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HomeMy WebLinkAboutNC0088226_Regional Office Historical File Pre 2018 (3)ILE DOPER EL S. REGAN LINDA CULPEPPER Director Certified Mai 7015 1520 0002 8386 8653 Return Receipt Requested Suzanne Fountain Wells Fargo Bank N A 550 S Tryon St 30th Floor Charlotte, NC 28202 NOWT AROLINA Environmental Quality February 27, 2019 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2019-LV-0125 Permit No. NC0088226 Duke Energy Center dewatering system Mecklenburg County Dear Permittee: A review of the February 2018 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s) indicated below: Limit Exceedance Violation(s): Sample Limit Reported Location Parameter Date Value Value Type of Violation 001 Effluent Lead, Total (as Pb) (01051) 2/20/208 01 Daily Maximum Exceeded Remedial actions, if not already implemented, should be taken to correct any noted problems. The Divisioi Water Resources may pursue enforcement actions for this and any additional violations. If the violations an continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent (SOC). If you have any questions concerning this matter or to apply for an SOC, please contact Edward Watson of the Mooresville Regional Office at 704-663-1699. Sincerely, tg- W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ Cc: WQS Mooresville Regional Office - Enforcement File NPDES Compliance/Enforcement Unit - Enforcement File nvavnmenta3 Quatity Di Esat Centex A nue,Sule 301 Me g e 281.15 Mr. Roach June 3, 2015 Page 2 of 2 Concurrent with this notification, the Division will solicit public comment on this draft by publishing a notice in newspapers having circulation in the general Mecklenburg County area, as required by the NPDES Program. Please provide your comments, if any, to me via email [derek.denard@ ncdenr.gov] or write to my attention care of DENR / DWR / NPDES Program no later than. July 10, 2015. Your written comments are welcome but not mandatory. Following the mandatory 30-day public comment period, the Division will review all pertinent comments on your permit draft, and take appropriate action prior to issuing your NPDES permit final. If you have questions concerning this draft, please e-mail me or call my direct line (919) 807-6307. Sincerely, Derek Denard, Environmental Specialist Division of Water Resources, NCDENR Enclosure: NPDES Permit NC0088226 (renewal DRAFT) hc: NPDES Program Files [draft permit and Fact Sheet] Brian T. Olin, P.G., ECS Carolinas, LLP [1.812 Center Park Dr. Suite D, Charlotte, NC 28217] ec: MRO / Michael Parker [michael.parker@ncdenr.gov] [draft permit, Fact Sheet] MRO / Wes Bell [wes.bell@ncdenr.gov] [draft permit, Fact Sheet] Richard Farmer [Richard.farmer@mecklenburgcountync.gov] [draft permit, Fact Sheet] Wastewater Operator Certification Group / Steve Reid [steve.reid@ncdenr.gov] [draft permit, Fact Sheet] Aquatic Toxicology Unit/ Susan Meadows [susan.meadows@ncdenr.gov] [draft permit, Fact Sheet] Permit NC0088226 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER RESOURCES PERMIT RECEIVED/NCDENR/DWR JUN 9 2015 WQROS MOORESVILLE REGIONAL OFFICE TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) In compliance with the provisions of North Carolina Gen and regulations promulgated and adopted by the North Commission, and the Federal Water Pollution Con to receivin the Cata conditions s is hereby authorized to na t~,n as amende Wells A. ge 215.1, other lawful standards ntal Management acility locate Wells Fare T tre VAR 500 2 202 The permit shall beco e ed kUnnamed Tributary to Little Sugar Creek in h efflueations, monitoring requirements, and other ereof. , 2015. This permit and the authorizao discharge shall expire at midnight on June 30, 2020. Signed this day , 2015. S. Jay Zimmerman, Director Division of Water Resources By Authority of the Environmental Management Commission Page 1 of 6 OCT. 0. 2016 86AM ECS CI-ARLOTTE NO. 580 P, Sipanne: certify that 1 agree to my designation as a Sack -up Operator in Responsiblt Charge for tiro facility noted. i tarderstand and will abide by the rides and retrulasinns pertaining to the responsibilities of the 13U ORC ES set forth in 15A NCAC 011G .0205 and fsiling to do so can result in Disciplinary Acsiom by the Water PuUation Conwl System Operators Certification Commission_" ..... «..........................................................(........... t......................... t................................., ........... Mali fax or emir Ike WPC CC, 1618 Mai Service Center, Raleigh, NC 27699-161S Fax: 919.7151126 original tel: Russia: ceriadiniri ainc4enrapv Water Pollution Control System Operator Designation Form WPCSoCC NCAC ISA $G 4201 Officer Name: (rc. f) C-t \ l Permittee Owner/ Mailing Address: s City:,r_ c Email address: �t1. Signature: Facility Name: State, ) x t Zip: ,`C'. - W(kkCS SUBMIT A SEPARATE FORM FOR EACH TYPE SYSTEM! Facility, Type/Grade: Biological WWTP Physical/Chemical Collection System Stirface lrrigaticn Land Application ..R t',.r.....1...t.4.640 «4**WW*041. *01.0 1.#"M.fe I1w1IM`r#M#s.tFa+r.rIYRYMtwit. Moft t#tM..rt►*r,** lw,*,*,#!11#...........M......................re Ri*V.*******. Operator in Responsible Charge (ORC) Print Fu11 Name: Certificate Type / Grade / Number: Wi! . / 4- gtt$ture: Work Phone #: Date: Ie) ](]-;(,, *`1 certify that 1 agree to my designation as the Operator in Responsible Charge for the ibeeilily noted. l emderstand and will abide by the rotes and regulations pcsceining to the to pensibilitiesofthe ORC as set ihrth in 'SA NCAC 0$G .0204 and failing to do so con result at Disciplinary Actioazs by the Water Pollution Cannel System Operators Certification Commission-" Back -Up Operator in Responsible Charge (DU ORC) Print Full Name: 3r"' 0 r .. (Ain Certificate Type / Gracie / Number' I'iZ i, \t7b"4) `+ 'Work Phone #: £1S1 1.g"Z_ Date: _ 1—iCti-- (t Maif 4r fax a copy to the Asheviilc 2090 US Hwy 70 Sweets on 28778 Fax: 828.99.7843 Phone. 828.296.4500 appropriate Regional Officer Washington 943 Washington $q Mall Washington 278$9 Fax: 752.946.9215 Phone: 752.946.6481 Fayetteville 225 Green St Suite 714 Fsyett villc28301-5043 Far: 910486.0707 Phornt 910.4333300 Wilmington 127 Cardinal Dr Wilmington 28405-21145 Fax: 91%350.2004 Phone: 910.796.7215 Mooresville 610E Center Ave Suite 301 Mooresville 2811 S Pax: 704.663.6040 Phone: 704463.1699 Winston-Salem 585 Waughtown St Winston-Salem 27107 Fat Phone 336.771.5000 Raid/0 3800 Semen Dr Raleigh 27609 Fax: 919571.471$ 1'boua 919.791.4Z00 Rtivisod 03-2014 OCT. 10. 2016 11:06AM ECS C -ARLOTTE NO. 580 Facility Fume: .a.a..I.tx.xt�y�'x�lxkYx'Mtttxsxxxkkifxklx.lY.xkkxx***s at■^�+tkaa*s*s yt.j44 akxii.ixx*x*A.a4tfwxk.xllllgM.a..4MM4txt.ski■*......k...........kx.xxxFxkx Back -Up Operator in Reepoosible Charge (BU ORC) Print Full Nam Certificate Ti Sigtature: N Work Phone #: (701.1 Date: 1046 -142 i certify that I agree to my designation as a ]rack -up Operator in Responsible Charge fiir the Iltaility noted. I understand and will abide by the rules sad regulations pertaining to the responsibilities of the BU ORC as set forth in I SA NCAC 08G .0205 and Sal -mate do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." .wa.aa...x.r.xx..ft.....awl.a.wat.....s..................xx.....a....tw..M.x#..a.x.xx..tk4...NN...af...*x....x......xw..4ii.xa.N*Y�tx......t....a.■.aa. Back -Up Operator in Responsible Charge (BU ORC) Print Full Name: Certificate Type I Grade / Number: Signature: "1 certify that T agree to ury designation as a Back-up Operator in Responsible Charge for the facility noe d I tnderstand and will abide by the rules and regulations pertaining to this responsibilities of the BU ORC asset forth in tSA NCAC 080 .0205 and hulling to do so cm result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission.* xw...art...xt.*Mill..-n..s,*.....N...xa.a....aa.......a..at..x...*nw.ax...fiataxar.r..t...t..w...w....kr................t4a.Mi4.ht....aat.4.t Back -Up Operator in Responsible Charge (BU (RC) Print Full Name: Certificate Type / Grade / Number: _ Vt+o Signature=taste xA .. a entity that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by Etta rules and regulations pertaining, to the rrvl+ancr"hilities of the BU ORC as set fo Ih in l SA NCAC 08G .0205 and failing to do so can result in Disciplinary Actions by the Water Pollution Control SySsern Operators Certification Corniissinn " .■.........■............ w•■..o...k.No.... ••w..wrua..... u..w.v.vw Hq. u.ur.................................................... ta..... Back -Up operator in Responsible Charge (BU ORC) Print Full Name: Certificate Type / Grade / Number: Signature: Date: TMl certify that I agree tG+ rrry designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by tha rules and neulations pertaining to the responsibilities atilt lilt ORC as set forth in I5A NC11f:080 ,0205 and railing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission-" Work Phone#: ..a•...•......a.n..a..nn........M.•...aa..N..4..N........x......a.w.w....M.aa...Y..N.........Ma.N..tl.. i.t............•......w.«..n........•.t....... Revised 03-2014 Water Resources Environmental Qual ity January 10, 2018 Mr. John Cranfill, Senior Chief Engineer (via email) Childress Klein 550 S. Tryon Street, Suite 180 Charlotte, NC 28208 Dear Mr. Cranfill: ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director Subject: Compliance Evaluation Inspection Wells Fargo / Duke Energy Center Groundwater Rernediation NPDES Permit No. NC0088226 Mecklenburg County Enclosed is a copy of the Compliance Evaluation Inspection for the inspection conducted at the subject facility on January 9, 2018, by MRO staff. Your cooperation during the site visit was much appreciated. Please advise the staff involved with this NPDES Permit by forwarding a copy of the enclosed report. The MRO would also like to extend a thank you to Brian Balesky and Wayne Way, Lead Technician Childress Klein, Chris Orrell and David Valentine of ECS and Mario Van Severen, of rethinkhzo. The system was observed to be operating within the permit guidelines. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Edward Watson at (704) 235-2198, or at edward.watson@ncdenr.gov. Sincerely, Edward Watson Hydrogeologist Division of Water Resources Mooresville Regional Office, NCDEQ CC: Chris Orrell, ORC (via email) " '"Nothing Compares - State of North Carolina 1 Environmental Quality; Water Resources 1 Wa'ter Quality Regional Mooresville Regional Office 1610 East Center Avenue, Suite 3011 Mooresville, North Caro 704-663-1699 ration 28115 EPA United States Environmental Protection Agency Washington, ©.C. 20460 Water Compliance Inspection Report Section A: National Data System Coding (i.e., PCS) Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Transaction Code NPDES 1 IN I 2 L 1 NC0088226 If l 12 1 18/01/09 117 18 Li I 19 1.L1 2011 211I11 1 I I I I I II I I I I I I 1 1 I I I I I I I I I I I I I I I II I I I I I r6 yr/mo/day Inspection Type Inspector Fac Type Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 6711,0 I 7013 1 71 ID Section B: Facility Data QA 721N1 11 174751III II1180 Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES oermit Number) Duke Energy Center dewatering system 550 S Tryon St Charlotte NC 28202 Entry Time/Date 10:30AM 18/01/09 Exit TimelDate 12:50PM 18/01/09 Permit Effective Date 15/09/01 Permit Expiration Date 20/06/30 Name(s) of Onsite Representative( s)ifittes(s)1Phane and Fax Number(s) /// Christopher David Orrell/ORC/704-200-3436/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Rhonda F Ballard,550 S Tryon St 30th Floor Charlotte NC 28202//704-374-47 Per 1111 Self -Monitoring Program Contacted No Section C. Areas Evaluated During Inspection (Check only those areas evaluated) Flow Measurement Operations & Maintenance • Records/Reports Facility Site Review Effluent/Receiving Waters aboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Edward Watson MRO GW/// Agency/Office/Phone and Fax Numbers EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete, Date Date Page# r � vr/m»ay 1am1me Inspection Type Section D,Summary o[Find ing/Cmnmmnts(Attach additional sheets nfnarrative and checklists asnecessary) On January 9, 2018, a representative of MRO conducted a compliance inspection under permit NCO088226 for the Duke Dewatering system located at 530 S. College Street, Charlotte, Mecklenburg County. The system was in operation during the site visit and system components were able to be reviewed. The system has a bypass cumponent, but all bypass water is routed throughtthe air stripper prior to being released toassure that noC.00.'Senter into the recievingstream. Historic Chronic Toxicity records indicate the sytem regularly passes wet testing. Analytical data indicates the system is operating within permitted conditions. During the site visit it was mentioned that although not required in the permit; influent and midpoint sampling would behelpful forundersbandingbeyaWhnoughoftheZeo|haondmveuaUsyabam effectiveness. ChildressKlein indicated that they wouild consider the additional sampling and if the additional sampling was performed, the analytical data would be shared with MRO, Reuse water from asecondary system not in this permit, captured from the permitted system and is run through the secondary system which also employs UVtreatment, The reuse water ioutilized for cooling water for the building H\AACsystem. �~ pennu munopmoa Inspection Date: 01m9m018 o~"e, mm/mv: Duke Energy Center ue~^terinnsystem Inspection Type: Compliance Evaluation Permit Yes No N4 NE (If the present permit expires inOmonths or|ess). Has the permitteesubmitted anew 0 1:1 0 El application? |othe facility andescribed inthe permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? 0 0 El El Is the inspector granted access to all areas for inspection? 0 0 El 0 Comment: This permit does not expire unh|G/3OCZ82O. Permit renewal applications must bereceived 180 days Prior to the expiration of the current permit, Operations & Maintenance |nthe plant generally clean with acceptable housekeeping? Does the facility analyze pmoono control parameters. for ex: K4L8S. IVICRT, Settleable 8clNa. pH. D0. Sludge Judge, and other that are applicable? Yes 0oNA NE Comment: The system treats water collected tromqhthe dewate nqsump, The operator views the system daily and records flow measurements. Certain system alarms are sent hothe operator via email. The system runs m40minute cycle period that runs a backwash for 1.5 minutes. The back wash alarm has to be re -set manually. The last waste manifest for the Zeohowas available for review, hmwever, the manifest does not indicate final destination for the spent zeolite. Effluent Pipe |nright nfway tothe outfaUproperly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: The effluent pipe is not able to be observed as the system desiqn has the pipe situated in an position that innot occauoob|e. However, asample was collected prior tothe discharge point and no odors, foam or solids were observed. FlonmMeasuremment-Effluemt #|nflow meter used for reporting? |oflow meter calibrated annually? |othe flow meter operational? (If units are separated) Does the chart recorder match the flow mete,? Comment: This system does not use a chart recorder. The flow meter was calibrated on 12/28/2017. Permit: NC0088226 Inspection Date: 01/09/2018 Owner -Facility: Duke Energy Center dewatering system Inspection Type: Compliance Evaluation Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Yes No NA NE ❑ ❑ ❑ ■ ■ ❑❑❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ DO NO Comment: Laboratory data was reviewed for 2017 during the site visit. The analvtical data is current and there were no constituents reporting above permitted limits. Sampling was not observed durinq this site visit. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6,0 degrees Celsius)? Is the facility sampling performed as required by the per representative)? frequency, sampling type Yes No NA NE ❑ ❑ ■ ❑ ■ © ❑ ❑ El ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: Sample collection was not observed during the site visit. A mention was made to be sure that Chain of Custody reflects that samples are preserved on ice. Page# 4 Water Pollution Control System Operator Designation For,. WPCSOCC NCAC 15A 8G .0201 Permittee Owner/Officer Name: 4 , 1(', n Cr-cn `t Mailing Address: SkiC) Zc fix* City: Or r','rtrtk-C State: IL. Zip: 2. (' - Phone #: (10)A) 7)" Email address: .1� • � , (�ii310S> Signature: ............... Facility Namkr'+ (1 t ►-re r <,ipt LraVeC Permit#: , SUBMIT A SEPARATE FORM FOR EACH TYPE SYSTEM! Facility Type/Grade: Biological WWTP Physical/Chemical Collection System Surface irrigation Land Application t. mo..•ws....•••..•....kit......i11...........................................................................................fl fl_..........•.. Operator in Responsible Charge (ORC) Print Full Name: ( tr--A-r. 3c r �C. lei (')t-rr I Certificate Type / Grade / Number:'Pe':1 _/ 41) 71i1.10 Work Phone #: (7 Signature: Date: 1() -1 b 'l (o "1 certit'q that l agree to my designation as the Operator in Responsible Charge for the facility noted. l understand and will abide by the rules and regulations pertaining to the responsibilities ofthe ORC as set forth in I5A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." ...............wss...mo...s.t.ws.wsaa........uo..uu.....•u.......s.....amows......mot...............................u..................• Back -Up Operator in Responsible Charge (BU ORC) CA Print Full Name: 1-1 Cs n CA tn Certificate Type / Grade / Number* Wit./ ‘('�' Signature: Work Phone#: (-;ar-t ) Fig-, :l►;� Date: _O-(U-Ji(.0 "1 certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities oldie BU ORC as set forth in I5A NCAC 08G .0205 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Mail, fax or email the WPCSOCC, 1618 Mail Service Center, original to: Email: certadminOncdenr.gov Mail or fax a copy to Me appropriate Regional nee: Asheville 2090 US Hwy 70 Swannanoa 28778 Fax: 828.299.7043 Phone: 828.296.4500 Washington 943 Washington Sq Mall Washington 27889 Fax: 252.946.9215 Phone: 252.946.6481 Raleigh, NC 27699-1618 Fax: 919.7151726 Fayetteville 225 Green St Suite 714 Fayetteville 28301-5043 Fax: 910.486.0707 Phone: 910.433.3300 Wilmington 127 Cardinal Dr Wilmington 28405-2845 Fax: 910.350.2004 Phone: 910.796.7215 Mooresville 610 £ Center Ave Suite 30I Mooresville 28115 Fax: 704.663.6040 Phone: 704.663.1699 Winston-Salem 585 Waughtuwn St Winston-Salem 27107 Fax: 336.771.4631 Phone: 336.771.5000 Raleigh 3800 Barnett Dr Raleigh 27609 Fax: 919.571.4718 Phone:919.791.4200 Revised 03-2014 Facility Name: fir, Permit #: i##ff#ffff«f»fifwwffffNfflWlf#Ntilf fiN.ff##f..fNf#till»fifiilfMf#»M#.fiiif Wfi!!M##Wftfl4tfiliiii#f MfiNiftff fffff#1WW##ffi##iF#YIR#fllf NflXYiFf Mf Nff#fiN Back -Up Operator in Responsible Charge (BU ORC) Print Full Name:-",Lxc �;txsp,�-�' UeN1-e,10A i„to� Work Phone #: (C, 4 ) c-?-1 Date: I C..) - ().-i �p #R certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by tt rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Wf.t#ff Nf Nfflrf iff iffi.fff Nfffi.iwifWlfff#tftfff.ff•NNNfftfiif#t*N•ffffNff##ff*NfNff#,WNfit*MlNNffffff•fff N#tNNl.tNftfl#Hitt i!!#i#Mf #fffffff N..f.i Back -Up Operator in Responsible Charge (BU ORC) Print Full Name: Certificate Type / Grade / Number: Work Phone #: ( # Signature: ©ate:_ "1 certify that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the BU ORC as set forth in ISA NCAC 08G .0205 and thiling to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." ifwfiwf fff ffl.f*Mffff.*W*♦ffft»#w.NffiffffftfM#fft!#fiffwfwfftfi.ifffflfff*Wf#Mf*M•wtf#fifwfliff#f#twfifNMlf.*WN#tff*Nlff•Niff Wfffi NNf RNtttYl***N Back -Up Operator in Responsible Charge (BU ORC) Print Full Name: Certificate Type / Grade / Number: Work Phone #: ( Signature: Date: "I certify that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." f Nff.f NfffHiMf..ffNfM..l.lil Ni...........fifW...Nwfu.«t..wN.wwWww..f.u..Jf«f#...Nf.ffNNt.ffi....W...wffNNf NNfftftf.fww..attft...f..Ntt.N. Back -Up Operator in Responsible Charge (BU ORC) Print Full Name: Certificate Type / Grade / Number: Work Phone #: ( ) Signature: Date: "1 certify that I agree to my designation as a rules and regulations pertaining to the respo; Disciplinary Actions by the Water Pollution ck-up Operator in Responsible Charge for the facility noted, 1 understand and will abide by the ailities of the R11 ORC as set fnrth in I5A NCAC 08G 0205 and failing to do so can result in ntrol System Operators Certification Commission." +ffii#f«w«a»»«ff«affff#f»##.f#fwfat Wtff w##kt.fi##!