NC0058084_Regional Office Historical File Pre 2018

tear.
If you have any questions concerning this matter or to apply for an St CC, please contact Wes Bell
Mooresville Regional Office at i704-663-1699.
Sincerely,
Docu$igned by:
A14
W. Carey
Water Qt
Mooresvii
Division (
)r
.ton

Bell, Wes
From: Steven Lambert <msiambert@yadtelnet>
Sent: Wednesday, April 17,2019 9:39 AM
To: Bell, Wes
Cc: 'David Risley'; 'Ronnie Ling'
Subject: [External] Notice of Deficiency NCO058081 -Gough Econ, Inc.
This is our offering, for now, addressing the factors included in the Notice of Deficiency:
All paperwork issues will immediately be corrected. Revised DMR's for the affected dates will be sent shortly.
Operations and equipment:
The dosing bell has proven erratic and has to be "messed with" to be sure it will discharge. A contractor has been called,
and a new bell ordered. Perhaps the old one can be repaired and maintained as a spare.
More sand is expected to be delivered today.
The sand be will now be raked, after cleaning, with a deep tined rake that can reach up to six inches into the sand,
Aerobic conditions are apparently being maintained in the bed as the Dissolved Oxygen of the filter discharge is >6.0
mg./L. This can change, however.
The staff has been notified that the discharge setting of the dosing tank/bell siphon should not exceed the holding
capacity of the recirculation tank to prevent bypass. We will took to our contractor to make this setting on initial
installation.
The chlorinator will be fully addressed after the previous actions have been taken, Although off level, the unit is still
rendering a chlorine residual. Gough staff have the necessary facilities and skills to provide for a more reliable platform
to mount and level the chlorinator.
If further communication is required, feel free to contact us.
Steven Lambert, ORC
oa
H
H

FILE
I=COOPM I�MTH' CAROLINA
1ftMniKDbWWr
Certified Mail #7016 1370 0000 25911841
RStUrn e
gqqggSd
January 8, 219
David P Risley
Gough Econ, Inc:
P© Box 668583
Charlotte, NC 28266
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2019- -0012
Permit No. NC 058084
Gough Econ WWTP
Mecklenburg County
Dear Mr. Risley:
review of the November 2018 Discharge Monitoring Report (DMR) for the subject facility revealed the
violation(s) indicated below:
imi Exc"dance ViAations)c
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Nitrogen, Ammonia Total (s 11/30/2018 4 5.32 Monthly Average Exceeded
N) - Concentration (CC 610
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of NorthCarolinaGeneral
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty -Five thousand dollars (2 ,ggg.0 may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issuers pursuant to G.S.
1-215.1.
North Carolina Department of Environmental Quality i Division of Water Resources
610 East Center Avenue, Suite 301„ Mooresville, NC 28115
70 63-1699

If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days_ after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any noncompliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Wes Bell of the
Mooresville Regional Office at 704-663-1699.
Sincerely,
,--DocuSigned by:
A14CC681AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File (Laserfiche)
NPDES Compliance/Enforcement Unit - Enforcement File (Laserfiche)
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

FILE
ROY COOPER NORTH CAROLINA
NLICHAEL S. REG.AX.,
sloc"OnY
LMA CLAIIEPPER
lnw�w Di-�evtar
Certified Mail #7016 1370 0000 25911773
R
November 16, 2018
David P Risley, President & CEO
Gough Econ Inc
PO Box 668583
Charlotte, NC 28266
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2018-LV-0136
Permit No. NC6058084
Gough Econ WWTP
Mecklenburg County
Dear Mr. Risley:
A review of the September 2018 Discharge Monitoring Report (DMR) for the subject facility revealed the
deficiency(s) indicated below:
Unit 9now n n
Sample Limit
Reported
Location Parameter Date Value
Value Type of Deficiency
001 Effluent Nitrogen, Ammonia Total (as 9/30/2018 2
2.08 Monthly Average Exceeded
N) - Concentration (C0610)
Please be aware that non-compliance with your permit could result in enforcement action by the Division or
Water Resources for these and any additional violations of State law. The Mooresville Regional Of
encourages you to take all necessary actions to bring your facility into compliance.
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704.663-1699

fps"',
If you should need any assistance or would like to discuss this non-compliance situation, please contact Wes
Bell of the Mooresville Regional Office at 704-663-1699.
Sincerely,
E A
for W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File (Laserfiche)
NPDES Compliance/Enforcement Unit - Enforcement File (Laserfiche)
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

FILE
Ploy C001>M NORTH CAROLINA
Go r
11 : _ REGANI
"`
rnwto r
Certified ail #7016 1370
�t11M Rgggeipt ue e
August 29, 2018
David P Risley, President & CEO
Gough Econ Inc
PO Box 668583
Charlotte, NC 28266
SUBJECT: NOTICE
Tracking Number: NOV-2018-L -0643
Permit No. NCO058084
Gough Econ WWTP
Mecklenburg County
Dear Mr. Risley:
A review of the May 2018 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below
Li ` it ExceAeance iolationf sk
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Nitrogen, Ammonia Total (as 5/31/2018 2 2.35 Monthly Average Exceeded
N) - Concentration (C0610)
Remedial actions, if not already implemented, should be taken to correct any noted problems. The Division of
Water Resources may pursue enforcement actions for this and any additional violations. If the violations are of a
continuing nature, not related to operation and/tar maintenance problems, and you anticipate remedial
construction activities, then you may wish to consider applying for a Special Order by Consent (SOC).
1, 0*9 QW) �
North Carolina Department of Environmental Quality l Division of Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 29115
704-663-169

If you have any questions concerning this matter or to apply for an SOC, please contact Wes Bell of the
Mooresville Regional Office at 704-663-1699.
Sincerely,
DocuSigned by:
A14CC681AF274;.'
W. Corey Basinger, Regional Supervisor
Water Quality Regional operations Section
Mooresville Regional Office
Division of Water Resources, NEQ
Cc:WQS Mooresville Regional Office - Enforcement` File (Lasencche)
DES Compliance/Enforcement Unit - Enforcement File (Laserfiche)
North Carolina [Department of Environmental Quality i Division of Water Resources
610 East. Center Avenue, Suite 301, Mooresville, NC 28115
704663-1699

0 W G '13H R-CEIVED/NC0SNRA)WR
Lj
JUN
cop C 0 No I ON C%*
BULK MATERIALS HANDLING SOLUTIONS
WQROS
MOOREsviLLE REGIONAL OFFICE
June 15, 2018
N.C. Department of Water Quality
Mooresville Regional Office
610 East Center Ave., Suite 301
Mooresville, N.C. 28115
Ref: Gough Econ, Inc. WWTP
NPDES Permit No. NC0058084
Mecklenburg County, N.C.
1
Our ORC offers these facts for your consideration and information. The violations
are for Fecal Coliform and Ammonia Nitrogen. Extreme freezing weather was probably a
factor in both violations. Recirculation piping was dislocated as a result of freezing causing
excessive ponding in a narrow space of the sand filter adversely effecting ammonia
treatment and likely allowing more fecal pass -through.
The fecal coliform exceedance was followed up by immediate resampling of the
effluent. The result on January 12, 2018 showed a return to compliant levels, Action was
taken to the extent of realigning the tablet chlorinator so hydraulics through the chlorinator
would improve contact with the tablets, thus producing a more reliable residual chlorine in
the ContactChamber. Filtrate Recirculation was also restored.
As this is a recirculating sand filter, the finer treatment for ammonia is the
continuous recycling of the filter effluent over the sand bed as evenly as possible.
Recirculation of the Filtrate was restored to more even distribution restoring ammonia
treatment efficiency.
You may contact ivir. Steven Lambert at 704-65 t-578 for further information, if
required
Respectfully Submitted,
ough Econ C.
David P. Risley
President & CEO
cc. Steven Lambert, GEI ORC
o:\wpadata\dpr\1etter\ncdenr 201 &:die
Gough Econ, Inc, P.O. Box 668583Charlotte NC 28 6-8583
Tel. 704,399.4501 Fox 04.392.8 06

FILE
Ploy COOPIM
WCHAEL IWO
S.
water REGAN
LINDA CLILPEPPER
Certified Mail #70161370 0000 2595 8112
Rei�u�n Re�ei t eauested
4 June 2018
David P Risley, President & CEO
Gough Econ Inc
PO Box 668583
Charlotte, NC 28266
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: GV-2018-LV-0393
Permit No. NCO058084
Gough Ecor WWTP
Mecklenburg County
Dear Mr. Risley:
A review of the January 2018 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated, below:
Limit Exomiano ViolationC
:Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent Coliform, Fecal MF, MFC Broth, 1/10/2018 400 1,553.1 gaily Maximum Exceeded
44.5 C (31616)
001 Effluent Nitrogen, Ammonia Total (as 1/31/2018 4 5.82 Monthly Average Exceeded
N) - Concentration (A610)
A Notice of Violation/Intent to Issue Civil Penalty is being; issued for the noted violation of North Carolina General
Statute (G..) 14-215.1 and the facility's NP©ES WW Permit. Pursuant to G.S. 1-215.A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
14-21.1.
State of NorthCarolina I Environmental Quality i Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

0 of - 0 - -
a Is a 411 0 1 0 a
so
— —7
oval
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Wes Bell of the
Mooresville Regional Office at 704-663-1699.
Sincerely,
DOCUSigned by:
_74CC681AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File (Laserfiche)
NPDES CorTipliance/Enforcement Unit - Enforcement File (Laserfiche)
State of North Carolina Envitorunental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28 1 tS
704-663-1699

Bell, Wes
From: Steven Lambert <[e-mail]>
Sent: Friday, January 19, 2018 7:21 AM
To. Bell, Wes
Cc; 'David Risley'
Subject: [External) Fecal Col form NCO058084 GOUGH ECON, INC.
This is to inform you that the January DMR will show a maximum daily violation of fecal coliform on 1/10/18.
Extreme cold weather caused the recirculation piping to come apart, greatly reducing filter efficiency. This could have
caused excessive fecal discharge to the chlorination tank and excessive chlorine demand. Still baffling is the residual
chlorine previous de -chlorination was 0.3 mg/L.
Staff completed repairs and increased the chlorine tablet tube array from one to three. We believe these actions will
better assure future compliance.
Thank you,
Steven Lambert
704-657-8847

December 9, 2016
David P Risley, President & CEO
Gough Econ Inc
PO Box 668583
Charlotte, NC 28266
SURIECT: NOTICE OF VIOLATION
T «_
Permit. N « i
«.
« «
NOV'-2016-LV-0648
8084
my
f 1 f
f f f
f
w Q ... * N .. . �.. (� ® ® ®. :* • � !. a ♦. �. � . . .:.. � ,..*.

Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File

RMM i
October 17 2016
David P Risley, President & CEO
Gough Econ Inc
PO Box 66 583
Charlotte, NC 28266
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NON-2016-LV-0563
Permit No. NCO058084
Gough Econ WWTP
Mecklenburg County
Dear Mr.
A review u1
indicated l
unit �xce
Sam
aported
Value TVpe of Violation
2.13 Monthly Average Exceeded
anv noted oroblem . The Division of
w s w� .ww w• w- • •• w w

looresville, Regionai umce at 7u4-663-1699.
Sincerely,
W. Corey Nsinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
*c: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
State; of Alor& Carolin I Enviromental QhWity I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
70.4-663-1699

PAT MCCRORY
`1
b0 ;4Y V . t UE.R V AART
Seovfioy
WaterResources S. JAY ZIMMERMAN
f.#7iCt£kY
N VIPOHMENTAL QUALITY
September 13, 2016
Mr. David Risley, President and CEO
Gough Econ, Inc.
P.0 Box 66858
Charlotte, NC 28266
Subject: Compliance Evaluation Inspection
Gough Econ WWTP
NPDES Permit No. NCO058084
Mecklenburg County
Dear Mr. Risley,:
Enclosed is a copy of the Compliance Evaluation Inspection for the inspection conducted at
the subject facility on September 12, 2016, by Qri Tuvia. Steven Lambert's 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.
The report should be self-explanatory; however, should you have any questions concerning
this report, please do not hesitate to contact ©ri Tuvia at (704) 235- .190, or at
[e-mail].
Sincerely,
Ctri Tuvia, Environmental Engineer
Mooresville Regional Office
Division of Water Resources, DEQ
Cc. NPDES Unit
MRa Files'
Mooresville Regional Offloe
Locatlon. 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Pax: [phone] t Custorner Service: 1-877-63.6748

United States Environmental Protection Agency Form Approved.
EPA Washington, O.C. 204W OMB No, 2040-0057
Water Compliance Inspection Report Approval expires 6-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES Yrimotday Inspection Type Inspector Fac Type
1 � 2 3 NCO058084 111 12 16/09112 117 18 1 C ( 191 0
Inspection Work [lays 'Facility Self -Monitoring Evaluation Rating S1 CIA ---------- Reserved
57 1.0 701 I 71IN 72 1 74 75 1 1�50 l� J Section l3: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date
POTW name and NPOES oerm t Number) 08:55AM 16/09/12 15107101
Gough Econ WWTP
9400 N Lakebrook Rd Sr Emit Time/Date Permit Expiration Date
Charlotte NC 26214 10:35AM 16/09/12 20/06130
Name(s) of Onsite Representative(s)tfitles(s)/Phone and Fax Number(s) Other Facility Data
P/!
Steven L LamberVORC/704-646-2602/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
David P Risley,PO Box 668583 Charlotte NC 28266/President/704-399-2306(
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit ■ Flow Measurement operations & Maintenance Records/Reports
Self -Monitoring Program a Sludge Handling Disposal ® Facility Site Review ® Effluent/Receiving Waters
Laboratory
Section C: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
{See attachment summary
Name(s) and Signature(s) of Inspector(s) Agency/OfficetPhone and Fax Numbers Date
Ori A Tuvia MRO WQ/1704-663-1699/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger MRO /J704=235-21941
EPA Form3660-3 (Rev 9-94) Previous editions are obsolete;
Page# 1

Page#
6

Permit: N O058084 Owner - Facility: Gough E0on WwrP
inspection bate: 09112/2016 Inspection Type: Compliance Evaluation
PerMiit
Yes No NA NE
(if the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
011
application?
Is the facility as described in the permit?
■
f-1
❑
❑
#k Are there any special conditions for the permit?
❑
M
❑
❑
Is access to the plant site restricted to the general public?
®
❑
0
❑
Is the inspector granted access to all areas for inspection?
®
❑
❑
❑
Comment: The subiect o rmit expires g/-_3Q/_2020.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
■
❑
❑ `
❑
Is all required information readily available„ complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on'DMRs?
®
❑
❑
❑
Is the chain -of -custody complete?
0
❑
®
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates 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 D ?
®
❑
N
❑
(if the facility is = or > 5 MD permitted flow) Do they operate 2417 with a certified operator
❑
0
■
❑
on each shift?
Is the ORC visitation log available and current?
■
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
■
❑
p
❑
Is a copy of the current NPD S permit available on site?
■
0
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
®
❑
Comment: DMR COCs Calibration i '` s and ORC ICr s were reviewed for the period June 2C115
through May 10. The facility's records were or nixed and well maintain
Laboratory
Yqs No NA NE
Are field parameters performed by certified personnel or laboratory?.
M000
Page#
3

Permit: NCO058064 Owner -Facility: GoughEconWWTP
Inspection Date: 09/12/2016 Inspection Type: Compliance Evaluation
Laboratory X21 Na NA NE
Are all other parameters(excluding field parameters) performed by a certified lab? an cio
# Is the facility using a contract lab? N 0 0 El
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 0 No
Celsius)?
Incubator (Fecal Colif6rm) set to 44.5 degrees Celsius+/- 0.2 degrees? o o a o
Incubator (BOD) set to 20.0 degrees Celsius +/- 1 .0 degrees? n o mo
instrumentation used for field analyses appeared to be properly calibrated.
Effluent Sampling
Yes No b!A_ HE
Is composite sampling flow proportional?
n
ci
a
o
Is sample collected below all treatment units?
0
0
0
0
Is proper volume collected?
a
0
0
0
Is the tubing clean?
0
0
0
0
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
0
a
0
Celsius)?
Is the facility sampling performed as required by the permit (kequency, sampling type
a
0
0
0
representative)?
Comment: Subiect permit re uires -grab sampling.
Upstream / Downstream Sam2ling
Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and
8000
sampling locaVion)?
Comment:
Qr)erations & Maintenance
)Les No
NA NE
Is the plant generally clean with acceptable housekeeping?
0000
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
11
0
a
0
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The facility apear ed to be proped y opeLatqd I and;well maintained at the tme of the
Septic Tank )Les No NA NE
(If pumps are used) Is an audible and visual alarm operational? ❑ 0 0 El
Is septic tank pumped on a schedule? El 11 11
Page# 4

Permit. NC005808 F Owner - Facility. Gough Eccn WWTP
Inspection gate. 09112/2016 Inspection Type: compliance Evaluation
e tic Tank Yes No NA NE
Are pumps or syphons operating properly? N 0 ® El
Are high and low water alarms operating properly? © 0
Comment. The se tic tank is ournoed as needed. Last pUmped by,StanleyEnvironmental on 71111 .
Sand Filters (Low rate)"' Yes No NA NE
(if pumps are used) Is an audible and visible alarm Present and operational? 11 Q all
Is the distribution box level and. watertight? ■ 0 © 0
Is sand filter free of ponding? M D ® 0
Is the sand filter effluent re -circulated at a valid ratio? R 0 © D
# Is the sand filter surface free of algae or excessive vegetation? ■
# Is the sand filter effluent re -circulated at a valid ratio? (Approximately; 3 to 1 ) D D 0 ■
Comment. Sand filter was recentiv re -dime. sand filter a eared to be working ade uatei ,
tsinfection-Tablet Yes No NA NE
Are tablet chlorinators operational? W E] © 0
Are the tablets the proper size and type? 0 0 11 11
Number of tubes in use? 1
Is the level of chlorine residual acceptable? i.
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination? M C1 00
Comment. 4 tubes are available 1 is in use.
De -chlorination Yes No NA NE
Type of system? Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)? © 0 M El
Is storage appropriate for cylinders? © [„ N D
# Is de -chlorination substance stored away from chlorine containers? 00 M
Comment;
Are the tablets the proper size and type? ■ 13 13 11
Are tablet de -chlorinators operational? ■ 'Q D Q
Number of tubs in use? 4
Comment: 4 tubes are available all 4 are in use.
Page# 5

Permit. NC0068084 Owner - Facility.
t
tedj toes the chart recorder match the flow meter?
antaneous flow monitoring is re aired -by the sub'egt ermit. 'The effluent h
isured by the bucket and stop watch method
ie outfall property maintained?
vater free of foam ether than trace amounts and other debris?
• pipes are required) are they operating properly?
be negativelyneggtively im acted.
I

"VA
TP
Certified Mail *7015 1520 0002 6984 7788
MMM &0=1121 HOUSIMd
August 19, 2016
David P Risley, President & CEO
Gough Econ Inc
PO Box 668583
Charlotte, NC 28266
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2016-LV-0088
Permit No. NCO058084
Gough Econ WWTP
Mecklenburg County
Dear Mr. Risley:
A review of the April 2016 Discharge Monitoring Report (DMR) for the
subject facility revealed the deficiency(s)
indicated below:
Limit Exceedance Defidtim(i):
Sample Limit
Reported
Location Parameter Date Value
Value Type of Deficiency
001 Effluent Colifbrm, Fecal MF, MFC Broth, 4/26/2016 400
411 Daily Maximum Exceeded
44.5 C (31616)
Please be aware that non-compliance with your permit could result in enforcement action by the Division of
Water Resources for these and any additional violations of State law. The Mooresville Regional Office
encourages you to take all necessary actions to bring your facility into compliance.
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

If you should need any assistance or would like to discuss this non-compliance situation, please contact Wes
Bell of the Mooresville Regional Office at 704-663-1699.'
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville; Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
State of North Carolina ( Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

Bell, Wes
From: Steven Lambert <rmlambert@yadtelnet>
Sent: Monday, August 15, 2016 .53 AM
To: Bell, Wes
Cc: 'David Risley"
Subject. NCO058084 Cough Econ, Inc. Fecal Coliform Noncompliance
As reportedto your office on August 10, 2016, an effluent sample was taken at Gough Econ, Inc. The result was
noncompliant for Fecal Coliform'(>2800 cnts). A follow-up sample was taken on August 12, 2016, which results will not
be in until today (8/15/16), as the culture wasn't read until Saturday, 8/13/16.
As I have not received a "heads up" calf from the laboratory, the present assumption is the result is good. You will
be updated' on the result as soon as it is available.
This occurred shortly after facility restart from extensive maintenance and repairs. Staff has changed the chlorine
tablets with fresh tablets and adjusted the recirculation pump starts and stops to induce more frequent filter discharge
through the tablet chlorinator. These actions should maintain a higher and more reliable chlorine residual in the contact
chamber, and should not harm compliance on other parameters.
You may reply to Mr. Risley or myself for further information, if required.
Sincerely,
Steven lambert

Attachment to June, 201E
Discharge Monitoring Report
NCO058084
Gough Econ., Inc.
This report shows noncompliance on the Ammonia Nitrogen parameter.
The required average of 2.0 mg./L was exceeded with an average of 2.13
mg./L. However slight the result, noncompliance must be reported.
Remedial Action
The entire month of July,; 2016 saw extensive effort to address overall
facility performance.
The filter was fouled and failing to pass water at the normal rate and at
optimal treatment. The facility vessels were pumped out to halt the
discharge and allow for removal of filter media and its replacement.
A search for contractors finally culminated in action during the last week
of July. Old media was removed, walls patched and waterproofed, and
loose blocks replaced. This ended with the total replacement of the sand
media.
The entire month was without discharge and full operation will
commence once facility vessels are full. Full compliance should result.

M
4
From: Steven Lambert <[e-mail]>
Sent: Wednesday, August 10, 2016 7:27 AM
To: Bell, Wes
Cc: 'David Risley'
Subject: RE: Docurnentl
AFTER EXTENSIVE REFURBISHMENT, FACILITY WAS RECORDED AS HAVING FLOW ON 8/5/2016. EFFLUENT WAS
SAMPLED ON 8/9/2016, SAMPLES WERE TAKEN TO THE CONTRACT LAB FOR ANALYSES. FIELD TESTING RESULTS
INDICATE ALL PARAMETERS ARE COMPLIANT.
From: Steven Lambert [mailto:[e-mail]]
Sent: Friday, July 29, 2016 10:34 PM
Subject: Documentl
Please find the DMR additional page to explain facility remediation and its possible positive result on compliance.

WK
K
PAT MCCRORY
Governor
:.
DONALD R. VAN DER VAART
Secretary
Water Resources S. JAY ZIMMERMAN
ENVIRONMENTAL GLIALITY
Director
July 18, 2016
CERTIFIED MAIL 7009 2250 0000 8087 1177
RETURN RECEIPT REQUESTED v.
Mr. David P Risley, & CEO President
Clough Econ, Inc.
PO Box 668583
Charlotte, NC, 286-8583
Subject: Notice of Violation NOV-2016-PC-0275
:Failure to Register & Submit Electronic Discharge Monitoring Reports (eDMRs)
Cough Econ WWTP
NPDES Permit'NCOO58O84
Mecklenburg County
Dear Mr. Risley.
Per the terms of your NPDES permit, you were required to register for, and begin using, the eDMR system
by 3/27/2016. Our records indicate that as of the date of this letter, the subject facility is not registered and
not submitting data electronically.
Failure to register and begin submitting reports electronically is a violation of the terms of your permit,
subjecting you to a possible assessment of civil penalties. In order to reduce the risk of receiving additional
enforcement action, you must complete'your registration and submit your July 2016 DMR electronically on
or before August 31, 2016.
The Division has prepared a website devoted to all aspects of eDMR, including registration: -for its use,
obtaining an eDMR user account, and answers to frequently asked questions. You are encouraged to visit the
ebsite at: lhtt y /deq.-nc y/ ibouticlivisi(�i2s/water-resourcces/ec mi-. Should you have further questions
regarding eDMR after reviewing the website's content, or have need of further assistance, you should contact
Derek Denard'at 919-807-6307 or [e-mail].
Thank you for your cooperation in this matter,
ricer y,
S. Jay Timmerman, P.G.
Director, Division of hater Resources
cc: NPDES File
Central Files
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center- I Raleigh, North Carolina 27699-1617
919-707-9000

Bell, Wes
From: Steven Lambert <mslambert@yadtelnet>
Sent: Thursday, July 07, 2016 5:44 AM
To: Bell, Wes
Cc: 'David Risley'
Subject: NCO058084--No Flow
As continual non-compliance of Ammonia Nitrogen is very possible, and the filter bed is scheduled for replacement of
sand media, this facility has been pumped clean. There has been no discharge since July 1, 2016 (Friday). Stanley
Environmental was the pumping contractor.
Kemp, Inc. is scheduled to begin the project on July 28, 2016.
All tanks will be monitored daily by operators and/or, plant personnel, just in case, to prevent discharge. At the rate this
facility discharges water, it will be weeks before the septic tank and dosing tank refill. Should this begin to happen
prematurely, another pumping will be ordered to prevent discharge.
Thank you,
Steven Lambert

PAT MCCRORY
DONA D R. -VAN DER VAART
KwtvPet y
Water Resources S. JAY IMM .MAN
1)hefor
June 24, 2016
David Risley
Gough Econ Inc
PO Box 66 583
Charlotte, NC 28266
.Subject: NPDES Electronic Reporting Requirements
Gough Econ WWTP
NPDES Permit Number: NCO058084
Gear NPDES Permittee:
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 can December 21, 2016, regulatedentities that are required to submit Discharge
Monitoring Reports (DIUiRs) will begin submitting these reports electronically. if you are currently
reporting your DMR 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 DMRs will be required, instead of voluntary.
• Phase 2 —Starting can December 21, 2020, regulated entities that are required to submit certain
other NPDES reports will begin submitting these reports electronically. Reports covered in the
second phase include Notices of Intent to discharge in compliance with an NPDES general permit,
Sewer Overflow/Bypass Event Reports, and a number of 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 2113, and should contain the requirement to electronically
report your Discharge Monitoring Reports using NC DWR's efMR system.'
In addition to requiring prmittees to report information electronically, the rule also requires permittees
to identify the initial recipient for the NPDES electronic reporting data (see 40 CFR 122.41(I)( )j. Initial
State of North Carolina I F:miro mental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina ?' 699-1617
919 807 6300

itial recipient of your electronic submission,
e, visit

Bell, Wes
From: Steven Lambert <[e-mail]>
Sent: Thursday, June 02, 201610:24 PM
To: Bell, Wes
Subject; APRIL 26, 2016 DAILY MAX FECAL EXCEEDENCE
GOUGH ECON, INC. NCO058284 MECKLENBURG CO.
AS REPORTED TO YOU ON THIS DATE BY TELEPHONE THIS EMAIL IS SENT AS WRITTEN CONFIRMATION.
THE APRIL, 2016 DMR WILL SHOW THE 400 COUNT LIMIT WAS EXCEEDED ON APRIL 26 2016. THE LAB RESULT WAS 411
COUNTS,
THE CONDITION OF THE SAMPLE WAS NEAR PRISTENE WITH ONLY AN ELEVATED LEVEL OF AMMONIA NITROGEN,
WHICH DID NOT EFFECT THE MONTHLY COMPLIANCE LIMIT.
THE TRC IN THE CONTACT CHAMBER WAS 0.25 mg/L. THIS MAY SEEM LOW, BUT TAKING THE CONDITION OF THE
EFFLUENT INTO ACCOUNT, SHOULD HAVE BEEN ADEQUATE.
WE WILL PAY STRICT ATTENTION TO SAMPLING PROCEDURES AND, IF NECESSARY, PLACE ADDITIONAL CHLORINE TO
RAISE TRC.
THIS IS NOT OUR USUAL PERFORMANCE AND HAS CAUSED GREAT CONCERN.
A PLAN IS UNDERWAY TO SERVICE THE SAND BED, WHICH WILL TEMPORARILY HALT EFFLUENT DISCHARGE. AS
DISCUSSED YOUR OFFICE WILL BE KEPT INFORMED OF THESE DEVELOPMENTS.`
THANK YOU,
STEVEN LAMBERT, ORC
1

Pat McCrory
Governor
Mr. David
Gough Eci
Post Office
Charlotte,
!2A *W
NCDENR
Irth Carolina Department of Environment and Natural Resources
Donald van der Vaart
Secretary
,rune 30, 2015
President and CEO
568583
Carolina 86-8583
Subject: Notice of Violation - Effluent Limitation
Trnrkk-inn Ni rrnhar KIi'llt_901 A%_I lt_nA9A
a as x.r a.. vra vx xaxe♦ s •vvvvvwv-r
Mecklenburg County
Dear Mr. Risley:
review of the February 2015 self -monitoring report for the subject facility revealed a violation of the
following parameter at Outfall 001;
Date Parameter eoo a Value Permit Limit
2f18115 Fecal Coliform 2,419.E CFUf100 ml 400 CFU/100 ml (Daily Maximum)
Remedial actions, if not already implemented, should be taken to correct any noted problems. The
Division of Water Resources may pursue enforcement actions for this and any additional violations. If
the violations are of a continuing nature, not related to operation and/or maintenance problems, and
you anticipate remedial construction activities, then you may wish to consider applying for a Special
Order by Consent (SOC).
If you have questions concerning this matter or to apply for a SOC, please do not hesitate to contact
r. Wes Bell or myself at (704) 6-169.
incerely,
Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
cc: Wastewater Branch
Central Files (MSC 1617-basement)
Mooresville Regional Office
Location: 613 East Center Ave., Suite 361 Mooresville, NC 28115
Phone: [phone] l Fax: (704) 663 }4Q i Customer Service:1-877-623-6748
Internet: http:lfpodal,ncdenr.orgrlweb/wq
An Equal i p«rt pity i Affirm fivr Fetit;r Employer- 301% Recyclar! ; 0% Post Consunier paper

Pat McCrory
overnOr
Mr David RisleyPresident
North Carolina Depattment of Environmental Quality
Donald R, van der Vart
Secretary
O
,
Gough Econ, Inc. WOROS
PO Box 668583
Charlotte, NC 2866-8563 r1liit t2EttCli OFFICE
SUBJECT: Payment Acluiowledgment
Civil Penalty Assessment
Gough Econ WW P
Permit Number: NCOO58O84
Case Number: T V-015-01 T
Mecklenburg County
Dear Mr, Risley;
This letter is to acknowledge receipt of check number 056602 fil the amount of $396,97 received from, you on September
2, 2015. This payment satisfies in hall the above civil assessment levied against the subject facility, and this case has
been closed. Payment of this penalty in no way precludes future action by this Division for additional violations of the
applicable Statutes, Regulations, or Permits.
If you have any questions please contact Wren Thedford at 919-807-6304,
Sincerely,
Wren Thedford
cc: Central Files
Mooresville Regional Office
>1697 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] \ FAX [phone]
Internet. wuw.ncwater,org
An Equal Opportunity a Afiirrnative Action Employer
September 30, 2015

FILE
RUM
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
September 8, 2015
CERTIFIED IL 7015 00 0002 9299 3359
RETURNEIPT REiiESTE
David Risley, President and CC?
Gough Egon, Inc.
P.U. Box 66858
Charlotte, NC 28266-8583
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143.215.1(a)(6) and NPDES Permit No. NCOO58084
Gough Ecn TP
Mecklenburg County
Case No. LV-2015-0172
Dear Mr. Risley:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
36.97 $300 civil penalty + $146.97 enforcement costs) against Gough Econ Inc.
This assessment is based upon the following facts: A review has been conducted of the self -
monitoring data reported for July 2014. This review has shown the subject facility to be in violation of
the discharge limitations found in NPDES Permit No NCO058084. The violations are summarized in
Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Gough Econ, Inc. violated the
terms, conditions, or requirements of NPDES Permit No. NO058084 and North Carolina General
Statute (G.S.) 143-215.1(a)(6) in the manner and extent shown in Attachment A. A civil penalty may
be assessed in accordance with the maximums established by G.S. 14 - 1 .6A(a)( ).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the Director
of the Division of Water Resources, I, Michael L. Parker, Regional Supervisor for the Mooresville
Region, hereby make the following civil penalty assessment against Gough Eon, Inc.
Mooresville Regional Office
Location 610 Fast Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] t Fax: [phone] t Customer ervice:1-877.623-6748
Internet: http:7lponal.ncdenr.orgfvvebtwq
An Equal Opportunity l Af€irrtative Action Employer - G°k Recyrcledfl0l% Post Consurner Fade;

$ 250.00 For I of the one (1) violation of G.S. 143-215, 1 (a)(6) and
NPDES Permit No. NCO058084, by discharging waste into the
waters of the State in violation of the permit monthly average
effluent limit for ammonia.
$ 250.00 TOTAL CIVIL PENALTY
$ 146.97 Enforcement costs
$ 396.97 TOTAL AMOUNT DUE
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. 143 B-282.1 (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 violations;
(2) The duration and gravity of the violations;
(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 violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which
the Envirom-nental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and Natural
Resources (do not include waiverform), Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Wastewater Branch -
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
2. Submit a written request for remission including a detailed justification for such request:
Please be aware that a request for remission is limited to consideration of the five factors listed
bAltyur CIO fboxr V'Acf� f^ +ba -f+" --+ -P+U- —4- n--A D--+—

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 by a waiver of your right to an administrative hearing and a stipulation 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 Resources at the address listed
below. In determining whether a remission request will be approved, the following factors shall be
considered:
(1) whether one or more of the civil penalty assessment factors in G.S. 1438-2 2 1(b) were
wrongfully applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from
the violation;
() whether the violation was inadvertent or a result of an accident;
() whether the violator had been assessed civil penalties for any previous violations; or
() whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please note that all information presented in support of your request for remission must be
submitted in writing. The Directorof the Division of Water Resources will review your evidence and
inform you of his decision in the matter of your remission request. The response will provide details
regarding case status, directions for payment, and provision for further appeal of the penalty to the
Environmental Management Commission's Committee on Civil Penalty Remissions (Committee).
Please be advised that the Committee cannot consider' information that was not part of the original
remission request considered by the Director. Therefore, it is very important that you prepare a
complete and thorough statement in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Waiver of Right to
an Administrative Hearing and Stipulation of Facts" form within thirty (30) days of receipt of this
notice. The Division of Water Resources also requests that you complete and submit`the enclosed
"Justification for Remission Request." Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 2769 -1612
OR
3. File a petition for an administrative hearing with the Office of Administrative Hearing :
If you wish to contest any statement in the attached assessment document you must file a
petition for an administrative hearing. You may obtain the petition form from the Office of
Administrative Hearings. You must file the petition with the Office of Administrative Hearings
within thirty (30) days of receipt of this notice. A petition is considered filed when it is received in
the Office of Administrative Hearings during normal office hours. The Office of Administrative
Bearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 ,m.,
except for official state holidays. The petition may be filed by facsimile (fax.) or electronic mail by an

Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DENR as follows:
Mr. Sam M. Hayes, General Counsel
DENR
1601 Mail Service Center
Raleigh, NC 27699-1601
Failure to exercise one of the options above within thirty (30) days of receipt of this nc
evidenced by an internal date/time received starnp, (not a postmark), will result in this matter 1:
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 af
review period of this assessment. If you have any questions about this civil penalty assessmei
contact staff in the Mooresville Regional Office at [phone].
(Ddte) Michael L. Parker, Region��;]Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
ATTACHMENTS
cc: Mooresville Regional Office Compliance File w/ attachments
Raleigh Compliance/Enforcement File w/ attachments
Central Files w/ attachments

ATTACHMENT
CASE NO. V--2015-0172
Outfall Date Parameter Revorted Value Per it Limit`
001 7/31/2014 Ammonia 4.37 mg/l* 2 m/I (Monthly Average)
* Denotes civil penalty assessment
Gough Econ, Inc. did not provide a response to NOV-2015-L -0204. Comments `tten
in the July 2014 DMR received on September 10, 2014were reviewed by DWR staff.
Mitigating factors were not found to result in a reduced civil penalty amount.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF MEC KLENBURG
IN THE MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN
OF CIVIL PENALTY AGAINST ) ADMINISTRATIVE HEARING
GOUGH ECON, INC. STIPULATION OF FACTS
PERMIT NUMBER NCO058084
FILE NO. LV-2015-017
Having been assessed civil penalties totaling $196.97 for violation(s) a, set forth in the
assessment document of the Division of Water Resources dated March 23.201.5, the undersigned,
desiring to seek remission of the civil penalties, does hereby waive the right to an administrative
hearing in the above -Mated matter and does stipulate that the facts are as'alleged in the assessment
document. The undersigned ftirther understands that all evidence presented in support of remission of
this civil penalty must be submitted to the Director of the Division of Water Resources 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 , 2015
BY
ADDRESS
TELEPHONE

