting Requirement Violations
NPDES Permit No, NCO086517
Charlotte Gateway Village, LLC Treatri
Charlotte, Mecklenburg County, North
LT 2003-0301
Dear Mr. Klimek. -
This letter was prepared by MACTEC Engineering and
Charlotte Gateway Village, LLC (our client) in respons(
of Civil Penalties assessed against Charlotte Gateway
requirements associated with NPDES Permit No. NCOI
2003 and received by Charlotte Gateway Village, LLC
ci-\ it penalty assessment of $10,000 is for not submitting
Auviv,t through November 2002 and April through Ji
Branch of the Division of Water Quality, The civil pe
client has not responded to the various Notices of V
Division of Water Quality for failing to submit the requi
This letter provides a brief explanation of the events
NOV*s and ultimately the civil penalty assessment and
issues, Presently, MACTECs environmental services
requirements in accordance with the NPDES permit
A k , X,1 D D 0111 1
"I"" ap- � I . race
I No groan
May 200,
2) In mid-T\,I
2002,tox
pipe and
sewage \A
cross -con
water.
3) Since mic
except fo
June 200'
maintenat
flowing 0
4) When the
August 2
arolina Ulill: f,;TOR'o` OFF1 ­ '
CE
IM:1 Wall) VVA.1141 'guu J11tv 111V ticdtllli
a.tween a sanitary sewer
is period in 2002, raw
net system. Once the
tear no longer received
gh the treatment system
Wgh the system in early
treatment system. The
mp; thus, water ceased
ateway Village, LLC on
TEC's Charlotte office
MACTEC Engineering and Consulting
2801 Yorkmont Road, Suite 100 * Charlotte, NC 28208
704-357-8600 * Fax: [phone]

(Cliarlotte Gateway Village, LLC
PPV 'S"Ptember 10, 200.3
P
Page 2
received a telephone call from our client asking for an explanation. It should be
noted that this was the first notification of the lack of reporting or any civil
penalties assessed by the State on this project to anyone within the MACTEC
organization other than Mr. Bruce Reilly. MACTEC immediately set up a
meeting with our client to discuss the situation and evaluate our options.
MACTEC also contacted Mr, Kevin Bowden of the Environmental Services
Branch for clarification of the letter, Mr. Bowden indicated that toxicity self -
monitoring reports had been received by the Branch through January 2003 but
that there had been no toxicity self -monitoring reporting forms received for April
2003 or Jul), 2003� Mr, Bowden stated that he had contacted Mr. Reilly on
several occasions about delinquent reports. Mr. Bowden also indicated that
DMR's had not been submitted to the State for the same time period. After
reviewing our project files, it was determined that monitoring activities of the
treatment system had been conducted on a routine> basis as stipulated in the
permit. No sampling was performed because there was no flow through the
system in 2003 (other than in early June).
Based on discussions with our client, Charlotte Gateway Village, LLC, our Mr. Bruce Reilly and
Mr. Kevin Bow,den of the Environmental Services Branch, MACTEC, with our client's approval,
has developed a plan to mitigate the non-compliance issues. Mr. Bruce Reilly has been removed
as manager for the Gateway Village project. Currently, Mr. Chris Corbin, P.G., the
environmental busines,, unit leader for the Charlotte office, will assume the role of project
manager. Mr. Corbin, will be assisted by Mr. Matt Gustis, P.E., a Senior Engineer with
MAL
T who has experience with treatment systems. Sampling (if necessary) and monitoring
(if' the treatment systern will be conducted in accordance kvuh the NPDES permit by Mr. Jot,
Vickers of our firm.
Since MACTEC became aware of the Notice of Violation and Assessment of Civil Penalties on
August 22, 2003. we submitted to the Division of Water Quality on August 28, 2003, all
delinquent DMR's since February 2003 and toxicity self -monitoring report forms for April and
Julv 2003, Although the civil penalties have been levied against Charlotte Gateway Village,
Ll_C. it is MACTEC's responsibility to submit the required documentation (DMR's and toxicity
self -monitoring reports) to the Division of 'Kater Quality and therefore MACTEC is responsible
for civil penalties levied against our client related to these reporting issues. The issue of non-
respon4iN.cness is also the responsibility of MACTEC, not our client.
the responsibility of MACTEC to remedy, we have taken - the following actions-,
• Mr. Bruce Reillv has been removed from responsible charge of all current projects
involving the submission of toxicity self -monitoring report forms.
• MACTEC will review our internal quality control procedures to determine the evident
failure of our responsibilities.
• Clear, concise lines of communication have been established with our client to respond
better to their needs, Multiple contacts, including the office manager, will be provided,

'age 3
A review of other similar projects under the direction of 'Mr. Reilly
' ''�,
that this is the accepted "culture'* of our firm, but rather a one-time evident failure of one of our
Principals to perform his contractual obligations to our client and our professional responsibilities
to the State of North Carolina. Fortunately, no toxicity limits were exceeded resulting in adverse
impacts to the environment since there has been no groundwater flow through the system. To
our knowledge, this is the first incident where MACTEC, formerly known as Law
Engineering and Environmental Services, Inc., has failed to perform our contractual
obligations which have resulted in a civil penalty assessment by the Division of Water
Quality for non -reporting of results. MACTEC has performed these types of professional
environmental services for over 20 years.
Therefore. we respectfully request that you rescind the civil penalty that has been levied against
our client, We request a meeting at your convenience to further discuss the issues and corrective
actions associated with this project.
MACTEC understands the seriou-,ness of these civil penalties and is committed to working
diligently to make sure that non-cornpliance of the permit does not occur in the future. If you
have any questions concerning this letter, please don't hesitate to contact the undersigned at �704)
357-8600
Sincere] ,
MACTEC ENGINEERING AND CONSULTING, INC.
Christopher L, Corbitt, P.G. Robert E. Smith, Jr., P.E.
Principal Chief Engineer
James Mark Smith, P.E,
Vice President
Cc- Mr, Robert Speice and Mr, Jeff McClanahan. Charlotte Gateway Village, LLC
Mr. Kevin Bowden, Aquatic Toxicology Unit

�N A Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
7 Alan W. Klimek, P.E., Director
Division of Water Quality
August 19, 2003
CERTIFIED MAIL
T RECEIPT }L TESTED
Mr. Robert Speice Al
Charlotte Gateway Village, LLC
800 West Trade Street
Charlotte, North Carolina 28202
AI IONSUBJECT: Notice of Violation and Assessment of Civil Penalties for Reporting Requireme
Violations
Dear'.
OVIREM
This
throu
Bran,
moni
Previ
May
Base
viola
not II
NY DES Pe t No.fN1—vVbojI/
Charlotte Gateway Village, LLC Treatment Facility
Mecklenburg County
LT 2003-0301
)lation for failure to report
nail to and receive
and
tv.

Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have talon into account
the Findings of pact and Conclusions of Law and the factors set forth at G.S. 143B-2 2. t( ), which
are.
(1) The degree and extent of harm, to the natural resources of the State, to the public health, or to
private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or 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; and
(8) The cost to the State of the enforcement procedures:
Within thirty days receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the Department of Environment, health, and NaturalResources
(do not include wa fiver fo ). Payment of the penalty will not foreclose enforcement action for any
" continuing or new violation(s), Please submit payment to the attention of.
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North 'Carolina 27699-1617
Q]Z
2, Submit a written request for remission or mitigation including a detailed justification for such.
request.
A request for remission or mitigation is limited to consideration of the reasonableness of the amount
of the penalty and is not the proper procedure for contesting the accuracy of any of the statements
contained in the assessment letter. Because a remission request forecloses the option of an
administrative hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in dispute. You roust
execute and return to this office the attached waiver and stipulation form and a detailed statement
which you believe; establishes whether.
(a) one or more of the civil penalty; assessment factors in G.S. 14313-282.1(b) were wrongfully
applied to the detriment of the petitioner;
(b) the violater promptly abated continuing environmental damage resulting from the violation,
(c) the violation was inadvertent or a result of an accident;
(d) the violater had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit this information to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-161 i
Please note that all information presented in support of a request for remission must be submitted in
writing. The Director of the Division of Water: Quality will review the information during a
bimonthly enforcement conference and inform you of his decision in the matter of the remission

request. His response will provide details regarding case status, directions for payment and provision
for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions. Please be advised that the Committee cannot consider
information that was not part of the original remission request considered by the Director and
therefore, it is very important that you prepare a complete and thorough statement in support of your
request for remission.
R
3. Submit a written request for an administrative hearing
If you wish to contest any statement in this assessment letter, you must request an administrative
hearing. This request must be in the form of a written petition to the Office of Administrative
Hearings and must conform to Chapter 150B of the North Carolina General Statutes. You must:
File your original petition with the
Office of Administrative Hearings
714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hand -deliver a copy of the petition to
. Dan Oakley
General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Failure to exercise one of the options above within Lhirty days as evidenced by a date stamp (not a
postmark) indicating when we received your response, will result in this matter being referred to the
Attorney General's Office with a request to initiate a civil action to collect the penalty. Please be
advised that additional assessments may be levied for future violations which occur after the review
period of this assessment:
If you have any questions, please contact Mr. Matt Matthews, Supervisor of the Aquatic Toxicology
Unit, at (1) 733-136"
Sincerely,
Alan W. Klimek, Director
Division of Water Quality
Date
Attachments
cc.
Point Source Compliance/Enforcement Unit
Matt Matthews -Aquatic Toxicology Unit
Central Files

FATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT TY OF MECKLENBURG AND NATURAL RESOURCES
IN THE MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ADMINISTRATIVE BEARING AND
STIPULATION OF FACTS
CHARLOTTE GATEWAY VILLAGE, LLC
NPDES PERMIT NO. NCO086517
FILE NO. LT-2003-0301_
Having been assessed civil penalties totaling for violation(s) as set
forth in the assessment document of the Director of the Division of Water Quality dated
I I - r;tvkt tn Ain --I- --:-- —'CAL- --.1 A— 1-1— 141,
assessment document. The undersil-ned further understands that all evidence presented in support of rentission
of this civil penalty must be submitted to the Director of the Division of Water Quality within 30 days of receipt
of the notice of assessment. No new evidence in support of a remission request will be allowed after 30 days
from the receipt of the notice of assessment.
This the day of x2003.
BY
ADDRESS
TELEPHONE

,N? Michael F. Easley, Governor
vlr
itij' tkw William G. Ross Jr., Secretary
01 North Carolina Department of Environment and Natural resources
Alan W. Klimek, P,E. Director
Division of Water Duality
...., f} l
1 f71t}4
kris Corbin
MACT'EC
2801 Yc>rkmont Road
Suite 100 AND kl �At ` r�" l
Charlotte, N( 282t 8 RCCO
;"Vk 0REe , � � rVr f
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Charlotte Gateway Village, LLC
First Union Commons W
Mecklenburg County ER :w!1 .f
Permit No: NCO08651
LT-2003- 301 & LT- 003-0302
Dear Mr.Corbitt:
This letter is to acknowledge receipt of check No. 297893 in the amount of $17,000.00 received
from you dated December 23, 2003. This payment satisfies in full the civil assessments levied
against the subject facilities and these cases have been closed. Payment of thes penalties in no way
precludes future action by this Division for additional violations of the applicable Statutes,
Regulations, or Permits.
f you have any questions, please callKevin Bowden at 919) 733 - 2136.
Sincerely;
For Coleen Sullins, Deputy Director
Division of Water (duality
cc: Enforcement File : LT-2003-0301
Enforcement File #: LT-2 03-03 2
Ma
1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Ct
tauter Service 1 800 6 3- `

