NC0085731_Regional Office Historical File Pre 2018

ROY COOPER
Interim DI"re'-for
1 Jarvis, General Engineering Manager
arillon Building
Trade Street
North Carolina 28202
Subject: Compliance Evaluation Inspection
The Carillon Building Dewatering System
Mecklenburg County
~'
-report,
xz
Edward Watson, Hydrogeologist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachment: Compliance Inspection Report
CC: MRO Files
Brain Wilson, S&ME (via email)
State of North Carolina Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 16 10 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115

EPA
de
151 3 1
w e
i
:a
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(See attachment summary
United States Environmental Protection Agency
Washington, D.C. 20460
w Compiiance Inspection Report
yrfmotd
11 121 18102A
valuation Rating Fit
71L
Phone and Fax Numbers)
hone and Fax Number
02/004-714.1 # 00!
Inspector Fac Type
191S1 20LJ
--Reserved
ner Facility Data
s evaluated)
elf -Monitoring Program'
•ar
Agency/Office/Phone and Fax Numbers Date
Division of Water Quality/l704-663-1699r
MRO W11P
Agency/Office/Phone and Fax Numbers Date
..r n r vinr:—v-a k—v n V41:r l: vjuwi tuivaris are Vosorele:.
Pag

F
aim
frequent inspections of the sump be performed. If the sump contains an oily sheen, an absorbent sock
may be utilized to collect the sheen,
Be advised that pollutants from stormwater may impact system compliance
Currently, Chronic Toxicity testing continues to produce passing results.
Page# 2

PerrnW NCOOSS7 1
application's
Is the facility as describ(
Are there any special,
Is access to the plant sit
Is the inspector granted
Comment: the err
Operations & Maini
Is the plant generally clE
Goes the facility analyze
Solids, pH, DO, Sludge
Comment: O&M ree
current.
Owner - Facility: CarillOrt Bu
Inspection "type. ComPlianci
months or less). Has the permittee submitted a new
iermit?
c for the permit?
Ad to the general publics
k all areas for inspection?
eduled for renewal on June 30, 20M
cceptable housekeeping?
control parameters, for ex: MLSS, MCRT, Settleable
id other that are applicable?
stem
No NA NE
n
0
11
El
0
El
d
E
0
©
E
if
El
1:1
El
0
El
El
11
Yes No NA NE
11
El
E3
El
andAgpqgLto be
)rds were reviewed
durina the site visit.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
11
[
C1
E
Is all required information readily available, complete and current?
11
E]
E]
11
Are all records maintained for years (lab. re, required 5 years)?
11
El
Q
Are analytical results consistent with data reported on DMRs?
11
D
11
El
Is the chain -of -custody complete?
11
E-1
(l
1:1
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 CIWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator
El
El
0
El
on each shift`
Is the ORC visitation log available and current?
11
0
El
0
Is the ORC certified at grade equal to or higher than the facility classification?
11
0
Is the backup operator certified at one grade less or greater than the facility classification?
11
®
El
E
P ge#

Permit: NCO085731 Owner - Facililly� Carillon Building Dewatering System
Inspection Date: 02/02/2018 Inspection Type-, Compliance Evaluation
Record KeMLng
Yes No NA NE
Is a copy of the current NPDES permit available on site'?
N
D
El
D
Facility has copy of previous years Annual Report on file for review?
C1
El
9
El
Comment: No annual report is reauired for this permit. Records were reviewed for 2017, The records
appear to be CQDMjoD1TejtetAannd_Min_gorder.
Effluent SaM21:in
a
Yes tLo NA NE
Is composite sampling flow proportional?
11
D
El
19
Is sample collected below all treatment units?
0
D
C1
1:1
Is proper volume collected?
10
El
El
11
Is the tubing clean?
1:1
El
13
0
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
El
El
El
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
IN
El
El
El
representative)?
Comment: Samples are collected for I g De
:h _2ermit parameters. This facility has reaulariv achieved
oassinct results for Chronic Toxicity testing,
Effluent Picie
Yes No NA NE
Is right of way to the outfall property maintained?
M
El
El
1:1
Are the receiving water free of foam other than trace amounts and other debris?
N
El
1:1
1:1
If effluent (diffuser pipes are required) are they operating property?
D
0
El
Comment: Effluent disch rs.
Page#
4

PAT MCCRORY
r.a Governor
DCNALD R. VAN DER VAART'
Secretary;
Water Resources . JAY ZIMMERMAN'
ENVIRONMENTAL QUALITY
Director
July 18, 2016
CERTIFIED MAIL 7009 2250 0000 8087 1191
RET-URN RECEIPT REQUESTED
Mr. Jesse Amundson, Hines Manager
Hines Charlotte Carillon LP
227 W Trade St, Suite 330
Charlotte, NC, 28202
Subject: Notice of Violation NOV-2016-PC- 277
Failure to Register & Submit Electronic Discharge .Monitoring Reports'(eDMRs)
CarillonBuilding groundwater remediation
NPDES Permit NCO085731
Mecklenburg County
Dear Mr. Amundson:
Per the terms of your NPDES permit, you were required to register for, and begin using, the eDMR system
by 5/2 /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 201E 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,
vebsit at: htt ;/l nc, rr r' bo /divisio s/w ter reso tces'c t r. Should you have further questions
regarding eDMR after reviewing the webste's content, or have need of further assistance, you should coal
Derek Denard at 19-807-6307 or derek.denard@a-,ncdenr.gov.
Thank you for your cooperation in. this matter:
ly;
;iucer
. Jay Zimmerman, P. .
.Director, Division of Water Resources
cc: NPDES File
Central Files
State of North Carolina j Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina27699-1617
919-707-9000

PAT MCCRORY
Governor
{ y
DONALD R. VAN DER VAART
Secfelafy
Water Resources S. JAY ZIMMERMAN
ENVIRONMENTAL QUALITY
Director
June 24, 2016
Larry Stinar'
Hines Charlotte Carillon LP
27 W Trade St
Charlotte, NC 28202 4E
Subject: NPDES Electronic Reporting Requirements
Carillon Building
NPDES Permit Number: NC 085731
Dear 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 (ie.,
electronic rather than paper -based).
EPA is phasing in the requirements of the rule over a 5-year period. The two phases of the rule, and their
key milestones, are:
• Phase 1—Starting on December 21, 2016, regulated entities that are required to submit Discharge
Monitoring Reports (DMRs) will begin submitting these reports electronically. If you are currently
reporting your 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 on December 21;, Z020, regulated entitiethat 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 2013, and should contain the requirement to electronically
report your Discharge Monitoring Reports using NC DWR's eDMR system.
In addition to requiring permittees to report information electronically, the rule also requires permittees
to identify the initial recipient for the NPDES electronic reporting data [see 40 CFR 122,41(l)( )]. initial
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center ( Raleigh, North Carolina 27699-1617
919 807 6300

recipient of electronic NPDES information from WDES-regulated j
entity (EPA or the state authorized by EPA to implement the NPDI
for receiving electronic NPDES Data [see 40 CFR 127.2(b)]. 'Permi°
submit the required NPDES information to the appropriateinitial
18, 2016, EPA. must identify and publish on its web site and in the Federal Register a listing of initial
recipients by state and by NPDES data group. Once available, you can use EPA's web site to find out or
determine the initial recipient of your electronic submission.
NC DWR has submitted a request to EPA to be the initial recipient for the following NPDES data groups;
1. Discharge Monitoring Reports;
2. General Permit Reports [Notices of Intent to discharge (Nils); Notices of Termination (NOTs)];
3. Pretreatment Program Reports; and
4. Sewer Overflow/Bypass Event Reports
EPA's web site will also link to the appropriate electronic reporting tool for each type of electronic
submission for each state. Instructions on how to access and use the appropriate electronic reporting
tool will be available as well.
For more information on EPA's NPDES Electronic Reporting Rule, visit
htt www2.e a: ov com fiance final -national- ollutant-dischar e-elimination s stern-n des -
electronic -reporting: rule. For more information on electronic reporting to NC DWR, visit
htt de nc. ov about divisions water -resources edmr rides -electronic -re ortin or contact Vanessa
Manuel at 919-807-6392 orvia 'email at Vanessa.Manuel@ncdenr. ov.
Sincerely,
Jeffre4j 0. P &
fors. Jay Zimmerman, P.G.
Cc: NPDES Fife
Central Files

TABLE
SUAIMARY OF GROUNDWATER ELEVATIONS
SHORENSTEIN ASSET SERVICESAjj#y#M00WMft
227;WEST TEE STREET
CHARLOTTE, `O NORTH CAROLINA
S ME PROJECT NO.1354-96-111
WELL DATE = TOP -OF -CASING DEPTH -TO- WATER LEVE
ID MEASURED ELEVATION WATER ELEVATION`
LrrF_rE-ET)ET ETJ
1128/95 744.22 29.14 715.08
2/14/96 744.22 2927 714.95
1029/96 744.22 29.46 714.7+
6/18/97 744.22 27.72 716.50
01/13/1998 744.22 27.28 716.94
12/29/1998 744.22 29.06 715.1
02/08/1999744.22 30.64 713.58
12/20/1999 744.22 2749 716.7
11/28/95 ` 745.59 31.02 714.57
2/14/96 745.59 31.04 714.55
10/29/96 745.59 ' 31.25 714.4
6/18/97 745.59 29.59 716.00
01/13/1998 745,59 27.21 718.38
12/9/1998 745.59 30.61 714.98
02/08/1999 745.59 2839 716.80
12/0/1999 745.59 2938 716.21
RWw 11/28/95 7 L65 9.81 711.8
/14/96 721.65 9.85 711.81
10/29/96 721.65 10.07 711,58
6/18/97 721.6 9.95 711.70
01/1311998 721.65' 10.97 710.68
12129/1998 721.65 647 715.18
02/8/1999 721.65 1.05 711.6;
12/20/1999 721.65 1.3 71135
R- 11/28/95 722.05 1015 711.9
2/14/96 722.05 10,15 711.90
10/29/96 722.05 13.31 709.74
6/18/97 722.05 20.75 701.30
01/13/1998 722.05 11.18 710.87
12/29/1998 722.05 6.86 71.19
02/08/1999 722.05 6.78 715.27
12/20/1999 722.05 5..32 716.73
RW-5 11/28/95 722.21 10,11 712.10
2/14/96 722.21 10.10 712.11
10/29/96 722.21 11.29 710.92
6/18/97 722.21 20.41 701.80
01/13/1998 722.21 11.11 71 L 10
12/2911998 722.21 6.17 716.04
02/08/1999 722.21 5.95 716.26
12/20/1999 722.21 4.58 717.3
PROJE 199061 I l\SemiAnnualReportl298A.xls fags

TABLE
SUMMARY OF GROUNDWATE
SHORENSTEIN ASSET SER."V
22'7 WEST TR
CHARLOTTE,NO
S&ME PROJECT
MEVATIONS
iLLON BUTLDING
ET
OLINA
6-111
WELL
DATE
TOP -OF -CASING
DEPTH -TO-
WA LEVEL
iD
MEASURED
ELEVATION
WATER
ELEVATION
(FEET)
(FEET)
(FE
RW-6
11128/95
715.81
10.08
70.7
2/14/96
715.1
6.1
709.50
10/29/96
715.81
7.01
708.80
6/18/97
715.81
6,94
708.87
01/13/1998
715.81
NS
NS
12/9/1998
715.81
3.69
712.12
02/08/1999
715.81
1102
704.79
12/2011999
715.81
RW-7
11/28/95
720.17
28.8
691.79
2/14/96
720.17
34.87
685.30
10/29/96
720.17
9.93
710.24
6/18/97
720.17
10.05
710.12
01/13/1998
720.17
11.15
709.02
12/29/1998
720.17
4.5
715.52
02/08/1999
720.17
4.55
715.6
12/20/1999
720.17
3.15
717.02
RW-8
11/28/95
721.36 -
9.1
711.7
2/14/96
721.36
9.56
711.80
1/29/96
721.36
1145
709.91
6/18/97
721.36
1032
711.04
01/13/1998
721.36
10.97
710.39
12/29/1998
721.36 -
5M03
716.3
02/08/1999
721.36
4.96
716AO
12/20/1999
721.36 '
419
717.17
RW-9
111 8/95
726.94
25.38
701.56 .
2/14/96
726.94
25.34
701.60
10/29/96
726.94
2655
700.39
6/18/97
726.94
25.95
700.99
01/13/1998
726.94
25.87
701.07
12/29/1998
726.94
9.65
717.29
02/08/1999
726.94
9.78
717.16
12/20/1999
726.94
8.47
718.47
W- 0
11/28/95"
726.42
14.64
711.78
2/14/96
726A2
14.92
711.50
10/29/96
726A2
15.21
711.21
6/18/97
726.42
15.41
711.01
01/13/1998
726A2
14.85
711.57
12/29/1998
726.42
7.49
718.93
02/08/1999
76.42
7.38
719.04
12120/1999
726.42
6.74
719.68
monitoring well,
ach metal casing.

PAT MCCRORY
DO N kN DER VAART
Scovorj
S. JAY ZIMMERMAN
January 29, 2016
Amundson, Hines Manager
We Street, Suite 330
NC 28202
Subject: Compliance Evaluation Inspection
Carillion ground water rernediation
NPDES Permit No. NCO085731
Mecklenburg County
Nmundson:
=I
V reports.
e enclosed report.
ori.tuvia@ncdenr,Rov.
Sincerely,
Ori Tuvia, Environmental Engineer
Mooresville Regional Office
Division of Water Resources, DEQ
Cc: NPDES (Derek Denard)
MRO Files
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mornesvitle, NC 28115
Phone: [phone] \ Far [phone] \ Customer Service: 1-877-623-6748

United States Environmental Protection Agency Form Approved,
EPA Washington, 0,C. 20460 OMB No, 2040-0067
Water Compliance Inspection Report Approval expires 8-31-98
'Section A: National Data System Coding (i.e., PCs)
Transaction Code NPDES yr/molday Inspection Type Inspector Fac Type
�j NC008573
4 111 121 16/01/27 117 18 L�j 19 L�j 20LJ 1 J2 3 1 1
211 111 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 11 1
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 OA -.--------Reserved-------
671 1'0 ' 7014 1 71 72 1 N 731 1 174 7
IN I
51 111 11110
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to PO , also include Entry Time/Date Permit Effective Date
POTW name and NPDES derail: Number t 09:45AM 16/01127 15/09101
Carillon Building
227 W Trade St Exit Time/Date Permit Expiration Data
Charlotte NC 28202 11:15AM 16/01127 20/06130
Narne(s) of Onsite Representafive(s)rrifles(syPhone and Fax Number(s) Other Facility Data
1/1
David Jar vis/1704-71 9-1100
Travis Quinn/1704-995-5481
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Ftora Jane D'Souza,9751 Southern Pines Blvd Charlotte NO 28273/1/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit in Flow Measurement Operations & Maintenanc* Records/Reports
Self -monitoring Program 11 Sludge Handling Disposal Facility Site Review EffluentlReceiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspectors) Agency/Office/Phone and Fax Numbers Date
Edward Watson MRO GW///
On A Tuvia MRO WQ//704-663-16991
Signature of Management 0 A Reviewer Agency/Office/Phone and Fax Numbers Date
William C Basinger MRO WQ//704-235-2194/
9-9) Previous obsolete.
Page#

PD S yr/molday Inspection Type (Cont.) 1
31 NCO085731 r� 1l 121 16/01/27 117 1
Section D: Summary of Finding/Comments (Attach additional shuts of narrative and checklists as necessary)
Notes writen by Ed Watson.
The Quarterly report of groundwater contaminants indicate there are currently exceedance for
Manganese (Mn) of 17. ug/L 1, - DCE AT 100 UG/l, 4- Bromoflurobenzene at 100 ug/L`and Toluene
t 1talug/L. Although these constituents are above the 2L standard for groundwater, they are reduced
from previously report groundwater laboratory results indicating, the system is operating to reduce
VOC impact to groundwater.
The waste carbon is extracted through an extraction port that is connected to the top of the Carbon
canister to allow for easy extraction of the spent Carbon. The system is set up as an in -line two
canister, system which allows one tank to perform extraction of solids and the second tank to act as a
polishing tank. The system is reversible to allow for the tanks to be reversed to allow for extraction of
the spent Carbon in the lead tank making the second tank the primary tank.
The system has sample ports that allow for mid -point sampling which helps with monitoring
breakthrough of constituents in the activated Carbon in the vessels. A copy of the spent Carbo
Manifest was provided to see the spent Carbon was being properly; disposed of by Evoqua and a copy
of the 1 /28/2015 manifest was provided.
The files were tap to date and in order. Samples are able to be extracted at the mid -point of the in -line
tanks and at the end of the treatment. Because the travel distance of the system drain line, we were
not able to view out -flow that empties into the un-named tributary to Er in's Creek.
A a
Page#

PermW NCO085731
inspection Date: 0112712016
the permit?
itions for the permit?
,tricted to the general public?
!ss to all areas for inspection?
Owner - Facility: Carillon Building
Inspection Type: Compliance Evaluation
Yes No NA. N
led a now
not
IN
El I
Flgw, Jqtr@gtbIene, ILon, Manganese, and Chronic toxicity.
Record Kee in
)Lej No NA NJ
Are records kept and maintained as required by the permit?
Is
0
El I
Is all required information readily available, complete and current?
M
C1
0 1
Are all records maintained for 3 years (lab, reg. required 5 years)?
IN
0
01
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?
IN
El
11
Has the facility submitted its annual compliance report to users and DWQ?
11
n
11
(if the facility Is = or > 5 MC permitted flow) Do they operate 24/7 with a certified operator
on each shift?
Is the ORC visitation log available and current?
0
0
0
Is the ORC certified at grade equal to or higher than the facility classification?
0
0
El
Is the backup operator certified at one grade less or greater than the facility classification?
0
El
Is a copy of the current NPDES permit available on site?
0
1)
Facility has copy of previous year's Annual Report on file for review?
11
El
11
1--ornmeni. L-,gcoras are wen mainiaineg. the jactitTy naS Deen mal-Kiggin—eir tnronic i oxcnv results
ironWillcorrect.
ant gam Lim
riposite sampling flow proportional?
Yes No NA NE
0 0 1:1
Page# 3