JUSTIFICATION FOR REMISSION REQUEST
DWR Case Number: LV-2015-0172
Assessed Party: Gough Econ, Inc
County: Mecklenburg
Permit Number: NCO058084
Amount Assessed: $396.97
',W"MW MIRM
0011�
a KWOUQUAM "#%=
future occurrenc�s);
(c) the violation was inadvertent or a result of an accident (i.e., explair,
was unavoidable or something you could not prevent or prepare for)
(d) the violator had not been assessed civil penalties for M prndqq�.�
(e) pg)ment of the civil poAfty will prevent DWMent for the remaining. nece!
actions (L e., explain how payment of the civil penalty will prevent you ft(
the activities necessary to achieve compliance).
EXPLANATION: (use additionalpages as necessary)

NORTH CAROLINA DIVISION OF WATER RESOURCES
ASSESSMENT FACTORS
Violaters Gou-h Econ, Inc
Facility: Gough Econ WWTP
County: Mecklenburg
Case Number: LV-201-0172
Permit Number. NCO058084
1) The degree and extent of harm to the natural resources of the State, to the public health, or t
private property resulting from the violation; No harm has been documented:
2) The duration and gravity of the violation; The ammonia monthly average permit limit was
exceeded by 118.5% for July 2014.
) The effect on ground or surface water quantity or quality or on air quality;: The effect on the
receiving Stream is unknown. Ammonia -nitrogen is treated as an in -stream toxicant by the State of
North Carolina because ammonia is an oxygen -consuming waste and increased concentrations could
reduce the amount of oxygen available to aquatic organisms:
4) The cost of rectifying the damage; The cost is unknown.
5) The amount of money saved by noncompliance; The amount of money saved by noncompliance is
unknown.
6) Whether the violation was committed willfully or intentionally; The Division of Water Resources
has no evidence that the violations were committed willfully 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
There have been 12 previous CPAs for the Gough Econ, Inc. with the last CPA being issued on
February 5, 2015 for fecal coliform and Ammonia permit limit violations in September 2013.
) The cost to the ;State of the enforce ent procedures.
The cost to the Division of Water Resources is $146.97.
Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Envision of Water Resources, N DENR

North Carolina Department of Environment and Natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
March 23, 2015
CERTIFIED MAIL #70110110 0000 9960 8058
RETURN RECEIPT REQUESTED
Mr. David Risley, President and CEO
Gough Eeon, Inc.
P. 4. Box 668583
Charlotte, Forth Carolina 28266-858
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking Number: G-2015-L.V-0204
Gough Econ VVWTP
NPIDES Permit NCO058084
Mecklenburg County
Dear Mr. Risley:
A review of the July 2014 self -monitoring report for the subject facility revealed violations of the
following parameters at Outfall 001:
Date Parameter Reoorted Value Permit Limit
7/31/14 Ammonia 4.4mg/L 2.0 mg/L'(Montly average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is being; issued
for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No.
NC0058084. Pursuant to G.S. 14-215.6A, a civil penalty of not more than twenty-five thousand;
dollars ($25,000,00) may be assessed against any person who violates or fair to act in accordance
with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1.
If you wish to provide additional information regarding the rioted violations, request technical
assistance, or discuss overall compliance please respond in writing within 20 days of receipt of this
Notice. A review of your response will be considered along with any information provided on the
July 2014 Discharge Monitoring Report. You will then be notified of any civil penalties that may be
assessed regarding these violations. If no response is received in this Office within the 20-day
period, a civil penalty assessment may be prepared.
Remedial actions, if not already Implemented, should be taken to correct any problems. The Division
of Water Resources may pursue enforcement actions for this and any additional violations. If the
Mooresville Regional Office
Locabon: 610 East Center Ave„ Suite 301 Mooresvilie, NO 28116
Phone: [phone] \ Fax: (704) 66MO40 \'Customer Service: 1-877-623- 748
Internet: httpltportai,ncdenr,org/webfwq

V-2016-LV-0204, Page 2
myself at [phone].
Sincerely,
Michael L. Park6r, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
cc: Wastewater Branch
MSC 1617 — Central Files Basement

Akin
North Carolina department of Environment and Neural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
March 04, 2015
Rl N
MAR fi1 ,
David P. Risley
Cough Econ Inc. WOROS
SVILLE REGIONAL OFF ,
PO Box 68583
Charlotte, NC 28265-8583
Subject: Acknowledgement of Pennit Renewal
Permit NCO058084
Mecklenburg County
Dear Mr. Risley:
The NPDES Unit received your permit renewal application on March 03, 2015. A member of the
NPDES Unit will review your application, They will contact you if additional information is required to
complete your permit renewal. You should expect to receive a draft permit approximately 30-45 days
before your existing permit expires.
If you have any additional questions concerning renewal of the subject permit, please contact .Bob
Sledge [phone].
Sincerely,
Wren Thedford
Wastewater Branch
cc: Central Files
NPDES Unit
1617 Mail service Center, Raleigh, North Carolina 27699-1617
Location:512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] Pax:919-807-6492FCustomer Service;1-877.623-6748
Internet:: www. ncwater.Arg
An Equal Opportunityi#tittirmative Action Employer

t 4
f
GOUGH
ECONvINC.
BULK MATERIALS S HANDLING SOLUTION
RECE-1VENDENRUDWR
February 25, 201
Mr. Wren Thedford Peruliffinn ..
NC DENR 1 DWR / NPDES Unit WOROS
1617 Mail :Service Center MOORESVILLE REGIONAL OFFICE
Raleigh, N.C. 27699-161
Subject: Permit Renewal Application Package
NPDES Permit NCO058084
Gough Econ Inc.
Mecklenburg County
Dear Mr. Thedford,
Please accept the attached renewal application for our waste treatment pet it referenced above. All
the associated originals and copy sets are enclosed.
Where have been no modifications made since our last permit was issued September 20, 2010 and
made effective November 1, 2010.
The application asks for a narrative description of our sludge management plan. Because our
system does not generate any solids we do not have a sludge management plan. However, we do hire the
services of Stanley Environmental Solutions, Inc. to pump out the septic, when instructed to do so by our
ORC, Mr. seven Lambert.
If you should have any questions or need additional information please do not hesitate contact rase
via phone or email,....direct line 704-3 9-2306 ext. 5114 or by email drisle , 6u he con.coan.
Respectfully Submitted,
Go gh E'co c.
David P. Risley
President & CEO
Cc: Steven Lambert — ORC
o:lwpdataldprlwastetreatment\NPDESpermitrenewal 201 5.disc
Gough Econ, Inc. P.t . Boar 668583 Charlotte IBC 2 266-8583 Tel. [phone] Fox 04. 92.87 6

6° NC DENRWR / NPDES
l r renewal Application Checklist
&1
MOOR'+tLI
-rhe following items are REQ11LIRED for all renewal pac age a
o A cover letter reelues ` g renewal of the permit and documenting any changes at the facility sine
issuance of the last permit. 't. Submit one signed original and two copies.
/o The completed application form (copy attached), signed y the permittee or an Authorized
Representative. Submit one signed original and two copies.
0 If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
the renewal package, written documentation must be provided showing the authority delegated to the
Authorized Representative (see fart 11.13.1 Lb of the existing NPDES permit),
o- A narrative description of the sludge management plan for the facility. Describe Ilow sludge (or caller
-Z solids) generated during wastewater treatment are handled. and disposed. If your facility has no such
copeplan (or the permitted facility does not generate any solids), explain this in writing, Submit one signed
original and two copies:
The foHowi ite s ra t % s brr itt d 1 an r ci ai or Industrial facilities discha 'n
'Drocess wastewater:
o Industrial facilities classified as Primary Industries (see Appendices A-1 to Title 40 of the Code of
Federal Regulations, fail 122) and ALL .Municipal facilities with a permitted flow 1.0 MGD must
submit a Priority Pollutant Analysis (PPA) . accordance with 40 ("FR fart 122.21.
The aboverequirement does NOT apply to o indus ial lac ffti
Send the completed renewal package to:
Wren Thedford
1617 Mail Service Center
Raleigh, NC." 699-161

NPDES LIB - FORM D /
For privately-ownedtreatment systems treating 10% domestic wastewaters 1.
Mail the complete application to: 00,
N. C. Division of Water Resources NPDES Progr
1617 ail Service Center, Raleigh, NC 27699-1617 � /`
PermitNPDES ,
Z
If ;you are completing this form in computer use the TAB key or the up -- down to move from one
field to the next. To check the boxes, click your mouse on trap of the box, Othenvise, p print or type.
1. Contact Information:
Owner Name
Facility Name
Mailing Address
city
State Zip Code t4 C
Telephone Number (7 ) �-4sai
Fax Number v ) 2�Z
e-mail Address b
. Location of facility producing discharge:
Check here if same address as above []
Street Address or State Road . ; . 9- t e a
City t
Mate / Zip Code
Count* � c
3. Operator Information:
Name of the firm, public organization or other entity that operates the facility, (Note that this is not
refening to the Operator rator in Responsible Charge or C l2Cj
Mailing Address M
Su
city S1°"."`e sit o 1
State / Zip Code K.C. 2
Telephone Number ( ) S
Fax Number (` o4) - 7 ,
e-mail Address
I of 3 srm_p 9/201

For privately -owned treatment systems treating I CI% domestic wastewaters I.
4. Description of wastewater:
Facility iar xteratirtg rite ater(check all that apply):
Industrial 9 Number of Employees
_43-
Commercial 0 Number of Employees
Residential El Number of Homes
School ❑ Number of Students/Staff
Other 1:1 Explain:
Describe the source(s) of wastewater (example: subdivision, mobile home park, shopping centers,
restaurants, etc.): i ic,.4r METAL T5.
t € e�
Number of persons served:
. Type of collection system
MO'Separate (sanitary sewer only) E Combined (storm sewer and sanitary sewer)
utfallInformation:
Number of separate discharge points
utfall Identification nu er(s) Wl
Is the outfall equipped with a diffuser? es
7. Name of receiving strew (s) ( ut� Ucant . Provide a "nap shotuing the e cact location of each
out faII)t1 tag
S. Frequency ofDischarge: [j Continuous Intermittent
If intermittent:
Days per week discharge ge occ ars: °Duration: A4NAgo a .
9. Describe the treatment systemo
List all installed components, including capacities, provide design rer oval fear BOD, TSS, nitrogen and
s. if the space provided is not sufficient, attach the description of the treatment system in. a
separate sheet of paper. rC- M Cot,45%5TSt o s. i �a co TA oA k. ect rl c <
m -Lri5 o L * Rer_!E t Tt' t ..a , f'oova r t r awe' t
gig
C 't $t 6t tm i a S ate`
RODS m6tL
WAS
e .s w rs
f 3 Form-D 9/2313

NPDES APPLICATION T O
For privately -owned treatment s ste s tweeting 00% domestic wastewaters <1.0 MGD
10. Flow Information:
Treatment Plant Design i , :t G
Annual Average daily floes � ... (for the previous 3 ;years)
Maximum daily flow e .r t o ,, ICI (for the previous years)
11. Is this facility located on Indian country?
El Yes No
. Effluent Data
AWWAPPLICANTS: Provide data for the parameters listed. Fecal Coliform, 1 emperature and pH shalt be grab
samples, for all other parameters . 4-ho rr composite sampling shall be used, 3f more than one analysis is reported,
orted,
report daily maximum and monthly averageIf only one analysis is reported, report as daily maximum,
RBIVEWAL APPLICANTS: Provide the highest single reading (Daily Maximum) and Monthly Average over
tl e as 6 man ths jr r pararneters curr ntl in our errnit: Mark. others ararr eter "NIA"
Parameter Daily Monthly Units of
Maximum A era e Measurement
t
Biochemical Oxygen Demand B D,5)
Fecal Coliform
Total Suspended Solids W r'
Temperature (Summer)
Temperature (Winter)
toll m
F,
13. List all permits, construction approvals and/or applications:
Type Permit Number Type Permit as ber
Hazardous Waste (RCl2A) NESHAPS (C
UIC (SDWA) Ocean Dumping (MPRSA)
NPDES Dredge or fill (Section 404 or MVA)
PSD (CAA) Other
Non -attainment program (CAA)
14. APPLICANT CERTIFICATION
I; certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate
t e
Printed name of Person Signing 'Title
.�
Signature of Applicant Date
North Carolina general Statute 14 - 1 , (b)() states; Any person who knowingly makes any false statement representation, or certification in any
application, record, report, plan, or other document tiles 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
required 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 $ 5,000 or imprisonment not more than 5 years, or both, for a similar offense:)
3 of 3 Form-D 9/2013

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Longitude: Sd 59'27'"
Location
Quad: F15SW 1 Mountain Island Lake
Receiving Streams Unnamed Tr'sbutaty Gough Eton, Inc.
to the Catawba River Mecklenburg Count
Stre tnz Class: WS_lV B C Y North Subbasui: 030834 dot to Scale
F

Allocco. Marcia
From: Steven Lambert <rnslambert@yaf
Seat.Tuesday, March 10 2015 :39 PM
To: Allocco, Marcia
Cc: [e-mail] ;
Subject: Fecal Coliform Feb:, 2015 Cough
ltel.net>
'con, Inc. NCO05808
,vill show a violation of the Maximum Day limit of
Fecal o orm. ;
The value reported by the laboratory was 2200. An immediate fo
c1. With the number of Fecal Coliform 'results available for the su
February for the monthly limit.
e have reviewed both the sampling method and disinfection pars
result.
ie up at another facility under our care, seems to
sure of this. I am sure they will be more careful with
this procedure.
z

W400 Ink
North Carolina Department of nviron ent and Natural Resources
Pat McCrory Mahn E, Skvarla, III
Governor Secretary
October 2, 2014
508:3
Mr. [avid Risley
Cough Econ, Inc.700 N. Tryon St. Suite 205
P.C.Q. Box 66858:
Charlotte, NC 28266
Subject; North Carolina Wastewater/Groundwater Laboratory Certification (Nip /G LC)
Maintenance Inspection
Dear Mr, Risley;
Enclosed is a report for the inspection performed on September 16, 2014 by Gary Francis and
Beth Swanson. Where finding(s) are cited in this report, a response is required Within thirty days
of receipt, please supply this office with a written item for item description of how these finding(s)
were corrected. If the finding() cited in the enclosed report are not corrected, enforcement actions
may be recommended. For certification maintenance, your laboratory mast continue to carry out
the requirements set forth in 15A NCAC; 2H .0800.
Copies of the checklists completed during the inspection may be requested from this office. Thank'
you for your cooperation during the inspection, If you wish to obtain an electronic gppy of this
ftppA by email or if you have questions or need additional information, please contact us at 828)'
206-4677.
Sincerely,
621
61Y.."
Gary`8rancies, Technical Assistance/C;ompliance'Specialist
Division of Water Resources
Attachment
cc,. Seth Swanson
Master File
Water Sciences Section
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Ra#e h, North Carolina 7699.1623
Location. 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] t FAX: [phone],
interret: .d faboro
An Equal Opportunity t Affirmative Actuon Ernp#ices

t
LABORATORY NAME:
NS PERMIT
ADDRESS:
On -Site Inspection Report
Gough Econ„ Inc.
NCO058084
P.O. Box 668583
Charlotte, NC 28266
CERTIFICATE # 508
DATE OF INSPECTION: September 16, 2014
TYPE OF INSPECTION: Field Maintenance
A DITGR( ). Beth Swanson and Gary Francies
LOCAL PERSON(S)CONTACTED: Steven Lambert and David Risley
1. INTRODUCTION:
This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater
Laboratory Certification (NC /CAW LC) program to verify its compliance with the requirements of 15A
NCAC 2H .0800 for the analysis of environmental samples.
11. GENERAL COMMENTS:
The field analyses for this industrial facility are conducted in situ or in a weather-protectedbox.
Contracted analyses are conducted by Statesville Analytical (Certification #440). Current quality
assurance policies for Field Laboratories and; approved procedures for the analysis of the facility's
currently certified parameters were provided at the time of the inspection. Proficiency Testing' (PT)
samples have been completed for 2014„ but this office is awaiting a Corrective Action Report (CAR) for
an unacceptable pH PT sample. The lab is reminded that this is due in our office by November 11, 2014.
A CAR guidance letter was provided at the time of the inspection.
Ill. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS:
Documentation
A. Finding. Error corrections; are not performed properly.
Requirement. All documentation errors must' be corrected by drawing;a single line through the
error so that the original entry remains legible. Entries shall not be obliterated by erasures or
markings. Wite-OutC , correction tape or similar products designed to obliterate documentation
are not to be used. Write the correction adjacent to the error. The correction must be initialed
by the responsible individual and the date of change documented. All data and log entries must
be written in indelible ink. Pencil entries are not acceptable. Ref: Quality Assurance Policies for
Field Laboratories.
Comment: Error corrections were made with a single line and initials, but no date.

Page 2
50 3 Gough Econ, Inc.
B. Finding:: The laboratory needs to increase the documentation of purchased materials and
reagents, as well as documentation of standards and reagents papered in the laboratory.
Requirement All chemicals, reagents, standards and consumables used by the laboratory
must have the following information documented: Date Received, Date Opened (in use),
Vendor; Lot Number, and Expiration Date. This information must be retained for chemicals,
reagents, standards and consurnables used for a period of five years. Consumable materials
such as pH buffers and lots of pre -made standards are included in this requirement. Ref.
Quality Assurance Policies for Field Laboratories.
Comment: Only pH buffer lot numbers were recorded for traceability. Total Residue Chlorine
standards are prepared when the annual standard curve is verified and traceability is lacking for
them and the Gel standard used for the daily quality control standard.
Quality Control
C. Finding: The auto-pipettors have not been calibrated annually as required.
Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fisted and adjustable auto-
pipettors, bottle -top dispensers, etc.), used for critical measurements, must be calibrated at
least every twelve months and documented. Each liquid -dispensing device must meet the
manufacturer's statement of accuracy. For variable volume devices used at more than one
setting, check the accuracy at the maximum, middle and minimum values. Testing at more than
three volumes is optional. When a device capable of variable settings is dedicated to dispense
a single specific volume, calibration is required at that setting only. Ref: Quality Assurance
Policies for Field Laboratories.
Comment: Replacing the auto-pipettor with fined volume volumetric pipets would be an option
to meet this requirement and avoid having to calibrate the auto-pipettor.
Proficient iestin
D. Finding. The preparation of Proficiency Testing (PT) samples is not documented.
Requirement. PT samples received as ampules must be diluted according to the PT provider's
instructions. The preparation of PT samples must be documented in a traceable log or other
traceable format. The diluted PT sample becomes a"routine environmental sample and is added'
to a routine sample; batch for analysis. Ref: Proficiency Testing Requirements, February 20,'
2012, Revision 1.2:
Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual
Chlorine PT would satisfy the documentation requirement:
E. Finding. The laboratory is not documenting Proficiency Testing (PT)' sample analyses in the
same manner as environmental samples.
Requirement: All PT sample analyses must be recorded in the daily analysisrecords as for any
environmental sample. This serves as the permanent laboratory record. Ref; Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results, therefore, PT samples must be analyzed and
the process documented in the same manner as environmental samples.

Page
#5083 Cough Econ, Inc.
Total Residual Chlorine - Standard Methods 4500 Ct -2000
F. Finding: The laboratory is not analyzing a reagent blank with the standard curve verification.
Requirement: Reagent dank: A reagent blank (sometimes also referred to as a method
blank) is only required when laboratory water is used to make quality control and/or calibration
standards. If you are using a sealed standard (e.., gel) for your daily check standard, a
reagent blank would only be analyzed when preparing the annual 5-point calibration curve or 5
annual calibration curve verification standards. Ref:NC WW/GW LC Approved Procedure for
the Analysis of Total Residual Chlorine.
Comment: A reagent blank is made from the same laboratory water source used to make
quality control and/or calibration standards with DPD The concentration of reagent blanks must
not exceed 5 % of the reporting limit (i.e., the lowest calibration or calibration verification
standard concentration), unless otherwise specified by the reference method, or corrective
action must be taken.
G. Finding: All original records were not on file.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref. 15
NC;AC 02H .0805 (g) (1)
Comment: The laboratory does not have records for annual verification of the curve for the
past five years. Documentation was found for curve verifications in'2014, 2012 2011, and
2000.
H. Finding: The laboratory is not verifying the GeI8 Standard every 12 months.
Requirement: Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily
standard curve verification only. These standards must be verified initially and every 12 months
thereafter, with the standard curve. When this is done, these standards may be used after the
manufacturer's expiration date. It is only necessary to verify the gel or sealed liquid standard
which falls within the concentration range of the curve used to measure sample concentrations.
For example, if you are measuring samples against a low range curve, a 200 µg/L standard
would be verified, and not the 80 [tg/L standard since the 800 standard would be measured
using a high range curve. Ref: Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The value of the Gel@) standard obtained at the time of the 5 point: verification, will be
the "true value" used throughout the year and until a new curve is verified.
1. Finding: The gel standard is not within the verified portion of the standard curve.
Requirement: The concentrations of the calibration standards must bracket the concentrations
of the samples analyzed. One of the standards must have a concentration equal to or below the
lower reporting concentration for Total Residual Chlorine. The lower reporting limit must be less
than or equal to the permit limit. 'Ref: NC /GW LC Approved Procedure for the Analysis of
Total Residual' Chlorine.
Recommendation: The maximum concentration analyzed for the annual curve verification was
80 pg/L. It is recommended that the laboratory verify the internal calibration using the following
concentrations: 15, 30, 50, 200 and 400 pg/L. This will verify the analytical range used to measure
the gel standard as well as the Proficiency Testing (T) samples (s cited in Finding J).

a
Page 4
##5083 Gough Econ, Inc:
J. Finding: The annual calibration curve verification does not bracket the concentration of the
annual Proficiency Testing (PT) samples.
Requirement: The concentrations of the calibration standards must bracket the concentrations
of the samples analyzed. One of the standards must have s concentration equal to or below the
lower reporting 'concentration for Total Residual Chlorine. The lower reporting limit must be less
than or equal to the permit limit. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Total Residual Chlorine.
Comment: The true value of the PT analyzed this year,; from ERA Study WP-233, was 202
lag/L; a value greater than the highest concentration calibration verification standard. Expanding
the calibration verification to 400 pg/L will eliminate the need for sample dilution and lessen the
chance of a dilution error.
K. ` Finding: Values less than the established reporting limit are being reported' on the Discharge
Monitoring Report (CAR).
Requirement: The concentrations of the calibration standards must bracket the concentrations of
the samples analyzed. One of the standards must have a concentration e ual to or below the
lower revortina concentration for Total Residual Chlorine. The lower relaortinq limit must be less
than ore ul to the permit limit. Ref: N /W LC Approved Procedure for the Analysis of
Total Residual Chlorine.
Comment: The laboratorycurrently has established a lower reporting limit of 15 pg/L by having
verified that " concentration when verifying the latest calibration curve. Values with
concentrations less than that must be reported as c 15 p/L on the DMR.
L. Finding: The calibration curve is not verified each day of sample analysis.
Requirement:` When a five -standard annual standard curve verification is used, the laboratory
must check the calibration curve` each analysis day. To do this, the laboratory must analyze a
calibration blank to zero the instrument and analyze a check standard each day that samples
are analyzed. The value obtained for the check standard must read within 10% of the true value
of the check standard. If the obtained value is outside of the 10% range, corrective action
must be taken. Ref: 'N /GW LC Approved Procedure for the Analysis of Total Residual
Chlorine.
Comment: The laboratory was analyzing the Gel standard on program 80 high ;range Total
Residual Chlorine '(TRC) and documenting` the value with process control samples. No
documentation was on file showing the Gel standard is analyzed on program 86, low level TRC,
which is the program used for compliance monitoring samples:
Temperature - Standard Methods 255E -2000
Dissolved Yd n - Standard Methods 4500 0 G-2001
Comment: Collection and analysis time needs to be more clearly defined for Temperature and
Dissolved Oxygen (DO). It appears that these two parameters are not meeting the regulatory hold time
since there is a separate collection and analysis time, even though the samples are analyzed its situ.
The laboratory may record one time for these analyses on the field sheet and notate that it is both
collection/analysis time.

Page
#583 Gough 5con, Inc.
Dissolved pKy_ en -- Standard Methods 4500 0 -2001
Standard Methods 4500 H+ -2000
Total Residual Chlorine - Standard Methods 4500 Cl G-2000
M. Finding: The laboratory benchsheet was lacking pertinent data: Instrument identification.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument Identification. Ref: NC WW/GW LC Approved Procedure for the Analysis
of Total Residual Chlorine, NC /GW LC Approved Procedure for the Analysis of Dissolved
Oxygen, NC WW/GW LC Approved Procedure for the Analysis of pH.
H — Standard Methods 4500 + - 00
Comment: The pH calibration documentation does not clearly state that the 7 s.u, buffer is used only
as a check buffer. It appears the analyst is performing a 3 point calibration, when it is actually a 2 point
calibration. A two point calibration is acceptable, but needs to be clarified on the log.
N. Finding:: All original records were not on file.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC
H .0805 (g) (1)�
Comment: Data omission, as noted in the Paper Trail section of this report, can be perceived as
falsification of data.
Temperature — Standard Methods 2550 -200
Q. Finding: The lab could not supply documentation for 5 years of annual thermometer calibration
checks,
Requirement: All thermometers and temperature measuring devices must be checked every
12 months against a National Institute of Standards, and Technology (MIST) traceable
thermometer. Ref: N /GW LC Approved Procedure for the Analysis of Temperature.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NAC 01-1.005 (g) (1).
Comment: Annual thermometer verification is performed by Statesville Analytical; however,
only documentation from 2014 and 2011 could be found from the last 5 years.
P. Findings: The temperature correction has not been posted nor applied to temperature readings.
Requirement: The following must be documented in indelible ink whenever sample analysis i
performed. 7. The temperature correction (even if it is zero) must be posted on the meter as
well as in hard copy format (to be retained for five years). Ref: NC WW/GW LC Approved'
Procedure for the Analysis of Temperature.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed. 5. Document sample temperature measurements with any applicable temperature
corrections applied. Ref: NC /GW LC Approved Procedure for the Analysis of Temperature.

Page
##5083 Gough Econ, Inc.
Q. Finding: The thermometer readings varied more than 10from the NIST traceable
thermometer reading.
Requirement: All thermometers and temperature measuring devices must be checked every
12 months against a National Institute of Standards and Technology (NIST) traceable
thermometer. The process must be documented and proper corrections made to all compliance
data. To check a thermometer or the temperature sensor of a meter, read the temperature of
the thermometer/meter against a MIST traceable thermometer and record the two
temperatures. The verification must be performed in the approximate range of the sample
temperatures measured, The thermometer/meter readings must be leas than or eual to 1"C
from the NIST traceable thermometer readin . The documentation must include the serial
number of the NIST traceable thermometer that was used in comparison. Also document any
correction that applies on both the thermometer/meter and on a separate sheet to be filed.
(NOTE: Other certified laboratories may provide assistance in meeting this requirement)`, Ref:
NC 1GW LC Approved Procedure for the Analysis of Temperature.
R. Finding: Thermometer increments are larger than allowed by the Approved Procedure when
reporting data to 10 C.
Requirement: The number of decimal places that the measurement is reported to will determine
the degree increments required for the measuring device. Standard Methods 2501- 2000 states
that the thermometer should have a scale indicated for every 0.1 °. This is required for all
measurements performed to tenth degree increments. (e.g., 24.70l). If measurements are
re` orted in whole numbers tem eratre measurina device havina a scale indicated fqLtyery
10C is adee uete (e.g., 22" ). Ref: NC ICW LC Approved' Procedure for the Analysis of
Temperature.
Recommendation: Currently, the laboratory is using a thermometer that is graduated in 2°
Fahrenheit increments. This thermometer was accidently ordered instead of the usual
thermometers in degree centigrade increments. It is recommended that the facility put into use a
Celsius thermometer with no greater than VC increments.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records and contract lab reports to DMRs submitted
to the North Carolina Division of Water Resources. Data were reviewed for NPDES permit #;
NC 058084 for February, May, and June, 2014. The following errors were noted:
Date Parameter Location on Value on Benchsheet Value on DMR
6/10/14 pH Effluent *No value 6.8 s.u.
*See Finding N above.
Can June 12 and 1 : The benchsheet and flow log, on June 12 documented readings of 260C and 13 pg/L
TRC and a flow value. There was no flow, temperature, or TRC data documented on ;June 13. The DMR
had the data entered on June 13, so the dates were switched on the DMR.

Page
# 083 hough Econ, Inc.
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of
this report will be made available to the Regional Office,
V. CONCLUSIONS:
Correcting the above -cited findings and implementing the recommendations will help this lab to produce
quality data and meet certification requirements. The supervisor was very proactive during the inspection
in comingup with ideas to improve record retention. The inspectors would like to thank the staff for its
assistance during the inspection and data review process, Please respond to all findings.
Report prepared by: Beth Swanson Date: September 24, 2014
Report reviewed' by: Gary Francies mate: September 25, 32014

Bell. Wes;
From STE`EN LEE LAMBERT [mslambertayadtel.net]
Sent: Tuesday, August 12, 2014 1:10 P
To: Bell, Wes
Subject: GOUGH ECON, INC. NCO0580 4 AMMONIA NONCOMPLIANCE
PER OUR RECENT CONVERSATION THE FOLOWING IS OFFERED FOR CONSIDERATION ON THIS
SUBJECT:
SAMPLE TAKEN ON 7/7/14 YIELDED A RESULT OF 87 MG/L.
WITH TWICE MONTHLY SAMPLING THIS WILL RESULT IN MONTHLY NONCOMPLIANCE FOR.
SUMMER LIMITS ON AMMONIA NITROGEN.
PREVIOUS SAMPLING, FACILITY DEFICIENCIES IN THE RECIRCULATION DISTRIBUTION
HEADERS WAS ADDRESSED AND WERE PROMPTLY CORRECTED.
INDICATION BY FIELD SAMPLING FOR AMMONIA INDICATED A ROUNDED FIGURE OF 1.2
MG/L. THIS IS THE FIRST TIME SUCH A VARIANCE IN OUR RESULTS AND THE LAB RESULTS
HAS OCCURRED.
AS REQUESTED, THE LAB CHECKED ITS RECORD OF ANALYSIS AND FOUND NO DEFICIENCIES
IN METHOD OR CALCULATION
RESPECTFULLY SUBMITTED,
STEVEN LAMBERT, ORC

Ar*A FILE
WCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E Skvarl , III
Governor Secretary
July 15, 2014
Mr. David Risley, President and CEO
Gough Bcon, Inc.
P.O. Box 668583
Charlotte, North Carolina 28266-858
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking : NOV-2014-LV-0264
Gough Egon WWTP
PQES Permit No. NCO058084
Mecklenburg County
Dear Mr. Risley:
Mooresville Regional office staff reviewed the information Gough Econ, Inc. and its representatives have
provided regarding the violations noted on the January 2014 Discharge Monitoring Report as noted in the
Notice of Violation and Notice of Recommendation for Enforcement NOV-2014-L.V- 264 sent to you o
June 16, 2014. Based upon the review, mitigating circumstances were found that would justify no further
action being taken against Gough Egon, Inc. at this time for the noted permit violations. Be advised that
should noncompliance continue, enforcement action, including the assessment of civil penalties, could be
taken by the Division of Water Resources in accordance with G.S. 143Y215. A(a)().
Thank you for your continued cooperation with the Division of Water Resources. Should you have any
questions regarding the decision by this office in regards to this matter please contact Ms. Marcia Allocco
or myself at [phone].
Sincerely,
Michael L. Parker, Regional supervisor
Water {duality Regional Operations Section
Division of Water Resources, NCDENR'
cc: Wastewater Branch
MSC 1617 Central Files Basement
Mooresville Regional Office
Location:: 610 East Center Ave„ Suite 301 Mooresville, NC 28115
Phone: [phone] ! Fax: [phone] Customer Service, 1-877.623-6748
Internet: hft J/ `rtar.ncdenr,o lwebtw

FILE 110-Al
irCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarl, ill
Governor Secretary
June 16, 2014
CERTIFIED AIL #7010 1870 0001 1558 1283
RETURN RECEIPT REQUESTED
Mr. David Risley, President and CEO
Gough Econ, Inc
P. C. Box 668583
Charlotte, North Carolina 28266-85 3
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tacking .ITV-2014-LV-0264
Gough Egon WWTP
NPDES Permit No. NCO0580 4
Mecklenburg County
Clear Mr. Risley.
A review of the January 2014 self -monitoring report for the subject facility revealed violations of the
following parameters at Outfall 001:
Late Parameter Reported Value Permit Limit
1/29114 Fecal coliform 410 CFU/100 mL 400 CFU/100 mL (Daily maximum)
1131/14 Ammonia 6.8 rng/L 4.0 m /L (Monthly average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOWNRE) is being issued
for the noted violations of North Carolina General Statute (G. .) 143-215.1 and NPDES Permit No.
NCO058084. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand
dollars (25,000.00) may be assessed against any person who violates or fails to act in accordance
with the terms, conditions, or requirements of any permit issued pursuant to G.S.; 14-215+.1.
If you wish to provide additional information regarding the noted violations, request technical
assistance, or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with any information provided on the
January 2014 Discharge Monitoring Report and subsequent correspondence with this office by your
ORC, You will then be notified of any civil penalties that may be assessed regarding these
violations. If no response is received in this Office within the 10-day period, a civil penalty
assessment may be prepared.
Remedial actions, if not already implemented, should be taken to correct any problems. The Division
of Water Resources may pursue enforcement actions for this and any additional violations. If the
violations are of a continuing nature, not related to operation and/or maintenance problems, and you
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] i Fax: [phone] i Customer Service:1-877-623-6743
Internet: hftp,l/portal.ncdenr.org/Weblwq
An Equat Opportunity � Affirrnative Action Employer - 30% RecyctecU10% Posi Consumer paper

# RPM ! 211219
1MUE-WR
g
North Carolina Department of Environment and Natural Resources '3
Division of Water Resources
Water Quality Regional Operations Section
Pat McCrory Thomas A. feeder John E. Skvarla III
Governor [director Secretary
December 13, 2113
CERTIFIED MAID #7010 1870 0001 1558 1412
RETURN RECEIPT REQUESTED
Mr. David Risley, President and CEO
Gough Econ, Inc.
P.O. Box 666583
Charlotte, North Carolina 26266-6563
Subject. Notice of Violation and Notice of Recommendation for Enforcement
Tracking #: N{ V-2013-LV-0730
Gough Edon VVWTP
N DES Permit No. NCO058084
Mecklenburg County
Dear Mr. Risley:
A review of the September 2013 self -monitoring report for the subject facility revealed violations of the
following parameters at Outfall 001:
Cate Parameter a noted Value Permit Limit
9110/13 Fecal coliform 415 CFUI100 mt_ 400 CFU/100 mL (Daily maximum)
9/10/13 Ammonia 15. grL 10.0 mg1L (Gaily maximum)
9f30113 Ammonia 8.0 mg1L 2.0 mg1L (Monthly average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violations of North Carolina General Statute (G.S.) 14 -215.1 and NPDES Permit No.
NC0051 064. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand
dollars ($25000.00) may be assessed against any person who violates or fails to act in accordance
with the terms, conditions, or requirements of any permit issued pursuant to C.S. 143-215.1.
If you wish to provide additional information regarding the noted violations, request technical
assistance, or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with the information provided on the
September 2013 Discharge Monitoring Report. You will then be notified of any civil penalties that
may be assessed regarding these violations. If no response is received in this Office within the
10-day period, a civil penalty assessment may be prepared.
Mooresville regional Office
Location; 610 East center Ave.. Suite 301 Mooresville, NC 28115 One�+
Phone: [phone] Fax l704) 6 3-60401 Customer Service: 1-877-6 3-674 C th c a
Internet: hftp://portal,nedenr.org/webtwq
An Equal Opportunity ° Affirmative Action Employer - 30R ttecycied,10% Pont Conoumer paper NahmallY

PAilocco, Marcia
From: Martha <[e-mail]>
Sent: Wednesday, October 30, 201.3 733 AM
To: ' Allocco, Marcia
Subject; NCO058084 Cough Econ,-Inc.-Fecal Coliform and Ammonia Noncompliance
Ms. Allocco:
Fecal Coliform.
On an effluent sample taken on September 10, 2013 the result was 41 C/100 mi, This exceeds the Maximum
Gaily Limit of 400 C/100 mi. The contract laboratory notified us on the next clay of the result, A follow-up sample on
September 12, 2013 yielded a result of <1 count. The last sample of the month also }yielded a result of <1 count. Field
testing of the chlorine contact chamber TRC showed ample chlorine to insure disinfection. The last sample of the month
shows a result of <0.5 mg/L.
Ammonia N;
The September 10 sample yielded a result of 15.9 mg/L, exceeding the Maximum Gay Limit of 10.0 mg/L and
causing the monthly limit of 2.0 mg/L to be exceeded. Field Ammonia N testing on the same date indicated a result of 1,15
mg/L.
Speculation as to Cause:
Previous to sampling filter bed maintenance was performed, including clearing of surface debris, algae scum and
vegetation. Deep raking of compacted sand was performed also. The disturbance of the bed likely caused temporary
disruption of treatment and/or release of contained ammonia and an increase of fecal discharge to the disinfection area.
Action Plan:
Rather than wait for lab reports to be mailed, it may be better to call for results as soon as they may be
available. Whatever action that may be necessary to halt further problems could then be implemented in a more timely
manner. Structural maintenance to the filter walls were completed in early October„ 2013 without disruption in treatment
or compliance. tough Econ has always followed a proactive stance to its environmental responsibilities.
Please contact me at 704-657-847 or 704-54-2504 if further information is required.
Thank you,
Steven Lambert, ORC
i