JA7' ,
} ..k Michael F. Easley, Governor
William G. Mass Jr., Secretary
} C Department of Environment and Natural Resources
4 Alan W. Klimek, P.E., Director
G?ivisicn cif Water Quali
` DEC 1 0 2003 NC DEPT. OF ENWRONMLNT
NATURALAND u
MOORESVILLE F190MAL OFFICE
,F
CERTIFIED MAIL, 7000 1530 0002 2100 7231
RETURN RECEIPT REQUESTED
Mr. James Patterson
First Union Commons
28 10 ONE FIRST UNION CENTER
CHARLOTTE, NC 2 202
Subject: Remission Request of Civil Penalty Assessment
NPD S Permit Number NCO086886
First Union Commons
Mecklenburg County
Case Number LT-2003-0302
Tear Mr. Patterson:
I have considered the information submitted in support of your request for remission in
accordance with G.S. 143-215.6A(t) and have decided to modify the initial civil penalty
assessment of 0,{10 .00 to the total amount of 9,000.0 .
If you choose to pay the modified penalty, send payment to me at the letterhead address within
thirty (30) days of receipt of this letter. Please make your check payable to the Department ment of
Environment and Natural Resources (ICE ).
ani
col
vexed to the North Carolina Environmental Management Commission's (EMC)
itt e On Civil Penalty Remissions (Committee) for final agency decision.
Iesire to make , oral presentation to the Committee on why your request for remission
one or more of the five statutory factors you were asked to address, you must complete
am the attached form within thirty (30) days of receipt of this letter. Please mail the
ted form to the attention of Bob Sledge at the following address:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 flail Service Center
Raleigh, NC 27699-1617
i WO
;ion of Water Quality 1617 Mail Service Center Rale
919) 733-701 Fax. (919) 3 -9 1

Sincerely;

STAIt OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF MECKLENE URG
IN THE MATTER OF ASSESSMENT J WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST 4 ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FIRST UNION COMMONS
NPTIES PERMIT NO. NCO086886
FILE NO. LT-2003-0302
Having been assessed civil penalties totaling 4 16100e> for violation(s) as set
forth in the assessment document of the Director of the Division of Water Quality dated A*z *s 141, 24" 3
er
the undersigned, desiring to seek remission of the civil penalties, does hereby waive the right to an
administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission
of this civil penalty must be submitted to the Director of the Division of Water Quality within 30 days of receipt
of the notice of assessment. No new evidence in support of a remission request will be allowed after 30 days
from the receipt of the notice of assessment.
This the day of Oe- ,2003.
BY 1,4,7�
BrIA*
ADDRESS
Aj
TELEPHONE
7,01/— 5f�7—bi:�470

AND NATtJr?f%,L,
MOORES'10,"l-
OCT 2 8 200.)
WATER"k ii, I I
... TION

J-T
} ... Michael F. Easley, Governor
` William C. Boss Jr., Secretary
r t Department of Environment and Natural resources
•4
Alan W Klimek, r. „Director
Division of Water Quality
October 3, 200
Mr. James Patterson
First Union Commons
28 10 ONE FIRST UNION CENTER
CHARLOTTE, NC 28202
Subject: Remission Request of Civil Penalty Assessment
First Union Commons Treatment Facility
ICES Permit NC()ffi
Mecklenburg County
Case Number ber° LT-2 } 3- }302
Dear Mr. Patterson. -
The Division of Water Quality is in receipt of your request for remission of the civil penalty
assessed in the matter of the case noted above (submitted on your behalf by MACTEC
Engineering and Consulting, Inc.). ;Unfortunately, we did not find a completed form waiving
your right to an administrative hearing along with your letter when it arrived in this office. As
this is a necessary part of the remission request, we respectfully ask that you complete` the
attached waiver form and return it to the attention of Bob Sledge at the letterhead address. Once
the completed waiver form is received, we can continue with the processing of your request.
Your request will be placed on the agenda of the Director's next scheduled enforcement
conference and you will be notified of the result.
If you have any questions about this matter, please contact me at (1) 733-5083, extension 547.
Sincerely,
Bob Sledge, Environmental` Specialist
Paint Source Compliance/Enforcement Unit
cc: w/attachments
Enforcement/Compliance w/originals tx
Central Files w/attachments
Enforcement File w/3 attachments
Aquatic Toxicology Unit - Kevin Bowden
MAC C
f.,
Customer Service Division of Water cluality 1617 Mail Service {enter Raleigh, NC 27699-1 17
1 800 3-7746 [phone] Fax: {919) 3-961

September 15, 2003 4MACTEC
q�Pr. Ian W. Klimek, Director
oint Source Compliance/Enforcernent Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Via: Certified Mail
OPP
ozlytp;�
Subject: Notice of Violation and Assessment of Civil Penalties for c/'0'4?�q
Reporting Requirement Violations op / o-y
NPDES Permit No. NCO086886
First Union Commons Treatment Facility
Charlotte, Mecklenburg County, North Carolina
LT 2003-0302
Dear Mr. Klimek:
This letter was prepared by MACTEC Engineering and Consulting, Inc. (MACTEC), on behalf of
Childress Klein Properties (our client, aka First Union Commons) in response to a Notice of
Violation and Assessment of Civil Penalties assessed against First Union Commons for violations
of reporting requirements associated with NPDES Permit No. NCO086886, In your letter, dated
August 19, 2003 and received by First Union Commons on August 22, 2003, you indicate that the
civil penalty assessment of $10,000 is for not submitting toxicity self -monitoring report forms for
June 2003 to the Environmental Sciences Branch of the Division of Water Quality, after receiving
Notices of Violation for failing to submit toxicity self -monitoring report forms in April and May
2003,
A previous Notice of Violation and Civil Penalty Assessment of $4,000 was also levied to First
Union Commons by the Division of Water Quality for failing to submit ithe required reporting
documentation in October through December 2002 and March 2003, This civil penalty was paid
by MACTEC and submitted to the Division of Water Quality on August 29, 2003 via certified
mail.
This letter provides a brief explanation of the events which resulted in the issuance of several
avOvs and ultiniately two civil penalty assessments and our plans to correct these non-
compliance issues. Presently, MACTEC's environmental services are, limited to monitoring and
reporting requirements in accordance with the NPDES permit for the facility. This project has
been managed by Mr. Bruce Reilly, a Principal Engineer within our firm.
When the civil penalty letter was received by First Union Commons on August 22, 2003, Mr,
Bruce Reilly was contacted by our client on August 25, 2003 asking for an explanation. Mr.
Bruce Reilly then notified his supervisor, who in turn notified the Charlotte office manager, Mr.
Mark Smith, It should be noted that this was the first notification of the lack of reporting or any
civil penalties assessed by the State on this prqject to anyone within the MACTEC organization
other than Mr. Bruce Reilly. Mr. Mark Srnitb then contacted our client to set up a meeting to
discuss the situation and evaluate our options. Mr. Mark Smith and Mr. Chris Corbits met with
Mr. Jim Patterson and Mr. Gary Smith of Childress Klein Properties on August 27, 2003.
MACTEC also contacted Mr, Kevin Bowden of the Environmental Services Branch for
clarification of the letter, Mr. Bowden indicated that toxicity self -monitoring reports had been
MACTEC Engineering and Consulting
2801 Yorkmont Road, Suite 103. Charlotte, NC 28208
704-357-8600 * Fax: [phone]

mrpv"
First tInion Commons Trearinent Facilin
(11 adone, North Carolina
S,,ntentber 15 2003
received by the Branch through December 2002.
monitoring reporting forms received for March 200:
had contacted Mr. Reilly on several occasions ab
indicated that DMR's had not been submitted to i
reviewing our project files, it was determined that n
had been conducted on a routine basis as stipulai
laboratory analysis was performed because water
toxicity testing was performed on a quarterly basis.
chronic toxicity testing of the system's effluent has p;
C�
Based on discussions with our client, First Union Cot
Bowden of the Environmental Services Branch, P
developed a plan to mitigate the non-compliance iss,
manager for the First Union Commons project.
environmental business unit leader for the Charlo,
manager, Mr. Corbin will be assisted by Mr. )
MACTEC, who has experience with treatment Bytei
ut that there had been no toxicity self -
or June 2003. Mr. Bowden stated that he
wut delinquent reports, Mr. Bowden also
ie State for the same time period. After
onitoring activities of the treatment system
,d in the permit. Monthly sampling and
low was present through the system and
oxicity self -monitoring results indicate that
ssed in 2003.
aeons, our Mr. Bruce Reilly and Mr. Kevin
[ACTEC, with our client's approval, has
of the treatment system will be conducted in accordance with the PDES permit by Mr. Joe
Vickers of our firm.
Since MACTEC became aware of the Notice of Violation and Assessment of Civil Penalties on
August 25. 2003, we initially submitted to the Division of Water Quality on August 28, 2003, the
most recent DMR (July 2003) and the toxicity self -monitoring report form for June 2003. The
remaining delinquent reporting forms were submitted during the week of September 1, 2003,
Although the< civil penalties have been levied against First Union Commons, it is MACTEC's
responsibility to submit the required documentation (DMR's and toxicity self -monitoring reports)
to the Division of Water Quality and therefore MACTEC is responsible for civil penalties levied
against our client related to these reporting issues. The issue of non -responsiveness is also the
responsibility of MACTEC, not our client.
Based on the seriousness of the accepted violations and penalties assessed, which will be wholly
the responsibility of MACTEC to remedy, we have taken the following actions:
• Mr. Bruce Reilly has been removed from responsible charge of all current projects
involving the submission of toxicity self -monitoring report forms,
• MACTEC will review our internal quality control procedures to determine the evident
failure of our responsibilities.
• Clear. concise lines of communication have been established with our client to respond
better to their needs. Multiple contacts, including thy:. -office manager, will be provided,
• A review of other similar projects, under the direction of Mr. Reilly will be performed to
assure that the projects are in compliance with applicable State and Federal guidelines
and permit requirements.
MACTEC apologizes for our disregard of our responsibilities on this project. We do not believe
that this is the accepted "culture" of our firm, but rather a one-time evident failure of one of our
Principals to perform his contractual obligations to our client and our professional responsibilities
to the State of North Carolina. To our knowledge, this is the first incident where MACTEC,

C
first Union Commons Treatment Fac ihts
Charlotte, North Carolina
September 15, 2003
attu cctrr cAIVU MAIVIIN UNIS Idtru wscrt tilts project,
MACTEC understands the seriousness of these civil penalties and is committed to working
diligently to make sure that non-compliance of the permit does not occur in the future. If you
have any questions concerning this letter; please don't hesitate to contact the undersigned at (' 04)
5i-8600,
Sincerely,
MACTk ENGINEERING AND CONSULTING, INC.
Christopher L. krbitt, G Robert E. Sun r., P.E.
Principal Chief Engineer
S
/mes Mark Smith, F.E.
Vice President
Cc: Mr, Jim Patterson and Mr. Gary Smith; First Union Commons
Mr. Kevin Bowden, Aquatic Toxicology Unit