Permit: NCO086731 Owner - Facility: Carillon Building
Inspection late. 01/2712016 Inspection Type: Compliance Evaluation
Effluent ate U! nti Yes No tLA NE
Is sample collected below all treatment units? MOOO
Is proper volume collected? 0 n CIO
Is the tubing clean? ❑ El 0 11
# Is proper temperature set for sample; storage (kept at less than or equal to 6.0 degrees M a 0 0
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment: Com osite S@Mgling gong by ISCG gaM21ing machine whigh was not on site at the tIm2 of
the inspection. ORC brina the sam ler when needed,
I_abzatary Yes N2 MA NE
Are field parameters performed by certified personnel or laboratory? In El Q "11
Are all other parameters(excluding Meld parameters) performed by a certified lab? N 0 0 11
# Is the facility using a contract tab? In 0 11 0
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees M 0 11 0
Celsius)"?
Incubator (Fecal Colifor ) set to 44.5 degrees Celsius+t- 0.2 degrees? El IN 0
Incubator (BOO) set to 20.0 degrees! Celsius +/-1.0 degrees"? © 0 In d
Comment: PACE IgboLatclEy analyze samples for Tetraethlene Iron and Manganese, ETS laborato
anal ze chronic toxicity sampling.
Flow Measurement - Effluent Yeas Llo N6 NE
# is flow meter used for reporting? 0000`
Is flow meter calibrated annually? 11 11 Cl 0
Is the flow meter operational? 0 © 11 11
(if units are separated) foes the chart recorder match the flow meter?
Comment: Flow meter is replacedyearl.
Ogerations �& Maintenance Yes No MA NE
Is the plant generally clean with acceptable housekeeping? 11 ❑
Goes the facility analyze process control parameters, for ex: MISS, MCRT, Settleable E]
Solids, pH, DO, Sludge .fudge, and other that are applicable?
Comment: a reggyery,Wells gumI2 into a 30t1Q anon g ualization tank tranferrin into two charcoal
filters. Charcoal is re laced once a vear ov Haz-Met Environmental services.
Page# 4

b?
c
16
Ph
n
A
N'4
.. �, ..
I1gCIVt11NCNtl1'l
AUG�
Donald R. van der V art
Secretary
August 10, 2015
tries
iern Pine Blvd
NC 28273-55 0
Subject: Issuance of NPi. ES Permit NCO085731
The Carillon Building dewatering system
Mecklenburg County
Class PC-1
[u ' les:
,ic on personnel Have reviewed and approved your application for renewal of the subject permit,
V, we are forwarding the attached NPDES discharge permit. This permitis issued pursuant to
ants of North Carolina General Statute 143-215.1'and the Memorandum ofAgreement, between
&na and the U.S. Environmental ental Protection Agency dated October 15, 2007 (or as subsequently
is final permit includes no major changes from the draft permit sent to you on June 3,
as note that the segment ofIrwin Creek to which your facility discharges is lasted, a raaired
f
Since y,
S.. day Zimmerman, Director
Division of Water Resources
Central Piles l resville' €regional Office NPDES Unit
t
David Jarvis / Hines Carillon LP [e-copy)- Richard Farmer 1 Mecklenburg Csiainty [e-copy]
I Service Center, Raleigh, North Carolina 7 -'1617 512 North Salisbury Street, Raleigh, North Carolina 27604
119 807-6 i FAX [phone] f http lfpodal,ncdenno4 blwq
Opportunity/Affirmative Action' Employer - 536 Recycled/1 Q°, Post Consumer Paper

r
effa
Permit NCO085731
SHEET
ition or discharge are hereby
t conditions, requirements, terms, andprovisions included herein
3.es Charlotte Carillon, LP is hereby authorizedto.-
les the fallowing components -
rge tank.:
�o carbon absorption units
icil%ty is located at The Carillon Building fOONOWAIM Street, Charlotte)
-klnburg County.
•' • ♦ lI r sIffillw
River Basin.
Page 2 of 6

Part I
A. (1) EFFLUENT LIMITATIONS AND N
[[1 A NCAC 02&0400 et seq., 15,4,
During the period beginning on the effective
the Permittee is authorized to discharge frory
d monitored' by the Permittee as specified l
PARMETER LIMITS
Monthly Weekly
„RCale] Average Avera'e
500 Q
8389 3.3 erg/L
Ilo 5
01D551
Permit NCO085731.
►NITORING REQUIREMENTS
CAC 0 B.0500 et seq.]
:te of this permit and lasting until expiration,
utfall 001. Such discharges shall be limited
low:
MQN1TOPJNG REQUIREMENTS
Daily , M ur er Sample Type Sample Location
M lrnurtt i=r�quenc
Monthly Instantaneous Effluent
Quarterly Grab Effluent
Quarterly Grab Effluent
Quarterly Grab Effluent
FTGP3BJ Quarterly I Qornposite Effluent
Footnotes.
1.. No later'than 270 days from the effective date of this permit, the perrnittee shall begin
submitting discharge monitoring reports electronically using the Division's eDMR system
[see A. {3)].
2. .All volumes of wastewater leaving the facility shall be monitored. if continuous flea
monitoring is not feasible, men the discharger shall record the approximate time that
discharge began and ended, along with the instantaneous flow at the time of the effluent
sampling.
. Refer to A. []}.;
There shall be no discharge of floating solids or visible foam in other than trace amounts,
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
[1.5A NCAC 02B.0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or
significant mortality to Ceriodaphnia dubi ar a
The permit holder shall perform at a minimum, gygrterly monitoring using test procedures
outlined in, the "North. Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," .Revised.
December 2010, or subsequent versions or "North.. Carolina Phase it Chronic Whole Effluent
Toxicity Test Procedure" (Devised- December 2010) or subsequent versions. The tests will be
performed during; the inonths o " . Thesemonths
signify the first month of each. (three-month) toxicity testing wafter assigned to the facility.'
Effluent sampling for this testing must be obtained during representative effluent discharge
d shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
Page 3 of 6

Permit NCO085731
If the test procedure performed as the first test of any single quarter results in a
failure or +ChV below the permit limit, then multiple -concentration testing shall be
performed at a minimum, in each of the two following months as described in `North
C'_. rnlltna 'P'hst+ew TT Mirn"4tw UMMo s vye.,n+'rr%,tr4^4+vrMTn +'D—...-.��a -

A
I
Permit NCO085731
3) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[NCGS 143- 5.1 (b)]
posed federal regulations require electronic submittal of all discharge monitoring reports
CRs) and specify that, if a Mate does not establish a system to receive such submittals,
-i permittees must submit DMRs electronically to the Environmental Protection Agency
k). The Division anticipates that these regulations will be adopted and is beginning
lens enta:tion.
rE: This special condition supplements or supersedes the following sections within Part it
its perm (Standard Conditions for NPDES .Pe its):
Section B. Signatory Requirements
(II.)'
► Section D. (2.) Reporting
Section D. (6.) Records Retention
k Section E. (5.) Monitoring Reports
ZeRorting FSupersedes Section D and Section E. 5. a
e' ' ning no later than 270 days from the effective date of this permit, the permittee
-hall begin reporting ;discharge monitoring data electronically using the NC DWR's
Uectronic Discharge Monitoring Report (eDMR) int rnet application,
tlohitoring results obtained during the previous month(s) shall be summarized for each:
aonth and submitted electronically using eDMR. The eDMR system allows permitted
�Lcilities to enter monitoring data and submit DMRs electronically using the internee.
Tntil such time that the state's eDMR application is compli t ;with PA's Gross -Media
electronic Reporting Regulation ( RO ERR) permittees will be required to submit all
ischargemonitoring data to the state electronically using eDMR and will be required to
omplete the eDMR submission by printing, signing, d s'ub `tting one signed original
nd a copy of the computer -printed eDMR to the following address:
'C DE / Division of`Water Resources / Information Processing Unit
TTENTION: Central Files / eDMR
617 Mail Service Center
alei h, NC 27699-1617
a permittee is unable to use the eDMR system due to a demonstrated hardship or due
> the facility teeing physically located in an area where less than. 10 percent of the
ouseholds have broadband access, then a temporary waiver from the NPDES electronic
-porting requirements may be granted and discharge monitoring data may be submitted
ri paper DMR forms (MR 1, 1,1, 2, 3) or alternative forms approved by the Director.
uplicate signed copies shall, be submitted to the mailing address above.
equests for temporary waivers from the NPDES electronic reporting requirements must
submitted in writing to the Division for written approval at least sixty (60) days prior to
ie'date the facility would be ,required under this permit to begin using eDMR.
arnporary waivers shall be valid for twelve (I') months and shall thereupon expire, At
Page 5 if 6

Permit N O085 31
Page 6 of 6

Facility
Location
Meeldenburg County
Map not to sole

NPDES Permit Standard Conditions
Page I of 1
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Dsfimtio s
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events. These samples shall be
representative of the wastewater discharged during the sample period.
eels
Samples are collected three times per week on three separate calendar days. These samples shall be representative of
the wastewater discharged during the swnple period.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean rater Act (CWA), as amended, 33 USC 1251, et.
seq.
Waal Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform, the geometric mean of such discharges.
AILthinetic Mean
The summation of the individual values divided by the number of individual values.
B ass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which is
not a designed or established or operating mode for the facility.
Calendar Dav
The period from midnight of one day until midnight of the next day.; However, for purposes of this permit, any
consecutive 2-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Week
The period from Sunday through the following Saturday.
Calendar Ouarter
One of the following distinct periods.' January ou h March, April through Tune, July through September, and
October through December.
A sample collecte over a 24-hour period by continuous sampling or combining grata samples of at least 10it
such a manner as to result in a total sample representative of the wastewater' discharge during the sample period. `1"kse
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time interval
between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically. Composite
samples may be obtained by the following methods.
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
() Constant tune/variable volume: a series of grab samples collected at equal time intervals over a 24 hour period
of discharge and combined proportional to the rate of flow measured at the 'time of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume e collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point. Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer, and the
preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system, or
Version 111091011.1

NPDES Permit Standard Conditions
Page 2 of 18
,nstant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
astant time interval. Use of this method requires prior approval by the Director. This method may only be
:d in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply:
Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
Influent samples shall not be collected more than once per hour.
Permittees with wastewater treatment systems whose detention time < 24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24 dour period.
Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours; there must be a minimum of four samples during a 24-hours lin
period.
iorirrg that occurs without interruption throughout the operating hours of the facility. Flow shall be
-ontinually except for the infrequent times when there may be no flow or for infrequent maintenance
i the flow device.
Wk
rge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
,y for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
iss of the pollutant discharged over the day. For pollutants expressed in other is of measurement, the
iarge" is calculated as the average measurement of the pollutant over the day. (40 CFR 1212; see also
- Sample," above.)
i invironmental Management Commission
vironmental Protection Agency
ities that require coverage under this NPDE S permit. Completion of facility closure will allow this
1
roduct of the individual values where N = the number of individual values. For purposes of
,tric mean, values of "0" (or "< [detection level]") shall be considered = 1.
at least 100 mL collected over a period of time not exceeding 15 minutes. Grab samples can ,be
'rab samples must be representative of the discharge (or the receiving stream, for instrearn
Version 1110912011,1

NP17ES Permit Standard Conditions
Page 3 of 18
Hazardous Substance
Any substance designated under 40 CFR fart 116 pursuant to Section 311 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical, instantaneous flow measurements coincide with the collection of any grab
samples required for the same sampling period so that together the samples and flow are representative of the discharge
during that sampling period.
Monthly Avery e concentration Lim "t
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliforra or other bacterial parameters or indicators, the geometric mean of such discharges.
Permit Issuiniz Authority
The Director of the Division of Water Resources.
Quarterly Average 'concentration limit)
The arithmetic mean of all samples taken over a calendar quarter.
Severe �aro�rty damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or
substantial and permanent loss ofnatural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production, .
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the CWA.
Upset
An incident beyond the reasonable control of the Pennittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper` operation.
WeeklAverae (concentration limit)
The arithmetic mean of all "daily discharges" of a Pollutant measured during the calendar week. In the case of fecal
coliforin or other bacterial parameters or indicators, the geometric mean of such discharges
Section B. General Conditions
l
e e e must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of a permit renewal application [40 CFR 122.41 ].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section
405(d) of the CWA within the time provided in the regulations that establish these standards or prohibitions or
standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any such sections in a permit issued under section 402, or any
requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the Act, is
subject to a civil penalty not to exceed $37 500 per day for each violation. [33 USC 1319(d) and 40 CFR
12 .41(a)(2)
c° The CWA provides that any person who negligently violates sections 301, 302, 30, 307, 308, 318, or 405 of
the Act, or any condition or limitation implementing any of such sections in a permit issued under section 402
of the Act, or any requirement imposed in a pretreatment program approved under section 40 (a)() or
402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
Version 1110912011.1

0 eVOQUA
WATER TFC NOLOGl
ANNUAL SPENT CARBON MANAGEMENT CERTIFICATION
I, (please print or type name of authorized agent), being duly informedand
knowledgeable, do hereby certify for and on behalf of ILArltsffi ( (please print or type
customer name) ("Customer") that the following information, as set forth in this "Annual Spent Carbon.
1. Evoqua Water Technologies LLC, ("EWT"), has ;previously reactivated, for Customer, carbon material
onto which various chemical constituents have been adsorbed (Spent Carbon").
2. The Customer has either;
a. tendered Spent Carbon to EWT for the purpose inter alia of obtaining waste characterization testing
from which the attached analytical report and Spent Carbon Profile Form ("Report") was generated,
which is incorporated by reference as if set forth in its entirety: or
b. tendered an analytical report and Spent Carbon Profile Form ("Report") derived pursuant to all
applicable Federal, Pennsylvania and local laws, rules and regulations, setting forth the physical and
chemical' characteristics of the Customer's Spent Carbon which is attached hereto and incorporated
by reference as if set forth in its entirety.
3. The physical and chemical characteristics set forth in the Report accurately reflect the physical and
chemical characteristics of Customer's Spent Carbon.
4, Customer is not aware of any analysis, data or other information which would indicate that the physical
and chemical characteristics or Customer's Spent Carbon is not substantially identical to the physical and
chemical characteristics set forth in the Report,
5. The process or operation by which Customer's Spent Carbon is generated is substantially identical to the
process or operation by which the Spent Carbon to which the Report refers was generated.
6. Customer is presently aware of no set of circumstances which could cause the information set forth in
the foregoing Paragraphs 1 through 5, inclusive, to be or become inaccurate, untrue, incorrect or
incomplete within one calendar year of the date hereof, and Customer will, upon becoming aware of
any such set of circumstances, immediately advise SII thereof in writing,
Profile Name: HLP-CNC-GW Generator; Name: Hines Charlotte Carillon LP
Site EPA ID#: NCD986171270 Generator Address: 227 West Trade St, Suite 300
Site Address: ` Carillon Bldg harlotte, C 2802
Charlotte, NC Signature: _
Contact: Print: ire itrt
Waste Codes: Title: r,rOJ
Analysis Date:' Date: )Z� �
118 Park Road Tel: +1 (724) $27-8181 Version. 2/21/14
Darlington, PA 16115 USA Fax: [phone],2257 N-, . ... �a,��3 k.�. �-�"'

4
49, 9 0 14
mk"CDENR
r.
North Carolina Department of Environment and Natural Resouroe&,'
Pat McCrory John E. Skvarla, III
Governor Secretary
September 8, 2014
CERTWIED MAIL 7013-2630-0001-8998-0577
RETURN RECEIPT REQUESTED
Mr. Brian E. Wilson, ORC
S&ME, Inc.
304 Timberlane Drive
Hount Holly, NC 28120
Subject: NOTICE OF VIOLATION
Hines Charlotte Carillon LP
Carillon Building
NPDES Permit NCO085731
Mecklenburg County
NOV-2014-LR-0043
Dear Mr. Wilson:
This is to inform you that the Division of Water Resources did not receive your monthly monitoring report
for June 2014. This is in violation of Part 11, condition D(2) of the NPDES permit, as well as 15A NCAC
2B .506(a), which requires the submittal of Discharge Monitoring Reports no later than the last calendar day
following_the resorting period. Failure to submit reports as required will subject the violator to the
assessment of a civil penalty of up to $25,000 per violation. You will be considered noncompliant with the
self -monitoring requirements of your NPDES permit until the report has been submitted.
To prevent further action, please submit said report within fifteen (15) days of receipt of this notice.
Additionally, this letter provides notice that this office will recommend the assessment of civil penalties if
the efficient operation of our water quality programs. We appreciate your assistance in this matter. If you
have any questions about this letter or discharge monitoring reports, please contact the at 919-807-6307 or
via e-mail at [e-mail].
i c ely,
in as A. . Ree'de r
0
Division of Water Resources, NCDENR
cc: Derek Denard, Compliance & Expedited Permitting Unit
Mooresville Regional, Office Supervisor, Surface Water Protection Section
Central Files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone] \ Internet: http://,ncwaterquality.org/
An Equal opportunity i Affirmative Action Employer— Made in part by recycled paper

North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
September 19,2014
Mr. Brian E. Wilson, ORC S F, 2 2 2 0 14
S&ME, Inc.
9751 Southern Pine Boulevard
Charlotte, NC 28273
Subject: Retraction of NOV-2014-LR-0043
CORRECTION
Hines Charlotte Carillon LP
Carillon Building
NPDES Permit NCO085731
Mecklenburg County
Dear Mr. Wilson:
On September 8, 2014, the Division issued a Notice of Violation (NOV) against Hines Charlotte Carillon
)rt with the Division of Water Resources within the
receipt of the NOV, Brian E. Wilson contacted the
; a result, I have withdrawn the NOV against Hines Charlotte Carillon LP for the
cted that the record of this violation be removed from our files.
M+
I 11aliN You ;rugYVU't Flompu attention to Tr S. YOU have al -r-1Vwl 4UV'+.ilVa about this III %,L, please.
contact me at 919-807-6307.
�"Since ely,
Thomas A. Reeder
Thomas
A.
Division of Water Resou e CDE
04�
-0-1-1, 4-
loft- W
Central Files
Brian Wilson [[e-mail]]
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone] k Internet: www,ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer -- Made in part by recycled paper

rr Ms. Gill'.
sible Charge with the findings of the inspection by forwarding a copy of the enclosed report.
m. enclosed report should be self-explanatory. If you have any questions concerning this
ply other matters, please do not hesitate to call Ms. Allocdo or me at this office.
Sincerely,
CX
for Michael L. Parker
Regional Supervisor
Surface Water Protection
Mooresville ille regional Office
ozelle, MCWP
, ., Suite 301 Mooresville, NC 28115 On
: 704 663-6040 k Customer Service: 1-7-523-6748 �F Car a
a Artinn Precei#nuAr.» R0%: PAPvAM/Ift Pne# C'.ancrimar nsartiexr

GENERAL:
The subject facility was last inspected by Ms. Erin Hall of the MCWQP on December 14, 201 OA
Compliance Evaluation Inspection Report was issued on December 20, 2010.
121UTiff
EM01
FLOW MEASUREMENT:
Effluent flow is measured instantaneously during each discharge event using a flow totalizer. A new
flow meter is installed annually. A new flow meter was installed on December 14, 2010, December 15,
2011, and December 17, 2012.

ireaimenT Tacmiy musi visit'
weeks of October 9, 2011 ti
Facility personnel stated th,
January 29, 2012 through F
Ift
:nvironmental Testing Solutions, Inc. conduct compliance monitoring
Pace Analytical Services and Environmental Testing Solutions, Inc.
inspection.
ICE:
I maintenance activities appeared to be acceptable for the size and type
ction C of the facility's NPDES permit states that the CRC of a Class I
Facility at least weekly. The treatment facility was not visited during the
igh October 15, 2011 and January 29, 2012 through February 4, 2012.
CDENR was contacted regarding the non -visit during the week of
uary 4, 2012, which was due to personnel/ORC changes.