, Marcia
From: Martha <mslambertyadtel.net>
Sent: Saturday, September 14, 2013 1113 P
To: Allocco, Marcia
Cc: 'David P Risley'
Subject: Gough Eco, Inc. NC005884-Fecal Coliform Noncompliance
September 14, 2013
To: Marcia Allocco
Division of Water Quality
From: Steven Lambert, ORC
Gough poor, Inc.
Subject: Fecal Coliform Noncompliance
Cough kern, Inc.
NPDES Permit No, NCO0 8 8
The contract laboratory has informed that a Fecal Coliform sample collected on September 10, 2013 yielded a result of
415 Counts per 100 ml. The chlorine residual in the Chlorine Contact Tank was in excess of 1.0 mg/L and the sample
clarity was good:
A second sample was collected on September 12, 2013 and word on its status has not reached us yet: The laboratory
usually informs us of noncompliant bacteria results. Most likely the result was goad, as no further telephone notifications
were issued:
There was no indication of any contamination in the field and sampling practices have been reviewed. There being no
adverse indicators in the field, the cause for this remains unknown,
e will inform you of any further developments. Should you require further information, contact me at 704--8847.
Thank you,
Steven Lambert

AT4;L.
F I L E;
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water QualityRegional Operations Section
Pat McCrory Thomas A. Reeder John P. Skvada, III
Governor Director Secretary
October 23, 2013
CERTIFIED MAIL #7010 18700001 1558`1344
RETURN RECEIPT REQUESTED
Mr. David Risley, President and CEO
Gough Econ, Inc:
P.O Sox 668583
Charlotte, North Carolina 28266-8583
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking #: NOV-2013-LV-0548
Gough Econ WWTP
NPDES Permit No, NCO058084
Mecklenburg County
Dear Mr, Risley.
A review of the duly 2013 self -monitoring report for the subject facility revealed a'violation of the
following parameter at tutfall 001:
Date Parameter Re carted 11alue Permit Limit
7/31/13 Ammonia 3.14 mg/L 2.0 mg/L (Monthly average)
Notice of Violation and Notice of Recommendation for Enforcement (NOWNIRE) is being issued
for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No.
NCO058084. Pursuant to G.S. 143-215.8A, a civil penalty of not more than twenty-five thousand
dollars ( 25,000. 0) may be assessed against any person who violates or fails to act in accordance
with the terms, conditions, or requirements of any permit issued pursuant to G.S: 143-215A,
If you wish to provide additional information regarding the noted violations, request technical
assistance; or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with the information provided on the
July 2013 Discharge Monitoring Report. You will then be notified of any civil penalties that may be
assessed regarding these violations. If no response is received in this Office within` the 10-day
period, a civil penalty assessment may be prepared.
Remedial actions, if not already implemented, should be taken to correct any problems. The Division
of Water Resources may pursue enforcement actions for this and any additional violations. If the
violations are of a continuing nature, not related to operation and/or maintenance' problems, and you
anticipate remedial construction activities, then you may wish to consider applying for a Special Order
by Consent.
Mooresville Regional Offioe
Location: 619 Past Center Ave., suite 301 Mooresville, NC 28115 One
Phone: [phone] l Fax (7€74) 66 -6040l Customer ervice:1-871623.674E NorthiCarolina
Internet: http:l(portal.ncdenr.orglweb/wq
An Equal Opportunity Affirmative Action Employer - 30% Recyeled,`10% Post Gonsumerpaper Awfirally

.Wr
FIL
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Thomas A. Reeder John E. Skvaria, III
Covemor Acting Director Secretary
June 13, 2013
r. David Risley; President & CEO
Cough Econ, Inc.
Post Office Box 668583
Charlotte, North Carolina 28266-83
SUBJECT: Compliance Evaluation Inspection
Cough Econ, Inc. WWTP
NPDES Permit No. NCO058084
Mecklenburg County, NC
Dear Mr. Risley;
On April 9,2013, Ms. Olivia Edwards 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.
Allow or me at this office.
Sincerely,
for Michael L. Parker
Regional Supervisor
Surface Water Protection
Mooresville Regional Office
Enclosure
cc: Rusty Rozzelle, MCP
Mooresville Regional Office
Location: fit 0 Fast Center Ave., Suite 301, Mooresville, NC 28115 � ��{ �+,
Phone: [phone] Fax: (704) 663a4O t Customer Service: 1-87 i -6748
Internet aterauarkcra

The current permit became effective on November 1, 2010, and expires on June 30, 2015. The permit
properly describes the facility. The facility appears to be adequate for the waste stream being treated. The
0.0012 MGD facility consists of a septic tank, a dosing tank, a surface, sand filter with PVC distribution
manifolds, a recirculation pump, effluent tablet chlorination, effluent tablet dechlorination, and cascade
aeration.
The certification classification for NCO058084 requires that the facility have an operator in responsible
charge (ORC) with a Grade I Biological Water Pollution Control System (WW-1) certification. The facility is
staffed (ORC and back-up) with personnel that possess the appropriate operator certification.
RECORDSIREPORTS:
Discharge Monitoring Reports (DMRs) were reviewed for the period January 2012 through December
2012. The ORC maintains detailed logs and calibration records relative to the operation, maintenance, and
self -monitoring of the facility.
FACILITYSITE REVIEW:
The facility only discharges effluent episodically. At the time of inspection, the facility was discharging. All
existing components of the facility were in service and appeared to be operating properly at the time of the
inspection.
EFFLUENTIRECEIVING WATERS:
The facility discharges to an unnamed tributary to the Catawba Ri ' ver, which is a Class WS-IV, B, and CA
water in the Catawba River Basin, A small amount of effluent was discharging from the facility during the
inspection. The effluent was clear. The receiving water did not appear to be adversely effected by the
effluent.
FLOW MEASUREMENT:
Flow measurement is accomplished by the bucket and stopwatch method when samples are collected,
which is in accordance with NPDES permit requirements.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (DMRs) were reviewed for the period January 2012 through December
2012. The DMRs indicate that the facility was in compliance with permit monitoring requirements and
discharge limits during the review period with the following exception:
NCO058084 requires that the effluent temperature be monitored daily. No temperature reading
was reported for April 2, 2012. A daily maximum effluent Ammonia concentration of 17.1 mg/L
was reported on the April 2012 DMR which exceeded the permit limit of 10.0 mg/L. A monthly
average effluent Ammonia concentration of 8.6 mg/L was reported on the April 2012 DMR which
exceeded the permit limit of 2.0 mg/L. These violations were addressed under separate cover by
the Division of Water Quality through the issuance of a Notice of Violation and Assessment of Civil
Penalty (LM-2012-0022).

P"AA
FILE Z,�
WCBEM"Rm
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Govemor Director Secretary
July 24, 2012
CERTIFIED MAIL #7010 0780 0000 5519 1598
RETURN RECEIPT REQUESTED
Mr. David Risley, President and CEO
Gough Econ, Inc.
P.O. Box 668583
Charlotte, North Carolina 28266-8583
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking #: NOV-2012-LM-0038
Gough Egon VVI
NPDES Permit No. NCO058084
Mecklenburg County
Dear Mr. Risley,�
A review of the April 2012 self -monitoring report for the subject facility revealed violations of the
following parameters at Outfall 001 :
Date Parameter Reoorted Value Permit LimittMonitorinq Requirement
4126/12 Ammonia 17.1 mg/L 10.0 mg/L (Daily maximum)
4/30/12 Ammonia 8.6 mg/L 2.0 mg/L (Monthly average)
4/1-4/7 Temperature 4x/week 5x/I
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and NPIDES Permit No.
K A el A A^ ^A� ^A 1. . — —1� . X,
- —
1wi
N N.M. I im. I ".12111IM 10 1

Allocco, Marcia
From: Martha [[e-mail]]
Sent: Friday, July 27, 2012 7-1 10 AM
To: Allocco, Marcia; 'David Risley'
Subject: FW: Ammonia noncom piance-Gough Econ, Inc., NPDES Permit # NCO058084
To: Marcia Allocco
From-, Steven Lambert, CRC
This is in reply to the Notice of Violation/Recommendation for Enforcement received by our office. The two
concerns were ammonia noncompliance and failure to report a daily effluent temperature.
A check of our records shows a temperature reading on April 2, 2012 was not transferred to the DMR. A corrected
report will be prepared and sent shortly.
We have had infrequent ammonia noncompliance in recent years, and the latest episode was a complete
surprise, This prompted an immediate evaluation of events previous to the sample date to determine a possible cause.
The accompanying Email sent to you on May 16, 2011 explains our findings and our actions to be taken when septic tank
pumping takes place.
Overall compliance for this facility is good. Non compliance is infrequent, usually involving ammonia, Fecal
Coliform noncompliance has occurred, but very rarely.
sis,
Econ has always been cooperative with this operator to the extent of having the sand filter anc
at is more proactive than Gough Econ in this area of concern,
at 704-546-2594 or 704-657-8847 or this Email address. Any further requested information will
led.
May 16, 2012 9:01 PM
I
econ.com'
noncompiance-Gough Econ, Inc., NPDES Permit # NCO058084
i that the April, 2012 [AMR will show this facility to be noncompliant for Ammonia Nitrogen,
is examined by lab personnel confirmed the result.
le collected earlier in the month yielded an result of <0,5 mg/L. This gave us no cause for alarm,
le for the lafter end of April, 2012 yielded a result of 171 mg/L, resulting in a total noncompliance for the
verage for this parameter,

annual pumping of the

0
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor
Director Secretary
March 26, 2012
Mr. David Risley, President & CEO
Gough Econ, Inc.
Post Office Box 668583
Charlotte, North Carolina 28266-8583
SUBJECT-
Compliance Evaluation Inspection
Gough Eon, Inc. WWTP
NPDES Permit No. NCO058084
Mecklenburg County, NC
Dear Mr. Risley.
On February 1, 2012, Mrs. Aliyah Owens 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.
Allocco or me at this office.
Sincerely,
for
Robert B. Krebs
Regional Supervisor
Surface Water Protection
Enclosure
cc- Rusty Rozzelle, MCWQP
looresville Regional Office
ocation: 610 East Center Ave., Suite 301, Mooresville, NC 28115
hone: 663-1699
One
Noith Carolina
(704) k Fax: [phone] Customer Service: 1-877-623-6748
iternet: www.ncwaterquality.org
Na&rally
I Equal Opportunity 1 Affirmative Action Employer — 300% Recycl"I 0% Post Consumer paper

United States Environmental Protection Agency
Form Approved,
EPA Washington, DC 20460
OMB No, 2040-0057
Water Compliance Inspection Report
Approval Expires 8131/98
�y :,k: N 3 at+ Z �+YMsy"k5� ?....,,.y�WY•*,.,+.ry l"y\', " �`5"s.. �?wx �„f`'p +i i �.��'t Ywtl ,..,hs ,av� 23`e "al.".'.tom:,-sn Rk .e � { �`. Y?£.h„'s.rn {. :•tiy.. � L�, n. �'Y.+,�. ��-:.
Transaction ' CodeNPDES Yr/Mo/Day Inspection Type Inspector Facility Type
N 5 NCO058084 12/02/01 S C 2
- Remarks:
Inspector: Mecklenburg County Water Quality Program
Inspection Work bays Facility Self Monitoring Rating B1 '' QA Reserved
1.0 4 N N
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htame and L ovation of Facility Inspected:
Entry Time#Date: Permit''Effetve:
Gough Econ I'P
11�0 AM 02l01/12 1110111'0
400 N L al<ebrook Ri3 SR
Exit TimelDate: Permit Expires:
Mecklenburg County, NC 28214
12.00 PM 02101/12 06/30/15
Name(s) of tin -Site Representatives/Title/Phone Number:
David P. Risley/CEO & President1704-399-2306
Name and Address of Responsible Official:
Title: CEO &President
David P. Risley
PO Box 668583 Phone Number: 704-3 9-2306
Charlotte, NC 28266
Contacted': Yes
,s` \ s; raL kr>}k�.?,h Y", x.. 9..\, ., t ,Y. 'rY`°'
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,�"."'i �k �,A.�`z+:
Y{�. '3 'r7 3k� qS s,�.< + k i' Y,k v3"12'
Permit ® Flow Measurement Operations &'Maintenance Z Sewer Overflow
Records/Reports Z Self -Monitoring' Program Z' Sludge Handling Disposal C] Pollution Prevention
Facility Site Review El Compliance Schedules El Pretreatment Program E] Multimedia
Effluent/Receiving Waters Z Laboratory El Stormwater EJ Other:
^,?^
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,n,^s'` � ael �.���•t2kS;r4R'ch`%{ � L ��v,�w`����L�'� t��t.:. `,��,�''��y;`�`tha
�`nt<<.iL .
See Attached Summary
Signature(s) of Inspector(s): Agency/Office#Telephone: Gate:
AID ah Owens MCWQP1704-336-3982 February 17, 2012
.Signature of wer: -Agency/Office: Date:
_CDENR -- Division of
Water Quality
Mooresville Regional Office March 26, 2012
a

PERMIT:
The current permit became effective on November 1, 2010, and expires on June 30, 2015. The permit
properly describes the facility. The facility appears to be adequate for the waste strum being treated. The
0.0012 MGD facility consists of a septic tank, a dosing tank, a surface, sand filter with PVC distribution
manifolds, a recirculation pump, effluent tablet chlorination, effluent tablet dechlonnation, and cascade
aeration.
The certification classification for NCO05 084 requires that the facility have an operator in responsible
charge (QRC) with a Grade I Biological Dilater Pollution Control System -1) certification. The facility i
staffed ( RC and back-up) with personnel that possess the appropriate operator certification.
RECORDSIREPORTS:
Discharge Monitoring Reports (DMR) were reviewed for the period January 2011 through December
2011, The CRC maintains detailed logs and calibration records relative to the operation, maintenance, and
self -monitoring of the facility.
FACILITY SITE REVIEW:
The facility only; discharges effluent episodically. At the time of inspection, the facility was not discharging.
All lather existing components of the facility were in service and appeared to be operating properly at the
time of the inspection.
EFFLUENT/RECEIVING WATERS:
The facility discharges to an unnamed tributary to the Catawba Diver, which is a Class WS-IV, B, and CA
water in the Catawba River Basin. No effluent was discharging from the facility during the inspection. The
receiving water did not appear to be adversely effected by the effluent.
FLOW MEASUREMENT:
Flow measurement is accomplished by the bucket and stopwatch method when samples are collected,
which is in accordance with NPDES permit requirements. The most recent flow; measurement was
conducted on January, 30, 2012, according to the operator log book.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (CMRs) were reviewed for the period January 2010 through December
2010, The permittee met all limit, monitoring, and reporting requirements during the review period
Records, reports, and logs were clear and well maintained.
LABORATORY:
Gough Econ is certified by the Division of Water Quality to perform field parameter laboratory analyses (NC
Laboratory Certification #50 3 -- temperature, residual chlorine, dissolved oxygen, and pH) and contracts
with Statesville Analytical (NC Laboratory Certification #440) to perform all other analyses specified in the
permit. Statesville Analytical was not evaluated under this inspection. A review of
documentation/instrumentation associated with field parameter laboratory analyses was completed during
the inspection. No deficiencies were found.

OPERATIONS & MAINTENANCE:
The current overall operating strategy of the ORCx appears acceptable for the size and type of 1
SLUDGE HANDLING & DISPOSAL:
An adequate spell response for three spills reaching surface waters should Include an evaluation
downstream of the point at which the spell entered surface waters to determine if a fish kill occurred. The
evaluation should also incline the collection of upstream dissolved oxygen and pH measurements for
background information and dissolved oxygen and pH measurements at multiple points downstream of the
entry point to document any; negative impact. Failure to report the bypass of collection system, pumping
station, or treatment facility subjects violators to penalties of up to $25,000.00 per day per violation.

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue "Teen H. Sullins Dee Freeman
Governor Director Secretary
April 12, 2011
r. David Risley, President & CEO
Gough Bcon, Inc.
Post Office Box 66858
Charlotte, North Carolina 28266-858
SUBJECT: Compliance Evaluation Inspection
Gough Econ, Inc. VVWTP
NPDES Permit No. NCO058084
Mecklenburg County, NC
Dear Mr. Risley;
On March 1, 2011, Mrs. Aliyah Owens of the Mecklenburg County Water Quality Program (MCWt P)
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,
Allocco or me at this office.
Sincerely;
for Robert B. Krebs
Regional Supervisor
Surface Water Protection
Enclosure
cc: Rusty Roelle, MWQP
Mooresville Re0ional Office }il
Location, 6'10 East Center Ave„ Suite 301, Mooresville, NC 28115
Phone: [phone]Fax: [phone] CustomerService: 1-87T623-6748 Northy C roll �c�
w Inte,,net<ww.ncwaterqualit ,org F. t�d(l A

United States Environmental Protection Agency Form Approved.
Washington , DC 20460 � O 1S No, 2040-0067
EPA
Water Compliance Inspection Report Approval Expires 8131198
Section A: National data System Coding
Transaction ode NPOES YriP cir-l`ay Inspection Type Inspector Facility Type
N 8 NCO058084 11/03/01 S
Remarks:
Inspector: Mecklenburg County Water Quality Program
inspection Work Days Facility Self -Monitoring Rating 61 QA Reserved
(} 5 4 N N
Section B: Facility Data . - � ��Name and L ocatlon of Facility Inspected: EntrFig
ermit Effective:
Gough Econ P01:0I01 f069400 N Lakebrook Rd S Exitermit Expires:
Mecklenburg County, NC 81402:13fJ110
Name(s) of On -Site Representatives/Title/Phone Number:
David P. Risley/CEO & resident/704-99-2306
Name and Address of Responsible Official: Title: CEO & President
David P. Risley
PO Box 668683 Phone Number: 704-399-206
Charlotte, NC 28266
Contacted: Yes
'Section +: Areas Evaluated t�uring lrispection ,, ,
� ' Permit � Flow Measurement � Operations & Maintenance � Sewer Overf#ow
� ntion
RecordslReperts {� Self -Monitoring Program � Sludge Handling Dispose# [.� Pollution Preve
Facility Site Review 1] Compliance Schedules El Pretreatment Program E] Multimedia
I"ffluentlReceivingstars Laboratory 0 Stormwater EJ Other:
t ectic n Cs:`Sci rnary;of Fl dings/06mm ots
Sec Attached Summary
Si natures) of Inspector{s): Agency/Office/Telephone: bate:
All ah Ovum MC QPI704- 6- 98 March 0, 2011
nature of Revie r: ncytC}ffice: Date:
NR — Division of Water Quality
Marcie Allocco Surface Water Protection -- Mooresville Regional Office April 12, 011
EPA Form 3560- (Rev 9-94) Previous editions are obsolete

FPERMIT:
The current pens -nit became effective on November 1. 2010, and expires on June 30, 2015. The permit
properly describes the facility. The facility appears to be adequate for the waste stream being treated. The
0.0012 _1v1GD facility consists of a septic tank, a dosing tank. a surface sand filter with PVC distribution
manifolds, a recirculation pump, effluent tablet chlorination, effluent tablet dechlorination and cascade
aeration.
The certification classification for NCO0580 4 requires that the facility have an operator in responsible
charge (ORC) with a Grade I Biological Water Pollution Control System (W W-1) certification. The facility
is staffed. (ORC and back-up)with personnel that possess the appropriate operator certification.
RECORDS/REPORTS:
Discharge Monitoring Reports (DMRs) were reviewed for the period January 2010 through December 2010.
The ORC maintains detailed logs and calibration records relative to the operation, maintenance, and self -
monitoring of the facility.
FACILITY SITE VIEW:
The facility only discharges effluent episodically. At the time of inspection, the facility was not
discharging. All outer existing components of the facility were in service and appeared to be operating
properly at the time of the inspection.
EFFLUENT/RECEIVING WATERS.
The facility discharges to an unnamed tributary to the Catawba River, which is a Class WS-IV, B and CA
water in the Catawba River Basin. No effluent was discharging from the facility during the inspection. The
receiving water did not appear to be adversely effected by the effluent.
FLOW MEASURE MENT: ,
Flow measurement is accomplished by the bucket and stopwatch method when samples are collected which
is in accordance with NPdES permit requirements.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (DMRs) were reviewed for the period January 2010 through December 2010
Records, reports, and logs were clear and well maintained. The DMRs indicate that the facility was in
compliance with permit monitoring requirements and discharge limits during the review period with the
following exceptions:
• A monthly average effluent ammonia -nitrogen concentration of 4.65 mgiL was reported on the
December 2010 DMR (calculated value should be 4.5 m tL based on two reported values during the
month), which exceeded the permit limit of4.0 mg/L. This violation was addressed under separate
cover by the Division of Water Quality through the issuance of a Notice of Violation (NOV— 01 I-
LV-0103).
• NCO058084 requires that the effluent temperature be monitored daily. No temperature readings

were reported for March I st, 10th, or-222nd 2010, resulting in monitoring violations in the Division
of Water Quality compliance database, The perm ittee and their designated ORC must ensure that
either a temperature readina is noted daily on, the monthly DMR or zero flow is recorded signifying
a discharge did not occur on the day in question.
Z:7 I
LABORATORY:
Gough Econ is certified by the Division of Water Quality to pertor-rn field parameter laboratory analyses
(NC Laboratory Certification',11,5083 - temperature, residual chlorine, dissolved oxygen, and pH" and
contracts with Statesville Analytical (NC Laboratory Certification #440) to perform all other analyses
specified in the permit. Statesville Analytical was not evaluated under this inspection. A review of
documentation/instrumentation associated with field parameter laboratory analyses was completed during
the inspection. No deficiencies were found.
OPERATIONS & MAINTENANCE:
The current overall operating strategy of the ORC appears acceptable for the size and type of the facility.
SLUDGE HANDLING & DISPOSAL:
Sludge removal is performed by Liquid Waste on an annual basis. Liquid Waste was not evaluated under
this inspection.
SEWER OVERFLOW:
Please be advised
+11aL pursuant to Part TT Section E of your NPDES permit and North Carolina
-
Administrative Code (NCAC) 15A 2B .0506 (a)(2), any failure of a collection system, put
treatment facility resulting in a bypass without treatment of all or any portion of the waste
reported to the appropriate regional office (Mooresville Regional Office 704/663-1699) a=
1-
but no later than 24 hours from the time the permittee became aware of the bypass. For sl
which occur in Mecklenburg County, it is requested that MCWQP be notified at 704/3-3 )6-
I-, A 1, 1-1 r, can be re orted by calling the North Carolina Divisior
)r
occurring on wee en 3 or v r u,,
Management at [phone]-
A written report shall also be provided within five (5) days of the time of the incident. The report shall
contain a description of the bypass, and its cause; the period of the bypass, including exact dates and times,
and if the bypass has not been corrected, the anticipated time it is expected to continue; and the steps taken
(or planned) to reduce, eliminate, and prevent recurrence of the similar events. Any spill that reaches
surface waters (i.e. any spill that reaches any water already present in a conveyance, stream, ditch, etc.:.) or
any spill greater than 1,000 gallons on the ground that does not reach surface waters must be reported.
An adequate spill response for those spills reaching surface waters should include an evaluation downstream
of the point at which the spill entered surface waters to determine if a fish kill occurred. The evaluation
should also include the collection of upstrearn dissolved oxygen and pH measurements for background
information and dissolved oxygen and pH measurements ,It multiple points downstrearn of the entry point to
document any negative impact. Failure to report the bypass of collection system, pumping station, or
treatment facility subjects violators to penalties of tip to $25,000.00 per day per violation.

f
*A
irCDEH-R
North Carolina Department of Environment and Natural Resource�
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins lee Freeman
Governer Director Secretary
March I5, 2011 ,
Mr. David Risley
Gough Econ, Inc,
Pot Office Boy 66858
Charlotte, North Carolina 28266
Subject: Notice of "Violation -- Effluent Limitations
Wracking : N?'V-2011-LV-010
Gough Econ W WTI'
NPDES Permit No. NCO05 0 1
Mecklenburg County
Clear Mr. Risley:
A review of the December 2010 self -monitoring report for the subject facility revealed a violation of the
following parameter at Outfall 001
Date Parameter Reported Value Permit Limit
December 20I0 Ammonia Nitrogen 4.5 mg/l 4.0 mg/1 (monthly average)
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 of
a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial
construction activities, then you may wish to consider applying for a Special Order by Consent. You may
contact John Lesley of this Office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Mr. Lesley or me at (704)
66-16q.
Sincerely;
Robert B. Krebs
Surface Water Protection
Regional Supervisor
cc: Point Source Branch
Jt
Mooresville Regional Office
Evocation` 610 East Center Ave.; Suite 301 Mooresville, NC 25115 1��One
Rhone. (704) 66.,-1699 \ Fax. [phone] t Customer Service: 1-87t-623-6746 1 � 6'tf1 Caro l nc
Internet: ww+w.ncvvatenqualnt ,or
An, Equal CsPortuiltY \ Atrmawe Adian Erto asr - 30% Rec ded/10% Post consumer Pape,

pp"PPOP NCDENR"""'
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Paves Perdue Coleen H. Sullins Dee Freeman
Governer Director Secretary
January 14, 2009
Mr. David Risley, President & CEO
Clough Ec n, Inc,.
Post Office Boy 66858
Charlotte, North Carolina 28266-8583
SUBJECT- Compliance Evaluation Inspection
Gough Icon, Inc'. WWTP
NPD S Permit No. NC058084
Mecklenburg County, NC
Dear Mr. Risley. -
On December 8, 2009, Mrs. Olivia Edwards 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.
Allocco or me at this office.
Sincerely,
}
for Robert B. Krebs
Regional Supervisor
Surface Water Protection
Enclosure
cc; ;Rusty Rozzelle, MCWQP
RBK/oje
Mooresville Regional Office One
)' Mooresville, NC 28115 N
orthCai
,040'3ustomef Service: 1-77-623-748
'Allattin
52ni�ar _:it?�a Ps*rurdAriMn�% Prsf ;"`.nnsitmt viiAnp'r

Econ, Inc.
aspection, Page 2
United States Environmental Protection Agency Form Approved.
Washington, DC 20460 OMB No. 2040-C
NCO058084 09/12/08 S C
Remarks:
Inspector: Mecklenburg County Water Quality Program
Facility Self -Monitoring Rating B1 CA Reser
A 1\1 N
Gough Econ WWTP 02:00 PM 12/8/09 09/011c,
9400 IN Lakebrook Rd SR Exit Time/Date: Permit
Mecklenburg County, NC 28214
3:00 PM 12/8/09 06/30/1
Name(s) of On -Site RepresentativeslTitle/Phone Number:
David P. Risley/CEO & President/704-399-2306
CEO
T
Name and Address of Responsible Official- Title:
: & Pr'
Title: CEO & President
David P. Risley
PO Box 668583 Phone Number: 704-399-2306
Charlotte, NC 28266
Contacted:
tac Y
ontacted: Yes
Permit
Z RecordslReports
Facility Site Review
Effluent/Receiving Waters Z
Flow Measurement Operations& Maintenance
Self -Monitoring Program Sludge Handling Disposal
Compliance Schedules El Pretreatment Program
Laboratory El Stormwater
Sewer Overflow
El Pollution Prevention
0 Multimedia
0 Other:
See Attached Summary
Signature(s) of Inspector(s):
Age ncylOfficelTeleph one:
Date:
Olivia J. Edwards
MCWQP/704-336-4761
January 13, 2009
4=1
g.,natore of Review Agency/Office:
Division of Water Quality
Dat
Marct Allocco
Surf eVVater Protection —Mooresville Regional Office
January 14, 2010
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete

Compliance Pavid R7isley, Gough Econ, Inc.
'o'gl 'I-Y'(7 E
Evaluation Inspection, Page 3
Januar�y 14,2010
GENERAL:
Mr. Wes Bell of the Mooresville Regional Office last inspected the facility on November 20, 2008. A
Compliance Evaluation Inspection report was issued on November 25, 2008.
PERMIT:
The current permit became effective on September 1, 2006, and expires on June 30, 2010, The permit
properly describes the facility. The facility appears to be adequate for the waste stream being treated. The
0.001 MGD facility consists of a septic tank-, a dosing tank, a surface sand filter with PVC distribution
manifolds, a recirculation pump, effluent tablet chlorination, effluent tablet dechlorination, and cascade
aeration. The certification classification for NCO058084 requires that the facility have an operator in
responsible charge (ORC) with a Grade I Biological Water Pollution Control System (WW-1) certification.
The facilit, y is staffed (ORC and back-up) with personnel that possess the appropriate operator certification.
RECORDS/REPORTS:
Discharge Monitoring Reports (DMRs) were reviewed for the period September 2008 through August 2009.
The ORC maintains detailed and accurate logs and calibration records relative to the operation,
maintenance, and self -monitoring of the facility.
FACILITY SITE REVIEW:
The facility only discharges effluent episodically. At the time of inspection the facility was not discharging.
All other existing components of the facility were in service and appeared to be operating properly at the
time of the inspection.
EFFLUENT IRECEIVING WATERS:
The facility discharges to an unnamed tributary to the Catawba River, which is a Class WS-IV & B CA
water in the Catawba River Basin. No effluent was discharging from the facility during the inspection. The
receiving water did not appear to be adversely effected by the effluent.
FLOW MEASUREMENT:
Flow measurement is accomplished by the bucket and stopwatch method when samples are collected in
accordance with NPDES permit requirements.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (DMRs) were reviewed for the, period September 2008 through August 2009.
Records, reports, and logs were clear and well maintained, The DMRs indicate that the facility was in
compliance with permit monitoring requirements and discharge limits during the review period, except for
the following-

Mr. David Risley, Gough Econ, Inc.
Compliance Evaluation Inspection, Page 4
January 14, 2010
• An ammonia -nitrogen concentration of 3.1 14 mg/L was reported on September 16, 2008, and an
am,nionia-nitrogen concentration of 0.90 mg/L was reported on September 30, 2008. When averaged
together these concentrations produce a monthly average ammonia -nitrogen concentration of 2.02
mg/L, which exceeded the permit limit of 2.0 mg/L. However, since the monthly average was only
I% above the permit limit a notice of Violation was not issued.
• An ammonia -nitrogen concentration of 1.90 mg/L was reported on April 14, 2009, and an ammonia -
nitrogen concentration of 2.24 mg/L was reported on April 28, 2009. When averaged together these
concentrations produce a monthly average ammonia -nitrogen concentration of 2.07 mg/L, which
exceeded the permit limit of 2.0 mg/L. This violation was addressed under separate cover by the
Division of Water Quality through the issuance of a Notice of Violation (Tracking Number NOV-
2009-LV-0367).
• While investigating a limit violation of fecal coliform, on October 21, 2009, Mr. John Lesley of the
Division of Water Quality Mooresville Regional Office spoke ',Nith the Operator in Responsible
charge at the facility; Mr. Steve Lambert. Mr. Lesley questioned Mr. Lambert regarding multiple
"Sample taken from effluent trough" notations on the NCO058084 DMRs Mr. Lesley had reviewed
and which had an accompanying residual chlorine concentration reported.
Mr. Lesley informed Mr. Lambert that only when effluent is leaving the Gough Egon, Inc.
WWTP should effluent samples be collected to obtain the total residual chlorine concentration
(TRC) in the effluent. If the WWTP only discharges on two of five days during the week then
those two days must have TRC analyses performed on the WWTP effluent, If there is only one
discharge during a particular week then only one TRC concentration is to be reported on the DMR.
LABORATORY:
Gough Econ is certified by the Division of Water Quality to perform field parameter laboratory analyses
(NC Laboratory Certification #5083 — temperature, residual chlorine, dissolved oxygen, and pH) and
contracts with Statesville Analytical (NC Laboratory Certification 4440) to perform all other analyses
specified in the permit, Statesville Analytical was not evaluated under this inspection. A review of
documentation/instrumentation associated with field parameter laboratory analyses was completed during
the inspection. No deficiencies were found.
OPERATIONS & MAINTENANCE:
The current overall operating strategy of the ORC appears acceptable for the size and type of the facility.
SLUDGE HANDLING & DISPOSAL:
Sludge removal is performed by Liquid Waste on an annual basis in or around September of each year.
Liquid Waste was not evaluated under this inspection.
SEWER OVERFLOW:
Please be advised that pursuant to Part 11, Section E ofyour NPDES permit and North Carolina
Administrative Code (NCAC) 15A 2B .0506 (a)(2), any failure of a collection system, pumping station, or

CC .. avid
idrisley, Gough Econ, Inc.
ornplia'ce Eahuatio, Inspection, Page 5
January 14, 2010
treatment facility resulting in a bypass without treatment
reported to the appropriate regional office (Mooresville I
but no later than 24 hours from the time the permittee be
which occur in Mecklenburg County, it is requested that
occurring on weekends or holidays can be reported by c<
Management at [phone].
A written report shall also be provided Within five (5) da
)f all or any portion of the wastewater shall be
egional Office 704/663-1.699) as soon as possible
ame aware of the bypass. For spills/bypasses,
,4CWQP be notified at 704/336-5500, Spills
ling the North Carolina Division of Emergency
s of the time of the incident. The report shall
and if the bypass has not been corrected, the anticipated time it is expected to continue; and the steps taken,
(or planned) to reduce, eliminate, and prevent recurrence of the similar events. Any spill that reaches
surface waters (i.e. any spill that reaches any water already present in a conveyance, stream, ditch, etc...) or
any spill greater than 1,000 gallons on the ground that does not reach surface waters must be reported.
An adequate spill response for those spills reaching surface waters should include an evaluation downstream
of the point at which the spill entered surface waters to determine if a fish kill occurred. The evaluation
should also include the collection of upstream dissolved oxygen and pH measurements for background
information and dissolved oxygen and pH measurements at multiple points do-vviistream of the entry point to
document any negative impact. Failure to report the bypass of collection system, pumping station, or
treatment facility subjects violators to penalties of up to $25,000.00 per day per violation.

ATALA.
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director
October 21, 2009
Mr. David P. Risley
Gough Econ, Inc.
PO Box 668583
Charlotte, NC 28266-8583
Subject: Renew al Notice
NPD]eS Permit NCO058084
Gough Econ WWTP
Mecklenburg County
Dear Permittee-
Your NPDES permit expires on June 30, 2010. Federal (40 CFR 122.41) and North Carolina (15A
NCAC 21-1.0105 (e)) regulations 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 renewal application, you may
disregard this notice.
assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after June 30, 2010, the current permit must b(
Discharge of wastewater without a valid permit would violate North Carolina General Statute
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 per
me at the telephone number or address listed below.
g 111�1111iliil; 111111gi 1 111!111 1 i�!�
ilillil��1111112 1 11 1 :: i i I � BE= o 111 11 11 Will
telephone number or e-mail address listed below,
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
cc.- Central Files
PPD"S i Pe''
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
512 North Salisbury Street, Raleigh, North Carolina 27604 NortliCarolina
Phone: [phone] / FAX [phone] / chades.weaver@ncdenr,gov AM(ralloff
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/1 0% Post Consumer Paper

a on at anct two copies,
tied facility does not generate any soh(
Ytiority VoUutant Analysis (VYA) m accorciance with 4V W, K Fart I /-Z.Z 1.
The above requirement does NOT apply to pdvately o"ed faciUdes treating 100%
domestic wastewater, for Jacifities which discharge non -process wastewater (cooling
water, alter backwash, etc.)
Send the completed renewal package to:
Mrs. Dina Sprinkle
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

Alfa co, Marcia
From: Martha lmsl mbortCc yadtel.net]
Sent: Wednesday, January 25, 2011 10:11 PM
To: Allocco, Marcia
Cc: [e-mail]
Subject: NCrO058084 Ammonia non-compliance
Cough Econ, Inc. WWTP December 2010 DMR will show non-compliance on the winter limit for ammonia.
This is a copy of the attachment to the DMR for your information.
Thank Your
Steven Lambert
January 28, 2011
Steven Lambert
Operator in Responsible Charge
Gough Econ, Inc.' W WTT'
NCO 58084
Subject: Ammonia lion -Compliance
This DMR will show non-compliance of the subject parameter exceeding the Winter Limit of4-.0 mg/L.
Extreme cold weather and weather conditions may have contributed to a reduced digestion of the an ' onia in
the filter bed.. The temperature of the wastewater has gotten dawn to a low of 5 degrees Celsius.
e filter bed has been raked regularly, and we are guarding against filter pending as much as possible. Should
a reduction not take place, other measures will be explored.
The exceedance is less than 2 %, as the monthly average was 4.65 mg/L.