August 1 , ' 200 3
CERTIFIEDMAIL
T N CEIPT �� STEDAUG 2 ,.e 201,03,
r. James L. Patterson
First Union Commons
2810 One First Union Center WA TE
SE
CNN
301 S. College Street
Charlotte, North Carolina. 28202
SUBJECT: Notice of Violation and Assessment of Civil Penalties for Reporting Requirement
Violations
DES Permit No. NCO08688
First Union Commons Treatment Facility
Mecklenburg County
L"T-2003-0
Dear'Mr. Patterson:
This letter transmits a Notice of Violation al i Assessment of Civil Penalty assessed against First Union
Commons i the amount of $
This assessment is based upon the following fact; the Tune 2003 toxicity self -monitoring report form was
not filed with the Environmental Sciences Branch of the Division of Water Quality within the thirty (30)
day reporting period in accordance with the monitoring and reporting requirements contained in your
DES Permit.
A previous Notice of Violation and Civil Penalty Assessment for failure to report the October through
December :2002 and March 2003 toxicity self -monitoring report forms on time to the Environmental
c a- - -. D -�, 111 -- —f + tha f°�re14-v it rartlfipri mail rtat d 6;17101 ntirec of Vinl'itiom for faiiinrr

Pursuant to G.S. 143-15.6A(c), in determining; the amount of the penalty I have taken into account
the Findings of fact and Conclusions of Law and the factors set forth at G.S. `,143B-28.1(b), which
are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface ater quantity or quality or on air quality
(4) The cost of rectifying the damage;
() The amount of money saved by noncompliance;
(6) Whether the violation was corrunitted willfullyor 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; and
(8) The cost to the State of the enforcement procedures.
Within thirty Clays receipt of this notice, you trust do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the Department of Environment, Health, and Natural Resources
(do not include waiver farm). Payment of the penalty will not foreclose enforcement action for any
continuing or new violation(s). Please submit payment to the attention of:
Point Source Compliance/Enforcement Unit
:Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617"
OR
2. Submit a written request for remission or mitigation including a detailed ,justification for such
request.
A request for remission or mitigation is limited to consideration of the reasonableness of the amount
of the penalty and is not the proper procedure for contesting the accuracy of any of the statements
contained in the assessment letter. Because a remission request forecloses the option of an
administrative hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in dispute. You must
execute and return to this office the attached waiver and stipulation form and a detailed statement
which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143-282.1(b) were wrongfully
applied to the detriment of the petitioner;
(b) the violator promptly abated continuing; environmental damage resulting from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit this information to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for remission must be submitted in
writing. The Director of the Division of Water Quality will review the information during a
bimonthly enforcement conference and inform you of his decision in the matter of the remission

request. His response will; provide details regarding case status, directions for payment and provision
for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions: Please be advised that the Committee cannot consider
information that was not Bart of the original remission request considered by the Director and
therefore, it is very important that you prepare a complete and thorough statement in support of your
request for remission.
R
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an administrative
hearing. This request must be in the form of a written petition to the Office of Administrative
Hearings and must conform to Chapter 150B of the North Carolina. General Statutes. You must:
File your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hand -deliver a copy of the petition to
. Data Oakley
General Counsel
Department of Environment and Natural Resources
601 Mail Service Center
Raleigh, North Carolina 27699-1601
Failure to exercise one of the options above within thinI days as evidenced by a:, date stamp (not a
postmark) indicating when we received your response; will result in this matter being referred to the
Attorney General's Office with a request to initiate a civil action to collect the penalty.Please be
advised that additional assessments may be levied for future violations which occur after' the review
period of this assessment.
If you have any questions, please contact Mr, Matt :Matthews, Supervisor of the .Aquatic 'Toxicology
Unit, at [phone].
Sincerely,
Alan W. Klimek, Director
Division of Water Cuatity
Q
irate
Attachments
cc:
Point Source Compliance/Enforcement Unit
Matt Matthews -Aquatic Toxicology Unit
Central Files

FOUN
F NORTH CAR. LINA DEPARTMENT t F ENVIRONMENT
A NATURALRESOURCES
Y OF C E G �
IN T MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST" } ADMINISTRATIVE BEARING AND
STIPULATION OF FACTS
FIRST UNION COMMONS )
DES PERMIT NO. NCO0888I
FILE NO LT-2003-0302
Having been assessed civil penalties totaling for violation(s) as set
forth in the assessment document of the Director of the Division of Water Quality dated
, the undersigned, desiring to seek remission of the civil penalties, dues hereby waive the right to an
administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission
of this civil penalty must be submitted to the Director of the Division of Water Quality within 30 days of receipt
of the notice of assessment. No new evidence in support of a remission request will be allowed after 30 days
from the receipt of the notice of assessment.
This the day of , 2003.
Y
ADDRESS
TELEPHONE

DIVISION OF WATE
August 8, 21
R-ANDUM
Alan Klimek
Jimmie Overtq�
Matt Matthews fi\
Kevin Bowden
Charlotte Gateway Village, LLC
NpDES Permit No. NCO086517
Mecklenburg County
File No. LT 2003-0301
IME
�UALITY
WK, IDEPT0F 1F,NV,R0NML-NT
AND NAT,,,'P �- RE03"XJRCES
IVIOORESI' "''-.WRCE
AUS 2 0 2003
scent
W Na, mp
ATERWAUTY SWIN
;t of: "
ment action,
C I _
Result Test Initiation AT NR _NOV Date M
NR/Pass 7/26/99 1014/99 10/7/99
NR LT 2000-0006 ($500.00) Paid 1/22
NR/Fail LT 2001-0001 12/18/00(Did not issue)
NRIH 8/23/01 8/24/01
NRJFaiI 7/22/02 1/3/03 1/13/03 1/21
NR/<45 8/19/02 1/3/03 1/13/03 1/21
NRI<45 9123/02 1/3/03 1/13/03 1121
NR/Fail 10/28/02 3/4/03 2/3/03 NC
NRIH 3/4/03 2/3/03
H 3/4/03
H 2/19/03 6/25/03
NR PROPOSED ENFORCEMENT ACTION 7123/03
NR
The facility has been issued numerous NOVs for non and/or late -reporting of toxicity self mo
to Charlotte Gateway Village, LLC for late/non-reporting of toxicity self -monitoring data have 1
,Ling when the AT report forms are due and contained proper procedures and addresses for submi
fice. All NOVs indicated that the facility is in violation of Title 15A, NCAC 213 .0506 (a)(1)(A
-.t name and telephone number if additional information is needed. All NOVs, have signed, return

Gage
Marlotte Gateway Village, LLC
august 8, 2003
gainst Charlotte Gateway Village, LLC dated 11/21/00
enforcementer'action did. not issue because it remained in the entry ice or ,grey
ter n
;d%to the Director for signature.
-- __! . Ir*--'—*—e fr;__' r W(I rpe-nrrtc indicate that five
i
en the case.
Piles and noted tha
I
I vw:.:vaat.,.,..,..t....t.r....._- -r'r--r
tse find data and correspondence supporting this Notice of Violation and Ci
L ..s _ ......__.....t......7 TaTn,.T h —;—t rllq± .
office has discussed the NOVA with staff from the Mooresville Regional uttice wno recomrncflu talus
Should you have any questions or need additional information, Tease contact me at 2136.
Rex Gleason -Mooresville Regional Office
Paint Source Compliance/Enforcement Unit
Aquatic Toxicology Unit Files

DIVISION OF WATER QUALITY - CIVIL PENALT'
Violator:
County: eckenbu County
Case Number: LT _2003-0301
MEMMEM
;SMENT
Facilit
S
olation;
it ( )significant
nificant
it )significant
pificant
cant ( )sigmas�
significant
cant )signific.
,nificant
nt ( )significant
;nificant
icant ( )significant
significant
d )not significant )moderately significant )significant
( )very significant ( )extremely significant
te cost to the State of the enforcement procedures.
)not significant ( )moderately significant )significant
)very significant )extremely significant
its Alan Klimek, P.E.

DWQ- - CIVIL ASSESSMENT REMISSION FACTORS CONSIDERATION
Case Number: LT 2003-0301 Region: Mooresville County: Mecklenburg
Assessed Entity: Charlotte Ggitetwffa y Village, LLC
Whether one or more of the civil penalty assessment factors were wrongly applied to the
detriment of the petitioner;
Notes:
wtiettier the vioiator prompuy uummumaj-1
violation;
otes•
Notes*
-emedial actions.
in t —es
(Check one)
denied_ Full Remission— Partial remissionAmountremitted_
Alan Klimek, P.E.

rx-r NOV
NC'ti.1E€tr3xlJutat z*��xx. rr xx.m.+�= ••--,._+� dam^, •M ... xvxvran
ssaust Afi xi sry £ eg&aa; Mpo c xx, H OTH34 2 y
PT'; 0.050 S at 200i H NR NR
7QIO: 0 IWC(%)100 order:

LC50/Acute Toxicity Test
(Mortality expressed as %, combining replicates)
Concentration
Mortality
startlend
Lt Method of Determination
Probit
Control
qT
95% Confidence Limits Moving Average
KPH
% Spearman Karber tither
y
Ceriodaphnia du i
Organism Tested
DFM Form AT-1
t
*w1w

I

._ � _.. ��.. a� a�

I

7,y
NNA
North Car
iFIED MA11.
RN
CE11>T TE1
3brt Speice
rite Gateway Village, LLC
`est Trade Street
ytte, North Carolina 28202
Violations
DES Permit t o. NCO086517
Charlotte Gateway Village, LLC Treamic
Mecklenburg County
LT 20€13-0301
ar Mr. Speice:
is letter transtnits a Notice of Violation and Assessmer
.teway Village, LLC in the amount of
i
=Facility
Micha
William
AlanW. Klimek, P.E., Director
Division of Water Quality
)on the above facts(s) and conclusions of law,1 hereby assess Charlotte Gateway vitl
civil penalty for this sixth violation of G.S.143-215.65, pursuant to th
1 to me by North Carolina Environmental Management Commission Regulation 15
G.S. 143-215.6A(h). Any continuing violation(s) may subject you to additional pen,
f Water Quality 1617 Mail Service Center Raleigh, NC 7699-1617 [phone] Cus 1 al