a s ,
LTXA, LE
NCDENR
North rolin ep rtment of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee
Governor Director
December 20, 20 10
Ms. Jetta Gill, Property Manager
Mines Charlotte Carillon LP
227 Nest Trade Street
Charlotte, North Carolina 28202
SUBJECT: Compliance Evaluation Inspection
The Carillon Building GWRS
NPDES Permit No. NCO085731
Mecklenburg County, North Carolina
Dear Ms. Gitl:
(MCWQP). This inspection was conducted as part of a cooperative working agreement between Med
County and the Division of Water Quality. Please provide the facility's Operator in Responsible Char
findings of the inspection by forwarding a copy of the enclosed report.
A deficiency was noted daring the inspection with regard to the subject permit as detailed and
Measurement section, it is requested that a written response be submitted to this Office by no later 1
January 20, 2011, addressing the deficiency noted in the report. In responding, please address your
the attention of Ms. Marcia`Allocco at the letterhead address. Additionally, please send a copy of this
Mr. RustyRozzelle ofMCWQP at 700 N. "Tryon Street, Suite 205, Charlotte, NC 28201
The enclosed report should be self=explanatory. If you have any questions concerning this rep
tither matters, pleasedo not hesitate to call Ms. AlloccC or me at this office.
Sincerely, '7,
for Robert B. Krebs
Regional Supervisor
Surface Water Protection
Enclosure
cc: Rusty Roelle, MCWQI'
Mooresville Regional Office { ��
Location: 610 Past Center Ave,, Suite 301, Mooresville, NC 26115
Phone. [phone] t Fax: [phone] Customer Service: 1-877- 3-6748 NoT
Internet: ,ncwaterquality.or
An Equal Opportunity t Affirmative Action Employer- 30% Recycled/10% Post Consumer paper �
r
=mnn

a
I IPA
N
Inspection Work Days
0.5
Name: and Cocati6n of Facil
Hines Charlotte Carillon LP
The Carillon Building GWRS
227 West Trade St,
Mecklenburg County, NC
Name(s) of On -Site Repres(
Curtis Helms / SE - Pro)et
David Reames / S&ME - CAR
Name and Address of Resi
Jetta Gill
Spectrum Properties
27 West Trade St.„ Suite 330
Charlotte, NC 28202
Stags Environmental Protection Agency
Washington, DC 20460
NFUEE i Yr/ o/uay Inspectioi
N O085 1 10/12/14 S
Remarks:
Inspector: Mecklenburg County Water Quality Pr(
Facility Self -Monitoring Rating 131
I N
;petted:
-47, [phone]
)fficial " µ
Farm Approved, 74
CAMS No, 2040-0057
Approval Expires 8/31/98
3
Type Inspector Facility Type
C
ram
CAA Reserved
N
—TTtle. Prof
IAVW+11'f
June 30, 20V
erty Manacier
Z Permit
0
Flow Measurement Z Operations & Maintenance
❑ Sewer Overflow
® Records/Reports
Z
Self -Monitoring Program [l Sludge Handling Disposal
El Pollution Prevention'
Z Facility Site Review
El
Compliance Schedules El Pretreatment Program
[:] Multimedia
® Effluent/Receiving Waters
0
Laboratory [-1 Stormwater
El Other:
Section D: Summary of Findings/Comments
See Attached Summary
Signature(s) of inspector(s):
A enc / fficelTelephone: _
Date:
Erin Hall
MCQP / [phone]
December 20, 2010
Signature of Reviewer:
Agency/Office:
Date:
k "mm �ry
t-m l."
�..wa. r
NCDENR - Division of Water Quality
Marcia Aftco
Surface Water Protection - Mooresville Renal Office
December 20, 2010
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete

"M
The fcil
Charlotte
The treat
located v
The aov
nspectio
operation
t facility was last inspected by Ms. Erin hall of the MC QP on September 23, 2008, A
Evaluation Inspection Report was issued on October 8, 2008:
nit to operate this facility was issued to Hines Charlotte Carillon, LP on September 20, 2010
effective date is November 1, 2010, and will expire on June 30, 2015. The property is
i' Spectrum. Properties, which occupiesthe same facility and has assumed responsibility for
is permitted to discharge 0,0316 MGD of treated effluent from a groundwater
i/dewatering system from Outfall 001 into the City of Charlotte's Municipal Separate Storm
cm. The treatment system[ consists of a surge tank, two carbon adsorption units, and all
)iping and related. equipment.
ity is staffed ( RC and back-up) with personnel that possess the appropriate operator
ion:
DS PORT
Is or logs are maintained on site. However, DMRs, operator visitation/maintenance lags, and
[sorption media exchange/disposal records were available upon request. Recordkeeping and'
ion appeared to be adequate.
rV SITEREVIEW:
Ay is located on the bottom level of the parking structure at the Carillon Building in Downtown
. The facility's permitted equipment is secured in a kicked room with an open-air, grated roof,
rent system is supplied by six (6) recovery wells, each containing individual pumps that are
ithin the footprint of the parking structure.
eground components of the treatment system were reviewed during the inspection. During the
r, dual pumps from the surge/collection tank to the carbon filters were both observed in
. A remote alarm was added to the system in 2008.
neat system outfall discharges via: underground piping into the City of Charlotte's Mur
3torrn Sewer System. The Storm Sewer System draining this area discharges into Irw i
t Class C water in the Catawba River Bassin. Due to the inaccessibility of the discharge
mpling is conducted at a valve that has been installed post -treatment, immediately
rm from the flow meter. Treated effluent was not observed during the inspection.

FLOW MEASUREMENT: 11
Effluent flaw is measured instantaneously during each discharge event using a flew totalizer. A new
flow meter was installed in October 2005. No calibration of this equipment was performed, but new
totalizers were installed annually through 2008. No calibration or equipment replacement was
performed for 2009. A new flaw meter was installed on December 14, 2010. The flaw meter should be
calibrated at a minimum of once per calendar year.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (DMI s) were reviewed for the period from August 2009 through July
2010. DMRs indicate that the facility was in compliance with monitoring requirements and permit
effluent limitations during this period.
LABORATORY:
Pace Analytical Services and Environmental Testing Solutions, Inc. conduct compliance monitoring
sample analysis for the facility. Pace Analytical Services and Environmental Testing Solutions, Inc.
were not evaluated during this inspection.
OPERATIONS & MAINTENANCE;
The documented operation and maintenance activities appeared to be acceptable for the size and type of
facility.

\jq ATc- 1Michael F. Easley, Governor
0 6,6
William G, Ross Jr., Secretary
C, CO North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
October 8, 2008
Mr. Jett a Gill, Property Manager
Hines Charlotte Carillon LP
227 West Trade Street
Charlotte, North Carolina 28202
SUBJECT: Compliance Evaluation Inspection
The Carillon Building GWRS
NPDES Permit No. NCO085731
Mecklenburg County, North Carolina
Dear M. Gill:
the suhject iacility on September 23, 2008, by Ms, Erin Hall
r Quality Program (MCWQP). This inspection was conduce
vorking agreement between Mecklenburg County and the Div
-tion by forwarding a copy of the enclosed report.
The enclosed report should be self-explanatory; however should you have any question
ming this report or any other matters, please do not hesitate to call Ms. Marcia Allocco o
Iffice.
Sincerely,
for Robert B. Krebs
Regional Supervisor
Surface Water Protection
ksure
Rusty Rozzelle, MCWQP
Craig Miller, City of Charlotte
One
2egional Office Division of Water Quality Phone [phone] Custome
A,ngwaterquit ity,ore 610 East Center Ave, Suite 301 Mooresville, NC28115 Fax [phone]-62
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

� United States Environmental Protection Agency, Washington, DC 20460
Form Approved
NPDES Compliance Inspection Report
l*a
OMB No. 2040-0003
North Carolina Department of Environment d Natural Resources
NCDEN�
Approval Expires
< 7 Division of Water Quality,Mooresville Regional
Q J } ��ICi.
!85
'�/ I r diwJ
Section A: National Data stean Cod�n
Transaction Code NPDES Permit No. YR/MQ/DAY Inspection Type Inspector
Facility Type
N 5 NCO085731 08/09/23 C C
Remarks.
Ins ector: Mecklebur Coon Water uali Pro ram
Inspection Work Days Facility Self -Monitoring Evaluation Rating BI QA -
Reserved...,....,...
0A 4 N N
Section R: Facility Data
Name and Location of Facility Inspected: Entry Time. Permit Effective bate:
Hines Charlotte Carillon LP 9: 0 am July
1, 2005
The Carillon Building GWRS Exit Time:
227 West Trade St. 10:00 am Permit Expiration hate.
Mecklenburg County, NC Gate. June
30, 2010
Se timber 23� 2008
Name(s) of On -Site Representative / Title() I -Phone No(s):
Curtis Helms / S M - Project Manager / (704) 52 -4726
Trim Steelman / S&ME - ORC / 704) 5 3-4726 / (704) 604- a478
Name and Address of Responsible Official: Title:
Jetta Gill Property Manager
Spectrum Properties Phone Not
227 West Trade St., Suite 330
Contacted?
[phone]
Charlotte, NC 28202
No
Section C: Areas Evaluated During Inspection
Permit Flow Measurement OperationsOperations& Maintenance
0 Sewer Overflow
Records/Repo Self -Monitoring Program Sludge Handling/Disposal
E) Pollution Prevention
Facility Site Review Compliance Schedules El Pretreatment Program
El Multimedia
Effluent/Receiving Waters Laboratory 0 Stormwater
Q Other:
Section D: Summary of Findings/Comments
All areas are ratedsatisfactory unless otherwise indicated. See Attached Sheet(s) for Summary
Signature(s) of Inspector(s): Agency/Office/Telephone:
Date:
Erin R. Hall MCWQP / (704) 4 -4870
September 30, 2008
ignature of Reviewer: Agency/Office.
, CDENR — Division of Water Quality
Date:
Marcia Allocco Surface Water Protection - Mooresville Regional Office
October 8, 20!
!:��
EPA. Form 3560-3 (Revised -85) Previous Editions are Obsolete

GENERAL:
Nis. Olivia Hutchins of the MCW P last inspected the subject facility can September 6,
2006. A Compliance Evaluation Inspection Report was issued can September 20, 2006.
PERMIT:
permit to operate this facility was issued to Cornerstone Carillon, LLC on July 1, 2005
and will be effective until June 30 2010. The ownership of the facility was changed to Hines
Charlotte Carillon LPon January 15, 2008. The property management has changed to Spectra
Properties, which occupies the same facility and has assumed responsibility for the GWRS.
The facility is permitted to discharge 0.031 MGD of treated effluent from a groundwater
remediation/dewaterir g system into the City of Charlotte's Municipal Separate Storm Sewer
System. The treatment system consists of a surge tank, two carbon adsorption units, and all
associated piping and`related, equipment.
The certification classification for NCO085731 requires that the facility have an operator
in responsible charge (CRC) with a Grade I Physical Chemical Water Pollution Control System
(PC-1) certification. The facility is staffed ((SRC and back-up) with personnel that possess the
appropriate operator certification. Please mark PC-1 on the Discharge Monitoring Reports
for the facility under "CLASS" (not O-Remediatio ).
RECORDS/REPORTS:
o records or logs are maintained on site. However, D.MRs, operator
visitation/maintenance logs, and carbon adsorption media exchange/disposal records were
available upon request.. Record keeping and organization appeared to be adequate.
FACILITY SITE "VIEW:
The facility is located on the bottom level of the parking structure at the Carillon building
in Downtown Charlotte. The facility's permitted equipment is secured in a locked room with an
open-air, grated roof. The treatment system is supplied by eight () recovery wells, each
containing individual pumps that are located within the footprint of the parking structure.
The aboveground components of the treatment system were reviewed during the
inspection. During the inspection, dual pumps from the surge/collection tto the carbon filters
were both observed in operation. A remote alarm has been added to the system within the pest
year,
EFFLUENT/RECEIVING WATERS.
The treatment system outfall discharges via underground piping into the City of
Charlotte's Municipal Separate Storm Sewer System. The Storm Sewer System draining this

area discharges into Irwin Creek, which is a Class C water in the Catawba River Basin. Due to
the inaccessibility of the discharge point, effluent sampling is conducted at a valve that has been
installed; post -treatment, immediately downstream from the flow meter. Treated effluent was not
observed during the inspection.
FLOW MEASUREMENT:
Effluent flow is measured instantaneously during each discharge went using a flow
totalizer. The ORC installed a new flow meter in October 2005. No calibration of this
equipment is performed, but new totalizers are installed annually.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (I MRs) were reviewed for the period from June 2007
through May 2008, D Rs indicate that the facility was in compliance with monitoring
requirements and permit effluent limitations during this period.
LAB©
The permittee contracts with face Analytical Services, Inc. (NC Certifications 412
[Huntersville] and #40 [,Asheville]) to perform all chemical analyses specified in the permit and
with Environmental Testing Solutions, Inc. to perform the Acute Toxicity testing specified in the
permit. Neither face Analytical Services, Inc. nor Environmental Testing Solutions, Inc. were
evaluated during this inspection.
OPERATIONS & MAINTENANCE.
e documented operation and maintenance activities appeared to be acceptable for the
size anditype of facility.

A ;€ Michael F. Easley, Governor/
{ C William G. Ross Jr., Secret
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
September 20, 2006
Ms, Debbie Newsome, Property Manager
Spectrum Properties
227 West Trade St., Suite. 33
Charlotte, NC 28202
SUBJECT: CT: Compliance Evaluation Inspection
Shorenstein Realty Investors Two, LP
Carillon Bldg. GWRS
DES Permit No. 'NCO08 731
Mecklenburg County, NCB
Dear Ms. Newsome:
On September 6, 2006, Ms Olivia Hutchins of the Mecklenburg; County Water
Quality Program (MCWQP) conducted an inspection at the subject facility. This
inspection was conducted as part ofa cooperative working agreement between
Mecklenburg County and the Division. of Water Quality. The enclosed report should be
self-explanatory.
If you have any questions concerning this report or any other matters, please do not hesitate
to call Ms. Marcia Allocco or me at this office.
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc Rusty Rozzelle, MCWQP
DRG/qJ A
FILE: Shorenstein.0085731.0906.circ
No'hCaro 'na IAV
NCDENR �r
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: +cv st ct,it rltt tlitt—or 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]- 23-6748
An Equal C ' rtunitylAffirmative Action Employer - 0% R cled[10% Post Consumer Paper

,ection Agency,'
ennit No. YR/MO/DAY In
)n Type Inspector Facility Type
X Program
Section B: Facility Data
a of Facility Inspected: Entry Time: Permit , E , flective Date:
Investors Two, LP 01:50 pm July 1, 2005
ng GWRS Exit Time:
02:20 pm Permit Expiration Date:
-

GENE
The subject facility was last inspected by MCWQP on :May 9 2005. A ;Notice of
Deficiency Compliance Evaluation Inspection Report was issued on May 25, 2005.
PERMIT:
A permit to operate the Cornerstone Carillon. GWRS was issued to Shorenstein Realty`
Investors Two, LP on April 1, 2003 and expired on June 30, 2005. A new permit to operate this
facility was issued to Cornerstone Carillon, LLC on July 1, 2005 and will be effective until June
30, 2010. The property management has changed to Spectrum Properties, which occupies the
same facility and has assumed responsibility for the GWRS. The change in name and
responsibility are correctly identified in the current permit.
The facility is permitted to discharge 0.0316 MGD of treated effluent from a groundwater
remediation / dewatering system into the City of Charlotte's Municipal Separate Storm Sewer
System. The treatment system consists of a surge tank, two carbon adsorption units, and all
associated piping and related equipment.
In 2005, an initial operator classification was assigned for permit NCO085731. The
classification requires that the facility have an operator in responsible charge (ORC) with a Grade
1 Physical Chemical Water Pollution Control System (PC-1) certification. The facility is staffed
(ORC and back-up) with personnel that possess the appropriate operator certification.
RECORDS/REPORTS:
No records or logs are maintained on site. However, DMRs, operator
visitation/maintenance logs, and carbon adsorption media exchange/disposal records were
available upon request. Record keeping and organization appeared to be adequate.
FACILITY SITE "VIEW.
The facility is located on the bottom level of the parking structure at the Carillon Building
in Downtown Charlotte. The facility's permitted equipment is secured in a locked room with an
open-air, grated roof. The treatment system is supplied by eight (8) wells, each containing
individual pumps that are located within the footprint of the parking structure.
The aboveground components of the treatment system were reviewed during the
inspection. During the inspection, dual pumps from the surge / collection tank to the carbon
filters were both observed in operation.
All other equipment related to the treatment system was reportedly functional during the
inspection. McCall Brothers is the designated contractor for well and pump repair service.

_1q
11 discharges via underground piping into the City of
rm Sewer System. The Storm Sewer System draining this
,hich is a Class C water in the Catawba River Basin. Due to
point, effluent sampling is conducted at a valve that has been
ed instantaneously during each discharge event using a flow
new flow meter in October 2005. No calibration of this
w totalizers are installed annually.
�eports (DMRs) were reviewed for the period from April 2005
cate that the facility was in compliance with monitoring

0W T Michael F. Easley, C
�© William G. Ross Jr.,!
Cam" North Carolina Department of Environment and Natural R
1y `C Alan W, Klimek, P. E-'
(division of mate
Date February 14, 2006 Am',
Af-41 D t
Flora Elliott MOOR ""
Carillon Cornerstone, LLC �
C/o &ME, Inc.
PO Box 7668
Charlotte, NC 2841 FEB 1 6
Subject: Notice of Incomplete Discharge Monitoring Report NCO085731
Dear I'e ittee:VVATErt Rl'
The purpose of this letter is to call your attention to problems with the recent submittal of the Discharge
Monitoring, Report (D ) from your facility. As you may know, the data recorded on your DMR is keyt
into the Division'sdatabase. Our data entry staff has informed me of problems with your recent DMR
submittal. Until these problems have been corrected, your DMR will be considered incomplete. Please
see the attached form along with a copy of the problem DMR for details regarding the D 's deficiency
Incomplete or illegible DMRs affect our staff s ability to provide a timely and effective evaluation of D
submittals. Please be aware that until the Division receives a corrected DMR, you may be considered
noncompliant with: your NPDES permit and 1A NCAC 02 .050, and you may be subject to further
rithin fifteen (15) days of the -date of this letter to the following address
Attention: Michele Phillips
Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, North Carolina 7699-1617
r assistance in this matter.
Sincerely,
Michele Phillips
ill�t�ll�t�giortal'>C�fi'l
ltral Files
ity 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Phone: [phone] Customer SeM
as 512 N. Salisbury St. Raleigh; NC 276044 Fax: [phone]
Adon Employ

V
,-x
Y-A
PermitNumber: ocoo
Facility: 1,Dn-
County: C
DMR Month and Year:
bu, t>
details.)
LJ
The written,
LI
The Average
LI
The Units of
LI
The DMR P�
Other:
are illegible.
,r Codes have been omitted.
is incomplete due to the
�ached DMRfor
have been omitted.