58084 - Gough Econ - Nov. 20, 2008 Inspection Follow-up
Subject: NCO058084 - Gough Econ - Nov. 20, 2008 Inspection Follow-up
From: "David P. Risley" <drisleyggoughecon.com>
Date: Thu, 20 Nov 2008 16:31:56 -0500
To: <[e-mail]>
Wes,
Thank you for your time and recommendations made during the inspection earlier today. I wanted to let
you know what I have addressed this afternoon in a meeting with the shop superintendent, maintenance
technician and our safety manager.
rar-MMOT! an,
Best Regards,
David
copying of this e-mail is strictly prohibited.
Of 1 3/31/

Ar� Michael FEasley, Cove cr
Q Cyr William G. Ross Jr., Secretary
? North Carolina Department of Environment and Natural Resources
("bud.
Coleen H. Sullins Director
Division of Water Quality
November 25, 2008
r. David Risley, President & CEO
Gough Econ, Inc.
Post Office Box 66 858 a
Charlotte, :North Carolina 282-8585
Subject: Compliance Evaluation Inspection`
Gough Econ, Inc. WWTP
NP ES Pen -nit No. NCO058084
Mecklenburg County, N.C.
`?ear Mr. Risley
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the
inspection conducted at the subject facility on November 20, 2008, by Mr. Wes Dell of this
Office. Please inform the facility's Operators -in -Responsible Charge of our findings by
forwarding a copy of the enclosed report,
The: report should be self-explanatory, however, should you have any questions concerning
the report, please do not hesitate to contact Mrs. Marcia Allocco or Mr. Bell at (70 ) 663-1.699.
Sincerely,
Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure
cc: Rusty Rozzelle, MCWQP
WB'
APANo;�tY�,Carolin.a
NCDENR
flEtCl
Mooresville regional Office Division of Water Quality Phone [phone] Customer Service
Internet: 610 Past Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone] -6748
cAW n......_r.,n...:i n.,-,......:., n.,---

)de NPDES yr/mo/day inspection Type In
Lj 31 NC0058084 111 121 08/11/'2'L 1 17 18U 1
Remarks
Jill III
rk Days Facility Self -Monitoring Evaluation Rating BI QA ------ -------------------
169 70L41 71 LN 72 LN 73L_J_j 74 7
Section B: Facility Data
ion of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date
I NPDES permit Number) 09.37 AM 08/11/,
ITP
Exit TimelDate
Book Rd Sr
28214 12:06 PM 08/11/:
to Representative(s)/Tities(s)/Phone and Fax Number(s) Other Facility Data
ey/& CEO Presideit/104-399-2306
at Responsible Official/TitielPhone and Fax Number Contacted
t
ey,20 Box 668583 Charlotte NC 28266/President/704-399-23 6/
yes
imm Self -Monitoring Program Sludge Handling Disposal 0 Facility Site Heview
L L-aboratory Storm Water
Section D: Summa!y of FindinqIComments JAttach additional sheets of narrative and checklists
(See attachment summary)
Narne(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Wesley N Bell MRO WQ//704-663-1699 EXti21921/ q /r/
Sign lure of Management Q ARevi w r Agency/Office/Phone and Fax Numbers Date I
I, I t aqj 07�
c MRO WQ//704-663-1699 Ext,2204/
mr
aocco
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete,
Page #

POE yrtmolday inspection Type
3 NCO058084 11 12� 08/11/20 17 18U-
Page # 2

Permit: NCO058084 Owner - Facility. Gough Econ VVWTP
inspection Date: 11/20/2008 Inspection Type: Compliance Evaluati(
Permit
(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?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Commeft The subject permit expires 6/30/10.
Record _"e !ng
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 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates 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- f-ili+',
Is a copy of the current NPDES permit available on site? a 0 U U
Facility has copy of previous year's Annual Report on file for review? o no a o
Page # 3

Permit: NCO058084 Owner - Facility: Gough Econ WWTP
Inspection gate: 11/20/2008 Inspection Type: Compliance Evaluation
Record Ke i Yes No N� ICE
Comment DMRs were reviewed for the period September 37 through August 08. A
daily maximum effluent fecal coliform violation was reported in September 07, The
Division has separately addressed this limit violation by the issuance of an NOV, The
effluent temperature was not reported on a daily basis in June 8, however, the
inspection verified that the discrepancies were transcription errors. An amended DMI
will be resubmitted. The ORC roust ensure the "<" values for fecal cdliform are
calculated properly to determine the monthly average value. In addition, the ORC must
ensure all collection and analysis times (effluent, upstream, and downstream samples)
and ORC/Backup ORC arrival/departure times are properly documented (June 08). The
facility's records were organized and well maintained.
Labe rattal Yes No NA PEE
Are field parameters performed by certified personnel or laboratory? ;
Are all other parameters(excluding field parameters) performed by a certified lab? 0 0 0 0
# Is the facility using a contract lab?
Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? 0
Incubator (Fecal Col form) set to 44.5 degrees Celsius+?- 0,2 degrees? 0 0 in 0
Incubator (BOO) set to 20,0 degrees Celsius"+i- 1.0 degrees? 0 0 in 0
Comment: {fin -site field analyses are performed under laboratory certification #83.
Statesville Analytical (##4 0) has also been contracted to provide analytical support, The
laboratory instrumentation used for field analyses appeared to be properly calibrated.
ffltl rl SAT bra Yes-- No NA NE
Is composite sampling flow proportional' 00 in 0
Is sample collected below all treatment units? n—
Is prosper volume collected? 0 0 0
Is the tubing clean? 0 0
Is proper temperature set for sample storage (kept at less than or equal to 0.0 degrees Celsius)? D n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? in f l 0
Comment:
Upstream / Downstream a lin Yes I$i NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? IN 0 0
Comment:
r ticans Main +an np Yes No NA NE
Is the plant generally clean with acceptable housekeeping? a 0 0 f l
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Mudge
Judge, and other that are applicable?
Page # 4

Permit: NCO058084 Owner - (Facility: Gough Econ VVVVT
Yf
id visual alarm operational?
a?
)perly?
ating property?
14/17/08.
Yes No
edible and visible alarm Present and operational? 0 0
and watertight? M 0
1? 0
circulated at a valid ratio? 0
ree of algae or excessive vegetation? is 0
e-circulated at a valid ratio? (Approximately 3 to 1) 0 0
ately 6 - 8 inches of wastewater was measured below the outlets
quality.
N
DYes No Aisinfection-Tablet
Are tablet chlorinators operational? MOO
Are the tablets the proper size and type? MOO
Number of tubes in use? I
Is the level of chlorine residual acceptable? MOO
Is the contact chamber free of growth, or sludge buildup? MOO
Is there chlorine residual prior to de -chlorination? noo
Comment:
Pag

Permit: NCO058084 Owner - Facility. Gough Econ VWVTP
Inspection Crate: 11/20/2008 Inspection Type: Compliance Evaluation
De -chlorination Yes No NA t
Type of system ? Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)? 00110
Is storage appropriate for cylinders? 00 wo
# Is de -chlorination substance stored away from chlorine containers? 0 0 NO
Comment:
Are the tablets the proper size and type?
Are tablet de -chlorinators operational? 0 fl
Number of tubes in use?
Comment.
Flow Measurement - Effluent Yes No NA N
# Is flow meter used for reporting? DONO
Is flaw meter calibrated annually? 0
Is the flow meter operational? D
OND
(if units are separated) Goes the chart recorder match the Flow meter? 00100
Comment: Instantaneous flow monitoring is required by the subject permit. The
effluent flaws are measured by the bucket and step watch method,
ffl_ n_t Ply Yes No NA N
Is right of way to the outfall properly maintained? NOOO
Are the receiving water free of foam other than trace amounts and other debris? a i 0 0
If effluent (diffuser pipes are required) are they operating property? l ) ci a f i
Comment. The trace discharge appeared clear with no foam. The receiving strum
did not appear to be negatively impacted.
Page '# 6

November r , 2009
To: Mr. John Leslie �
Division of Water Quality
919 North Main Street
Mooresville, N C; 28115
From: Steve Lambert
ti
154 Sunflower wer Road
Statesville, NC 28625
Subject: Daily Maximum Violation,
Fecal olifo term
Gough Econ, Inc.
SPermit No.
As reported you by telephone, this letter informs oo of the subject violation
detected by analysis by our contract loar toi . An explanation of this violation is not passible
doge to the lack of visible turbidity in the sample and a Total Chlorine Residual of 0.61 /1
previous dechlorination. The result of the analysis was >6000 counts per 100 ml.
Follow-up analysis has shown that the facility has returned to compliant level with
result of <1 count per 100
Extra care will be taken to insure that the le is taken correctly and protected
from cross contamination. Care had already been taken to protect the sampling point from vector
contatnination, but this too will be reviewed on a continuing basis.
Please call me at 7 -6 7- 847 if lurther information is required.

m"
HCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins lee Freeman
Governor Director Secretary
August 13, 200
r. David P. Risley
Gough Econ Inc.
Past Office Box 668583
Charlotte, North Carolina 226-58
Subject: Notice of Violation - Effluent Limitations
Tracking # NOV-2009- ,V-0367
Gough Econ WWTP
NPDES Permit No NCO058084
Mecklenburg County
Dear Mr. Risley:
A review of the April 2009 self -monitoring report for the subject facility revealed a violation of the following
Parameter:
Pipe Parameter Reported Value Permit Limit
001 ammonia nitrogen 2.07 Ong/l 2.0 mg/l
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 of a continuing nature,
not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may
wish to consider applying for a Special Order by Consent. You may contact Mr. John Lesley of this Office for additional
information:
If you have questions concerning this matter, please do not hesitate to contact Mr. Lesley or me at 704/663-1699.
Sincerely,
Robert B. Krebs
Surface Water Protection
Regional Supervisor
cc: Point Source Branch
Mecklenburg, County "Water Quality Protection
Mooresville Regional Office
Location: 610 East Center Ave.„ Suite 301 Mooresville, NC 28115 0[1C-1
Phone: [phone] t Fax: [phone] \ C«stomer Service: 1-877-623-6748 NortliCaroltna
Internet: www,mvitaterquality,org IA'aturall
An Equal Opportunity \ Affirmative Acbon Employer - 50% Recycled/10% Past Consumer paper

Michael F. Easley, Governor
William G. Ross Jr.; Secretary 4
North Carolina Department of Environment and Natural Resources
Coleco H. Sullins, Director
Division of Water Quality
February 7, 2008
CERTIFIED MAIL #70071490 0004 4505 6554
RETURN RECEIPT REQUESTED
Mr.: David Risley
Gough Econ, Inc.
PO Box 66858
Charlotte, North Carolina 28266
Subject: Notice of Violation - Effluent Limitation
Tracking #: NOV-20-LV-0074
Gough Econ, Inc. WWTP
NPDES Permit No. NC0058084
Mecklenburg County
Dear Mr. Risley:
A review of the September 2007 self -monitoring report for the subject facility revealed a
violation of the fallowing parameter at Outfall 01:
Date Parameter Reported Value Permit Limit
9/2 /07 Fecal coliform 590 CFU/100 mL 4`00 CFU/I00 mL (Daily maximum)
Remedial actions, if not already implemented, should be taken to correct any problems.
Since the comments section on the reverse of the relevant Discharge Monitoring Report provided
an explanation for the noted effluent limit violation, it is not requested that a response be
submitted, however, should you have additional information concerning the violations or
comments which you wish to present, please submit them to the attention of Ms. Marcia Allocco.
The Division of Water Quality may pursue enforcement actions for this and any
additional violations. If the violations are of a continuing nature, not related to operation and/or
maintenance problems, and you anticipate remedial construction activities, then you may wish to
consider applying for a Special Order by Consent. You may contact Ms..Allocco of this Office
for additional information,
ATAOne l c1YCYlln
DEHR
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Sell
Internet. www,newateretualitv.ora 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]-623-6'
An Equal Opportunity/Affirmative Action Employer— 50% Recycledfl0% Post Consumer Paper

Mr. David Risley
NOV-2008-LV-0074
Page 2
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
Regional Supervisor
Surface Water Protection
cc: Point Source Branch
Rusty Rozzelle, MCWQP
MA

60
William G. Ross X, Secretary
r " North Carolina Department of Environment and Natural Resources
;1 Coleen H. Sullins, Director
Division of Water Quality
December10, 2007
Mr. David Risley, President
Gough Econ, Inc:
P.O Box 66858
Charlotte, NC 28266-858
SUBJECT Compliance Evaluation Inspection
Gough Econ, Inc. W WT '
NPDES Permit No. NC 058084
Mecklenburg County, N
Dear Mr. Risley:
ted an inspection at the subject facility. This inspection was c
;ed report should be self-explanatory.
Charlotte, NC 28202.'
If you have any questions concerning this report or any other matters, please do not hesitate to ca
Ms. Allocco or me at 704/66 -1699.
Sincerely,.
for Robert B. Krebs
Regional Supervisor
Surface rater Protection
Enclosure
cc: Rusty Rozzelle, MC +QP
RBK1ojh
File: WQ GoughEcon0058084,1207
WAe Csir(AIiC
,resvilie regional Office Division of Warr Quality Phone [phone] Customer Se
net: kvwm n ww0ler u lity ctr 610 East Center Ave, Smite 301 Mooresville, NC 28115 Fax [phone]-623-
An Equal Opportunity/Affirmative Action Employer.. 50% Recycledil0% Post Consumer Paper

lit , Mooresville Regional Office
Transaction Cade NPDES Permit No. YR/MO/DAY Inspection Type Inspector Facility Type
N 5 NCO058084 07/12/03 C
C 2
Remarks:
Ins ectov Mecklenbur Cciun Water uali Pr ram
Inspection Work Days Facility Self -Monitoring Evaluation Rating , BI QA Reserved.....,......
1.0 5 N ` N
Section R: Facility
Data
Name and Location of Facility Inspected:
Entry Time:
Permit Effective Date:
Gough Eton,Inc. WP
:
10:30
Exit Time:
September 1, 2006
Center Grove Lane
Mecklenburg County; NC
11:15
Permit Expiration Date:
Date:
.tune 30, 2010
December 3, 207
Name(s) of On -Site Representatives-------Title(s)--------Phone 1' of ):
r. Steve Lambert l Operator in Responsible Charge (ORC)1(704) 546-2602
Name and Address of Responsible Official: Title:
Mr. David Risley President/CEO, Manufacturing
Gough Eton, Inc.
P. 0. Box 668583 Phone No.
Contacted?
Charlotte, North Carolina 28266 (704) 39 -4501
Yes
Section C:
Areas Evaluated During Ins ection
Permit Flow Measurement Operations & Maintenance
Sewer Overflow-
Records/Reports Self -Monitoring Program Sludge Handling/Disposal
❑ Pollution Prevention
Facility Site Review ❑ ComplianceSchedules ] Pretreatment Program
❑ Multimedia
fuen eceivr
❑ tither:
Section D: Summary of Findings/Comments
All areas are rated' satisfactory unless otherwise indicated. See attached Sheet(s) for Summary
Signature(s) of Inspector(s): Agency/Office/Telephone:
Date:
Olivia J. Edwards MCWQPt(704) 336-5500
December 3, 2007
ignature of Reviewer: I ocy/office:
DLNR -- Division of Water Quality
PT�l e,
I
Marcia Alloc o Surface Water Protection —:Mooresville Regional Office
December 10, 2007
EPA. Form 3560-3 (Revised -85) Previous Editions are Obsolete
GENERAL:

GENERAL:
Ms. Olivia Edwards of the Mecklenburg Co
inspected tl--e facility on November 27, 2006. A Coral
issued on January 9, 2007.
PERMIT:
The current permit became effective on Septen
The permit properly describes the facility. The facility
wastestreani being treated.
The O.00 12 MGD facility consists of a septic to
with PVC distribution manifolds, a recirculation pump
tablet dechlorination, and cascade aeration.
The certification classification for NCO058084
in responsible charge (ORC) with a Grade I Biolo ical
_ I M. Al irk I ky it K41 EE I=_
Water Quality Program (MCWQP) last
ance iEvaluation Inspection report was
er 1, 2006, and expires on June 30, 2010.
ppeas to be adequate for the
squircs that the facility have an operator
-F"
RDS/REPORTS:
Discharize 1vlonitorin2 Renorts (DMRs4 were reviewed for the nerind 9ante-mhf-,r ?00A
through August 2007. The CRC maintains detailed and accurate logs and calibration records
relative to the operation, maintenance and self -monitoring of the facility.
FACILITY SITE REVIEW:
The facility only discharges effluent episodically. At the time of inspection the facility
was not discharging. All other existing components of the facility were in service and appeared
to be operating properly at the time of the inspection.
EFFLUENT/RECEIVING WATERS -
The facility discharges to an unnarned tributary to the Catawba River, which is a Class
WS-IV & B CA water in the Catawba River Basin. No effluent was discharging from the facility
during the inspection. The receiving water did not appear to be adversely effected by the
effluent.
FLOW MEASUREMENT:
Flow measurement is accomplished by the bucket and stopwatch method when samples
are collected in accordance with NPDES permit requirements.

rAA7; A`
Iffilmo 0
the Gough Econ, Inc. permit for limn and monitoring violations in May 2007. The
compliance system generates violations after the data from your monthly Discharge Monitoring
Reports (DMRs) has been entered and compared with the requirements of your permit,
N O058084. It appears that temperature readings for May 1 -17, 2007, were entered in the :Flow
column and no temperature readings were reported for this period resulting in a monthly average
flow limit violation and temperature monitoring violations. Please submit an amended DMR
to the .Division of Water Quality for May 2007 or provide the Division with an explanation
for noted violations,
LABORATORY:
Gough Econ is certified by the Division of Water (duality to perform field parameter
eter
laboratory analyses (NC Laboratory Certification ##5083 — temperature, residual chlorine,
dissolved oxygen, and pH) and contracts with Statesville Analytical (NC Laboratory Certification
##440) to perforin all ether analyses specified in the permit. Statesville Analytical was not
evaluated under this inspection. A review of documentation/instrumentation associated with
field parameter laboratory analyses was completed during the inspection. No deficiencies were
found.
OPERATIONS & MAINTENANCE:
The current overall operating strategy of the ORC appears acceptable for the size and type
of the facility.
SLUDGE HANDLING & DISPOSAL:
Sludge removal is performed by Liquid Waste on an annual basis in or around September
of each year. Liquid Waste was not evaluated under this inspection.
SEWER OVERFLOW:
Please be advised that pursuant to Part 11 Section E of your NPDES permit and. North
Carolina Administrative Code (NCAC) 15A 2B .0506 (a)(2) y failure of a collection system,
pumping station, or treatment facility resulting in a bypass without treatment of all or any portion
of the wastewater shall be reported to the appropriate regional office (Mooresville Regional
Office 74I663-1 b99) as soon as possible but no later than 24 hours from the time the permittee
became aware of the bypass. For spills/bypasses, which occur in Mecklenburg County, it is

Pr
requested that MC (P be notified at 704/33 -5500, Spills occurring on weekends or holidays
can be reported by calling the North Carolina Division of Emergency Management at (00) 58-
03 . A written report shall ,Olso be provided within five (5) days of the time of the incident.
The report shall contain a description of the bypass, and its cause; the period of the bypass,
including exact dates and times, and if the bypass has not been corrected, the anticipated time it
is expected to continue; and steps taken (or planned) to reduce, eliminate, and prevent recurrence
of the similar events, Any spill that reaches surface waters (i.e. any spill that reaches any water
already present in a conveyance, stream, ditch, etc...) or any spill greater than 1,000 gallons on
the ground that clues not reach surface waters must be reported.
An adequate spill response for those spills reaching surface waters should include an
evaluation downstream of the point at which the spilt entered surface waters to determine if a fish
kill occurred. The evaluation should also include the collection of upstream dissolved oxygen
d pH measurements for background information and dissolved oxygen and ply measurements
at multiple points downstream of the entry point to document any negative impact. Failure to
report the bypass of collection system, pumping station, or treatment facility subjects violators to
penalties of up to $25,000.00 per day per violation.

September 28, 2007
To: Mr. John Leslie
Division of Water Quality
919 North Main Street 'ECEIVED
Mooresville, SIC`; 28115
p
OCT
t From:
Gough Econ, Inc.
154 Sunflower cad
Statesville, NC 28625
Subject: Gough Eco , hie.
DFS #NCO058084
Maximumaily Violation
Fecal Coliform
s reported to you in our telephone conversation of September 7, 2007, the sample
taken for analysis for Fecal Coliform Bacteria (September 25, 2007) produced results indicating a
violation of the 400 count Maximum DailyLimit for this parameter. The result, relayed to me by
telephone on September 26, 2007, was 560 counts. As the previous ecal Coliform analysis
result was <1 count, the monthly limit is probably not in danger of noncompliance.
The laboratory is now analyzing another samplecollected on September 27, 0 7�
All1%oA s xyot r rev tr 4i r4 +hot ffirof +a' to vsrtga A lu% ruins ne AiA TQC nrt-- ire to
If further information is required, feel free contact me at - ' - 4" .

FV 6� V�3 A T
Michael F. Easley', Gov'14
William G. Ross Jr„ Secretary
g^ North Carolina [Department of Environment and NaturalResources
t ^C Alan W.Klimek, P . Director
Division of Water Quality
January 9, 2007
Mr. David Risley, Vice President
Gough Econ, Inc.
P.O Box 668583
Charlotte, NC 2 266-8583
SUBJECT: Compliance Evaluation Inspection
Gough Econ, Inc, WWTP
NPIDES Permit No. NC O058084
Mecklenburg County, NC
Dear Mr. Risley:
On November 27, 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 7 4/663-1699.
Sincerely,
Samar Bo-Ghazale
Acting Regional Supervisor
Surface Water Protection
Enclosure
cc: Rusty Rozzelle, MCWQP
SBG/ol h
File: WQ G ugh conOO58084:1106
. No One Carer ma
MCDENR
�
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: rc tiakitg��.oi, g 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal OpportuniWA Brmative Action Employer - 50% Recycled/10% Post Consurner Paper

401t United States Environmental Protection Agency, Washington, DC 20460 Farm Approved
NPDE5 Compliance Inspection Report ATAOMB No. 2040-0003
North Carolina Department of Environment and Natural Resources Approval Expires
'Wil°`` urk
Division of Water Quality. Mooresville Regional Office 7/31/85
Section As National Data stem Coditl
'rransaction Code NPDES Permit No. YR.,'MO/DAY Inspection Type Inspector :Facility Type
N 5 NCO058084 06/:11/27 `' C C 2
Remarks:
Ins ector: Nieklenur Count Water uali Pro r
Inspection Work Days Facility Self -Monitoring Evaluation :Rating B1 QA :...... Reserved.:..........
Lo S N N
Section B: Facility Data
Nance and Location of Facility Inspected: ]Entry 'Time. Permit Effective Date:
12:45 pat September1, 2006
1 Gough Econ, Inc. WW'TP Exit Time:
Center Grove Lane 1:30 pro Permit Expiration Date.
Mecklenburg County, NC Date: June 0 2 � OIO
November 27, 2006
i
Name(s) of Can -Site Representatives ------- Title(s)-------- Phone No(s):
,E
Mr. Steve Lambert / Operator in Responsible Charge (ORC) {` [phone]
Name and Address of Responsible Official: Title.
Mr. David Risley President/CEO, Manufacturing
} Gough Econ,'Inc.
. 0 Box 668583 Phone No. Contacted`'
Charlotte, North Carolina 28266 [phone] Yes
Section C.
Areas Evaluated Durin .:Ins action
Y it Flow Measurement ( Operatiota &Maintenance sewer Overflow
Records/Reports elf Monitoring Program Z Sludge Handling/Disposal El Pollution Prevention
Facility Site Review ] Compliance Schedules ® Pretreatment Program D Multimedia
Effluen eceiviOther:
Section D: Summary of Findings/Comments
All areas are rated satisfactory unless otherwise indicated, See Attached Sheet(s) for Summary
Signature(s) of Inspector(s). Agency/Office/Telephone: Date:
Olivia J. Hutchins MCW QP/[phone] Nove ber 28, 2006
Signature of Reviewer- ney/Office: Date.
Marcia Allocco NC NRlDWQ (704) 663-169 January 8 00
EPA Form 350-3 (Revised 3-8) Previous Editions are Obsolete

AA
GENERAL:
The facility was last inspected on December 20, 2005 by Ms. Olivia Hutchins of the
Mecklenburg County Water Quality Program (MCWQP). A Compliance Evaluation Inspection
report was issued on January 20, 2006.
PERMIT:
A permit to operate this facility was issued on January 1, 2002 and expired on August 3 1,
2006. A new permit to operate this facility was issued on September 1, 2006 and will be
effective until June 30, 2010. The facility operated under the requirements of both permits
during the period of review. Both the expired and the new permit appear to property describe the
facility. The facility appears to be adequate for the waste stream being treated.
The 0.0012 MGD facility consists of a septic tank, dosing tank, surface sand filter with
PVC distribution manifolds, recirculation pump, effluent tablet chlorination, effluent tablet
dechlorination, and cascade aeration.
The certification classification for NCO058084 requires that the facility have an operator
in responsible charge (ORC) with a Grade I Biological Water Pollution Control System (WW-1)
certification, The facility is staffed (ORC and back-up) with personnel that possess the
appropriate operator certification.
RECORDS/REPORTS:
Discharge Monitoring Reports (DMR's) were reviewed for the period November 2005
through September 2006. The OR C maintains detailed and accurate logs and calibration records
relative to the operation, maintenance, and self -monitoring of the facility,
FACILITY SITE REVIEW:
The facility only discharges effluent episodically. At the time of inspection the facility
was not discharging. All other existing components of the facility were in service and appeared
to be operating properly at the time of the inspection.
EFFLUENT/RECEIVING WATERS:
The facility discharges to an unnamed tributary to the Catawba River, which is a Class
WS-IV & B CA water in the Catawba River Basin. No effluent was discharged from the facility
during the inspection. The receiving water did not 'appear to be adversely affected by the
effluent.

FLOW MEASUREMENT
Flow measurement is accomplished by the bucket and stopwatch method when samples
e collected in accordance with NPDES permit requirements.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (DMRs) were reviewed for the period. November 2005
through September 2006. The reports indicate that the :facility was meeting permit effluent limits
during this period and that all parameters e being monitored at the proper frequency and
location. Records, reports and logs are clear and well maintained,
LABORATORY:
Cough Econ is certified by the Division of "Water Quality to perform field parameter
laboratory analyses (NC Laboratory Certification 45083 — temperature, residual chlorine,
dissolved oxygen, and pH) and contracts with Statesville Analytical (NC Laboratory Certification
##44 ) to perforin all other analyses specified in the permit. Statesville Analytical was not
evaluated under this inspection. A review of documentation/instrumentation associated with
field parameter laboratory analyses was completed during the inspection. No deficiencies were
found.
OPERATIONS & MAINTENANCE:
The current overall operating strategy of the ORC appears acceptable for the size and type
of the facility.
SLUDGE HANDLING & DISPOSALS
Sludge removal is performed by Liquid Waste, Inc. on an annual basis in or around
September of each year. Liquid Waste, Inc. was not evaluated under this inspection.
SEWER OVERFLOW:
W:
Please be advised that pursuant to Part 11 Section E of your NPDES permit and North
Carolina. Administrative Mode (NCAC) 15A 2B .0506 (a)(2), any failure of a collection system.,
pumping station or treatment facilitresulting in a bypass without treatment of all or any portion
of the wastewater shall be reported to the appropriate regional office (Mooresville Regional
Office 704/663-1699) as soon as possible but no later than 24 hours from the time the permittee
becarne aware of the bypass. For spills/bypasses which occur in Mecklenburg County, it is
requested that MCWQP be notified at 704/336-5500, Spills occurring on weekends or holidays
can be reported by calling the North Carolina Division of Emergency Management at 919/733-
330, 800I662-7956, or 800/858-0368. A written report shall also be provided within five (5)
days of the time of the incident. The report shall contain a description of the bypass, and its
cause; the period of the bypass, including exact elates and times, and if the bypass has not been.

V
corrected, the anticipated time it is expected to continue; and steps taken (or planned) to reduce,
eliminate, and prevent recurrence of the similar events. Any spill that reaches surface waters
(i.e. any spill that reaches any water already present in a conveyance, stream, ditch, etc...) or any
spill greater than 1,000 gallons on the ground that does not reach surface waters must be
reported.
An adequate spill response for those spills reaching surface waters should include an
evaluation downstream of the point at which the spill entered surface waters to determine if a fish
kill occurred. The evaluation should also include the collection of upstream dissolved oxygen
and pH measurements for background information and dissolved oxygen and pH measurements
at multiple points downstream of the entry point to document any negative impact. Failure to
report the bypass of collection system, pumping station or treatment facility subjects violators to
penalties of up to $25,000.00 per day per violation.

'r t" V4 A Michael F. Easley, Governor
0
13�O William G. It Jr., Secretary
North Carolina Department of Environment and Natuml Resources
>
Alan W. Klimek, P.E. Director
ANIND" IN` 7`3 0 U R C E 9
December 15, 2006 U100REE-1111"I'l JIL OFFICE
5083
Mr. David P. Risley DEC 1 9 200,
Gough Econ, Inc.
P.O. Box 668583
Charlotte, NC 28266-
M
HT A T L ;i I Y00 E
SUBJECT.- Wastewater/Groundwater Laboratory Certification Renewal
Field Parameters Only
Dear Mr. Risley:
The Department of Environment and Natural Resources, in accordance with the
provisions of NC GS 143-215-.3 (a) (10), 15 NC 2H .0800, is pleased to renew
certification for your laboratory to perform specified environmental analyses required by
EMC monitoring and reporting regulations 15 NCAC 2B .0500, 2H .0900 and 2L .0100,
.0200,.0300, and 2N .0100 through .0800.
C-1—A ;—e ­­e ­— ;- - ^—r+;;;--4­ +k— --A I.—*,+^ ^f astir tw
certification. Please review this certificate to insure that your laboratory is certified for
parameters required to property meet your certification needs.
Please contact us at 919-733-3908 if you have questions or need additiol
information.
Sincerely,
Pat Donnelly
Branch Manager
Enclosure
cc* Chet Whiting
Mooresville Regional Office
it Service Center Raleigh, NC 27699-1623 Phone [phone] Gust(
. 4405 Reedy Creek Road Raleigh, NC 27607 Fax [phone]"
)portunity/Affirmative Action Employer - W1. Pecycled/1001. Post Consumer Paper

STATE OF NORTH CAROLINA DEPARTMENT OF THE
ENVIRONMENT AND NATURAL RESOURCES
CERTIFICATIONDIVISION OF WATER QUALITY
LABORATORY
In accordance with the provisions of N. .C. S. 143-21&3 (a) (1), 143- 1 . ()(10) and MCAC 2H.0800:
Field Parameter Only
5,
"$"' r w
UGH ECON, INC.
is hereby certified to perform environmental analysis as listed on Attachment I and report monitoring data to DWQ for
compliance with NPDES effluent surface water, groundwater, and pretreatment regulations.
By reference 15A NCAC 2H.0800 is made a part of this certificate.
This certificate does not guarantee validity of data generated„ but indicates the methodology, equipment, duality control procedures,
records, and proficiency of the laboratory have been examined and found to be acceptable.
This certificate shall be valid until December 31, 2007
Certificate No. 5083
Pat Donnelly

Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
FIELD PARAMETERS ONLY
eme, Gough Econ, Inc. Certificate Number: 5083
ddresa: P.O. Box 668583 Effective Gate: 01101/2007'
Charlotte, NO 282 6- Expiration bete: 12/3112007
Date of Last Amendment:
'he above named laboratory, having duty met the requirements of 15A NCA 21-1.0800,-is hereby certified for the measurement 5f the parameters listed below.
CERTIFIED PARAMETERS
NORGANICS
RESIDUAL CHLORINE
Sid Method 4500 Cl G
ASSOLVED OXYGEN
Std Method 4500 O G
rH
Std Method 4500 H B
"EMPERATURE
Std Method 25508
its certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples, Laboratories are
,iblect to civil penalties and/or decertification for infractions as set forth in t 8A NCAC 21-1.0807.

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross, Jr,, Secretary
Alan W. Klimek, P.E., Director
December 13, 2005
David P. Risley
Gough Eden, Inc.
PO Box 668583
Charlotte, NC 28266
Subject: Renewal Notice
NPDES Permit NCO058084
Gough Econ WWTP
Mecklenburg County
Dear Permittee:
Your NPDES permit expires on August 31, 2006, Federal (40 CFR 122.41) and North Carolina (15A NCAC
2H,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 not later than March
4, 2006. Failure to request renewal by this date may result in a civil assessment of at least $500.00. Larger penalties
may be assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after August 31, 2006, the current permit must be renewed. Discharge
of wastewater without a valid permit would violate North Carolina General Statute 143-215,1; 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
e-mail address listed below.
Sincerely,
V
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
NPDES File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
512 North Salisbury Street, Raleigh, North Carolina 27604 NofthCaro hna
Phone: [phone], extension 511 / FAX [phone] / [e-mail] Aahmally
An Equal Opportunity/Affirmative Action Employer -- 50% Recycled/l 0% Post Consumer Paper

NPDES Permit NCO058084
Gough can WWTP
Mecklenburg County
The following items are REQUIRED for all renewal packages:
• A cover letter requesting renewal of the permit and documenting any changes at the
issuance of the last permit. Submit one signed original and two copies.
• 71"he completed application form (copy attached), signed by the perinittee or at
Representative. Submit one signed original and two copies.
• If an Authorized Representative (such as a consulting engineer or environmental consult
the renewal package, written documentation must be provided showing the authority del
such Authorized Representative (see Part ILB 1 Lb of the existing NPDES permit).
• A narrative description i of the sludge management plan for the facility. Describe how slit
solids) generated during wastewater treatment are handled and disposed. If your facility
plan (or the permitted facility does not generate any solids), explain this in writing. Subtr
original and two copies.
The following items must be submitted by any Municipal or Industrial facilities d
t)rocess wastewater:
industrial facilities classified as Primary Industries (see Appendices A-D to Title 40 of the Cod4
V
water, fitter backwash, etc.)
I-ILEASE NOTE:
Due to a change in fees effective January 1, 1999, there is no renewal fee required with your
application package.
Send the completed renewal package to:
Mrs. Carolyn Bryant
NC DENR / IOW Q / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

pplopp-
Carolina Department of Environment and WDENR
Natural Resources
Division of ator Quality
Michael F. Easley, governor William G. Ross, Jr, Secretary
Alan W. Klimek, P E., DirectDr
June 22,'2005
. David Risley, Vice President
Gough Ecran, Inc.
P.U. Box 668583
Charlotte, NC 8266-8583
SUBJECT: Compliance Evaluation Inspection
Gough Econ, Inc, WWFP
DES Pen -nit No. NCO058084
Mecklenburg County, NC
Dear Mr. Risley.
On June 7, 2005, Ms. Olivia Hutchins afthe Mecklenburg County Water Quality Program
(MCWQP) conducted inspection at the subjectfacilitylilty This mspection was conducted as part
of°a cooperative working agreement between Mecklenburg County and the Division of Water
Quality The enclosedreport should be self-explanatory
If you have any questions report or any other matters, please do not
hesitate to call Mr. Richard Bridgeman or me at 7041663-169 _
erel,
i D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
Enclosure
cc~ Rusty Rozzelle, MCWQP
DRG/ojh
File: WQ GoughEcon0058084.0605
MooresvilleRegional Office One
610 East Center Avenue, Suite 301, Moores0ide, North Carolina 2 115 NdfthCarohna
Phone: i 63-1 991 Fax. i 63--6040l Internet: h2o.enr.state,nc.us Vatmally
An Equal OpportunitylAffirmative Action Employer— 50% Reo 10% Post Consumer Paper

Protection Agency,
msaction Code NPDES Permit No. YR/M0/DAY Inspection Type Inspector
N 5 NCO058084 05/06/07 C C
Remarks.
Inspector: Mecklenburg County Water Quality Program
pection Work Days Facility Self -Monitoring Evaluation Rating BI QA .......... Re
0.6 3 N N
Ej
2:1
Di
In
Charge (ORC) / [phone]
,ble Official:
Pat
Time:
pin
it=.
Records/Reports 0 Self -Monitoring Program Z Sludge Handling/Disposal El Pollution Prevention
Facility Site Review El Compliance Schedules E) Pretreatment Program D Multimedia
Effluent/Receiving Waters Lab2to a [j Stonnwater El Other.
Section 'D:'Summary of Findings/Comments
All areas are rated satisfactory unless otherwise indicated. See Attached Sheet(s) for Summary
Signature(s) of Inspector(s): Agency/Office/Telephone: Date:
& tl*�&' q 4( kka",O MCWQP/[phone] June 8, 2005
Olivia J., Hutchins
Signature of Reviewer: Agency/Office Date:
EPA Form 3560-3 (Revised 3-85) Previous Editions are Obsolete

GENERAL:
The facility was last inspected by MCWQP on June 28, 2004. A Notice of Deficiency was
issued on July 23, 2004. A Notice of Violation "and Assessment of Civil Penalty was issued on
August 5, 2004, for an AmmoniaNitrogen monthly average occurring in April 2004.
PERMIT:
e 0.00121V GD facility s of septic tank, dosing e sand filter with
-� e- c� •®� 1 � rr - ► � Ifs
water in the Catawba River Basin.
. PQ "TS.
ittenance and self -monitoring of the
ITE REVIEW:
rly at the time of the " ction.
ECEIMG WATERS:
S' ' ENT:
e collected inaccordance 'with NPDES permit requiremn s.

adequate spill;response for those spills reaching surface watersshould include an
evaluation downstream of the paint at which the spill entered surface waters to determine if a fish
kill occurred, e evaluation should also include the collection of upstream dissolved oxygen and
pH measurements for background information d dissolved oxygen and pH measurements at
multiple ;paints downstream of the entry point to document any negative impact. Fail to report
the bypass of collectionsystem,p' station or t facility subjects violators to
penalties of up to $ 5,000.00 per day per violation.