Pursuant to G.S. 143-215,6A(c), in determining the amount of the penalty I have taken into account
the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282. I(b), which
are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) = The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or 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-, and
(8) The cost to the State of the enforcement procedures.
Within thirty days receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the Department of Environment, Health, and Natural Resources
(do not include waiverform). Payment of the penalty will not foreclose enforcement action for any
continuing or new violation(s). Please submit payment to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
QR
2. Submit a written request for remission or mitigation including a detailed justification for such
request.
A request for remission or mitigation is limited to consideration of the reasonableness of the amount
of the penalty and is not the proper procedure for contesting the accuracy of any of the statements
contained in the assessment letter. Because a remission request forecloses the option of an
administrative hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in dispute. You must
execute and return to this office the attached waiver and stipulation form and a detailed statement
which you believe establishes whether:
(a) 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;
(b) the violator promptly abated continuing environmental damage resulting from the violation;
(c) the violation was inadvertent or a result of an accident;
payment of the civil penalty will prevent payment for the remaining necessary rernei
actions.
submit this information to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
e note that all information presented in support of a request for remission must be subrr
ig. The Director of the Division of Water Quality will review the information during a
nthly enforcement conference and inform you of his decision in the matter of the remis

request. His response will provide details regarding case status, directions for payment and provision
for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions, Please be advised that the Committee cannot consider
information that was not part of the original remission request considered by the Director and
therefore, it is very important that you prepare a complete and thorough statement in support of your
request forremission.
QR
Submit a written request for are administrative hearing:
1f you wish to contest any statement in this assessment letter, you, must request an administrative
hearing. This request must be in the forma of a written petition to the Office of Administrative
Hearings and must conform to Chapter 150B of the North Carolina general Statutes. You must.
Pile your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hated -deliver a copy of the petition. to
Ilan Oakley
General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Failure to exercise one of the optionsabovewithin Lhirtj days as evidenced by a date stamp (not a
postmark); indicating when we received your response, will result in this matter being referred to the
Attorney Generars Office with a request to initiate a civil action to collect the penalty. Please be
advised that additional assessments may be levied for future violations which occur after the review
period of this assessment.
if you have any questions, please contact Mr. Matt Matthews, Supervisor of the Aquatic Toxicology
Unit, at (91 ) 73-2136.
Sincerely,
Alan W. Klimek, Director
Division of Water Quality
Date
Attachments
cc: Rex Gleason -Mooresville Regional Office
Paint Source Compliance/Enforcement Unit
Matt Matthews -Aquatic Toxicology Emit
Central Files

STATIC OF NORTH CA OLINA DEPARTMENT OF ENVIRONNIENT
AND NATURAL RESOURCES
COUNTY OF MECKLENBURG�
IN THE MATIER OF ASSESSMENT WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST }ADMINISTRATIVE HEARING AND
} STIPULATION OF FACTS
CHARLOTTE GATEWAY VILLAGE, LLB �
DES PERMIT NO. NCO086517 )
FILE NO. LT-2003-030
Having been assessed civil penalties totaling for violation(s) as set
forth in the assessment document of the Director of the Division of Water Quality dated
, the undersigned, desiring to seep remission of the civil penalties, does hereby waive the right to an
d "nstrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented its support of remission
of this civil penalty must be submitted to the Director of the Division ofWater Quality within 30 days of receipt
the notice of assessment.
day of 2003.
BY
ADDRESS
TELEPHONE

governor
A7' r� William G• Ross, Jr- secrilary
p Department of Environment and Natural Resources
Alan W. Klimek, P-E„ Director
1 Division Of Water Quality
July 23, 2003
Cr 1 tJ r 0 0 4- t 36 f
CERTIFIED MAIL
RETURN RECEIPT RE UESTETJ
Nlr, Rob Deice, Senior Property Manager
Cousins Real Estate -Gateway Village
1S()o West Trade Street
Suite 100
Charlmte, NC 29202
SUBJECT: NOTICE.OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NCt)086 S17
Charlotte Gateway Village I Cousins Real Estate
Mecklenburg County
Dcar Mr. Spcicc:
lion dfTitle 1 A of the North Carolina Administrr filed nolaterThis is to info you that the Environmental Sciences Branch has not received your toxicity self-ive monitoring
ti
which states that -monthly monitoring reports shall b
report form for the month of May 2C?t13. This is in viola
Chapter 2> Subchapter 2B, Section .i3 (i (a)(iodf
than 30 days after the end of the reporting period for which the report was made." dicers that a chronic toxicity
There is tic T ischarge Monitoring Report (DMR) in Central Files fol May to indicate y
t ie uirs ynu t€t'subrnit a Aqu tic- T"oaticzt "pelf-Moraitorzn
test was conducted: Please note that your 1NT'Tfw pe rl
Form to this office eluting month in which toxicity testing is required, regardless of whether a discharge occurs from
the facility.
Please remember thaat reporting o toxicity self-mo i€oring datRe o
must be entered on your Dirting form (AT Report form) must bea dual requirement, Toxicity test
;charge Report and the Toxicity
11 within the aired dine frame. TI there
you should also complete the
submitted to: T W /E 13, 1 fi21 M a mon h inail Service t vhiiich trax a aNty testing is required.then
comment suction and submit
is no discharge from the facility during the
^f chc, Aquatic Toxicity Test Form, wrote No alp, rt, t`acillt concerning sub mission of
nrd- itadicate that prevav�c w t
cst Form to this office 11 have a in the event the facility does tsc a
ents contained in your NPO
considered' noncompliant with the. reporting requirem
3 until you make acceptable demonstraton curie trrihe Env
od.oPlease be advisednmental Sciences Bthat lit;
torte as auv$,.. .__ —
rc or€in *ref toxin€ self-rmoni€onnO data su its v
his Notice, pleas'
-fie reveres side of this Notice contains a summary Or irnstions concerning this toxicity monitoring and reporting
requirements. please read this one page summryandunif you have any que
unit at {919) 7'33-2136.
Mr, Kevin Bowden with the Aquatic To
xicolojgy
Sincerely,
Jim e Overton
Assistant Water Quality Section Chief
for Environmental Sciences
cc. Rex Gteason- NWOresvilte Regional OJ r e
John Lesley:- Mooresville Renon.al Office
Aquatic Toxicology Unit Fifes
Central Fibs
Raleigh, ND 279
N w "R Environmental Sciences Branch
161 Mail Service Center
Customer service

WHOLE EFFLUENT TOXIC['
IN ADDITI(
North Carolina Division
Environmental Sciei
1621 Mail Servi(
Raleigh, North Carolin
I
> Toxicity test results shall be riled with the Environmental Scien(
port wmcn is suormucc to:
at r Quality
Center
1- 1617
ing address:
Water Quality
es Branch
Center
27699-1621
> Toxicity test condition language contained in your NPDES permit may require use (
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails (
permit limit, then at least two multiple concentration toxicity tests (one per month) v
months. As many analyses as can be completed will be accepted. If your NPDES
concentration toxicity testing upon failure of any single quarterly test, you
concentration toxicity testing or multiple concentration toxicity testing per the I
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influer
3�- Toxicity testing months are specified by the NPDES Permit, except for NPDES '
monitoring requirements (eg, if the testing months specified in your,NPDES p(
0 Z, _=1
December, then toxicity testing must be conducted during these months).
> Should the permittee fail to monitor during a month in which toxicity monitoring i!
1� 0
begin immediately until such time that a single test is passed. Upon passing this mo
revert to the quarterly months specified in the permit. Please note that your permit r
I
> If your NPDES Permit specifies episodic monitoring and your facility does not h,,
then you must provide written notification to the Environmental Sciences Branch t
during, the first six months of the calendar year.
C,
If you receive notification from your contract laboratory that a test was invalids
Environmental Sciences Branch at [phone] and provide written docui
invalidated and the date when follow-up testing will occur.
If your facility is required to conduct toxicity testing during a month in which no d:
information block located at the top of the AT form indicating the facility name, I
the nionth/year of the subject report. You should also write -No Flow- on the AT
normal procedures.
> The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Respc
which have not received a facility classification, In these cases, a duly authorizec
form, The AT form must also be signed by the performing tab supervisor.
> To determine if your AT test forms were received on time by the Division of Water
our toxicity test results certified n_iai1, return receipt requested to the EnvironmenU
?ermits which contain episodic toxicity
snit are March, June, September, and
required, then monthly monitoring will
nthly test requirement, the permittee will
nay or may not contain this language,
,ve a discharge from January 1-June 30,
C�
y June 30 that a discharge did not occur
,red, you should immediately notify the
rientation indicating why the test was
scharge occurs, you should complete the
iermit number, pipe number, county and
`orm, sign the form and submit following
risible Charge (ORC) except for facilities
facility representative must sign the AT
Quality, y9A may canside, -submitting
it Sciences Branch.

A
Michael F, Easdey
Governor
(
WiHiarn G. Ross,,lr., Secretary
tom'✓` `� Department of Environment and Natural Resources
Alan W', Klimek, F .E., Director
Division of Water Quality
June 25, 2 O3
-706,z 10 0 15361 2 7 6.3 ;
CERTIFIED MAIL
:R cTU 2N R C"1MIPT REC
cxu
UESTELD
Mr, Randall Nltiler
Cousins Real Estate -Gateway Village
8()o West "Trade Street
Suite 100
Charlotte, IBC 24202
SUBJECT:
NOTICE Of VIOLATION
Effluent Toxicity Testing
iNPDES Peranrt Noa NC0086517
Charlotte:; Gateway village t Cousins Real Estate
Mecklenburg County
Dear. ivlr. Miller.
n i i� to inform you that the Environmental Sciences has not received your toxicity Self -monitoring
... ,. ... _s. r+.._..i..... A'4_;x;CttltiVPCtdeI
E
at Form to this office in the: event the t kiln u€ c'S 1101
__........»......,.;tc nra ntiimprt in you
t—;i itv rna'nitr
reverse 5111C V1 tmt — -- ,•,• _ __ ,.
Please read this one page summary and if you have anyquestions concerning this Notice, please c
owden with the Aquatic Toxicology Unit at (919) 7 3-2136.
Sincerely,
Rmr�ie O erton
Assistant Water Quality Section Chief
For Environmental Sciences
ex sleison- ;\Iooresville Regional Office
)hn Lesley -,'Mooresville: Regional Office
,quatic Toxicology Unit Files
ventral files
Environmental Sciences Branch 1621 Mail Service Center Raleigh, NG 2769 -I

ox
North Carolina Divisi
Central
1617 Mail Sep
Raleigh, NC
North Carolina Divisi
1\c11ti su, i,v,t
rmorfirrr* Rui d (eg, January test result is one Dy the ena or retort
> Toxicity test condition language contained in your NPDES permit
upon failure of any single quarterly toxicity testa if the initial p
permit limit, then at least two multiple concentration toxicity tests
months. As many analyses as can be completed; will be accepted
concentration toxicity testing upon failure of any single qua,
concentration toxicity testing or multiple concentration toxicity
effective July 1 1999. Follow-up multiple concentration toxicity
> ' Toxicity testing months are specified by the NPDES Permit, ex
monitoring requirements (eg, if the testing months specified it
December, then toxicity testing must be 'conducted during these r
> Should the perittee fail to monitor during a month in which tox
begin immediately untilsuch time that a single test is passed. Up
revert to the quarterly months specified in;he permit. Please note
If your NPDES Permit specifies episodic monitoring and your f
then you must provide written notification to the. Environmental
during the first six months of the calendar year.
> if you receive notification from your contract laboratory that
Environmental Sciences Branch at [phone] and proti
invalidated and the date when follow-up testing will occur.
If your facility is required to conduct toxicity testing during a rtt
information block located at the top of the AT form indicating
the monthlyear of the subject report, You should also write "No
normal procedures.
The Aquatic Toxicity Test forms shall be signed by the facili
which have not received a facility classification. In these c
form. The AT form must also be signed by the performing It
> To determine if your AT test forms were received on time b
v)ur to icity test results certified mail, return receipt request
to per month) will be conducted over the following two
f your NPDESpermit does not require use of multiple '
ly test, you may choose to conduct either single
}zing per the Division's 'T enforcement initiatives
ing will influence the Division's enforcement response.
it for NPDES Permits which contain episodic toxicity
our NPDES permit are March, June,' September, and
ths).
ty monitoring is requited, then monthly monitoring wilt
passim this monthly test requirement, the pernittee will
at your permit may or may not contain this language.
lity does not have a discharge from January I -June 30,
ences Branch by June 30 that a discharge did not occur
:st was invalidated, you should immediately notify the
written documentation indicating why the test was
,i in which no discharge occurs, you should complete the
facility name., permit number, pipe number, county and
ow11 on the AT form, sign the; force and submit following
y
ty's Operator in Responsible: Charge (ORC) except for facilities
ases, a duly authorized facility representative must sign the A
�b supervisor.
the Division of Water Quality, ygAnay consider submitting
ed to the Environmental Sciences Branch.