D,
2rd
cl
North Carolina Department of
Michael F. Easley, Governor
William G. Ross Jr,, Secretary
nvironment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
Date: November 23, 2005
St Ste 330 Ninv
28202
cc of Incomplete Discharge Monitoring Report NCO085731
e:
)f this letter is to call your attention to problems with the recent submittal of the Discharge
eport (DMR) from your facility. As you may know, the data recorded on your DMR is keyed
ion's database. Our data entry staff has informed me of problems with your recent DMR
attached form along with a copy of the problem DMR for details regarding the DMR's deficiei
Mete or illegible DMRs affect our staff s ability to provide a timely and effective evaluation of I
als. Please be aware that until the Division receives a corrected DMR, you may be considered
ipliant with your NPDIES permit and 15A NCAC 02B .0506, and you may be subject to furthe
:meat action. Please take the necessary steps to correct the problems and submit two copies of
A DMR within fifteen (15) days of the date of this letter to the following address:
Attention: Michele Phillips
Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
)roper completion of DMRs, please contact Michele Phillips at 919-733-5083 Ext. 534. Thank
ar assistance in this matter,
Sincerely,
]an W. Klimek, P.E.
antral Files
One
NX t,
ality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Phone: [phone] Customer Service
"us 512 N. Salisbury St. Raleigh, NC 27604 Fax: [phone]
ie Action Employer

P
I ne, VIVISIon 01 W =I y ' ty uc:111b UIZ; zutr�cu��xsa
following reason(s): (Please see the highlighted ar
e wfitten values illegible.
b e Average, Maximand/or the Mininn
LI e Units of measure have been onutted or
eport
c�
-UL;VI pIr-M tau:. Lv a;uc
mawhed .t MR for details.)
nts have been onutted.
�t*
yy-
k`

DIVISION OF WATER QUALITY 1"�F :. �
`' July 19, 200
jut.,,
RAND
U
John Lesley
DWQ/ --- MRC? u
Kevin Bowden
Aquatic Toxicology Unit
Initiation of Civil Penalty Assessment Recovery
listed below has been assessed a civil penalty. To date, we have not received
determine whether or not MRO received contact from the facility regarding p,
remission or whether or not there are on -going settlement negotiations. Pleas(
by July 29, 2005 if your region has any relevant information related to this ca
week of August 1 2005 this office will submit a request to the Office of Adn
Hearings for a petition search.
Date F&U
Case No. FaE!!!ty Permit Assessed Received
"Spectrum
Properties/Cornerstone
T-2005-0004 Carillon. LLC". NCO0 7 1 4/25/0 51 I0
to contact me at 919/733-2136.

b
CER'T°IFII
RETURN
Mr. David
Spectrum
C?orl e.rsto,
Suite330
2`7 West
Charlotte,
1011"MI
UEEIMM
y
violation(
to identifi
t J Michael F..Easley, Governor
(; William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Qw�;
Alan W. Klimek, 1'.E. Director
Division cal' Water Quality
February 10, 2()06
MAIL
"CEIPT REQUESTEL?
chrnond, Property Manager
)perties
Zarilln, LLC
tote Street
trth Carolina 2 202
NOTICE OF VIOLATION
Whole Effluent Toxicity Testing
C` PDES Permit No. NCO085731
Cornerstone Carillon, LLC Treatment Facility
Mecklenburg County
hmor d:
is to inform you that a review of your toxicity self -monitoring report form for the month of December 2005
olation of the toxicity limitation specified in your NPDES Permit.
should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity
Your efforts may include conducting a`Toicity Reduction Evaluation (TRE), a site -specific study designed
to causative agents of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity
control options, and confirm reductions in effluent toxicity. Please be aware that North Carolina General Statutes provide
for assessment of civil penalties for violations of NPDEkS permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent
Monitoring; and Reporting; Requirements. Please note appropriate mailing addresses for submitting .our 1
oizitor-arag Re)orts ( MRs) and Agiwazic Toxicity (AT) Test Forms. We encourage you to review this inform,
would be helpful to discuss this situation or possible solutions to resolve effluent toxicity noncompliance, plea,
me or Mr. Kevin Bowden with this office at (919) 73 -2136i
Sincerely,
74I , ,Z2
Matt Matthews
Aquatic Toxicology Unit Supervisor
cc: �' �Mr ,. <aITice
John Lesley -Mooresville Regional Office
Aquatic Toxicology Unit
Central Files
0/
North Carolina Division of water Quality 1621 Mail ,Service Center Ralei8h, NC 27699-1621 Phone [phone] Custome
Internet: www.esh.enr.state.nc.us 4401 Reedy Creek Rd, Raleigh, NC 27607 FAX [phone],
An Equal Opportunity/Affirmative Action Employer— 50% Recyciedll0°1® Post Consumer Paper
'aroli n a

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFOR
The following items are provided in all effort to assist you with identifying critical and sometimes ova
reporting infortnation. Please take, time to review this information, The items below do not address
same number.
The pqnmittee- is responsible for ensuring that toxicity testing is conducted a
forms are appropriately filed.
The reporting of whole effluent toxicity testing data is a dual jKqqipemgm.
parameter code) of your monthly Discharge Monitoring Report which is su
North Carolina Division of W,
Central Files
1, 617 Mai I Service Cei
Raleigh, NC 27699-1
IN ADDITION
Toxicity test data (original "AT" form) must be stet
North Carolina Division of W;
Environmental Sciences 1
1621 Mail Service Cel
Raleigh, North Carolina 27,
Toxicity test results shall be riled with the Environmental Sciences Sect
period (eg, January test result is due by the end of February).
Toxicity test condition language contained in your NPDES permit may rett
of any single quarterly toxicity test. If the initial pass/fail test fails or if the
multiple concentration toxicity tests (one per month) will be conducted ovel
completed will be accepted, If your NPDFS permit does not require, use of
single quarterly test, you may choose to conduct either single concentration
the Division's WET enforcement initiatives effective July 1, 1999..Follow-
Division's enforcement response,
omitted to:
ter Quality
iter
i17
vIATION
it requirement and that toxicity report
fitted to the following address:
r Quality
tion
r
)-1621
Toxicity testing months are specified by the NPDES Permit, except for NPDES Pen -nits which con
requirements (eg, if the testing months specified in your NPDES permit are. March, June, Septembi
must be conducted during these months).
If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge fr,
provide written notification to the Environmental Sciences Section by June 30 that a discharge did
of the calendar year.
If you receive notification from your contract laboratory that a test was invalidated, you should inn
Sciences Section at [phone] and provide written documentation indicating why the test ww
follow-up testing will occur.
If Your facility is required to conduct toxicity testing during a month in which no discharge occurs,
block located at the top of the AT form indicating the facility name, permit number, pipe number, 1
subject report. You should also write "No Flow" on the AT form, sign the form and submit follow
The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (
not received a facility classification. In these cases, a duly authorized facility representative must!
also be signed by the performing lab supervisor.
To determine if your AT test forms were received on nine by the Division of Water Quality,
test results certified mail return receipt requested to the Environmental Sciences Section.
in January I -June 30, then you must
of occur during the first six months
tediately notify the Environmental
invalidated and the date when
you should complete the information
,mmy and the montli/year of the
rig normal procedures.
)RC) except for facilities iich have

an, LL+
Michael K Easley, Qovemor
William G. Mass Jr., secretary
C North Carolina Department of Environment and Natural Resources
Alan W, Klimek, P.E. Director
i Division of Water Quality
July 28, 2005
` 227 W Trade St
FICE
Ste 33
t
Charlotte, NC 2822
SUBJECT: Payment Acknowledgment y `'
Civil Penalty Assessment
Siorenstein Realty Investors
Permit Number: NCO085' 31
Case Number: T-2005_(1 .,
�uYSECTION
Mecklenburg County
Dear Mr. Richmond:
This letter is to acknowledge receipt of cheek number 000701 in the amount of $2,053.42 received
from you dated July 21, 2005. This payment satisfies in full 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 Penuits.
f you have any questions, please call Robert L Sledge at 919-733-5083 Ext547.
Sincerely,
Frances Candelaria
Central Files
17 Mail service Center Raleigh, NC 27699-1617 (19) 7 0-7015 Ct

\NA
Michael F. Easley, Governor
William G. Ross Jr,, Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Fi
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 5-
Mr. David Richmond, Property Manager APR 2 6 2NIfY5,
Spectrum Properties
Cornerstone Carillon, LLC
Suite 330
227 West Trade Street
Charlotte, No Carolina 28202 tINV A i
SUBJECT: Notice of Violation and Assessment of Civil Penalty for Violations of NC General
Statute 143-215. 1 (a)(6) and NPDES Permit No. NCO085731
Cornerstone Carillon, LLC WWTP
Mecklenburg County
TX 2005-0004
Dear Mr. Richmond:
This letter transmits a Notice of Violation and Assessment of Civil Penalty against Cornerstone Carillon, LLC in
the amountof 2,�-5`5-71Z ($ civil penalty + $ enforcement costs).
I —Z 0 - -- - CI-11 ---i�L —1127
This assessment is based upon the following facts. A review of the facility's toxicity self - monitoring data for
December 2004 through February 2005 has been conducted. The review has shown Cornerstone Carillon, LLC to
be in violation of the 90% chronic toxicity effluent discharge limitation found in NPDIES Permit No. NCO08573 1.
The Company's toxicity self -monitoring reports for December 2004 through February 2005 revealed the
following effluent toxicity permit limit violations.
December 2004 fail
February 2005 <45% (chronic value)
Based upon the above fact(s), I conclude as a matter of law that Cornerstone Carillon, LLC violated the terms,
conditions or requirements of NPDES Permit No. NCO085731 and N.C.G.S 143-215. l(a)(6) in the manner and
extent shown above. A civil penalty in accordance with the maximum established by N.C.G.S. 143-215.6A(a)(2),
may be assessed against a person who violates the terms, conditions or requirements of a permit required by
N.C.G.S. 143-215.1(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
Quality, 1, Matt Matthews, Aquatic Toxicology Unit Supervisor hereby make the following civil penalty
assessment against Cornerstone Carillon, LLC.
One
NroCarolina a,
4turally
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, NC 27699-1621 Phone [phone] Custorner Service
Internet www.esIp.enr.state.nc.us 4401 Reedy Creek Rd, Raleigh, NC 27607 FAX [phone]
An Equal Opportunity/Affirmative Acton Employer — 50% Recycled/10% Post Consumer Paper
0

V
0 For of / violation(s)of G.S. 143-215.1(a)(6) and
NPDES Permit No. NCO08573 1, by discharging waste into the
waters of the State in violation of Cornerstone Carillon, LLC's
permit effluent limit for chronic toxicity for December 2004.
a a a For of violation(s) of G.S, 143-215.1(a)(6) and
NPITESPermit-No. NC008573 1, by discharging waste into the
waters of the State in violation of Cornerstone Carillon, LLC's
permit effluent limit for chronic toxicity for January 2005.
$ Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Find
of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282. I (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private
property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which The
Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days receipt of this notice, you must do one of the following:
I Submit payment of the penalty.
Payment should be made directly to the Department of Environment and Natural Resources (do not
w violation(s). Please submit payment to the attention of-.
Point Source Branch
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.
Please be aware that a request for remission is limited to consideration of the five factors listed below as they
may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the
proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Because a remission request forecloses the
option of an administrative hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation and agreement that no factual or legal issues are in dispute. Please
prepare a detailed statement that establishes why you believe the civil penalty should be remitted, and submit
it to the Division of Water Quality at the address listed below. In determining whether a remission request
will be approved, the following factors shall be considered:
(1) one or more of the civil penalty assessment factors in G.S. 143B-282,1(b) were
wrongfully applied to the detriment of the petitioner;
(2) the violator promptly abated continuing environmental damage resulting from the
violation;
(3) the violation was inadvertent or a result of an accident;
(4) the violator had been assessed civil penalties for any previous violations;
(5) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing.
The Director of the Division of the Division of Water Quality will review your evidence and inforra you of
his decision in the matter of your remission request. The response will provide details regarding the case
status, directions for payment, and provision for her 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 reauest for remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil
Penalties Waiver of Right to an Administrative Hearing and Stipulation of Facts" form within thirty (30) day
of receipt of this notice. The Division of Water Quality also requests that you complete and submit the
enclosed "Justification for Remission Request." Both forms should be submitted to the following address:
Point Source Branch
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
OR

3. File a petition for an administrative hearing with the Office of Administrative Hearings:
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.
file the petition with the Office of Administrative Hearings within thirty (30) days of receipt of this noti
petition is considered filed when it is received in the Office of Administrative Hearings during normal o
hours. The Office of Administrative Hearings accepts filings Monday through Friday between the hour
with the Office of Adinnustrative Hearings. The pefition may be faxed - provided the original and one copy c
the document is received in the Office of Administrative Hearings within five (5) business days following the
faxed transmission. The mailing address for the Office of Administrative Hearings is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 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, NC 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
internal date/time received stamp (not a postmark), will result in this matter being referred to the Attorney
General's Office for collection of the penalty through a civil action. Please be advised that additional penalties
may be assessed for violations that occur after the review period of this assessment.
Please be advised that any continuing violation(s) 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 me at 919-733-
2136.
7�
Date Matt Matthews
Aquatic Toxicology Unit Supervisor
Environmental Sciences Section
ATTACHMENTS
cc:
Point Source Branch File w/attachments
Aquatic Toxicology Unit File w/attachments
Central Files w/attachments

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMI
AND NATURAL RESOURCES
COUNTY OF MECKLENBURG}
}
IN THE MATTER OF ASSESSMENT WAIVER. OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ADMINISTRATIVE HEARING
STIPULATION OF FACTS
CORNERSTONE CARILLON, N, LLC WWT
DES PERMIT NO. NC 0 5'731
FILE NO, T - 005- 00
Having been assessed civil penalties totaling for violation
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 t
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 re
of this civil penalty must be submitted to the Director of the Division of Water Quality within. 30 days
of the notice of assessment. No new evidence in support of a remission request will be allowedafter 3(
from the receipt of the notice of assessment.
This the day of , 2005.
I
ADDRESS
TELEPHONE

JUSTIFICATION FOR REMISSION REQUEST
D WQ Case Number: T -200 -OQ44 County: Mecklenburg
Assessed Party: ;Cornerstone Carillon WWTP
Permit No (if applicable): NCO0857 1 Amount Assessed:
Please use this form when requesting remission of this civil penalty. You must also complete the
".Re nest For.Remissio Waiver o Ri t to an Administrative Hearia and Sti a atio of Facts"
form to request remission of this civil penalty. You should attach any documents that you
believe support your request and are necessary for the Director to consider in evaluating your
request for remission. Please be aware that a request for remission is limited to consideration of
the five factors listed below as they may relate to the reasonableness of the amount of the civil
penalty assessed. Requesting remission is not the proper procedure for contesting whether the
violation(s) occurred or the accuracy of any of the factual statements contained in the civil
penalty assessment document. Pursuant to N. .G.S. § 143B-28 .1(c), remission of a civil
penalty may be granted only when one or more of the following five factors applies. Please
cheep each factor that you believe applies to your case and provide a detailed explanation,
including copies of supporting documents, as to why the factor applies (attach additional pages
as needed).
(a) one or more of the civil penalty assessment factors in .C.G. S. 142B-2 2.1 b
were wroneful1v anulied to the detriment of the pgtitioner (the assessment factors are listed in
the civil penalty assessment document);
(b) the violator promptly abated continuing envirompental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or 'something you could not prevent orpr°epare for);
(d) the violator had not been assessed civil penalties for anvprevious violations;
(e) pgMent of the civil -penalty will prevent payment for the remaining neessar
remedial actions (i.e., explain howpayment of the civilpenalty will prevent you from perforrmng
the activities necessary to achieve compliance),
EXPLANATION:

•
CIVIL PENALTY ASSESSMENT ADDENDUM
Water Quality (DWQ) issues/reissues NPDES permits with whole effluent toxicity
ant chronic toxicity test condition language requires permittees to conduct multiple
cm a single quarterly failure to meet the chronic toxicity permit limit. Permittees with
hieved.
it testing will be modified upon
ACUTE TOXICITY TESTING
• A NOV will be issued for each acute limit violation.
• A civil penalty will be assessed for any two consecu

Environmental Testing Solutions, Inc.
7565 Phone: [phone]
NC 28802 Fax: [phone]
E-mail: JimSurnper @aol,com
t Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: December 27, 2004
S&ME' Inc. NPIDES #: NC- 0085731 Pipe #: 001 County Meelcicniaur�
Carillon Builwl;ai;-
Lory Performing Test: Environmental Tcstiria'Solutiorts, b Continents:
tre of Operator in Responsible Charge:
ire of Laboratory Supervisor: Project; 1612
Samples- 041215,01
ginat To: North Carolina Department ol'Euvirojunent and Natural Resources Chronic Test Results
DWQ/ Environmental Sciences Branch Calculated t: NA
1621 Mail Service Center Tabular t: NA
Raleigh, NC 27699-1621 % Reduction: I Mo
rolina Ceriodaphnia Chronic Pass/Fail Reproduction Toxicity Test Percent Average
Morality Reproduction
)Mnisrus 1 2 3 4 5 6 7 8 9 10 11 12 Control Control
,f Young, Produced 13112-5126 13 1 2 31-1 28, 28 35 29 [28 25 31 0.0 29.1
,vival: (L)ive, (D)ead::]-- L LL I L L L LL I-L I L IL L L Treatment 2 Treatment
100.0 0.0
Percentage EEE control CV
it 2 Organisms 1 2 3 4 5 6 7 8 9 10 11 12 10A Pass Fail
-- - -
,f Young Produced 0 0 0 -0 0 0 0 000 1 1 0 0
,vival: (L)ive, (D)ead D D D ]b D I D I D D D D I D 100 X
LLEJ
Test Start Date: 12-15-04
Itrol
atment 2 Collection (Start) Date: LI
r. t 9t Sample 1 12-13-04 Sample2
V 5 w 21
9/L) Skunple Type/Duration
Itrol Orob con4l. Wration
atment 2 7a8 7.8 Sample I X 24-h ;2
Sample 2
de Toxicity Test Alkalinity (mg CaCO,/L)
(expressed as 17b, combining replicates,) Hardness (mg CaC%/L) 44
a.
r• j
Conductivity otinhos/cm) 442
on(%) Total Residual Chlorine (mgA-)
<0,10
Sample Temp, at Receipt (T)
M
Method of Determination Vr
"oufidence Limits Trimmed Spearman Karber C E'VI
73
to Probit
Other: Control
LLL�j high colic.
ft Tested: Ceriodaphnia dubia Duration: 6-days pH (S.U.)
arm AT -I (3187) rev. 11195