MM
W A 7-
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Q (
C7 7 North Carolina Department of Environment and Natural Resources
--
Alan W. Klimek, P.E. Director
Division of Water Quality
December 1, 2004
)83
r. David P. Risley
ou h Econ,; Inc.
0. Box 668583
� arllotte, NC 28266-
JBJECT: Wastewater/Groundwater Laboratory Certification Renewal
Y
FIELD PARAMETERS ONLY
ear Mr. Risley;
L, .0100, .0200, .0 00, and 2N .0100 through .0800.
Enclosed for your use is a certificate describing the requirements and limits of your certification. Please revi'
lis certificate to insure that your laboratory is certified for all parameters required to properly meet yi
artication needs.
Please contact us at 919-733-3908 if you have questions or need additional information.
Sincerely,
James W. Meyer
Laboratory Section
ncloure
c: Chet Whiting
Mooresville Regional Office
EC 0 e"
ion, ca<
Itur
Laboratory Section 1623 Mail Service Center; Raleigh, NC 27699-1623
4405 Reedy Creek Road; Raleigh, NC 27607
Phone [phone] FAX [phone] / Internet: www.dwglab.org
An Equal Opportunity/Affirmative Action Employer — 50% Reeycled110% Post Consumer Paper

STATE OF NORTH CAROLINA DEPARTMENT OF THE
ENVIRONMENT AND NATRIL RESOURCES
IO'N OF WATIER QUALITY
LABORATORY CERTIFICO"ATION PROGRAM
In accordance with the provisions of N.C.G.+. 143- 1 , (I) (1), 143-215.3 (a)(10) and NCAC 2H.0800
Meld Parameter ndy
STArt
�c
-71
Y
Y',(rjv
�� Lai �,, ,z ,. •� _ ..«�` �,,
•j w+r Y` to
GOUGH ECON, INC.
}
Is hereby certified to perform environmental analysis as listed on Attachment hand report monitoring data to DWQ for
compliance with NPDE5 effluent surface grater; grou dwater; and pretreatment regulations.
By reference 15A NCAC 2H .0800 is made a part of this certificate.
This certificate does not guarantee validity of data generated, but indicates the methodology, equipment quality control procedures,
records, and proficiency of the laboratory have been 7amined and found to be acceptable.
This certificate shall be validuntil e ember 31, 2005
Certificate No. 5083
James W- Meyer
C
1

FV Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
FIELD PARAMETERS ONLY
b Name: Gough Econ, Inc. Certificate Number: 5083
[dress: P.O. Sox 668583 Effective mate: 01/01/2005
Charlotte, NC 28266- Expiration Date: 12/3112005
Elate of Lest Amendment:
a above named laboratory, having duly met the requirements of 15A NCAC 21-1.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS j
ORGANICS
: IDUAL CHLORINE
3tdMethod 4500 Cl G
SSOLVED OXYGEN
3td Method 4500 G G
I
3td Method 4500 H B
UPERATURE
31d Method 2550B
its certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples, Laboratories are
bject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.0807.

A
Michael F. ley, Governor
William G. Roses Jr., secretary
_ North Carolina
CO
.:�
of En i ent and Natural
Alan W. KInek, P.F. Director
Division of Water Quality
September 8, 2004
avid P. Risley
ough Econ Inc.
?. ,Box 68583
harlotte, IBC 28266
T
LJBJECT: PAYMENT ACKNOWLEDGMENT
CIVIL PENALTY ASSESSMENT
SEP 1 3 2004
Gough Econ Incorporated
Mecklenburg COUNTY
PERMIT NO: NCO058084
L-2004-0327
earMr. Risley:
his letter is to acknowledge receipt of check No. 35142 in the amount of $335.04 received from you dated

I
GOUGH ECON, INC. FIRST CITIZENS BANK 018
P.O- BOX 668583 & TRUST COMPANY 013151
CHARLOTTE, NORTH CAROLINA 28266 CHARLOTTE, NC 28202
PH. 704-399-4501 66-30-531
*TVIRE-E HU11DRED THIRTY FIVE,*: D01-1 ARS AND 4 Cr-:*1%1T S
DATE Al
08/30/04
11400035I42us 10*05310030010*00013LS801321111

Michael F, B
William G. Ro
> Alan W4 Klimek. P. E. lei
DiviskwofWatcrQuality
Coleman H, Salim& Dcputy Director
Divisim ofW4ter (Nality
August 5, 2004
CERTIFED MAK 7003 2260 00013550 2462
RETURN RE-CEIPT REQUES ED
Mr. David P. Risley, Vice President
Gough Econ, Inc.
9400 N. Lake Brook Road
P.O. Box 668583
Charlotte, NC 28266-8583
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215. 1 (a)(6) and NPDES Permit No. NCO058084
Gough Econ, Inc. WWTP
Case No. LV-2004-0327
Mecklenburg County
Dear Mr. Risley:
•
Xvision of Water Quality, Moores-ille RegiotW Office. 919 North Uiat Street lvloormWeNC28115 (704)663-1

250.00 For 1 of the one (1) vic
215,1(a)(6) and NPDES Perm
discharging waste into the wat
violation of the permit mondj3
for Ammonia Nitrogen,
$ 250.00TOTAL, CIVIL PENALTY
$ 85.04 Enforcement costs.
335.04 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining unt of the penalty I have en
into account the Findings of Fact 'and Conclusions of Law and the factors set forth at G.S. 14313-
2.1(b, which
(1) The degree and extent of harm to the `natural resources of the Mate, to the public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;
() The effect on ground or surface water quantity or quality or onair quality;
() The east of rectifying the e,
(5) The amount ofmoney saved by noncompliance;
() Wheher the violations were committed willMy 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,
d
(8) The cast to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the folio
. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiverform). Payment ofthe penalty
t foreclose firther enforcement action for any continuing or new violation(s).
Please b ' payment to the attention of -
Point Source Compliance/Enforcernent Unit
Division of Water Quality
1617 MAR Service Center
Raleigh, North Carolina2769 -161'7

A W"A, LWULV,6,
Division of Water Quality
1617 Mail Service Center
Raleigh, No Carolina 27699-1617
2R
3. File a petition for an administrative hearing with the Office of
If you wish to contest any statement in the attached assessment document you
must file a petition for an administrative hearing. You nay obtain the petition
form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this
notice. A petition is considered filed when it is received in the Office of
Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 am.
and 5:00 p.m., except for official to holidays. The original and one (1) copy of
the petition must be filed with the Office of Administrative Hearings. The petition
may be faxed — provided the original and one copy of the document is received in
the Cif-ce of A dmm�i' ative iheari6gs wimm nve (5) business days lioiiow4 die
faxed transmission. The niailing address fog the Office of Administrative Hearings
is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
Telephone: [phone] Facsimile: [phone]
A copy of the petition must also be served on DENR as follows:
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, No Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the
petition.

Section staff of the Moores dikJR-ggional, Office at 704/663-1699.
144e4, s- 2 0
---/(DatD. Rex Gleason, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
Division of Water Qualit3,
ATTACHMENTS

Attachment
Gough Ecor4 Inc.
DES Permit No. NC0058084
Case Number LV-2004-027
Limit Violations, April 2004
* denotes assessment of civil penalty.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
D NATURAL RESOURCES
COUNTY OF sec eubu
IN THE MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN
CIVIL PENALTIES AGAINST ADMINISTRATIVE HEARING
}AND STIPULATION GP FACTS
Gough Econ, Inc.
PERMIT NO. NCtl058084 FILE NO. V-2004-032
Having n assessed civil es totaling W5.04 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated August S. 2004, the undersigned,
desiring to seek remission of the civil penalties, does hereby wai 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 firther understands that all evidence presented in support o
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 remission
request ` will be allowed after 30 days from the receipt of the notice of assessment.
This the day of °t:004
BY
ADDRESS
TELEPHONE

EFFLUENT
? 1F DES Penttit No (' , t'�7
Discharge No. 61
Facility Nan1t C ^ 'r
1dX *.
Ci141111Y
T
s
Ciper ttrrr n1 G�pt)IL4i111C taC C ( �tk )
r' J , r
° -
Grade ��
Phone
Ctm lied Laboratories (1)
:. ;11 ( )
CHE CK BOX IF ORC HAS CHANGED 1'crss.
t1(s) Collecting Sample;
Mail 01UGSNAL and ONE COPY to
11TTN: CENTRAL FILES
DENR
(SIGNATME OF OPERATOR IN RESPONS113L MARGE) DATE
1617 MAIL SERVICE CEINTFR
13l'THISSMNATURE, 1 CERTtrt"Tft>rT rttis$tLreactrtc,�CC`v►t��t .anazectncti tt rca
RALEIGI-L NC 3i699-1617
TUE or-w or my 1.-raow ncE.
50050 00010
00400 50060
00310 00610 00530
31616 00300
00600
006t-
FLOW
..,
i aca! unnt hctow
Ei}i$
kiRS i'!I tj
�tGD C
UNITS <
nt^11- m-JL ni--/L
'/100 ntll
t wfl—
tw&L
nte'L ( �
t
E
a
`{
11 Q , I I ,1 .. 1 4° . 1' I 1 .1 1 1 »" .. I . i i l
1 2umol l I '! I 1,J ;', 1 i✓d s I t c, 1 " 1 . I " 1 1 1 I 1 1 1 1
1 241 1 1 1 1 11 1 1 1 1 1 1 1 1;
1 ?{ o k'1 1- I
1
�.�:
2S+a �A r.i1 1 1-7 1 1 1
I 3Q I 1 1 I i _ I I I I I I I 1 1
t
r Ully i Inut I M w t t w I" ( cr' t T 3� AS, 13
Q r ml NIR-

Facility Status - please cliccl, one of tile follt,,A�ijjg:
All monitoring �data and sampling frequencies meet permit requirements
Monitoring data and/or sampling frequencies do NOT meet permit requirements
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment,
roviding a time table for completion,of improvements.
2- 0 4z4 2-.%4
N H35-0
A I V- � 1 1.
peoluucs Tor
submitting false infortilation, including the possibility of fines and imprisonment for knowing violations."
Permittee (Please print or type)
Signature of Permittee Date
afeV*Z Aj444-4/1. e Aj C. (gs.),
'ermiftee Address
Phone Number Permit iration Date
PARAMETER CODES
...........
. ......... 66GS2-Color(ADMI) WM5 Condumi
............. ................... . .00080..... .... v1tv . ...... . . . . . .......... ... . ..........
00300 Dissolved Oxygen 00310!99� 003,0 COD F(
.......... . . .....
005560H&2n��_ ...... _ ........ (-)0-60n ...
T Total 00610 An=ooia Nttm eta
...... -4 ....... 0400
...................... *- - -----
00630 Nitmtesfttrites 'i 0066S Total
...... t ........ sulfid& 009V Toxai Ma
. ..........
00929 i ........... .........
5646yii;�agori& " W951 Tow Fluori'd**e­*-- 1 01002 Total A=mic . . ........... UZZI
................. .. Chinn... -
01032H=valentuum 1 1034
. . . ............ ................................ 4 . ................... ....... ................... 01045 —..—
. .. .............. ........
hom
01067147ickel I 01077Saver
......... ..................................... I 0101)2zinc 01105 Altunimtto,
. . . ...........
:..Q 1.1 �47- Selc.ni.Lrr�n ... ......31616 Fiat CoLfnma....... ...... 327301atal Phenolics 54225 Beittme
................ .. ......... .......... ........................... -- .......
7=60 -VIBAS i 5006A Rr-idual "-Worint.
nr
................... - ...................... ................ ................
. . .. . . .......... 19007Merl 81551 xylene
...........
........... ........ ........ I-- ....... ..........
Parameter Code assistance may be obtained by calling the Division's Point Source Compliance/Enforcement Unit at [phone] or
by visiting the NPDES web site at httnL/j2oMr.sWte.nc-us/NTQF,9 and visiting the 'Documents- section.
The monthly avem,-,e for fecal coliform is to reported as a GEONfErRIC mean. 'Use only units designated in the reporting facility's
permit for reporting data.
ORC must visit facility and document visitation Of hCility as required per ISA NCAC 8A.0202 (b) (5) (B).
If signed by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506 (b) (27)
(D).
DWQ Form MR -I (Revised 772000)

Permit NCO058ci,
A. (I.) EFFLUENT L-I IITAT ONS AND MONITORING REQUIREMENTS - FINAL
During the period Beginning can the effective date, of the permit and lasting until expiration, thr PcMkittecw IS
authorized to discharge from outfall 001. Such discharges shall be limited and monitoredby the Permitter as
specified below:
Yp
a r
R YF
Wj
!
u
• i N u err m �� � �� t ��
�,� 2� � i w� w u
f i
GeS
stream samples above discharge point. Downstream samples shall be collected approi
:barge point.
he p l shall not be less than LO standard units nor greater than 9.0 standard units,
shall be no discharge of floating solids or visible foam in other than trace amounts.

A I a ri ql� P�OA
NCDENR
North Carolina Department of Environment and Natural Resources
Michael R Easley, Governor Division of Water Quality William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
October 18, 2004
CERTIflED _MAIL
RETURN RECEIPT REQUESTED
7003 2260 00013550 3070
Mr. David Risley, Vice President
Gough Econ, Inc.
P.O. Box 668583
Charlotte, NC 28266-8583
Subject: Notice of Violation - FMuent Limitations
Trucking #- NOV-2004-LV-0518
Gough Zon, Inc WWTP
NPDES Pe No. NCO058084
Mecklenburg County
Dear Mr. Risley:
A review of the. Irma. INIA qAf-mt%nit^r;n&vnnrf f,flh. �-I,—+ C-1.+- --I-A
following parameter:
BM Parameter ReDorted Value Limit
001 Fecal Coliforni 3700/100 ml 400/100 ml FIN
Remedial actions, if not already implemented, should be taken to correct any problems. The Division
at 704/663-1699.
Sincerely,
D. Rex Gleitgon, P.E.
Surface Water Protection Regional Supervisor
cc: Point Source Branch
Rusty RozzelleMCWQP
RMB
Mooresville Regional Office One
610 East CenterAvenue, Suite 301, Mooresville, North Carolina 28115 NofffiCarolffia
Phone: [phone] Fax. [phone] Internet: h2o.enr.state.nc.us ;WMM4

GOUGH
ECOKINC.
SULK MATERIALS HANDLING SOLUTIONS
Mr. Richard Bridgeman July 29, 2004
N.C. Department of Water Quality
Mooresville Regional Office
919 North Main Street ENE-, (.., ..< x,
Mooresville N.C. 2811.5 At t
Subject: NOTICE OF DEFICIENCY
Compliance Evaluation Inspection
Gough Econ, Inc. W' TP AUG 0 2 2004
NPDES Permit No, NCO058084
Mecklenburg County, N.C.
�a
Dear Mr. BrldgemanAR
S
Our ORC, Mr. Steven Lambert, offers this explanation of the method used to
determine the effluent flow from our system to the receiving stream:
I . The operator examines the dosing tank level to determine if the tank is full or
not. The dosing volume of the tank is 549 gallons (.000549 MG).
2. If the dosing bell is exposed, a discharge dose has occurred and released 549
gallons (000549 MG). This figure is reported on the operator's records and
reported on the DMR.
The ORC contends that this is more accurate than "catching off' an effluent
measurement with a bucket and stopwatch. A permit modification being an extreme measure
to remedy this problem, the ORC will comply with the "catch —off" method of flow
measurement beginning with the August 2004 reporting period. You may contact Mr.
Lambert at 704-546- 594 or 704-657-8847 for any other information you may require,
Respectfully Submitted,
ough Ec
J)"
David P. Risley
President & CE7/"��
cc: Rusty Rozzelle, MCDEP
Steven Lambert, GEI ORC
o:\rvpadata\dpr\letter\ncdenr.Inspect 2004.doc
Gough Econ, Inc. P.O. Box 668583 Charlotte NC -8583 Tel, 04.399.4.501 Fax [phone]

\N A
William G. Kmv% jr- Secretary
'olinn l)cpnTimcw or i., vironment a"d Natural kesourom
North C. ar
AlanVN'. Klinvk, r. L Director
-H DivWoo orWater Quality
colH. sullow rxcpulS- Director
Divusion of W, aw Quality
July 23, 2003
CERTIFIED MAIL
RETURN RECEIPT MQUESTSD
Mr. David Risley, Vice President 7003 2260 00013550 2226
Gough Econ, Inc.
P.O. Box 668583
Charlotte, NC 28266-8583
SUBJECT: NOTICE OF DEFICIENCY
Grough Econ, Inc. WWTP
NPDES Permit No. NCO058084
Mecklenburg County, NC
Dear Mr. Risley:
On June 28, 2004, Mr. James P. Wilson of the Mecklenburg County Water Quality Program
Rozzelle of MCWQP at 700 N. Tryon Street Suite 205, Charlotte, N.C. 28202.
If you have any questions concerning this report or any other matters, please do not hesitate to call
Mr. Richard Bridgeman or me at 704/663-1699.
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc: Rusty Rozzelle, MCWQP
DRG/jpw
File: WQ GoughEcm0058084.nov.604 4
XNR
service
1-877-623-6748

VV1, united States Environmental Protection Agency, Washington , DC 20460
NPDES Compliance Inspection Report
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Mooresville Regional Office N
Donn Approved ,
OMB No, .2.(40-Cif 03
Approval Expires
:l'e5
Section A. Natiotal Datit stcn Rodin
Transaction Code NPDES Permit No YR./MO/DAY Inspection Type Inspector Facility Type
N 5 NCO058084 04/06/28 C C �
Remark
Ins ector: Mecklenburg Coon Water uali Pro
Inspection Work Days Facility Self -Monitoring Evaluation Rating BI QA ....Reserved....,....,,.
0.4 3 N N
c
Name and Location of Facility inspected:
Permit Effective Date.
EntrFa
9:00 January 1, 002
Gough Econ, Inc. WWTP
Exit
Center Grove Lane:
10:1Expiration Date:
Mecklenburg County, NC
DateAugust 31, 2006
June
Name(s) of On -Site Representatives Titles)Phone No(s),
Mr. Steve Lambert t Operator in Responsible Charge ;(ORC)1(704) 546-2594'
Name and Address of Responsible Official. Title:
Mr. David Risley "Vice President, Manufacturing
Gough Econ, Inc.
P, 0. Box 668583 Phone No. Contacted?
Charlotte, North Carolina 28266 (704) 399-4 01 yes
��
'nS: � 4 -.. ..: L.z .., a.�Cy'yy�:,4c c� `:' . `'•C -�vv . �Lk
�"\<ai. �. �C:S"�\,1
�#4. S�zZ y�yV,. ,:..: y. ^:D \�.�y.
!� Y.� c+P M`'1�\�� `�ahf�� .., ,�y �
.,..aZ..K_. , :..u�ei.\.l ,, as•n�EEalun ...D ,� +V8H.1;, `�a.`.,'�4Sk���?` "� 44`�i\�` £�v`���3`�e,�a, ���,�t`'^�
"
Permit Flow Measurement � f�perations &Maintenance � Sewer Overflow
Records/Reports ® Self -Monitoring Program Sludge Handling/Disposal El Pollution Prevention
Facility Site Review M Compliance Schedules ❑ Pretreatment Program gr ❑Multimedia
Effluent/Receiving Waters Laboratory ❑ Stormwater
s
.N , a)'� \S ..;• d..., 9 . �" ''-.`ecton<:il~ 'UJE �4.,+K,+Ai CmA f'3 Qe'
v
All areas are rated satisfactory unless otherwise indicated. See Attached Sheet(s) for Summary
Signature(s) of Ispector(s):
Agency/Office/Telephone:
Date:
MCWQP/[phone]
July 19, 2004
James P. Wilson, II
Signature of Reviewer:
Agency/Office
Date.
EPA. Form 3560-3 (Revised 3-85) Previous Editions are Obsolete'

The facility was last inspected by MCWQP on June 13, 2003. A Notice of Violation
issued on July 28, 2003.
PERMIT:
The 0.0012 MGD facility consists of septic tank, dosing tank, surface sand filter with
PVC distribution manifolds, recirculation pump, effluent tablet chlorination, effluent tablet
dechlorination,and cascade'aeration.
The current permit issued on January 1, 2002, and expires on August 31, 2006.
e Operator'in Responsible Charge (ORC), Steven L. Lambert, maintains a North
Carolina Operators Certification Grade IV (Certification number 6081), which is acceptable for
the class of the facility.
The facility discharges to an unnamed tributary to the Catawba River, which is a Class
WS4V & B CA water in the Catawba River
RECORDS/REPORTS:
Discharge Monitoring Reports (D 7s) were reviewed for the period May 2003 through
tenance and self-monitoringof the fac'
only discharges effluent episodically. At the time of inspection the facility
sction.
W MEASUREMENT:
of sampling ."." This means that grab samples and flow measurenient should occur concurrently.
RATING: Unsatisfactory

SELF -IV,
Discharg
,)A(U
,RY:
rule Analytical performs analysis of effluent samples. The laboratory is certified
the State of No Carolina to perform analysis on all parameters specified in the
;vifle Analytical wasnot evaluated under this inspection.
RECEIVING WATERS:
ceiving stream exhibited no signs of detrimental impact at the time of inspection.
;charges to an unnamed tributary to the Catawba River, which is a Class WS-IV &
i the Catawba River Basin.
TORING PROGRAM:
noted:
1. One (1) Ammonia (NH3 as Nitrogen) exceedance* in violation ofmontruy average
maximum permit lin* was reported for the month of February 2004. A Notice of
Violation was issued.
2. One (1) Ammonia (NI13 as Nitrogen) exceedance** in violation of monthly average
maximum permit limit was reported for the month of April 2004. Issuance of civil penalty
assessment pending.
3. One (1) Fecal Coliform, exceedance in violation of daily maximum permit limit was
reported in November 2003. A Notice of Violation was issued.
Ammonia (NH3 as Nitrogen) exceedance, occurred just before the facility changed the sand
filter media due to overabundance of organic matter.
Ammonia (NI13 as Nitrogen) exceedance, occurred just after the facility changed the sand
filter media. The ORC speculates that there was not a sufficient population of bacteria
present to adequately treat the first dose.
RATING.- Unsatisfactory
OPERATIONS & MAINTENANCE:
The current overall operating strategy of the ORC appears acceptable for the size and type
of the facility; although the lack of wastewater the facility treats appears to allow the sand filter
bed to dry out occasionally, which may impair the functionality of the system.
SLUDGE HANDLING & DISPOSAL
Sludge removal is completed by Liquid Waste on an annual basis in or around September
of each year Liquid Waste was not evaluated under this inspection.

Michael . uY> invernor °
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
.flan W KliR E. Director
Division of Water Quality
ColH. SullinsDeputy Director
Division of Water Quality
.tune 2, 2004
7003 2260 00013550 1939
Notice of Violation - Effluent Limitations
Gough Econ, Inc. WWTP
ICES Permit No. NCO058084
NV-2004-LV-0302
Mecklenburg County
Dear Mr. Risley:
wing parameter:
hm Parameter Renorted Value 'Limit
001 Ammonia Nitrogen.. 4.3 rng/L. 4.0 mg/L FIN
Remedial actions, if not already implemented, should be taken to correct any problems. The
contact Sonja Williams at 704/663-I699. _ s
If you have questions concerning this matter, please do not hesitate to contact Mr. Bridgeman or me
at 704/663-I699.
Sincerely, a
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
cc: Point Source Compliance/Enforcement Unit
Rusty Ro Celle, MCWQP
MR
IclihC arolina
j
' c xr l IJivss an of W v, vloor c R 919 titiutft 42 vide NC 281? S 7fi4� 663-1699 Customer Service
I-8'77-623-674

/04
71,75-;v
4,41 r�wy "4 V, -4
�.J 3 A' 13" "' 3 8",",

June 2, 2004 �?
r
. John Leslie J U N
Division of Water}lit"
919 North Main Street
Mooresville, NC 28115
� U
Re: (Dough Econ, Inc.
NCO05 0 1
Ammonia Violation
Filter Bed Repairs
Our filter bed repairs were completed April 22, 2004. The block walls of the Ater bed
were sealed with portland cement, filter underdrain depths adjusted to plan specifications and Full
media replacement was performed. Flow began'entering the bed, once the septic tank and dosing
tank finally Filled..
Effluent was sampled on April 27, 2005 and revealed a high ammonia nitrogen result.
This impacted the monthly average calculation, which exceeded the 2.0 g.1L limit.
The April D VIR will show this violation and will outline the fact that the new media in
the Ater bed apparently had not produced enough biology to reduce the ammonia. It should also
be noted that the primary biological treatment in the septic tank mayhave been impacted due to
the necessity of pumping the contents out before filter repairs could be initiated.
Subsequent monitoring is encouraging, as results are very low. Should you require more
information, feel free to contact me at 704-546-2594.
Steven Lambert, OR ,
Gough Econ, Inc .. g a ,

pppppp� 00I)EPT.01--F-,kIVIR0NMB#Y
AND .AL RESOURCES
From. Steven L. Lambert E °°» � `N L
154 Sunflower Road
Statesville, NC 2862
To: Mr. John Lesley
Division of Water Qualm
19 North Main Strut � �,
Mooresville, N 2811
�. � N
Subject: Gough Econ, Inc:
NCO0 8084
Mecklenburg County
Repairs and Maintenance
As outlined in our conversation of April 6, 2004, the subject facility is showing periodic
non-compliance with Ammonia Nitrogen limits. The sand filter is loaded to the paint that it
ponds excessively and requires a complete media change to alleviate both problems. There i
also concern at the block walls of'the filter will allow water to exit the containment onto the
ground during dosing periods.
Gough Econ, Inc, the permittee, has contracted with McCall Brothers, Inc. to perform
these tasks to get the filter to full working order:
Pump out the septic tank and dosing tank to allow for storage of sewage ding the work.
This will prevent the possibility of discharge for approximately five to six days. Should it
be necessary, more septic pumping will be performed to prevent discharge. The pumped
liquid will be hauled to the City of Charlotte.
Remove dosing and re -circulation piping to access the filter media.
Remove and dispose of filter media.
Seal the inside walls of the filter against dosinater exiting e filter canto the ground.
Replace the Ater media with new gravel and sand.
Reinstall dosing and re -circulation piping.
Allow normal operation to continue.
The permittee has met maintenance requirements and made improvements in the past to
better insure compliance. This is a continuation of their commitment to be good environmental

stewards.
Should you require further
2594or at 04- -884' .
Sincerely,
teven rc, vrcc
tough Econ, Inc.
riformation, you may contact Steven Lambert at ' -546-

V A t ichael F. Easley, Governor
William G. Ross It, Secretary
y North Carolina Department ofEnvironment and Natural Resources
r
} I Alan W. Klimek, P E. Director
Division of Water Quality
Cohn H. Sullin& Depury Director
Division ofIA'ater Quality
February , 2004
CERTIFIED MAIL
RETURN RECEIPT JESTED
. David Risley, Vice President 7003 220 0001 3491 1647
Gough Econ, Inc.
P.O. Box. 66858
Charlotte, NC 28266-8583
Sub, Notice of Violation - Effluent Limitations
ns
Gough Econ, Inc. WWTP
DES Permit No. NCO058084
NOV-2004-LV-0063
Mecklenburg County
Dear Mr, Risley:
A review of the November 2003 self -monitoring report for the subject facility revealed a violation of
the following parameter:
DIN Parameter Reoorted Value Limit
001 Fecal Colifo 560/100 ml 400/100 ml FIN
Remedial actions, if not almdy implemented, should be taken to correct any problems. The
Division of Water Quality may pursue orcement actions for these and any additional violations. If the
violations are of a continuing nature, not related to operation and/or maintenance problems, and you
anticipate remedial construction activities, then you may wish to consider applying for a special Order by
Consent. You may contact Richard Bridgeman of this Office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Mr. Bridgeman or me
at 704/663-I699.
Sincerely,
ten:.
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
cc. Point Source Compliance/Enforcement Unit
Rusty Rozzelle, MCWQP
RMB
i7amalty Division of Water Quality, mooresvine Regional Office, 919 North Main Stmet, Mooresville NC 29115 [phone]

12-18-1995 10:49pm FROM GOUGH ECOIN. INC. (ENG) 704 392 8706 P'I
November 23,2003
Mr. John Leslie
Division of Water Quality
919 North Main St.
Mooresville, N.C. 28115
Subject: Gough Econ, Inc.
NPDES Permit No. NCO058094
Fecal Coliform Violation
Remedy Report
Dear Mr. Leslie:
an normal TRC.
•
dosing.
We believe this action will keep the TRC up and Fecal Coliform in compliance. Contact
me at 704-657-8847 if you require more information.
Steven Lambert, ORC

Mr
Go
P.
Ch
July 12, 2002
David Risley, 'Vice President
ugh Econ, Inc.'
>. Box 668583
irlotte, NC 28266-883
SUBJECT. Compliance Evaluation Inspection
Gough Econ, Inc.. WWTP
NPDES Permit No. NC O0580 4
Mecklenburg County, ty, NC
it Mr. Risley.
d report should be self-explanatory.
to call Mr. Richard Bridgeman or me at 704/663-16 .
-Sincerely,
� D. Rex Gleason, P.E.
Water Quality Regional: Supervisor:..
re
y Rozzelle, MCWQP
ra
4tt5 084.602
Y
919 North Main Street, Mooresviile NC 281 w6 Phone (704) 66:- 9!
FAX [phone]

Transaction Cod
N 5
Inspection Work Days
0.5
Water Cor
e NPDES No. Yr/M4
NC0058084 02/0
InSDCCtOT: Meckle,
Facility Evaluation Rating 131
3 N
-tion Type Inspector Facility Type
C C 2
ivalitv Pro2rarn
QA .......... Reserved ...........
N
Name and Location of Facility. Inspected: Entry Time- 9:00 am Perudt Effective Date:
June 24, 2002 January 1, 2002
Gough Econ, Inc. NWrIT
Center Grove Lane Exit Time/Date: 9:50 am Permit Expiration Date:
Mecklenburg County, NC June 24, 2002 August 31, 2006
-- ---------
Name(s) of On -Site Representative(s)/Title(s)/Phone No(s)/Fax No(s):
Mr. Steve Lambert / Operator in Responsible Charge (ORC) / [phone]
Name and Address of Responsible Official: Title. Vice President, Manufacturing
Mr. David Risley
Gough Econ, Inc.
P. O. Box 668583 Phone No: [phone] Contacted? Yes
Charlotte, North Carolina 2826( 1
Permit �/ Flom, Measurement V' Operations & Maintenance Sewer Overfl
✓ Records/Reports vl" Self -Monitoring Program Sludge Handling/Disposal Pollution Pr
Facility Site Review Compliance Schedules Pretreatment Multimedia
✓ Effluent/Receiving Waters o"Laboratory Storm Water Other:
See Attached Sheet(s) for Summary. All areas rated satisfactory unless otherwise noted.
Name(s) and Agency/Office/Telephone No: Date:
D. Will Autry MCWQP / [phone] June 27, 2002
Date:
S ignature of Management QA Reviewer: Agency/Office/Phone & Fax No: Date:
I
EPA Form 3560-3 (Rev. 9-94) Previous editions are obsolete

GENERAL:
The facility was last inspected by MCDEP on May 25, 2001. A Notice of Violation
Compliance Evaluation Inspection report was issued on June 15, 2001.
PERMIT:
The 0.0012 MGD facility consists of a septic tank, dosing tank, surface sand filter with
PVC distribution manifolds, recirculation pump, effluent tablet chlorination, effluent tablet
dechlorination, and cascade aeration.
The current permit was issued on January 1, 2002, and expires on August 31, 2006.
The Operator in Responsible Charge (ORC) maintains a North Carolina Operators
Certification Grade IV, which is acceptable for the class of the facility.
The facility discharges to an unnamed tributary to the Catawba River, which is a Class
WS-IV & B CA water in the Catawba River Basin.
Ca PORTS:
Discharge Monitoring Reports (DMR's) were reviewed for the period April 2001 through
February 2002. The reports appeared to be properly completed. The ORC maintains detailed
logs and calibration records relative to the operation & maintenance and self -monitoring of the
facility.
FACILITY SITE REVIEW:
All of the existing components of the facility were in service and appeared to be operating
properly at the time of the inspection.
FLOW MEASUREMENT:
Flow measurement is accomplished by the ORC visually noting the level in the dosing
tnnl- t-nob tirm- hp xAc4c tbp� fnnilitv TbA 4Qt-11;tX7
and based upon the level of the dosing tank the ORC determines how many times the dosing tank -
has discharged.
LABORATORY:
Analysis of effluent samples is performed by Statesville Analytical. The laboratory is
certified (NC #440) by the State of North Carolina to perform analysis on all parameters
specified in the permit. Statesville Analytical was not evaluated under this inspection,

ppr"
FLUENT/RECEIVING WATERS:
The facility was not discharging during the inspection, and the receiving stream exhibited
no signs of detrimental impact. The facility discharges to an unnamed tributary to the Catawba
River, which is a Class WS-TV & B CA water in the Catawba River Basin.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (DI R's) were reviewed for the period April 2001 through
February 2002. The reports indicate that all parameters are being monitored at the required
frequency and locations, except for the following:
1. Upstream and Downstream Temperature was not reported for the month of August 2001.
2. Upstream and Downstream Dissolved Oxygen was not reported for the month of January
2002.
ORC will be submitting amended DMR's to address these issues.
The facility and site appeared to be properly operated and maintained. There was an
,ssive amount of algae on the upper surface of the sand filter. The ORC said that it would be
oved and new sand added in the very near future. The current overall operating strategy of
?RC appears acceptable for the size and type of the facility.
JDGE HANDLING & DISPOSAL
Sludge removal is completed by Liquid Waste on an annual basis in or around September
ach year. Liquid Waste was not evaluated under this inspection.
VER OVERFLOW:
Please be advised that pursuant to Part 11, Section E of your NPDES permit and North
Mina Administrative Code (NCAQ 15A 2B .0506 (a)(2), any failure of a collection system,
tping station or treatment facility resulting in a bypass without treatment of all or any portion
fie wastewater shall be reported to the appropriate regional office (Mooresville Regional
ce 704/663-1699) as soon as possible but no later than 24 hours from the time the perinittee
une aware of the bypass. For spills/bypasses which occur in Mecklenburg County, it is
iested that MCDEP be notified at 704/336-5500. Spills occurring on weekends or holidays
be reported by calling the North Carolina Division of Emergency Management at 919/733-
1662-7956, or 800/858-0368. A written report shall also be provided within five (5)
- time of the incident. The report shall contain a description of the bypass, and its
period of the bypass, including exact dates and times, and if the bypass has not been
the anticipated time it is expected to continue; and steps taken (or planned) to reduce,

"qq
SEWER OVERFLOW: (Continued)
maw+.— a,- 5--.' — — v ax.c VAA"� uc.rw. 11uL xvuuxl auxicLu4. VV"L%I.La 1J.1"ZK UVI 1;;TVI vuu.
An adequate spill response for those spills reaching surface waters should include an evaluation
downstream of the point at which the spill entered surface waters to determine if a fish kill
occurred. The evaluation should also include the collection of upstream dissolved oxygen and
pH measurements for background information and dissolved oxygen and pH measurements at
multiple points downstream of the entry point to document any negative impact. Failure to report
the bypass of collection system, pumping station or treatment facility subjects violators to
penalties of up to $25,000.00 per day per violation.

pr')'t � -- K��.
July 12,
Mr. David Risley, Vice President
Gough Econ, Inc.
P.Q. Box 668583
Charlotte, NC 28266-8583
SUBJECT: Complia
Gough
NPIE
Mecle
Dear Mr. Risley:
12
Evaluation Inspection
i, Inc. WWTP
chit No. NCO 58 84
County, NC
hesitate to call Mr. Richard Er dgeman or me at 704/66 -16 '.
-Sincerely,
f
t
-�; � D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc: Dusty Rozzelle, MCW P
DRG/d a
File: WQ 0058084.60
R C. Division & Water Quality 919 North Main Street, Mooresville NC 28115 Phone [phone]
FAX (7D4) 663-SW

Water Compliance Inspecti
NC Division of Water Quality / Moore
ion Code NPDES No. Yr/Mo/Day
5 NCO058084 02/06/24
Remarks
InsDector: Meek-lenbure Countv
Xork Days Facility Evaluation Rating BI
.5 3 N
m Approved,
1B No, 204MOS7
)roval Expires 8-3 1 -98
spection Type Inspector Facility, Type
C C
er Ouahtv Program
QA..........Reserved ...........
N I
ion of Facility Inspected: Entry Time: 9:00 am Permit Effective Date:
June 24, 2002 January 1, 2002
WWTp
re Exit Time/ 9:50 am Permit Expiration Date:
anty, NC June 24, 2002 August 31, 2006
itte Represent ative(s)/Title(s)/Phone No(s)/Fax No(s):
rt / Operator in Responsible Charge (ORC) / [phone]
— ----------
ess of Responsible Official: Title- Vice President, Manufacturing
---- ------
Phone No: [phone] Contacted? Yes
Carolina 28266 1
v riow measurement uperations &. ivimmenance
zwwer vvernow
v' Self -Monitoring Program ✓ Sludge Handling/Disposal
Pollution Prevention
IV Compliance Schedules Pretreatment
Multimedia
Waters v Laboratory Storm Water
Other:
. .. . . ...
(s) for Summary. All areas rated satisfactory unless otherwise noted.
r"(s) of Inspecto Agency/Office/Telephone No:
Date:
MCWQP / [phone]
June 27, 2002
Date:
Management QA Reviewer: Agency/Office/Phone & Fax No: Date:
titions are obsolete

facility was last inspected by MCDEP on May 25, 2001. A Notice of Violation
Evaluation Inspection report was issued on June 15, 2001.
.d cascade aeration.
it permit was issued on January 1, 2002, and expires on A
,ina Operators

ENT/RECEIVING WATERS:
W16111iffiffim.
inspection, and the receiving stream exhibited
rges to an unnamed tributary to the Catawba
e Catawba River Basin.
,re reviewed for the period April 2001 throug
,h
aters are being monitored at the required
is not reported for the month of August 2001
i02.
will be submitting amended DMR's to address these issues.
riONS & MAINTENANCE:
he facility and site appeared to be properly operated and maintained. There was an
9
amount of al ae on the upper surface of the sand filter. The ORC said that it would be
and new sand added in the very near future. The current overall operating strategy of
appears acceptable for the size and type of the facility.
E HANDLING & DISPOSAL
ludge removal is completed by Liquid Waste on an annual basis in or around September
ear. Liquid Waste was not evaluated under this inspection.
OVERFLOW:
lease be advised that pursuant to Part 11, Section E of your NPDES permit and North

C
SEWER OVERF
multiple paints downstrea
the bypass of collection sy
penalties of up to $25,000
.00 per clay per violation.