Michael F. Easley
Governor
William G, Ross, Jr., Secretary
r-4_c, Department of Environment and Natural Resources
DW&�i
Alan W. Klimek, P.E., Director
3, 2Division of Water Quality
February 003
7011? 3*00 6011 0 6­0 S
CERTIFIED A_MAIL �TED
EE�:NEN �RECEIPT RE�UES
Mr. Randall Miller
Cousins Real Estate -Gateway Village
goo West Trade Street
suite 100
Charlotte, North Carolina 28202
SUBJECT: NOTICES OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NCO086517
Charlotte Gateway Village / Cousins Real Estate
Mecklenburg County
Dear Mr, Miller: This is to inform you that the Env ir6nmental Sciences Branch has not received your toxicity self-
--ti— nf ormher and November 2002. This is in violation of Ttie 15A
,on met with representatives fri
at I t" I
nation filled in at the top of the form.
the mout­,3 v, cart forms were submitted to this ottice Nvittrin mt; i-jull
!ntal Sciences Branch that the red cl�
na period, Please be advised that late andlor non-retiOrtn'ta of to (icitv self- mo ni toring
) I authorit of the Division.
u to the enforcement ,
he reverse side of this Notice contains a summary of important toxicity monitring ais nd r
I
questions emote,ning thN
nts. Please read this one page summary and if you have any
,tact Mr. Kevin Bowden with the Aquatic Toxicology Unit at (9 19) 73' )-2136,
Sincerely,
I erton
Assistant Water Quality Section Chief
for Environmental Sciences
Rex Gleason- Mooresville Regional Office
John Lesley- Mooresville Regional Office
Aquatic Toxicology Unit Files
Central Files
C_;,a r.ont;ir Raleigh, NC 27699

> The pgmltte6 is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
> The reporting of whole effluent toxicity testing data is a dual All toxicity test results must be entered (with the
appropriate parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT' form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
> Toxicity test results shall be riled with the Environmental Sciences Branch no later than 30 days after the end of the
January test result isdueby. the. end of February).-,.---..-,,,-
> Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronit value is lower than the
permit limit, then at least two multiple concentration toxicity tests (one per month) will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999, Follow-up multiple concentration toxicity testing will influence the Division's enforcement response,
> Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September. and
December, then toxicity testing must be conducted during these months).
> Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing this monthly test requirement, the permittee will
revert to the quarterly months specified in the permit. Please note that your permit may or may not contain this language.
> , If Your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January I -June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not Occur
during the first six months of the calendar year.
> If you receive notification from your contract laboratory that a test was invalidated, You should immediately notify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why the test was
invalidated and the date when follow-up testing will occur,
Z7
If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the
information block located at the too of the AT form indicating the facility name, permit number, pipe number. county and
the month/year of the subject report. You should also write "No Flow" on the AT form, si-n the form and submit following
normal procedures,
> The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (?RC) except for facilities
which have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT
form. The AT form most also be signed by the performing tab Supervisor.
> To determine if your AT test forms were received on time by the Division of Water Quality,
your toxicity test results certified mail, return receipt requested to the Environmental Sciences Branch,

4 A Michael F, F.aslay
Governer
William G.Gloss, Jr- S cre.a y
1)epartment of Environment and Natural'Resources
I Alan W. Klimek,p, ,, Director
Division of Water Quality
January 13, 2003
CERTIFIED MAIL;
:R T CE ST 17
Mr. Randall Miller
Cousins Real Estate Corporation
00 Vest Trade Street, Suite 100
Charlotte, North Carolina 2820
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Perna No. i CO086517
Gateway Village Treatment Facility
' Mecklenburg County
Lear Mr. Miller.
This is to inform you that the Environmental Sciences Branch has received your toxicity
ptemV
self-mciittrin report for for the months ,f Ji1ly,' August nil- f the Mort arolr►a
report forms were receivver, the
ed late:. This in violation of Tale l5A
d `nistrative Code, Chapter ,Subchapter 2B, Section .0506 which the reporting
"hat
monthly monitoring reports shall be filed no later than 30 days after the end
period for which the report was made."
you will be considered noncompliant with the reporting requirements contained in your
LES Pe t for the months' of July, August and iSeptember 002 until
you
make ' e ed acceptable
this
demonstration to the Environmental Sciences Branch that the report
office within the required 30 day reporting period. Please e note ote formsathe our office sable is se and future incidents
inyolvin latelnon-re or in of toxicit self- onitt tin r
Cousins Real Estate to the enforcement author%the Li4 ision.
;tv mnnitorina and
The reverse slue or tnrs iww,
ig'requirements. Please read this one page°summary and if you have any questions
ling this Notice, please contact e, r. Matt Matthews or r. Kevin Bowden with the
Toxicology` Unfit at (19) i 33-2136.
Sincerely,
in Overton
Assistant `eater Quality Section Chief
for Environmental Sciences
Rex Gleason-Mooresvitle Regional office
John Lesley -Moores v i Ile Regional Office
Mr. Richard Donaldson, Cousins Leal Estate, 1,01 N. Tryon Street, Suite 17C1tJ, Charlotte N�
Aquatic Toxicology Unit Sites
Central Files
Pnvironrnentai Sciences Branch 1621 Mail Service Center, Raleigh, NG 27699-16 1 l

WHOLE EFFLUENT TOXICITY NIONITORING AND REPORTING INFOR�,MATION
;_,,_Wor another Unit representative at the same number.
> 1'he Re �rttee is responsible for ensuring that toxicity testing is conducted according to the permit requi
0
toxicity report forms are appropriately fit ed.
appropriate parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
> Toxicity test results shall be (tied wvith the Environmental Sciences Ilrnch no+later than 3t} days a€ter the end of the
> Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the
permit limit, then at least two multiple concentration toxicity tests (one per month) will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
> Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
C:1
December, then toxicity testing must be conducted during these months).
> Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing this monthly test requirement, the permittee will
revert to the quarterly months specified in.the permit. Please note that your permit may or may not contain this language.
> If your NPDES Permit specifies episodic monitoring0 and your facility does not have a discharge from January I -June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not Occur
during the first six months of the calendar year,
1�
> if you receive notification from your contract laboratory, that a test was invalidated, you should immediately notify the
Environmental Sciences Branch at [phone] and provide -written documentation indicatin.- why the test was
invalidated and the date wwheri follow-up testing will occur.
> If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the
information block located at the top of the AT form indicating the facility name, permit number, pipe number, county and
7
the month/year of the subject report. You should also write -No Flow" on the AT form, sian the form and submit following
normal procedures.
> The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge kORC) except for facilities
I
which have riot received a facility classification. In these cases, a duty authorized facility representative must sign the AT
form, The AT form must also be signed by the performing lab supervisor,
C�l 4:1
> To determine if your AT test forms were received on time by the Division of Water Quality, you a egnsid—er su-bmitting
ycacir toxicity test results certified mail, return receipt requested to the Environmental Sciences Branch.

Michael E. Easley
NNA Governor
William G. Ross, Jr,, Secretary
xG
7 [)apartment of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
August 24, 2001
-70qq 3-400 0011 6OS-0 -70is'
CERTIFIED MAID,
j:E:TURNREC�EIPT R�FUES�TED
Ms. jerri Tuck
Cousins Real Estate Corporation
101 North Tryon Street
Charlotte, N.C. 28246
Subject: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NCO086517
Gateway Village
Mecklenburg County
Dear Ms. Tuck:
This is to inform you that the Environmental Sciences Branch has not received your toxicity self -monitoring
s is in ofT,litle 15A,,of,the-,Nort�,(:�arollina,,Aldmilnistrative Code,
report form f9r,the month of Ltipe �00111.1 Tin
Chapter 2, Subchapter 2B, S - Sec .0506 (a)(1)(A) which states that -monthly -monitoring reports shall be filed no later
than 30 days after the end of the reporting period for which the report was made."
Information contained on your June DIMR indicates that no discharge occurred during the month of June,
t-- -4-;-A thar vnur PDES tie it, effective 4/1199, contains language that requires you to submit an Aquatic
1 —1- --- - ------ told him to fax in a "No Flow" AT form to our office. This conversation
jr office has not received any correspondence from the facility regarding no di
1>
ill be considered noncompliant with the reporting requirements contained in
ne until You make acceptable demonstration to the Environmental Sciences B
was submitted to this office within the 30 day reporting period. In addition
ireLeare not received within the re aired tirne frameyouM.-
be assessi
F ti— Nintir-,- mruains a summary of important toxicity U
111e. a — - --
:nrs. please read this one page summary and if you have any questions concerning tins OVUL
ie Robeson with the Aquatic Toxicotogy Unit at [phone],
incerely,
verton
Assistant Water Quality Section Chief
for Environmental Sciences
John Lesley -Mooresville Regional Office
Aquatic Toxicology Unit Files
Central Files
Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621

wd.
North'Carolin2
Central
1617 Mail Sery
Raleigh, NC 2`
IN ADDII
i) must be submitted to the fol
North Carouna Laiv
Environmental
1621 Mail ;
Raleigh, North C
rersorti i period (eg, January test result is due by the end of February:
All toxicity test results must be entert
t which is submitted tw
ter Quality
ter
i17
urine Lne M77t i
If you receive' notification from your contract laboratory that a test was it
Environmental' Sciences Branch at (919) 73: -2136 and provide written
invalidated and the date when fallow -up testing will occur.
If your facility is required to conduct toxicity testing during a month
complete the information block located at the trip of the AT form indica
number, county and the mon€lilyear of the subject report. You should al
form .and submit fallowing normal procedures.
> The Aquatic Toxicity Test forms shrill be signed by the facility's Ope
which have not received a facility classification. In these cases, a di
form. The AT form must also be signed by the performing lab superN
To determine if your AT test forms were received on time by the Div
your toxicitest results certified mail, return receipt requested to the
.ss:`
uality
i
41) t
tl UG 4.VIIUU44G41 V YCrt ult 1V11V_111S ixv_
ermit does not require use of multiple:
iay choose to conduct either single
vision's WET enforcement initiatives
e the Division's enforcement response.
sits which contain :episodic toxicity
mit are March, ,tune, September, and
•equired, then monthly monitoring will
.lily test requirement„ the perttee will
ry or may not contain this language,
e a discharge from January I -June 30,
June 30 that discharge did not occur
a
isible Charge (ORC) except for facilities
facility representative trust sign the AT
iirrinmental Sciences Branch.