San
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C
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C
T
S
Con
Environmental Testing Solutions, Inc.
3ox7565Phone. [phone]
,Ville, NC 28802Fax: [phone]
E- '1: JirnS'urnner@aol-cotn
vent Aquatic Toxicity Report Form - Phase n Chronic Cerioda hnia d"ub a Date: - February ;1, 2005
cility, Inc. NPDES ##: NC- 0085731 Pipe ##: 001 County: Mecktenbur
Carillon Building
boratory'Performing Test: Environmental Testin Solutions, lnc.,,. r 1 o eats: "
,nature of Operator in Responsible Charge: x �� "Test t test at 48-hoursdue to s rtattty:
,,nature of Laboratory Supervisor: Project, lads
samples: O5O126,01
Original To: North Carolina Department of Environment and Natural Resources
DWQ/ Environmental Sciences Branch
1621 Mail Service Center S date kind siatc: Start " Bad
Raleigh, NC 27699-1621 1 01-26.OS 1 01.28-05 1 11,13 .� OS60
low
r
r • �c . ! ` r ar �
r + rr.. a ���� ...s .a . . ��•��°���� .
IAt Percentage
.,-1 2 3 4 5 6 7 8 9 10
mom
tl
Adult Sumvat (L)ive, (D)ead D
L7
1:1
l7
13
D I U D
I D
D
Effluent Percentage turf®
Treatment 5 2aardsins2
3
4
5
6 7 8
9
10
,e
Number ofYoung Produced
Adult S val. (L)ive, Dead 13
I7
D
D
D
Lt 17 D
D
D
%V. 'ma
Effluent Percentage Eiil
Treatment 6 fir anisn 1
2
3
4
5
'6 7 8
9
to
mm
Number of'Young Produced
w Adult survival: Live, (Lt)ead L1
Il
DD
Ili
D D D
B
Il
�
Overall Analysis:
Result: FAEL LOEC:
45%
NOEC.-
< 45%
ChV:
<4 %ti
DWQ farm AT- (819) Rev. 11195

HCD1
it and Natural Resources
Division of Water Quality
vernor William G. Ross, Jr., Secretary
May 25, 2005 Alan W. Klimek, P.E., Director
,biclimond, Property Manager
roperties
`rade St., Suite. 330
4C 28202
SURXCT: NOTICE OF DEFICIENCY
Compliance Evaluation Inspection
Shorenstein Realty Investors Two, LP
Carillon Bldg, GWRS
NPDES Pennit No. NCO085731
Mecklenburg County, NC
is rand:
May 9, 2005, Mr. Jeff Price of the Mecklenburg County Water Quality Prograrn
conducted an inspection at the subject facility. This inspection was conducted as part
ative working agreement between Mecklenburg County and the Division of Water
re enclosed report should be self-explanatory.
ies detailed under the Re_cord/Reoorts heading. Ile monitoring frequency violations
Idressed under separate cover.
f you have any questions concerning this report or any other rnatters, please data not
o call Mr. Richard Bridgeman or me at this office.
Sincerely,
D. Rex Gleason,
Surface Water Protection Regional Supervisor
e
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United States Env
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NPD]
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North Carolina L
Division of
Transaction
Code NPDES
N
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inspection Work mays Facility
1.0
is " trinumll, i I F
0* OMB Noa-2040-0003
9,
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nspection 'Type Inspector Facility Type
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QA ........Reserved.............
N
N
ata
try Time:
Permit Effective Date:
00 am
April 1, 2003
it Time:
42 am
Permit Expiration Date:
te.
June 30, 2005
G9, 2005
Title:
. David Richmond Property Manager
Spectrum Properties
227 West Trade St*, Suite. 330 Phone No. Contacted'?
Charlotte, NC 28202 (704) 3-129Rio
Section Ct Areas Evaluated DuringInspection
Pe it Flow Measurement Operations &: Maintenance Sewer Overflow
Records/Reports Self -Monitoring Program Sludge Handlin isposal El Pollution Prevention
Facility Site Review Compliance Schedules Q Pretreatment Program El Multimedia
EffluentlReceiving Waters Laboratory Stormwater E Cther.
Section U: Summary of Findings/Comments
All areas are rated satisfactory runless otherwise indicated. See Attached Sheet(s) for Summary
Si natures) of Inspectorr(s). Agency/Office/Telephone: Date:
Jeff Price L4 MC QP / [phone] May 10, 2005
f
Signature of Reviewer: Agency/office Date:
EPA Form 3560-3 (Revised 3-85) Previous Editions are Obsolete

EN L:
was last ted by MWQP on December 22, 2003. A Compliance
lnsj�ction Report was issued on January 20, 2004.
in responsibility.
a ♦ • «a ♦ r •
/REPORTS:
ecords or logs we maintained on site. However, DMRs, general rote 14
ni7Afion appeared to be adequate.
section hea&ag of this ort. DMRs appeared to be completed properly, exoept as
Quarterly toxicity test results were incorrectly reported as Pass/Fail under parameter
code THP3B in January, March, June, September and December 2004, and in March
2005. Pass/Fail results should only be reported under parameter code TGP3B.
A multiple -concentration toxicity test result was incorrectly reported as Pass/Fail
der parameter de THP3B in February 2005. Multiple -concentration to "city test
results should be reported as,'"> or < VALUE %".
Marginal

'1444
FACILITY SITE
e fiteffity is located on the bottom level of the parking structure at the Carillon Building
in Downtown Charlotte. The facility's permitted equipment is secured in a locked room with an
open-air, en roof: The treatment system is supplied by eight (8) wells, each containing
individual pumps that are located within in the footprint ofthe 'parking e.
The aboveground components of the treatment system were reviewed during the
inspection. During the . inspection, dual pumps from surgelcollection tank to the carbon filters
were both observed in operation. Also during the 'inspection, one well pumped groundwater ` to
the control room, clue to an incorrectly positioned valve. The valve was openedd
valve -
handle was removed to prevent this incident from c' ing.
All other equipment related to the treatment system was reportedlyetio during
inspection. McCall Brothers is the designated contractor for well and p
service-
EFFLUENT/RECEIVING ''WATERS
e treatment system outfitll dischargesunderground piping into the City of
Charlotte"s Municipal Separate Storm Sewer System. The Storm Sewer System . i ng this
area discharges into Irwin Creek, which is a Class C water in the Catawba River Basin. Due to
the `inaccessibility of the discharge point, effluent ling is conducted .t a valve t has been
installed post -treatment,' ' ' tel downstream, from the flow meter. Treated effluent was not
observed during the `inspectiort.
FLOW EAS ME
Effluent flow is measured instantaneously during each discharge event using a flow
totalizer. ORC installed a new flow meter on November 12, 2004. No calibration of this
equipment is performed, but new totaIiz&rs are installed annually.
SELF -MONITORING PROGRAM. -
Discharge Monitoring f e reviewed for the period from
through March 2005. DMRs indicate that the facility was in compliance with monitoring
requirements and permit effluent limitations during this period, with the following exceptions:
1. One (1) failure to monitor monthly Tetrachloroethene in November 2004. This
constitutes o (1) violation of the subject permit. A Notice of "Violation (NOV) win
be issued.
2. One (1) Quarterly Toxicity (T'GP B) test failure in December 2004 for which a NOV
was issued.

nsat sfactory
l�«
satriple analysis for the facility. No laboratory evaluations were conducted du
ONS & M lit CE

Michael F. Easley, Governor
9_�
William G. Ross Jr., Secretary
9
North Carolina Department of Environment and Natural Resources
r Alan W. Klimek, P.E, Director
° /` Division of grater duality
:Mare 11, 2005
�n v Fib
CERTII
RETUR
Mr. Ia
Spectrul
Dear Mr, I
TI
indicates a
Y1
violation(.,
_. r t I15
'T� r' r^7 T
Property Manager
LL
ina 28202
"_-E
�u.
OF VIOLATION
Effluent' Toxicity Testing
iS Permit No. N O0857 1
rstone Carillon, LLC Treatment Facility
enburg County
you that a review of your toxicity self -monitoring report form for the month of Januaryi200
fthe toxicity limitation specified in your NPDES Permit.
ke whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity
81
to identify the causative agents of effluent toxicity, isolate the
control options, and confirm reductions in effluent toxicity. ' Pl+
for assessment of civil penalties for violations of NPDES pe �
sources of toxicity, evaluate
itations and requirements. `
The reverse side of this Notice contains important information concerning your Whole Effluent Tonicity
Monitoring and Reporting Requirements. Please note appropriate mailing addresses for submitting year Discharge
Monitoring Reports (DMRs) and Aquatic: Toxicity (`A) 'lest Forms. We encourage you to review this information; if it
would be helpful to discuss this situation or possible solutions to resolve effluent toxicity noncompliance, please contact
me or Mr. Kevin Bowden with this office at (919) 7 3-213E.
Sincerely;
Matt Matthews
Aquatic Toxicology Unit Supviso
cc. eville Regional Office
John Lesley -Mooresville Regional Office
Aquatic Toxicology chit
Central Files
North Carolina Division of Water Quality 1621 Mail service Center Raleigh, NC 27699-1621 Phone (919) 73
tnternet: .esb.enr•state.ncmus 4401 Reedy Creek Rd, Raleigh, NC 27607 FAX (919) 73
An Equal Opportunity/Affirmative Action Employer - 50% Recycled110% Post Consumer Paper
XhCaarolina
tlrally
1-2136 Customer service
3-9959 1-877-023-6748

WHOLE E]~FLUES
A 'Do following items are provided in an e
retaorthuz information. Please take time t
same number.
'TOXICITY MONITORING AND REPORTING 11
:>rt to assist you with identifying critical and soinetirr
review this information. The items below do not ad
S� The ep r ittee is responsible for ensuring that toxicity testing is conducted acco •
forms are appropriately filed.
�o The reporting of whole effluent toxicity testing data is a deal requirement, All t
parameter code) oil your monthlyDischarge Monitoring Report which is submit
North Carolina Division of Water i
Central Files
1617 Mail Service Center
Raleigh, NC 76 -1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitt
North Carolina Division of Water +
Environmental Sciences Secti
1621 Mail Service Center
Raleigh, North Carolina 27699-
Toxicity>test results shall be filed with the Environmental Sciences Section I
period (eg, January test result is due by the end of February).
r 'Toxicity test condition language contained in your NPDES permit may require r
of any single quarterly toxicity test. If the initial pass/fail test fails or if the chrc
multiple concentration toxicity tests (one per month) will be conducted over the
completed will be accepted. If your NPDES permit does not require use of mull
single quarterly test, you may choose to conduct either single concentration tox
the Division's VVET enforcement initiatives effective July 1, 1999. Follow-up n
Division's enforcement response.
Toxicity testing months are specified by the NPDES Permit, except for NPDES
requirements (eg if the testing months specified in your NPDES permit are Mar
must be conducted during these montlts)
led to.
uality
ed to the following address.
duality
)n
1621
to later than 34 days after the end of the renortin
se of multiple concentration toxicity testing upon failure
)me value is lower than the permit limit, then at least two
following two months. As many analyses as can be
ile concentration toxicity testing upon failure of any
city testing or multiple concentration toxicity testing per
rultiple concentration toxicity testing will influence the
If your NPDES Permit specifies episodic' monitoring and; your facility does not have a discharge
provide written notification to the Environmental' Sciences Section by June 30 that a discharge dic
of the calendar year.
Y If you receive notification from your contract laboratory that a test was invalidated, you should irr
Sciences Section at (919) 733-216 and provide written documentation indicating why the test wt
follow-up testing will occur.
isor.
,eived on time by the Division of Water Quality, you rnay consider submits
11— 41.Ji 1— V4#4A t— I#1b 1:: t11-1 , 41114" 4L41W4Q­i# "' 41—.t;itl V i i 4Tt 19.k1tx11LC4A 6d i+: bA l4+ 'i.Jiri,at,}—,

Michael F. Easley, Governor
Ci William G, Ross Jr., Secretary
to
7 North Carolina Department of'Environment and Natural Resources
a
L Alan W. Klimek, P.E, Director
Division of Water Quality
.......... February 16, 2005
CERTIFIED MAIL
_(1 f
RETURN RECEIPT REQUESTED $ ;, I
CE
Mr. David Richmond, Property Manager
Spectrum Properties
CornerstoneCarillon, LLC
Suite 330
227 West Trade Street
Charlotte, North Carolina 2820
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity Testing
DES Permit No. NCO085731
Cornerstone Carillon, LLC Treatment Facility
Mecklenburg County
Dear Mr. Richmond:
This is to inform you that a review of your toxicity self -monitoring report form for the month of December 204
indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity
violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation (T ), a site -specific study designed
to identify the causative agents of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity
control options, and confirm reductions in effluent toxicity. Please be aware that North Carolina General Statutes provide
for assessment of civil penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your; Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note appropriate mailing ling addresses for submitting your Discharge
Monitoring Reports (DrI2Rs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this information; if it
would be helpful to discuss this situation or possible solutions to resolve effluent toxicity noncompliance, please contact
me or Mr. Kevin Bowden with this office at (19) 733-2136
Sincerely,
Matt Matthews
Aquatic Toxicology Unit Supervisor
cc:
John Lesley -Mooresville Regional C)ffice
Central Files None Carolina
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, NC 27699-1621 Phone [phone] Customer Service
Internet. EMM esb.enr.state.nc.us 4401 Reedy Creek Rd. Raleigh, NC 27607 FAX [phone]' 1-977-623-674
An Equal OpportuniWAffirmative Action Employer- 50% Recycled/10% Past Consumer Paper

WHOI:
➢ The following items are pro;
art to assist you with identifying criti
t t i
r The Rer ittee is responsible for ensuring that toxicity testing is conducted a
forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. a
parameter code) on your monthly discharge Monitoring Report which is su'
North Carolina Division of Wi
Central Files`
1617 Mail Service Cei
Raleigh, NC 2769 -11
IN ADDITION
Toxicity test data (original "ATform) must be suI
North Carolina division of W�
Environmentalsciences c
1621 Mail Service Cei
Raleigh, North Carolina 271
Toxieltv test results shall be filed with the Environmental Sciences Sect
g:tod fog, January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may requ
of any single quarterly toxicity test. If the initial pass/fail test fails or if the
multiple concentration toxicity tests (one per month) will be conducted ove
completed will be accepted. If your NPDES permit does' not require use of
single quarterly test, you may choose to conduct either single concentration
the division's WET enforcement initiatives effective July 1, t99. Follow -
Division's enforcement response.
Toxicity testing months are specified by the NPDES Permit, except for NPI
requirements (eg if the testing months specified in your NPDES permit are
■
d to the following address:
duality
on
1621
must be conducted during these months).
If your NPDES Permit specifies episodic monitoring and your facility dries not have a i
of the calendar year.
arming lab supervisor.
S� To determine if your AT test forms were received on time b
test results certified mail return receipt requested to the EnA
y the Division of Water Quality, you may consider submitting your toxicity
iTonmental Sciences Section:

NorthNCDENR
archDepartment of Environment and Natural Resources
�vis�n ofater Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
May 25, 2005 Alan W. Klimek, .E., Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. David Richmond, Property Manager 7003 2260`0001 3552 3283
Spectrum Properties
227 West 'Trade St., Suite 330;
Charlotte, NC 28202
Subject: Notice of ViolationMonitoring Frequencies
Shorenstein Realty investors Two, LP
The Carillon -Bldg. GVRS
NAMES Permit No. NCt 085 31
NOV-2005-MV-0024
Mecklenburg County
Dear Mr. Richmond:
Moores,
Phone:
An Equ,
!iwe Parameter dynLail
101 Tetrachloroethene Monthly 2�
one .failure during each of the months of November 2004 and February 2005.
If you have questions concerning this matter, please do not hesitate to contact Mr. Bridgem or
D41663-169 .
Sincerely,
D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
One
Q o ,na
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Mic
WN A ,.
NCDENR William G. moss
+ North Carolina Department of Environment and Nati
(30
C Alan W. Klimek
Division o
September 9, 2004
David Dillard
Shorenstein Realty Investors
27 West Trade Street, Suite 330
Charlotte, NC; 28202
Subject: Renewal Notice
DES PernTit NCO085731
horenstein Realty Investors
Mecklenburg County
Dear Pe ` ittee:
Your NPDES permit expires on June 30, 2005. Federal (40 CFR 122.41) and North Carolina (15AN <
you have already mailed your renewal application, you may disregard this notice.
To satisfy this requirement, your renewal package must be sent to the Division postmarked no later than January 1,
2005. 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 June 30, 2005, 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 at the telephone
number or address listed below. You may also contact the Mooresville Regional (.office at [phone] to begin the rescission
process.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must submit with
the permit renewal application. If you have any questions, please rcontact `me at the telephone number or e-mail address listed
below.
Sincerely,
Charles 11 Weaver, Jr.
DES Unit
2004
cc: Central Files
r..
L ES File'
1617 Mail Service Center, Raleigh, North Carolina 27699-1 17 919 733-508 „ extension 511 (fax) 919 733.0719
Vlsrr US ON THE INTERNET @ hftp://h2o.enrstate.nc.us/NPDES e-mail: [e-mail]

,- It ... ,
vE.F&uac -- .11 V w+vF-
� M
f •' a >
t t ► it
i«
e to a change in fees effe(
NPDES Permit N08!
Shorenstein Realty Ine
Mecklenburg Counto
2UIRED for all renewal
PLEASE N©"n
re January 1, 1999, the
application pads
any changes at the facility since
I.
Send the completed renewal package to:
Mr. Charles H. Weaver, Jr.
NC DFNR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617

January 13, 2004
NCDENR
Division of Water Quality
• • Main Street
Mooresville, NC 28115
Attention: Mr. John Leslie
Reference: Special Order by Consent
The Carillon Building
Groundwater Treatment System
NPICES Permit No. NCO085731
so
ince 1973
17 Deca&s . . lWme Re"ons
R UstenR mVmd. 1P solve�
WC DFPTOF FWROW&r
1`11RCER
FICE
Charlotte, Mecklenburg County
Dear Mr. Leslie:
On behalf of our client, Shorenstein Realty Services, L.P. (Shorenstein), S&ME, Inc. (S&ME) is
respectfully submitting this letter to update the NCDENR on results of recent effluent
compliance monitoring and describe our planned future activities as they relate to the
Application for a Special Order by Consent (SOC) previously submitted for the subject facility.
This letter is also a follow-up to our telephone conversation on January 6, 2004.
REGULATORY CORRESPONDENCE
In October 2003, an Application for an SOC was submitted to the NCDENR following four
consecutive chronic toxicity test failures conducted from June through September 2003 on the
facility's groundwater treatment system effluent. An SOC was requested in order to allow our
client to achieve conditional compliance with the facility's NPICES Permit limitations while at
the same time actively pursuing a solution that would allow routine compliance with the Permit's
final effluent limitations. A draft SOC was received by Shorenstein on December 11, 2003. A
cover letter accompanying the draft SOC indicated that an administrative fee of $2,686.63 would
be assessed against Shorenstein as a penalty for the NPICES Permit violations that occurred in,
the previous months (June through September 2003.)The NCDENR's cover letter stated that the
administrative penalty is due 15 days following approval and execution of the SOC.
S&ME, Inc.
9751 Southern Pine Blvd.
Charlotte, North Carolina 28273
Mailing address:
RO. Box 7668
Charlotte, North Carolina 28241-7668
[phone]
[phone] fax
www.smoinc.com