0
KIN
" Daniel J. Dougherty
531 Stice Shoals Road
Shelby, N.C. 28152
License # 27155
May 25,2003
Dear Mr. Lambert,_
Due to a heavy work schedule, I test resign from my duties as Back Up CRC for the
Gough h Ec ►n Waste Treatment Facility, permit # NC O058084. The effective date is
0/03.
Very truly yours,
Daniel J. Dougherty
CC: Technical Assistance and Certification Unit, Raleigh, N.C.
DENP,Mooresville Regional Office. Attn: Sonja Williams

krofin l
1vlron ent
urces
Ruality
xovernor
Secretary
ire for
�`V#RCiM�.Ne RN G7 tVK1 LJtCA4- t"S«"9CJF'Cir
March � ,
ISLEY,VICE PRESIDENT
C 28266
SUBJECT: PAYMENT ACKNOWLEDGEMENT,
CIVIL PENALTY ASSESSMENT
GOUGH ECON INCORPORATED
MECKLENBURG COUNTY
PERMIT NO: NCO058084
LV U3-142
x , y _ •'.. _.. _t^ _t_ _ _i_ w T _ I)INZ A _'_ a1-- ..«..•.. 4 -4r d l '224 AC ..«-.ti-.ie _A P­
If you have any questions, please call Bob Sledge at [phone].
Sincerely,
Coleen Sullins, Chief
Water Quality Section
4 ..
Cc: Enforcement File : LV 03 -142
C)ffice upry
Central Files
_
1617 Mail Service Center, Raleigh, NC 27699.1617 Telephone 919-733- U Fax '919-733-%12
An Equal l Opportunity Afiar ' tive Action Employer 50% r cl 10 % post -consumer paper

�-; Ow
Michael F, Easley ')i,
Governor
William G. Ross, Jr., secretary
North Carolina Department of Environment and Natural Resources
Alan W, Klimek, P.E., Director
Division of Water Quality
February 21, 2003
FIED MAIL
M RECEIPT REQUESTED /VUI 2510 0005 0287 9047
rid P. Risley, Vice President
-con, Inc.
x 668583
-e, NC 28266-8583
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215.1
Gough Ec
Case No.
Mecklenb
M
)n, Inc. WWTP
,V 03-142
Irg County
a

s- For
For
215. 11
discha
violati
limit I
TOTi
85.45 Enfor4
$ TUTS
Pursuant to G.S. 143-215.6A(c), in detertnii
into account the Findings of Fact and Conclusions
282.1(b), which are:
o
rent costs.
AMOUNT DUE
g the amount of the penalty I have taken
,aw and the factor-, set forth at G.S, 143B-
iance.-
over which the Environmental Management Commission has regulato
authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following
1. Submit payment of the penalty:
Fayment should be made chrectly to the order of the Department of Enviromnei
and Natural Resources (do not include waiver form). Payment of the penalty w
not foreclose her 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
4Z#vhr"*t+ o ccrr ift rt r-tknvi"a+ fnr- r-,mrm*iaev*tin "r- rn;+;rratinn ;nAtidina -A Ap+ailod
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 violations-,
(c) the violations were inadvertent or a result of an accident,
(d) the violator had been assessed civil penalties for any previous violation;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of
Ms. Coleen Sullins
Water Quality Section Chief
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
her appeal of the penalty to the Environmental Management Commissum'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 ypurr request for remission,

OR
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 15 }B of the
Forth Carolina General Statutes. You must. -
File your original petition with the
Office of Administrative Hearings
714 Mail Service Center
Raleigh, North Carolina 799-714
and
Mail or hand -deliver a copy of the petition to
Mr. Dan , Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 7i99-1 01
Office at 704/ 3- l699.
''(Da t e
'(Dated D. Rey on l'.i .
Water Quality regional Supervisor
Mooresville Regional Office
Division of Water Quality
ATTACHNENTS
cc. Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files / attachments

U11111VIII4.04IU UPCtt
Parameter
- Fecal C oli o
denotes assessment of civil
Attachment
002
u4onthly Average Limit Violations
Reported Value
Limit
Units
3.1.
2.0
mg/L
Daily Maximum Limit. Violations
Reported Value
Limit
Units
700 *
400
/100 ml
enaltys.

STATE OF NORTH CAROLINA
COUNTY OF Mecklenburg
IN THE MATTER OF ASSESSMENT
CIVU, PENALTIES AGAINST
Gough Econ, Inc.
PERMIT NO, NCO058084
AND NATURAL RESOURCES
ADMINISTRATIVE HEARING
AND STIPULATION OF FACTS
FILE NO, LV 03-142
for
)f the Division of Water Quality dated
ied, desirina to seek remission of the civil
from the receipt of the notice of assessment.
This the day of 20(
BY
ADDRESS
TELEPHONE

EFFLUENT
NIMES PER IT No
DISCEARGE NO,1�1 N, 10 N71 H YEAR -2,�,j Z,
FACILITY NAIME
CLASS UNTY
PERATOR IN RESPONSIBLE C�I-HAdRGE (OR
Z, P 01�
Y PHON7E
GRADE::a —4 4-
CERTIFIED LABORATORIES (1)
CHECK BOX IF ORC IIAS CHANGED
PERSON(S) CdLLF-Cn'sG SAMPLES, 7
Mail ORIGINAL and ONNE COPY toy�
ATTNCENTRAL FILES
DIVISION OF WATER QUALITY
(SIGNATUREOF PERATO lNRESP0NSlBLF-CrL-kRGF-', DATE
1617!%UL SERVICE CENTER
ICY THIS SIGNATURE, I CERTIFY TILAT THIS REPORT IS
RALEIGH, NC 27699-1617
ACCI:RATE AND COMPLETE TO THE BEST OF )n'KNONVLEDGE-
-40050 0001j:1 00400 50060
00310 i 00610 0051 31616 00300: 0060-0110%65!
FLOW
ENTER PARAMETER CODE .ABON'E
z
7- NAMEAND UNITS BE]
I NF
7
Z z
IIRSjl 11RI YiBrN' I MGD 0 C I-a—LGl I NIG,L NIG,L NIGA, ;:/100MI-1 VIGIL %J.-
MQL i
Ll
t
loi
%
_74
IF 6 111 AJ
,40 0 y
241/2,, 2 </o
v
I
2611o5o 2�;, '74- 4/o
6�17'7
J
AVERAGE
1 -7 0 SIS 6-,4 5-1 �'e 1-7. '14
7.6
"ell
ZJ
---n,57

All monitoring data and sampling frepuenc
If the facility is noncompliant, please comment on corrective acti=
and a time -table for improvements to be made.
ze�13 Aj !: sue.. ' ` L+ _4-2'
9 M'
'µ /} �/ kn, e+^ww. � ✓r"a ., r..M F +i �" /"M.4:
"I certify, raider penalty of law, that this document and all attachme
'tting false information, including the possibility of fine;
Pei
11
4
(Rs
i NOT meet permit requirements
NoncornDliant
g taken in respect to equipment, operation, maintenance, etc..'
, !/f
r
3uzrib�r
Ea
0 1067 Nickel
010 7 Silver
1
designated in the reporting facility's permit for reporting data,
zsit facility and document visitation of facility as required per 15A NCAC- G .0204,

A. Ia) EFFLUET
'LIMITATIONS AND MONITC
Such discharges shall
HITS
Dissolved Oxygen2
Fecal Conform 200/100 ml
(geometric mean)
Total residual Chlorine
Temperature (°C)
Temperature perature (°C)
p3
Footnotes:
1. Upstream samples above discharge point.I
discharge point.
2 e daily- average dissolved oxygen effluent
. The pH shall not be less than 6.0 standard t
ere shalt be no discharge of floating solids or
rG1dld`Yiidi itti
?/Month
21Month
Weekly
400/100 ml 2/Month
17}tgtl. Meek
Daily
T - FINAL
•
:ollected approximately 'ately 200 feet below
than 6.0 mg/L.
trd units.
amounts.

Fast Track Worksheet
'i
sough Econ Incorporated
l
Statutory Matt urn Via, i
r iot ti "
massments for previous Total Assessment Factor
1.00
Total
Number Penal Batt
Assessed Parameter Violation Violation Factor Total Penalty
mmonia
roae itn nthlyl
air
Total Penalty
Percent of the MeAtmumPenatty
Authorized by G.S. t-215.6A. '50
d
nents
ared by Richard Bridgeman

State of North Carolina
Department of Environment �
ang Natural Resources
Division of Water Quality
Noma
Michael F. Easley, Governor
Wiliam G. Ross
Jr., Secretary MCA n; D E N mKft,
Alan Klimek, P , .E., Director NORTH CAROUNA DEPARTMENT OF
NV1RbNMNT ANC# ATIiRASw 4URc
� February ', 2003
MR. RICHARD DONALDS N
101 NORTH TRYON ST /STE 1
CHARLOTTE, NC 28246
SUBJECT. PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
CHARLOTTE GATEWAY VILLAGE
MECKLENBURG COUNTY
PERMIT NO: NCO086517
TX 01- 008
Dear Mr. Donaldson:
This letter is to acknowledge receipt of check No. 3156 in the amount of $2,0 7.77 received eived from
you dated February 04, 2003. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations or Permits.
If you have any questions, please call Bob Sledge at [phone].
Sincerely,
7/� NC
DEPT. OF ENVIRONMENt
AUM'SOORCES
Coleen Sullins, thief 00MOVILLE, R cw fit OFFICE
4A Water Quality Section
k
a
Cc Enforcement Fi TX 01-008
Central Files i' LIT
1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax 919.733.%Il
An Equal Opportunity Afr►r ' tive Action Employer 51' recycl 10% post-consuiner paper

CERTII
RETLTF
Mr. Ric
Cousim
11 Nol
Charlot
Emu
ECEIPT REQUESTET? l
d Donaldson
gal Estate Corporation
Tryon Street, Suite 1700
'forth Carolina 28246
Notice of Violation and Assessment (itCivil Penalty for Violations
General Statute 143-215.1(a)(6) and NPDES Permit No. NCO0865-'
Cousins Real Estate Corporation l`reatment System
Mecklenburg County
TX 01-00
D
s letter transmits a Notice of Violation and assessment of civil penalty against C
Corporation (the Company) in the amount of�2,097.77 ($2,000 civil penalty +
t costs).
tic toxici
Permit No. NC0086517, Z`he Company's toxicity self -monitoring reports for { ctober thrd
)er 2000 revealed the following violations.
October 2000 Fail
November 200 F a l i
Based upon the above fact(s), I conclude as a r a+t r tat letw that the Company violated the
onditions or requirements of NPDES Permit No, iw00 ,6517 and NCGS 143-215.1(a)(6)' i
ner and extent shown above. A civil penalty in <x.. `:,once with the maximum established
143-21 . (a)(2) may be assessed against a Sacs violates the terms, conditions
-tents of a permit required by NCGS 14 - 15� i
Jdress. Telephone (704) 66 i- Location:
Main Street Fax (04) 663-i. . 919 North Main Street
:. NC 28115 Mooresville, NC 2811.1
An EqualOpportuni:.. %ftirmativeAction Employer zr)'f rec,,,:!.ed lt7%post consumer paper

discharging waste into the
of the permit effluent limit
month of October 2000.For of the (1) viols
and NPDES Permit No. N4
waste into the waters of the
permitted effluent limit for
month of November 2000.
$ '' f TOTAL C L PENALT
the maximum penalty aut
97.77 Enforcement costs.
0,%' 7, �'� TOTAL AMOUNT DUE
Pursuant to NCGS143-215.6A.(c), in determining the amount o
account the Findings of Fact and Conclusions of Law and the factors se
282.1(b), which are.
(1) The degree and extent of harm to the natural resources of the St
private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on a
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionall
(7) The prior record of the violator in complying or failing to camp
the Environmental Management Commission has regulatory our
(8) The cost to the State of the enforcement procedures.
Within thirty days receipt of this notice, you must do one of th
1. Submit payment of the penalty:
Payment should be made directly to the Department of Environ
(do not include waiver form). Payment of the penalty will not f
for any continuing' or new violation(s). Please' submit payment
Point Source Compliance/Enforcement
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
the penalty I have taken into
forth at NCGS 143E-
te,; to the public health, or to
x quality;
with programs over which 's
iority; and
2 ;
following:
lent and Natural Resources
recluse enforcement action
the attention of.
Jnit

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 that you believe establishes whether:
(a) ; one or more of the civil penalty assessment factors in NCCGS 14B-28. l(b) were b
wrongfully applied to the detriment of the petitioner; t
(b) the violator promptly abated continuing environmental damage resulting from the
violations;
(c) the violations were 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 infonnation to the attention of:
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
s
s
t: 1
Office of Administrative Hearings
714 Mail Service Center
Raleigh, North Carolina 27699-6714
and

and -deliver a copy of the petition to
Mr. Dan McLawhorn, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Date D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
Division of Water Quality
ATTACHMENTS
cc: Regional Supervisor w/attachments
Point Source Compliance/Enforcement Unit File w/attachments
Aquatic Toxicology Unit File w/attachments
Central Files w/attachments
JL

STATE OF NORTH CAROLINA " DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF MECKLENBURG
IN THE MATTER OF ASSESSMENT } WAIVER OF RIGHT TO AN
OF CIVIL PENALTY AGAINST )ADMINISTRATIVE HEARING AND
COUSINS REAL ESTATE, INC. WWTP } STIPULATION OF FACTS
PERMIT NO. NC0086517 )
FILE NO. TX d 1- 08
Laving been assessed civil penalties totaling for
violation(s) as set forth in the assessment document of the Division of `eater C, uality dated
the 'undersigned, desiring to seek remission of the civil penalties, does
as the day of 0
BY
ADDRESS
TELEPHONE

t
CIVIL PENALTY ASSESSMENT ADDENDUM
The Division of Water Quality (DWC)! issues/reissues NPDES permits with whole effluent toxicity
JET) limits. The current chronic toxicity test condition language requires perittees to conduct multiple
)xtctty test ranure wttn toltow-up multiple concentration toxicity testing(as contained in
single concentration toxicity testing, thereby influencing the level of DW 's enforcement
i
1. CHRONIC TOX CITY TES
• The first test of the quasi
value (Chi') test.
• If the pass/fail test fails a
Violation (NOV) is issue
conducted over the follo
will be accepted.
• A NOV will be issued fc
• Any civil penalties asses
may be assessed civil pe
limit is not achieved. DI
multiple concentration to
quarter. Chronic values
average is ? the chronic
monthly violations occut
permit limit, the facility
quarter in which compli
• NPDES Permits containi
—permit renewal to inludi
11. ACUTE TOXICITY TESTA
E** A NOV will e issued to
A civil penalty will be as
If you are unable to consistently corn
respective Regional Office to discuss the pas;
provides conditional compliance for permit p
may be issued in situations where facility ope
per 'ttee/DWQ and contains toxicity as a no:
Reduction Evaluation (T ), submit quarterl
that compliance with the whole effluent toxic
.nt for single concentration test results that do not meet chronic
ins are:
zch acute limit violation.
sed for any two consecutive acute limit violations.
with your toxicity permit limitation, you may notify your
lity of entering into a Special Order by Consent (SOC). The SOC
meters with which the facility can not consistently comply and
ion and maintenance are not in question. If a SOC is signed by the
mpliant parameter, you will be required to: conduct a Toxicity
RE progress reports and eliminate/reduce effluent toxicants so
limit can be demonstrated.

DIVISION OF WATER QUALITY - CIVIL PENALTY ASSESSMENT
Violator: COUSINS REAL ESTATE CORPORATION TREATMENT SYSTEM
County: MECKLENBURG COUNTY
Case Number: TX 01-008
ASSESSMENT FACTORS
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;
)not significant )moderately significant )significant
)very significant )extremely significant
2) The duration and gravity of the violation;
mot significant )moderately significant )significant
)very significant )extremely significant
3) The effect on ground or surface water quantity or quality or on air quality;
)not significant ( )moderately significant )significant
)very significant )extremely significant
4) The cost of rectifying the damage;
)not significant )moderately significant )significant
)very significant )extremely significant
5) The amount of money saved by noncompliance;
)not significant ( )moderately significant )significant
)very significant )extremely significant
6) Whether the violation was committed willfully or intentionally;
)not significant )moderately significant )significant
)very significant )extremely significant
)not significant mtoderately significant ( )significant
( )very significant ( )extremely significant
8) The cost to the State of the enforcement procedures.
)neat significant ( mioderately significant ( )significant
)very significant )extremely significant
Date D. Rex Gleason, P.E.
REMISSION FACTORS
Whether one or more of the civil penalty assessment factors were wrongly applied to the
detriment of the petitioner;
Whether the violator promptly abated continuing environmental damage resulting from
the violation;
Whether the violation was inadvertent or a result of an accident;
Whether the violator had been assessed civil penalties for any previous violations; and
Whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Date Kerr T. Stevens

:UI
ETT Environmental
CONTROL ORGANISMS
1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced 23 24 23 26 N/A 27 18 21 12 20 N/A 22
Adult (L)ive (D)ead L L L N/A L L ---- L IL L N/A L
Effluent ,%
T
TREATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
Complete This for Either Test Test Start Date
Collection (Start) Date 11-1800
pH 1st sample I at sample 2nd sample Sample 1 11-17 2000 Sample 2 11-21 2000
Control 7,8 7.8 7.8 &0 7.8 7.4 Sam2ltType tDuratlqn�
Treatment 2 8,0 81 7.5 7.5 8.5 8.2 Grab Comp Duration 1st 2nd
Sample I X Tox Tox
start end start end start end Sample 2 x Dilution Sample Sample
_j
D.O. 1 st sample 1 st sample 2nd sample Hardness (mg/L) 50.0
Control [;8,5 8,2 9,0 8.8 Spec. Cond. (}mhos) 232 517 518
Treatment 2 8.6 9.0 9.O 8.8 Chlorine (mg/L) <0�05 <0.05
Sample Temp. at receipt (*C) li7 V-
LCSO/Acute Toxicity Test
(Mortality expressed as %, combining replicates)
Concentration
Effi
Mortality starttend start/end r---r--i
LC50 = Method of Determination I I Control
95% Confidence Limits Moving Average Probit High Conc.
% 1 Spearman Karber Other pH D.0,
lorganism Tested Ceriodaphnia du is
DEM Form AT-1
5r-CI- U

•
5r.WAf
M
p
! 1 i
.a
a r
a
12
950 Y
0.009
<2
<5
<1
<1
<1
<3
<5
<1
2.8
<1
<0,1
471=o,00s
I <1
13;
14
15
16
17
'' 1200" Y
0.005
<1
<1
<1
18
19
20
21
2
25e.
26
27
29
30
`0.015
Avexa
0.010
<2
<5
<1
<1
<1
<3
<5
<1
1, 2.8
<1
71
<0.1 <0,005
<1
«r<
ammum
O.ti15
<2
<5
<1
<1
<1
<3
<5
<1
1 2.8
<1
<0.1
< .1 <0,€o5
<1
F
Minimum
ti.005
<2
<5
<1
<1
<1
<3
<5
<1
2.8
<1
<0.1
al <0.005
<1
�
::
m,ty
0.05
30.0
71.E
i1.0
8.85
DFTM Form MR-
(Revised 12/94)

ity Status: (Please check one of the following)
iata and sampling frequencies meet permit requirements
All monitoring data
Wrective actions being taken in respect to equipment, operatic
Chronic Toxicity failures.
00010
Temperature
00556
Oil
00076
Turbidity
00600
Tot
00080
Color (Pt -Co)
00610
Air
000.82
Color (ADMI)
00625
Toi
Nil
00095
Conductivity
00630
Nii
00300
Dissolved Oxygen
00310
BODs
00665
To
00340
COD
00720
Cy
00400
pH
00745
Tol
00530
T=d Suspeded
00927
Tol
Residue
00929
Toi
00545
Settleable Matter
00940
Tot
ORC must visit facility and document visitation of facility as required per 15A NCAC 8A.020
If signed by other than the permittee, delegation of signatory authority must be on file with the
(2) (D)•
5/31/00
Permit Exp. Date
50060 Total
Residual
Chlorine
murn
ZJJ
benzene
481
Toluene
260
MBAS
516
PCBs
050
Flow
33-5083, extension 581 or 534.
mated in the reporting
5) (B).
)er 15A NCAC 2B.0506 (b)

EFFLUENT
'ER,',IITN( NCO086517 DISCHARGENO. 1 MONTH November YEAR 2000
Y NAME Garewav Vllase CLASS COUNTY Mecklenburz
'OR IN; RESPC)NSIBLE CHARGE (CORC) Eric Donnedy G E I PHdNE (r04 )357-8600
ED LABORATORIES (1) Prism Laboratories, Inc. (2) ETT Environmental, Inc.
OX IF ORC HAS CHAINGED PERSON(S) CO ECTING SAMPLES Eric Donnelly
NAL and ONE COPY to:
ORAL FILES Fy,
'IRON; ENTALN NAGEMENT (SI , PERA IN RESPONS CE)`° ',-D r. Df
BYTHIS SIGNATURE, I CERTIFY THAT THIS REPOR
ice Center ACCURATE AND COMPLETE TO THE BEST OF MY:) NOWLE GE.
C 27699
50050 0010
f
;
iI
OW
Enter
Pa amcter Code
l 1
Above
N=e and Units
Below
•'
w
... ,W
INF
as
E
c v
a
ER
HRS HR.S f YIN
iv1GI)
m1zI
rnz/1 uq/1
uqll
UZ/t usz(i ueli
UkIl
UZ/1 ue/1 m i mvrl MZ1 UZ/1 P%F
1f
3 71 S
Y`
An"
i
t 10001
Y'
0,008
31
f
I
(I( Q1Q
11f f
=i
tr i
13
14f
151 800
Y
0.001
161 1
171 1020
Y
0.013
<2
<5 <I;
<I
<1 <3 <5
<1
5
<3
<0.1 <0.1 0,005
77
1°I
21 1330
N
0.010
211
22f
f
23
24..
261
�7
28i
31�
Averai e
0.009
<2
<5 <1
<1
<1 <3 <5
<1
5
<l
<0,1
M x
0.(ii3,'
<2
<w <1
<1
<1 <3 ; <5
<1
MIYBY1Titim
0,001
<2
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rtl
<1 <3
Comp. (C) / Grab (G)
4ionWv Urnit
k
0.05
30,0
71.E
I I.b
8,85
nt-M zZ..— rtAn_, ,
R^vr cd I2194S

All monitoring data and sampling frequencies meet permit requirements
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
tify, under penalty of law, that this documentand all attachments were prepared under my direction or supervision in accordance
a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
ry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
marion submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
,ries for submitting false information, including the possibility of fines and imprisonment for knowing violations,"
Cousins real Estate Corporation/ Charlotte Gateway V-Mage, LLC
of Law Engineering and Environmental Services, Inc.
on behalf of Charlotte Gateway V'dlaze, LLC
Permittee (Please print or type)
-D�-'A—t i
Si re of Permittee" IDate
incepenclenct: ti—ciitcr Ivi IYU11 utdcC4
I
Address
Phone Number
Permit Exp. Date
PARAMETER CODES
)010
Temperature
00556
Oil & Grease
00951 Total Fluoride
01067
Nickel
50060
Total
)076
Turbidity
00600
Total Nitrogen
01002 Total Arsenic
01077
Silver
Residual
)080
Color (Pt -Co)
00610
Ammonia Nitrogen
01092
Zinc
Chlorine
)082
Color (AI MI)
00625
Total Kieldhal
01027 Cadmium
01105
Aluminum
Nitrogen
)095
Conductivity
00630
Nitrates/Nitrites
01032 Hexavalent Chromium
01147
Total Selinium
71880
Forrmddeh,(de
)300
Dissolved Oxygen
01034 Chromium
31616
Fecal Coliform
71900
Mercury
)310
BOD,
00665
Total Phosphorous
32730
Total Phenolics
81551
Xylene
)340
COD
00720
Cyanide
01037 Total Cobalt
34235
Benzene
X00
pH
00745
Total Sulfide
01042 Copper
34481
Toluene
)530
Toni Suspended
00927
Total Magnesium
38260
MBAS
Residue
00929
Total Sodium
01045 Iron
39516
PCBs
)545
Settleable Matter
00940
Total Chloride
01051 Lead
50050
Flow
neter Code assistance may be obtained by calling the Water Quality Compliance Group at [phone], extension 581 or 534.
monthly average for fecal coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
''s permit for reporting data.
C must visit facility and document visitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B).
;igned by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506 (b)

Permit No. NCO086517
STATE OF NORTH CAROLINA
DEPARTMENT OF: ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In;compliance with the provision of North Carolina (general Statute 143-215.1, other 'lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Cousins Real Estate Corporation
is hereby authorized to discharge wastewater from a facility located at
Gateway Village
800 Block -West Trade Street
Charlotte, North Carolina
Mecklenberg County
to'receiving waters designated as Irwin Creek in the Catawba River Basin
in'accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, III, and IV hereof.
T'his permit "t shall became effective April 1, 1999.
This permit and authorization to discharge shall expire at midnight on May 31 2000.
Signed this day March. 29, 1999.
Original Signed By
David A Goodrich
Derr T. Stevens, Director
Division of Water Quality
y Authority of the Environmental Management Commission

Permit No. NC00865),,�'
•
•
�apqanese
•
E
11114, 1
Notes:
1. Sal
2. Th(
1 If IfWITw
4hi
There -:
'bie foam in other than trace amounts,

Fast Track Worksheet
Case Number
iC 01 008
Facility Name
CC US`INS REAL ESTATE/GATEWAY VL
Permit Number INCO086517
Previous Case
in the Last
Statutory Msximun'
Per violation
000
two years
Number of Assessments for Previous 6 C Ns 'Total Assessment Factor
*1 02
0 3 Q 4 0 5 0 6 1.00
1.00
Exit
C:
Total
Number
Number
Penalty/ Assessment
Violations
Assessed Parameter Violation
Violation Factor
Total Penalty
Exceed whole
' 1000 1
$1000.00
effluent toxic!
1
Exceed whole
1000
$100.00
effluent toxicit
Grand Total Penalty
$2401.00
Percent of the Maximum Penalty
Authorized by G.S. 143-21.6A.
Comments

State of North Carolina
e art enl. of E virc e t
ang Natural Resources
Division of Water Quality
Michael F. Easley, Governor
Wiliam G. Ross
Jr., Secretary D E N
Alan Klimek, E .E., Director NoIRTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
February 7, 2003
MR. RICHARD DONALDSON
101 NORTH TRYONT /STE I
CHARLOTTE, NC 28246
SUBJECT: PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
CHARLOTTE GATEWAY VILLAGE
MECKLENBURG COUNTY
PERMIT NO: NCO086517
TX 01-019
Dear Mr: Donaldson
This letter is to acknowledge receipt of check No. 3156 in the amount of $3,086.63 received.from
you dated February 04, 2003. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed, Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations or Permits,
If you have any questions, please call Bob Sledge at [phone].
Sincerely,
111
1
Coleen Sullins, Chief' `
Water Quality Section
Cc: Enforcement Pile # : TX 01- 19
a
.ra
Central piles
1 17 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]
yin Equal Opportunity Affirmative tive Action Employer 50% recycle&l0% post -consumer paper

NNA
'6
co t-
y
CE-RTIFIED MAIL
Ti GL`IP",.
W.•*chard Donaldson
Cousins Real Estate Corporation
•�
ichael F. ley SF
Governor
William G. Fuss, Jr.,Secretary
North Carolina Department of Environment and Natural Resources
Kerr T. Stevens, Director
Division of Water Ouality
June 1, 2001
Charlotte, North Carolina 28246
SUBJECT: Notice of Violation and Assessment of Civil Penalty for Violations of NC
General Statute 143a-215.1(a)(6) and NPDES Permit No. NCO086517
Cousins Real Estate Corporation Treatment System
Mecklenburg County
TX 01-01
Dear Mr. Donaldson:
This letter transmits a Notice of Violation and assessment of civil penalty against Cousins Real
Estate in the amount of $3,086.63 (3,000 civil penalty + 86.63 enforcement casts).
This assessment is based upon the following facts. A review of the facility's toxicity self -
monitoring data from January through March 2001 has been conducted:. The review has shown Cousins
Real Estate to be in violation of the 90% chronic toxicity effluent discharge limitation found in NPDES
Permit No. NCO086517. Cousins Real Estate's toxicity self -monitoring reports for January through
March 2001 revealed the following violations.
January 2001 79.4% (chronic value)
:February 2001 fail
March 2001 <30% (chronic value)
Based upon the above fact(s), I conclude as a matter of law that Cousins :Real Estate: violated the
terms, conditions or requirements of NPDES Permit No. NCO086517 and NCGS 14 - 15.1(a)(6) in the
manner and extent shown above. A civil penalty in accordance with the maximum established by
N.C.G.S. 143-15.6A(a)(), may be assessed against a person who violates the terms, conditions or
requirements of permit required by NCGS 14-15.1a)r
NMrNR-
Customer Service Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115 PHONE [phone]
1 800 633-7748 FAX [phone]

Based upon the above findings of fact and conclusions oflaw, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the Director of
the Division of Water Quality, 1, D. Rex Gleason, Division of Water Quality Regional Supervisor for the
Mooresville Region, hereby make the following civil penalty assessment against Cousins Real Estate:
For 1 of the one (1) violation of NCGS 143-
215. 1 (a)(6) and NPDES Permit No. NC0086517, by
discharging waste into the waters of the State in violation of
the permit effluent limit for chronic toxicity during the
month of January 2001.
6� C)
For of the (1) violation of NCGS 143-215. 1 (a)(6)
and NPDES Permit No. NC0086517, by discharging waste
into the waters of the State in violation of the permitted
effluent limit for chronic toxicity during the month of
February 2001.
$ For of the (1) violation of NCGS 143-215.1(a)(6)
and NPDES Permit No. NC0086517, by discharging waste
into the waters of the State in violation of the permitted
effluent limit for chronic toxicity during the month of March
2001.
$ TOTAL CIVIL PENALTY
86.63 Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to NCGS 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 NCGS 143B-282. 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 violations;
(2) The duration and gravity of the violations;
(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 violations were 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 and Natural Resources (do
not include waiver form). 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 that you believe establishes whether:
(a) one or more of the civil penalty assessment factors in NCGS 143B-2 82. 1 (b) was
wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from the
violations;
(c) the violations were inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(c) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit this information to the attention of.
Ms. Coleen Sullins
Water Quality Section Chief
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 part of the original remission reguest considered by the Director and,

therefore, it is vM iWortant that you pre are a cg=lete and thorough statement in soport of
your request for remission.
OR
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
Of of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hand -deliver a copy of the petition to
Mr. 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 thirty 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 any continuing violation(s) may be the subject of a new enforcement
action, including an additional penalty. If you have any questions about this civil penalty assessment,
please contact the Water Quality Section staff of the Mooresville Regional Office at [phone].
Date D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
Division of Water Quality
ATTACHMENTS
cc: Regional Supervisor w/attachments
Point Source Compliance/Enforcement Unit File w/attachments
Aquatic Toxicology Unit File w/attachments
Central Files w/attachments
JL

CIVIL PENALTY ASSESSMENT ADDENDUM
The Division of Water Quality (DWQ) issues/reissues NPDES permits with whole effluent toxicity
(WET) limits. The current chronic toxicity test condition language requires permittees to conduct multiple
concentration testing upon a single quarterly failure to meet the chronic toxicity permit lima. Pe `trees with
ICES permits which contain "old" chronic toxicity pass/fail testing language will have the C7PTI N to respond
to any single quarterly toxicity test failure with follow-up multiple concentration toxicity testing (as contained in
the current language) or single concentration toxicity testing, thereby influencing the level of DWC 's enforcement
response:
NOTE,: Choosing to respond to a chronic toxicity `fail" result with a pass/fail test instead of conducting multiple
concentration toxicity testing during the second and third months of the monitoring quarter (monitoring quarter
defined by your permit) will result in enforcement for single concentration test results that do not meet chronic
toxicity permit limitations.
Important WET Enforcement Policy items are:
I. CBRONIC TOXICITY TESTING
• The first test of the quarter can be conducted as either a pass/fail test or a chronic
value (CV) test.
• If the pass/fail test fails or if the ChV is lower than the limit, then a Notice of
Violation (NOV) is issued and at least two ChV tests (one per month) will be
conducted over the following two months. As many analyses as can be completed
will be accepted.
• A NOV will be issued for ANY test result failing to meet the permit limit.
• Any civil penalties assessed will be based on performance over: a quarter. Facilities
y be assessed civil penalties for any month in which compliance with the WET
limit is not achieved. 'IWQ's enforcement response can be influenced by conducting
multiple concentration testing for the second and third months of the monitoring
quarter. Chronic values for all follow-up tests will be averaged arithmetically. If the
average is ? the chronic permit limit, then civil penalties will not be assessed for
monthlyviolations occurring during the quarter. If the average chronic value is < the
permit limit, the facility will be assessed civil penalties for each month during the
quarter in which compliance with WET was not achieved..
• NPDES Permits containing chronic toxicity pass/fail testing will be modified upon
permit renewal to include the new permit language.
11. ACUTE TOXICITY TESTING
• A: NOV will be issued for each acute limit violation:
• A. civil penalty:.will be assessed for any two consecutive acute limit violations.
If you are unable to consistently comply with your toxicity permit limitation, you may notify your
respective Regional Office to discuss the possibility of entering into a'Special Order by Consent (SOC). The SOC
provides conditional compliance for permit parameters with which the facility can not consistently comply and
may be issued in situations where facility operation and maintenance are not in question. If a SOC is signed by the
permittee/DWQ and contains toxicity as a noncompliant parameter, you will be required to: conduct a Toxicity
Reduction Evaluation (T , submit quarterly TRE progress reports and eliminate/reduce effluent toxicants so
that compliance with the whole effluent toxicity limit can be demonstrated.
W