to of North Carolina
apartment of Environment
and Natural Resources
Division of Water Quality
NOWN00990M
James B. Hunt, Jr., Governor
Bill Holman, Secretary NCDENR
Kerr T. Stevens, Director NORTH CAROLINA DEPARTMENT OF
ENviRONME:NT ANo NATURAL RE:SOUR CES
October 7, 1999
CERTMD ? 067 737
RETURN RECEIPT REQUESTED
Mr. John Goff
Cousins Real Estate Niations Bank
101 N. Tryon Stree!!Suite 1700
Charlotte, North Carolina 28246
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC0086517
Cousins Real Estate Treatment Facility
Mecklenburg, County ------
Dear Mr. Goff:
I ILIV 1-1 V1 LAIa — — ___ , - - --­ --- ­ - - -
states, "monthly monitoring reports shall be filed no later than 30 days after the end of the reporting pet
which the report is made."
You will be considered noncompliant with the reporting requirements contained in your NPICES
for the month of July until you make acceptable demonstration to the Environmental Sciences Branch,
July 1999 AT report form was submitted to this office within the 30 day reporting period. In addition, ij
the next twelve (12) months, future reports are not received within the required time frame, you may be a
a civil penalty.
The reverse side of this Notice c6mains a summary of important toxicity, monitoring and rep(
requirements. Please read this one page summary page and if you have any questions concerning this 1�
or any aspect of your toxicity testing requirement, please contact Mr. Kevin Bowden with the At
Toxicology Unit at [phone].
Sincerely,
7
---RmizLe O*rton
Assistant Water Quality Section Chief
for Environmental Sciences
cc: Rex Gleason -Mooresville Regional Office
John Lesley -Mooresville Regional Office
Aquatic Toxicology Unit Fifes
Central Files
Mailing Address: Telephone [phone] Locatiorr
1621 Mail Service Center Fax [phone] Reedy Cref
Raleigh, NC 27699-1621 State Courier #52-01-00 Raleigh, NO 27E
An Equal Opportunity Affirmative Action Employer 50% recycledtloo/. post consumer;

North Carolina Division of
Central Files
1617 Mail Service (
Raleigh, NC 27699
Toxicity test data (original "AT"' form) must be submitted to the f,
North Carolina Division of
Raleigh, North Carolina
>-- Toxici 9, test results shall be riled with the Environmental Sci
reorti _ig,2g_i0_d (eg, January test result is due by the end of Feb
> Toxicity test condition language contained in your NPDES perm
upon failure of any single quarterly toxicity test. If the initial
permit limit, then at least two multiple concentration toxicity test
months. As many, analyses as can be completed will be accepte
concentration toxicity testing upon failure of any single qu
concentration toxicity testing or multiple concentration toxicit
effective July 1, 1999. Follow-up multiple concentration tc
response.
> Toxicity testing months are specified by the NPE
monitoring requirements (eg, if the testing wont
December, then toxicity testing must be conducted
> If your NPDES Permit specifies episodic'moniEor
then you must provide written notifications to the I
during the first six months of the calendar year.
> If you receive notification from your contract lal
Environmental Sciences Branch at (919) 733-2
invalidated and the date when follow-up testing wi
> If your facility is required to conduct toxicity tesdi
information block located at the top of the AT fol
the monthlyear of the subject report. You should
normal procedures.
> The Aquatic Toxicity Test forms shall be signed b,
which have not received a facility classificatiom
form. The AT form must also be signed by the pel
> To determine if your AT test forms were receive(
your toxicity test results certifiedmail return rece
All toxicity test MjglLs must be enterei
t which is submitted to:
uality
address:
htality
h
621
you may choose to conauct enner single
the Division's WET enforcement initiatives
will influence the Division's enforcement
DES Permits which contain episodic toxicity
ES permit are March, June, September. and
aot have a discharge from January I -June 30.
inch by June 30 that a discharge did not occur
validated, you should immediately notify the
documentation indicating why the test was
the facility's Operator in Responsible Charge (ORC) except for facilities
sr these cases, a duly authorized facility representative must sign the AT
forming lab supervisor.
on time by the Division of Water Quality, you may consider s ibmittin
pt requested to the Environmental Sciences Branch.

Complete items 1Zand U. Also completes
f , „ "..'.
w4V: j Item 4 If Restricted fr}eI1VF:C"rf is GleSlt"E'd.
iijr Print yo6r name and address on the reverse C, ig atur, f
so that we can return the card to you. 0 Agent
Attach this card to the back of the mailpiece,( r0 Addressee
or on the front if space permits;
D. is delry address di e ant from item t
1. Article Addressed to: if YES, enter delivery address below:
MS .JERRI TUCK
COUSINS R ESTATE CCR�'t��cAi'1tN
101. NORTH 'T`RYON STREET
CHARLOTIE NC 28246. Servi ype
Certified Mail © Express Mail
red C3 Return
CI Registered Receipt for Merchandise:
Ci Insured Mail 0 C.OS D.
j 4. Restricted Delivery? (Extra Fee) 0 Yes
2, cle Number (Copy from service label)
9 Oct
P Form 3811, July 1999 Domestic Return Receipt 1e2595--M-0952
r
SENDER:
I also wish to receive the
dtar 2 for a oral servi following services (far an
y ■ Complete items t an
a Complete Items 3, 4a, and 4b.
N 0 a Print your a and address on ravarsa'of tams so that care return this extra fee:
■ oaee d t t�foms to the t of the mailpiece, or on the flack if space does not 1. El Addressee's Address
Atta. Wri t"Rafurn Receipt on the milplaoa below the article numbe
a r. 2. Restricted Delivery U
Is The Return Receipt Will show to whom the article was delivered and the data Consult postmaster for fee'.
dk1fivered,
S
Articl9_Addresse ta._ .. _ 4a. ArticIe Nu er.._.. _
C� .2 = 4, ServiceType
'91 pall, c" 0 Registered ertl�led
' 11 Express Mail insured
t t t _F1 Receipt for a d` [I COD
7. Cate of Delivery
.t .
Cap G r „
! 5. Received By: (Print Name) 8. Addressee's Address (Only if requested
and fee is paid)
i
:f fSnat: (4d or )
�
102
mu595.9& Domestic Return Receipt
2 P Forec ber 1994
SENDER: I also wish to receive the
a w Complete items t sl�dl,, 2 for additional sarvices. fallowing services (far an
■ Complete Items 3, 4a, and 4b.
a Print your name and address on the reverse of this formso that we can carom this extra fee):
card to ou. 1.1 Addressee's Address
a A t its form to front of the mailpiece, or on the back if space does not
re parm+i. . C3 Restricted Delivery
•Write `Return Receipt Requested" on the mallpiace below the artids number.
■ The Return Receipt will show to whom the article was delivered and the data Consult postmaster for fee.
delivered.
3. Article Addressed to: 4a. Article Number
CM ,
4b. service Type
0 Registered Certified
, �fj' oo 0 Express Mall 0 Insured
/r umRaceipittorfiferchandise 0 COD
7. Date of Delivery
ll
t' 5, ec ived By: (Print Name) S. Addressee's Address (Only if requested
d fee is paid)
l
. inatu a: ( ee or Agent)
l• ,
PS Farm 3811, December ember 1994 1=95.98-B-o Do tic Return R ccsp
1

complete items 1 and/or 2 for
Comp4ete items 3, 4a, and 4b,
x
w mint your nameand addressc
red'to yytau.
s Attach ihie town %athe front of
p�r€ntt'Return Receipt Reqws
a i As Return Receipt will show }
deOvereds
E
. ArticleAddressed to.
S. Received By: (Print his
A
PS Form 3811, Decemb
f c
.f.
e
a li wu ��I��V'MI I®d 6�BNyW kl}IIIIII�fI Iiti �I� i i� �rl�b ��rWll�
i�i
u,,IIR ��I�
SEN ER: C®MP THIS SECTION COMPLETE c
• • - •: a ^°
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■
s
w
SENDS : COMPLETETHIS SECTION COMP IS SECT11
1 w U
if
F
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fA
yy

P-1 -20 3 FRI 07:06 AM FAX NO. Pi 01
A
,pep rtlhcr 10, 2003 MACTEU
Mr: Alain W. l inick, Director
floirtt Sotjj-L;o ('Csrtapli itico/J,nfk)t'cctTicrtt;Unit:
Divis
1617
j\alc.i,
vi is r
Subjo
Door
This 1
Chill
if Willer Quality
� Scxvicc Ccntc r
4orlll C at-olina 27699-1 17
`
fied Mail
vtl Penalties for
UJ Q-
�poritng R
jr
NPOE'S Permit N(?. NC ()fl#tfr417
Charlotte Gate ircility
C"lt;triolle, Mccklettliut` ; C"ottrt a'Clarrtrlintt
1
Klimek:
iiy V i11.r'c, LLC: {atrr cticart} iir r
m sty Nsed a{ inst Charlotte G a
r0 ,ltc.cl wlillr NPDRS Permit No
'd by Charlotte Gawwfry villiat,r
:4trilCtrt (If' $10 000 is for not sub
Nov,, richer 2002 and April thrc
,vkl rn of Witer Qllaal ly. The (
Warlct Quality for Railing tci stibmIt the rc uit
provides a brief, explanation CA, the events v
for violations
rur letter, tialeci
onitorink, report forms for
Frivirarimental Sciences
48i2 84l V�• >+4+i+Fi s•.r+v ..r wa ,... a. w. a. tv .. a..
n (NOWS) that Wart sent by the
korting documentation.
tesulted in the issuance of several
livt�:jidy, MACTEC"'s ci-tvirt ninctrtal scrvice,s dire ttttaircd to monitoring atnd wporlin
'srls ira ;lrct,Cd,)nce with the N11DES permit for (ho flciltty. This pr(kiect has hecia
l)y Mr. Bruce Reilly, a Principarl Fiipjoec:r within our firer
No grouri lwil(er Was disc;lrrar'go.d hito the trr mnicnt systetri from rant; 2001 tnttil
ny 2t702,
Tit mid -May 2002, wirer dischar feel tlarouf,lr the system. From May to October
2002, toxicity testing flited duo IU -i c r'rrs c-totrtrttcttan between it sanitary Sewer
pipe .aril clean groundwatr:r collcdforr pit>lo- For rhi.a period in 2002, raw
ticwa-c was through the groundwater Irt.artrrit.nt ayslcim once the
egoss-connecting piles wcre repilod, lire rrcitment system no longer receivcd
W lTel'.
Sirrect mid-Novc.tniboi 2002, ttwxc bas been no flow thrOLIgh till; trc;2trrtctrt system
except for arlrproximately 67,300 gailltrtrs that pvlsscd through the system in early
Jiltae 2003 ouc'to it polop faililiv trait associated with the treatment system. The
riaainten,i ce 5udl' at ('t�rtcw ty 'dill tl c ic'p aired the pump; thus, wafter c:el sod
flowing throtigh tho system again.
W11c;)r 111t, Civil peraatl(y letter w;v, received by Charlotte Gateway Villaec, LLC on
1lr nist 22, 2003, Mr. Kirk Smith, Wriaccr of AC:` EC"s Cliarlotte office
MACTCC Cncginccnng atnri G onsutlio
2801 Yorkit rrt flood, 100 • Chals lle, NC 28;,)04
70:1 :ti'>/•t:600•Fzjv /04 S51.8638