CENT MONITORING & UPCOMING ACTIVITIES
In October 2003, a routine change -out of the granular activated carbon (C) was performed,
During the carbon change -out, a corroded valve handle (see attached photograph) was
discovered and removed from the inside of one of the GAC vessels. The source of valve handle
is unknown. However, since the removal of the valve handle and change -out of the carbon, three
monthly chronic toxicity tests have been conducted on the groundwater treatment system's
effluent (October through. December 2003). At the completion of each of the three tests, the
results were characterized by the laboratory as "Pass". used on these results, S&ME believes
that it is likely that the corroded valve handle served as a source of dissolved metals (capper,
lead, and/or zinc) that proved to be toxic to the chronic toxicity test organism.
t this point, S&ME plans on perfonning one additional monthly chronic toxicity test during the
weep beginning January 11, 2004. Concurrent with this test, laboratory analysis for the metals
copper, lead, and zinc will also be conducted:. The intent of this testing is to evaluate
concentrations of these metals relative to the toxicity test results. If the results of this sampling
are favorable, S&ME will likely request that the Application for an SOC be rescinded. Toxicity
test results for January 00 will be presented on the January 2004 Discharge Monitoring Report
(DMR)x S&ME will also issue a letter to your office that summarizes the January 2004
laboratory analyses. In addition, this letter will describe our planned future activities, i.e.,
rescind the Application for an SOC and continue monitoring under the NPDES Permit
requirements or proceed with executing the SOC. S&ME will also likely pursue a reduction in
the assessed penalty at that time.
e.
e appreciate your assistance on the project and look forward to resolving this issue. Please
contact us at 704-523-4726 if you have any questions regarding this correspondence.
Respectfully Submitted,
S&ME, Inc.
rge s elf
Project." ages Senior Ilydrogeologist
cc: Randy Pazera
-2-

VVN4 A � �� Michael F. ley, Go r `
William . R. Jr,, Secretary
P North Carolina Department of Environment and Natural Resources
Ird
—i Alan W. YJimek, R E. Director
-� Division of Water QtWity
Coleen H. SullinsDeputy Di or
Division of Waiter Quality
January 20, 2004
Ms'. Nicole Taylor, Acting Property Manager
Shorenstein Realty Services, L.LC`
227 West Trade St., Ste. 30
Charlotte, NC 2202
SUBJECT: Compliance Evaluation Inspection
Shorenstein Realty investors Two, LP
Carillon Bldg. GWRS
NPDES Permit No. NCO08i31
Mecklenburg County, NC
Dear Ms. Taylor
n December 22, 2003, Mr. Jeff` Price 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.
This report is not being issued as a Notice of Violation because Notices have previously
been issued for the Chronic Toxicity test failures covered under the Self -Monitoring Program
heading review.
If you have any questions concerning this report or any other matters, please do not
hesitate to call Mr. Richard Bridgeman or me at this office.
Sincerer,
4"9 M a�'q
i D Rex t ale on, P.E.
Water Quality Regional Supervisor
Enclosure
cc: Rusty Rozzelle, MC QP
DRG/jsp
FILE: Shorenstein.0085731.1203,doc
one E
! rrtxtx�tl tf Division of W iiy, .4f ile ite io 91 N aan M Ie NC 28115 (704) 6 3-16 9 Customer Service
1-8 7-623-6 48

, United Mates Environmental Protection Agency, Washington, DC 20460 Forra Approved
Aft Tj NPD S Compliance e Inspection Report AR
OMIT No. 2040-0003
North Carolina Depart ent o Enviro e t and. Na al Resources Approval Expires
Division of Water Quality, Mooresville Regional Office WCDENR 7/31/85
Section A: National Data stem `C odin`
Transaction Cede NPDES Permit No. Y O/DAY Inspection Type Inspector Facility Type
N 5 NCO085731 03/12/22 C C 2
Remarks:
Inspector Mecklenbur C"caun Water Quail Prts ram
Inspection Work Days Facility Self -Monitoring Evaluation Rating BI CAA .... Reserved.
1.5 2 N N
Section B: Facility Data
Name and Location of Facility Inspected: Entry Time: Permit Effective Date:
Shorenstein Realty; Services, LI,C 1:45 pro April 1, 2003
The Carillon Building Exit Time:
227'West Trade St; 2:30 pm Permit Expiration Date.
Mecklenburg County, NC Date: June 30, 2005
December 22, 2003
Name(s) of On -Site Representative t Title(s) / hone o(s)
George Flores / S&:ME - ORC / [phone]
Name and address of Responsible Official: Title.
Ms. Nicole Taylor Acting Property Manager
Shorenstein Realty Services, LLC"
Phone No. Contacted?Contacted?227 West Trade St., Ste. 3
Charlotte. NC 28202 { 7t}4) 33 -12 No
Section C': Areas Evaluated During Inspection
Z Pe it Z Flow Measurement Z Operations & Maintenance [l Sewer Overflow
Records/Reports Z Self -Monitoring Program [ Sludge Handling/Disposal D Pollution Prevention
Facility Site Review [] Compliance Schedules E] Pretreatment Program ❑ Multimedia
*Effluent/Receiving Waters Z Laboratory [l Storrawater [l Other:
Section D. Summary of Findings/Comments
All areas are rated satisfactory unless otherwise indicated. See AttachedSheet(s) for Summary
Signature(s) of Inspector Agency/Office/Telephone: bate:
Jeff Price IN l MCGti QP / [phone] January 7, 2004
Signature of Reviewer. ,agency/Office Date:
EPA Fonn 3560-3 (Revised "3- ) Previous Editions are Obsolete

ENE
The subject facility was last inspected by MC:WQF on April 1, 2003. A Compliance
ce
,aluation Inspection Report was issued as a Notice of Violation on April 24, 2003.
1 IT:
The subject facility's previous permit expired on August 31 2001. However, the facility
"♦ • a • � t` off : 4 � �� :
t• i t e'' � • � i • �
R
responsible for this facility during most of the period of review. North Carolina
tification is not currently required for this type of facility.
EPORTS:
Drds or logs are maintainedcan site. However, DMRs, general maintenance logs
id organization tion appeared to be adequate.
the period March 2003 through December 2003. DMRs indicate that the facility satisfied
monitoring requirements during the period of review, except as detailed in the Self -Monitoring
Program section heading of this report.
FACELITY SITE
The facility is located on the bottom level of the parking structure at the Carillon wilding
in Downtown lott . The facility's permitted equipment is secured in a locked room with an
open-air, grated roof. The treatment system is supplied by eight ( );wells, each containing
individual that are located within the footprint of the parking structure.
The aboveground components of the treatment system were reviewed during the
inspection. During the inspection, the primary pump transferred groundwater from the surge tank
to the adsorption tanks, and submersible pumps transferred groundwater from the individual wells
to the surge tank. All ether components of the treatment system were reportedly operational t
the time of the inspection, although their operation was not observed.

EFFLUENT/RECEIVING WATERS. -
The treatment system outfall discharges via underground piping into the City o
Charlotte's Municipal Separate Storm Suer System. The Storm Sewer System draining this
area discharges into Irwin Creel, which is a Class C water in the Catawba River Basin. Due to
the inaccessibility of the discharge point, effluent sampling is conducted at a valve that has been
installed post -treatment, immediately downstream from the flow meter. Treated effluent was not
observed during the inspection.
FLOW MEASUREMENT:
Effluent flow is measured instantaneously once a mouth using a flow totalizer. S
Technicians installed a new flow meter on February 28, 2003. No calibration of this equipment i
scheduled until February 2004.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (D - ) were reviewed for the period from March 2003
through December 2003. DMRs indicate that the facility was in compliance with monitoring
requirements and permit effluent limitations during this period, with the following exceptions:
1, O (1) Chronic "Toxicity (TGP3B) test fail e * was reported for the 2" Quarter in
June 2003. This constitutes one (1) violation of the subject permit.
2. One (1) Multiple -Concentration Chronic Toxicity (Tf1P 8) test thilure was reported
in July 2003. This constitutes one (1) violation of the subject permit,
3. One 1 Multiple -Concentration Chronic Toxicity (THP3'B) test failure * was reported
in August 2003. This constitutes one (1) violation of the subject permit.
4. One (1) Chronic Toxicity (TGP38) test failure * was reported for the 3'd Quarter in
September 2003. This constitutes one (1) violation of the subject permit.
denotes that Notice of Violation was issued for each toxicity test facilure.
The DMRs correctly identified the non -compliant facility status for the indicated months.
No'additional violations of the subject permit 't were reported or observed during the period o
review.
RATING: Unsatisfactory

LABORATORY:
Pace Analytical Services analyzes compliance monitoring ° mples for this facility. Na
laboratory evaluations were conducted during this inspection.
OPERATIONS & MAINTENANCE:
e facility appeared to be orderly and secure. The reported operation and maintenance
appeared to be acceptable for the size and type of facility.

State ® North Carolina
Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
October 22, 2003
CERTIFIED MAIL
RETURN RECEIPT
ECEIRITEQUESM
Mr. David Dillard 70012510 0004 8286 5160
Shorenstein Realty Investors/Carillon Building
227 W. Trade Street, Suite 330
Charlotte, North Carolina 28202
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NCO085731
Shorenstein Realty Investors Treatment Facility
Mecklenburg County
Dear Mr, Dillard:
This is to inform you that a review of your toxicity self -monitoring report for for the month of
August 2003 indicates a violation of the toxicity limitation specified in your NPDES Permit.
penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent
Toxicity Monitoring and Reporting Requirements. Please not updated mailing addresses for submitting
your Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Fonns. We encourage you
to review this information and if it would be helpful to discuss this situation or possible solutions to
resolve effluent toxicity noncompliance, please contact Mr. John Lesley with this office at (704) 663-
1699.
Sincerely,
D. Rex Gleason, P.E.
Regional Water Quality Supervisor
cc: Aquatic Toxicology Unit
Central Files

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTINC
I he tollowing items are provided in an effort to assist you wit]
toxicity testing and reporting information. Please take time to n
address' car inelud all the tacit testica and re ortin re iij
you should have any questions about your toxicity testing requ
the Aquatic Toxicology Unit at (919) 7,33-2136 or another Unit rel
The RgrMilLeg is responsible for ensuring that toxicity testing is
and that toxicity report forms are appropriately filed.
The reporting of whole effluent toxicity testing data is a dual
entered (with the appropriate parameter code) on your me
submitted to:
North Carolina Division of Wal
Central Files
1617 Mail Service Cent
Raleigh, NC 27699-16',
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the
North Carolina Division of Wal
Environmental Sciences B:
1621 Mail Service Cent
Raleigh, North Carolina 276
Toxicity test shall be filed with the Environmental SJe
elf the r orting p ioc (eg, January test result is due by the end
Toxicity test condition language contained in your NPDES per
toxicity testing upon failure of any single quarterly toxicity test.
value is lower than the permit limit, then at least nvo multiple
be conducted over the following two months. As many analyse
NPDES permit does not require use of multiple concentrati(
quarterly test, you may choose to conduct either single conceril
toxicity testing per the Division's WET enforcement initiativ,
concentration toxicity testing will influence the Division's enforc
Toxicity testing months are specified by the NPDES Permit, ex(
toxicity monitoring requirements (eg, if the testing months sp(
September, and December, then toxicity testing must be conduci
If your NPDES Permit specifies episodic monitoring and your fa
June 30, then you must provide written notification to the En
discharge did not occur during the first six month: of the calend
If you receive notification from your contract laboratory that a
notify the Environmental Sciences Branch at [phone] and
the test was invalidated and the date when follow-up testing wil,
If your facility is required to conduct toxicity testing during a n
complete the information block located at the top of the AT foi
pipe number, county and the month/year of the subject report
form, sic0m the form and submit following normal procedures.
The Aquatic Toxicity Test forms shall be signed by the facility':
for facilities which have not received a facility classificatioi
representative must sign the AT form. The AT form must also bi
To determine if your AT test forms were received on time I
subrnittimz vour toxicity test results certified mail, return
same number,
rement. All toxicity <test results must be
nanny uiscnarge ivionuoring i-,eport winch is
er Quality
>r
7
'ollowing address:
er Qualitv
'anch
?r
?9-1621
rtces Branch nrs later than da s after the end
of Februarv).
mit may require use of multiple concentration
If the initial pass/fail test fails or if the chronic
oncentration toxicity tests (one per month) will
nave a cuscnarge rrom, january i-
-iences Branch by June 30 that a
liclated, you should immediately
!n documentation indicating why
no discharge occurs, you should
he facilitv name, permit number,
also write "No Flow" on the AT
Zesponsible Charge (ORC) except
uses, a duly authorized facility
, performing lab supervisor.
ty, you may consider
vironmental Sciences
Branch,

w
North Carolina Departrnent of Environn
low
AL
00,
April 24, 2003
ITIFIED MAIL
rURN RECEIff REQUESTED
Albert Whitecavage, Chief Engineer
renstein Realty Services, LLC
70012510 0004 8287 7293
West Trade St., Ste. 330
rlotte, NC 28202
SUwECT: NOTICE OF VIOLATION
Compliance Evaluation Inspection
Shorenstein Realty Investors Two, LP
Carillon Bldg. GWRS
NPDES Permit No. NCOOSS731
Mecklenburg County, NC
r Mr. it wage:
Dry
wing issued as a Notice of Violation (NOV) because of violati
to 205, Charlotte, NC 28202.
If you have any questions concerning this report or any other matters, please do not hesitate to call
Richard Bridgeman or me at this office.
Sincerely,
c"l,
D. Rex Gleason, P.F-
Water Quality Regional Supervisor
cos
Rusty Rozzelle, MCWQP
G/jsp
Sty otenswin.0085731.0403,doc
Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115
699 CU
040 11

"United States v " o ntal Protection Agency, Washington. DC 204,60 Form APlaro
. '_- 1?ES Compliance Inspection Report WA C)l�fl� Ica. 2C
ti Department of Environment" R AG ANCDENRpproval E�
1 ivi " of �� ater Quality. � R gi l R 7/ 11
Section A: National Data
Transaction Code NPDES Permit No. YR,,U0tDAY Inspection Type Inspector Facility
5 N-00085731 3/ 4/ 1 C C 2
Re`
tor
Inspection Work Days Facility Self -Monitoring Evaluation a B1 QA -Reserved....
0.5 2
Name and Location ofFacility Inspected: Entryme: Permit RfI`eetive'D
Sharenstein Realtv i r C _ � December1, 1996
The can _ T
227 West Trade St. = 9 wn Permit Expiration
Mecklenburg Counry. NC:Date: August 31'. 2001
Arril 1. 20031
Name(s)' of On -Site Representative 7 Tfffels3 / Phone `Vo(s):
RBIs. Jennifer Claghom- ORC 7 33- 4 ;"2f
Name d Addrm of R a Official: Ttdv.
Mr. Albert Whiteca-w-jae Chief Engineer
Shorenstein Realty Sc�vces, LLC i Phone l lo. Contact
227 West Trade it, Ste. 330 i 3No. tat
Charlotte, NC 28212
a, ti
Permit Flame Mmsurement Operadoes & Maintenance Seger C ve
Records4teports, Self -Monitoring Pro S Handling/Disposal Q Pollution Pi
Facility Site Review Compliance Schedules t Program Multimedia
EffluenvReceb. ing WatersLaboratory
;swrnmater Other.
ALA
gVC
All areas are rated satisfactory unless otherwise indkatecL See AttachedSheet(s) for Summary
Signature(s) s). t etc y/O a n : Date:
Jeff Price n � QP (7 ) 336-5500 April 9,20(
,
Signature of Reviewer:s Agency/Office Date:
r2
19t, X,,
EPA Fc,,m 3560-2 t ed 3-8 Previous Editions are Obsolete

GENERAL:
Unsatisfactory

FACILITY ' '
the inaccessibility ° the &scharge point. effhxm sunpling is cond=ted
post-treatment,immediately ed` ° ely d fromr o effluent
the inspection.
FLOW MEASUREMENT:
Effluent flow is measured instantancoush, once a momh using a flow tot
Technicians new flaw meter on Le
Afarginal
NflrORING P OG ?kip

OGRAM (Cont.):
(1) additional violation. No a
RATING.- Unsafisfactory
LABORATORY:
RATING: Marginal

Sm*ce 1973
North Carolina Department ofEnvironment and Natural Resources (NCDE )
Division of Water Quality
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 211
Reference: NPDES Permit No. NCO 85731
Response to Notice of Violation
The Carillon Building Groundwater Remediation System
Mecklenburg County; North Carolina
S&ME Project No. 1354-02-32
Dear Mr. Bridgem
On behalf of the Shorenstein Realty Investors Two, -LP (Shorenstein), & E, Inc. (S&ME) is
submitting this response to the Notice of Violation letter dated March 17, 2003 for the Carillon
Building groundwater remediation system (system.) in. Mecklenburg County, North Carolina. The
system is used to treat groundwater generated by eight () de-watering/recovery wells.
The noted violation of the exceedance of the permit limit for the tetrachloroethene parameter in
November 2002 was corrected by the replacement of the spent carbon. Once it was noted that the
tetrachloroethene parameter had been exceeded, the carbon was replaced in December 2002. After
the carbon was replaced, subsequent effluent analyses slid not show a detection of the
tetrachloroethene parameter above the pen -nit restricted limit, To prevent possible future
exceedances of the pennit limit for the tetrachloroethene parameter, S&ME has implemented a
schedule for replacement of carbon every five () months instead of every six ) months as had
been done previously.
S PAE, Inc. Mailing address: � [phone]
9751 Southern Pine Blvd. RC . Box 7668 [phone] fax
Charlotte, North Carolina 28273 Charlotte, North Carolina 28241-7668 www.smoinc.com

ppppppp-
Response to Notice of Violation S&MIS Project No. 1 4-0 -382A'
Carillon Buil in Gro water Re diatson S stem NP]Dl S Pe zt No. NC008 731 Aril 15. 2003
If further explanation is needed in response to the Notice of Violation, do not hesitate to contact us
t (704) 23-4726
Sincerely,
S&ME, Inn.
Jennifer Claho , E.I, Dane A. Ho a, P.E.
Staff Professional Enviromnental Services Manager
Enclosure
cc: Rusty Rozzelle, I CW P
Preston Hombeak, Shorenstein Realty Investors Two, LP
D. Rex Gleason, NCDENR Division of Water Quality
2

1 iN Fax:[phone] Apr 7 2003 11:16 P.0
pc�
+ fam G,
crth Carolina Depa=enz of Environment and Na
Alan W. i(l"orn;
Division
March 17, 2003
R'TI'IED Zvi
LUF--§TF,ID
W. Preston Hornbeak, Chief Engjrieer
shorerste` Realty investors, Two, LP
7 "West Trade Street, Suite 330
Charlotte, -NC 2S 0;
Subject:Notice of Violatiol t- Effluent LWtations
The Carillon Building Gro aster l edzati Sy,stw
U S permit No. NC08 '731
Mecklenburg County
b
A. review of the November,2002 self-monitormg report car the uibj t facility l da violation
the following parameter -
Parameter BoqqLd Value L°
001 Tetrachloroethene 9.4 a 8.8 a IN
should be task o y problemThe
Division of Water Quality may pursue Remedial aeti ; if nc�t alimplemented,ent a 'odz this and any additional violations. if the
c u have nuestions coact
rid of tbi$ offim for adda`fio al.
dog g this matters please do not hesitate to contact I
at 7041663-1,
SincUely,
. Rex Gleason, P.F-.
Water Quality Regional Supervisor
Point Source Co pli nf'o tUnit
customerService Mooresville Regional Offics, 919 North Main Stmeet. Maoremlc NC 28115 PHONE [phone]
., rarr.