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF MECKLENBURG
IN THE MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ADMINISTRATIVE BEARING AND
STIPULATION OF FACTS
COUSINS REAL ESTATE CORP. WWTP
NPDES PERMIT NO. NCO086517
FILE NO. TX 01-019
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, 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 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.
BY
ADDRESS
TELEPHONE
N1

hole Effluent Toxicity Testing Self -Monitoring Summary
APR MAY JUN JUL AVG S L P OCI NOV cc
REQUIRINENT YEAR JAN 11311 MAR
oshits Reall Estate -GatewiY—Niffilit fleno chr firn: 90% (grain) 1997
C0086517AX)l Regin!41111999 Nequency: Q TVF + JauAprJulOct + NonCoiupSingle is
aunty Mecklentserg Regiow Mkt) Suhhasia:CT834 1999 rail Fail pass NFVPass Fait Fag Fall
F: 0,050 2000 Pass NR pascall; Pass NFVFafl Fall 941
Qflr� 0 I%k'C(%):Io0 200t 79A Fall <30 Aft
V Pre 1997 Deal Available
LEGEND:
PERM -Perrult Requitrnsent Frequency Motouning frequency: Q- Quittrrly� W Monthly; BM- Bitnurchly; SA- Semiannually; A- Anuurdty� OW Only wtien discharging; 0- Discrinfinued utcuotoring mquirenne
Begin= IN"tourtubteluirad 7QIO= Peceiving, %arrarn low flow criterion (cfs) +=quarterly Months dun testing mustoccur- ex. Jan. Apt, Jut, Oct NonConti, = Cancer Compliance Re4uutulent
� = P, 'nil test AC - Acute Clip, -Chrunic
PF - Pennitted Mov (N GD) IWC% = Instremii waste concentration PT ass/1'
Data Notation: ( - Fathead Mintuiw* - Cern-japtuda sp.; illy - Mysid shrimp, Cliv - Chronic value, P - Mortality of stated Mrcentage at highest at - Perfunned by DWQ Aquatic Tox Unit; he - Had test
Peporting Notation: --- = Data not required; Nk - Not reported Facility Activity Status. I - Inactive, N - Newly Isruted(To connructy H - Active Imm net discharging; t-More data available for moth in questiato = ORC signature needed

, . 4 r .d #
Database pull only. Complete information may be found through file search, Cases with date assessed greater
an 7I1198 may be regional assessments. Some cases are still open for final agency decision, Cases labeled "LT
w TM" are violations of permitted effluent limits and/or monitoring requirements. No violations <20% over the threshold

FffiluentAquatic Toxicity Report Form/Phase 11 Chronic Ceriodaphnia
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Environmental Sciences Branch
Division of Water Quality
N.Q. DENR
161 Mail Service Center
Raleigh, NC 27699-1 21
t
JAN 2 C 5
73%
DENT Form AT-34Rev. 1r
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ENV nL: but:NCi:i ,S

Effiuent'Aquatic Toxicity Report Form/Phase 11 Chronic Geriodaphn a
Fallity. Gateway �/lllage
F'Ee# 001
County: Mlenlaurg
Labora l�erfor ing Tes
�
E.nvir
Comments:.
Signature crf y
Signature of
oaf all ei�lu♦erlt ireatmertt test organisms.
Tact Start irate Time
end [date Tirrre
Info 03/07/01 1630
03109/01
Sample Information
Sampler
Sample
Ccsn#roi
S#art Day2 Days
Start oay2 oay5
Collection Start gate
0106101
03109101
Treatment 901/6 900d0" 90%
control control control
Crab
grab
grab
pH Init. 6,40
7,79
Composite (Duration)
pH Final 7.91
7,78
Hardness (mglL)
48,0
0.0. Init : 6.4
8.i
Spec. Cond, (umhos.cm)
645
483
188
C.o. Final 8,1
6.2
Chlorine (mglL)
0 05
<0.05
Temp snit 24,9 241 24,0
24.9 24.7 24o
Sample temp, at Receipt
2,3
1 A
—7TZilj 24.4
24.7 24.0 24 4
e ,.°
i
Chronic Test Results
e;
Final Cant Mort, % o%
org
_% Cent 3rd Brood NA
1
2 :3
4 5
6 7
8 9 10 11 12 mean
Control Repro CV NA
Control # Young 0
0 0
0 0
f} Q1
01 01 0
none I none'I a 1
48 Hour Mortality
AK-It-L-
L L
L I L
L L
L L
none Inone I
Control two
0of10 1t}of10
,.
1
2 3
4 5
6 7
8 9 10 11 12 mean
Significant? No
Effluent % # Young 0
01 01
01 01
0 0
0 0 0 none none 0,0
Final Mortality Sign.
ro an
30.0o% Adult C)
77 I
C7 C7
L7 [?
i 7 10 Wane none 100%
30010 or
Re roduCtlon Anal ses
1
2 3
4 5
6 7
8 9 10 mean Repro LOSC=
<30% NOBC= <30%
Effluent % # Young 0
0
1 01
01 0-F-01
01
01 01 0 0.0 Method:
NA
gt Red Normal Dist?
no Method Koimogorm,
60.0%o Adult I
D`I
C7
I C7 I D I
D I C7 I
D C7 C? 1t1o°1a Statistic
NA Critical 1.035
Equal Var?
NA Method Bartietts
1
2 3
4 5
6 7
6 9 10 mean Statistic
NA Critical 1510
Effluent % # Young 0
0 0
0 0
0
0
0 0 0 0,0 NA
eo method:
80.0%o Adult 3
C? C7
C7 C7
C7
C7
10 10 D 100% ffuent as
A Critical
30%
NA 2.18
1
2 3
4 5
6 7
6 9 10 mean 60%
NA 2.18"
Effluent % #Young 0
01 01
01 0
01 01
0
01
0 ao 80°a
,. meu SUT.
N 2.18
NA ,
90.O10 Adult D
DJ
L DC7
i7
C7
10 10o°/a 10010
NA 2.18
overall Anglysis
1
2 3
4 5
6 7
8 9 10 mean Result ='PASS/
AIL or
Effluent %#Young 0
0 0
0 0
0
0
0
0 0 0.o Test LOSC:
-<30% NO C= <30%
100.0°o Adult D
C l- 7
DC7
l
J
C7 C7 100°� Chronic Value= 30%
1
MAIL. Environmental
Sciences Branch
To: Division of Water Quality
N,C, DENR
1621 Mall Service
Center
Raleigh, NC 7699-15 1
tX
DEM Form AT-3 Rev, 111 5

to
+:r

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
Compliant
t
AJI
monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
the facility, is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
Investit*ation into causes of Chronic Toxicity failure is currently underway. Permanent treatment system is scheduled to be installed
iar Avril 2001. Older existing° system coon c nents inav be the cause of failure.
"I crrti4,, under penalty oflaw, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on y
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
Cousins real Estate Corporation/ Charlotte Gateway Village, LLC
of Law Engineering and Environmental Services, Inc.
on behalf of Charlotte Gat v Y�illazt, LLC
Permutes (Please print or e)
WSie'o'TPLerr6a,0���� ate
ontpr 1 (ii N Trvrni csrretc tt f 704) -7755 5131d00
Permittee Address
r'none iv Der
PARAMETERCODES
00010 Temperature 00556
Coil & Grease 00951 Total Fluoride 01067
Nickel 50060 Total
00076 Turbidirv� , 00600
Total Nitrogen 01002 Total Arsenic 01077
Salver
Residual
00080 Color (Pt -Co) 00610
Ammonia Nitrogen 01092
Zinc
Chlorine
00092 Color(t1LaAH) 00625
Total Kieldnal 01027 Cadmium 01105
Al irium
Nitrogen
00095 Conductivity 00630
Nitrates/Nitrites 01032 13exava ent Chromium 01147
Total 8elinium 71880
Formaldehydi
00300 dissolved Oxygen
01034 Chromium 31.616
Fecal. Coliform 71900
Mercury
00310 BODs 00665
Total Phosphorous 32730
Total Phenolics 81551
Xylene
00340 COD 00720
Cyanide 01037 Total Cobalt 34235
Benzene
0 pH 00745
Total Sulfide 01042 Copper 34481
Toluene
00530 Total Suspended 00927
TotalMagnesmin 38260
MBAS
Residue 00929
Total Sodium 01045 Iron 39516
PCBs
00545 strdeabie matter 00940
Total Chloride 01051 Lead 50050
Flow,
Parameter Code assistance may be obtained by caffing the Water Quahty Compliance Group at [phone], extension 581 or 534.
The monthly average for fecal c€aliforin is to be reported ass GEOMETRIC mean. Use only units designated in the reporting
racilitl>'s permit for reporting data.
ORC muse visit facility and document visitation of facility as required per 15A NGAC 8A .0202 (b) (5) (B);
If signed by otherNtlian the permittee, delegation of signatory authority roust be on file with the state per 15A NGAC 2B .0506 (b)
(2) (D).

NPDESPERMITNO. NCO086517
DISCHARGENO. 1
MONTH Februaxy YEAR 2001
FACILITY NAME Gat y V31i1%
GLASS
COUNTY Mecklenburg
OPERATOR IN RESPONSIBLE CHARGE (C RC)-
Eric Donne !y-
GRADE I PHONE: [phone]
GER ED t RATORIES (1)
Prism Laboratories, Inc.
(2) ETT .Environmental, Inc.
CHECKBOXIFORC HAS CHANGED
PERSON(S) COLLE
PLES Donald Warren
MaH ORIGINAL and ONE COPY to.
A : CEh FILES
x
/
DIV.OFENVIRON N-rAL MANAGEMENT
(SIGNTATURE OF=AT0=RESP
µ
DENR
161`7Nlall Canter
BYTHISSICrNATURE,ICERTIFS` TTHIS #i, OURC
ACCURATE ACOMPL .TOTEIEBEST,Or MY EGA 0;:;:
AND
SIGH, NC 27699
a D
FLOW Enter Parameter Code
E " EFi: y Above
Name .and Units�
Below
"
,rl e INF 1
,.,
S
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CI r4 0 €n 0 c3 : i--
J
it
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` Facility Status: (please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
Compliant
All X
monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
If the facility is noncompliant, please comment on corrective actions being; taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
InvestiELtion into causes of Chronic Toxicity failure indicated system was not o eratingror erh": _De-vavaterin um s were not o eratinL
in auto. Electrical, circuits were fixed and punil2s were restarted. Permanent treatment systern scheduled to be installed
Mar A ril 2001. Gilder , also be the cause of failure.
"I certify, under penalty cif"law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for ;gathering the information, the ,
information submitted is, to the hest of my knowledge and belief,true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including l the possibility of fines and imprisonment for knowing violations."
Cousins real Estate Corporation/ Charlotte Gateway Village, LLC
ofLav, Engineerin" and :environmental Services, Inc.
on behalf of Charlotte Garewav Village, LI. C
Permittee (Please print or type)
Sirl tune of Perirree* ate
IM tN) 't ten t, ctrpnr t7 i 333-7755 5/31/00
Permrttee Address
PARAMETER CODES
00010 Temperature00556 -
Oil & Grease 00951 Total Fluoride
01067
Nickel 50060 Total
00076 'Tttrfi dirt' 00600
Total Nitrogen 01002 Total Arsenic
01077
Silver
Residual
00080 Collar (Pr -Co) 00610
Ammonia Nitrogen
01092
Zinc
Chlorine
00082 Color ( ;BSI) 00625
Total Kieldhal 01027 Cadmium
0110-5
Aluminum
Nitrogen
00095 Conductivity 00630
Nitrates/Nitrites 01032 Hexavalent Chromium
Oil i
Total Selinium, 71880
Formaldehyde
00300 Dissolved Oxygen
01034 Chromium
31616
Fecal Coliform 71900-
Mercury
00310 BODs 00665
Total Phosphorous
32730
Total Phenolics 81551
: ylene
00340 COD 00720
Cyanide 01037 Total Cobalt
34235
Benzene
00400 pH 00745
Total Sulfide 01042 Copper
34481
Toluene
00530 'Total Suspended 00927
Total Magnesium
38260
MBAS
Residue 00929
Total Sodium 01045 Iron
39516
PCBs
00545 Sett eabic, Matter 00940
Total Chloride 01051 Lead
500-50
Flog"
Parameter Code assis-lance mac' be obtained tag' calm the War,..- ivalin, Compliance Group at
(919) 7 : -JOss, extension 581 or 534
Tne monthh average for fecal colnorm is to be reported as a GEOMETRIC mean. Use only unit; ciesurnated In trae reporthr
facility's permit for reporting; data:
ORC must visit facility and document visitation of fadilin, as required per 15 A NCAC 8A.0202 (b) (5) (B).
If signed by other than the permittee, delegation of si naton, authority must be on file with, the
state per 15A N .AC :28.0506 (b)
(2) (D)•

•
50050
001911
FLOW
Enter Parameter Ct c
Above Name andUnits
:4
Below
z
INF
Z
rl)
Z
M
L)
URS MLS
YIN
MGD
mgIl
Mg1l
ugll
UgIl
ugll
UgIl
ug/I
-9/1
U911
-g1I
mg/I
mg/l
rng/I
ugA
P/F
2
3
4
-OMO
6 1130
N
< 5
77-
1
< I
<1
<5
<1
6.1
< 1
OJ8
OAS
<o,00s
<1
F
1 9 110201
N
1 07064
< I
< I
< I
10
11
121 1200
N
0.011
131 1
14
15
16
17
18
191
----1-1145
20
NT
0.011
21
22
23
24
.25
26 1340
N
0,012
27
28
291
3,01
311
---- -- -
Averne
0.00S
<2
<5
I
<I
<I
<L
<
<1
0.18 0,18
<0,0051
< I
Alaxirtlum
"12
<2
<5
<1
<1
<I-L<--,J-
<,5
1 < 1
1 6.1
1 <1
OAS 1
0.18
1 < om'51
<1
I F
Minimum
<2
<5
<1
<1
<1
<3
1 <5
<I
1 6.1
<1
0.18
0. 18
< 0,00
< I
F
G
G
C,
G
G
Comp� (U / Grab,tk.) ._. -.Y �-I I o I
Mitnthiv Limit 3CW 71,4 1 11j)
DENI Forni MR-1.1
(ReviseJ 12194)

, .. „•..: fi,��,; ,.m. .
-Facility Status: (Please elteeic one of the following)
All monitoring data and sampling frequencies meet permit requirements
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance:, etc.;
and a time table for improvements to be made.
Investication into causes of Chronic Toxiciry failure indicated system was not onerattnr� proneriv, lie-waterinc numns were not oneratin`,'
in auto, Electrical circuits were fixed and puT2s were restarted. Permanent treatment system installed and operational Aril 23, 2001.
Chrc nic4 Toxicity failure clue to faulty system components,
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, tion, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
Cousins real Estate Corporation/ Charlotte Gateway Village, l.LC
of Law Engineering and Environmental Services, Inc.
on 'behalf of Charlotte Gateway Village, LLC
Permittee (Please print or e)
t�
Signa - of Perrnittee** bate
One lndenendence Center 101 N. Trvon Street (704t .;3;-7755 5 31i00
Pernuttet Address Phone Number Permit Bxp, Date
PAR,VVIETER CODES
10 Temperature 0055E Oil & Grease 00951 Total Fluoride 01067 Nickel 50060 Total
76 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual
00080 Color (Pt -Co) 00610 Ammonia Nitroten 01092 Zinc Chlorine
82 Color (ADMt) 00625 Total Kieldhal 01027 Cadmium 01105 Aluminum
Nitrogen
00055 Conductivity 00630 Nitrates/Nitrites 01032 Ilexavalent Chromium 01147 Total Seiinium 71880 Formaldehyde
00300 Dissolved Oxygen01034 Chromium 31616 Fecal Coliforrn 71900 Mercury
0031() BOD, 00665 Total Phosphorous 32730 Total Phenolics 81551 Xylene
00340 COD 00720 Cyanide 01037 Total Cobalt 34235 Benzene
00400 pH 00745 Total Sulfide 01042 Copper 34481 Toluene
00530 Total suspended 00927 Total Magnesium 38260 MBAS
Residue 00929 Total Sodium 01045 Iron 39516 PCBs
00545 settleable Matter 00940 Total Chloride 01051 Lead 50050 Flow'
Parameter Cade assistance may be obtained by calling the Water (duality Compliance Group at (19) 73-5083, extension 581 or 534.
The monthly avera(,e for fecal coliform is to be reported as a G ONI TRIC mean. list only units desipnat-,6 in the reporting
tacihv, c permit tt>r reporting data.
O C must visit facility and document visitation offs-ihiy as required per 15A NCAC SA 0202 (b) (5) 113 .
* It sicced try other than the nermittee, deleaanon of sign; tore authority must be on iile with the.: state per '5.A NCA 2B .0506 (b)
(2) (lit`
x�

kwil
Permit No. NCO086517
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
1 A "I ') 1 Z 1 —+1,—
Management Commission, and the 1, ederal w aterronurion t-onuoi tu;L, 4b 4LUUJ,1UVU,
Cousins Real Estate Corporation
is hereby authorized to discharge wastewater from a facility located at
Gateway Village
800 Block -West Trade Street
Charlotte, North Carolina
Mecklenberg County
to waters receiving designated as Irwin Creek in the Catawba River Basin
tn' --nate
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
P si 1, 11, 111, and BT hereof.
This permit shall become effective April 1, 1999.
This permit and authorzation to discharge shall expire at midnight on, May:3) 1, 2000.
Signed this day March 29, 1999.
0riginal Sign6d By
David A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority, ofthe Environmcntal Management Commission

A (1). I I`l=LUFt+r LIMITATION AND MONITORING REQUIREMENTS - FINAL Permit No, NCO(
During ' � riod b clinninq on the effective date of file permit and lasting Utitil exlairalion, the 'ermitt e Is authorized to discharge from outfall serial nt
g the I
001. Such discl usi gtis shall be, limited and mor itored by the 1 ermittee e ,,c ified below:
"'' y��y'yy♦{ +0 iaCO.",W . ' k"A"."i'r r°� F.,to., v,i.. @.:14
$ rk
y
r `Mbtitfit y I"r+e" teiri ¢' ta'f l:�iattr�r
t �ver ge Maximum r,
Continuous Re order l r E
Flow 8,05 G Ural --�-E11191— - -
otal uslaerrded Residue _ —Monthly__ Greta
CII and Crease _Crete
�. _._�__...._. .�.�.._ 71.�1 ugll clMtartt
I en erne ._ ._mow .__. a Grab E
l l,t? ugll 2/Month
I"oluene _ Monthly Grab
I tlayltaerzeire __ _ _ Monthly Grab
ylene Monthly grab
We
l eit Butyl Fiber (M"rl=)
- Monthly grab
i, Cliloroetl�arr _ __ W _ Monthly Grata
Chlorotoi i ca Grab
_rof _ _.._ ._ _ __�..8,6 ug1! /Mond --
Tetrachtoroethene Monthly Grata
Trich aroethene Monthly . Grab
Iron _ __ __ Monthly Grab
Man9arre e Monthly Grab
t ead - Quarterly Grab
Chronic xl (axicity t __
Notes:
2 :tarr t f locati ansa - Effluent, I -influent skimmed from the surface f a quiescent zone {e.g., holding tank} ifpossible.abe discontinued after submitting
1 Ire grab sariilale for oil and grease Should be
c is not detected above laboratory quantit tion levels during the tits t eight sampling events, then lead n onitorirag may
If lead
written request and receiving subsequent approval front DENR,
4, C 11trarric. (t,'rat carl�rf�lirria} l' ll=arl to rc it Limit at 90 f� w refer to Special Condition A( ),
There shall he no discharge of floating solids or visible foam in other than trace amounts.

Supplement to Effluent Limitation and Monitoring Requirement
Should test ;data from this monitoring requirement or tests prfo ed the o Caroling
;M Division of Water er Quality indicate potential impacts to the receiving stream, this permit may be
re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions specified in the cited document, such as minimum
control organism survival, minimum control organism. reproduction, and appropriate
environinental controls, shall constitute an invalid test and will require immediate follow-up
testing to be completed no later than the last day ofthe month following _ g the month of the initial
conito

Fast Tack Worksheefi
Case Humber X ©1 t319
Facility Name
C ;tJ IN FI AL ESTATE/GATEWAY V
Permit plumber INCO086517
Previous Case _ Statutory Maximun
in the Last IYes per violation
two years
Number of Assessments for previous 6 DMRs Total Assessment Factor
0 1 0 2 0 3 0 4 t! 5 0 6
.ClC2
Total
Number Number
Penalty/ Assessment
Violations Assessed Parameter Violation
Violation Factor
Total Penalty
1
t chronic tox 1/61
Exceed whole
$1000 1
$10I OO
effluent toxicit
1
chronic tox 2/01
Exceed whole
$1000 '
$1000.0
effluent toxicit
1
] chronic to /61
Exceed whole
$1000
$1000.00
effluent toxicity
3
Grand Total Penalty
$3000.00
Percent of the Maximum Penalty
Authorized by G.S.143-1 6.6A.
Comments
EA for quarter 1/01-3/01. 1/01 79A , 2/01=Fail, 3/01= <30%; 90% chronic limit.
*'

February 11, 2003
;DY MILLER
TH TRYON ST /STE I
)TTE
SUBjECT. PAYMENT ACKNOWLED(
CIVIL PENALTY ASSESSNI
CHARLOTTE GTE .AY
MECKLENBURG COUNTI
PERMIT NO: NCO086517
TX 03.001
Miller:
any questions, please call Bob Sledge at [phone].
Sincerely,
I -Cole n Sullins, Chief
Water Quality Section
it File#: TX 03 -001
;naf Of fice Supervisor
1Is
7 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]'
qual Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

NGS 143-
Enforcement costs.
TOTAL AMOUNT DUE
(c), in determining the amount of the penalty I have to
usions of Law and the factors set forth at NCGS 143B-
k
Environmental Management Commission has regulatory authority; and
(8) The east to the State of the enforcement procedures.
Within thirty days receipt of this notice, you must do one of the following:
l . Submit payment of the penalty:

Based upon the above findings of fat and conclusions of law, and in accordance with authority provided
by the Secretary of the Department of Environment and Natural Resources and the Director of the
Division of Water Quality,1, D. Rex Gleason, Water (duality Regional Supervisor for the Mooresville
Region, hereby make the following civil penalty assessment against Cousins Real Estate.
' For , of the one (1) violation of NCGS 13-
215.1(a)(6) and NPDES Permit No. NCO086517, by
discharging waste into the waters of State in violation of
the permit effluent limit for chronic toxicity during the
month of July 2002.
S For of the one (1) violation ofNCGS 14-
215,1(a)(6) and NPDES Permit No. NCO086517, by
discharging waste into the waters of the State in violation of
the permitted effluent limit for chronic toxicity during the
month of August 2002'
S '_ For of the one (1) violation of NCGS 143-
215.1(a)(6) and NPDES Permit No. NCO086517, by
discharging waste into the wasters of the State in violation of
the permitted effluent limit for chronic toxicity during the
month of September 2002.
S To C'� C , 0
TOT PENALTY
$ 86.63 Enforcement costs.
:?
' TOTAL AMOUNT
Pursuant to NCGS 143-215.6A(c), in determining the amount of the penalty 1 have taken into
account the Findings of Fact and Conclusions of Law and the factors set forth at NCGS 14313-82.1(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 violations;
(2) The duration and gravity-ofthe violations;
() The ;effect on ground or surface quantity or quality or, on .air, quality; .
(4) The cost of rectifying the damage,
() The amount of money saved by noncompliance,
(6) Whether the violations were 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 -
Submit payment of the penalty.

or new violauvafks). raeusc buU11'Ut PaYLLIVUL av Luc eau viluuia V1.
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 flail Service Center
Raleigh, North Carolina 27 -161 i
OR
written request for remission or 'mitigation including a detailed justification for
est.
for remission or mitigation is hinted to consideration of the reasonableness of the
114 VI; LIIv P.+.kl""Y a au 0 II & LIIv 1..+AwFvl F L€vvLLLlty I—YV114v�.e 48:iE� a+1— B..F..,....u.---T — 6i -J -I 61;
vents contained in the assessment letter. Because a remission request forecloses the option
administrative hearing, such a request must be accompanied by a waiver of your right to an
iistrative hearing and a stipulation that there are no factual or legal issues in dispute. You
execute and return to this office the attached waiver and stipulation form d a detailed
nent that you believe establishes whether:
one or more of the civil penalty assessment factors in NCGS 143B-2 2 1(b) was
wrongfully applied to the detriment of the petitioner,
the violator promptly abated continuing environmental damage resulting from the
violations;
the violations were inadvertent or a result of an accident;
the violator had been assessed civil penalties for any previous violations,
payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
e submit this information to the attention of:
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
therefore it is very im ortant that vou Drenare a cola fete and thorough statement in su art of
our re uest for remission,
OR

File your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mr. Dan Oakley, General Cot
Department of Environment a
1601 Mail Service Center
Raleigh, North Carolina 2764
601
9r
Date D. Rex Gleason, I
Water Quality Rej
Monrewille'Recri(
11111 11'V­rIj_VIP_IN I I>
cc: Regional Supervisor w/attachmeats
Point Source Compliance/Enforcement Unit File w/attaclunents
Aquatic Toxicology Unit File w/attachmeras
Central Files w/attachmeats
JL
a new enforcement
I penalty assessment,
e at [phone].
Of-\
Nam

. Submit a written request for an administrative hearing:
f 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 A'nis tive Hearings
6714 Mail Service Center
Raleigh, North Carolina 27 r99-6714
and
Mail or hand -deliver a copy of the petition to
Dan Oakley, General Counsel
Department of Environment d Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Failure to exercise one of the options above within thirtV 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
Attomey General's Office with a request to initiate a civil action to collect the penalty
Please be advised that any continuing violation(s) may be the subject of a new enforcement
action, including an additional penalty. If you have any questions about this civil penalty assessment,
please contact the Water QualitySection staff of the Mooresville Regional Office at (704) 6 -1699.
ca ra
Date D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
Division of Water Quality
ATTACHMENTS
cc: Regional Supervisor w/attachments
Paint Source Compliance/Enforcement Unit File /attachments
Aquatic Toxicology Unit File w/attar eats

STATE OF NORTH CAROLINA
t-V"tTTkTlr-V ^I'- IL41'�f%T7T 1"�XMTTnf"
from the receipt of the notice of assessment.
This the day of
BY
ADDRESS
TELEPHONE

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
. NATURAL RESOURCES
COUNTY OF MECKLENBURG}
IN THE MATTER OF ASSESSMENT } WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ADMINISTRATIVE HEAR1NG'`
STIPULATION OF FACTS
COUSINS ESTATE CORPORATION )
}
DES PE T NO. NCO0865I 7 }
FILE NO. - TX 03-001
Having been assessed civil penalties totaling for violations 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, 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 clay of 2003.
BY
ADDRESS

1'ti►r PaceAnatyt
/224'
ASI �cieAnalyticalo
Phhi,o,
cent Aquatic ToMflq p6rt Form/Phase 11 chronic Gerlod'aphn a
..a
•�
"" �...
r
#..
< a «. a +..rays w{.
s a
1
N
N
N
Ib
i • . a .
a
Y
M
i
i A
r f
e
t
� i
oa
• a` 'a ca .a ,a
� �a1

Fast Track Worksheet
Statutory Maximun
per violation
for previous 6 DMRs Total Assessment Factor
40 0
Total
Penalty/ Assessment
enr tox-z5/uz hxceect wnoic,
effluent toxicity
chr tox-9/02 Exceed whole $1000 $1000.00
effluent toxicit
Grand Total Penalty 13000.00,
Percent of the Maximum Penalty
Authorized by G.S. 143-215.6A. 4.00
)mit,ted 7/02-9/02 AT report forms as a package on 1/3/03.

a
mimm
i
w
. , e,
� ��a I=
t Y, tom-- ULii utnartotte Uat wayyoiage, Llc (;0086517 I Mecklenburg
1 , s :8 _ 5, 84.4U

State of North Carolina
De 'art ent of Environment
an Natural ResourcesAfflil
Division ofWater (duality 00% MOW
Michael F. Easley, Governor a-1koff— N R
Willam G. Ross Jr., Secretary'
C W MrV
UanKlimek, .E., Director NORTH CAPOUNA DMPAF4MMM4T OF
November *7, 2002
. DAVID RISLE '
PO BOX 668583
CHARLOTTE, NC 28266
SUBJECT: PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
GOUGH ECQN INCORPORATED
MECKLENBURG COUNTY
PERMIT NO: NCO058084
LV 02-493
Dear Mr. Risley:
This letter is to acknowledge receipt of check No. 31822 in the amount of $1,085.45 received from
you dated November 04, 2002. This payment satisfies in full the civil assessment levied against
the subject facility and this ease has been closed.. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations or Permits.
If, you have any questions, please call Bob Sledge at 919) 33-5083.
Sincerely,
-f4l�oleen Sullins, Chief
Water Quality S ti )',
Cc. Enforcement File : LV tit-493 �
002
Central Files
>;
1617 Mail Service Center, Raleigh, NC 7699-1617 Telephone 919- 3 - 0 3 Fax 919-7- 12
An :equal Opportunity Affirmative Action Employer 50 % r ci 10 % post -consumer paper

\WN A
0
a Ile
co William
3� North Carolina Department of Environment a
i6wo-6 111C' Alan W. Klimek, Director
%W Division of Water Quality
goo,
October 7, 2002
70012510 0005 0287 0136
'ERTIFIED MAIL
XTURN RECEIPT REQUESTED
Ir. David P. Risley, V.P. of Manufacturing
rough Econ, Inc.
.0. Box 668583
harlotte, NC 28266-8583
I3it 4: Notice of Violation
Penalty for Violatio
143-215. 1 (a)(6) and
Gough Econ, Inc. )A
Case No. LV 02-49:
Mecklenburg Count
WTP
UNION
Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural Resources
and the Director of the Division of Water Quality, 1, D. Rex Gleason, Water Quality Regional
Supervisor for the Mooresville Region, hereby make the following civil penalty assessment
against Gough Econ, Inc.:
AA
NMrN—R
Customer Service Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115 PHONE [phone]
1800 623-7748 FAX [phone]

a
` `' '' For Z of the one (1) violation of G.S. 143-
215. 1 (a)(6) and NPDES Permit No. NC 0 8d84„ by
discharging waste into the waters of the State in
violation of the permit monthly average effluent
limit for Ammonia Nitrogen.
O o , � TOTAL CIVIL PENALTY
.5 Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty l have taken
into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 1438-
282.1(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 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;
d
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
d Natural Resources (do not include waiver firm ). Payment of the penalty will
not foreclose further 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 276-1617

. 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 d
a detailed statement which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 1 3B- 82.1(b)
were wrongfully applied to the detriment of the petitioner,
(b) the violator promptly abated continuing environmental damage resulting
from the violations,
(c) the violations were inadvertent or a result of an accident,
(d) the violator had been assessed civil penalties for any previous violation,
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh,'` North Carolina 276 -1 17
consiaerect by the virector and tt
complete and thorough statement
OR

i to contest any statement
petition with the
Off
671
Ral
and
Uail nr hn"A-AP14rAr tt oar%xr of fbo,^,-f;fif%" fti
Mr.
Der
160
Rall
M=
rent letter, you must request an
e form of a written petition to
mform to Chapter 150B of the
esources
lays, as evidenced by a date
ie, will result in this matter
--11-
the penalty.
Please be advised that any continuing violation(s) may be the subject of a new
enforcement action, including an additional penalty. If you have any questions about this civil
penalty assessment, please contact the Water Quality Section staff of the Mooresville Regional
Office at 704/663-1699.
7z
(Date) D. Rex GliLon, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
Division of Water Quality
ATTACHMENTS
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
RMB

Attachment
Gough Econ, Inc.
NPDES Permit No. N O058 } 4
Case Number LV 02-493
Limit` Violations, May 2002
Monthly Average Limit Violations
Parameter Reported Value Limit Units
Ammonia Nitrogen 2. 2.0 mglL
denotes assessment of civil penalty.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF Mecklenbure
IN THE MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN OF
CIVIL PENALTIES AGAINST ADMINISTRATIVE HEARING
AND STIPULATION OF FACTS
Gough Eton, Inc.
PERMIT NO. NCO058084 FILE NO. LTV 02-493
Having been assessed civil penalties totaling for
violation(s) as set forth in the assessment document of the Division of Water Quality dated
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 2002
BY
ADDRESS
TELEPHONE

_E _ , _.ry
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DWQ Form NS-t (01fO3)

Pemift NCOI
criod beginning on the effective date of the permit and lasting until e>.-piration, the PCrm
) discharge from outfaU 001. Such discharges shall, be limited and monitored by the Permi
INV:
IOU to].
•1! .11 16401111-341M
OWCEMED MMOOMMM
•
Dissolue t xygen, ral Emuem,
Upstream & Downstream
Fecal Coliform 200/100 ml 4001100 ml 2/Month Grab Effluent
�geometric mean)
Total Residual Chlorine 17pg/L 2/Week Grab Effluent
Temperature (CC) Daily Grab Effluent,
Temperature {CC) Weekly Grab Upstream & Downstream
pH3 2/ Month Grab Effluent
F-Qotnote,%,
1. Upstream samples above discharge point. Downstream samples shall be collected approximately 200 feet below
discharge point.
2. The daily average dissolved oxygen effluent concentration shaU not be less than 6.0 mg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Fast Track Worksheet
er' 2 93
ne 12ough Econ incorporated
ber PICO058084
ae Statutory M ximur
per violation
of Assessments for previous DMRs Total Assessment Factor �
JO 0 3 p 4D 05 6.
Total
Number Penalty/ Assessment
Assessed Parameter Violation Violation Fatter Total Penalty
NH3-N Monthly/Quarterly 1 00 1 $1000.00
av
Grand Total Penalty $1000.00
Percent of the Maximum penalty
Authorized by G.S. 143-216.6A. 4.
00
i
t
a

t 4
Addendum
of
A eN
NSESSMENT OF
NON�DisCHARGE OT.
FOR ELIMIN
NPDES PERMIT
DES Permit : NCO05808
Prepared For:
Gough Econ, Inc.
400 North Lakebr© k Road
Charlotte, NC"
Mecklenburg County
Prepared y:
TNENCO, Inc.
Mooresville, NC
April, 1997

This report was prepared by:
INENCO, Inc.
132 W. Statesville Avenue
Mooresville, NC 28115
[phone]
Jam s W. Gilpin, PE
Principal Consultant
James W. Gilpin, PE
///� Z'

Introduction
A report on possible engineering alternatives to discharge had been prepared in October, 1996.
This initial report partially fulfilled the requirements of the engineering work needed to satisfy
the Mate of North Carolina regulatory community, according to the letter sent from. NC
DEHNR to Gough Econ, Inc. of October 25, 1996. With this reply, NC DEHNR sent guidelines
for the preparation of a more complete report. While we cannot agree that all of the guidelines
are applicable to a very small business that generates and treats only domestic (sanitary) waste
water, we have prepared this addendum to -the initial report which further outlines the possible
alternative approaches to the treated waste water discharge. We will discuss each of the
paragraphs of the October 25, 1996 NC DEHNR letter in more detail. In addition, on
February 7, 1997, David Rimer of the Meckleburg County Department of Environmental
Protection conducted an inspection of the facility and its compliance history. This is located in
Appendix 6.
Discussion
11 unicipal ,Ve)verage Connection
There were several alternatives discussed in the initial report, a copy of which is attached for
ready reference as Appendix I . The first alternative is the possibility of discharging directly into
a sanitary sewer. The local sewer service is provided by the Charlotte Mecklenburg Utility
Department (CMUD. Numerous discussions have been held with CMUD in regard to future
plans. Discussions have been held with Mr. Allen Brown, an engineer with the department, and
with Mr. Bobby Spiers (704-391-51 9) who is the industrial and commercial Customer Service
Manager, and performs studies for future service.
Initial discussions were around the fact that CMUD plans to extend a sewer line along the north
aide of'1-5 and Performance Road which would serve the industries on that side of1-5. Please
note that hough Econ is on the south side oft- 5 and hydraulically down gradient. A lift station
l

Y
is planned for the low spot along the proposed run, which would be at the base of the same
creek into which Gough Econ now discharges their waste water. The first discussion explored
the possibility that Gough Econ could tie into this lift station. There are two primary road
blacks. (1) A separate small lift station would be required to pump the waste water to the
proposed larger lift station. Even. though Cough Econ is prepared to expend the funds necessary
for the construction, CMUD said they would not be interested in owning and maintaining
another small lift station. (2) The NC DOT will not allow waste water to be pumped underneath
an interstate right-of-way, even though this could be accomplished by piping through the
existing creek culvert. Therefore, connection to this line is not possible.
Additional discussions were held with CMUD during the past month. There has been a
reordering of priority for the construction of (a) the fourth runway at the Charlotte Douglas
International Airport, and (b) the construction of the western leg of the loop 1-485, from 1-77 to
1-85. The construction of the western leg has now been accelerated so as to be complete in the
1999 to 2000 time frame. The expected 1-85 terminus of this leg will be between Sam Wilson
Road and Tuckasegee Road. CMLTD is expected to extend sewer lines along this stretch of road
construction so as to accommodate probable industrial and commercial development in the
corridor. The expected completion date of the main sewer lines is now no later than January
2001. Also at that time, CMLTD proposes to extend the sewer line in a westerly direction down
the south side of 1-85 to service those businesses in the area, including Cough Econ. The actual
calendar date for lateral extension has not been specified, but should be relatively shortly after
main line completion.
e believe that connecting to the CNWD system would be the most attractive alternative, even
given the length of time needed to implement this solution. This alternative is between three and
five years away from implementation. Expected tie in costs would probably be in the range of
6,000. to 10,000, once the lateral extension had been completed.