SEP-12— 0 3 FRI 07:06 AM FAX NO, P. 02
Cher olle Gatr wly villfa,ec, IJ.0
Page 7
rccoivc.d it telcphonc call from our clicni asking for an explanation, It should tic
noted Ill at this wits the first notific aican of tlae lack of reporting or any civil
pewiltics assessed by the Stahl; ccn this projcet to anyone: within the MACTEC
organization other than Mr. Bruce Reilly.; MAC:TITC itninediaTely set tali a
tinootirag; with otar client to "discuss the situation aancl Cvtalttille Out options:
MAC`i'E'C.: also, conttacwd Mr, Kcvin Bowden of tine l:nvironmentail Service
lirarncli for clarification of tide letter, Mr. Bowden indictited that toxicity self-
ttioniLoring reports had been ic'ceived by the Branch througli January 2003 but
that there had been no toxicity self-mouiolrine, repo Ling forms received for April
2003 or July 2003, Mr. ftowden :Mated that lie had contacted Mr, Reilly can
several occasions about delincluent reports. Mr. Bowden also indicated dint
DMIk's had not been submitted to the State for the same tulle period ` After
revicawing our project files, it was determined that monitoring activitie .ti of the
Treaattiie nt system had been conduciod oil <°a routine basic as stipul.ited in the
permit. No saamplinF, was, I ctfoaaracd because there was no flow through tile:
system if) 2003 (c lhor thin ita cirly )ittle}.
lta<e'd Oil cliSc:Giiirrtts with sitar client, Charlotte Gateway Village, LLC, our Mr. Bruce, Reilly and
Mr. Kc,vin Bowden of (lie FilvironnicniA Services Branch, MAcr C:, with our client"s approval,
has 6l ,,vcloped a Flail to mitigate the non-comphatace issues, Mr. Broce. Reilly ba.s bcen removed
ass uaatulagt r for `the C aitt.way Villttf,c p-oject, Currently, Mr. Chris Corbitt, f'.t.�r., the
etav'irratttaacattill business unit Itiader for tlae Cliaarlotte office, will atssunse tile, role, of project
ni.rrtag}car. Mr. C`'.urbitt will be <assistod by Mr, Mat( Gustis, VE' , it Senior Engineer with
MAC:Tl;C , who Bits exp:rience`with trt.attmcttl systems, Sampling (Ifnecessary) and monitoring
taf 11w lrvalsatc'at systetrt will lit conducted in accordance with tho NVIX-IS permit by Mr. Joc
Vickocs of cittr firtia.
Siiicc. MAC"TEC bccatnc aware of the Notict: of Violation aitad Assewnent, of Civil Penalties oil
An ,uNt 22, 2003, we submitted to the Division of Water Quality cats August- 28. 2003, all
delinquent DMR's since. lacbrutry 2003 raised toxicity self -monitoring report forms for Aril ,and
July 2003 Although the cavil; penalties have lack.n levied agaiinst Charlotte Galew:ay Village,
LLc' it is iMAC"1 EC:'s respunsibillty to sobtitit the rccloired documentation (DMR's and toxicity
st ll`-mollittatitV, aCl'tarts) to the Division of Witter (duality <uici therefore MACTEC is responsiblc
for civil pcwilties levied �qg alrisl our client rcl,atcd to these reporting; issue~s. The. issue of non-
responsivenoss is .also tilt, responsibility cif MAC:"rrv, tiot out -client.
llaast'd c#tt tlac^ cc'r iollsnoAi of file acccpted violations and peri altius tassessco, which will bo. wholly
dw respousibility of MACTFICr to romedy, we have taken the followings actions:
r, 131'11c $ Redly has lic'cn removed from responsible charge of all current projects
iaavtalvitagtile. sulttiiis+,at ri oftoxicity self-raauniloringreport forttts.
« MACTI:C, Will review out- intttnaal duality control procedures to determine the evident
fta lure of our rc..sponsibiIitics,
Chc ar, concise lines of communication have licert cmaablishod with our client to respond
licttt.r to their nce(K Multiple Contacts, including tile; office. maniger, will bo providt.d.

SFP-12-2003 FRI07:07 AM FAX N0 P, 03
Choi Gam way `Vrtlul„„t, LLC
.4tvlelllbo It>, 3t7U:
Page 3
A review of oilior simikir larc.iccts mider the rtircctiotr of Mr. Reilly will be performed it)
itsstrre that tlrc prolreis are ill colliptiatrce with api>lictthle State and federal guidelines
,mid permit rEquit'C:ments.
MACTF,C allcrlogiz , for our disrcl~:tt' l Of Our resllc milrilitics oil this larnicct. We do not believe
that this is the %cc'l ied "ctrlitire" of out, firm, but rather a one-time, evident failure of one Of our
PfillCilra111. try Purfcrrral Iris Contractual obligations to our client and our professional resl)onsihiliti s
to tile St3tO rat' Ntjih C zirolina.i Fortc nlicly, no toxicity limits were exceeded resulting in adverse
itrtlaaaets to (lie envirrartnrent since there has boat no grr.rttndwater flow lbrough the sysiona. To
out, renew icrlllc, this is the first incident where MACTEC, forimerly krlowtt as Law
l"Mpillcerinf; 1110 Ell virtrrrrtiental +ervires" 111c; has faikd to peti'rtrm our contractual
rllrliga(ions which have resulted in a civil penalty asst,ssnYem fly the Division of Witter
t; uAlity for ,lent-rellorting of rr?sults. MAC"l'cr has Perfcrrrlaed tlresv types of professional
environmental services for over ?p years,
Therefore, we reslicctfrtlly request that you recrrtcl the civil penally that has lacers levied ar airrst
out. cltrrrl: We request a mocting at yottr convenience to tijr'ther discuss the issues and corrovive
arctimis alcsociatod with this project.
MAC:I'lsC nrrcler'starncls thc soriotisness of tlri:so civil pelmitres a'ntJ is coralrtritted to working
elrl lrt�rrtlyto 111t4e sure that lion-com lianco, of the permit docs not occur in the future. if you
lratvo any tloostions co►lecriring this louc.r, please don't hesitate to contact the undersigned at (704)
357-li600
Sincerely,
AC.:TECw I:NCilNU-1E '.ING AND CONSULTING, INC,
�, %lPf *--?111
Cll istopher L Corbin, l'.Ci. Robert K Sillith, Jr., l"L
Principal � Chief Engineer
C Ry Witt) Permission
lh
,l:lrwlc's Ma'lti �irrtit�r, 1'.l?.
Vice Pretsislcrrt
CCMr. ltO(Vt't Spricc> orid M r, Jcff McC"larnathall; Cltart'lcrtW Gate way Village, LLC.
Mr. Kovin Bowden, Aquatic Toxicology Unit
8 - '.® With P rmisslorl

4-
XN A Michai
William
North Carolina Department of Environment
Alan W. I
Na�
p Div
Coleen H. SL
Div
July 25, 2003
CERTIFFIED MAUL
RETURN RECEIff REQUESTED 70012510 0004 8286 6846
Mr. Jeff McClanahan, Assistant Chief Engineer
Cousins Real Estate Corp.
800 W. Trade Street, Suite 100
Charlotte, NC 28202
SUBJECT: NOTICE OF VIOLATION
Compliance Evaluation Inspection
Charlotte Gateway Village, LLC
NPDES Permit No. NCO086517
Mecklenburg County, NC
Dear Mr. McClanahan:
On June 30, 2003, Mr. James Wilson of the Mecklenburg County Water Quality Progr
(MCWQP) conducted an inspection at the subject facility. This inspection was conducted as p
cooperative working agreement between Mecklenburg County and the Division of Water Quay,
enclosed report should be self-explanatory.
-- .1 -- ---' - —1 a...,..,--y— I — —.�Y vuas.wa MAMLL%lia, FulwazV, UV 11vt 11Vw14t'TZ Lk
call Mr. Richard Bridge an or me at this Office.
Sincerely,
�S
D. Rex Gleason, P. E.
Water Quality Regional Supervisor
Enclosure
cc: Rusty Rozzelle, MCWQP
DRG/jpw
File: WQ GatewayCousins,0036317.0703.nov,doe
Mooresville Regional Office, 919 North Main Street Mooresville. North Carolina 28115
Phone [phone]"
Fax [phone]

4P J'Eosr" to
Protection A�en11
iWA
Section A: National Data, System Coding
Transaction Code NPDES Pen -nit No. YRfMO/DAY Inspection Type Inspector Facility Type
N 5 NCO086517 03/06/30 < C C 2
Remarks:
Insnector: Mecklenburg County Water gLa �yPr gram
Inspection Work Days Facility Self -Monitoring Evaluation Rating BI QA
0.7 2 N," N
.... Reserved. ......
Section B: Facility Data
Name and Location of Facility Inspected:
Gateway Village GWRS
Entry Time:
8:00 am
Exit Time:
Permit Effective Date:
July 1, 2001
800 Block W. Trade Street
Charlotte, NC 28202
9:30 am
Date:
Permit Expiration Date:
May 31, 2005
June 30,2002
Name(s) of On -Site Representatives -Title(s)-Phone No(s):
Mr. Bruce Riley (Maptech, Inc.) Operator in Responsible Charge [phone]
Mr. Jeff McClanahan Assistant Chief Engineer [phone]
Name and Address of Responsible Official:
Mr. Jeff McClanahan
Cousins Real Estate Corp.
800 W. Trade Street, Suite 100
Charlotte, NC 28202
Title:
Assistant Chief Engineer
Phone No.
[phone]
Contacted?
Yes
1
Section C:
Areas Evaluated During Inspection
Permit Flow Measurement Operations &Maintenance
Sewer Overflow
Records/Reports Self -Monitoring Program Sludge Handling/Disposal
❑ Pollution Prevention
Facility Site Review Compliance Schedules ❑ Pretreatment Program
❑ Multimedia
Effluent/Receiving Waters Laboratory El Stormwater
El Other:
Section D: Summary of Findings/Comments
All areas are rated satisfactory unless otherwise indicated. See Attached Sheet(s) for Summary
Signature(s) spector(s):
Jayne ��Wilsl, 11
Agency/Office/Telephone:
MCWQP/[phone]
Date:
July 11, 2003
j
Signature of Reviewer:
Agency/Office
Date:
EPA Form 3560-3 (Revised 3-85) Previous Editions are Obsolete

GENERAL:
The facility was last insnected by MCW(D
Eva
PEI
stre
rem
pha
pun
Res
,ion Inspection report was issued to Cousir
IT:
The current permit properly describes the
being treated.
'ORDS/REPORTS:
a
10 111(11 A
records, and maintenance logs were readily available and in proper order.
FACILITY SITE REVIEW:
The facility is permitted to discharge to the municipal storm, water collection system
which discharges to Irwin Creek, a Class C water in the Catawba River Basin.
All of the major components of the facility were in service but not operating at the time
of inspection. When Gateway Village was developed, slurry walls were installed around the
perimeter of the complex. These slurry walls have effectively prohibited groundwater from
rising to the level required for system operations. The system had not discharged except during a
7-month period in 2002. An improperly maintained grease trap at a Chic-Fil-A restaurant caused
the discharge in 2002. The vent line for the grease trap was erroneously tied to the vent line
serving the ground water rernediation system. When the grease trap began overflowing, it
backed into the vent line, which discharged directly to the recovery well. This discharge caused
numerous consecutive chronic toxicity failures until the problem was identified and repaired,
FLOW MEASURMENT:
Flow measurement is accomplished using a continuous recording flow meter, which was
installed new in May 2001. This method is acceptable per permit requirements. By regulation,
flow meters must be calibrated at least once annually. There was no calibration record available
at the time of inspection.
Rating: Mar gfinal
_

LABORATORY:
Prism Laboratories, Inc. and ETT Environmental perform analysis of effluent samples.
Prism Laboratories and ETT Environmental, Inc. are certified by the State of North Carolina to
perform analysis on all parameters specified in the permit. Prism Laboratories and ETT
Environmental were not evaluated during this inspection.
EFFLUENT/RECEIVING WATERS:
The facility is permitted to discharge to the municipal storm sewer systeni, which
conveys the effluent to Irwin Creek. The facility was not discharging at the time of inspection.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (DMRs) were reviewed for the period January 2002
through March 2003. The reports indicate that the facility was in compliance with permit
effluent limits and monitoring requirements during this period, except for the following:
I . Effluent Tetrachloroethene (TCE) was only measured once per month in the months of
May, July, September, October and November of 2002. This constitutes five (5) failures
to monitor for effluent TCE in violation of twice monthly monitoring requirements. This
oversight occurred because the CRC was not aware of the twice -monthly monitoring
requirement.
2. Effluent flow is not recorded as an instantaneous measurement. Part 11, Section A(7)(b)
indicates that an "instantaneous flow measurement is a measure of flow taken at the time
of sampling". This means that the grab samples and flow must be measured concurrently.
Facility effluent has not passed a chronic toxicity test during the review period. The facility
©RC has conducted tests every month, but the system has not discharged since November 2002
(see Facility Site Review heading, paragraph 2, sentence 2 for explanation).
Rating: Unsatisfactory '
OPERATIONS <AND MAINTENANCE:
The facility and site appear to be adequately maintained. The current overall operating
strategy of the site operator appears acceptable for the size and type of the facility.