-
' -,
�- ' ' � ' -
6 North Carolina Department of Environi
Ala
Mr. Randy Pazera
Shorenstein Realty Two, LP.
227 West Trade Street, Suite 330
Charlotte, North Carolina 28202
Subject: Special Order by Consent
Carillon Building WWTP
NPDES Permit No. NCOO�
Mecklenburg County, NC
Dear Mr. Pazera:
request from Shorenstein Realty Two, L.P. Through the Order conditional compliance ca
achieved while the Company actively pursues the capability to comply with the final efflL
limitations contained in the NPDES Permit'issued to the Company for the operation of th(
Carillon Building Wastewater Treatment Facility.
Thoroughly review the Order. As the document suggests, it will be entered into ol
after the Company's consent. If the Company is satisfied with the content of the Order, p
sign as indicated on the last page. Upon the Order's return to this Office,'it will be forwai
the Director of the Division for final approval.
Please note that an upfront penalty in the amount of $2686.63 is due no later than
following the date on which this Order is approved and executed by the Commission. Th,
penalty reflects a settlement of outstanding penalties/violations occurring prior to enterin�
the special order.
Should you have any questions or require assistance, please do not hesitate to cont
either Mr. John Lesley or me.
'D. /�� C;X-0--
Water Quality Regional Supervisor
Attachments
Cc: Central Files
Bob Sledge, Compliance Unit
NV- Laralina
Vtarlglly
M C. Division of Water Quality, Mooresville Regional Office, 919 North Main Srrec� Mooresville NC 28115 (704) 663-169i

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF MECKLENBUR.G
IN THE MATTER OF )
NORTH CAROLINA SPECIAL ORDER BY CONSENT
CUES PERMIT ) EMC WQ NO. 3-012
NO NCO 857 1 )
HELL BY
SHORENTEIN REALTY )
INVESTORS TWO, L.P. �
Pursuant to provisions of North Carolina General Statutes (G.S.) 143-215.2, this Special Order by
and the North Carolina Environmental Management Commission, an agency of r
olina created by G.S.`14 E- 82, and hereinafter referred to as the Commission:
n:
Smpany and the Commission hereby stipulate the following:
koncornplianee with final effluent limitations constitutes causing and ci
the Commission asset forth in G.S. Chapter 143, Article 21.
(c) Since this Special Order is by Consent, neither party will file a petition for a contested
or for judicial review concerning its terms.
. The Company, desiring to comply with the permit identified in paragraph l(a) above, hereby a
to do the following:
(a) Comply with all terms and conditions of the permit except those effluent limitations
identified in paragraph 1(a) above. See Attachments A and B for all monitoring requirernt
and effluent limitations. The permittee may also be required to monitor for other paramett
deemed necessary by the Director in future permits or administrative letters.
(b) As settlement of all violations of NPDES Permit No. NCO085731 occurring prior to er
into this Special Order by Consent, Shorenstein Realty Investors Two, L.P. agrees to p
sum of 2,686.63. A certified check must be made payable to the Department of
Environment and Natural Resources and forwarded to the Director of the Division of
Quality at 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 by no later
fifteen (15) days following the date on which this Order is approved: and executed by t
Commission and received by the Company,
(c) Undertake the following activities in accordance with the indicated time schedule;

1) Continue implemntatic
scope of the THE Nvork she
reduction activities, alterna
optimization/substitution a
studies, and all efforts to cl
)f the `i'oxicity Reduction Evaluation (T E), The
consider but is not limited to. toxicity source
discharge options, chemical
°ities,review of self -monitoring data, treatability
icterie, identify and confirm effluent toxicants
>rts to the Mooresville Regional Office no later that
er 15 and December 15 2004. The reports will d
in tr B ate to the following addre
Street, Mooresville, NC 2$115.
°r. T Progress Reports mu
M/DWQ, Attn: John Lesley,
needed to achieve compliance with final permit limits.
4) Achieve compliance with the NPDES Permit Limits by no later th<
2004.
(d) During the time in which this Special Order by Consent is effective, compl
citations that have been modified from NPDES requirements by this Orde
a to Unit Permit Limit C+
c Tonicity Pass/Fail Pass (@ 9{}% uarterl Full -Ran
of the DWQ, by check payable to the North Carolina Department of Environment and Natural Resources
stipulated penalties according to the following schedule for failure to meet the deadlines set out in
paragraphs 2(c) and (e, or failure to attain compliance with the effluentliittions/monitoring
requirements contained in Attachment A.
Failure to meet a schedule date
Failure to maintain compliance with
any modified limit contained in the SOC
Failure to achieve compliance
Monitoring frequency violations
Failure to submit progress reports
$100/day for the first 7days; $ 00/day
thereafter
1000/violation
$1031.00
$ 100per omitted value per parameter
$ 0/day for the first 7 days; $ 5t1/day thereafter

at noncompliance wa
,jod;
war
that the stipulated penalties are not due if the Company
.d solely by:
ttee;
iot be considered as events beyond the pe ittee' control, or
nation of the above causes.
e whether the 30 days has elapsed.
7. The pe' ittee upon signature of the Special Order by Consent, will be expected to complywit
schedule dates, terms, and conditions of this document.
8. This Special Order by Consent shall expire March 31, 2005.
For,Shorenstein Realty Investors Two, L.P.:
Date
(Title)
For the North Carolina Environmental Management Commission
Date
Chair of the Commission

SOC Attachment A
haracteristies
M�_nth
Average Maxin
Flow 0.0316 MGD
Terrachloroethene 8.85 u�
-Iron
anganese
Chronic iC4 Monitoring
Only
r)ITIRFMFNTq
-Monitorina Re
(jra
irtSft
Gra
irtSrly
Gra
athly
Cot
60% 75%, and 90'/�), monitor only, monthly.
There shall be no discharge of floating solids or foam visible in other than trace amounts,

�e k rkA_(aAt
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
September 23, 2003
-CERTIFIED MAIL
RE!M!ECE1P!!EQ1M= 7001,2510 0004 8,286 5641
Mr. David Dillard
Shorenstein Realty Investors/Carillon Building
227 W. Trade Street, Suite 330
Charlotte, North Carolina 28202
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NCO085731
Shorenstein Realty Investors Treatment Facility
Mecklenburg County
Dear Mr. Dillard:
Thi's is to inform you that a review of your toxicity self -monitoring report form for the month of
Juiv 2003 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the
effluent toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation
(TRE) which is a site -specific study designed to identify the causative agents of effluent toxicity, isolate
the sources of toxicity, evaluate the effectiveness of toxicity control options, and then confirm reductions
in effluent toxicity. Please be aware that North Carolina General Statutes proVide for assessment of civil
penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent
Toxicity Monitoring and Reporting Requirements. Please note updated mailing addressesfor submitting
your Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you
to review this information and if it would be helpful to discuss this situation or possible solutions to
resolve effluent toxicity noncompliance, please contact Mr. John Lesley with this office at (704) 663-
1699.
Sincerely,
D. Rex Gleason, P.E.
Regional Water Quality Supervisor
cc: Aquatic Toxicology Unit
Central Files

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
The following items are provided in an effort to assist you with identifying critical and sometimes overlooked
toxicity testing and reporting information. Please take time to review this information. The items below do not
address or inetude all the toicit testin and re ortirc requirements contained i hour NPI)I zee it, If
you should have any questions about your toxicity testing requirement, please contact Mr. Kevin Bowden with
the Aquatic Toxicology Unit at [phone] or another Unit representative at the same number.
> The Rgrmittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement
and that toxicity report forms are appropriately filed...
The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity; test results must be
entered (with the appropriate parameter code) on your 'monthly Discharge Monitoring Report which is
submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 769-161
IN ADDITION
Toxicity test data (original "AT" form.) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch.
1621 Mail Service Center
Raleigh, North Carolina 27699-11
'� `Toxicity* test results shall be filed with the Environmental Sciences Brancia no later than t� da s after the end
of the reporting period (eg, January test result is due by the end of February).
> Toxicity test condition language contained in your NPDES permit may require use of multiple concentration
toxicity testing upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic
value is lower than the permit limit, then at least two multiple concentration toxicity tests (one per month) will
be conducted over the following two months. As many analyses as can be completed will be accepted. If your
NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single
quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration
toxicity testing per the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple
concentration toxicity testing will influence the Division's enforcement response.
Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic
toxicity monitoring requirements (eg if the testing months; specified in your NPDES permit are March, June,
September, and December, then toxicity testing must be conducted during these months).
If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-
June 30, then you must provide written notification to the Environmental Sciences Branch by June 30 that a
discharge did not occur during the first six months of the calendar year.
> If you receive notification from your contract laboratory that a test was invalidated, you should immediately
notify the Environmental Sciences Branch at (919) 73-2136 and provide written documentation indicating why
the test was invalidated and the date when follow-up testing will occur.
r If your facility is required to conduct toxicity testing duringa month in which no discharge occurs, you should
complete the information block located at the top of the AT form indicating the facility name, permit number,
pipe number, county and the month/year of the subject report. Lou should also write "No Flow" on the AT
form, sign the form and submit following normal procedures.
The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (C RC) except
for facilities which have not received a facility classification. In these cases, a duly authorized facility
representative must sign the AT form. The AT .form must also be signed by the performing lab supervisor.
To determine if your AT test forms were received on time by the Division of Water Quality, )Lou may consider
sub itting_voiir toxicity test results certified mail return receipt requested to the Environmental Sciences
Branch.

State of North Carolina
nPr%nrfrnPnf nf 'FnvirnnmP'nt and Nafnral 1ZPQnnrrPr.
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
August 20, 200
QERTIF*
Mr) MAIL
70012510 0004 8297 6415
Mr. David Dillard
Shorenstein Realty Investors/Carillon Building
227 W. Trade Street, Suite 330
Charlotte, North Carolina 28202
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NCO085731
Shorenstein Realty Investors Treatment Facility
Mecklenburg County
Dear Mr. Dillard:
This is to inform you that a review of your toxicity self -monitoring report form for the month of
June 2003 indicates, a violation of the toxicity limitation specified in your NPDES Perinit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the
effluent toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation
(TRE) which is a site -specific study designed to identify the causative agents of effluent toxicity, isolate
the sources of toxicity, evaluate the effectiveness of toxicity control options, and then confirm reductions
in effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil
penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent
to review this information and if it would be helpful to discuss this situation or possible solutions to
resolve effluent toxicity noncompliance, please contact Mr. John Lesley with this office at (704) 663-
1699.
Sincerely,
D. Rex Gleason, P.E.
Regional Water Quality Supervisor
cc: Aquatic Toxicology Unit
Central Files

HC
NFORMATION
p toxicity •
llowing it,
.. ,
ire provided in an effort to assist you with id€
filed..
enterer' (with the appropriate parameter cede) on you
submitted to:
North Carolina Division c
Central File
1617 Mail Service
Raleigh, NC 276',
INADDM(
`I'oxicl test data 4(ari "A must b submitted t(
,,,,North Ca,rolipa Divisio q
V IX, Environmental Scier
4621'Mail Service'
Raleigh, North Carolim
• • • lmmffla#M
conducted according to the permit requirement
M ulrement. All toxicity test results must be
nthly Discharge Monitoring Report which is
er Quality
=r
olloing address,
anch
T
9-621 r
1, 1999. Follow-up multiple
ermits which contain episodic
'DES permit are March, June,
ionths).
re a discharge from January I-
ces; Branch by June 30 that a
you receive notification from your contract laboratory that a test was invalidated, you should immediately
notify the Environmental Sciences Branch at [phone] and provide written documentation indicating why
the test was invalidated and the elate when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should
complete the information block located at the top of the AT form indicating the facility name, permit number,
pipe number, county and the month/'year of the subject report. You should also write "No Flow" on the AT
form, sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test formsshall be signed by the facility's Operator in Responsible Charge (ORC) except
for facilities which have not received' a facility classification. In these eases, a duly authorized facility
representative must sign the AT form. The AT farm must also be signed by the performing lab supervisor.
' To determine if your AT test forms were received on time by the Division of Water Quality, you may consider
submitting., your toxicity test results certified mail, return receipt requested to the Environmental Sciences
Branch.

ppr"
( \,\ � P
� 11'n ' �1
AL Sm*ce 1973
IFFSSME \116 Three Decades . . . 7hreeReasons
it r lists & f on . t soh gym
May 6, 2003
NC ,
AND NATURAL RES"CES
North Carolina Department ofEnvironment and: Natural Resources � m
Division of Water Quality
qn
Mooresville Regional Office
919 North Main Street WAY 0 8 2003
Mooresville, North Carolina 2811
Attention: Mr. Richard 0"I'SETIM
Reference: NPDES Permit No. NCO085731
Response to Notice of Violation
The Carillon Building Groundwater Remediation System
Mecklenburg County, North Carolina
S&ME Project No. 134-0-382A
Dear Mr. Bridgeman:
On behalf of the Shorenstein Realty Investors Two, LP (Shorenstein), S&ME, Inc. (S&ME) is
submitting this response to the Notice of Violation (NOV) letter dated April 23, 2003 for the
Carillon Building groundwater remediation system (system) in Mecklenburg County, North
Carolina. The system is used to treat groundwater generated by eight (8) de-watering/recovery
wells.
In response to the noted "unsatisfactory" rating under Records/Reports, S&ME is attaching the
amended Effluent Reports (DWQ Form MR-1.1) for April 2002, December 2002, and January
2003 with the corrections detailed by the NOV. The mislabeled April 2002 Discharge Monitoring
Report (DMR) has been amended to identify it as April 2002. The analytical laboratory estimates of
constituent concentrations below established minimum detection limits (MDL) have been changed
to display "<MDU on the re -submitted monthly NPDES reports as per the requests of the
Mecklenburg County Water Quality Program (MCWQP) and North Carolina; Department of
Environment and Natural. Resources (NODE ) Division of Water Quality,
)704) 23-d726
[phone] fax
www.smoinc.com
E, Inc.
9751 Southern Pine Blvd.
Charlotte, North Carolina 28273
Mailing address:
RO, Box 7668
Charlotte, North Carolina 8 41-7668

S&ME Project No. 1354-02-382A
Response to Notice of Violation
May 6 Zoo3
Carillon Buildin Groundwater gemediation S stem Nl'1`)ES Permit No, NCOo85731
" under the Self-c�nitvring ProgramCategory' The
There are three noted failures to monitor' lied for by March
facility's previous permit expired on August 31,
001. The. new permit was applied
instructed b Charles Weaver of NODE DWQ Water Quality Section DES Unit.
4, 2001 as y ) Manganese
The permit was to be issued in April 200. The failure to monitor monthly Leon (Fe
T
oethane (TCE) concentrations in April 002 was a result of suspending
(Mn), and Tetrachlor April 200
in activities due to the anticipated issuance of the permit in April 2002. The Water
sampling D Q
report indicates that ME was awaiting direction from Susan Wilson of NODE
p
Quality Section NPDES Unit.
under the ,Self -Monitoring Progr a Category of the exceedance of
The ascend noted violation and ermit effluent limit noted on
tetrachloroethane concentrationin excess of the daily maximum � of Violation letter dated April
November 20, 00 was addressed in S&ME's Response to No
violation of the exceedance was corrected in December 002 by the
15, 200. The noted viola ...star had been
repla
cement o the spent carbon once it was noted that the tear chloroethene par detection of
exceeded. After the carbon was replaced, subsequent effluent analyses did no sht�v adefu e
the tetrachloroethene parameter above the permit restricted limit. To pre possible
star, S& has implemented a
exceedances of the permit limit for the tetrachloroethene par months as had
edule for replacement f carbon every five (5) months instead of every six ()
sch
been done previously.
Pro am category addressed the failure to
The third noted violation under the Self -Monitoring April 002 DR. The amended April.
identify the facility status of being non -compliant on the
ein submitted and has been corrected to show the non -compliant facility status.
2002 D is b g
nt cate ory, the Notice of Violation lists a "marginal" rating for
Under the Flow easuremc g
ocumentaion of maintenance and/or calibration schedules to ensure proper functioning
inadequate d
meter. Recorded semi-annual flow meter checks have been instituted as part of our
of the flow perform and record these semi -
inspection activities. All field personnel have been instructed to
2

S&ME Project No. 1354-02-382A
Response to Notice of Violation
annual flaw meter checks.
The operations an
d Maintenance category of the NOV indicated a "marginal" rating for
inadequate documentation of inspections of pumps and valves. Sc,ME has since begun recording
all inspections. All field personnel have been instructed to regard all equipment inspections.
inspec
tions of the eight () wells and pumps supplying the treatment system are on a two-year
schedule and are performed by McCall Brothers. All documentation of these inspections will be
kept on file and available for review.
l ation is needed in response to the Notice of Violation., do not hesitate to contact us
If further exp
at (74) 52-47:26.
Sincerely;
S ME Inc.
iDane A. Ho a, P.B.
jerr ifer Clag orn, E.I. Environmental Services Manager
Staff Professional
Enclosures
cc. Rusty Rozzelle, MCWQP
Bob Landram, Shorenstein Realty Investors Two, LP
3

REVISED
EFFLUENT
ENT
NPDES PERMIT NO. NC: 0085731
DISCHARGE NO. 001 MONTH '. „A`
Pad,:;": ; YEAR 2002
FACILITY NAME Shorenstein Real!j Investors Two, LP CLASS 0-Remediation
COUNTY Mecklenburg
OPERATOR IN RESPONSIBLE CHARGE
(ORC)'
&M s Inc. - Jim fonder GRADE
ILIA PHONE [phone]
CERTIFIED LABORITORLES (I)
PACE Analytical (2)
CHECK BOX IF ORC HAS CHANGED
PERSON(S) COLLECTING SAMPLES
Mail ORIGINAL and ONE COPY to:
?
TT N- CENTRAL FILES
x ,
DIVISION OF WATER DUALITY
(SIG RE OF OPEXATOR IN ftOONSI CHARGE)
BATE
I6I7 MAIL SERVICE CENTER
BY THIS SIGNATURE, I CERTIFY THAT S REPORT IS
LEIGH, NC E76"- 617
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
50050
7839
I045 IOSs
FLOW
Enter Parameter Code Above Name
EFF ■
and Units Below
I INF
e+
d C c
FIRS HRS Y}BtN MGD
}t8%L
m m L
4
6
O
I.
12
13
14
..
16
�m�
IN

Facility Status: (Please check one of th
All monitoring data and sampling frequencies meet
All monitoring data and sampling frequencies do NOT
e following)
permit requirements 0
Complian
neet permit requirements M
Noncomplia
- - - - - - - - - - - -X %A
=N 't in 1\1 -NAIC
V- -)C-ca-
"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, 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,"
"c, LQ
Permittee (Please print or type)
D2 �JN'E
\r
turc- �o
'S (Required)
atur�rf ermi
k4l A
----ASjL-A -
Permittee Address Phone Number
Permit Exp, Date
PARAMETER CODES
00010 Temperature 00556 Oil & Grease 00951 Total Fluoride 01067 Nickel 50060 Total
00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual
00080 Color (Pt -Co) 00610 Ammonia Nitrogen 01092 Zinc Chlorine
00082 Color (ADMI) 00625 Total Kjeldhal 01027 Cadmium 01105 Aluminum
Nitrogen
00095 Conductivity 00630 Nitrates/Nitrites 01032 Hexavalent Chromium 01147 Total Selenium 71880 Formaldehyde
00300 Dissolved Oxygen 01034 Chromium 31616 Fecal Coliform 71900 Mercury
00310 BOD5 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 01045 Iron 38260 MBAS
Residue 00929 Total Sodium 01051 Lead 39516 PCBs
00545 Settleable Matter 00940 Total Chloride 01062 Molybdenum 50050 Flow
Parameter Code assistance may obtained by calling the Point Source Compliance/Enforcement Unit at [phone] or by visiting
the Water Quality Section's web site at hZo—.enr.state.nc.us/wqs and linking to the Unit's information pages,
Use only units designated in the reporting facility's permit for reporting data,
ORC must visit facility and document visitation of facility as required per 15A NCAC 8G �0204.
If signed by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506 (b)
(2) (D).