I 4
The parcel measures about 450 feet by 350 feet, and is currently used as a storage area for
industrial machines and parts. With the set back requirements for spray irrigation, this addition
of this parcel still does not allow for spray irrigation, however, with the set back requirements
for drip irrigation, the addition of this parcel would allow for the development of about two
useful acres for drip irrigation, Because of the percolation characteristics (please see Appendix
3) and the limited amount of useful land, this option is less than optimal, but is viable. The
owner of the property was approached as to purchase of the property. He stated that he was not
interested in selling the property.
The property to the west is (a) very small, (b) is very steeply sloped, (c) quite rocky, and (d
empties directly into a tributary to the Catawba River basin. This land would be of no use for
drip or spray irrigation due to direct runoff.
To the south lies a large parcel of land, comprised of about sixty-seven acres (67 A.), This land
contained two ponds, both of which are shown on the map included as Appendix 2. If the
portion nearest to hough Econ could be utilized, then, with proper setbacks for drip irrigation,
approximately eleven acres (l I A.) would be necessary for an optimal drip irrigation system.
The land, however, appears to be currently in probate court. The present owners have not been
identified so as to proceed with possible purchase requirements.
,Pump and Haul
For the previous report a "pump and haul" alternative was discussed, however the costs
associated with this alternative need to be explored. Pump and haul would require temporary
storage of the treated effluent until a quantity sufficient enough could be removed and hauled to
a CMUD facility. A study of this option has been done, and quotes have been obtained.
A contract waste hauler was contacted, to haul the waste water to a CMTJD facility would cost
70 to 90 per gallon, for the largest volume that can be hauled, 3500 gallons, A tank would have
to be installed to accommodate a large volume of collected. water, This water would need to be
pumped to the tank from an installed sump area. The estimated installation and start up costs
4

k
for this alternative would be cr $15,000
15,000 annually.
Upgrade Existing System or Ammonia Reduction
The proposed permit limits for ammonia call for the reduction of ammonia in the treated and
discharged waste water. Additional process steps could be incorporated on the present waste
water treatment system so as to reduce the ammonia to the acceptable permit level. One process
calls for break point chlorination which would chemically neutralize the ammonia; however, the
allowable chlorine levels allowed in the permit will not allow this option to be explored without
expensive chemical neutralization. Another process calls for pH increase and extended aeration,
d subsequent pH adjustment prior to discharge. Our experience is that this system is difficult
to control, and can easily get out ofadjustment, further, the ammonia level reductions expected
by this process may not be at accepted permit levels. The pH adjustment procedure is not going
to be further considered at this time unless the ammonia levels can be expressed in daily weight
rates based on total flow allowable under the permit.
A%turnkey package process for arnmonia reduction has been explored, The process has a number
of steps, some of which are proprietary. The total cost for this process; based on a flow of up to
400 gallons per day, and including installation, is in the range of $85,000.
An ammonia 'filtration" system utilizing mineral resins is being explored for its use on this low
flow system. :Early estimates show installation and startup cost to be around $5000,00 . Early
calculations show that these resins would be capable of 100% removal, but the amount of
removal material compared to the number of gallons treated indicate that the cost will be around
0,00 for each 100 gallons treated. Long term costs associated with this option mare it less
than feasible,
5

Option
Existing
Sewerage
UpGrade
Cost Comparative
Five Year Costs
1 ,000
$22,500
$14000
$90,000
;Relocation @$200,000 @$3,600 $218,000
vaporation a $50,000 @40,000 $250,000
Surface Disposal @$35,000 + @$2,000 @$9500
if land were available Acreage: $50,000 est.
Based on the information gathered and presented here, the alternative that is most appealing to
Gough Econ, and most feasible is inclusion into the MUD system. This, unfortunately, is a
few years away. It is hoped that the current limits placed on the discharge can be Dept past the
date of November 1, 1997.
I Costs per Year
Ustall Costs

ti
Aftarwnrri
We believe the above discussion will satisfy the requirements of the engineering study. However,
there are several other points we would like to have considered by NC DEHNR during their
deliberations and permit monitoring activities:
1. All of the waste water generated is from domestic or sanitary sources. There is no process
water combined with the domestic waste water.
2. The average waste water discharge is 350 gallons per day from the facility. This is about
2 % of the maximum allowable flow of 1200 gallons per day.
3. The residual ammonia currently average 8.9 ppm, or about 5% of the previous allowable
ammonia level of 16 ppm. This level, however, is about 4.5 times the new permit level of
2 ppm.
4. At the expected flow discharge rate of 350 gallons per day, the total ammonia being
discharged is in the range of 0.025 pounds per clay. The new permit lever of 2 ppm at a
flow rate of 1200 gallons per day would allow 0.019 pounds per day of ammonia, and at
the off-season permit level of 4 ppm and a flow rate of 1200 gallons per day, the ammonia
discharged would be 0.038 pounds per day, to the basis of these calculations, we fail to
understand the impact of the ammonia on the entire Catawba River basin, We would life
to request a permit level which would be expressed in pounds per day rather than
concentration: in that we have taken many steps to reduce our water usage and discharge
rate.
7

APPENDICES

APPENDIX
Assessment of Non -Discharge Options
Report
October, 199

Na
ASSESSMENT OF
N�DISCHARGE OPTIONS
FOR ELIMINATION OAN
NPDES
As Required By the Permit)
Prepared Ftr:
Gough Econ, Inc.
400 North Lakebrook Road
Charlotte, NC
Prepared. By:
NN, Inc.
Davidson, NC

- -------- -
Introduction volume in agiven arnourn of time. This result is than extrapolated over a, 24 hour day
Under Part III Section E of NPDES permit issued to, Cough Econ. Inc:.., a request is and recorded for permit compliance, For compliance, this number Nvorks eod], because it
made fur an "en is based on known flow data and a, conservatively high estimate. However, for
in report evaluating alternatives to dischalroe," Thiso prtAirrunary
lo
study evaluates the feasibility of several alternatives, It is the intention cif this report to evaluating alternatives to discharge, the reliability of these nurnbers is in doubt. An
assumption must be maxle, and the future calculatic-ms, involving flow must hinge on this
not only satisfy the requirernents ofthe, J)erruit, but to truly recommend a. course of
action that would physically and econoinically allow Gough Econ tceliminate this costly
permit. Feasibility a-, it is rnentioned in Part III Section E is arsinned to be physical
feasibility. This assumption is based on the statement in Part III Section, E requesting
costing infc)rrnation on a new bill treatment waste water plant if "no feasible alternatives"
are available for discharge. Since the costs ofa, wastewater treatment plarawcould be in
the range of $100,000,00, anyafiernative less costly would be more economically feasiblc.
Currently the waste water generated by the facility, which is all domestic, is treated
through a septic tank whose effluent is foofished with a sand filter. The water is then
chlorinated using tablets, and directed down a cascading aerator. The treated effluent is
remarkably clean, and under normal conditions causes no adverse effects to a recening
water. Aliftc,ugh water is present year round, the creek receiving the discharge is
classified as a'zeru,' flow creek. In addition, the creek is a tributary to the Catawba, River
Basin. These waters are falling under more restrictive constraints as their use is
expanding. Therefore, it is evident that the state is requiring these evaluations in an
effort to forve a reduction of the pollution discharged into the ri,oT basin.
The septic system is designed with a rmucinturn capacity of] 200 GPD. This design
consideration is based on 45 employ yes with as estimated usage of 25 gallons each per
day. The facility currently works five days a week with one daily shift (,A'approxiniately
32 employ ees (30 men and 2 Nvorrien). The aetual flows are well below the maxiinum
assumption. It isa, recominendationof this report that at some future time a
representative vveek of operation be selected for, evaluation of the waste Nvater flows, An
additional note as to the flow through this system, the plant operator, Mr, Chip
Hutchins, stated that it is no -A unconinion for the septic system to reach a zero flow status.
Because of the rigid sampling protocol required by the permit, samples aj,,re at times
taken at the nearest collecticin locaticar to the, discharge. This location, however, is
before tire last two treatment steps of the plant, on the inlet side of the tablet chlorinator,
It is to,-c be noted that one of the design pluses of a septic system is its adaptation to
discontinuous operation. This flexibility does not exist within tire conditions of the
NPDES pernin,
Alternatives to discharge have been extensively researched. Several approaeftes to
disposal of the voiter have been, reviewed and the individual ideas condensed herein. A
brief description of the process involved in each alternative havealso been included.
Please m,-Ae that these alternatives have been evaluated fur their use for disposing the
effluent frorn the current septic system. Within each a1ternative, it may be possible to
eliminate some of the steps involved in the treatincrit, but this evaluation In no way is
one of primary treart-nent of the waste water.
al1c),,vable. Hows are currently measured as a condition of the NPDES permit. Because
the system has no for-unar), measuring device, flows are rnewsured by filling a knosoon
2

stringent than those for any other land application approach, These factors eliminate
rapid infiltration from the list of feasible options. Active evaporation can be a, capital intensive option of waste water disposal.
Evaporation alk,)ws for a reduction in volume that would exceed Residues frorn
the evaporator would most likely be non -hazardous and could be dried or solidified and
The last type of land application considered here is over land fk)w. This approach uses placed in the dumpster. Another consideration with an evapotatcn- is an energy source.
Electricity can be utilize, but power consumption would be high and this source may not
the surface of natural area to treat waste waters. Spray or drip irri�arion rnethods are be the most economically feasible. Natural gas or, propane may be a better enerrgy
use: to apply water on the top ofa, grassy slope. The waste water is applied at a, rate that
optimizes contact firne and flow. The water flows over the surfaceallowing natural source, Evaporation is energy intensive, in fact it takes approximately 100 gallons of
processes to treat the, effluent. Collection ditches at the. bottom of the slope are sorne propane to evaporate 500 gallons of water from 60'K An evaporator may also require
francs provided if tlowsaxe high cmough. Again this option is hampered by setbacks. air air permit application and possibly a long term air permit. Several evaporator
Also, the topographyof tire site leaves no slope,,., for application. Over land flow is not a manufactures have been contacted to estimate the costs of art evaporator. Costs range,,
feasible option. from $30,000 to $50,000, This exuberant cost alone, places a turn -key evaporator
outside the reahn offeasibility,
mauling
Another method of eliminating a diseharge is cc,llectionof the waste water in holding
tank and disposal via hauling to a CMUD facility. A holding tank of adequate size
would be necessary to detain the waste water, A collection basin and a level activated
pumping system would be required to transport the water to the holding tank. A tank
with the capacity, of 2 to 3 weeks of flow would allow for accumulation. A hauling
contractor was contacted and questioned about this task. The size of the haulers largest
tanker (3500 gallons) is a, constraint in the evaluation of this option. A holding uink for,
stability; arid distribution may be, necessary for, a land application process, Application
rates may not be high enough to allow for the in this case
accurnulation in the holding tank rnay still require hauling to a C)JUD facility,
Passive evaporation has also been considered. Unfortunately, as with land application
techniques a large, area would be required for effective evaporation. The land
constraints previously discussed would also effect this option. A passive evaporator is also
climate dependent. Our local climate would not be conducive to passive evaporation.
This option is not feasible.

Conclusions Afterward
The preliminary feasibility ofseveral optietris have been carefully considered vvith the For, the purpose of writing this report, the facility at Gongh Ex.on, Inc. was examined
pros and cons of each noted. Of the options cot i side red. few desei ve., further including a walk through of the plant, and the P-rounds. In addition, procedures ziii(i
consideration, Determination oftrue feasibility of these options is a ritulti-step process. records pertaining to the NPDES permit and the treatment systern have, been
This initial cc�risideration of possible applicable alternatives being lh(:Y first, step, exhaustively reviewed, It is the opinion ofthe INENGO, Inc. that Gough peon, Inc. is
-in exceptional industrial citizen. This facility's impact on the local environment is
1,,, d Applica tion minimal alworst, The lestingofthe effluent at theoutfall into the unnamed tributary of
Drip irrigation bay be a feasible alternative to discharge, jkccctrding the state regulations
controlling these options, an in-depth evaluation is required front both an agn.-moinist
and a soil scientist. The reports along vvith systern design requirernents would be
required fear the application for a permit. The conditions of such a permit are not
known, but is aswrned that the sampling requirements vvould be less than these for the
NPDES pentut. The land area available for drip irrigation at Gough Econ is
approxii-nately '/+ acre. Application of waste waters over this area would be equivalent
to less than 0,1 inches pet, day. Preliminary. evaluation indicates this option is fseisitfle.
Hauling
Hauling waste water from Gough Econ, Inc- to a. treatment facility is a viable stop gap
measure. However, long-term hauling is less practicaL The ci,stsassociated are
curnul.ative and could easily approach $10,000/year. Thisapproach also makes Gc)ugh
Econ. Inc. re lizint on a hauler for the service. Although long terin costs make it less
attractive,, this option is feasible.
Canneoirm to CMUD
the Catawba River has also revealed that Gough Econ, Inc. has been a good
environmental chizen. It is understood by us that elimination of this ouffiall is vearnted,,
however the outfall, up, and down stream testing indicates that the small flows from this
facility (500 gpd) inay be beneficial to the area ecology by diluting the pollutants corning
froni sources tip stream, as well as stormwater runoff froyn 1-85, In our opinions, Gough
Econ, Inc. should be allowed to keep the ourrent NPDES permit at previous pert -nit
discharge levels, if they so choose, until connection to CMUD seosers is possible.
This option is not only the rnist cost effective, it is the mca st preferred. Connection to
GM sewers is only a matter of nine. Industrial %maste water generators in the area are
NVai ting for CNIUD to make a ccmnection possible is feasible
9 10

APPENDIX
Adjacent Property Ownership

R
T1..
fr
P
ft#w is the • River.
Appendix�j* site. Please see e for USGS mapping,
fflel 1-85 and would ..d to cross Moorese
great��Titetosts associated with this type of outtall over such a
There is also a branch of Lake Wiley (Paw Creek) that extends to within approximately l
miles of the site, An outfall to this body of water would require the piping to be placed th
established neighborhoods, and negotiate Old Dowd Road and the main line of :Southern
Railways. Again, the costs associated with this type of outfall over such a great length ma
option not feasible. Finally, on the USGS maps two small lakes are evident on the proper
located south of Gough Econ. It is our understanding that these have been drained.
Cher Non -discharge Systems
The initial report outlined a possible drip irrigation system which was initially discarded di
(a) set back requirements, (b) percolation characteristics of the soil, and (c) the use of the
potentially available for drip irrigation for other purposes. However, NC DEHNR request
additional information on this alternative. Appendix 4 outlines the set back requirements
drip irrigation, and highlights the remaining land space for irrigation uses. It is very small.
DEHNR requested that a property search be made regarding the possible purchase of nea
laird for irrigation purposes. Appendix 3 shows the tests conducted at hough Econ for tl
evaluation of subsurface disposal. These test results are inferred for the alternatives that i
surface disposal, for Gough Econ and the surrounding properties.
Through the Mecklenburg County tax records, the surrounding property owners were ida
and their addresses obtained. As illustrated in the tax map, in Appendix 2, the adjacent pr
that may be available for drip irrigation is small. To the north of the site is I-8.5 and its associated
right-of-way. To the east lie established commercial and residential areas. One parcel in the
east-southeast direction may be probable for use. The parcel is approximately four acres (4 A:)
in size with no existing structures. It is owned by the neighboring industrial machine company.
3

Alternatives that with the correct engineering design this type of disposal method was possible. The
Where a recorm-nendation can be made, feasibility for each alternative is discussed. design would have to, meet the county's criteria. Exact regulations determining the
Factors outside of the cc)ntrol of Gough Ecom Inc. in several crucial alternatives shift the position and layout of a septic leach field have net yet been explored. However, the
prior disapproval from the county on this matter would be a hurdle to current
feasibility determinations. These factors will be discussed. It is also noted that this
evaluation is based on assumptions and calculaticars made by INENCO, Inc. The implementation, if an in-depth ewaluation of the site showed the leach field to be
discussion of each alternative has not been explored regarding the opinions of Gough possible. For this reason, it seerns that, this option is not feasible.
Econ, Inc, implementing any of these alternatives.
The connection of the facility to Charlotte -Mecklenburg Utilities Department's (CMUD)
sewers may eliminate the reliance of the facility on a. septic'treatment systern and may
allow direct discharge to the sanitary sewer. This option is hampered by the fact that
there are no accessible sewer lines in the vicinity of the Gough Ecom Inc. facility.
Several industries north of the facility, on the north side of 1-85 are currently lobbying
CMUD for inclusion to the sewer systern. However, in conversations with CMUD,
INENCO was told that there were no current plans to include the area. into the CMUD
rea.1m. Currently, the area is not part of the City of Charlotte. If the-, area Were
annexed, then inclusion into the sewer system would come within twci years of the
annexation date. Although this is one of the best alternatives to discharge, imminent
connection is not possible.
Leach HeldforSeptic System
Over1and Apphcation
Disposal of waste. water using land application methods is a very practical use of
resources. Reclaimed waste water can be used to provide water and nutrients to a cover
crop. This cover crop can then in turn provide a. beneficial use such as a. hay field, or
aesthetic in terms, of a flower garden: Additionally, land applied waste water is actually
being treated by the natural processes that foster our ecological systems. Reclaiming
and finding a use for waste water is also environmentally responsible, resulting in public
relations bonuses. There are several variations of on -site land application disposal
methods. Each method will be separately addressed because each deserves its own
design considerations. As with all waste water design considerations health and safety
are predominant factors. This is definitely the case with land application methods.
Slo w Rate Jhifiltritian
This type of disposal option utilizes irrigation equipluent to apply the treated waste
water over an area- It is allowed to percolate in to the sub surface, evaporate, and
transpire as it is used by plants, The treated effluent would be applied at a rate
Leach fields are the Most COMMOn disposal method ff..n- waste waters treated by septic
systems. jurisdiction for, this option lies with Mecklenburg County Environmental consistent with the water holding and transportation properties of the soil. Gough Econ.,
Health Department. An inquiry for a leach field was made at the time of facility Inc. sits on several acres of lowsJoped land. howeverthe land is configured as a long
construction. An assessor deemed the sites soils "unsuitable for the installation of a corridor. This configuration comes into play as minimum setbacks as defined b), NC
a
DEIINR are employed, Setbacks from the well, property line. and surface drainage
absorption sewage system." The letter attached to the report did, however, state
,,round
4

features leave almost no land as forany type of land application. As the setbacks lower than estimated, rotation may be replaced with intermittentcy. This scenaric, is
or buffers change for each type application. land constraints beconte a. dorninant factor. fie.asible as a rriethod for the disposal of waste water. For the sake of feasibifitf', sorne
A spray irrigaflon system typically casts the irrigation water through pressure w rzzles quick calculations have been rnade. Five Hundred (500),gallons of waste water spread
applying it to a large, area- Atornized waste veater may be carriNi by wnids: Also, over a20 ft x 40 ft area constitute I inch of precipitation. Oil the South side of the
freezing Gough Econ. Inc, facility there is a lonmi island surrounded by drive. This area is
temperatures may call for special equipment, and may cause complications.
Buffers for a spray irrigation type system dictate that 400 feet must be between the
wetted perimeter and other, property. The facility property is approximately 400 ft wide
and 600 ft long, Because of -construction setbacks, the facilities structures lie in the
centerofthe property. Therefore. a,100 fc---,t buffer allows ncrooln for spray irricsation
waste water disposal.
Another type of irrigation system used for, disposal of waste waters is drip irrigation,
This system does net cast the waste water over an area but rather, uses drip irrig
ation
lines to introduce the waste water to the surface offfic disposal area, Drip irrigation in
this case also means that the, waste water would be released at thesc�il surface, most
probably under a. blanket of mulch or stone. Microbes in the top layer of soil would
provide the final treatment step for the treated effluent. Their, plants planted through
the drip irrigation blanket would receive the benefits ofa continual water source, and
additional nutrients. Sonny cif the water would be evaporated, but the majority would
percolate into the soil subsurface, Buffers for drip irrigation axe tire smallest of any lurid
application buffers. The, property line buffer of 50 feet, the Nvater veoll buffer of 100 feet,
and the cinurrage features buffer ref` 25 feet leave several small areas of land to be
crcnsidei,edf(-.rdt,il)irrigation, Preliminary soils research indicau-,&that WkB or Wilkes
approximately 1/4 of an acre, and approximately rectangular. Large hard wood trees rare
intermittently placed through the area. If this were landscaped eliminating the lawn and
adding,a variety or perennials, a drip irrigation system beneath a layer Of Mulch could
be Used to enhance the facilities aesthetics, as well as use waste vcater. A drip irrigation
system ,,over this area delivering five hundred gallons pet, day (500 -gleb svoidd be
watering the area with an additional <0,1 inches of water daily. Art additional
coulpficatic.m of this type of systern is the fact that it would most likely require,, a fence to
keep the area separate from the public. It is unclear at this point if the fence
surrounding the entire, facility would quality, This option as mentioned before is one
that is feasible, as well as one that could be good for public relations.
Rapid Infiltration
A rapid infiltration systern consists of a earthen pond or series Of ditches vvinch store the
waste water while the writer perculates through the ditch into the sub surface. This
apprc,,ach is similar n, a the leach field normally associated with septic ranks, but this
takes place at the surface. Therefore, the same problems that exist in a leach field exist
with rapid infiltration. In rapid infiltration system, the land area, on which the souer is
placed is actually less than it vo-,)uld be in a, the leach field. This concentratk)n Of water
soils with 4% to 81, a slopes are. predominant to the site, These soils are considered pool, produces permanent saturation of the. local vadose zone resulting in groundwater
for waste disposal and infiltration areas. Further consideration ofa drip irrigation mounding. In fact, this mehiccl of treatment is someturres accompanied with
system would be dependent on an in depth study of the soils actual ability to store and
groumhv,-iter recovery wells to eliminate the mounding. Also, the areawhtxe the
transmit water, Also, it is typiail of these., types or irrigation systerns to rotate over more
infiltration system is would be an eyesore. Ustly, setbacks for rapid infiltration are more
than one area, this allows the soils to draiD. Since actual flows are believed to be much
5 6

'ile Kees Configure Window Trace Help
)3/11/1997 CHAR-MECK TAX DEPARTMENT PUBLIC ACCESS SYSTEM TDPA030 C
10: 3 AM CURRENT REAL ESTATEDETAIL SUMMARY "TPC 3
)3 -�15 -`1 FIRE. I TWP: 2SITUS: MECK ' D:
)WNER/MAILING ADDRESS MO T : ANNEXED
,OUGH ECON INC
TYPE ; DOMESTIC
a0 BOX 668533 DEED : 4257 0974
DATE : 12/03/ 19 7 9
'HA LOTTR NC 28266
'OT ACRE- 6.290 AC LEGAL: M4-501
> ITUS . 9400 LAKEBROOK RD MECK
--
;ARD I OF 1 1997 APPRAISAL DATA TOTAL
,OUGH ECON LAND 175,360
)UILT 1954 NET COND .92 BLDG 502,970
;QFT: 26,492 AUX Sty. FT 2,241 OB F 9,570
:ONE; I2CD NEIGHBORHOOD: 05501 TAXABLE 687,900
iC:RE : 6.290
?SE/MODEL: PREFAB WHS/WHSE/INDUS
<-TYPE CHOICE, NOTES FS:MORE INFO F7.UP CLEAR.RESET
PRESS ENTER.' FI:HELP F2:OPTIONS F3;RETURN F6: PREV INFO F .DOWN F1'2:EXIT
'ile Keys Configure Window Trace Help
,3/11/1997 CHAR-MECE. TAX DEPARTMENT PUBLIC ACCESS SYSTEM TDPA030 C
0:47 AM CURRENT; PEAL ESTATE DETAIL SUMMARY TP03
153-159-15 FIRE: 1 TWP: 12 SITUS: MECK SD.
,WNE;R/MAILING ADDRESS MORT: ANNEXED:
,DAMS OUTDOOR ADVERTISING L P
TYPE : PARTNERSHP
O BOX 31144 DEED : 7673 ' 0773
DATE : 0 / 21 / 19 94
HARLLOTTE NC 28231
OT ACRE: .250 AC' LEGAL: I-85
ITL:S: LAKEWOOD DR MECK
------------------------------------------------------------------------------
APD I OF 1 1997'APPRAISAL DATATOTAL VALUE
LAND 400
UILT 0000 NET COND % m 1.00 BLDG
F'T : AUX S . FT : OBXF'
ONE: R3 NEIGHBORHOOD: 05301 'TAXABLE 490
CRE: .25C)
SE/MODEL: SINGLE FAM/VACANT
<-TYPE CHOICE, FS : MORE INFO F7 : UP C LEAR RES T
PRESS ENTER. FI:HELP F2;OPTIONS F3;RETURN F6 PREY' INFO 1`8:DOWNi° F12: X T
ile Keys Configure Window Trace Help
3/11/1997 CHAR-MECK TAX. DEPARTMENT PUBLIC ACCESS SYSTEM TDPA030 C
):48 AM CURRENT REAL ESTATE DETAIL SUMMARY TP0
53- 59-16 FIRS: 1 TWP: 12 SITUS: MECK SD:
NER/MAILING ADDRESS MORT~ ANNEXED
'KNOWN
TYPE INDIVIDUAL
DEED t 0

RE: . O00 AC
LEGAL:
S 1 -S5
S I-85 HY MECK
1OF 1 1997
APPRAISAL,
DATA
TOTAL 'VALUE
LAND
2,000
0000 NET COND % :
1.00
BLDG
AUX SQ. FT
OBXF
R3 NEIGHBORHOOD:'05301
TAXABLE
2,000
.976 <--CALCULATED
DEL: SINGLE FA?v /VACANT
YPE CHOICE,
F5:MORE INFO F7:UP
CLEAR:RESET
RESS ENTER. F1:HELP F2:OPTIONS
F: :RETURN
F6:PREY INFO} FS:DOW°12:EN;IT
Keys Configure Window
Trace
Help
1997 CHAR-MECK TAX DEPARTMENT
PUBLIC ACCESS SYSTEM
`I'DPA030 C
AM CURRENT REAL ESTATE DETAIL SUMMARY
TP03
9-25
FIRE:
1 TWP: 2 SITUS:
MECK SD:
MAILING ADDRESS
MORT:
ANNEXED:
CEBRON tf
TYPE :
INDIVIDUAL
STLAND FARM RD
DEED :
4898 O493'
DATE :
08/31/1984
HOLLY NBC 28120
RE: 1.590 AC
LEGAL:
NA
9300 LAKEBROOK RD MECK
-------------------------------------------------------------------------
1 OF 1 1997
APPRAISAL
DATA
TOTAL VALUE
DRICH
LAND
5,1,950
1965 NET COND
.53
BLDG
174,830
12,600 AU:X SQ . FT
OBXF ,
12CD NEIGHBORHOOD:
05501
TAXABLE
226,750
1.90
DEL: WAREHOUSE /WH E I DUS
YPE CHOICE, NOTES
F.MORE INFO) F7:UP
CLEA:RESET
RESS ENTER. Fl:HELP F2:OPTIO7NS
F3:RETURN
F6:PREV INFO FS:DOWN F12:EXIT
Keys Configure Window
Trace
Help
1997 CHAR-MECK TAX DEPARTMENT
PUBLIC ACCESS
SYSTEM
TDPA030 C
AM CURRENT REAL ESTATE
DETAIL SUMMARY
TP03
9-10
FIRE:
1 TWP: 2 SITUS:
MECK SD:
MAILING ADDRESS
MORT:
ANNEXED:
CEBRON WEST'LY
TYPE .
INDIVIDUAL
STLAND FARM RD
DEED .
4634 0151
DATE .
02/28/1983
L Y- NC 28120
RE: 4.270 AC,
LEGAL:
LAKEBROOK RD
LAKEBROOK RD MECK
1 OF 1 1997
APPRAISAL
DATA
-ra+ ----
rva....rw.»---
TOTAL* VALUE
LAND
2,000
3000 NET COND % :
1.00
BLDG
AUX SQ. FT
OBXF
13 NEIGHBORHOOD:
_05301
TAXABLE
20,000
1.270

<-I.YPE CHOICE, F.S:MORE INFO F 7UP CLI
PRESS ENTER. F I : HELP F`? : OPT IONS F : RETURN F ; PREV INFO FS : DOWN
1 Keys ConfigureWindow Trace Help
1/11 1997 CBAR-MECK TAX DEPARTMENT PUBLIC ACCESS SYSTEM TU1
r : 49 ANC CURRENT REAL ESTATE DETAIL SUMMARY
3-51- 1 FIRE: I TWP: ? SITU : ME(
="NE /MAILING ADDRESS MORT : ANNEXED
'COY EUNICE WATSON
1Y ENTIRETY)(BY MILL) TYPE : INDIVIDUAL
A CLANTON RD STE C DEED ; 0000 0000
BATE : 11/18/197V
.ARLOTTE NC 28217
�T ACRE: 66.980 AC GOOD LEGAL: NA
TUS: WILKINSON BV MECR
.RD 1 OF 1 1997 APPRAISAL DATA TOT
LAND
'ILT 0000 NET COND % ; 1.00 BLDG
1FT AUX SQ. FT OBXF
,NE: R 3 NEIGHBORHOOD: 05301 'TAXABLE
'RE: 66.980
E/MODEL : SINGLE FAM,/VACANT
-TYPE CHOICE, NOTES F5 t MORE INFO F7 ;'UP CL
PRESS ENTER. F 1 : HELP F? . OPTIONS F3 : RETURN FC , PREY INFO FS: DOWN'

Evaluation of Ground Disposal Options

ECKLENBURG COUNTY
DEPARTMENT OF ENVIRONMENTALHEALTH
1200 BLYTHE BOULEVARD
CHARLOTTE. NORTH CAROLINA 28203
A60
r
SIR. NO. 20081
T.C. NO.: PO -159-1
DATE: 10-1-3
C. F. Wilbraham
Cough Econ, Inc.
I-5 at Sam Wilson Road
Charlotte, NC 28208
Re: Property located at End of Lakebrook Road
Dear Mr. Wilbraham:
t your request,a field investigation was conducted on the property designated
r
1C
.-*. .r r r •W11MR&IMPA41#1 sit• •�_
• r
the effluent would not be expected to Contaminate and surface - or gr
supply and that the effluent would not be exposed to the ground surf
puns will be reviewed and if it is 'found that the system may be reds
petted to function satisfactorily, approval will be given upon the ex
you of a "Septic Tank Agreement Form" provided by this office.
If I may be of assistance, please feel free to call. �(
Sincerely,
Bill D. Hardist r, Jr.
Environmental Health Supervisor
BOH/kb
Enclosure -.

/DEPARTMENT OF
SITE EVALUATION
S.I.R. NO. a0
RONME TAL HEALTH
LEMBURG'COU%STY,
T.C. NO.r-
tdOtITH CAROL I NA
(Ground
Absorption
Sewage Disposal)
OWNER: COU(; FCo
PLAT HO
A DRE S: ,fi. A Llpr FrR0041 RU
LOT SIZE:
LOCATION OF SITE:
00 A f Aa
Ntd
FA"TORS
AREA 1
AREA 2
AREA 3 AREA 4
S
S S
S -- IV PS
1. SLOPE
P ---
.---1.0
-
U
U U
2. SOS'%. TEXTURE 12- 6 -inches)
S-.,, 'y, Loamy, Cl ayey
S k --Ini
PS d .I
S
PS - 1
� S /�tt � S
PS PS
tp
3.
S
S V"X
S S
{ t'-" aches
PAS
P$
PS j'cS
. SOIL DEPTH (inches)
'rPS
S
S
PS P
t
tJ
U
. RESTRICTIVE HORIZONS
S
S S
(Inches)
o t>.c
jtil t� tS
/00 PS
(Impervious strata Rock_
U
U
U U
6. SOIL DRAINAGE/GROU%DI�:A`ER
(external and internal)
PS 5
S 1e1
S S
PSG PS
S
S S
7. OTC -DER (Specify)
PS
PS
PS PS
U U
. SOIL GROUP
Q_
. SITE CLASSIFICATIONtSuJ1ril
Ju,
1. SOIL SERIESC�ccii
t
S = Suitable PS -
Provisionally SuTitfalbse U
- Unsuitable
*See Diagram on Back (includes:
soil areas, property lines, roads, streams,'
gullies,
wet areas,
fill areas, wells, water bodies, slopes)
Recommendations/Comments:
Described r A
Title::
Date.
_
EHD 5 (Revised: 6/82

etaGk Map'

LEGEND
DRIP jlftlGRTION
NOT[: SETBACKS ARE 11IOES FOR DRIP [IRRIGATION
t"
-.:..,F.

APPENDIX 6
USGS Area Map Sections

Compliance Evaluation Inspection

State of North Carolina
Depart ant of Environment,
Health and Natural Resources �
Mooresville Regional office
James B. Hunt, Jr., Governor Erw."."))k 1E H NF
.Jonathan B. Howes, Secretary
DIVISION OF WATER QUALITY
February 10, 1997
Mr. David Risley
Gough Fcon, Inc.
Post office Box 668583
Charlotte, N.C. 28266
Subject: Compliance Evaluation Inspect
Cough Econ, Inc. WWTP
NPI ES Permit NO. 1 CO058084i
Mecklenburg County, N.C.
Dear r Mr. Risley:
at this 6afice.
Sincerel
D . Rest` l
Waver Qua
Enclosure
lij
y
r
eason, P.E-.
cc: Mr. Rusty Rozzlle, MCHRP
DJt
919 North Main Sheet,
Mooresville, North Carolina 2 115 Nviwl
Voice 704 -199
FAX 704-
1An E auc l oppo pit Affir

Facility: Gough Econ, Inc
NPDES Permit Number: NC0058084
Inspection Date: February 7, 199
PERMIT:
The current permit'expires on A
limits will be effective on November
(NH3 as N) and Total Residual Chlorin
The Operator in Responsible Cha
Carolina Operators Certification Grad(
the class of the facility.
RECORDS/REPORTS:
The ORC maintains daily logs and
self -monitoring, maintenance, instrun
control.
compietea proper. y a5 Zuw4u.L-Ltzu
ILITY SITE REVIEW:
mv,= n nnii man far-iii-tv con
ade reaeration.
iver Basin.
Lst 31, 2001. New permit
1.4!0 / -ror 1U=Qn1d al
j, which is acceptal
;) were reviewed
e permit.
^f = Mani -it- i-
.­
and appeared to be operating properly at the time
inspection.
FLOW MEASUREMENT:
Flow measurement is accomplished using an insta
stopwatch and bucket method, which is in accordance wig
permit requirements.
LABORATORY:
Analysis of effluent samples is performed by PAR Labor
which is certified by the State of North Carolina (certific
to perform analysis on all parameters specified in the pern

Facility: Gough Econ
NPDES Permit Number*- NCO058084
Inspection Date: February 7
Laboratories was not evaluated u
EFFLUENT/RECEIVING WATERS:
The effluent was clear
detrimental effect on the rece.,
inspection.
SELF -MONITORING PROGRAM.*
Self -monitoring reports (DN
January 1996 through December 199
7
this inspection.
[id not appear to have a
stream at the time of the
6.
itored at the frequency and location required by the
RATIONS & MAINTENANCE:
The wooden steps beside the cascade post aeration
Vegetative growth should be removed from the sand
,,resh sand should be replaced in the filter in order to
idequate treatment.