N
March
andy Miller
ns Real Estate Corp.
�. Trade Street, Suite 100
)tte, NC 28202
SUBJECT:
Compl
ate,
800 B1,
NPDE!
Meckl(
,W. Millen,
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
Village
- W. Trade Street
ermit No. NCO086517
urg County, NC
tate to call Mr. Richard Bridgeman or me at this Office.
Sincerely,
D. Rex Gleason, P. E.
Water Quality Regional Supervisor
losure
Rusty Rozzelle, MCEP
T
IQ Cousins.0086517.0202,doc
Fax (704)663

es Environmental Protection Agency, Washington, DC 20460
NPDES Comnliance Insnection Renort
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Property
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EPA Form 35604 (Revised 3-85) Previous Editions are Ohs ol to

r
ps.
[he facility was last inspected by MCDEP on June 14, 2001. A Notice of
Luiwiiy La ui%, vpwuavvi iii kkjx\.%-) ivi uIv. 14%anky.
'he current permit became effective on June 1, 2001 and expires on May 31, 2005.
DS/REPORTS:
)ischarge monitoring reports (DMR's) were reviewed for the period January 2001
December 2001. The reports appeared to be properly completed.
TY SITE REVIEW:
he facility is permitted to discharge to the municipal storm water sewer which flows to
eek, a Class C water in the Catawba River Basin.
system A* installed. 7 WO
W MEASURMENT:
Flow measurement is accomplished in a continuous recording flow meter, which was
led new in May 2001. -
am"
Prism Laboratories, Inc. and ETT Environmental perform analysis of effluent samples.
i Laboratories and ETr Environmental, Inc. are certified by the State of North Carolina to
rm analysis on all parameters specified in the permit. Prism Laboratories and ETT
=onmental were not evaluated during this inspection.

EFFLU
I
to Irwin
I
throu
efflu(
Per
(RECEIVING WATERS. -
[TOTING PROGRAM:
voiauons.
tit effluent monitoring frequency requirements were 1
Rating: Unsatisfactory
OPERATIONS AND MAINTENANCE:
The facility and site appear to be adequately maintaine
strategy of the site operator appears acceptable for the size
d. The current overall operating
d type of the facility.

Permit Number: NCO086517
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
A
limitations, monitoring requirements, and other conditions set forth in Parts 1, 11, 111 and IV hereof
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on May 31, 2005.
Signed this day
............ .
Derr .,T.-'Stve4Director
Division of Water Qual
By Authority of the Environmental Management Commission
SUPPLEMENT TO PERMIT COVER SHEET

r
Cousins Real Estate
aereby authorized to:
Permit Number. NCO086 1'7
potation
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Permit Number: N O0
G REQUIREMENTS
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•
December 13, 2000
s. Jerry Tuck
Iusins teal Estee Corporation
11`orth Tyron Street
tarlotte, :forth Carolina 284
Subject: NI'DES Draft Permit
Permit No. NCO086 r1
GatewayVillage
Mecklenburg County
#ar Ms. Tuck.
sign of Water Quality has reviewed information specific to the facility and prepared a
it for your review. Enclosed is the draft permit` for the Cousins peal Estate
do - Gateway Village.
view the draft permit carefully. Check to insure that the facility information is correct,
address and location.
.ovide comments you have regarding this draft permit to I ENR - DWQ NPDES Unit
han January 20, 2001a
swing items highlight changes that have been incorporated into the draft permit.
can the Division's analysis there is not a reasonable potential that the Gateway Village
urge will contain the following pollutants, therefore the monitoring and/or li t for
pollutants has been removed from the permit.
-- Benzene
-- Toluene';
-- Ethylbe ene
_-- Xylene
-- MTBE
Lead
phance with the 30.0 g/L Total Suspended residue (TS%) limit will based on a
hly average" e daily maximum T alb " 't shall be 45 nag/L.
s17 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 7699-1617 - TELEPHONE 919-7 5 %FAX 19-7 719
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 10 POST -CONSUMER PAPER
VISIT US ON THE INTERNET Q hftp://h2o.enr,state.nc.us/NPDES

i
Permit Number: NCO086 a 1'
ie limit will based on a weekly average.
vith a life time exposure, the weekly average'
i

■
Department of Environment and Natural Resources
Division of Water Quality
Fact Sheet For NPDES Permit NCO086517 if
Facility Information
Applicant/ Facility Name4: Cousins Real Estate - Gateway Village
Applicant Address4: 101 North Tyron Street, Suite 1700, Charlotte
Facility Address4: 800 West Trade Street, Charlotte
Permitted FlOW2,4,7: 0.05 MGD
Type of Waste2,4,7: Ike watering/ groundwater remediation
Facility/Permit StatUS4: Renewal
County244.7-
Mecklenburg
Miscellaneous
Receiving StreaM2,4: Stormdrain to Irwin Creek
Stream Classificationl,2: C
303(d) Listed?-5: Yes (Irwin Creek)
Subbasin2: 03-08-34
Drainage Area (nii2): [calculated] < 0.1 Mi2
Summer 7Ql0(CfS)6: 0.0 {star mdrain)/ 0.49 cfs (Irwin Creek)
Winter 7QlO(CfS)6: N/A
Average Flow(CfS)6: N/A
IWC (%): 100%
Primary SIC Code: N/A
Regional Office: Mooresville
USGS Topo Quad: G 15 NE - Charlotte: East
Permit Writer: Nfichael Myers
Date: November 30, 2000
Summary
Law Engineering acting on behalf of the permittee has submitted an application for renewal of
NPDES permit NC0086517. Cousins Real Estate - Gateway Village requires a NPDES discharge
permit to dispose of permanent dewatering/remediated groundwater to waters of the state.
Cousins Real EstaWs NPDES permit has expired and they have requested renewal of their
les, and deter n-dnes the conditions that must be achieved prior to discharging
s fact sheet summarizes the rationale used to determine permit limits and
�rrrtit is required to dispose of groundwater that has been contaminated with
)yproducts and chlorinated solvents at a site in downtown Charlotte.
ischarge are Imuted to disposal to POTW because the surrounding area is
J, Charlotte -Mecklenburg Utilities has indicated that they are unwilling to
Fad Sheot
NPDE'�') Rcne�val
Pagc I

accept;
availa
A 0.074
Fer tank
fore discharge is still the only option
o handle a permitted flow of 0.05 NIGD.'
f the following treatment units:
ted in series)'
to Irwin Creek in the Catawba River Basin.
k has a drought condition flow 0.0 cfs. Irwin
d) list as impaired for fecal colif r ., with
> l wastewater treatment system, and
groundwater. Rernediated groundwater is
1 ) contribute to the cause of impairment to
tin Creek.
,tream Monitoring
torin.g
to the repeated toxicity failures in 1999 the facility was assessed in the amount of $3,097.77
February 25, 2000.
dcity Testing
,rent Requirement: Quarterly Chronic Toxicity Q 0% Jan, Apr, Jul, Oct.
ornmended Requirement: Quarterly Chronic Toxicity @ 90% Jan, Apr, Jul, Oct.
posed Changes
�d on the reasonable potential analysis it is recommended that the following requirements
e ovd from the permit:
ene limit and monitoring
zene limit and monitoring
rlbenzene monitoring
=nemonitoring`
3E monitoring
monitoring
i monitoring
FactShvct
Pa +e

VV The 30mg/ L limit for TSS will be implemented as monthly average instead of a daily
maximum. The daily maximum TSS limit will be set at 45 mg/ L.
The limit for Tetrachloroethene shall remain at 8.85 ug/L. However, the limit will be
implemented as a weekly average. The linut is based on the EPA Criteria for this pollutant of
concern and the carcinogenicity risk based on a life time exposure. Since the limit is based on a
life time exposure the weekly average limit is appropriate. Limits for carciogens are
determined using a mass balance approach with the mean annual average flow. However,
since this discharge is to a stormdrain the mean annual average flow cannot be determined
with the available information. The Division's policy is to treat storindrains as zero flow
streams with a average flow of zero. Using an assumed average flow of zero the limit is set at
the criteria of 8.85 ug/ L.
The sample type for TSS and Toxicity shall be modified to composite. The permitted flow rate
is 50,000 gpd. DWQ policy states that for permitted flows greater than 30,000 gpd samples shall
be composite. Though the facilities actual flows have never exceeded 0.023 MsGD unless the
facility request a pern-dt flow reduction to <= 30,000 gpd, composite samples shall be required,
Proposed Schedule for Permit Issuance
Draft Permit to Public Notice: December 13, 2000.
Permit Scheduled to Issue:
References
L Division of Water Quality's Basinwide Information Management System, September 22,
2000, ies is] ilia iNeuse, idf
2. 2000. NPDES Rpli.,ional Staff ReDort and Reconunendations for the Renewal of Cousins
R 517 March 14, 2000, Mooresville
Regional Office
3. 19998. Catawba River Bilsinwide North Carolina Division of Water
Quality, Water Quality Section.
4. 1999. NPDES Pernut Annlication Short For C - GW Cousins Real Estate - Gateway
Village.
5. 2000. North Carolina Division of
Water Quality, Water Quality Section. Copies obtained through Planning Branch,
Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina.
6. 1993. Low Flow Characteristics of Streams in North Carolina United States Geological
Survey Water -Supply Paper 2403. Copies obtained at U.S. Geological Survey, Map
Distribution, Box 25286, MS306, Federal Center, Denver, CO 80225.
7. 1996. NCO086517 NPDES Permit. Issued to Cousins Real Estate Corporation, expiration
May 31, 2000. Copies obtained through The Division of Water Quality, Central Files,
Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina.
State Contact
If you have any questions on any of the above information or on the attached permit, please
contact Michael Myers at [phone] ext. 508.
NAME: DATE:
Fact shoo
NPDF'`; Renewal
Pat"(' I

Regional Office Comment
�y
,EGION6,L REVIEWER
IAME: DATE:
EGIONAL SUPERvISOR
AME: DATE:
Fact Sheet
Renow'd