REVISED
ppro, EFFLUENT
NPDES PERMIT NO, NC 0085731 DISCHARGE NO. 001 MONTH January'
YEAR 2003
FACILITY NAME ShDrenstein Realty Investors Two, LP CLASS 0-RetnediatiDn COUNTY
Mecklenburg
OPERATOR IN RESPONSIBLE CHARGE (ORS') S&&M E Inc. • Nicholas Parker GRADE N/A
PHONE 704- 23-4'726
CERTIFIED LABORITORIES (1) PACE Analytical (2)
CHECK BOX IF ORC HAS CHANGED PERSON(S) COLLECTING SAMPLES Nicholas Parker
Mail ORIGINAL and ONE COPY to:
ATTN. CENTRAL FILES CA C, — ,
DIVISION OF WATER QUALITY (SIGNA UR'E OF OPERAT R IN RESPONSIBLE C GE) DXfE
1617 MAIL SERVICE CENTER. BY THIS SIGNATURE, I CERTIFY THAT THIS R: , RT I5
RALEIGH, NC 276"-16I7 ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
c
so050 78399 1045 1055
FLOW Enter Parameter Code Above Name
EFFS and Units Below
Ems,,
to
INF
HRS HRSY(B/N MGD Jt m m L
I
.. .., ... ..........
4
8
10
II
12
'13 - .
14
'16
18
20
24
2S _
26
.% .. .., , .. .... .. .. . :...
28 13:30 100 Y 0,0210 � . ,�I ti>�� ; , �I1.(la:' 0.066
,29
30
3 .; ... , :..... .. . , :. , , ..
AVERAGE 0.02I0. 0.00 0.00 0 .0 66
MAKIMLIM :.....
MINIMUM 0.0210 . <I .: <0.05 0.066
ttsiarstanenu(I)'IGrob '(G). 1..
Monthly Limit D.0316 8.$5 m
D QFortMR.-LI(01/00)
Notes.
Changed the TETRACHLOItOETHANE Reported Concentration on January 2 , 2002 from ND to <1 µg/L (the Laboratory Minimum Detection Limit)
Changed the IRON Reported Concentration on January 28, 2002 from ND to <0.05 mg/L (the Laboratory Minimum Detection Limit)
Effluent Limitations. Flaw = Monthly Avg., All Other Parameters — Daily Maximum
to - monitor only, no limitation
mg/L - milligrams per liter, ng/L = micrograms per liter
When calculating the arithmetic mean, the less than detection limit value is considered to equal zero.
If all results for a particular parameter during the month are less than the detection limit value, than the average for the month is recorded as zero.
The maximum and mi ium for the month are recorded as the value or the less than detection limit value

>-,LDLLd
Marc]
'IL
ECEIPT BKQEESTED 7001251
William
North Carolina Dezaxi^ent of Environment an
Alan W. K
Divis
17, 2003
10004 8287 7729
a Ho beak; Chief Engineer
t Realty Investors Two, LP
Grade Street, Suite 330
SIC 28202
Subject: Notice of Violation - Effluent nt i it ton
The Carillon Building Groundwater Remediati
DES Permit No. NCO085731
Mecklenburg County
)b p.
parameter:
Parameter Re orted value Limit
T trachlor here 9.4 ug/L 8.85 g/L FIN
If you have questions concerning this matter, please do not hesitate to contact Mr. Bride
at 704/ 63-1 99.
Sincerely,
A-11
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Point Source Complian /Enforcment Unit
RMB
Customer Service Mooresville Regional Office, 919 North Main Street, Mooresville. NC 28115 PHONE'
tit d E NUR 1 800 62'-7r48 FAX

V�i�A&Cxw T-. =i
William G� Pt)$
North Carolina Department of� =_nvtionmetir anci rs�aj
Alan W. Kftme�
Division r
June 25, 2002
In Preston Hornbeak, Chief Engineer
iorenstein Realty Investors Two, LP
17 West Trade Street, Suite 330
harlotte, North Carolina 28202
SUBJECT: Compliance Evaluation Inspection
Shorenstein Realty Investors Two, LP
The Carillon Building GWRS
NPDES Permit No. NCO085731
Mecklenburg County, N.C.
ear Mr. Hombeak:
On June 12,2002, Mr. D. Will Autry of the Mecklenburg County Water Quality Pro
,osed report should be self-explanatory.
call Mr. Richard Bridgeman or me at this office.
'Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
sty Rozzelle, MCWQP
)85731,602
ality 919 North Main Stre—et, Mooresville NC 28115 Prione (704) BW�-169S
AX [phone]

W 'S
T
Transaction Code NPDE;
N 5 NCO08
0�5
9 QA
N
;�ccuonn_rarjmymma
Name and Location of Facility Inspected: Entry Time: 11:00 am
Permit Effective Date:
June 12,2002
December 1, 1996
The Carillon Building GWRS
g
227 W. Trade St. Exit Time/Date: 11:40
am Permit Expiration Date:
Mecklenburg County, NC June 12, 2002
August 31, 2001
Name(s) of On -Site Representative(s)/Title(s)/Phone No(s)/Fax No(s):
Mr. Jim Ponder / S&ME, Inc. I Operator in Responsible Charge (ORC) / 704-523-4726
Name and Address of Responsible Official: Title: Chief Engineer
Mr. Preston Hombeak
Shorenstein Realty Investors Two, LP
227 West Trade Street, Suite 330 Phone No: [phone] Contacted? No
Charlotte, NC 28202
,Section�,C:Ar,eas�,EvaluatedDuring4o�oectioit. !yk�horeareas�,evaluated)",�",
v/ Permit K Flow Measurement Operations & Maintenance
Sewer Overflow
,v/ Records/Reports Self -Monitoring Program Sludge Handling/Disposal
Pollution Prevention
v" Facility Site Review Compliance Schedules Pretreatment
Multimedia
Effluent/Receiving Waters VLaboratory Storm Water
Other:
See Attached Sheet(s) for Summary. All areas rated satisfactory unless otherwise noted.
Name(s) and Sign ure(s) of Inspectors- Agency/Office/Telephone No:
Date:
D� Will Autry MCWQP / [phone]
June 20, 2002
Date:
Signature of Management QA Reviewer: Agency/Office/Phoue & Fax No:
Date:
EPA Form 3560-3 (Rev. 9-94) Previous editions are obsolete

Ale
GENERAL:
The facility was last inspected on April 24, 2001 by Mr. David J. Rimer of the
Mecklenburg County Department ent of Environmental Protection ( CD P). A Compliance
Evaluation Inspection Report was issued on May 17, 2001.
PERMIT:
The NPDES permit for the facility expired on August 31, 2001. The pennittee had
submitted the application for permit renewal prier to the last inspection on April 24, 2001, but
has not received a new pennit or other notification from the division. As such, the facility is
presently operating under the expired permit.
The groundwater remediation system consists of a surge tank, two transfer pumps, and
two carbon adsorption units.
S ME, Inc. of Charlotte, NC operates the ground water remediation facility. Jim Ponder
is the Operator in Responsible Charge (ORC) for the facility,
RECORDS/REPORTS:
Discharge Monitoring Reports (DMRs) were reviewed for the period April 2001 through.
February 2002.
Records, reports, and logs are clear d wellmaintained; no discrepancies were noted.'
FACILITY SITE
All of the major components of the facility were in service and appeared to be operating
properly at the time of the inspection, except for one of the pumps which is about to be serviced.
The facility discharges to the City of Charlotte's Municipal Storm Sewer System, which
discharges to Irwin Creek. Irwin Creek is a Class C water in the Catawba :River Basin.
Cl►W MEASUREMENT:
Flow measurement at the facility is accomplished using a totalizer flow meter in
accordance with an NPDES Permit Modification elated October 20, 1999.
L O TORY:
Analysis of effluent samples is performed by Pace Analytical. Pace Analytical Services,
Inc. is certified by the state of North Carolina to perform analysis on all parameters specified in
the permit. Pace Analytical was not evaluated under this inspection.

EFFLUENT/RECEIVING WATERS:
e facility discharges to the City of Charlotte's Muni
underground piping and is therefore not accessible. The Storr
Creek, a Class C water in the Catawba River Basin.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (D s) were reviewer
February 2002. The reports indicate that the facility was in cc
frequencies and permit effluent limits at the times of ono 'tori
for the following:
The Tetrachloroethen, Iron, and Manganese values w
May 2001 D
This was discussed with. the CRC during the inspection. He
sampling and will be submitting an amended D R to correct
OPMAINTENANCE:TIONS &
The facility and site appeared properly operated and
operating strategy appears acceptable for the size and type of
ere not properly indicated on the
produced documentation of the
this error.
aintained. The current overall
the facility.

Cove r
PPP 7�� Michae
William G. Ross, Jr;, ecretary
cNorth Carolina Department of Environment and Natural Resources
KerrT. Stevens, Director
Division of Water Quality
May 17, 2001
Freston Ho beak:, Chief Engineer
Shorenstein Realty Investors Two; L
227 test Trade Street, Suite 330
Charlotte, North Carolina 2 202
SUBJECT: Compliance Evaluation Inspection
Shorenstein Realty Investors Two, Lp
e Carillon Building GWRS
N DES Permit No. NCO085731
Mecklenburg County, N.C.
Dear Mr. Ho bear:
On April. 24, 2001, Mr. David Rimer of the Mecklenburg County Department of
Environmental Protection ( ICDEP) conducted an inspection at the subject facility. This
inspection was conducted as part of a cooperative working agreement between Mecklenburg
County d 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 co not
hesitate to call Mr. Richard Bridgeman or me at this office.
Sincerely,
.1
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc: Rusty Rozzelle, MCI E
DR
FILE:; WQ 008 731.401
#+�75EW,
Customer Service Mooresville Regional Office, 919 North Main Street, Mooresville, NC 29115 PHONE (704) 16 9
1 800 6 3-7748 FAX [phone]

Environmental
.. li I YYYm
..
g;
/Dat
stit
noM PMTitle:
INCH
Chief Efigi4w
III,
�3�� L
Phone�o I 2r��_
# i # iDate:
i 5500
;.....
-;��"nageuiottt QA Reviewer: Agency/Office/Phone & Fax No:
—7-
Dk�;
aa

GENE
The facility was last inspected on June 23, 2000 by Mr. David J. Rimer of the
Mecklenburg County Department ent of Environmental Protection (MCDEP), A Compliance
Evaluation Inspection Report was issued. on July 14, 2000.
PE
The NPI ES permit for the facility expires on .August 31, 2001. The permittee has
submitted the application for permit renewal. The current permit properly describes the facility
d appears adequate for the waste stream being treated.
S, Inc. of Charlotte, NC operates the ground water remediation facility. Jim Ponder
is the Operator in Responsible Charge (ORC) for the facility.
RECORDS/REPORTS:
Discharge Monitoring Reports (DMRs) wwere reviewed for the period March 2000 through
February 2001 and appeared to be properly completed.
Records, reports, and logs are clear and wellmaintained; no discrepancies were noted.
FACILITY CILI'T " SITE VIE
The groundwater remediation system consists of a surge tank, two transfer pumps, and
o carbon adsorption units.
All of the major components of the facility were in service and appeared to be operating
properly at the time of the inspection.
e facility discharges to the City ofCharlotte Municipal Storm Sewer 'System, which
disc ges� to Irwin Greek. Irwin Creek is a Class C water in the Catawba River Basin.
FLOW MEASUREMENT:
Flaw measurement at the facility is accomplished using a totalizer flow meter in
accordance with an NPI ES Permit Modification letter dated October 20, 1999.

LABORATORY:
Analysis of effluent samples is performed by Pace Analytical, Pace Analytical Services,
Inc, is certified by the state of North Carolina to perform alysis on all parameters specified in
the permit. Pace Analytical was not evaluated under this inspection.
EFFLUENT/RECEIVINGWATERS:"
e facility was not discharging at the time of the inspection.
SELF -MONITORING PROGRAM:
Discharge Monitoring Reports (U s) were reviewed for the period March 2000 throug
February 2001. The reports indicate that the facility was meeting permit effluent limits and
monitoring requirements during this period. The reports indicate that all parameters are being
monitored at the required frequencies and locations.
OPERATIONS & MAINTENANCE:
The facility and site appeared properly operated and maintained. The current overall
operating strategy appears acceptable for the size and type of the facility.

C.
NCDENR
North CE
January 29, 21
DA-VID DILLARD
SHORENSTEIN RFALTY INVESTORS
227 West Trade Street, Suite 330
CT- AR.LOTI' , NC 2820
Dear Permitteew
The subject permit expires on August 31, 2001 North Carol
the permit by this date may resin
u delinquency of the request.
Michael F. Easley
Governor
William G. Fuss, Jr.„ Secretary
olina Department of Environment and Natural Resources
Kerr T. Stevens, Director
Division of Water Quality
)1 tr tqP l �
IIC
neat of civil penalties of up to $25,000 per day
Mecklenburg County
discharge has ceased at your facility and you Irish to rescind this permit, contact B l
sforcetnent Unit at (919) 733- 083, extension 547. You may also contact the Moore%
to begin the rescission process.
I checklist to complete your renewal package. The checklist identifies the items you
ed at the bottom of this page.
Sincerely;
IW4 �, I ItAl
Charles H. Weaver,jr,
NPDES Unit
leg
a
n
Uel
it Service Center, Raleigh, North Carolina 27699-1617 919 733.508 , extension 511 (fax) 919 733-071
SON THE INTERNET @ hftp://h2o.enr.state.nc.us/NPDES e-mail: [e-mail]

NPDES Permit NCO085731
SHORENSTEIN REALTY INVESTORS
Mecklenburg County
The following items are REQUIRED for all renewal packages:
U A cover letter requesting renewal of the permit and documenting any changes at the facility since
issuance of the last permit, Submit one signed ori&al and two copies.
U The completed application form (copy attached), signed by the permittee or an Authorized
Representativc. Submit one signed original and two copies.
U 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 any
such Authorized Representative (see Part II.B. 1 Lb of the existing NPDES permit).
U A narrative description of the sludge management plan for the facility. Describe how sludge (or other
solids) generated during wastewater treatment are handled and disposed. If your facility has no such
plan (or the permitted facility does not generate any solids), explain this in writing, Subirtit one signed
original and two copies.
The following items must be submitted ONLY by Industrial facilities discharging pLqcess
wastewater:
U Industrial facilities classified as Primary Industries (see Appendices A-D to Title 40 of the Code of
Federal Regulations, Part 122) must submit a Priority Pollutant Analysis (PPA) in accordance with 40
CFR Part 122.21. If the PPA is not completed within one week of March 4, 2001, submit the
application package without the PPA. Submit the PPA as soon as possible after March 4, 2001.
The above requirement does NOT apply to municipal or non-industlialfacifftles.
PLEASE 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:
Mr. Charles H. Weaver, Jr.
NC DENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
919 North Maim Street Mooresville, North. Carolina 28115
November 24, 2003
CERTIFIED MAIL
RETURNCEIPT REQIMSTED
7003 2260 00013491 0824
Mr. David Dillard
Shorenstein Realty Investors/Carillon Building
227 W. Trade Street, Suite 330
Charlotte, North Carolina 28202
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NCO085731
horenstein Realty Investors Treatment Facility
Mecklenburg County
Dear Mr. Dillard:
This is to inform you that a review of your toxicity self -monitoring report form for the month of
September 2003 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the
effluent toxicity violatio(s). Your efforts may include conducting a Toxicity Reduction Evaluation
(T ) which is a site -specific study designed to identify the causative agents of effluent toxicity, isolate
the sources of toxicity, evaluate the effectiveness of toxicity control options, and then confirm reductions
in effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil
penalties for violations of NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent
Toxicity Monitoring and Reporting Requirements. 'lease note updated mailing addresses fear submitting
your Discharge Monitoring Reports (I MRs) and Aquatic Toxicity (AT) 'Test Forms. We encourage you
LW I VlI YY LL110 Al$1 VLdAY4i4L J11 44 .- Z1 S& vY a.ra _ a.+v - w+c vv;u ci+av uavvwal- - r,-w--u xw .x..+....a... _ .-
resolve effluent toxicity noncompliance, please contact Mr. John Lesley with this office at (704) 663-
169 .
Sincerely,
D. Rex Gleason, P.E.
Regional Water Quality Supervisor
cc; Aquatic Toxicology Limit
Central Files

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
The following items are provided in an effort to assist you with identifying critical and sometimes overlooked
toxicity testing and reporting information. Please take time to review this information. The items belpw do not
. if
you should have any questions about your toxicity testing requirement, please contact Mr. Kev in Bowden with
the Aquatic Toxicology Unit at [phone] or another Unit representative at the same number.
The R�� �ittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement
and that toxicity report forms are appropriately filed.
The reporting of whole effluent toxicity testing data is a dual recuirement. All toxicity test results must be
entered (with the appropriate parameter code) on your monthly Discharge Monitoring Report which is
submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
!Ioqx�icii test �resultsshall be filed with the Environmental Sciences Branch no later than 30 days afterlhe end
of the revorting-period (eg, January test result is due by the end of February).
Toxicity test condition language contained in your NPDES permit may require use of multiple concentration
toxicity testing upon failure of any single quartierly toxicity test. If the i'nitial pass/fail test fails or if the chronic
value is lower than the permit limit, then at least two muitiple concentration toxicity tests (one per month) will
be conducted over the following two months. As many analyses as can be completed will be accepted. If your
NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single
quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration
toxicity testing per the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple
concentration toxicity testing will influence the Division's enforcement response.
Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic
toxicity monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June,
September, and December, then toxicity testing must be conducted during these months).
If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-
June 30, then you must provide written notification to the Environmental Sciences Branch by June 30 that a
discharge did not occur during the first six months of the calendar year.
> If you receive notification from your contract laboratory that a test was invalidated, you should immediately
notify the Environmental Sciences Branch at [phone] and provide written documentation indicating why
the test was invalidated and the date when follow-up testing will occur.
> If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should
complete the information block located at the top of the AT form indicating the facility name, permit number,
pipe number, county and the month/year of the subject report. You should also write "No Flow" on the AT
form, sign the form and submit following normal procedures.
> The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except
for facilities which have not received a facility classificat�on, In these cases, a duly authorized facility
representative must sign the AT forin. The AT form must also be signed by the performing lab supervisor,
To determine if your AT test forms were received on time by the Division of Water Qualitv, you may consider
submittine vour toxicity test results certified mail, return receipt requested to the Environmental Sciences
Branch.