#tf#ttM«f ff w.fff#Nfw.f twin»»awtMfi##.fa:ffaaf»»ffffxaf NN#N#«#a#ff#ifffa»ew,ft»«»»«tf.»»f«t##ttf«tt«ff«M«MWs»t«»»Ntwtf tt ttW Revised 03-2014 Water Resources ENVIRONMENTAL QUALITY July 21, 2016 PAT MCCRORY Governor DONALD R. VAN DER VAART Secretary S. JAY ZIMMERMAN Director OFFie,E, Ms. Suzanne Fountain MAC DI086-300 Wells Fargo, N.A. — Wells Fargo Tryon Street GWR 550 South Tyron Street, 30th Floor Charlotte, NC 28202 Subject: Retraction of NOV-2016-LR-0028 Discharge Monitoring Reports (DMRs) for April 2016 Wells Fargo, N.A. — Wells Fargo Tryon Street GWR NPDES Permit NC0088226 Mecklenburg County Dear Ms. Fountain: On July 5, 2016, the Division issued a Notice of Violation (NOV) against Wells Fargo, N.A. — Wells Fargo Tryon Street GWR. The NOV was based upon a violation of the reporting requirement by failing to file the April 2016 Discharge Monitoring Report (DMR) with the Division of Water Resources within the thirty (30) day reporting period. Subsequent to your receipt of the NOV, Brian Olin, P.G., CPG with ECS Carolinas, LLP, contacted the Division indicating that the April 2016 DMR was intended to be submitted electronically by the eDMR system on May 26, 2016. On that day the eDMR was "Certified", but was not "Submitted" through the eDMR system, which required an extra step in processing. A hard copy was mailed on July 1, 2016. On July 16, 2016, an incomplete hard copy was received and our staff noted that the status in the eDMR system reflected "Certified", but did not reflect "Processed." At that time, Brian Olin was notified of the situation by our staff. Afterward, the eDMR was submitted through the eDMR system on June 23, 2016 and the completed hard copy DMR was received on July 8, 2016. Since this was a first attempt at utilizing the eDMR system and the intent was to submit the eDMR on May 26, 2016 in a timely manner, I have withdrawn the NOV against Wells Fargo, N.A. — Wells Fargo Tryon Street GWR for the cited violation and directed that the record of this violation be removed from our files. State of North Carolina I Environmental Quality I Water Resources 1617 Mail Service Center I Raleigh, North Carolina 27699-1617 919-707-9000 Ms. Fountain July 20, 2016 Page 2 of 2 Thank you for your prompt attention to this matter. If you have any questions about this letter or discharge monitoring reports, please contact Derek Denard at 919-807-6307 or via e-mail at derek.denard@ncdenr.gov. Sincerely, S. Jay Zimmerman, P.G., Director Division of Water Resources cc: BRIAN ©LIN, P.G., CPG, ECS Carolinas, LLP [B©lin@ecslimited.com Derek Denard, Compliance & Expedited Permitting Unit NPDES Files NC0088226 Central Files Water Resources ENVIRONMENTAL QUALITY July 5, 2016 CERTIFIED MAIL7009 2250 0000 8087 1061 RETURN RECEIPT REQUESTED PAT MCCRORY Governor DONALD R. VAN DER VAART SSrn>Inry S. JAY ZIERMAN Ms. Suzanne Fountain MAC DI086-300 Wells Fargo, N.A. — Wells Fargo Tryon Street GWR 550 South Tyron Street, 30`h Floor Charlotte, NC 28202 Subject: Notice of Violation/Recommendation for Enforcement (NOV NOV-2016-LR-0028 Late Discharge Monitoring Reports (DMRs) for April 2016 Wells Fargo, N.A. — Wells Fargo Tryon Street GWR NPDES Permit NC0088226 Mecklenburg County Director E Dear Ms. Fountain: A review of the Division of Water Resources (DWR) database which tracks the monthly submittal of Discharge Monitoring Reports (DMRs) revealed that the April 2016 DMR has not been filed with the Division within the thirty (30) day reporting period in accordance with the monitoring and reporting requirements contained in your NPDES permit. The April 2016 DMR. was received late on June, 23 2016. A Notice of Violation (NOD-2016-LR-0003) [see enclosed copy] was sent to you for failure to submit the January 2016 DMR no later than the thirtieth (30th) day following the reporting period. This notice was received by you on April 21, 2016. Within said Notice, you were informed that future reports not received within the required timeframe would result in further enforcement actions. The January 2016 DMR has not been received by mail or eDMR. This Notice of Violation/Notice of Recommendation for Enforcement (N©V/NRE) (NOV-2016- LR-0028) is being issued for the late April 2016 DMR. Based upon the above facts, I conclude as a matter of law that Wells Fargo, N.A. violated or failed to act in accordance with the requirements of NPDES Permit NC0088226 and G.S. 143-215.65. A civil penalty of not more than $25,000.00 per violation may be assessed against a person who fails to file, submit, or make available any documents, data, or reports required by G.S. 143-215.65. The State's enforcement costs in this matter may be assessed pursuant to G.S. 143-215.3(a) (9) and. G.S. 143-282.1(b) (8). State of North Carolina I EnvirotYmental Quality I Water Resources 1617 Mail service Center Raleigh, North Carolina 27699-1617 919 807 6300 Ms. Fountain July 5, 2016 Page 2 of 2 If you wish to provide additional information regarding the noted violations and prevent further action, please respond in writing within ten (10) days of receipt of this notice. A review of your response will be considered and you will be notified of any civil penalties that may be assessed. regarding these violations. If no response is received in this Office within the 10-day period, a civil penalty may be assessed. If you have any questions about this letter or discharge monitoring reports, please contact me at 919-807-6307 or via e-mail at derek.denard@ncdenr.gov. Sincerely, S. Jay Zimmerman, Director f- Division of Water Resources cc: Derek Denard, Compliance & Expedited Permitting Unit NPDES Files NC0088226 Central Files PAT MCCRORY Goirrign DONALD R. VAN DER VAART Water Resources ENVIRONMENTAL QUALITY April 12, 2016 CERT FMB IVIAIL7013 2630 0001 8998 4407 RETURN RECEIPT REQUESTED Mr. John Cranfill, Sr. Chief Engineer MAC DI086-300 Wells Fargo, N.A. — Wells Fargo Tryon Street GWR 550 South Tyron Street, 30th Floor Charlotte, NC 28202 Subject: NOTICE OF DEFICIENCY (NOD-2016-LR-0003) Late Discharge Monitoring Reports (DMRs) for January 2016 Wells Fargo, N.A. — Wells Fargo Tryon Street GWR NPDES Permit NC0088226 Mecklenburg County Dear Mr. Cranfill: Secretory. S. JAY ZIMMERMAN' arreciiir This is to inform you that the Division of Water Resources received the monitoring report for January 2016 late on March 29, 2016. This is in violation of Part il, 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 reporting 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. Additionally, this letter provides notice that this office will recommend the assessment of civil penalties if future reports are not received within the required time frame during the next twelve (12) reporting months. The Division must take these steps because timely submittal of discharge monitoring reports is essential to the efficient operation of our water quality programs. We appreciate your assistance in this matter. If you have any questions about this letter or discharge monitoring reports, please contact me at 919-807-6307 or via e-mail at derek.denard@ncdenr.gov. . Jay Zimmerman, Direct Division of Water Resources cc: Derek Denard, Compliance & Expedited Permitting Unit MRO DWR WQROS (NP-DESTAYCl/088,22:6") Central Files Brian Olin, ECS CAROLINAS, LLP,1812 Center Park Drive, Suite D, Charlotte, NC 28217 State of North Carolina I Environmental Quality I Water Resources 1617 Mail service Center I Raleigh, North Carolina 27699-1617 919 807 6300 Water Resources ENVIRONMENTAL QUALITY June 24, 2016 Rhonda Ballard Wells Fargo Bank N A 550 S Tryon St 30th Floor Charlotte, NC 28202 Subject: NPDES Electronic Reporting Requirements Duke Energy Center Dewatering System NPDES Permit Number: NC0088226 Dear NPDES Permittee: PAT MCCRORY DONALD R. VAN DER VAART S. JAY ZIMMERMAN EC .s ._1:1\J'CD ENRIDWIR hirec;tor The U.S. Environmental Protection Agency (EPA) recently published the National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule. The rule requires NPDES regulated facilities to report information electronically, instead of filing written paper reports. The rule does not change what information is required from facilities. It only changes the method by which information is provided (i.e., electronic rather than paper -based). EPA is phasing in the requirements of the rule over a 5-year period. The two phases of the rule, and their key milestones, are: Phase 1—Starting on December 21, 2016, regulated entities that are required to submit Discharge Monitoring Reports (DMRs) will begin submitting these reports electronically. If you are currently reporting your 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, 2020, regulated entities that are required to submit certain other NPDES reports will begin submitting these reports electronically. Reports covered in the second phase include Notices of Intent to discharge in compliance with an NPDES general permit, Sewer Overflow/Bypass Event Reports, and a number of other NPDES program reports. Incorporating Electronic Reporting Requirements into NPDES Permits The NPDES Electronic Reporting Rule requires authorized NPDES programs to incorporate electronic reporting requirements into NPDES permits beginning December 21, 2015. Under the new rule, the electronic reporting process supersedes the paper reporting process. According to our files, your NPDES permit became effective after November 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(I)(9)J. Initial State of North Carolina Environmental Quality j Water Resources ] 617 Mail Service Center Raleigh, North Carolina 27699-1617 919 807 6300 recipient of electronic NPDES information from NPDES-regulated facilities (initial recipient) means the entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving electronic NPDES Data [see 40 CFR 127.2(b)]. Permittees are required to electronically submit the required NPDES information to the appropriate initial recipient, as determined by EPA. By July 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 (NOIs); Notices of Termination (NOTs)j; 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 http://www2.epa.gov/compliance/final-national-pollutant-discharge-elimination-system-npdes- electronic-reporting-rule. For more information on electronic reporting to NC DWR, visit http://deq.nc.gov/about/divisions/water-resources/edmr/npdes-electronic-reporting or contact Vanessa Manuel at 919-807-6392 or via email at Vanessa.Manuelncdenr.gov, Sincerely, Jeffrey ©. Pau.pa-vt forS. Jay Zimmerman, P.G. Cc: NPDES File Central Files PAT MCCRORY Governor DONALD R. VAN DER VAART Water Resources ENVIRONMENTAL QUALITY April 12, 2016 CERTIFIED MAIL7013 2630 0001 8998 4407 RETURN RECEIPT REQUESTED Mr. John Cranfill, Sr. Chief Engineer MAC D1086-300 Wells Fargo, N.A. — Wells Fargo Tryon Street GWR 550 South Tyron Street, 30' Floor Charlotte, NC 28202 Subject: NOTICE OF DEFICIENCY (NOD-2016-LR-0003) Late Discharge Monitoring Reports (DMRs) for Januar), 2016 Wells Fargo, N.A. — Wells Fargo Tryon Street GWR NPDES Permit NC0088226 Mecklenburg County Dear Mr. Cranfill: Secretory S. JAY ZIMMERMAN' RECEIVE:Mc D YA.146tnAN' L IL IL WORMS MOORESVILLE SI L OFFCE This is to inform you that the Division of Water Resources received the monitoring report for January 2016 late on March 29, 2016. This is in violation of Part II, 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 reporting 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. Additionally, this letter provides notice that this office will recommend the assessment of civil penalties if future reports are not received within the required time frame duringthe next twelve (12) reporting months. The Division must take these steps because timely submittal of discharge monitoring reports is essential to the efficient operation of our water quality programs. We appreciate your assistance in this matter. If you have any questions about this letter or discharge monitoring reports, please contact me at 919-807-6307 or via e-mail at derek.denardncdenrgov. S. Jay Zimmerman, Direc Division of Water Resources 4LCompliance & Expedited Permitting Unit NPDES Files NC0088226 Central Files Brian Olin, ECS CAROLINAS, LLP, 1812 Center Park Drive, Suite D, Charlotte, NC 28217 State of North Carolina Environmental Quality I Water Resources 1617 Mail service Center Raleigh, North Carolina 27699-1617 919 807 6300 Water Resources ENVIRf3NMEN Y.AL iXUALITY March 30, 2016 Mr: John Cranfill, Chief Engineer Childress Klein 550 South Tryon Street, Suite 180 Charlotte, NC 28208 Se.=i tarry S, JAY ZIMMERMAN Dircoor Subject: Compliance Evaluation Inspection Wells Fargo / Duke Energy Center Ground water remediation NPDES Permit No. NC0088226 Mecklenburg County Dear Mr. Cranfill: Enclosed is a copy of the Compliance Evaluation Inspection for the inspection conducted at the subject facility on March 21, 2016 by Ori Tuvia and Ed Watson. Your cooperation during the site visit was much appreciated. Please advise the staff involved with this NPDES Permit by forwarding a copy of the enclosed report. After further review of the Transit Time Flow Meter — Onicon F-3500, it was confirmed that the flow meter does need to be calibrated annually. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Ori Tuvia at (704) 235-2190, or at ori.tuvia@ncdenr.gov. 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., Sulte 301 Mooresville, NC 28115 Phone: (704) 663.1899 \ Fax; (704) 663-6040 \ Customer Service: 1-877-623-6748 EPA United States Environmental Protection Agency Washington, D.C. 20480 Water Compliance Inspection Report Section A: National Data SystemC (Le., PCS) Form Approved. OMB No, 2040-0057 Approval expires 8-31-98 Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 I] 2 1 NC0088226 111 12 1 16/03/21 117 18 LI 19 20L 211111111111111111111j1111111111111111111111p6 Inspection Work Days Facility Self -Monitoring Evaluation Rating 81 QA Reserved--- 67 Ito 1 70 14 .1 71 1N 1 72 1N1 731 1 174 75 j 1 1 1 1 1 1 180 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Duke Energy Center dewatering system 550 S Tryon St Charlotte NC 28202 Name(s) of Onsite Representative(s)Mtles(s)/Phone and Fax Number(s) 1/1 David Everett Valentine//704-634-9238 / David Everett Valentine/ORC/704-634-9235/ John Cranfill/f704-330-2545 / Name, Address of Responsible OfficiaVTitle/Phone and Fax Number Rhonda F Ballard,550 S Tryon St 30th Floor Charlotte NC 28202//704-374-4761/ • Perrnit Ill Self -Monitoring Program III Laboratory Entry Time/Date 01:45PM 16/03/21 Exit Time/Date 03:00PM 16/03/21 Other Facility Data Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) 111 Flow Measurement II Sludge Handling Disposal Operations & Maintenanca Facility Site Review Permit Effective Date 15/09/01 Permit Expiration Date 20/06/30 Records/Reports Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Edward Watson Ori A Tuvia Signature of Management, A Reviewer MRO GW/// MRO VVQ11704-663-1699/ Agency/Office/Phone and Fax Numbers Andrew Pitner 0 GW//704-663-1699 Ext210 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Date 3/3C) /16 Date Page# NPDES NC0086226 12 yr/mo/day 16/03/21 Inspection Type I17 18 LJ (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Notes by Ed Watson: A review was conducted of the permitted groundwater remediation and dewatering system present at this facility. The is a complex system set into two parts. The first system treats the water collected from the dewatering sump. Afterwards the treated water is discharged into an onsite storm drain that eventually empties into Irwin Creek, a Subbasin of the Catawba River Basin. We requested a copy of the manifest to be submitted for the spent Zeolite so we are track cradle to grave of the Zeolite material, The second system recaptures water form the dewatered treatment and is run through a second air stripper and reverse osmosis system and then to a bacterial treatment area before being uses as cooling water for the HVAC system. Page# 2 permit:woo08u22o Inspection Date: nmuxzoa owner 'Facility: Doke Energy Center umwamnng system Inspection Type: Compliance Evaluation Permit (If the present permit expires in 6 months or less). Has the permittee submitted a new |athe facility medescribed inthe permit? #Are there any special conditions for the permit? Is access to the plant site restricted $uthe general public? |othe inspector granted access hoall areas for inspection? Yes No NA NE Comment: The current permit became effective on 9/1/2015.and expires on@302020,The Permit authorizes the discharge of surplus treated groundwater, Record Keepinq Are records kept and maintained aarequired by the permit? |oall required information readily available, complete and current? Are all records maintained for 3years (|ab. reD.required 5yearo)? Are analytical results consistent with data reported onDIVIRo? |othe che/n*f-custodycomplete? Dates, times and location ufsampling Name ofindividual performing the sampling Results ofanalysis and calibration Dates ofanalysis Name oYperson performing analyses TrenopomadCOCo Are DMRacomplete: duthey include all permit parameters? Has the facility submitted its annual compliance report hnusers and OVVQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator oneach shift? iothe ORCvisitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? |othe backup operator certified atone grade less orgreater than the facility classification? |oacopy ofthe current NPDESpermit available onsite? Facility has copy ufprevious year's Annual Report nnfile for review? Comment: OMRo.COC.ORClogs and calibration logs were reviewed for the period of December 2O13through June 2015. Review nfDecember 2013DYNRrevealed the <]RC visitation was inconsistent with ORC logs and sampling time, Calibration logs must indicate the time as well amthe date the meter was calibrated. Permit: NC0088226 Owner - Facility: Duke Energy Center dewatering system Inspection Date: 03/21/2016 Inspection Type: Compliance Evaluation Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(exciuding field parameters) performed by a certified lab? # Is the facility using a contract lab? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1,0 degrees? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ▪ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ 11 ❑ Comment: The permittee contracts with Pace Analytical Services, Inc. to perform all chemical analyses (NC Laboratory Certification # 12) and ETS, Inc. to perform Chronic Toxicity testing specified in the permit. Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter'? Yes No NA NE • ❑ ❑ ❑ ❑ II ❑ ❑ 11 ❑ ❑ ❑ ▪ ❑ ❑ ❑ Comment: F-3500 Electromagnetic Flow meter was less than two years old have not been calibrated. The need for calibration was discussed and calibration has been scheduled. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: Grab sampling method is required by the permit. Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: Effluent discharge into a storm drain. Yes No NA NE ❑ ❑ � ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ MI ▪ ❑ ❑ ❑ 11 ❑ ❑ ❑ Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ 11 ❑ Page# 4 Permit: NC0088226 Owner - Facility: Duke Energy Center dewatering system Inspection Date: 03/21/2016 Inspection Type: Compliance Evaluation Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Yes No NA NE II El © © • El Comment: The system treats water collected from a dewatering sump. Treated water is discharged into an onsite storm drain that eventually empties into Irwin Creek. Page# .NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Governor Donald van der Vaart Secretary 8/13/2015 Mr. Ron Roach, Sr. Chief Engineer Wells Fargo N.A. - Wells Fargo Tyron Street GWR 550 South Tyron Street Charlotte, NC 28202 Subject: Dear Mr, Roach. Notice of Violation — Monitoring Violation Tracking Number NOV-2015-MV-0099 Wells Fargo Tryon Street GWR NPDES Permit NC0088226 Mecklenburg County A review of the May 2015 self -monitoring report for the subject facility revealed monitoring violation(s) of the following parameter(s) at Outfall 001: Date 1 Parameter 5/31/2015 1 PH Reported Value None Monitoring Requirement Monitor and report monthly Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Resources may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. If you have questions concerning this matter, please do not hesitate to contact Ori Tuvia or me at (704) 663-1699. Michael L. Parker, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDENR cc: Wastewater Branch Central Files (MSC 1617-basement) Mooresville Regional Office Location: 610 East Center Ave„ Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Internet http:Itportal,ncdenr,org/web/wg An Equal Opportunity l Affirmative Action Employer — 30% RKycled/10% Post Consumer paper DEC: 18. 2015 2:18PM ECS C ARLOTTE NO, 087 Water Pollution Control System Operator Designation Form WPCSOCC Ci-c)/Lco-,L, NCAC LA 8C .0201 Permittee Owner/Officer Name; ) 4 6 ( F-44,45,;, Mailing Addre,ss: City: Facility Name: Faciiit Biological WWTP Physical/Chemical Collection System Zip: Date: 5-tfr rt Permit #: SUBMIT A SEPARATE FORM FOR EACH TYPE SYSTEM! Operator in Responsible Charge (ORC) Print Full Name: Surface Irrigation Land Application certify that 1 agree to ray designation as the Operator in Responsible Charge Oar the facility noted. I understand and will abide by the rules and mettlatkuis pertaining to the responsibilities of the ORC as sct forth in ISA NCAC ORO .0204 and failing to do so can result in Disciplianry Actions. by the Water Pollution Control System Opernaars Certification Commission." Back -Up Operator in Responsibk Charge (BU ORC) Print Full Name: L Certificate Type Signature: "I certify that rules and regu Disciplinary A y designati utwg to Water .I01100.11.4MV.V.WOMWWW.A...41,41.A.AMAO Moil, fax or email the original to: Mail or fax a copy to the eppropelote Regional Office: • Phone #: (161 Doe: aS in Responsible Charge for the facility noied. fondetatand and will abide by the the rponibilitit.s ofthc DU ORC as set forth in ISA NCAC 011G .0205 and failing to 6040 Call nautt in Pollution Control System Operators ecrtiOcation Conunis&iort." WPCSOCC, 1618 Mail Service Center, Raleigh, NC 27699-1618 FAX: 919.7112726 Email: certadtreinatincdenr.cov Asheville 2090 US l-hvy 70 Swa.nnanoa 28773 Fax: 828.299.7043 Phone: /08.296.4500 Wmcilingtosl 943 vetshington So Mull 1,Vashinton 27$09 Fas: 2$1940,9215 Phone: 352.946.6401 Fayetteville 225 Green St Suite 714 Faraleville 28301-5043 Fax: 910A86-0707 Pbone: 910.433,3300 ‘Vilmingion /27 Cardinal Dr Wilmington 28405-2S45 FAS: 910350.2004 Phone: 010.796.7215 Mooresville 610 e Center Ave Suitt 301 Mooresville 28115 Fax: 704.663.6040 Phan= 704463.1699 Wins too-Sa leni 585 Waughtcom St Winston-Salem 27107 Fax: 334.771.4631 Phone: 336.7/14400 Raleigh 3800 Darren Dr Raleigh 27609 Fan 9 19.571,415 Fbone:910,791.4200 Revised 03-2044 NCDAM North Carolina Department of Environment and Natural Resources Pat McCrory Governor Mr. Ron Roach, Sr. Chief Engineer Wells Fargo, N.A. — Wells Fargo Tryon Street GWR 550 South Tyron Street Charlotte, NC 28202 Dear Mr. Roach: Donald R. van der Vaart Secretary June 3, 2015 Subject: Draft NPDES Permit NC0088226 Wells Fargo Tryon Street GWR 500 Block of South Tyron St, Charlotte 28202 Mecklenburg County In response to your request to renew the subject NPDES permit, the Division of Water Resources (DWR or the Division) hereby transmits this draft for your review and comment. Please review this document to assure your understanding of the permit limits and monitoring conditions, and to correct errors, if any. The Division understands that you have made no significant changes to your facility the last permit renewal. Therefore, we have made only minimal changes to your previous permit: • added updates to facility map, outfall locations and parameter codes • updated the limit for Naphthalene to 12 µg/L in accordance with water quality standards for freshwater • updated the limit for n-Butylbenzene to 550 ug/L in accordance with human health standards. Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates that these regulations will be adopted and is beginning implementation. The requirement to begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added to your NPDES permit. [See Special Condition A. (3.)] For information on eDMR, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://portal.ncdenr.org/web/wq/admin/bog/ipu/edmr. For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the following web site: :// 2. a. ov/co 'ance/proposed-npdes-electronic-reporting-rule. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Phone: 919-807-6300 \ Internet: vvvvw,ncwaterguality,org An E.qual Opportunity \ Affirmative Action Ernployer —Macte in part by recycled paper Permit NC0088226 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit hearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions described herein. Wells Fargo, N.A. is hereby authorized to: continue operating a 0.087 MGD groundwater remediecycle treatment facility with discharge of surplus treated groundwater wastewa © one (1) 2,500 gallon influent equaliza © influent transfer pump © one (1) 6 stage air stripper system © Intermediate transfer pump © one (1) zeolite media filter © antiscalant and other pretrea © one (1) ultra filtration system o first stage Reverse tnosis syst o one (1) 350 re 3 ��llection o one (1) 350 perm collectio o second stage t o second stage Restem o effltetae tau 0 located at the` County; and includ following components; 1ite backwash, Reverse Osmosis concentrate ash wastewater discharges to regional WWTP of South Tryon Street, Charlotte, NC in Mecklenburg 2. discharge from said treatment works via Outfall 001 at a location specified on the attached map, into an unnamed tributary to Little Sugar Creek [Stream Segment 11-1.37-8], currently a Class C waterbody within Subbasin 03-08-34 [HUC: 03050103] of the Catawba River Basin Page 2 of 6 Permit NC0088226 PART I A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge via Outfall 001. Such discharges shall be limited, monitored and reported i by the Permittee as specified below: ValftitittAnitr# Flow MGD Total Suspended Solids (TSS pt Benzene Toluene 3 ( Ethylbenzene Total Xylenes 3 Total Lead 3 (u.g/L) ,2 Dichloroethane Naphthalene n-Butylbenzene Methyl Tert-Butyl Ether (MTBE) 3 Chlorofor Tetrachloro Trichloroethert.,,, Total Zinc 3 (µ Total Copper 3 ( Chronic Toxicity 4 Footnotes: 1. No later than 270 days from hIjITfective date of this permit, the permittee shall begin submitting discharge monitoring reports electronically using the Division's eDMR application system [see A. (3.)] 2. All "Effluent" samples shall be collected after the point of convergence of all dewatering streams and prior to the point of connection with the storm sewer. 3. This sample to be collected concurrently with quarterly Chronic Toxicity. 4. Chronic Toxicity (Ceriodaphnia) limit at 90% with testing in March, June, September, and December [see A. (2)]. 44 1 50050 C0530 30.0 m 00400 > 6.0 and, 34030 34010 34371 4728 01051 7734.. 010 dard units Satilletlifilatthiefigt1/4,4,1ret vtiM1rwiimkkiw4,,,1401,4*%w Cte.1 • MAIMM,044.,k, ntinuous Recording Effluent 0 onth onthly onthly rab Effluent Grab Effluent rab Gra Grab uent Effluent Effluent nthly Grab Effluent Grab Effluent o Z-,45 Monthly Grab Effluent Monthly Grab Effluent onthly Grab Effluent nthly Grab Effluent Monthly Grab Effluent Quarterly Grab Effluent Quarterly Grab Effluent Quarterly Grab Effluent Conditions: There shall be no discharge of floating solids or visible foam in other than trace amounts. Discharge shall show no evidence as a source for oily film or sheen on the receiving stream. Page 3 of 6 Permit NC0088226 A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) [15A NCAC 02B .0500 et seq.] The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 90%. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. The tests will be performed during the months ofJanuary, April, July and October. These months signify the first month of each three-month toxicity testingquarter assigned to the facility. Effluent sampling for this testing must be obtained during representativ uent discharge and shall be performed at the NPDES permitted final effluent discharge below alt ent processes. If the test procedure performed as the first test of any sing permit limit, then multiple -concentration testing shall ttrmed a following months as described in "North Carolina Puascii Chronic Who Procedure" (Revised -December 2010) or subsequefl�ThIons. All toxicity testing results required as part of Monitoring Form (DMR-1) for the months, the pass/fail results and THP3B for the C the following address: Attention: Completed Aquatic Toxicity the end of the reporting criod for Test data shall be complete accui concentrate© onse data, an Total residual chlorine of the efflu disinfection of th.4'waste stream. Should there be no disc the permittee will complet",i facility name, permit number,11. Flow" in the comment area of t address cited above. this permit coMitin iwbich tests we, t— e. Additio IL er Sciei e filed s in a failure or ChV below the um, in each of the two uent Toxicity Test ',entered on th uent Discharge using the paran code TGP3B for R Form AT-3 (original) is to be sent to ater Resources c Toxicology Branch TN ater Sciences Section no later than 30 days after all sup p e 'cal/physical measurements and all laboratory supervisor and ORC or approved designate signature. e must be measured and reported if chlorine is employed for NW, the facility facility during a month in which toxicity monitoring is required, n located at the top of the aquatic toxicity (AT) test form indicating the `er, county, and the month/year of the report with the notation of "No . The report shall be submitted to the Water Sciences Section at the Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. Page 4 of 6 Permit NC0088226 NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONIT©RING REPORTS [G.S. 143-215.1(b)] Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a state does not establish a system to receive submittals, then permittees must submit DMRs electronically to the Environmental Protection (EPA). The Division anticipates that these regulations will be adopted and is beginning 1 ion in late 2013. g P g g im p � NOTE: This special condition supplements or supers t le follow ections within Part II of this permit (Standard Conditions for NPDES Permits) • Section B. (11.) Signatory Requirements • Section D. (2.) Reporting • Section. D. (6.) Records Reten • Section E. (5.) Monitoring Rep Reporting [Supersedes Section D. (2 Beginning no later th from the Ytty s pe t, the permittee shall begin reporting discharge oring electroni g R's Electronic Discharge Monitoring Report (e " ) int rn pplicatio Monito submi monit eDMR a (CROME electronically' signing, and sub following address: data and su ation is corn ermittees s) shall be summarized for each month and em allows permitted facilities to enter onica `ing the internet. Until such time that the state's s Cross -Media Electronic Reporting Regulation equi ry submit all discharge monitoring data to the state be rewired to complete the eDMR submission by printing, original and a copy of the computer printed eDMR to the NC DENR / DWR / Info ii Processing Unit ATTENTION: Central Files / eDMR. 1617 Mail Service Center Raleigh, North Carolina 27699-1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband. access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. Page 5 of 6 Permit NC0088226 Requests for temporary waivers from the NPDES electronic reporting requirements must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin using eDMR. Temporary waivers shall be valid for twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary waiver by the Division. Information on eDMR and application for a temporary waiver from the NPDES electronic reporting requirements is found on the following web page: http://portal.ncdenr.org/web/wq/adminibog/ipu/edmr Regardless of the submission method, the first DMR is d the issuance of the permit or in the case of a new faci • commencement of discharge. 2. Sienatory Requirements [Supplements Se All eDMRs submitted to the permit issuing autn Section B. (1 l.)(a) or by a duly authorized reprer' Section B. (11.)(b). A person, and n position, reporting purposes. For eDMR submissions, the person sigh account and login credeng*Jo access tht Carolina's eDMR sys 'ng for e the following web p http://portal.ncdenr.or Certifi the fo WIL • utp an et 2.22] 1�THER STATEMENTS OF CERTIFICATION e last day of the month following ast day of the month following the , . by son described in Part 11, a, (b) and edes Section B. (11.) (d)1 shall be signed ve ofthkperson as bed in Part II, ated signatory ority for eDMR uIRRmust obtain an eDMR user iWIinformation on North an user account, please visit R '4010V 4c,14, R using the state's eDMR system shall make "I cert , underpcnaltv o this document and all attachments were prepared under my direction or supeon in accordance with a system designed to assure that qualified personnel properly gather and uate Ihe intormalion submitted, Based on my inquiry of the person or persons who manage the s iem, tr those persons directly responsible for gathering the information, the information submittedsubtniited 15,v-k,10 ihe best of my knowledge and belief true, accurate, and complete. I AtA,' am aware that there are significant penalties for submitting false information, including the possibility offines and imprisonment for knowing violations." 3. Records Retention [Supplements Section D. (6.)1 The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR. 122.41]. Page 6 of 6 Wells Fargo, N. A. Tyron Street GWR 500 block of Tyron Street, Charlotte 28202 Receiving Stream: Stream Segment: Drainage Basin: Latitude: State Grid/USGS Quad: UT to Little Sugar Creek 11-137-8 Catawba 36' 1330" Gl5NE / Charlotte East, NC Stream Class: C Sub -Basin: 03-08-34 HUC: 030501030102 Longitude: 80° 50' 54" Facility Location Scale 124,000 NPDES Permit NC0088226 Mecklenburg County DENR / DWR / NPDES EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT NPDES Permit NC0088226 Derek Denard, Com•liance & Ex edited Permitting Unit / 919-807-6307 04Jun2015 Wells Fargo, N.A. — Wells Fargo Tryon Street GWR 550 South Tyron Street, Charlotte, NC 28202 500 Block of South Tyron. St, Charlotte 28202 0.087 MGD 100% Industrial. Groundwater Remediation Discharge PC-1. Renewal UT to Little Sugar Creek 0 4.1 19.1 Mecklenburg MRO Catawba 03-08-34 Impaired: Copper, Turbidity, Fish Community, Fish Tissue Hg, Benthos Poor Charlotte East, NC Facility Summary This facility is an industrial facility (flow <1 MGD) with groundwater remediation reclaim/recycle treatment facility with discharge of surplus treated groundwater wastewater. The design capacity of the treatment system is 0.087 MGD. No significant changes have been made to this facility since the last permit renewal. The facility consists of the following wastewater treatment units: © one (1) 2,500 gallon influent equalization tank © influent transfer pump O one (1) 6 stage air stripper system o Intermediate transfer pump O one (1) zeolite media filter © antiscalant and other pretreatment chemical systems © one (1) ultra filtration system © first stage Reverse Osmosis system O one (1) 350 reject water collection tank O one (1) 350 gallon permeate collection tank © second stage transfer pump © second stage Reverse Osmosis system o effluent/reuse pump © treated wastewater/reuse meter © support equipment for disposal of zeolite backwash, Reverse Osmosis concentrate wastewater, and Reverse Osmosis wash wastewater discharges to regional WWTP Monthly average FLOW (MGD) — Last 29 months Arp2012-Feb2015 that discharge occurred: [Ave 0.00549 MGD; Maximum, Monthly average flow = 0.07820 MGD; Minimum, Monthly average flow = 0.00004] Toxicity — This permit requires Whole Effluent Toxicity (WET) testing using Ceriodaphnia dubia to be performed as a 7-day pass/fail test at 90% effluent concentration, during January, April, July and October [TGP3131. Quarterly WET testing indicated a 100% passing rate for the past 12 tests (Sep2011- Dec2014). For Renewal — This permit reflects discharge at Outfall 001. • added Electronic Reporting - Discharge Monitoring Reports page Section A. (3.) • added updates to facility map, outfall locations and parameter codes • updated the limit for Naphthalene to 12 ug/L in accordance with water quality standards for freshwater • updated the limit for n-Butylbenzene to 550 ug/L in accordance with human health standards. Stream — Discharge from WWTP for Outfall 001 is into an unnamed tributary to Irwin Creek [Stream Segment 11-37-8]. The segment is listed as "impaired" for Copper, Turbidity, Fish Community, Fish Tissue Hg, Benthos Poor in the 2014 North Carolina Integrated report and 303(d) list. RPA — A Reasonable Potential Analysis (RPA) was conducted on Copper, Lead, Zinc, MTBE, Toluene, Benzene, Ethylbenzene, 1,2-dichloroethane, Naphthalene, n-Butylbenzene, Tetrachloroethene, Trichloroethene and Xylene (mixture) because Discharge Monitoring Reports (DMRs) reported concentration above method -detection levels (MDLs) for the past four and a half (4 1/12) years (Sep2011- Feb2015) of data. Permit Limits were removed from the following parameters because Discharge Monitoring Reports (DMRs) reported concentration below method -detection levels (MDLs) and/or there was no reasonable potential to exceed water quality stands for fresh water (FW) or human health standards (HH): Lead, Toluene, Benzene, Ethylbenzene, 1,2-dichloroethane, Naphthalene, n-Butylbenzene and Xylene. Facet Renewal 2013' NPORS NC00882.26 Pago FEB I a. Z015 MENR North Carolina Department of Environment and Natural Resources711:,, Pat McCrory Governor Ron Roach, Sr. Chief Engineer Well Fargo, N. A. 550 South Tryon Street Charlotte, NC 28202 Dear Mr. Roach: Donald R. van der Vaart Secretary February 09, 2015 Subject: Acknowledgement of Permit Renewal Permit NC0088226 Mecklenburg County The NPDES Unit received your permit renewal application on February 09, 2015. A member of the NPDES Unit will review your application. They will contact you if additional information is required to complete your permit renewal. You should expect to receive a draft permit approximately 30-45 days before your existing permit expires. If you have any additional questions concerning renewal of the subject permit, please contact Derek Denard (919) 807-6307. Sincerely, Wren Thedford Wastewater Branch cc: Central Files NPDES Unit 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-6300‘ Fax: 919-607-6492/Customer Service: 1-877-623-6748 Internet:: wvvw.ncwater:orn An Equal OpportunitylAffirmatlye Acton Employer NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, III Governor Secretary May 27, 2014 CERTIFIED MAIT, 7013-2630-0001-8998-0720 RETURN RECEIPT REQUESTED Attention: Ron Roach Wells Fargo Bank, NA 301 S. College St., Ste 2800 Charlotte, North Carolina 28208 Subject: NOTICE OF DEFICIENCY Wells Fargo — Duke Energy Center Dewatering System NPDES Permit NC0088226 Mecklenburg County NOD-2014-LR-004 Dear Mr. Roach : This is to inform you that the Division of Water Resources did not receive your monthly monitoring report for January 2014 and March 2014. This is in violation of Part II, 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 reporting 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. In addition, our records indicate that receipt of DMRs have been chronically late over the past 15 months (see below). onrtoring Report Date Due Date Received 02-2013 03/1/1.3 05/17/13 04-2013 05/31/13 07/02/13 05-2013 07/01/13 07/30/13 08-2013 0/01/13 10/22/13 09-2013 10/31/13 01/02/14 10-2013 12/01/13 02/14/14 11-201.3 12/31/13 03/13/14 2-2013 01/31/14 03/13/14 02-2014 03/31/14 05/13/14 To prevent further actio notice. please submit the misrng reports within fifteen (15) days of receipt of this 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Phone: 919-807-63001 Internet: http://www.ncwaterquality.org/ An Equal Opportunity t Affirmative Action Employer — Made in part by recycled paper Mr. Roach May 27, 2014 Page 2 of 2 Additionally, this letter provides notice that this office will recommend the assessment of civil penalties if future reports are not received within the required time frame durin the next twelve 12 re ortin months. The Division must take these steps because timely submittal of discharge monitoring reports is essential to the efficient operation of our water quality programs. We appreciate your assistance in this matter. If you have any questions about this letter or discharge monitoring reports, please contact me at 919-807-6307 or via e-mail at derek.denard@ncdenr.gov. Sincerely, Derek Denard Division of Water Resources, NCDENR cc: Derek Denard, Compliance & Expedited Permitting Unit Brian T. C?„� * GECS Carolinas, LLP [1812 Center Park Dr. Suite D, Charolette, NC 28217] Central Files ECS CARO INAS ,.d Geotechnical • Construction Mate Complex Permitting Unit NCDENR/DWR/Water Permitting Section Attn: Ron Berry, PE Archdale Building, NCDENR/DWR 1617 Mail Service Center Raleigh, NC 27669-1617 '.`Setting the Standard d Service Environmental Facilities Ong October 28, 2013 FECL;VFD DIVISEON 'Ar, T R QUALM, CCT 0 ?O'3 t1lOORESVILLE t"t 6.JN,SE OFF Reference, Request for Minor Industrial Permit Application Modification Wells Fargo Tryon Street GWR - NPDES Permit NC0088226 500 Block of South Tryon Street Charlotte, Mecklenburg County, North Carolina ECS Project 08-7008D Dear Mr, Berry: ECS Carolinas, LLP (ECS), on behalf of Childress Klein Properties and Wells Fargo, N.A., is requesting approval for modification to the existing system that is currently operating and has National Pollutant Discharge Effluent System (NPDES) permit NC0088226. These modifications are based on discussions with Mecklenburg County and the North Carolina Department of Environment and Natural Resources (NCDENR). The modifications are designed to address additional treatment of water prior to bypassing treatment when parts of the system must be bypassed due to system maintenance, as prolonged storage in the on -site mixing tanks would results in flooding of the subgrade basement if discharge does not occur. The permit includes the capture of site rain water and de -watering groundwater from the site subgrade parking garage but also de -watering groundwater from the adjacent subgrade parking garage at "The Green at Wachovia". Additionally, the captured water is routed through an on - site water treatment system designed by Aquapura, Inc. that utilizes the water for on -site needs such as in cooling towers thereby lowering the amount of municipal water required. BACKGROUND INFORMATION The subject site is the Wells Fargo Tryon Street GWR (WFTS-GWR) which includes the tower and subgrade parking deck at 550 South Tryon Street, located at the 500 block of South Tryon Street in Charlotte, Mecklenburg County, North Carolina. The WFTS-GWR site is bound by Church Street to the northwest, 1st Street to the northeast, Stonewall Street to the southwest and South Tyron Street. Currently, the site is operating NPDES permit No. NC0088226 and discharging groundwater to a storm sewer located in South Tryon Street. The storm sewer ultimately discharges to Little Sugar Creek, a Class C surface water in the Catawba River Basin. Figures 1 and 2 indicate the location of this site and outfall location. Permit Modification The system incorporates the water previously being discharged from two systems, the WFTS- GWR and The Green at Wachovia systems in order to supply the non -potable water demand for the site building. However, there may be times when there will be more water generated than Drive, Suite 0, Charlotte, NC 232 7 T. 704w525 5'I52 • : 704-357-0023 www,ecslimited.corrr ECS C r i k3.s,t, ° . .i (lantia , ;..1..0 • I_t_'S, NFkiwest, lt.<'a FiCS Sayatheast, i.Ll Request for Minor industrial Permit Application Modification Wells Fargo Tryon Street GWR Charlotte, North Carolina ECS Project 08-7008© October 28, 2013 will be required for use by the building. Therefore, the intermittent discharge of the excess water from the system may occur. The system consists of three collection sumps located below the bottom level of the WFTS- GWR subgrade parking deck where the groundwater at the WFTS-GWS and The Green at Wachovia will collect. Water within the sumps is then routed to a 2,500 gallon mixing tank of the Aquapura system, which begins the water treatment. Treated water is pumped into one of several subgrade holding tanks, the treated water remains stored until needed as part of the non -potable use of the building. The non -potable water use consists of makeup water for the cooling towers located on the top of the WFTS-GWR building. Plans showing the generalized existing and modified system, including location of the additional flow meters is attached. System Modifications In order to not result in untreated water being discharge to the storm sewer during bypass as was previously the case; a second air sparge has been installed. The new bypass is planned to be to the storm sewer system after treatment by the air stripper. The second air stripper will ensure treatment if one of the air strippers is down. Figures showing the existing system are included as Figure 3. Figures showing the proposed modifications are included as Figures 4 and 5. Additional Sampling In accordance with the existing NPDES permit, the system includes treatment of the water prior to discharge, via the Aquapura system. The permit also requires that the discharge be monitored, sampled, and reported. Additionally, a monthly DMR is required to be submitted to the NCDENR, DWQ. The DMR requires the monthly monitoring, including the collection of grab effluent samples for laboratory analysis, and reporting. Once per quarter, additional grab samples of the effluent are required to be collected and submitted for laboratory analysis for chronic toxicity with results submitted to the NCDENR. ECS does not recommend changes to the scheduled sampling. Additional sampling has been conducted after the air sparge system prior to treatment of the rest of the system and shown that levels of the treated water after the air sparge are below the current permit limits. Three rounds of laboratory analytical data after the air sparge treatment but before additional treatment are available and are included as Attachment I. A copy of the most recent post treatment data (from September 2013) collected prior to discharge in accordance with the current permit and reporting is included as Appendix II, 2 Request for Minor Industrial Permit Application Modification Wells Fargo Tryon Street GWR Charlotte, North Carolina ECS Project 08-7008© October 28. 2013 SUMMARY AND CLOSING Wells Fargo, N.A. is requesting a modification to the system that has been operating under permit number NC0088226. Should more detailed figures and information be required, they can be provided to the NCDENR, upon request. Additionally, the various representatives of Wells Fargo, N.A., Childress Klein and ECS are available to meet with NCDENR personnel to expedite the permit approval process. If there are questions regarding this submittal, or a need for further information, please contact us at (704) 525-5152. Respectfully submitted, ECS CAROLINAS, LLP Brian T. Olin, P.G. Environmental Geologist cc: Ron Roach, Childress Klein Attachments: h S. Lair, P.G. Cht Geologist Minor Industrial Permit Application Form Figures Appendix I — Post Air Sparge Laboratory Data Appendix II — September 2013 DMR Monitoring Laboratory Data NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. Mail the complete application to: N. C. Department of Environment and Natural Resources Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 NPDES Permit Number 1. Contact Information: Owner Name Facility Name Mailing Address City State / Zip Code Telephone Number Fax Number e-mail Address NCO() 88226 Please print or type. Wells Fargo, N.A. - Wells Fargo Tryon Street GWR Wells Fargo Tryon Street GWR 550 South Tryon Street Charlotte North Carolina 28202 704-944-1620 704-342-9039 RonRoachchildressklein om 2. Location of facility producing discharge: Check here if same as above ZI Street Address or State Road City State / Zip Code County 500 Block of South Tryon Street Charlotte North Carolina 28202 Mecklenburg 3. Operator Information: Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the Operator in Responsible Charge or ORC) Name Mailing Address City State / Zip Code Telephone Number Fax Number 4. Ownership Status: Childress Klein Properties 550 South Tryon Street Charlotte North Carolina 28202 704-944-1620 704-342-9039 Pagel of 5 C-MI 10/08 NPDES PERMIT APPLICATION — SHORT FORM C—Minor Industrial Minor industrial, manufacturing and commercial facilities. State E Private 0 Public R 5. Standard Industrial Classification (SIC)cmde(m): 7389 @. Number of employees: 2,500+/' 7, Describe the treatment system List all instoDedwaste treutre:n1components with oupucitien describe the processes that generate wastewaters, /fthe space pnnnkdedisnot ou/ attach o separate sheet ofpaper with. the systern description. The permit includes the capture of site rain water and de -watering groundwater from the site yubgrode parking garage but also de -watering groundwater from the adjacent oubgradn parking garage at "The Green at VVachovia^ AddihonaUy, the captured water is routed through an on -site water treatment system designed by Aquepuna. Inc, that utilizes the water for on -site needs such as in cooling towers thereby lowering the amount of municipal water required, When the site building is fully occupied and operational, the system iodesigned tuuse uptoS5%of the treated groundwater captured from both sites and little to no discharge to the outfaU in expected, The system incorporates the water previously being discharged from two systems, the VVFTS-GVVR and The Green atVVmchovia systems in order to supply the non -potable water demand for the site building. However. there will be times when there may be more water generated than will be required for use by the building. Therefore, the intermittent discharge ofthe excess water from the system may occur. The system nona$o of three collection sumps located below the bottom level of the VVFTS'GVVR mubgnuda parking deck where the groundwater at the VVFTS-GVVS and The Green at VVmchuvim will collect ina4.00Ugallon tank. Water within the sumps iothen routed ton2.5DOgallon mixing tank ofthe Aquapuns myotem, which begins the water treatment via two pumps capable of up to 96 gallons per minute (Qpm), Treated water is pumped into one of several oubgrade holding tonks, the treated water remains mXonad until needed as port of the non -potable use of the building. The non -potable water use consists of makeup water for the cooling towers located on the top of the VVFTS-GVVR building, The system includes four pumps as shown on Figure and the as -built drawing, The pumps range from 1 to 7,5 hp in capacity, Plans showing the generalized modified syntem, including the current and potential future location of the flow mater, and the effluent sampling |ooadon, system components and npenificadVna, including all pumps were included with the Request for Authorization to Construct Permit dated May 18.2O11. , T'he major components of the system generally consist of the following: � Air stripper (to remove volatile organics; � Zaohemedia filter: � Anti -scaling dosing system; + U|tna'fi|tradonaystam: � Reverse osmosis (RO)systems; � Pumps; and � Permeate storage tanks, The Aquopuno system in designed to handle 87.840 gallons per day (Jpd) of groundwater, but it is estimated to collect and treat approximately 40.000 gpd, Of this treated amount, 87% (approximately 34.80Ogpd)will be used in the cooling towers, with the remaining 1396 (5.200gpd) potentially being discharged tothe sewer via the NPOEGpermit, An additional air stripper is proposed to be installed as a back-up. The bypass in the event of system failure will bemoved toafter the air-othpper This design will allow for treatment ofthe groundwater prior to discharge in the event ofa system failure. Sampling has shown contaminants are not present in the treated water after the air stripper (See Attachment 1), The additional treatment after the air stripper in designed as o redundancy and to allow for re -use of the water in the cooling system and building operation. A plan showing the existing system is attached along with a plan showing the proposed NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. additional air stripper. 8. Is facility covered under federal effluent limitation guidelines? No Yes El If yes, specify the category? 9. Principal product(s) produced: N/A Principal raw material(s) consumed: Briefly describe the manufacturing process(es): None. It is a mufti -tenant general office building. A groundwater treatment system is in operation associated with dewatering the sub -grade parking garage. Page 3 of 5 C-MI 10/08 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. 10. Amount of principal product produced or raw material consumed (List specific amounts consumed and/ or unit per Day per Year Product Produced o Consumed (AVERAGE) N A 11. Frequency of discharge: If intermittent: Days per week discharge occurs: Varies (batch discharge) Duration: Varies (batch discharge threeea Produced or Raw 1V Consumed PEAK) a erial Continuous Ei Intermittent 12. Types of wastewater discharged to surface waters only Discharge ‘anitary - monthlyaverage tility water, etc. - m.onthly average 7,070 GPD N/A Flow (GALLONS PER DMA Process water - monthly average N/A or t monthly average Other — monthly average Explain: 4,690 GPD N/A Monthly Average total discharge (all types) ,760 GPD 13. Number of separate discharge points: 1 Outfall Identification number(s) 14. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including latitude and longitude): unknown tributary to Little Sugar Creek in Catawba River Basin: Lat 35°1225,5" N, Lon 80'5052„8" A map is attached. Page 4 of 5 C-MI 10/08 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. 15. Effluent Data [for new or proposed discharges] Provide data forthe parameters listed, Temperature and pH shall he grab samples., composite sampling shill be used. If more than one analysis is reported, report dai4, If only one analysis is reported, report as daily maximum, NOTE: Permittees requesting renewal should complete the table ONLYfor the parameters currently monitored. Summarize theast3rs of effluent data. Parameter Daily Maximum Biochemical Oxygen Demand (BOD5 Monthly Average other paratneters 24-hour UM and monthly average. Units of Measurement hemical Oxygen Demand (COD) Total Organic Carbon Total Suspended Solids <2 mg/L Ammonia as N Temperature (Summer) Temperature (Winter) pH 7.04 Standard Units Fecal Calif (If sanitary waste is present) Total Residual Chlorine (if chlorine is used) Note: See Attachment ost Recent Effluent Da a 16 List all permits, construction approvals and/or applications (check all that apply and provide permit numbers or check none if not applicahlef Permit Type Permit Number Type Number Hazardous Waste (RCRA) NESHAPS (CAA) UIC (SDWA) Ocean Dumping (MPRSA) NPDES NC008826 Dredge or fill (Section 404 or PSD (CAA) Other Non -attainment program 17. List any chemicals that may be discharged (Please list and explain source and .potential amounts) Benzene, toluene, ethylbenzene, xylene, naphthalene, lead, copper, TCE, PCE, 1,2-dichloroethane, n-butylbenzene, chloroform, oil & grease, The source for these compounds is contamination in the groundwater beneath downtown Charlotte, Page 5 of 5 C-MI 10/08 NPDES PERMIT APPLICATION - SHORT FORM t Minor industrial, manufacturing and commerc 19. Is this facility located on Indian country? (check one) Yes © No 9. Applicant Certification dustrial I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete, and accurate. Ron Roach Printed name o Person Signing Title Signature of Applieat Date North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who J nowi sgly makes any false statement representation, or certification in any application, record, report, plan, or offer document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) Page 6 of 5 C-MI 10108 FIGURES USGS Quad: G15SE Charlotte East, NC Qutfall Facility Latitude: 35°12'25,5" N 35' 13'28.5" N Longitude: 80'50'518" W 80'50'55.3" W Stream Class: C Subbasin 03-08-34 HUC: 03050103 Receiving Stream UT to Little Sugar Creek Facility Location Wells Fargo Tryon Street GWR NC0088226 Mecklenburg County LEGEND • Dewatering System Location Dewatering Wells and Piping SOURCE: Mecklenburg County Property Ownership Land Records Information System (POLARIS) via Internet 2009 Aerial Photograph Permitted Dewatering System Sewer Outfall (001) CAIROLMAII FIGURE 2 De -Watering System and Discharge Location Plan Wells Fargo Tryon Street NPDES Permit NC0088226 Charlotte, North Carolina ECS PROJECT NO, 08-7008A SCALE: As Noted Permeate Suggested center Reject Water lines for lights Terminal \ Plea t.. t. TES i rsntrcal is the au:'e •s f c a ! suggested location — away from water saur es. PEST ENV RONMENTAL SYSTEMS 429 Meodover lit %Allege, Circle Tess (919) 'S,a —9q9? FO5G (919 5370056 600 gal reject water buffer tank — by other CrUAPURA 61 E P 9`5 Efficiency cal°o i=a. First : t. t(rlatt NC crar a pump.. 2500 Gal Tank 6"Air Fxhoust for Air Str°ia per 1,100 CFM FEED WATER SYSTEM Duke Energy Proposed Air Stripper By -Pass with Whole System zip, T,ne 42 with Aquaracd4 TO STORM! SEWER as requlrotl P O$1$ I/NMT statue Grunotos CRT5 16 (SS) HP) Storage tanks TO COOLING TOWERS Duke Energy Proposed Air Stripper By -Pass Detail I XI©N3ddb Pace Analytical Services, inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 June 20, 2013 Mr. Brian Olin ECS Charlotte 1812 Center Park Dry Suite D Charlotte, NC 28217 RE: Project: Wells Fargo-CMUD 08-7008C Pace Project No,: 92161946 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville. NC 28078 (7041875-9092 Dear Mr, Olin: Enclosed are the analytical results for sample(s) received by the laboratory on June 18, 2013. The results relate only to the samples included in this report. Results reported herein conform to the most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless otherwise noted in the body of the report. Analyses were performed at the Pace Analytical Services location indicated on the sample analyte page for analysis unless otherwise footnoted. If you have any questions concerning this report, please feel free to contact me. Sincerely, a ct,9, u Angela Baioni angela,baioni@pacelabs.com Project Manager Enclosures REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc. Page 1 of 25 Pace Analytical Services, inc. Pace Analytical Services, Inc. Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr. 9800 Kinsey Ave. Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 CERTIFICATIONS Project: Wells Fargo-CMUD 08-7008C Pace Project No,: 92161946 Charlotte Certification IDs 9800 Kincey Ave, Ste 100, Huntersville, NC 28078 North Carolina Drinking Water Certification #: 37706 North Carolina Field Services Certification #: 5342 North Carolina Wastewater Certification #: 12 South Carolina Certification #: 99006001 Asheville Certification I©s 2225 Riverside Dr., Asheville, NC 28804 Florida/NELAP Certification #: E87648 Massachusetts Certification #: M-NC030 North Carolina Drinking Water Certification #: 37712 Florida/NELAP Certification #: E87627 Kentucky UST Certification #: 84 West Virginia Certification #: 357 VirginiaNELAP Certification #: 460221 North Carolina Wastewater Certification #: 40 South Carolina Certification #: 99030001 West Virginia Certification #: 356 VirginiaNELAP Certification #: 460222 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 2 of 25 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc, 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 SAMPLE ANALYTE COUNT Project: Wells Fargo-CMUD 08-7008C Pace Project No, 92161946 Pace Analytical Services, 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 Lab ID Sample ID 92161946001 AS 92161946002 Zeotite 92161946003 GW3 92161946004 GW1/2 92161946005 Gmem Method Analytes Analysts Reported Laboratory EPA 1664E3 CLW 1 PASI-C EPA 200 7 JMW 3 PASI-A EPA 8260 MCK 64 PASI-C SM 2540D ANS 1 PASI-A EPA 16640 CLW 1 PASI-C EPA 200,7 JMW 3 PASI-A EPA 8260 MCK 64 PASI-C SM 25400 ANS 1 PASI-A EPA 16640 CLW 1 PASI-C EPA 200.7 JMW 3 PASI-A EPA 8260 MCK 64 PASI-C SM 2540D ANS 1 PASI-A EPA 16646 CLW 1 PASI-C EPA 200 7 JMW 3 PASI-A EPA 8260 MCK 64 PASI-C SM 2540D ANS 1 PASI-A EPA 1664B CLW 1 PASI-C EPA 200,7 JMW 3 PASI-A EPA 8260 MCK 64 PAS(-C SM 2540D ANS 1 PASI-A REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytic -al Services, Inc, Page 3 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (338)623-8921 Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 ANALYTICAL RESULTS Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 Sample: AS Parameters HEM, Oil and Grease Gil and Grease 200,7 MET ICP Copper Lead Zinc 8260 MSV Low Level Acetone Benzene Bromobenzene Bromochloromethane Bromodichloromethane Bromoform Bromomethane 2-Butanone (MEK) n-Butylbenzene Carbon tetrachloride Chlorobenzene Chloroethane Chloroform Chloromethane 2-Chlorotoluene 4-Chlorotoluene Dibromochloromethane 1,2-Dibromoethane (EDB) Dibromomethane 1„2-Dichlorobenzene 1,3-Dichlorobenzene 1,4-Dichlorobenzene Dichlorodifluoromethane 1,1-Dichloroethane 1,2-Dichloroethane 1,1-Dichloroethene cis-1,2-Dichloroethene trans-1,2-Dichloroethene 1,2-Dichloropropane 1,3-Dichloropropane 2,2-Dichloropropane 1,1-Dichloropropene cis-1,3-Dichloropropene trans-1,3-Dichloropropene Diisopropyl ether Ethylbenzene Hexachloro-1,3-butadiene 2-Hexanone Date: 06/20/2013 04:52 PM Lab ID: 92161946001 Collected: 06/17/13 11:00 Received: 06/18/13 15:35 Matrix: Water Results Units Analytical Method; EPA 1664B ND mg/L Analytical Method; EPA 200.7 18.3 ug/L ND ug/L ND ug/L Analytical Method: EPA 8260 ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L. ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L. ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L NO ug/L Report Limit DF Prepared Analyzed CAS No, Qual 5.0 1 Preparation Method; EPA 200.7 5.0 5.0 10.0 25.0 1 1.0 1 1.0 1 1.0 1 1_0 1 1.0 1 2.0 1 5.0 1 1.0 1 1.0 1 1.0 1 1,0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1,0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 5.0 1 06/19/13 12:15 06/19/13 12;15 06/19/13 12:15 REPORT OF LABORATORY ANALYSIS 06/19/13 12;20 06/20/13 00:26 7440-50-8 06/20/13 00:26 7439-92-1 06/20/13 00:26 7440-66-6 06/19/13 16;53 67-64-1 06/19/13 16:53 71-43-2 06/19/13 16:53 108-86-1 06/19/13 16:53 74-97-5 06/19/13 16;53 75-27-4 06/19/13 16:53 75-25-2. 06/19/13 16:53 74-83-9 06/19/13 16:53 78-93-3 06/19/13 16:53 104-51-8 06/19/13 16;53 56-23-5 06/19/13 16:53 108-90-7 06/19/13 16;53 75-00-3 06/19/13 16:53 67-66-3 06/19/13 16:53 74-87-3 06/19/13 16:53 95-49-8 06/19/13 16:53 106-43-4 06/19/13 16;53 124-48-1 06/19/13 16:53 106-93-4 06/19/13 16;53 74.95-3 06/19/13 16:53 95-50-1 06/19/13 16:53 541-73-1 06/19/13 16:53 106-46-7 06/19/13 16:53 75-71-8 06/19/13 16;53 75-34-3 06/19/13 16:53 107-06-2 06/19/13 16:53 75-35-4 06/19/13 16; 53 156-59-2 06/19/13 16:53 156-60-5 06/19/13 16:53 78-87-5 06/19/13 16:53 142-28-9 06/19/13 16:53 594-20-7 06/19/13 16:53 563-58-6 06/19/13 16;53 10061-01-5 06/19/13 16:53 10061 -02-6 06/19/13 16; 53 108-20-3 06/19/13 16:53 100-41-4 06/19/13 16:53 87-68-3 06/19/13 16:53 591-78-6 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 4 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. Pace Analytical Services, tac. 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 ANALYTICAL RESULTS Project: Wells Fargo-CMUD 08-7008C Pace Project No,: 92161946 Sample: AS Lab ID: 92161946001 Collected: 06/17/`13 11.00 Received: 06/18113 15:35 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual 6260 MSV Low Level Analytical Method: EPA 8260 p-lsopropyltoluene ND ug/L 1,0 1 Methylene Chloride ND ug/L 2.0 1 4-Methyl-2-pentanone (MIRK) ND ug/L 5.0 1 Methyl-tert-butyl ether ND ug/L 1,0 1 Naphthalene NO ug/L 1.0 1 Styrene ND ug/L 1.0 1 1,1,1,2-Tetrachloroethane ND ug/L 1.0 1 1,1,2,2-Tetrachloroethane ND ug/L 1.0 1 Tetrachloroethene ND ug/L 1.0 1 Toluene ND ug/L. 1.0 1 1,2,3-Trichlorobenzene ND ug/L 1.0 1 1,2,4-Trichlorobenzene ND ug/L 1.0 1 1,1,1-Trichloroethane ND ug/L 1.0 1 1,1,2- Trichloroethane ND ug/L 1.0 1 Trtchloroethene NO ug/L 1.0 1 Trichlorofluoromethane NO ug/l_ 1,0 1 1,2,3-Trichloropropane ND ug/L 1.0 1 Vinyl acetate ND ug/L 2,0 1 Vinyl chloride ND ug/L 1.0 1 Xylene (Total) ND ug/L 2.0 1 m&p-Xylene ND ug/L 2,0 1 o-Xylene ND ug/L 1,0 1 Surrogates 4-Qromofluorobenzene (S) 101 % 70-130 1 06/19/13 16:53 460-00-4 Dibromofluoromethane (S) 118 % 70-130 1 06/19/13 16:53 1868-53-7 1,2-Dichloroethane-d4 (S) 112 % 70-130 1 06/19/13 16:53 17060-07-0 Toluene-d8 (S) 101 % 70-130 1 06/19/13 16:53 2037-26-5 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids ND mg/L 5.2 1 06/19/13 11:17 Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS 06/19/13 16:53 99-87-6 06/19/13 16:53 75-09-2 06/19/13 16:53 108-10-1 06/19/13 16:53 1634-04-4 06/19/13 16:53 91-20-3 06/19/13 16:53 100-42-5 06/19/13 16:53 630-20-6 06/19/13 16:53 79-34-5 06/19/13 16:53 127-18-4 06/19/13 16:53 108-88-3 06/19/13 16:53 87-61-6 06/19/13 16:53 120-82-1 06/19/13 16:53 71-55-6 06/19/13 16:53 79-00-5 06/19/13 16:53 79-01-6 06/19/13 16:53 75-69-4 06/19/13 16:53 96-18-4 06/19/13 16:53 108-05-4 06/19/13 16:53 75-01-4 06/19/13 16:53 1330-20-7 06/19/13 16:53 179601-23-1 06/19/13 16:53 95-47-6 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 5 of 25 Pace Analytical Services, Inc. Pace Analytical Services, Inc. Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 ANALYTICAL RESULTS Project: Wells Fargo-CMUD 08-7008C Pace Project No,: 92161946 Sample: Zeotite Lab ID: 92161946002 Collected: 06/17/13 11:00 Received: 06/18/13 15:35 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual HEM, ©Hand Grease Oil and Grease 200.7 MET ICP Analytical Method: EPA 1664B ND mg/L 5.0 1 06/19/13 12,20 Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Copper 12.0 ug/L 5,0 1 06/19/13 12:15 06/20/13 00:35 7440-50-8 Lead ND ug/L 5.0 '1 06/19/13 12:15 06/20/13 00:35 7439-92-1 Zinc ND ug/L 10.0 1 06/19/13 12:15 06/20/13 00:35 7440-66-6 8260 MSV Low Level Analytical Method: EPA 8260 Acetone ND ug/L 25.0 1 06/19/13 17:09 67-64-1 Benzene ND ug/L 1.0 1 06/19/13 17:09 71-43-2 Bromobenzene ND ug/L 1.0 1 06/19/13 17:09 108-86-1 Bromochloromethane ND ug/L 1.0 1 06/19/13 17:09 74-97-5 Bromodichloromethane ND ug/L 1.0 1 06/19/13 17:09 75-27-4 Bromoform ND ug/L 1.0 1 06/19/13 17:09 75-25-2 Bromomethane ND ug/L 2.0 1 06/19/13 17:09 74-83-9 2-Butanone (MEK) ND ug/L 5.0 1 06/19/13 17:09 78-93-3 n-Butylbenzene ND ug/L 1.0 1 06/19/13 17:09 104-51-8 Carbon tetrachloride ND ug/L 1.0 1 06/19/13 17:09 56-23-5 Chlorobenzene ND ug/L 1.0 1 06/19/13 17:09 108-90-7 Chloroethane ND ug/L 1.0 1 06/19/13 17:09 75-00-3 Chloroform ND ug/L 1.0 1 06/19/13 17:09 67-66-3 Chloromethane ND ug/L 1.0 1 06/19/13 17:09 74-87-3 2-Chlorotoluene ND ug/L 1.0 1 06/19/13 17:09 95-49-8 4-Chlorotoluene ND ug/L 1,0 1 06/19/13 17:09 106-43-4 Dibromochloromethane ND ug/l_ 1.0 1 06/19/13 17:09 124-48-1 1,2-Dibromoethane (EDB) ND ug/L 1.0 1 06/19/13 17:09 106-93-4 Dibromomethane ND ug/L 1.0 1 06/19/13 17:09 74-95-3 1,2-Dichlorobenzene ND ug/L 1,0 1 06/19/13 17;09 95-50-1 1,3-Dichlorobenzene ND ug/L 1,0 1 06/19/13 17:09 541-73-1 1,4-Dichlorobenzene ND ug/L 1.0 1 06/19/13 17:09 106-46-7 Dichlorodifluoromethane ND ug/L 1.0 1 06/19/13 17:09 75-71-8 1,1-Dichloroethene ND ug/L 1.0 1 06/19/13 17:09 75-34-3 1,2-Dichloroethene ND ug/L 1,0 1 06/19/13 1'7:09 107-06-2 1,1-Dichloroethene ND ug/L 1.0 1 06/19/13 17:09 75-35-4 cis-1,2-Dichloroethene ND ug/I_ 1,0 1 06/19/13 17:09 156-59-2 trans-1,2-Dichloroethene ND ug/L 1.0 1 06/19/13 17:09 156-60-5 1,2-Dichloropropane ND ug/L 1.0 1 06/19/13 17:09 78-87-5 1,3-Dichloropropane ND ug/L 1.0 1 06/19/13 17:09 142-28-9 2,2-Dichloropropane ND ug/L 1,0 1 06/19/13 17;:09 594-20-7 1,1-Dichloropropene ND ug/L 1.0 1 06/19/13 17:09 563-58-6 cis-1,3-Dichloropropene ND ug/L 1.0 1 06/19/13 17:09 10061-01-5 trans-1,3-Dichloropropene ND ug/L 1.0 1 06/19/13 17:09 10061-02-6 Diisopropyl ether ND ug/L 1.0 1 06/19/13 17:09 108-20-3 Ethylbenzene ND ug/L 1.0 1 06/19/13 17:09 100-41-4 Hexachloro-1,3-butadiene ND ug/L 1.0 1 06/19/13 17:09 87-68-3 2-Hexanone' ND ug/L 5.0 1 06/19/13 17:09 591-78-6 Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 6 of 25 Pace Analytical Services, Inc* 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc, 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 ANALYTICAL RESULTS Project: Wells Fargo-CMUD 08-7008C Pace Project No: 92161946 Pace Analytical Services, Inc* 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 Sample: Zeotite Lab ID: 92161946002 Collected: 06/17/13 11:00 Received: 06/18/13 15:35 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No„ Qual 8260 MSV Low Level Analytical Method: EPA 8260 p-lsopropyltoluene ND ug/L 1,0 1 06/19/13 17:09 99-87-6 Methylene Chloride ND ug/L 2.0 1 06/19/13 17:09 75-09-2 4-Methyl-2-pentanone (MIBK) ND ug/L 5.0 1 06/19/13 17:09 108-10-1 Methyl-tert-butyl ether ND ug/L 1,0 1 06/19/13 17:09 1634-04-4 Naphthalene NO ug/L 1,0 1 06/19/13 17:09 91-20-3 Styrene ND ug/L 1.0 'I 06/19/13 17:09 100-42-5 1,1,1,2-Tetrachloroethane ND ug/L 1.0 1 06/19/13 17:09 630-20-6 1,1,2,2-Tetrachloroethane ND ug/L 1.0 1 06/19/13 17:09 79-34-5 Tetrachloroethene ND ug/L 1,0 1 06/19/13 17:09 127-18-4 Toluene ND ug/L 1.0 1 06/19/13 17:09 108-88-3 1,2:3-Trichlorobenzene ND ug/L 1.0 1 06/19/13 17:09 87-61-6 1,2,4-Trichlorobenzene ND ug/L 1.0 1 06/19/13 17:09 120-82-1 1,1,1-Trichloroethane ND ug/L 1,0 1 06/19/13 17:09 71-55-6 1,1,2-Trichloroethane ND ug/L 1.0 1 06/19/13 17:09 79-00-5 Trichloroethene ND ug/L 1.0 1 06/19/13 17:09 79-01-6 Trichlorofluoromethane ND ug/L 1.0 1 06/19/13 17:09 75-69-4 1,2,3-Trichloropropane ND ug/L 1,0 1 06/19/13 17:09 96-18-4 Vinyl acetate ND ug/L 2.0 1 06/19/13 17:09 108-05-4 Vinyl chloride ND ug/L 1.0 1 06/19/13 17:09 75-01-4 Xylene (Total) ND ugtL 2,0 1 06/19/13 17:09 1330-20-7 m&p-Xylene ND ug/L. 2.0 1 06/19/13 17:09 179601-23-1 o-Xylene ND ug/L 1.0 1 06/19/13 17:09 95-47-6 Surrogates 4-Bromofluorobenzene (S) 99 % 70-130 1 06/19/13 17:09 460-00-4 Dibromofluoromethane (S) 114 % 70-130 1 06/19/13 17:09 1868-53-7 1,2-Dichloroethane-d4 (S) 107 % 70-130 1 06/19/13 17:09 17060-07-0 Toluene-d8 (S) 100 % 70-130 1 06/19/13 17:09 2037-26-5 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids ND mg/L 2,9 1 06/19/13 11:18 Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc„ Page 7 of 25 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 Pace Analytical Services, Inc, 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 ANALYTICAL RESULTS Pace Analytical Services, Inc, 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 Sample: GW3 Lab ID: 92161946003 Collected: 06/17/13 11:15 Received: 06/18/13 15:35 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No, Qual HEM, Oil and Grease Analytical Method: EPA 1664B Oil and Grease ND mg/L 5.0 1 ' 06/19/13 12:22 200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200,7 Copper ND ug/L 5.0 1 06/19/13 12:15 06/20/13 00:38 7440-50-8 Lead ND ug/L 5.0 1 06/19/13 12:15 06/20/13 00:38 7439-92-1 Zinc ND ug/L 10.0 1 06/19/13 12:15 06/20/13 00:38 7440-66-6 8260 MSV Low Level Analytical Method: EPA 8260 Acetone ND ug/L 25.0 1 06/19/13 17:25 67-64-1 Benzene ND ug/L 1.0 1 06/19/13 17;25 71.-43-2 Bromobenzene ND ug/L 1.0 1 06/19/13 17:25 108-86-1 Bromochloromethane ND ug/t.„ 1.0 1 06/19/13 17:25 74-97-5 Bromodichloromethane ND ug/L 1.0 1 06/19/13 17:25 75-27-4 Bromofonh ND ug/L 1.0 1 06/19/13 17:25 75-25-2 Bromomethane ND ug/L 2,0 1 06/19/13 17:25 74-83-9 2-Butanone (MEK) ND ug/L 5.0 1 06/19/13 17:25 78-93-3 n-Butylbenzene ND ug/L 1.0 1 06/19/13 17:25 104-51-8 Carbon tetrachloride ND ug/L 1.0 1 06/19/13 17:25 56-23-5 Chlorobenzene ND ug/L 1,0 1 06/19/13 17:25 108-90-7 Chloroethane ND ug/L 1.0 1 06/19/13 17:25 75-00-3 Chloroform ND ug/L 1.0 1 06/19/13 17,25 67-66-3 Chloromethane ND ug(L 1,0 1 06/19/13 17:25 74-87-3 2-Chlorotoluene ND ug/L 1.0 1 06/19/13 17:25 95-49-8 4-Chlorotoluene ND ug/L 1.0 1 06/19/13 17:25 106-43-4 Dibromochloromethane ND ug/L 1.0 1 06/19/13 17:25 124-48-1 1,2-Dibromoethane (EDB) ND ug/L 1.0 1 06/19/13 17:25 106-93-4 Dibromomethane NO ug/L 1.0 1 06/19/13 17:25 74-95-3 1,2-Dichlorobenzene ND ug/L 1.0 1 06/19/13 17:25 95-50-1 1,3-Dichlorobenzene ND ug/L 1.0 1 06/19/13 17:25 541-73-1 1,4-Dichlorobenzene ND ug/L 1.0 1 06/19/13 17;25 106-46-7 Dichlorodifluoromethane ND ug/L 1.0 1 06/19/13 17:25 75-71-8 1,1-Dichloroethane ND ug/L 1.0 1 06/19/13 17:25 75-34-3 1,2-Dichloroethane NO ug/L 1,0 1 06/19/13 17:25 107-06-2 1,1-Dichloroethene ND ug/L 1.0 1 06/19/13 17:25 75-35-4 cis-1,2-Dichloroethene ND ug/L 1.0 1 06/19/13 17:25 156-59-2 trans-1,2-Dichloroethene NO ug/L 1.0 1 06/19/13 17;25 156-60-5 1,2-Dichloropropane ND ug/L 1.0 1 06/19/13 17:25 78-87-5 1,3-Dichloropropane ND ug/L 1.0 1 06/19/13 17:25 142-28-9 2,2-Dichloropropane ND ug/L 1.0 1 06/19/13 17:25 594-20-7 1,1-Dichloropropene ND ug/L 1.0 1 06/19/13 17:25 563-58-6 cis-1,3-Dichloropropene ND ug/L 1.0 1 06/19/13 17:25 10061-01-5 trans-1.3-Dichloropropene ND ug/L 1.0 1 06/19/13 17:25 10061-02-6 Diisopropyl ether ND ug/L 1.0 1 06/19/13 17:25 108-20-3 Ethylbenzene ND ug/L 1.0 1 06/19/13 17:25 100-41-4 Hexachloro-1,3-butadiene ND ug/L 1.0 1 06/19/13 17:25 87-68-3 2-Hexanone ND ug/L 5,0 1 06/19/13 17:25 591-78-6 Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 8 of 25 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7'176 (704)875-9092 ANALYTICAL RESULTS Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 Sample: GW3 Lab ID: 92161946003 Collected: 06/17/13 11:15 Received: 06/18/13 15:35 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No, Qua( 8260 MSV Low Level Analytical Method: EPA 8260 p-Isopropyltoluene Methylene Chloride 4-Methyl-2-pentanone (M(BK) Methyl-tert-butyl ether Naphthalene Styrene 1,1,1,2-Tetrachloroethane 1,1,2,2-Tetrachloroethane Tetrachloroethene Toluene 1,2,3-Trichlorobenzene 1,2,4-Trichlorobenzene 1,1,1-Trichloroethane 1,1,2-Trichloroethane Trichloroethene Trichlorofluoromethane 1,2,3-Trichloropropane Vinyl acetate Vinyl chloride Xylene (Tota() m&p-Xylene o-Xylene Surrogates 4-Bromofluorobenzene (S) Dibromofluoromethane (S) 1,2-Dichloroethane-d4 (S) Toluene-d8 (S) ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L NO ug/L ND ug/L 1.8 ug/L. ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L 1,0 1 2.0 1 5 0 1 1.0 1 1.0 1 1.0 1 1.0 1 1,0 1 1.0 1 1 0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1 0 1 2.0 1 1.0 1 2.0 1 2 0 1 1.0 1 70-130 1 70-130 1 70-130 1 70-130 1 06/19/13 17:25 99-87-6 06/19/13 17:25 75-09-2 06/19/13 17:25 108-10-1 06/19/13 17:25 1634-04-4 06/19/13 17:25 91-20-3 06/19/13 17:25 100-42-5 06/19/13 17:25 630-20-6 06/19/13 17:25 79-34-5 06/19/13 17:25 127-18-4 06/19/13 17:25 108-88-3 06/19/13 17:25 87-61-6 06/19/13 17:25 120-82-1 06/19/13 17:25 71-55-6 06/19/13 17:25 79-00-5 06/19/13 17:25 79-01-6 06/19/13 17:25 75-69-4 06/19/13 17:25 96-18-4 06/19/13 17:25 108-05-4 06/19/13 17:25 75-01-4 06/19/13 17:25 1330-20-7 06/19/13 17:25 179601-23-1 06/19/13 17:25 95-47-6 06/19/13 17:25 460-00-4 06/19/13 17:25 1868-53-7 06/19/13 17:25 17060-07-0 06/19/13 17:25 2037-26-5 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids ND mg/L 2,7 1 06/19/13 11:18 REPORT OF LABORATORY ANALYSIS Date: 06/20/2013 04:52 PM This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 9 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite.A Eden, NC 27288 (336)623-8921 Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Or. 9800 Kincey Ave. Suite 100 Asheville, NC 28504 Huntersville, NC 28078 (828)254-7176 (704)875-9092 ANALYTICAL RESULTS Sample: GW1/2 Lab ID: 92161946004 Collected: 06/17/13 11:30 Received: 06/18/13 15:35 Matrix: Water Parameters Results Units Report. Limit DF Prepared Analyzed CAS No. Qual HEM, Oil and Grease Oil and Grease 200.7 MET ICP Analytical Method: EPA 1664E ND mg/L 5.0 1 06/19/13 12:23 Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Copper ND ug/L 5.0 1 06/19/13 12:15 06/20/13 00:42 7440-50-8 Lead ND ug/L 5.0 1 06/19/13 12:15 06/20/13 00:42 7439-92-1 Zinc ND ug/L 10.0 1 06/19/13 12:15 06/20/13 00:42 7440-66-6 8260 MSV Low Level Analytical Method: EPA 8260 Acetone ND ug/L 25.0 1 06/19/13 17:40 67-64-1 Benzene ND ug/L 1.0 1 06/19/13 17:40 71-43-2 Bromobenzene ND ug/L 1.0 1 06/19/13 17:40 108-86-1 Bromochloromethane ND ug/L 1.0 1 06/19/13 17:40 74-97-5 Bromodichloromethane ND ug/L 1,0 1 06/19/13 17:40 75-27-4 Bromoform ND ug/L 1.0 1 06/19/13 17:40 75-25-2 Bromomethane ND ug/L 2.0 1 06/19/13 17:40 74-83-9 2-Butanone (MEK) ND ug/L 5.0 1 06/19/13 17:40 78-93-3 n-Butylbenzene ND ug/L 1.0 1 06/19/13 17:40 104-51-8 Carbon tetrachloride ND ug/L 1.0 1 06/19/13 17:40 56-23-5 Chlorobenzene ND ug/L 1.0 1 06/19/13 17:40 108-90-7 Chloroethane ND ug/L 1.0 1 06/19/13 17:40 75-00-3 Chloroform ND ug/L 1.0 1 06/19/13 17:40 67-66-3 Chloromethane ND ug/L 1.0 1 06/19/13 17:40 74-87-3 2-Chlorotoluene ND ug/L 1,0 1 06/19/13 17:40 95-49-8 4-Chlorotoluene ND ug/L 1.0 1 06/19/13 17:40 106-43-4 Dibromochloromethane ND ug/L 1.0 1 06/19/13 17:40 124-48-1 1,2-Dibromoethane (EDB) ND ug/L 1.0 1 06/19/13 17:40 106-93-4 Dibromomethane ND ug/L 1,0 1 06/19/13 17:40 74-95-3 1,2-Dichlorobenzene ND ug/L 1.0 1 06/19/13 17:40 95-50-1 1,3-Dichlorobenzene ND ug/L 1.0 '1 06/19/13 17:40 541-73-1 1,4-Dichlorobenzene ND ug/L 1.0 1 06/19/13 17:40 106-46-7 Dichlorodifluoromethane ND ug/L 1,0 1 06/19/13 17:40 75-71-8 1,1-Dichloroethane ND ug/L 1.0 1 06/19/13 17:40 75-34-3 1,2-Dichloroethene NO ug/L 1.0 1 06/19/13 17:40 107-06-2 1,1-Dichloroethene ND ug/L 1,0 1 06/19/13 17:40 75-35-4 cis-1,2-Dichloroethene ND ug/L 1.0 1 06/19/13 17:40 156-59-2 trans-1,2-Dichloroethene ND ug/L 1.0 1 06/19/13 17:40 156-60-5 1,2-Dichloropropene ND ug/L 1.0 1 06/19/13 17:40 78-87-5 1,3-Dichloropropene ND ug/L 1.0 1 06/19/13 17:40 142-28-9 2,2-Dichloropropane ND ug/L 1.0 1 06/19/13 17:40 594-20-7 1,1-Dichloropropene ND ug/L 1.0 1 06/19/13 17:40 563-58-6 cis-1,3-Dichloropropene ND ug/L 1.0 1 06/19/13 17:40 10061-01-5 trans-1,3-Dichloropropene ND ug/L 1.0 1 06/19/13 17:40 10061-02-6 Diisopropyl ether ND ug/L 1.0 1 06/19/13 17:40 108-20-3 Ethylbenzene ND ug/L 1.0 1 06/19/13 17:40 100-41-4 Hexachloro-1,3-butadiene ND ug/L 1.0 1 06/19/13 17:40 87-68-3 2-Hexanone ND ug/L 5,0 1 06/19/13 17:40 591-78-6 Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc., Page 10 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc, Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 - (704)875-9092 ANALYTICAL RESULTS Project: Wells Fargo-CMUD 08-7008C Pace Project No,: 92161946 Sample: GW112 Lab ID: 92161946004 Collected: 06/17/13 11:30 Received: 06/18/13 15:35 ix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual 8260 MSV Low Level Analytical Method: EPA 8260 p-Isopropyltoluene ND ug/L 1.0 1 Methylene Chloride ND ug/L 2,0 1 4-Methyl-2-pentanone (MIBK) ND ug/L 5.0 1 Methyl-tert-butyl ether ND ug/L 1,0 1 Naphthalene ND ug/L 1.0 1 Styrene ND ug/L 1,0 1 1,1,1,2-Tetrachloroethane ND ug/L 1.0 1 1.1,2,2-Tetrachloroethane ND ug/L 1.0 1 Tetrachloroethene tO ug/L 1,0 1 Toluene ND ug/L, 1.0 1 1,2,3-Trichlorobenzene ND ug/L 1.0 1 1,2,4-Trichlorobenzene ND ug/L 1.0 1 1,1,1-Trichloroethane ND ug/L 1,0 1 1,1,2-Trichloroethane ND ug/L 1,0 1 Trichioroethene ND ug/L 1:0 1 Trichlorofluoromethane 3.9 ug/L 1.0 1 1,2,3-Trichloropropane ND ug/L 1,0 1 Vinyl acetate ND ug/L 2,0 1 Vinyl chloride ND ug/L 1,0 1 Xylene (Total) ND ug/L 2.0 1 m&p-Xylene ND ug/L 2.0 1 o-Xylene ND ug/L 1.0 1 Surrogates 4-Bromofluorobenzene (S) 102 % 70-130 1 06/19/13 17:40 460-00-4 Dibromofluoromethane (S) 120 % 70-130 1 06/19/13 17:40 1868-53-7 1,2-Dichloroethane-d4 (S) 104 % 70-130 1 06/19/13 17:40 17060-07-0 Toluene-d8 (S) 101 % 70-130 1 06/19/13 17:40 2037-26-5 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids ND mg/L 3.4 1 06/19/13 11:19 Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS 06/19/13 17:40 99-87-6 06/19/13 17:40 75-09-2 06/19/13 17:40 108-10-1 06/19/13 17:40 1634-04-4 06/19/13 17:40 91-20-3 06/19/13 17:40 100-42-5 06/19/13 17:40 630-20-6 06/19/13 17:40 79-34-5 06/19/13 17:40 127-18-4 06/19/13 17:40 108-88-3 06/19/13 17:40 87-61-6 06/19/13 17:40 120-82-1 06/19/13 17:40 71-55-6 06/19/13 17:40 79-00-5 06/19/13 17:40 79-01-6 06/19/13 17:40 75-69-4 06/19/13 17:40 96-18-4 06/19/13 17:40 108-05-4 06/19/13 17:40 75-01-4 06/19/13 17:40 1330-20-7 06/19/13 17:40 179601-23-1 06/19/13 17:40 95-47-6 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 11 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: Wells Fargo-CMUD 08-7008C Pace Project No,: 92161946 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 ANALYTICAL RESULTS Sample: Gmem Lab ID: 92161946006 Collected; 06/17/13 11:50 Received: 06/18/13 15:35 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual HEM, Oil and Grease Oil and Grease 200.7 MET ICP Copper Lead Zinc 8260 MSV Low Level Analytical Method: EPA 1664B ND mg/L 5.0 1 06/19/13 12:23 Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 39.4 ug/L 5.0 1 06/19/13 12:15 06/20/13 00:45 7440-50-8 NO ug/L 5.0 1 06/19/13 12:15 06/20/13 00:45 7439-92-1 ND ug/L 10.0 1 06/19/13 12:15 06/20/13 00:45 7440-66-6 Analytical Method: EPA 8260 Acetone NO ug/L 25.0 1 06/19/13 17:56 67-64-1 Benzene ND ug/L 1.0 1 06/19/13 17:56 71-43-2 Bromobenzene ND ug/L 1.0 1 06/19/13 17:56 108-86-1 Bromochloromethane ND ug/L 1.0 1 06/19/13 17:56 74-97-5 Bromodichloromethane ND ug/L 1.0 1 06/19/13 17:56 75-27-4 Bromoform ND ug/L 1.0 1 06/19/13 17:56 75-25-2 Bromomethane ND ug/L 2.0 1 06/19/13 17.56 74-83-9 2-Butanone (MEK) ND ug/L 5.0 1 06/19/13 17:56 78-93-3 n-Butylbenzene ND ug/L 1.0 1 06/19/13 17:56 104-51-8 Carbon tetrachloride ND ug/L. 1,0 1 06/19/13 17:56 56-23-5 Chlorobenzene ND ug/L 1.0 1 06/19/13 17:56 108-90-7 Chloroethane ND ug/L 1.0 1 06/19/13 17:56 75-00-3 Chloroform 1.9 ug/L 1.0 1 06/19/13 17:56 67-66-3 Chloromethane ND ug/L 1.0 1 06/19/13 17:56 74-87-3 2-Chlorotoluene ND ug/L 1.0 1 06/19/13 17:56 95-49-8 4-Chlorotoluene ND ug/L 1.0 1 06/19/13 17:56 106-43-4 Dibromochloromethane ND ug/L 1.0 1 06/19/13 17:56 124-48-1 1,2-Dibromoethane (EDB) ND ug/L 1.0 1 06/19/13 17:56 106-93-4 Dibrornomethene ND ug/L 1.0 1 06/19/13 17:56 74-95-3 1,2-Dichlorobenzene ND ug/L 1.0 1 06/19/13 17:56 95-50-1 1,3-Dichlorobenzene ND ug/L 1,0 1 06/19/13 17:56 541-73-1 1,4-Dichlorobenzene ND ug/L 1.0 1 06/19/13 17:56 106-46-7 Dichlorodifluoromethane NO ug/L 1.0 1 06/19/13 17:56 75-71-8 1,1-Dichloroethene ND ug/L 1.0 1 06/19/13 17:56 75-34-3 1,2-Dichloroethane ND ug/L 1,0 1 06/19/13 17:56 107-06-2 1,1-Dichloroethene ND ug/L 1.0 1 06/19/13 17:56 75-35-4 cis-1,2-Dichloroethene ND ug/L 1.0 1 06/19/13 17:56 156-59-2 trans-1,2-Dichloroethene ND ug/L. 1,0 1 06/19/13 17:56 156-60-5 1,2-Dichloropropane NO ug/L 1.0 1 06/19/13 17:56 78-87-5 1,3-Dichloropropane ND ug/L 1.0 1 06/19/13 17:56 142-28-9 2,2-Dichloropropane ND ug/L 1.0 1 06/19/13 17:56 594-20-7 1,1-Dichloropropene ND ug/L 1.0 1 06/19/13 17:56 563-58-6 cis-1,3-Dichloropropene ND ug/L 1.0 1 06/19/13 17:56 10061-01-5 trans-1,3-Dichloropropene ND ug/L 1.0 1 06/19/13 17:56 10061-02-6 Diisopropyl ether ND ug/L 1.0 1 06/19/13 17:56 108-20-3 Ethylbenzene ND ug/L 1.0 1 06/19/13 17:56 100-41-4 Hexachloro-1,3-butadiene ND ug/L 1,0 1 06/19/13 17:56 87-68-3 2-Hexanone ND ug/L 5.0 1 06/19/13 17:56 591-78-6 Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 12 of 25 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 ANALYTICAL RESULTS Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 Pace Analytical Services, Inc, 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 Sample: Gmem Parameters 8260 MSV Low Level p-Isopropyltoluene Methylene Chloride 4-Methy1-2-pentanone (MIBK) Methyl-tert-butyl ether Naphthalene Styrene 1,1,1,2-Tetrachloroethane 1,1 „2,2-Tetrachloroethane Tetrachloroethene Toluene 1.2.3-Trichlorobenzene 1.2.4-Thichlorobenzene 1,1 ,1-Trichtoroethane 1,1,2-Trichloroethane Trichloroethene Trichlorofluoromethane 1,2,3-Trichloropropane Vinyl acetate Vinyl chloride Xylene (Total) m&p-Xylene o-Xylene Surrogates 4-Bromofluorobenzene (S) Dibromofluoromethane (S) 1,2-Dichloroethane-d4 (S) Toluene-d8 (S) 2540D Total Suspended Solids Total Suspended Solids Date: 06/20/2013 04:52 PM Lab ID: 92161946005 Collected: 06/17/13 11:50 Received: 06/18/13 15:35 Matrix: Water Results Units Report Limit DF Prepared Analyzed CAS No, Qual Analytical Method: EPA 8260 ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L 104 % 110 % 107 % 97 % Analytical Method: SM 2540D ND mg/L 1.0 1 2.0 1 5.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 2.0 1 1.0 1 2.0 1 2,0 1 1.0 1 70-130 1 70-130 1 70-130 1 70-130 1 2.6 REPORT OF LABORATORY ANALYSIS 06/19/13 17:56 99-87-6 06/19/13 17:56 75-09-2 06/19/13 17:56 108-10-1 06/19/13 17:56 1634-04-4 06/19/13 17:56 91-20-3 06/19/13 17:56 100-42-5 06/19/13 17:56 630-20-6 06/19/13 17:56 79-34-5 06/19/13 17:56 127-18-4 06/19/13 17:56 108-88-3 06/19/13 17:56 87-61-6 06/19/13 17:56 120-82-1 06/19/13 17:56 71-55-6 06/19/13 17:56 79-00-5 06/19/13 17:56 79-01-6 06/19/13 17:56 75-69-4 06/19/13 17:56 96-18-4 06/19/13 17:56 108-05-4 06/19/13 17:56 75-01-4 06/19/13 17:56 1330-20-7 06/19/13 17:56 179601-23-1 06/19/13 17:56 95-47-6 06/19/13 17:56 460-00-4 06/19/13 17:56 1868-53-7 06/19/13 17:56 17060-07-0 06/19/13 17:56 2037-26-5 06/19/13 11-19 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc., Page 13 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7'176 QUALITY CONTROL DATA Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 QC Batch: GCSV/14893 QC Batch Method: EPA 1664B Associated Lab Samples: 92161946001, METHOD BLANK: 995147 Associated Lab Samples: Parameter Oil and Grease 92161946001, Units mg/L Analysis Method: Analysis Description: EPA 1664E 1664 HEM, Oil and Grease 92161946002,92161946003,92161946004,92161946005 Matrix: Water 92161946002,92161946003,92161946004,92161946005 Reporting Limit Analyzed Blank Result ND 5.0 06/19/13 12:19 LABORATORY CONTROL SAMPLE: 995148 Parameter Oil and Grease MATRIX SPIKE SAMPLE: Parameter Oil and Grease Date: 06/20/2013 04 52 PM Units mg 995149 Units Spike Conc. Qualifiers LCS Result 40 33.1 LCS Rec 92161662001 Spike Result Conc, NO 40 MS Result % Rec Limits Qualifiers 78-114 36,0 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. MS % Rec % Rec Limits Qualifiers 86 78-114 Page 14 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc* 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 QC Batch: MPRP/13578 AnalysisMethod: EPA 200.7 Analysis Description: 200,7 MET Associated Lab Samples: 92161946001, 92161946002, 92161946003, 92161946004, 92161946005 QC Batch Method: EPA 200.7 Pace Analytical Services, Inc. 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 METHOD BLANK: 995318 Matrix: Water Associated Lab Samples: 92161946001, 92161946002, 92161946003, 92161946004, 92161946005 Blank Reporting Parameter Units Result Limit Analyzed Qualifiers Copper ug/L ND 5.0 06/20/13 00:19 Lead ug/L ND 5,0 06/20/13 00:19 Zinc ug/L ND 10,0 06/20/13 00:19 LABORATORY CONTROL SAMPLE: 995319 Parameter Spike LCS LCS % Rec Units Conc, Result % Rec Limits Qualifiers Copper ug/L 500 473 95 85-115 Lead ug/L 500 475 95 85-115 Zinc ug/L 500 483 97 85-115 MATRIX SPIKE & MATRIX SPIKE DUP CATE: 995320 995321 MS MSD 92161946001 Spike Spike MS MSD MS MSD % Rec Parameter Units Result Conc. Conc, Result Result % Rec % Rec Limits RPD Qual Copper ug/L 18.3 500 500 502 507 97 98 70-130 1 Lead ug/L ND 500 500 463 467 93 93 70-130 1 Zinc ug/L ND 500 500 494 501 97 99 70-130 1 REPORT OF LABORATORY ANALYSIS Date: 06/20/2013 04:52 PM This report shall not be reproduced, except in full: without the written consent of Pace Analytical Services, Inc, Page 15 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 QC Batch: MSV/23352 QC Batch Method: EPA 8260 Associated Lab Samples: 92161946901, 92161946002, 92161946003, 92161946004, 92161946005 Analysis Method: Analysis Description: THOD BLANK: 995445 Matrix: Water Associated Lab Samples: Parameter EPA 8260 8260 MSV Low Level 92161946001, 92161946002, 92161946003, 92161946004, 92161946005 Blank Reporting Result Limit Analyzed Qualifiers 1,1,1,2-Tetrachloroethane ug/L 1,1,1-Trichloroethane ug/L 1,1,2,2-Tetrachloroethane ug/L 1.1,2-Trichloroethane ug/L 1,1-Dichloroethane ug/L 1,1-Dichloroethene ug/L 1,1-Dichloropropene ug/L 1,2,3-Trichlorobenzene ug/L 1,2,3-Trichloropropane ug/L 1,2,4-Trichlorobenzene ug/L 1.2-Dibromoethane (EDB) ug/L 1,2-Dichlorobenzene ug/L 1,2-Dichloroethane ug/L 12-Dichloropropane ug/L 1,3-Dichlorobenzene ug/L 1,3-Dichloropropane ug/L 1,4-Dichlorobenzene ug/L 2.2-Dichloropropane ug/L 2-Butanone (MEK) ug/L 2-Chlorotoluene ug/L 2-Hexanone ug/L 4-Chlorotoluene ug/L 4-MethyI-2-pentanone (MIBK) ug/L Acetone ug/L Benzene ug/L Bromobenzene ug/L Bromochloromethane ug/t. Bromodichloromethane ug/L Bromoform ug/L Bromomethane ug/L Carbon tetrachloride ug/L Chlorobenzene ug/L Chloroethane uglL Chloroform ug/L Chloromethane ug/L cis-1,2-Dichloroethene ug/L cis-1,3-Dichloropropene ug/L Dibromochloromethane ug/L Dibromomethane ug/L Dichlorodifluoromethane ug/L Diisopropyl ether ug/L Ethylbenzene ug/L Hexachloro-1,3-butadiene ug/L Units ND 1.0 06/19/1313:08 ND 1.0 06/19/1313:08 ND 1.0 06/19/1313:08 ND 1.0 06/19/1313:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/1313,08 ND 1.0 06/19/13 13:08 ND 1,0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 1,0 06/19/13 13:08 ND 1.0 06/19/1313:08 ND 1.0 06/19/13 13:08 ND 1,0 06/19/13 13:08 ND 1.0 06/19/1313:08 ND 1.0 06/19/1313:08 ND 1,0 06/19/13 13:08 ND 1.0 06/19/13 13:08 NO 5,0 06/19/13 13:08 ND 1,0 06/19/13 13:08 ND 5.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 5,0 06/19/131108 ND 25.0 06/19/13 13:08 ND 1.0 06/19/1313:08 ND 1,0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 2.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 NO 1,0 06/19/13 13:08 ND 1.0 06/19/1313:08 NO 1.0 06/19/1313:08 ND 1,0 06/19/1313:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 ND 1.0 06/19/13 13:08 REPORT OF LABORATORY ANALYSIS Date: 06/20/2013 04:52 PM This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc., Page 16 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 METHOD BLANK: 99445 Matrix Associated Lab Samples: 92161946001, 92161946002, 92161946003, 92161946004, 92161946005 Blank Result Parameter m&p-Xylene Methyl-tert-butyl ether Methylene Chloride n-Butylbenzene Naphthalene o-Xylene p-Isopropyltoluene Styrene Tetrachloroethane Toluene trans-1,2•Dichloroethene trans-1,3-Dichloropropene Trichloroethene Trichlorofluoromethane Vinyl acetate Vinyl chloride Xylene (Total) 1,2-Dichloroethane-d4 (S) 4-Bromofluorobenzene (S) Dibromofluoromethane (S) Toluene-d8 (S) Units ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L LABORATORY CONTROL SAMPLE: 995446 Parameter 1,1,1,2-Tetrachloroethane 1,1,1-Trichloroethane 1,1,2, 2-Tetrachloroethane 1,1,2-Trichloroethane 1,1-Dichloroethane 1,1-Dichloroethene 1,1-Dichloropropene 1,2,3-Trichlorobenzene 1,,3-Trichloropropane 1,2,4-Trichlorobenzene 1 „2-Dibromoethane (EDB) 1,2-Dichlorobenzene 1,2-Dichloroethane 1,2-Dichloropropane 1,3-Dichlorobenzene 1,3-Dichloropropane 1,4-Dichlorobenzene 2,2-Dichloropropane 2-Butanone (MEK) 2-Chlorotoluene Units ug/L. ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ugiL ug/L ug/L ugiL ug/L ug/L ND ND ND ND ND ND ND ND ND NO ND ND ND ND ND ND ND 106 104 115 104 Spike Conc, Reporting Limit 2.0 1.0 2.0 1.0 1,0 1.0 1,0 1.0 1.0 1,0 1.0 1.0 1.0 1.0 2.0 1.0 2.0 70-130 70-130 70-130 70-130 Analyzed Qualifiers 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 06/19/13 13:08 Pace Analytical Services, Inc. 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 LCS LCS % Rec Result % Rec Limits Qualifiers 50 47.6 95 70-130 50 48.4 97 70-130 50 50.1 100 70-130 50 53.6 107 70-130 50 53.1 106 70-130 50 48.6 97 70-132 50 51,1 102 70-130 50 46.5 93 70-135 50 44.2 88 70-130 50 46.9 94 70-134 50 48.7 97 70-130 50 48.9 98 70-130 50 48.3 97 70-130 50 50.2 100 70-130 50 48.6 97 70-130 50 45.1 90 70-130 50 47.8 96 70-130 50 50.1 100 58-145 100 119 119 70-145 50 46.0 92 70-130 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, Date. 06/20/2013 04:52 PM without the written consent of Pace Analytical Services, Inc,. Page 17 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. 2225 Riverside Or, Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 Pace Analytical Services, Inc. 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 LABORATORY CONTROL SAMPLE: 995446 Spike LCS LCS % Rec Parameter Units Conc. Result % Rec Limits Qualifiers 2-Hexanone ug/L 100 94.9 95 70-144 4-Chlorotoluene ug/L 50 48.5 97 70-130 4-Methyl-2-pentanone (MIBK) ug/L 100 102 102 70-140 Acetone ug/L 100 120 120 50-175 Benzene ug/L 50 50.7 101 70-130 Bromobenzene ug/L 50 47,3 95 70-130 Bromochioromethane ug/L 50 52.1 104 70-130 Bromodichloromethane ug/L. 50 48.6 97 70-130 Bromoform ug/L 50 50,1 100 70-130 Bromomethane ug/L 50 69.6 139 54-130 F,L0 Carbon tetrachloride ug/L 50 48,2 96 70-132 Chlorobenzene ug/L 50 48,8 98 70-130 Chloroethane ug/L 50 47.9 96 64-134 Chloroform ug/L 50 50.0 100 70-130 Chloromethane ug/L 50 45.9 92 64-130 cis-1;2-Dichloroethene ug/L 50 50.2 100 70-131 cis-1,3-Dichloropropene ug/L 50 49.4 99 70-130 Dibromochloromethane ug/L 50 49.3 99 70-130 Dibromomethane ug/L 50 52.5 105 70-131 Dichlorodifluoromethane ug/L 50 44.0 88 56-130 Diisopropyl ether ug/L 50 53.0 106 70-130 Ethylbenzene ug/L 50 48.1 96 70-130 Hexachloro-1,3-butadiene ug/L 50 48,5 97 70-130 m&p-Xylene ug/L 100 94.8 95 70-130 Methyl-tert-butyl ether ug/L 50 52.4 105 70-130 Methylene Chloride ug/L 50 47,0 94 63-130 n-Butylbenzene ug/L 50 47.4 95 70-130 Naphthalene ug/L 50 45.5 91 70-138 o-Xylene ug/L 50 47.7 95 70-130 p-Isopropyltoluene ug/L 50 48.1 96 70-130 Styrene ug/L 50 49.2 98 70-130 Tetrachloroethene ug/L 50 48.5 97 70-130 Toluene ug/L 50 51.2 102 70-130 trans-1,2-Dichloroethene ug/L 50 51,4 103 70-130 trans-1,3-Dichloropropene ug/L 50 49.5 99 70-132 Trichloroethene ug/L 50 47,1 94 70-130 Trichlorofluoromethane ug/L 50 48.0 96 62-133 Vinyl acetate ug/L 100 109 109 66-157 Vinyl chloride ug/L 50 53.3 107 69-130 Xylene (Total) ug/L 150 142 95 70-130 1,2-Dichloroethene-d4 (S) %© 92 70-130 4-Bromofluorobenzene (S) % 100 70-130 Dibromofluoromethane (S) % 100 70-130 Toluene-d8 (S) % 103 70-130 Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 18 of 25 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc„ Pace Analytical Services, Inc, 2225 Riverside [Jr. 9880 Kincey Ave„ Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project: Wells Fargo-CMUD 08-7008C Pace Project No,: 92161946 MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 995447 995448 MS MSD 92161949001 Spike Spike MS MSD MS MSD % Rec Parameter Units Result Conc. Conc, Result Result % Rec % Rec Limits RPD Qual 1,1,1,2-Tetrachloroethane ug/L ND 50 50 50.4 50.6 101 101 70-130 0 1,1,1-Trichloroethane ug/L ND 50 50 57.5 56,0 115 112 70-130 3 1,1.2,2-Tetrachloroethane ug/L ND 50 50 51.2 50.9 102 102 70-130 1 1,1,2-Trichloroethane ug/L ND 50 50 55.0 56.3 110 113 70-130 2 1,1-Dichloroethane ug/L ND 50 50 59.7 58.9 119 118 70-130 1 1,1-Dchloroethene u6/L ND 50 50 58.7 58.0 117 116 70-166 1 1,1-Dichloropropene ug/L ND 50 50 58.3 59.3 117 119 70-130 2 1,2,3-Trichlorobenzene ug/L ND 50 50 42.5 44.8 85 90 70-130 5 1,2,3-Trichloropropane ug/L NO 50 50 47,2 47,0 94 94 70-130 0 1,2,4-Trichlorobenzene ug/L ND 50 50 44.0 45.1 88 90 70-130 2 1„2-Dibromoethane (EDB) ug/L, ND 50 50 51.8 49,9 104 100 70-130 4 1,2-Dichlorobenzene ug/L ND 50 50 50.9 48.9 102 98 70-130 4 1„2-Dichloroethane ug/L ND 50 50 52.3 52,6 105 105 70-130 1 1,2-Dichloropropane ug/L ND 50 50 52,5 52.9 105 106 70-130 1 1,3-Dichlorobenzene ug/L NO 50 50 49.7 48.9 99 98 70-130 2 1,3-Dichloropropane ug/L ND 50 50 47.8 47.7 96 95 70-130 0 1,4-Dichlorobenzene ug/L ND 50 50 49,5 49,1 99 98 70-130 1 2,2-Dichloropropane ug/L ND 50 50 53.6 52,6 107 105 70-130 2 2-Butanone (MEK) ug/L ND 100 100 132 133 132 133 70-130 1 MO 2-Chlorotoluene ug/L ND 50 50 49.0 48.7 98 97 70-130 1 2-Hexanone ug/L NO 100 100 95.7 95.6 96 96 70-130 0 4-Chlorotoluene ug/L ND 50 50 50.1 50.5 100 101 70-130 1 4-Methyl-2-pentanone (MIBK) ug/L ND 100 100 106 111 106 111 70-130 4 Acetone ug/L ND 100 100 109 108 109 108 70-130 1 Benzene ug/L ND 50 50 56.9 57.5 114 115 70-148 1 Bromobenzene ug/L ND 50 50 47,1 47.1 94 94 70-130 0 Bromochloromethane ug/L ND 50 50 58.4 53.1 117 106 70-130 9 Bromodichloromethane ug/L ND 50 50 51.3 51.9 103 104 70-130 1 Bromoform ug/L. ND 50 50 44.5 44.8 89 90 70-130 1 Bromomethane ug/L ND 50 50 66.6 75.5 133 151 70-130 12 MO Carbon tetrachloride ug/L ND 50 50 57.4 58.0 115 116 70-130 1 Chlorobenzene ug/L ND 50 50 50.6 51.2 101 102 70-146 1 Chloroethane ug/L ND 50 50 63,7 57.0 127 114 70-130 11 Chloroform ug/L. ND 50 50 56.8 56.1 114 112 70-130 1 Chloromethane ug/L ND 50 50 53.9 40,7 108 81 70-130 28 cis-1,2-Dichloroethene ug/L ND 50 50 56.8 55.7 114 111 70-130 2 cis-1,3-Dichloropropene ug/L ND 50 50 50.2 52.4 100 105 70-130 4 Dibromochloromethane ug/L. ND 50 50 48.9 48.0 98 96 70-130 2 Dibromomethane ug/L ND 50 50 57.4 56.5 115 113 70-130 2 Dichlorodifluoromethane ug/L ND 50 50 52.6 53.9 105 108 70-130 2 Diisopropyl ether ug/L ND 50 50 56.5 56.3 113 113 70-130 0 Ethylbenzene ug/L ND 50 50 50.1 50.7 100 101 70-130 1 Hexachloro-1.3-butadiene ug/L ND 50 50 46.5 48.2 93 96 70-130 4 m&p-Xylene ug/L ND 100 100 101 103 101 103 70-130 1 Methyl-tert-butyl ether ug/L ND 50 50 55.8 55.0 112 110 70-130 1 Methylene Chloride ug/L ND 50 50 50.1 49.5 100 99 70-130 1 n-Butylbenzene ug/L ND 50 50 46.9 47.9 94 96 70-130 2 Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc„ Page 19 of 25 Pace Analytical Services, Inc. Pace Analytical Services, Inc. Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (335 )623-8921 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project: Wells Fargo-CMUD 08-7008C Pace Project No,: 92161946 MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 995447 995448 MS MSD 92161949001 Spike Spike MS MSD MS MSD % Rec Parameter Units Result Conc. C©nc, Result Result % Rec % Rec Lirnits RPD Naphthalene ug/L NO 50 50 44,3 44J 89 89 70-130 1 o-Xylene ug/L NO 50 50 50.8 51,3 102 103 70-130 1 p-Isopropyltoluene ug/L ND 50 50 48,8 50.5 98 101 70-130 4 Styrene ug/L ND 50 50 51.2 51.5 102 103 70-130 1 Tetrachloroethene ug/L ND 50 50 52.9 51.4 106 103 70-130 3 Toluene ug/L ND 50 50 55.5 57,3 111 115 70-155 3 trans-1,2-Dichloroethene ug/L ND 50 50 58.5 58.5 117 117 70-130 0 trans-1,3-Dichloropropene ug/L ND 50 50 49,8 52,0 100 104 70-130 4 Trichloroethene ug/L ND 50 50 53.4 55.1 107 110 69-151 3 Trichlorofluoromethane ug/L ND 50 50 61,1 60,3 122 121 70-130 1 Vinyl acetate ug/L ND 100 100 101 103 101 103 70-130 2 Vinyl chloride ug/L NO 50 50 62,6 63.5 125 127 70-130 1 1,2-Dichloroethane-d4 (S) % 104 95 70-130 4-Bromofluorobenzene (S) % 99 101 70-130 Dibromotuoromethane (S) % 102 102 70-130 Toluene-d8 (S) % 100 103 70-130 Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS Qua( This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc., Page 20 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr. 9800 KinceyAve. Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 Q Batch: WET/25866 Analysis Method: SM 2540D QC Batch Method: SM 2540D Analysis Description: 2540D Total Suspended Solids Associated Lab Samples: 92161946001, 92161946002, 92161946003, 92161946004, 92161946005 METHOD BLANK. 995247 Matrix: Water Associated Lab Samples: 92161946001, 92161946002, 92161946003, 92161946004, 92161946005 Blank Reporting Parameter Units Result Limit Analyzed Qualifiers Total Suspended Solids mg/L ND 2,5 06/19/1311:16 LABORATORY CONTROL SAMPLE; 995248 Parameter Spike LCS LCS % Rec Units Conc. Result % Rec Limits Total Suspended Solids mg/L 250 204 SAMPLE DUPLICATE: 995257 Ta Parameter Suspended Solids Date: 06/20/2013 04:52 PM 82 80-120 92161946001 Dup Units Result Result RPD mg/L ND ND REPORT OF LABORATORY ANALYSIS Qualifiers Qualifiers This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 21 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 QUALIFIERS Project: Wells Fargo-CMUD 08-7008C Pace Project No,: 92161946 Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 Pace Analytical Services, Inc. 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 DEFINITIONS DF - Dilution Factor. if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of the sample aliquot, or moisture content, ND - Not Detected at or above adjusted reporting limit, J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit, MDL -Adjusted Method Detection Limit, PRL - Pace Reporting Limit, RL - Reporting Limit. S - Surrogate 1,2-Diphenylhydrazine (8270 listed analyte) decomposes to Azobenzene, Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RFD values. LCS(D) - Laboratory Control Sample (Duplicate) MS(D) - Matrix Spike (Duplicate) DUP - Sample Duplicate RPD - Relative Percent Difference NC - Not Calculable, SG - Silica Gel - Clean -Up U - Indicates the compound was analyzed for, but not detected, N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270, The result reported for each analyte is a combined concentration. Acid preservation may not be appropriate for 2-Chloroethylvinyl ether, Styrene, and Vinyl chloride. Pace Analytical is TNI accredited, Contact your Pace PM for the current list of accredited analytes. TNI The NELAC Institute. LABORATORIES PAS( -A Pace Analyt"scat Services - Asheville PAST-C Pace Analytical Services - Charlotte ANALYTE QUALIFIERS F3 The recovery of the second source standard used to verify the initial calibration curve for this analyte is outside the laboratory's control limits, The result is estimated. LO Anatyte recovery in the laboratory control sample (LCS) was outside QC limits. MO Matrix spike recovery and/or matrix spike duplicate recovery was outside laboratory control limits. Date: 06/20/2013 04:52 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc._ Page 22 of 25 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 KinceyAve, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA CROSS REFERENCE TABLE Project: Wells Fargo-CMUD 08-7008C Pace Project No.: 92161946 Lab ID Sample ID QC Batch Method Analytical QC Batch Analytical Method Batch 92161946001 AS EPA 1664B GCSV/14893 92161946002 Zeotite EPA 1664B GCSV/14893 92161946003 GW3 EPA 1664B GCSV/14893 92161946004 GW1/2 EPA 1664B GCSV/14893 92161946005 Gmem EPA 1664E GCSV/14893 92161946001 AS EPA200,7 MPRP/13578 EPA200.7 ICP/12365 92161946002 Zeotite EPA 200.7 MPRP/13578 EPA200.7 ICP/12365 92161946003 GW3 EPA 200.7 MPRP/13578 EPA 200,7 ICP/12365 92161946004 GW1/2 EPA200.7 MPRP/13578 EPA200.7 ICP/12365 92161946005 Gmem EPA 200.7 MPRP/13578 EPA 2001 ICP/12365 92161946001 AS EPA 8260 MSV/23352 92161946002 Zeotite EPA 8260 MSV/23352 92161946003 GW3 EPA 8260 MSV/23352 92161946004 GW1/2 EPA 8260 MSV/23352 92161946005 Gmem EPA 8260 MSV/23352 92161946001 AS SM 2540D WE1/25866 92161946002 Zeotite SM 2540D WET/25866 92161946003 GW3 SM 2540D WET/25866 92161946004 GW1/2 SM 2540D WET/25866 92161946005 Gmem SM 2540D WET/25866 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 23 of 25 Date: 06/20/2013 04:52 PM Client I .arT e: Where Received: Courier: © Fed Ex © UPS© USPSQ Custody Seat on Cooler/Box Present: Packing Material: Bubble Wrap Thermometer Used: IR Gun T1102 T Temp Correction Factor T1102: Corrected Cooler Temp.: Terrtrs �d be above freezin tody Present: Chain of Custody Filled Out: Chain of Custody Relinquish arnpter Name & Signature onC©C: LSh les Arrived within Hold Time: old Time Analysis (<72hr): Rush Turn t ound Time R Sufficient Volume: Correct Containers Used: -Pace Containers Used: v VVu)fl. tft !%SI,1 f{I♦ Q Pace Nunt rsvltte u untersviiie © Asheville [] Eden 0 Raleigh Client© Commerctairlf Pace lei. -- - yes no Seats intact: 0 yes ubbte Bags © Non Type of Ice: ue None ection T101: No Correction Biological Tissue is Frozen: Yes No lkl/A ee 0 ON/A ©N/A 3. ©N/A4. ©N/A 5.. ©N/A 8. DN+o ©N/A ON/A 8.. ONo ON/A 9. ©No ©N/A no pr begun ' Containers ,Filtered volurne recei e i i3issol Sample Labels match COC: -Includes daie/tirne/ID/Analysis l latd AR containers needing preservation have been check All containers needing preservation are found to be In compliance with EPA recommendation. exceptions: VOA, coliform, TOC. OW. WFDR©leatert mples checked for dechk rination: Headspace in VOA Vials ( >Bmm): Trip Blank Present: Trip Blank Custody Seals Present Pace Trl Person Contacted: Commence Resotutlon: SCURF Review SRF Revi Note: Whenever there is a ct�a�y samples, a copy of this form will tie sent Certification Office ( Le out of hold. Incorrect p incorrect containers) Yes ©No Ale. ©Yes ONo :�1ir A 11. ©Yes it3No ©N/A -12. o ON/A Ytss ©N© ©N/A ©No ©Yea © A 14. OYes IN1A 15. ©Yes DNa ,�9A"15. Dyes ONo . JN/A N out csf temp. Y l N Page 24 of 25 Section A Requited Met irtfermaticen DruWtrrg Water 'Water Waste Wet*, eroded Sttitf5o&d SAMPLE tD C-9 Air Sam* !Os MUST SE UNIQUE Tram* Other CHAIN•OF-CUSTODY / Anal,tica Request Document The Chaim -of -Custody y S as U 'GAL URCUMEN'L All reteeadt feeds must be completed accuratoty, Section C "r>rTci.sart+r Mcxa. raj S4+r4np eeun kxrn yrew 4+6 bnxtuDrvp F'ae;oN NET NI day Pe'eiaaas aes� rPsr Ica 4d c"� 4,�F tam rtctlr mart isa� eft' pradd �n „3ki a#at,.. F�At„.i,,,^C��"8� t Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 August 02, 2013 Mr, Brian Olin ECS Charlotte 1812 Center Park Dry Suite D Charlotte, NC 28217 RE: Project: Wells Fargo Monthly Pace Project No.: 92166625 Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 1-luntersville, NC 28078 (704)875-9092 Dear Mr, Olin: Enclosed are the analytical results for sample(s) received by the laboratory on July 26, 2013. The results relate only to the samples included in this report. Results reported herein conform to the most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless otherwise noted in the body of the report. Analyses were performed at the Pace Analytical Services location indicated on the sample analyte page for analysis unless otherwise footnoted. If you have any questions concerning this report, please feel free to contact me. Sincerely, CL 9)1 Angela Baioni angela.baioni@pacelabs,com Project Manager Enclosures REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 1 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville, NC 28804 (828)254 7'176 CERTIFICATIONS Project: Wells Fargo Monthly Pace Project No.: 92166625 Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 Charlotte Certification IOs 9800 Kincey Ave. Ste 100, Huntersville, NC 28078 North Carolina Drinking Water Certification #: 37706 North Carolina Field Services Certification #: 5342 North Carolina Wastewater Certification #: 12 South Carolina Certification #: 99006001 Asheville Certification IDs 2225 Riverside Dr„ Asheville, NC 28804 Florida/NELAP Certification #: E87648 Massachusetts Certification #: M-NC030 North Carolina Drinking Water Certification #: 37712 Florida/NELAP Certification #: E87627 Kentucky UST Certification #: 84 West Virginia Certification #: 357 VirginiaNELAP Certification #: 460221 North Carolina Wastewater Certification #: 40 South Carolina Certification #: 99030001 West Virginia Certification #: 356 VirginiaNELAP Certification #: 460222 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc., Page 2 of 16 Pace Analytical Services, Inc, Pace Analytical Services, Inc, Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 SAMPLE ANALYTE COUNT Project: Wells Fargo Monthly Pace Project No.: 92166625 Lab ID Sample ID 92166625001 AS-1 Method Analytts Analysts Reported Laboratory EPA 1664E CLW 1 PASI-C EPA 200,7 JMW 2 PASI-A EPA 8260 MCK 64 PASI-C SM 2540D ANS 1 PASI-A REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 3 of 16 wmtpawleaccan Project: Wells Fargo Monthly Pace Project No.: 92166625 Pace Analytical Services, Inc., 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc, Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 Kincey Ave. Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 ANALYTICAL RESULTS Sample: AS-1 Lab ID: 92166625001 ected: 07/25/13 14:20 Received: 07/26/13 14:10 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No, Qual HEM, Oil and Grease Oil and Grease 200.7 MET ICP Lead Zinc 8260 MSV Low Level Analytical Method: EPA 1664B ND mg/L 5.0 1 07/30/13 09:23 Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 ND ug/L ND ug/L Analytical Method: EPA 8260 5.0 1 07/27/13 09:50 07/29/13 15:20 7439-92-1 10.0 1 07/27/13 09:50 07/29/13 15:20 7440-66-6 Acetone ND ug/L 25.0 1 08/01/13 05;36 67-64-1 Benzene ND ug/L 1,0 1 08/01/13 05:36 71-43-2 Bromobenzene ND ug/L 1.0 1 08/01/13 05:36 108-86-1 Bromochloromethane ND ug/L 1.0 1 08/01/13 05:36 74-97-5 Bromodichloromethane ND ug/L 1,0 1 08/01/13 05:36 75-27-4 Bromoforrn ND ug/L 1.0 1 08/01/13 05:36 75-25-2 Bromomethane ND ug/L 2.0 1 08/01/13 05:36 74-83-9 2-Butanone (MEK) NO ug/L 5,0 1 08/01/13 05:36 78-93-3 n-Butylbenzene ND ug/L 1.0 1 08/01/13 05:36 104-51-8 Carbon tetrachloride ND ug/L 1.0 1 08/01/13 05;36 56-23-5 Chlorobenzene ND ug/L 1.0 1 08/01/13 05;36 108-90-7 Chloroethane ND ug/L 1.0 1 08/01/13 05:36 75-00-3 Chloroform ND ug/L 1.0 1 08/01/13 05:36 67-66-3 Chloromethane ND ug/L 1.0 1 08/01/13 05:36 74-87-3 2-Chlorotoluene ND ug/L 1.0 1 08/01/13 05:36 95-49-8 4-Chtorotoluene ND ug/L 1.0 1 08/01/13 05:36 106-43-4 Dibromochloromethane ND ug/L 1.0 1 08/01/13 05:36 124-48-1 1,2-Dibromoethane (EDB) ND ug/L 1.0 1 08/01/13 05:36 106-93-4 Dibromomethane ND ug/L 1.0 1 08/01/13 05:36 74-95-3 1,2-Dichlorobenzene ND ug/L 1,0 1 08/01/13 05:36 95-50-1 1,3-Dichlorobenzene ND ug/L 1,0 1 08/01/13 05:36 541-73-1 1,4-Dichlorobenzene ND ug/L 1,0 1 08/01/13 05:36 106-46-7 Dichlorodifiuoromethane ND ug/L 1.0 1 08/01/13 05:36 75-71-8 1,1-Dichloroethane ND ug/L 1,0 1 08/01/13 05:36 75-34-3 1,2-Dichloroethane ND ug/L 1,0 1 08/01/13 05:36 107-06-2 1,1-Dichloroethene ND ug/L 1.0 1 08/01/13 05:36 75-35-4 cis-1,2-Dichloroethene ND ug/L 1.0 1 08/01/13 05:36 156-59-2 trans-1,2-Dichloroethene ND ug/L 1,0 1 08/01/13 05:36 156-60-5 1,2-Dichloropropane ND ug/L 1;0 1 08/01/13 05;36 78-87-5 1,3-Dichloropropane ND ug/L 1.0 1 08/01/13 05:36 142-28-9 2:2-Dichloropropane ND ug/L 1.0 1 08/01/13 05;36 594-20-7 1,1-Dichloropropene ND ug/L 1,0 1 08/01/13 05:36 563-58-6 cis-1,3-Dichloropropene ND ug/L 1.0 1 08/01/13 05:36 10061-01-5 trans-1,3-Dichloropropene ND ug/L 1.0 1 08/01/13 05:36 10061-02-6 Diisopropyl ether ND ug/L 1.0 1 08/01/13 05:36 108-20-3 Ethylbenzene ND ug/L 1.0 1 08/01/13 05:36 100-41-4 Hexachloro-1,3-butadiene ND ug/L 1,0 1 08/01/13 05:36 87-68-3 2-Hexanone ND ug/L 5.0 1 08/01/13 05:36 591-78-6 prlsopropyltoluene ND ug/L 1,0 1 08/01/13 05:36 99-87-6 Date: 08/02/2013 03;30 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc_ Page 4 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 ANALYTICAL RESULTS Project: Wells Fargo Monthly Pace Project No.: 92166625 Sample: AS-1 Lab ID: 92166625001 Collected: 07/25/13 14:20 Received: 07/26/13 14:10 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qua) 8260 MSV Low Level Analytical Method: EPA 8260 Methylene Chloride 4-Methy1-2-pentanone (MIBK) Methyl-tert-butyl ether Naphthalene Styrene 1,1,1,2-Tetrachloroethane 1,1.2.2-Tetrachloroethane Tetrachloroethene Toluene 1,2,3-Trichlorobenzene 1.2,4-Trichlorobenzene 1,1:1-Trichloroethane 1,1,2-Trichloroethane Trichloroethene Trichlorofluoromethane 1,2.3-Trichloropropane Vinyl acetate Vinyl chloride Xylene (Total) m&p-Xylene o-Xylene Surrogates 4-Bromofluorobenzene (S) Dibromofluoromethane (S) 1,2-Dichloroethane-d4 (S) Toluene-d8 (S) ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L NO ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L 99 % 103 % 108 % 97 % 25400 Total Suspended Solids Analytical Method. SM 2540D Total Suspended Solids ND mg/L Date: 08/02/2013 03:30 PM 2.0 1 5.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1,0 1 1.0 1 1.0 1 1.0 1 1,0 1 1.0 1 1.0 1 1.0 1 1,0 1 2,0 1 1.0 1 2,0 1 2.0 1 1.0 1 70-130 1 70-130 1 70-130 1 70-130 1 2.8 REPORT OF LABORATORY ANALYSIS 08/01/13 05:36 75-09-2 08/01/13 05:36 108-10-1 08/01/13 05:36 1634-04-4 08/01/13 05:36 91-20-3 08/01/13 05:36 100-42-5 08/01/13 05:36 630-20-6 08/01/13 05:36 79-34-5 08/01/13 05:36 127-18-4 08/01/13 05:36 108-88-3 08/01/13 05:36 87-61-6 08/01/13 05:36 120-82-1 08/01/13 05:36 71-55-6 08/01/13 05:36 79-00-5 08/01/13 05:36 79-01-6 08/01/13 05:36 75-69-4 08/01/13 05:36 96-18-4 08/01/13 05:36 108-05-4 08/01/13 05:36 75-01-4 08/01/13 05:36 1330-20-7 08/01/13 05:36 179601-23-1 08/01/13 05:36 95-47-6 08/01/13 05:36 460-00-4 08/01/13 05:36 1868-53-7 08/01/13 05:36 17060-07-0 08/01/13 05:36 2037-26-5 07/29/13 12:03 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 5 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville, NC 29804 (828)254-7176 QUALITY CONTROL DATA Project: Wells Fargo Monthly Pace Project No.: 92166625 Pace Analytical Services, Inc, 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 QC Batch: GCSV/15185 Analysis Method: EPA 1664B QC Batch Method: EPA 1664B Analysis Description: 1664 HEM, Oil and Grease Associated Lab Samples: 92166625001 METHOD BLANK: 1018888 Matrix: Water Associated Lab Samples: 92166625001 Parameter Oil and Grease Blank Reporting Units Result Limit Analyzed mg/L ND 5.0 07/30/13 09:21 LABORATORY CONTROLAMPLE, 101888 Parameter Units Oil and Grease rng/L MATRIX SPIKE SAMPLE: 1018890 Spike LCS LCS Conc. Result % Rec Parameter Units Oil and Grease mg/L Date: 08/02/2013 03:30 PM Qualifiers 40 386 92 % Rec 4 Qualifiers 92166394001 Spike MS MS % Rec Result Conc, Result % Rec Limits Qualifiers ND 40 36.6 91 78-114 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc_ Page 6 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Project: Wells Fargo Monthly Pace Project No,: 92166625 Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 QC Batch: MPRP/13867 Analysis Method: EPA 200.7 QC Batch Method: EPA 200,7 Analysis Description: 200.7 MET Associated Lab Samples: 92166625001 METHOD BLANK: 101818 Associated Lab Samples: 92166625001 Parameter Lead Zinc LABORATORYCONTROL SAMPLE: Parameter Lead Zinc Units ug/L ug/L Units ug/L ug/L Matrix: Water Blank Reporting Result Limit Analyzed Qualifiers ND ND 5.0 07/29/13 14:17 10.0 07/29/13 14:17 Spike LCS LCS % Rec Conc, Result % Rec Limits 500 464 93 85-115 500 476 95 85-115 Qualifiers MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1018320 1018321 MS MSD 92166466001 Spike Spike MS MSD MS MSD % Rec Units Result Conc. Conc, Result Result %© Rec % Rec Limits RPD Qual Parameter Lead ug/L ND 500 500 461 447 91 89 70-130 3 Zinc ug/L ND 500 500 465 438 86 81 70-130 6 MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1018322 1018323 MS MSD 92166379001 Spike Spike MS MSD MS MSD % Rec Parameter Units Result Conc, Conc. Result Result % Rec % Rec Limits RPD Qual Lead ug/L ND 500 500 418 406 83 81 70-130 3 Zinc ug/L ND 500 500 440 427 87 84 70-130 3 Date: 08/02/2013 03:30 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 7 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc, 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Project: Wells Fargo Monthly Pace Project No,: 92166625 Pace Analytical Services, Inc, 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 QC Batch: MSV/23795 Analysis Method: EPA 8260 QC Batch Method: EPA 8260 Analysis Description: 8260 MSV Low Level Associated Lab Samples: 92166625001 METHOD BLANK: 1020591 Matrix: Water Associated Lab Samples: 92166625001 Parameter Blank Reporting Units Result Limit Analyzed Qualifiers 1,1„1,2-Tetrachloroethane ug/L ND 1.0 07/31/13 22:40 1,1,1-Trichloroethane ug/L ND 1 0 07/31/13 22:40 1,1,2,2-Tetrachloroethane ug/L ND 1,0 07/31/13 22:40 1.1,2-Trichloroethane ug/L ND 1.0 07/31/13 22:40 1,1-Dichloroethane ug/L ND 1,0 07/31/13 22:40 1,1-Dichloroethene ug/L ND 1.0 07/31/13 22:40 1,1-Dichloropropene ug/L ND 1.0 07/31/13 22:40 1,2,3-Trichlorobenzene ug/L ND 1.0 07/31/13 22:40 1,2,3-Trichloropropane ug/L ND 1,0 07/31/13 22:40 1,2,4-Trichlorobenzene ug/L ND 1.0 07/31/13 22:40 1,2-Dibromoethane (EDB) ug/L ND 1.0 07/31/13 22:40 1,2-Dichlorobenzene ug/L ND 1.0 07/31/13 22:40 1,2-Dichloroethane ug/L ND 1.0 07/31/13 22:40 1,2-Dichloropropane ug/L ND 1.0 07/31/13 22:40 1,3-Dichlorobenzene ug/L ND 1,0 07/31/13 22:40 1,3-Dichloropropane ug/L ND 1.0 07/31/13 22:40 1,4-Dichlorobenzene uglL ND 1.0 07/31/13 22:40 2,2-Dichloropropane ug/L ND 1,0 07/31/13 22:40 2-Butanone (MEK) ug/L ND 5.0 07/31/13 22:40 2-Chlorotoluene ug/L ND 1.0 07/31/13 22:40 2-Hexanone ug/L ND 5.0 07/31/13 22:40 4-Chlorotoluene ug/L ND 1,0 07/31/13 22:40 4-Methy1-2-pentanone (MIBK) ug/L ND 5.0 07/31/13 22:40 Acetone ug/L ND 25.0 07/31/13 22:40 Benzene ug/L ND 1,0 07/31/13 22:40 Bromobenzene ug/L ND 1,0 07/31/13 22:40 Bromochloromethane ug/L ND 1,0 07/31/13 22:40 Bromodichloromethane ug/L NO 1,0 07/31/13 22:40 Bromoforrn ug/L ND 1 0 07/31/13 22:40 Bromomethane ug/L ND 2.0 07/31/13 22:40 Carbon tetrachloride ug/L ND 1.0 07/31/13 22:40 Chlorobenzene ug/L ND 1,0 07/31/13 22:40 Chloroethane ug/L ND 1,0 07/31/13 22:40 Chloroform ug/L ND 1.0 07/31/13 22:40 Chloromethane ug/L ND 1.0 07/31/13 22:40 cis-1,2-Dichloroethene ug/L ND 1.0 07/31/13 22:40 cis-1,3-Dichloropropene ug/L ND 1,0 07/31/13 22:40 Dibromochloromethane ug/L ND 1.0 07/31/13 22:40 Dibromomethane ug/L ND 1,0 07/31/13 22:40 Dichlorodifiuoromethane ug/L ND 1.0 07/31/13 22:40 Diisopropyl ether ug/L NO 1.0 07/31/13 22:40 Ethylbenzene ug/L ND 1,0 07/31/13 22:40 Hexachloro-1,3-butadiene ug/L 2,8 1,0 07/31/13 22:40 Date: 08/02/2013 03:30 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc„ Page 8 of 16 Pace Analytical Services, Inc, 205 East Meadow Road Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. Pace Analytical Services, Inc,. 2225 Riverside Dr, 9800 Kincey Ave. Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project: Wells Fargo Monthly Pace Project No.: 92166625 METHOD BLANK: 1020591 Matrix: Water Associated Lab Samples: 92166625001 Parameter m&p-Xylene Methyl-tert-butyl ether Methylene Chloride n-Butylbenzene Naphthalene o-Xylene p-lsopropyltoluene Styrene Tetrachloroethene Toluene trans-1,2-Dichloroethene trans-1,3-Dichloropropene Trichloroethene Trichlorofluoromethane Vinyl acetate Vinyl chloride Xylene (Total) 1,2-Dichloroethane-d4 (S) 4-Bromofluorobenzene (S) Dibromofluoromethane (S) Toluene-d8 (S) Blank Reporting Units Result Limit Analyzed Qualifiers ug/L ND 2.0 07/31/13 22:40 ug/L ND 1.0 07/31/13 22:40 ug/L ND 2.0 07/3'1/13 22:40 ug/L ND 1,0 07/31/1322:40 ug/L ND 1.0 07/31/1322:40 ug/L ND 1,0 07/31/13 22:40 ug/L ND 1.0 07/31/13 22:40 ug/L ND 1.0 07/31/13 22:40 ug/L ND 1,0 07/31/13 22:40 ug/L ND 1.0 07/31/13 22:40 ug/L ND 1.0 07/31/13 22:40 ug/L ND 1,0 07/31/13 22:40 ug/L ND 1.0 07/31/13 22:40 ug/L ND 1.0 07/31/13 22:40 ug/L ND 2.0 07/31/1322:40 ug/L ND 1.0 07/31/13 22:40 ug/L ND 2.0 07/31/1322:40 106 70-130 07/31/1322:40 % 97 70-130 07/31/13 22:40 % 102 70-130 07/31/13 22:40 % 97 70-130 07/31/13 22:40 LABORATORY CONTROL SAMPLE: 1020592 Spike LCS LCS % Rec Units Conc. Result % Rec Limits Qualifiers Parameter 1,1,1,2-Tetrachloroethane 1.1,1-Trichloroethane 1,1,2,2-Tetrachloroethane 1,1,2-Trichloroethane 1,1-Dichloroethane 1,1-Dichloroethene 1,1 -Dichloropropene 1,2,3-Trichlorobenzene 1,2,3-Trichloropropane 1,2,4-Trichlorobenzene 1,2-Dibromoethane (EDB) 1,2-Dichlorobenzene 1,2-Dichloroethane 1,2-Dichloropropane 1,3-Dicblorobenzene 1,3-Dichloropropane 1,4-Dichlorobenzene 2,2-Dichloropropane 2-Butanone (MEK) 2-Chlorototuene Date: 08/02/2013 03:30 PM ug/L 50 49,8 100 70-130 ug/L 50 52.5 105 70-130 ug/L 50 51.4 103 70-130 ug/L 50 52.3 105 70-130 ug/L 50 52.3 105 70-130 ug/L 50 57.4 115 70-132 ug/L 50 57.2 114 70-130 ug/L 50 57.9 116 70-135 ug/L 50 46.4 93 70-130 ug/L 50 57.8 116 70-134 ug/L 50 53.4 107 70-130 ug/L 50 53.3 107 70-130 ug/L 50 49.5 99 70-130 ug/L 50 50.1 100 70-130 ug/L 50 52.7 105 70-130 ug/L 50 50.2 100 70-130 ug/L 50 52,0 104 70-130 ug/L 50 57,2 114 58-145 ug/L 100 104 104 70-145 ug/L 50 52.2 104 70-130 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 9 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc, 2225 Riverside Dr, Asheville, NC 28804 (828)264-71'76 QUALITY CONTROL DATA Project: Wells Fargo Monthly Pace Project No.: 92166625 Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 LABORATORY CONTROL SAMPLE: 1020592 Spike LCS LCS % Rec Parameter Units Conc, Result Rec Limits Qualifiers 2-Hexanone ug/L 100 112 112 70-144 4-Chloratoluene ug/L 50 54,0 108 70-130 4-Methy1-2-pentanone (MIBK) ug/L 100 101 101 70-140 Acetone ug/L 100 101 101 50-175 Benzene ug/L 50 53.4 107 70-130 Bromobenzene ug/L 50 51,2 102 70-130 Bromochloromethane ug/L 50 47.9 96 70-130 Bromodichloromethane ug/L 50 50,2 100 70-130 Bromoform ug/L 50 56.1 112 70-130 Bromomethane ug/L 50 56,5 113 54-130 Carbon tetrachloride ug/L 50 55.6 111 70-132 Chlorobenzene ug/L 50 52.2 104 70-130 Chloroethane ug/L 50 39.1 78 64-134 Chloroform ug/L 50 51,3 103 70-130 Chloromethane ug/L 50 47.5 95 64-130 cis-1,2-Dichloroethene ug/L 50 54.1 108 70-131 cis-1,3-Dichloropropene ug/L 50 52,3 105 70-130 Dibromochloromethane ug/L 50 53.6 107 70-130 Dibromomethane ug/L 50 52.5 105 70-131 Dichlorodifluoromethane ug/L 50 39.0 78 56-130 Diisopropyl ether ug/L 50 53.9 108 70-130 Ethylbenzene ug/L 50 50.9 102 70-130 Hexachloro-1,3-butadiene ug/L 50 60.9 122 70-130 m&p-Xylene ug/L 100 104 104 70-130 Methyl-tert-butyl ether ug/L 50 56.9 114 70-130 Methylene Chloride ug/L 50 54.4 109 63-130 n-Butylbenzene ug/L 50 54,1 108 70-130 Naphthalene ug/L 50 51.3 103 70-138 o-Xylene ug/L 50 53.0 106 70-130 p-Isopropyltoluene ug/L 50 54.6 109 70-130 Styrene ug/L 50 54.6 109 70-130 Tetrachloroethene ug/L 50 53.8 108 70-130 Toluene ug/L 50 51.0 102 70-130 trans-1,2-Dichloroethene ug/L 50 55.0 110 70-130 trans-1,3-Dichloropropene ug/L 50 52.8 106 70-132 Trichloroethene ug/L 50 49.9 100 70-130 Trichlorofluoromethane ug/L 50 44.9 90 62-133 Vinyl acetate ug/L 100 10.4 10 66-157 F3,L0 Vinyl chloride ug/L 50 48,7 97 69-130 Xylene (Total) ug/L 150 157 104 70-130 1.2-Dichloroethane-d4 (S) 'Xi 95 70-130 4-Bromofluorobenzene (S) % 98 70-130 Dibromofluoromethane (S) ok 94 70-130 Toluene-d8 (S) % 98 70-130 Date: 08/02/2013 03:30 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc„ Page 10 of 16 Pace Analytical Services, Inc, Pace Analytical Services, Inc, Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr, 9800 Klncey Ave. Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project: Wells Fargo Monthly Pace Project No.: 92166625 MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1020593 1020594 MS MSD 92166624001 Spike Spike MS MSD MS MSD % Rec Parameter Units Result Conc, Conc. Result Result % Rec % Rec Limits RPD Qual 1,1-Dichloroethene k ug/L ND 50 50 57.0 52.1 114 104 70-166 9 Benzene ug/L ND 50 50 62.3 57,8 125 116 70-148 7 Chlorobenzene ug/L ND 50 50 62,5 58,3 125 117 70-146 7 Toluene ug/L ND 50 50 58.8 55.1 118 110 70-155 7 Trichloroethene ug/L ND 50 50 64.2 60.4 128 121 69-151 6 1,2-Dichloroethane-d4 (S) % 104 102 70-130 4-Bromofluorobenzene (S) % 97 97 70-130 D bromofluoromethane (S) % 103 101 70-130 Toluene-d8 (S) % 97 97 70-130 Date: 08/02/2013 03:30 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 11 of 16 Pace Analytical Services, Inc. Pace Analytical Services, Inc, Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project Wells Fargo Monthly Pace Project No 92166625 QC Batch: WET/26422 Analysis Method: SM 2540D QC Batch Method: SM 2540D Analysis Description: 2540D Total Suspended Solids Associated Lab Samples: 92166625001 METHOD BLANK: 1018508 Matrix: Water Associated Lab Samples: 92166625001 Blank Reporting Parameter Units Result Limit Analyzed Qualifiers Total Suspended Solids mg/L ND 2.5 07/29/13 11:57 LABORATORY CONTROL SAMPLE: 1018509 Spike LCS LCS % Rec Parameter Units Conc: Result % Rec Limits Qualifiers Total Suspended Solids mg/L 250 254 102 80-120 SAMPLE DUPLICATE: 1018510 Parameter Total Suspended Solids ATE: 10 Parameter Total Suspended Solids Date: 08/02/2013 03:30 PM mg/L 92166596001 Dup Units Result Result RPD Qualifiers Units mg/L 238 246 92166482002 Result 88 0 Dup Result 88 0 RPD REPORT OF LABORATORY ANALYSIS 0 Qualifiers This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 12 of 16 Pace Analytical Services, Inc. Pace Analytical Services, Inc. Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr, 9800 Klncey Ave. Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 QUALIFIERS Project: Wells Fargo Monthly Pace Project No.: 92166625 DEFINITIONS DF - Dilution Factor, if reported„ represents the factor applied to the reported data due to changes in sample preparation, dilution of the sample aliquot, or moisture content, ND - Not Detected at or above adjusted reporting limit. J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit MDL-Adjusted Method Detection Limit. PRL - Pace Reporting Limit, RL - Reporting Limit. S - Surrogate 1,2-Diphenylhydrazine (8270 listed analyte) decomposes to Azobenzene. Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values, LCS(D) - Laboratory Control Sample (Duplicate) MS(D) - Matrix Spike (Duplicate) DUP - Sample Duplicate RPD - Relative Percent Difference NC - Not Calculable, SG - Silica Gel - Clean -Up U - Indicates the compound was analyzed for, but not detected, N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270, The result reported for each analyte is a combined concentration, Acid preservation may not be appropriate for 2-Chloroethylvinyl ether, Styrene, and Vinyl chloride. Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes. TNI - The NELAC Institute. LABORATORIES PASI-A Pace Analytical Services - Asheville PASI-C Pace Analytical Services - Charlotte ANALYTE QUALIFIERS F3 The recovery of the second source standard used to verify the initial calibration curve for this analyte is outside the laboratory's control limits, The result is estimated. LO Analyte recovery in the laboratory control sample (LCS) was outside QC limits. Date: 08/02/2013 03:30 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 13 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 Kincey Ave. Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA CROSS REFERENCE TABLE Project: Wells Fargo Monthly Pace Project No,: 92166625 Lab ID Sample ID QC Batch Method Analytical QC Batch Analytical Method Batch 92166625001 AS-1 EPA 1664B GCSV/15185 92166625001 AS-1 EPA 200,7 MPRP/13867 EPA 200,7 92166625001 AS-1 EPA 8260 MSV/23795 92166625001 AS-1 SM 2540D WET/26422 Date: 08/02/2013 03:30 PM REPORT OF LABORATORY ANALYSIS ICP/12626 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc., Page 14 of 16 Client. Name: Where Received: Huntersville Condition Upon Ret:eilat iSCU Document Numb F-CHR-CS-03-rev. Pets 1 012 Pace Huntersvi © Eden [l Raleigh Courier © Fed Ex 0 UPS© USPS© Client Commercial Pace Other Custody Seal on Cooler/Box Present: © ye no Seals Intact: © yes 0 no Packing Material: © Bubble WrapBt1bbte Bags © Nonerj Other Thermometer Used: IR Gun T1102 130 Type of Ice: ( Blue None --In Samples on ice, cooling process has begun Temp Correction Factor T1102: Correction T1301: No Correction Corrected Cooler Temp: c Biological Tissue Is Frozen: Yes No NIA Temp should be above 'eez n Chain tRttsit Turrt Around Tirrte Re ut Volume: Correct Containers Used: -Pace Containers Used: A iNo INIA 9, YES No ©NIA nt OYes C N OtA Flit d volume Ceived for Dissolved DYes DNo iiBA Al pre LaDls rrtatch COC: -Includes date tirne/ID/An n prn are found to be in A recommendation>. TOC, amp ked for dechiorination: No ON/A 12, Yes D f to ©N/A 13, ©NIA Yes DYes DNo N> A 14. .Heads arce in VsA Vets ern :. Y N A Trip Blank Present: ©Yes DNo Trip Blank Custody Seals Present DYes DNo iNrA Pace Trip Slank Lott u�sedj:. Person Contacted: Comments/ Resolution: SCURF Review: SRF Review: Note: Whenever there Is a discrepancy affecOng North Carolina compliance samples, a copy of this form wttl be cant to the North Car Ina OEWNR Certification Office ( i.e out of hold, incorrect preservative, out of temp, Incorrect containers} 6 G a �•OF-CU TOY Ana Ica Request Document The Chtlinot-Ctiatody is a LEGAL DOCUMENT,. AP relevant Raids must be cw npteted accurately.. Section A Required. Deem tmterns:Wont Dent tna Wmmr Water Waste Water Pr©dtxt bowsaw SAMPLED °° ee (iteZ, €r 91 ' mete Os MUST BE UNIQUE TGete Other NAL Invariant ant NtNar:Fly cip *9 ttie *OM you ore akcceOng P 's NET 30 day payment to Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 August 27, 2013 Mr. Brian Olin ECS Charlotte 1812 Center Park Dry Suite D Charlotte, NC 28217 RE: Project: Wells Fargo Monthly 7008D Pace Project No.: 92169582 Pace Analytical Services, Inc, Pace Analytical Services, Inc. 2225 Riverside Dr. 9800 Kincey Ave. Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7'176 (704)875-9092 Dear Mr. Olin: Enclosed are the analytical results for sample(s) received by the laboratory on August 21, 2013. The results relate only to the samples included in this report. Results reported herein conform to the most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless otherwise noted in the body of the report, Analyses were performed at the Pace Analytical Services location indicated on the sample analyte page for analysis unless otherwise footnoted. If you have any questions concerning this report, please feel free to contact me. Sincerely, Angela Baioni angela.baioni@pacelabs.com Project Manager Enclosures REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 1 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services„ Inc. Pace Analytical Servtces, Inc. 2225 Riverside Dr. 9800 Kincey Ave. Suite 100 Asheville, NC 28804 Huntersviile, NC 28078 (828)254-7176 (704)875-9092 CERTIFICATIONS Project: Wells Fargo Monthly 7008D Pace Project No.: 92169582 Charlotte Certification lDs 9800 Kincey Ave, Ste 100, Huntersviile, NC 28078 North Carolina Drinking Water Certification #: 37706 North Carolina Field Services Certification #: 5342 North Carolina Wastewater Certification #: 12 South Carolina Certification #: 99006001 Florida/NELAP Certification #: E87627 Kentucky UST Certification #: 84 West Virginia Certification #: 357 VirginiaNELAP Certification #: 460221 Asheville Certification IDs 2225 Riverside Dr,, Asheville, NC 28804 North Carolina Wastewater Certification #: 40 Florida/NELAP Certification #: E87648 South Carolina Certification #: 99030001 Massachusetts Certification #: M-NC030 West Virginia Certification #: 356 North Carolina Drinking Water Certification #: 37712 VirgirliaNELAP Certification #: 460222 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full; without the written consent of Pace Analytical Services, Inc., Page 2 of 16 Pace Analytical Services, Inc. Pace Analytical Services, Inc. Pace Analytical Services, Inc. 205 East Meadow Road • Suite A 2225 Riverside Dr 9800 Kincey Ave. Suite 100 Eden, NC 27258 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 SAMPLE ANALYTE COUNT Project: Wells Fargo Monthly 7008D Pace Project No: 92169582 Lab ID Sample ID 92169582001 AS-1 Method Analytes Analysts Reported Laboratory EPA 1664E CLW 1 PASI-C EPA 200.7 JDA 2 PASI-A EPA 8260 MCK 64 PASI-C SM 2540D ANS 1 PASI-A REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 3 of 16 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: Wells Fargo Monthly 7008D Pace Project No,: 92169582 Pace Analytical Services, Inc, 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 ANALYTICAL RESULTS Pace Analytical Services, Inc, 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 Sample: AS-1 Lab ID: 92169582001 ected: 08/20/13 15:15 Received: 08/21 13 15:15 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No, Qual HEM, Oil and Grease Oil and Grease 200.7 MET ICP Analytical Method: EPA 1664B ND mg/L 5.0 1 Analytical Method: EPA 200,7 Preparation Method: EPA 200.7 08/23/13 09:23 Lead ND ug/L 5.0 1 08/22/13 14:05 08/24/13 16:54 7439-92-1 Zinc ND ug/L 10,0 1, 08/22/13 14:05 08/24/13 16:54 7440-66-6 8260 MSV Low Level Analytical Method: EPA 8260 Acetone ND ug/L 25.0 1 08/24/13 14:17 67-64-1 Benzene ND ug/L 1,0 1 08/24/13 14:17 71-43-2 Bromobenzene ND ug/L 1,0 1 08/24/13 14:17 108-86-1 Bromochloromethane ND ug/L 1,0 1 08/24/13 14:17 74-97-5 Bromodichloromethane ND ug/L 1.0 1 08/24/13 14:17 75-27-4 Bromoform ND ug/L 1.0 1 08/24/13 14:17 75-25-2 Bromomethane ND ug/L 2.0 1 08/24/13 14:17 74-83-9 2-Butanone (MEK) ND ug/L 5.0 1 08/24/13 14:17 78-93-3 Carbon tetrachloride ND ug/L 1.0 1 08/24/13 14:17 56-23-5 Chlorobenzene ND ug/L 1.0 1 08/24/13 14:17 108-90-7 Chloroethane ND ug/L 1.0 1 08/24/13 14:17 75-00-3 Chloroform ND ug/L 1,0 1 08/24/13 14:17 67-66-3 Chloromethane ND ug/L 1.0 1 08/24/13 14:17 74-87-3 2-Chlorotoluene ND ug/L 1.0 1 08/24/13 14:17 95-49-8 4-Chlorotoluene ND ug/L 1.0 1 08/24/13 14:17 106-43-4 1,2-Dibromo-3-chloropropane ND ug/L 5,0 1 08/24/13 14:17 96-12-8 Dibromochloromethane ND ug/L 1.0 1 08/24/13 14:17 124-48-1 1,2-Dibromoethane (EDB) ND ug/L 1.0 1 08/24/13 14:17 106-93-4 Dibromomethane ND ug/L 1.0 1 08/24/13 14:17 74-95-3 1,2-Dichlorobenzene ND ug/L 1.0 1 08/24/13 14:17 95-50-1 1,3-Dichlorobenzene ND ug/L 1,0 1 08/24/13 14:17 541-73-1 1,4-Dichlorobenzene ND ug/L 1.0 1 08/24/13 14:17 106-46-7 Dichlorodifluoromethane ND ug/L 1,0 1 08/24/13 14:17 75-71-8 1,1 -Dichloroethane ND ug/L 1.0 1 08/24/13 14:17 75-34-3 1,2-Dichloroethane ND ug/L 1.0 1 08/24/13 14:17 107-06-2 1,1-Dichloroethene ND ug/L 1.0 1 Q8/24/13 14:17 75-35-4 cis-1,2-Dichloroethene ND ug/L 1.0 1 08/24/13 14:17 156-59-2 trans-1,2-Dichloroethene ND ug/L 1,0 1 08/24/13 14:17 156-60-5 1,2-Dichloropropane ND ug/L 1.0 1 08/24/13 14:17 78-87-5 1,3-Dichloropropane ND ug/L 1,0 1 08/24/13 14:17 142-28-9 2,2-Dichloropropane ND ug/L 1,0 1 08/24/13 14:17 594-20-7 1,1-Dichloropropene ND ug/L 1.0 1 08/24/13 14:17 563-58-6 cis-1,3-Dichloropropene ND ug/L 1,0 1 08/24/13 14:17 10061-01-5 trans-1,3-Dichloropropene ND ug/L 1.0 1 08/24/13 14:17 10061-02-6 Diisopropyl ether ND ug/L 1.0 1 08/24/13 14:17 108-20-3 Ethylbenzene ND ug/L 1.0 1 08/24/13 14:17 100-41-4 Hexachloro-1,3-butadiene ND ug/L 1.0 1 08/24/13 14:17 87-68-3 2-Hexanone ND ugit. 5.0 1 08/24/13 14:17 591-78-6 p-Isopropy)toluene ND ug/L 1.0 1 08/24/13 14:17 99-87-6 Date: 08/27/2013 04:38 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 4 of 16 Pace Analytical Services, Inc. Pace Analytical Services, Inc. Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr, 9800 Kincey Ave. Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 ANALYTICAL RESULTS Project: Wells Fargo Monthly 7008D Pace Project No.: 92169582 Sample: AS-1 Lab ID: 92169582001 Collected: 08/20/13 15:15 Received: 08/21/13 15:15 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual 8260 MSV Low Level Analytical Method: EPA 8260 Methylene Chloride 4-Methyl-2-pentanone (MIRK) Methyl-tert-butyl ether Naphthalene Styrene 1,1,1,2-Tetrachloroethane 1,1,2,2-Tetrachloroethane Tetrachloroethene Toluene 1,2,3-Trichlorobenzene 1,2,4-Trichlorobenzene 1,11-Trichloroethane 1,1,2-Trichloroethane Trichloroethene Trichlorofluoromethane 1.2,3-Trichloropropane Vinyl acetate Vinyl chloride Xylene (Total) m&p-Xylene o-Xylene Surrogates 4-Bromofluorobenzene (S) Dibromofluoromethane (S) 1,2-Dichloroethane-d4 (S) Toluene-d8 (S) ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L. ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L 99 % 101 % 105 94 % 2.0 1 5.0 1 1,0 1 1.0 1 1.0 1 1.0 1 1.0 1 1,0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1,0 1 1,0 1 1.0 1 2.0 1 1.0 1 2.0 1 2.0 1 1.0 1 70-130 1 70-130 1 70-130 1 70-130 1 08/24/13 14:17 75-09-2 08/24/13 14:17 108-10-1 08/24/13 14:17 1634-04-4 08/24/13 14:17 91-20-3 08/24/13 14:17 100-42-5 08/24/1314,17 630-20-6 08/24/13 14:17 79-34-5 08/24/13 14:17 127-18-4 08/24/13 14:17 108-88-3 08/24/13 14:17 87-61-6 08/24/13 14:17 120-82-1 08/24/13 14:17 71-55-6 08/24/13 14:17 79-00-5 08/24/13 14:17 79-01-6 08/24/13 14:17 75-69-4 08/24/13 14;17 96-18-4 08/24/13 14:17 108-05-4 08/24/13 14:17 75-01-4 08/24/13 14:17 1330-20-7 08/24/13 14:17 179601-23-1 08/24/13 14:17 95-47-6 08/24/13 14:17 460-00-4 08/24/13 14:17 1868-53-7 08/24/13 14:17 17060-07-0 08/24/13 14:17 2037-26-5 2540D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids ND mg/L 2.7 1 08/22/13 07:53 Date: 08/27/2013 04:38 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc., Page 5 of 16 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: Wells Fargo Monthly 7008D Pace Project No.: 92169582 Pace Analytical Services, 2225 Riverside Or, Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Pace Analytical Services, Inc. 9800 Kincey Ave, Suite 100 Huntersville NC 28078 (704)875-9092 QC Batch: GCSV/15384 Analysis Method: EPA 16648 QC Batch Method: EPA 16648 Analysis Description: 1664 HEM, Oil and Grease Associated Lab Samples: 92169582001 METHOD BLANK: 1034461 Matrix: Water Associated Lab Samples: 92169582001 Parameter Oil and Grease Blank Reporting Units Result Limit Analyzed Qualifiers mg/L ND 5.0 08/23/13 09:21 LABORATORY CONTROL SAMPLE: 1034462 Parameter Oil and Grease Units mg/L MATRIX SPIKE SAMPLE: 103446 Spike LCS LCS % Rec Conc. Result % Rec Limits Qualifiers 40 92169315001 Parameter Units Result 35.8 Spike Conc. Oil and Grease mglL NO 40 Date: 08/27/2013 04:38 PM 90 MS Result 6 7 REPORT OF LABORATORY ANALYSIS 78-114 MS % Rec % Rec Limits 92 78-114 Qualifiers This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc„ Page 6 of 16 Pace Analytical Services, #nc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: Wells Fargo Monthly 7008D Pace Project No.: 92169582 Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville„ NC 28804 (828)254-7176 QUALITY CONTROL DATA Pace Analytical Services, #nc. 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 QC Batch: MPRP/14035 QC Batch Method: EPA 200.7 Associated Lab Samples: 92169582001 METHOD BLANK: 1033745 Associated Lab Samples: 92169582001 Parameter Lead Zinc ug/L ug/L Units Analysis Method: Analysis Description: atax: water Blank Result Limit Analyzed Qualifiers EPA 200.7 200,7 MET Reporting ND 5.0 08/24/13 15:07 ND 10-0 08/24/13 15:07 LABORATORY CONTROL SAMPLE: 1033746 Spike LCS LCS % Rec Parameter Units Conc, Result % Rec Limits Qualifiers Lead ug/L 500 446 89 85-115 Zinc ug/L 500 446 89 85-115 MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1033747 1033748 MS MSD 92168931001 Spike Spike MS MSD MS MSD % Rec Parameter Units Result Conc. Conc. Result Result % Rec % Rec Limits RPD Qual Lead ug/L ND 500 500 435 429 87 86 70-130 1 Zinc ug/L 15,2 500 500 465 456 90 88 70-130 2 MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1033749 1033750 Parameter MS MSD 92169473002 Spike Spike MS MSD MS MSD % Rec Units Result Conc, Conc. Result Result % Rec % Rec Limits RPD Qual Lead ug/L --N© 500 500 442 446 88 89 70-130 1 Zinc ug/L 4,9J 500 500 449 453 89 90 70-130 1 Date: 08/27/2013 04:38 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc. Page 7 of 16 Pace Analytical Services, Inc, Pace Analytical Services, Inc. Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project: Wells Fargo Monthly 7008D Pace Project No,: 92169582 QC Batch: MSV/24032 Analysis Method: EPA 8260 QC Batch Method: EPA 8260 Analysis Description: 8260 MSV Low Level Associated Lab Samples: 92169582001 METHOD BLANK: 1035024 Associated Lab Samples: 92169582001 Parameter Matrix: Water Blank Reporting Units Result Limit Analyzed Quaiifie 1,1,1,2-Tetrachloroethane ug/L ND 1,0 08/24/1314:01 1,1,1-Trichloroethane ug/L ND 1.0 08/24/13 14:01 1,12,2-Tetrachloroethane ug/L ND 1,0 08/24/13 14:01 1.1,2-Trichloroethane ug/L ND 1.0 08/24/13 14:01 1,1-Dichloroethane ug/L ND 1.0 08/24/13 14:01 1,1-Dichloroethene ug/L ND 1,0 08/24/13 14:01 1,1-Dichloropropene ug/L ND 1,0 08/24/13 14:01 1,2„3-Trichlorobenzene ug/L ND 1.0 08/24/13 14:01 1,2,3-Trichloropropane ug/L ND 1.0 08/24/13 14:01 1,2,4-Trichlorobenzene ug/L ND 1.0 08/24/13 14:01 1,2-Dibromo-3-chloropropane ug/L ND 5.0 08/24/13 14:01 1,2-Dibromoethane (EDB) ug/L ND 1.0 08/24/13 14:01 1,2-Dichlorobenzene ug/L ND 1,0 08/24/13 14:01 1,2-Dichloroethane ug/L ND 1.0 08/24/13 14:01 1,2-Dichloropropane ug/L ND 1.0 08/24/13 14:01 1,3-Dichlorobenzene ug/L ND 1,0 08/24/13 14:01 1,3-Dichloropropane ug/L ND 1,0 08/24/13 14:01 1,4-Dichlorobenzene ug/L ND 1.0 08/24/13 14:01 2,2-Dichloropropane ug/L ND 1,0 08/24/13 14:01 2-Butanone (MEK) ug/L ND 5,0 08/24/13 14:01 2-Chlorotoluene ug/L ND 1.0 08/24/13 14:01 2-Hexanone ug/L ND 5,0 08/24/13 14:01 4-Chlorotoluene ug/L ND 1,0 08/24/13 14:01 4-Methyl-2-pentanone (M)BK) ug/L ND 5.0 08/24/13 14:01 Acetone ug/L ND 25.0 08/24/13 14:01 Benzene ug/L ND 1.0 08/24/13 14:01 Bromobenzene ug/L ND 1,0 08/24/13 14:01 Bromochloromethane ug/L ND 1.0 08/24/13 14:01 Bromodichloromethane ug/L ND 1.0 08/24/13 14:01 Bromofornl ug/L ND 1.0 08/24/13 14:01 Bromomethane ug/L ND 2.0 08/24/13 14:01 Carbon tetrachloride ug/L ND 1,0 08/24/13 14:01 Chlorobenzene ug/L ND 1,0 08/24/13 14:01 Chloroethane ug/L ND 1.0 08/24/13 14:01 Chloroform ug/L NO 1.0 08/24/13 14:01 Chloromethane ug/L ND 1.0 08/24/13 '14:01 cis-1,2-Dichloroethene ug/L ND 1.0 08/24/13 14:01 cis-1,3-Dichloropropene ug/L NO 1.0 08/24/13 14:01 Dibromochloromethane ug/L ND 1,0 08/24/13 14:01 Dibromomethane ug/L ND 1,0 08/24/13 14:01 Dichlorodifluoromethane ug/L ND 1.0 08/24/13 14:01 Diisopropyl ether ug/L ND 1,0 08/24/13 14:01 Ethylbenzene ug/L ND 1.0 08/24/13 14:01 Date: 08/27/2013 04:38 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 8 of 16 Pace Analytical Services, Inc. Pace Analytical Services, Inc. Pace Analytical Services, tnc. 205 East Meadow Road - Suite A 2225 Riverside Dr. 9800 Kincey Ave Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project: Wells Fargo Monthly 7008D Pace Project No,: 92169582 METHOD BLANK: 1035024 Matrix: Water Associated Lab Samples: 92169582001 Blank Reporting Parameter Units Result Limit Analyzed Qualifiers Hexachloro-1,3-butadiene ug/L m&p-Xylene ug/L Methyl-tert-butyl ether ug/L Methylene Chloride ug/L Naphthalene ug/L o-Xylene ug/L p-Isopropyltoluene ug/L Styrene ug/L Tetrachloroethene ug/L Toluene ug/L trans-1,2-Dichloroethene ug/L trans-1.3-Dichloropropene ug/L Trichloroethene ug/L Trichlorofluoromethane ug/L Vinyl acetate ugll_ Vinyl chloride ug/L Xylene (Total) ug/L 1,2-Dichloroethane-d4 (5) % 4-Bromofluorobenzene (S) Dibromofluoromethane (S) Toluene-d8 (S) °!o ABORAT©RY CONTROL SAMPLE: 10 Parameter 1,1,1,2-Tetrachloroethane ug/L 1,1,1-Trichloroethane ug/L 1,1,2,2-Tetrachloroethane ug/L. 1,1,2-Trichloroethane ug/L 1,1-Dichloroethane ug/L 1,1-Dichloroethene ug/L 1,1-Dichloropropene ug/L 1,2,3-Trichlorobenzene ug/L 1,2,3-Trichloropropane ug/L. 1,2,4-Trichlorobenzene ug/L 1,2-Dibromo-3-chloropropane ug/L 1,2-Dibromoethane (EDB) ug/L 1,2-Dichlorobenzene ug/L 1,2-Dichloroethane ug/L 1,2-Dichloropropane ug/L 1,3-Dichlorobenzene ug/L 1,3-Dichloropropane ug/L 1,4-Dichlorobenzene ug/L 2,2-Dichloropropane ug/L 2-Butanone (MEK) ug/L Date: 08/27/2013 04:38 PM Units ND ND ND ND ND ND ND ND ND ND ND NO ND ND ND ND ND 104 100 100 94 Spike LCS Conc, Result 1.0 08/24/1314:01 2.0 08/24/13 14:01 1,0 08/24/13 14:01 2,0 08/24/13 14:01 1,0 08/24/1314:01 1.0 08/24/1314:01 1.0 08/24/1314:01 1,0 08/24/1314:01 1,0 08/24/1314:01 1.0 08/24/13 14:01 1.0 08/24/1314,01 1.0 08/24/13 14:01 1.0 08/24/1314:01 1.0 08/24/13 14:01 2,0 08/24/13 14:01 1,0 08/24/1314:01 2.0 08/24/13 14:01 70-130 08/24/13 14:01 70-130 08/24/13 14:01 70-130 08/24/13 14:01 70-130 08/24/13 14:01 LCS % Rec % Rec Limits 50 56.9 114 70-130 50 51,3 103 70-130 50 53,8 108 70-130 50 52,7 105 70-130 50 49,5 99 70-130 50 51,2 102 70-132 50 48.8 98 70-130 50 55.1 110 70-135 50 52.9 106 70-130 50 57.0 114 70-134 50 60,0 120 70-130 50 56.5 113 70-130 50 60.5 121 70-130 50 49.3 99 70-130 50 46.9 94 70-130 50 59,4 119 70-130 50 50,9 102 70-130 50 59,4 119 70-130 50 37,5 75 58-145 100 95,3 95 70-145 REPORT OF LABORATORY ANALYSIS Qualifiers This report shall not be reproduced; except in full, without the written consent of Pace Analytical Services, Inc. Page 9 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Project: Wells Fargo Monthly 7008D Pace Project No.: 92169582 Pace Analytical Services, Inc. 9800 Kincey Ave, Suite 100 Huntersville, NC 28076 (704)875-9092 LABORATORY CONTROL SAMPLE: 1035025 Parameter Spike LCS LCS % Rec Units Conc, Result % Rec Limits Qualifiers 2-Chlorotoluene ug/L 50 59.3 119 70-130 2-Hexanone ug/L 100 113 113 70-144 4-Chlorotoluene ug/L 50 59.8 120 70-130 4-Methyl-2-pentanone (MIBK) ug/L 100 108 108 70-140 Acetone ug/L 100 96,9 97 50-175 Benzene ug/L 50 51,6 103 70-130 Bromobenzene ug/L 50 57.2 114 70-130 Bromochtoromethane ug/L 50 48.7 97 70-130 Bromodichloromethane ug/L 50 52.7 105 70-130 Bromoform ug/L 50 58.5 117 70-130 Bromomethane ug/L 50 50.4 101 54-130 Carbon tetrachloride ug/L 50 52.1 104 70-132 Chlorobenzene ug/L 50 55.6 111 70-130 Chloroethane ug/L 50 46.1 92 64-134 Chloroform ug/L 50 51.8 104 70-130 Chloromethane ug/L 50 54.4 109 64-130 cis-1,2-Dichloroethene ug/L 50 48.8 98 70-131 cis-1,3-Dichloropropene ug/L 50 46.3 93 70-130 Dibromochloromethane ug/L 50 57.2 114 70-130 Dibromomethane ug/L 50 50.6 101 70-131 Dichlorodifluoromethane ug/L 50 48.2 96 56-130 Diisopropyi ether ug/L 50 49.8 100 70-130 Ethylbenzene ug/L 50 53.6 107 70-130 Hexachloro-1,3-butadiene ug/L 50 55,1 110 70-130 m&p-Xylene ug/L 100 111 111 70-130 Methyl-tert-butyl ether ug/L 50 50.0 100 70-130 Methylene Chloride ug/L 50 45.0 90 63-130 Naphthalene ug/L 50 55.8 112 70-138 o-Xylene ug/L 50 56.7 113 70-130 p-Isopropyltoluene ug/L 50 56.8 114 70-130 Styrene ug/L 50 55.0 110 70-130 Tetrachloroethene ug/L 50 56.1 112 70-130 Toluene ug/L 50 51.8 104 70-130 trans-1,2-Dichloroethene ug/L 50 48.1 96 70-130 trans-1,3-Dichloropropene ug/L 50 47,4 95 70-132 Trichloroethene ug/L 50 52.1 104 70-130 Trichlorofluoromethane ug/L 50 53.0 106 62-133 Vinyl acetate ug/L 100 90.3 90 66-157 Vinyl chloride ug/L 50 36.9 74 69-130 Xylene (Total) ug/L 150 167 111 70-130 1.2-Dichloroethane-d4 (S) % 103 70-130 4-Bromofluorobenzene (S) % 94 70-130 Dibromofluoromethane (S) % 95 70-130 Toluene-d8 (S) ok 98 70-130 Date: 08/27/2013 04:38 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc„ Page 10 of 16 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: Wells Fargo Monthly 7008D Pace Project No: 92169582 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Pace Analytical Services, Inc. 9800 Kincey Ave, Suite 100 Huntersvitle, NC 28078 (704)875-9092 MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1035026 1035027 MS MSD 92169275013 Spike Spike MS MSD MS MSD % Rec Parameter Units Result Conc. Conc. Result Result % Rec % Rec Limits RPD Qual 1,1-Dichloroethene ug/L ND 50 50 57,8 54,2 116 108 70-166 6 Benzene ug/L ND 50 50 57.0 54.7 114 109 70-148 4 Chlorobenzene ug/L ND 50 50 59.9 59,7 120 119 70-146 0 Toluene ug/L ND 50 50 52,8 51.1 106 102 70-155 3 Trichloroethene ug/L ND 50 50 60.1 58.8 120 118 69-151 2 1,2-Dichloroethane-d4 (S) % 101 101 70-130 4-Bromofluorobenzene (S) % 98 98 70-130 Dibromofluoromethane (S) %© 97 96 70-130 Toluene-d8 (S) % 94 94 70-130 Date: 08/27/2013 04:38 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 11 of 16 Pace Analytical Services, Inc. Pace Analytical Services, Inc. Pace Analytical Services, Inc. 205 East Meadow Road .. Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project: Wells Fargo Monthly 7008D Pace Project No.: 92169582 QC Batch: WET/26782 Analysis Method: SM 2540D QC Batch Method: SM 2540D Analysis Description: 2540D Total Suspended Solids Associated Lab Samples: 92169582001 METHOD BLANK: 1033488 Matrix: Water Associated Lab Samples: 92169582001 Blank Reporting Parameter Units Result Limit Analyzed Qualifiers Total Suspended Solids rng/L ND 2.5 08/22/13 07:37 LABORATORY CONTROL SAMPLE: 1033489 Parameter Total Suspended Solids mg/L E DUPLICATE: 1033490 Parameter Units Spike LCS LCS % Rec Conc. Result % Rec Limits Qualifiers 250 244 98 80-120 Total Suspended Solids mg/ Units 92169589001 Dup Result Result RPD Qualifiers 136 184 30 06 SAMPLE DUPLICATE: 1033491 92169321001 Dup Parameter Units Result Result Total Suspended Solids mg/L 67.0 60.0 Date: 08/27/2013 04:38 PM RPD REPORT OF LABORATORY ANALYSIS 1 06 Qualifiers This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 12 of 16 Pace Analytical Services, Inc. Pace Analytical Services, Inc, Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 QUALIFIERS Project: Wells Fargo Monthly 7008D Pace Project No.: 92169582 DEFINITIONS DF - Dilution Factor, if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of the sample aliquot, or moisture content. ND Not Detected at or above adjusted reporting limit, J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit, MDL - Adjusted Method Detection Limit, PRL - Pace Reporting Limit, RL - Reporting Limit S - Surrogate 1,2-Diphenylhydrazine (8270 listed analyte) decomposes toAzobenzene, Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values. LCS(D) - Laboratory Control Sample (Duplicate) MS(D) - Matrix Spike (Duplicate) DUP - Sample Duplicate RPD - Relative Percent Difference NC - Not Calculable, SG - Silica Gel - Clean -Up U - Indicates the compound was analyzed for, but not detected, N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for each analyte is a combined concentration, Acid preservation may not be appropriate for 2-Chloroethylvinyl ether, Styrene, and Vinyl chloride. Pace Analytical is TNI accredited, Contact your Pace PM for the current list of accredited analytes. TNI - The NELAC Institute. LABORATORIES PASI-A Pace Analytical Services - Asheville PASI-C Pace Analytical Services Charlotte ANALYTE QUALIFIERS 06 The relative percent difference (RPD) between the sample and sample duplicate exceeded laboratory control limits. Date: 08/27/2013 04:38 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,_ Page 13 of 16 Pace Analytical Services, Inc. Pace Analytical Services, Inc, Pace Analytical Services, Inc. 205 East Meadow Road', Suite A 2225 Riverside Dr, 9800 Kincey Ave. Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA CROSS REFERENCE TABLE Project: Wells Fargo Monthly 7008D Pace Project No.: 92169582 Lab ID Sample ID QC Batch Method Analytical QC Batch Analytical Method Batch 92169582001 AS-1 EPA 1664B GCSV/15384 92169582001 AS-1 EPA200.7 MPRP/14035 EPA200.7 92169582001 AS-1 EPA 8260 MSV/24032 92169582001 AS-1 SM 2540D WET/26782 Date 08/27/2013 04:38 PM REPORT OF LABORATORY ANALYSIS ICP/12776 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services. Inc, Page 14 of 16 pie cNn i on Upon Receipt CURL urnent Num F-CHR-CS-O3-rev,11 Client Name: Where Received: r--Huntersviiie As yeville [] Eden Courier: © Fed Ex [..,J UPSD USPS© CiientL] CommerciaC Custody Seal on Cooler/Box Present: 0 yes Q Seals intact: Packing Material; [J Bubble Wrap 0 Bubbfetgs © None [ Oth Thermometer Used: IR Gun T1102 T 1) Type of ice: a Blue None Temp Correction Factor T1102: No Correction T1301: No Correction Corrected Cooler Temp:... Temp ilould Custody Present: of Custodv Filled Ou hero of Custody Reiirlslui+,theel' Raleigh Other o . © yes D Biological Tissue Is Frozen: Yes No tture on COC: ONo ONiA Hold Time: f EIN0 DNA '5. ush Turn Around Time Reg Correct Containers Used: -lace Containers Used: Sample Labels mat Trip Blank Present Trip Blank Custody Seals Present Pace Trip Blank. Lot # If Furc to ed) { Client Notification/ Resolutio Person Contacted: Comments/ Resolution: SCURF Rev SRF Revie Note: Whene samples, a copy of Certification Office (l.e oast of hold, incorrect pres ect containers) DN/A 9, DNtA A 10 Page 1 of 2 uing Authori Ht ntersvUie Quarity,Office t9 is Y I N Page 15 of 16 Section D Rn©ulndCrimnt Informathon SAMPLE ID (A-Z, G 4 t ,») Sentpte I©s MUST 9E UNKSUE rn cn CHAIN -OF -CUSTODY Analytical Request Document The Chefn-of-Custody Is €a LEGAL DOCUMENT% fit relevant fields must be completed accurately, Section C yNa e Ft E LAY AeeNCY r" GROUND WATER '"" E R NKWNk WATER UST i",.' RCRA OTHER F-AL APPENDIX I1 Pace Analytical Services, Inc. Pace Analytical Services, Inc. Pace Analytical Services, Inc. 205 East Meadow Road - Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100 Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 September 23, 2013 Mr. Brian Olin ECS Charlotte 1812 Center Park Dry Suite D Charlotte, NC 28217 RE: Project: WELLS FARGO MONTHLY Pace Project No:: 92172624 Dear Mr: Olin: Enclosed are the analytical results for sample(s) received by the laboratory on September 18, 2013, The results relate only to the samples included in this report. Results reported herein conform to the most current TNI standards and the laboratory's Quality Assurance Manual, where applicable, unless otherwise noted in the body of the report. Analyses were performed at the Pace Analytical Services location indicated on the sample analyte page for analysis unless otherwise footnoted. If you have any questions concerning this report, please feel free to contact me Sincerely, (40., 16(26arti Angela Baioni angelataioni@pacelabs,com Project Manager Enclosures REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc., Page 1 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)823-8921 Project: WELLS FARGO MONTHLY Pace Project No.: 92172624 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 CERTIFICATIONS Charlotte Certification 10s 9800 Kincey Ave, Ste 100, Huntersville, NC 28078 North Carolina Drinking Water Certification #: 37706 North Carolina Field Services Certification #: 5342 North Carolina Wastewater Certification #: 12 South Carolina Certification #: 99006001 Asheville Certification IDs 2225 Riverside Dr., Asheville, NC 28804 Florida/NELAP Certification #: E87648 Massachusetts Certification #: M-NC030 North Carolina Drinking Water Certification #: 37712 Florida/NELAP Certification #: E87627 Kentucky UST Certification #: 84 West Virginia Certification #: 357 VirginiaNELAP Certification 4: 460221 North Carolina Wastewater Certification #: 40 South Carolina Certification 4: 99030001 West Virginia Certification #: 356 VirginiaNELAP Certification 4: 460222 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 2 of 16 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Asheville, NC 28604 Huntersville, NC 28078 (828)254-7176 (704)875-9092 SAMPLE ANALYTE COUNT Project: WELLS FARGO MONTHLY Pace Project No.: 92172624 Lab ID Sample ID Method 92172624001 001 Analytes Analysts Reported Laboratory EPA 1664B CLW 1 PASI-C EPA 200.7 JMW 3 PASI-A EPA 8260 MCK 63 PASI-C SM 2540D MDW 1 PASI-A REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, ut the written consent of Pace Analytical Services, Inc,. Page 3 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: WELLS FARGO MONTHLY Pace Project No,: 92172624 Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 ANALYTICAL RESULTS Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Iduntersville, NC 28078 (704)875-9092 Sample: 001 Lab ID: 92172624001 Collected: 09/17/13 11:00 Received: 09/18/13 15:15 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual HEM, Oil and Grease Analytical Method: EPA 1664B Oil and Grease ND mg/L 5.0 1 09/19/13 10:40 200.7 MET ICP Analytical Method: EPA 200.7 Preparation Method: EPA 200.7 Copper ND ug/L 5,0 1 09/19/13 09:15 09/20/13 00:44 7440-50-8 Lead ND ug/L 5,0 1 09/19/13 09:15 09/20/13 00:44 7439-92-1 Zinc ND ug/L 10,0 1 09/19/13 09:15 09/20/13 00:44 7440-66-6 8260 MSV Low Level Ana cal Method: EPA 8260 Acetone ND ug/L 25.0 1 09/20/13 06:34 67-64-1 Benzene ND ug/L 1.0 1 09/20/13 06:34 71-43-2 Bromobenzene ND ug/L 1,0 1 09/20/13 06:34 108-86-1 Bromochloromethane ND ug/L 1,0 1 09/20/13 06:34 74-97-5 Bromodichloromethane ND ug/L 1,0 1 09/20/13 06:34 75-27-4 Bromoform ND ug/L 1.0 1 09/20/13 06:34 75-25-2 Bromomethane ND ug/L 2.0 1 09/20/13 06:34 74-83-9 2-Butanone (MEK) ND ug/L 5.0 1 09/20/13 06:34 78-93-3 n-Butylbenzene ND ug/L 1.0 1 09/20/13 06:34 104-51-8 Carbon tetrachloride ND ug/L 1.0 1 09/20/13 06:34 56-23-5 Chlorobenzene NO ug/L 1.0 1 09/20/13 06:34 108-90-7 Chloroethane ND ug/L 1.0 1 09/20/13 06:34 75-00-3 Chloroform ND ug/L 1.0 1 09/20/13 06:34 67-66-3 Chloromethane ND ug/L 1.0 1 09/20/13 06:34 74-87-3 2-Chlorotoluene NO ug/L 1,0 1 09/20/13 06:34 95-49-8 4-Chlorotoluene NO ug/L 1.0 1 09/20/13 06:34 106-43-4 Dibromochloromethane ND ug/L 1.0 1 09/20/13 06:34 124-48-1 1,2-Dibromoethane (EDB) ND ug/L 1.0 1 09/20/13 06:34 106-93-4 Dibromomethane NO ug/L 1.0 1 09/20/13 06:34 74-95-3 1,2-Dichlorobenzene ND ug/L 1.0 1 09/20/13 06:34 95-50-1 1,3-Dichlorobenzene ND ug/L 1.0 1 09/20/13 06:34 541-73-1 1,4-Dichlorobenzene ND ug/L 1.0 1 09/20/13 06:34 106-46-7 Dichlorodifluorometharte ND ug/L 1.0 1 09/20/13 06:34 75-71-8 1,1-Dichloroethane ND ug/L 1,0 1 09/20/13 06:34 75-34-3 1,2-Dichloroethene ND ug/L 1.0 1 09/20/13 06:34 107-06-2 1 „1-Dichloroethene ND ug/L 1.0 1 09/20/13 06:34 75-35-4 cis-1,2-Dichloroethene ND ug/L 1,0 1 09/20/13 06:34 156-59-2 trans-1,2-Dichloroethene ND ug/L 1.0 1 09/20/13 06:34 156-60-5 1,2-Dichloropropane ND ug/L 1,0 1 09/20/1306:34 78-87-5 1,3-Dichloropropane ND ug/L 1.0 1 09/20/13 06:34 142-28-9 2,2-Dichloropropane ND ug/L 1.0 1 09/20/13 06:34 594-20-7 1,1-Dichloropropene ND ug/L 1.0 1 09/20/13 06:34 563-58-6 cis-1,3-Dichloropropene ND ug/L 1.0 1 09/20/13 06:34 10061-01-5 trans-1,3-Dichloropropene ND ug/L 1,0 1 09/20/13 06:34 10061-02-6 Diisopropyl ether ND ug/L 1.0 1 09/20/13 06:34 108-20-3 Ethylbenzene ND ug/L 1.0 1 09/20/13 06:34 100-41-4 Hexachloro-1,3-butadiene ND ug/L 1,0 1 09/20/13 06:34 87-68-3 2-Hexanone ND ug/L 5.0 1 09/20/13 06:34 591-78-6 Date: 09/23/2013 05:06 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 4 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: WELLS FARGO MONTHLY Pace Project No.: 92172624 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 Kincey Ave. Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 ANALYTICAL RESULTS Sample: 001 Lab ID: 92172624001 Collected: 09/17/13 11:00 Received: 09/18/13 15:15 Matrix: Water Parameters Results Units Report Limit DF Prepared Analyzed CAS No, Qual 8260 MSV Low Level Analytical Method: EPA 8260 plsopropyltoluene Methylene Chloride 4-Methyl-2-pentanone (MIBK) Methyl-tert-butyl ether Naphthalene Styrene 1,1,1,2-Tetrachloreethane 1,1,2,2-Tetrachloroethane Tetrachloroethene Toluene 1,2.3-Trichlorobenzene 1,2,4-Trichlorobenzene 1.1.1-Trichloroethane 1,1,2-Trichloroethane Trichloroethene Trichlorofluoromethane 1,2,3-Trichloropropane Vinyl acetate Vinyl chloride Xylene (Total) rn&p-Xylene o-Xylene Surrogates 4-Bromofluorobenzene (S) 1,2-Dichloroethane-d4 (S) Toluene-d8 (S) ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L NO ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND ug/L ND uglL NO ug/L ND ug/L 101 % 98 % 97 % 1.0 1 2.0 1 5 0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1.0 1 1,0 1 1.0 1 1.0 1 1.0 1 1.0 1 2.0 1 1.0 1 2.0 1 2.0 1 1.0 1 70-130 1 70-130 1 70-130 1 09/20/13 06:34 99-87-6 09/20/13 06:34 75-09-2 09/20/13 06:34 108-10-1 09/20/13 06:34 1634-04-4 09/20/13 06:34 91-20-3 09/20/13 06:34 100-42-5 09/20/13 06:34 630-20-6 09/20/13 06:34 79-34-5 09/20/13 06:34 127-18-4 09/20/13 06:34 108-88-3 09/20/13 06:34 87-61-6 09/20/13 06:34 120-82-1 09/20/13 06:34 71-55-6 09/20/13 06:34 79-00-5 09/20/13 06:34 79-01-6 09/20/13 06:34 75-69-4 09/20/13 06:34 96-18-4 09/20/13 06:34 108-05-4 09/20/13 06:34 75-01-4 09/20/13 06:34 1330-20-7 09/20/13 06:34 179601-23-1 09/20/13 06:34 95-47-6 09/20/13 06:34 460-00-4 09/20/13 06:34 17060-07-0 09/20/13 06:34 2037-26-5 254,0D Total Suspended Solids Analytical Method: SM 2540D Total Suspended Solids ND mg/L 2.7 1 09/19/13 09:58 Date: 09/23/2013 05:06 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace ,Analytical Services, Inc.. Page 5 of 16 Analytical wsw i pacelift cam Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: WELLS FARGO MONTHLY Pace Project No,: 92172624 Pace Analytical Services, Inc. 2225 Riverside Dr Asheville, NC 28804 (828)254-7175 QUALITY CONTROL DATA Pace Analytical Services, Inc. 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 QC Batch: GCSV/15567 QC Batch Method: EPA 16646 Associated Lab Samples: 92172624001 Analysis Method: Analysis Description: METHOD BLANK: 1049972 Matrix: Water Associated Lab Samples: 92172624001 Parameter Oil and Grease mg Units EPA 1664B 1664 HEM. Oil and Grease Blank Reporting Result Limit Analyzed Qualifiers ND 5.0 09/19/13 10:39 LABORATORY CONTROL SAMPLE: 1049973 Spike LCS LCS % Rec Parameter Units Conc. Result % Rec Limits Oil and Grease mg/L MATRIX SPIKE SAMPLE: Parameter Oil and Grease Date: 09/23/2013 05:06 PM 1049974 mg Units 40 35.7 89 78-114 Qualifiers 92172655004 Spike MS MS % Rec Result Conc. Result % Rec Limits ND 40 36.2 90 REPORT OF LABORATORY ANALYSIS 7 4 alifie This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 6 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project WELLS FARGO MONTHLY Pace Project No.: 92172624 QC Batch: MPRP/14219 QC Batch Method: EPA 200.7 Associated Lab Samples: 92172624001 Analysis Method: Analysis Description: EPA 200.7 200.7 MET METHOD BLANK: 1049890 Associated Lab Samples: 92172624001 Parameter Units Copper ug/L Lead ug/L Zinc ug/L Matrix: Ater Blank Reporting Result Limit Analyzed Qualifiers NO 5,0 09/19/13 23:29 ND 5,0 09/19/13 23:29 NO 10,0 09/19/13 23:29 LABORATORY CONTROL SAMPLE: 104989 Parameter Spike LCS LCS % Rec Units Conc. Result % Rec Limits Copper ug/L 500 518 104 Lead ug/L 500 494 99 Zinc ug/L 500 495 99 85-115 Qualifiers MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1049892 1049893 MS MSD 92171809001 Spike Spike MS MSD MS MSD % Rec Parameter Units Result Conc. Conc. Result Result % Rec % Rec Limits RPD Qual Copper ug/L 136 500 500 659 655 105 104 70-130 1 Lead ug/L ND 500 500 496 493 99 99 70-130 1 Zinc ug/L 488 500 500 968 965 96 95 70-130 0 MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1049894 1049895 MS MSD 92172326001 Spike Spike MS MSD MS MSD % Rec Parameter Units Result Conc. Conc. Result Result % Rec % Rec Limits RPD Qual Copper Lead Zinc u ug/L ug/L ND 500 500 511 515 102 103 70-130 1 ND 500 500 490 496 97 99 70-130 1 3.6 500 500 3980 4020 79 86 70-130 1 mg/L REPORT OF LABORATORY ANALYSIS Date: 09/23/2013 05:06 PM This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 7 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project. WELLS FARGO MONTHLY Pace Project No.: 92172624 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Pace Analytical Services, Inc, 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 QC Batch: MSV/24304 Analysis Method: EPA 8260 QC Batch Method: EPA 8260 Analysis Description: 8260 MSV Low Level Associated Lab Samples: 92172624001 METHOD BLANK: 1050646 Associated Lab Samples: 92172624001 Parameter 1,1,1,2-Tetrachloroethane 1,1,1-Trichioroethane 1,1,2,2-Tetrachloroethane 1,1,2-Trichloroethane 1,1-Dichloroethene 1,1-Dichloroethene 1,1-Dichloropropene 1 „2,3-Trichlorobenzene 1,2,3-Trichloropropane 1,2,4-Trichlorobenzene 1,2-Dibromoethane (EDB) 1,2-Dichlorobenzene 1,2-Dichloroethene 1,2-Dichloropropane 1,3-Dichlorobenzene 1,3-Dichloropropane 1,4-Dichlorobenzene 2,2-Dichloropropane 2-Butanone (MEK) 2-Chlorotoluene 2-Hexanone 4-Chlorotoiuene 4-Methyl-2-pentanone (MIBK) Acetone Benzene Bromobenzene Bromochloromethane Bromodichloromethane Bromoform Bromomethane Carbon tetrachloride Chlorobenzene Chloroethane Chloroform Chloromethane cis-1,2-Dichloroethene cis-13-Dichloropropene Dibromochloromethane Dibromomethane Dichlorodifluoromethane Diisopropyl ether Ethylbenzene Hexachloro-1, 3-butadiene Date: 09/23/2013 05:06 PM Matrix: Water Blank Reporting Units Result Limit Analyzed Qualifiers ug/L ND 1.0 09/19f13 23:10 ug/L NO 1.0 09/19/13 23:10 ug/L ND 1,0 09/19/13 23:1Q ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ugtL ND 1,0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1,0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 5.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 5.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 5.0 09/19/13 23:10 ug/L ND 25,0 09/19/13 23:10 ug/L ND 1,0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 2.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1,0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1,0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1,0 09/19/13 23:10 ug/L ND 1.0 09/19/13 2.3:10 ug/L ND 1.0 09/19/13 23:10 ug/L ND 1,0 09/19/13 23:10 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full„ without the written consent of Pace Analytical Services, Inc.. Page 8 of 16 Pace Analytical Services, Inc, Pace Analytical Services, Inc, Pace Analytical Services, Inc, 205 East Meadow Road - Suite A 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Eden, NC 27258 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project: WELLS FARGO MONTHLY Pace Project No,: 92172624 METHOD BLANK: 1050646 Matrix: Associated Lab Samples: 92172624001 e Blank Reporting Parameter Units Result Limit Analyzed Qualifiers m&p-Xylene ug/L ND 2.0 09/19/13 23:10 Methyl-tert-butyl ether ug/L ND 1.0 09/19/13 23:10 Methylene Chloride Lig/L ND 2.0 09/19/13 231 0 n-Butylbenzene ug/L ND 1.0 09/19/13 23:10 Naphthalene ug/L ND 1.0 09/19/13 23:10 o-Xylene ug/L ND 1.0 09/19/13 23:10 p-Isopropyltoluene ug/L ND 1.0 09/19/13 23:10 Styrene ugiL ND 1.0 09/19/13 23:10 Tetrachloroethene ug/L ND 1.0 09/19/13 23:10 Toluene ug/L ND 1.0 09/19/13 23:10 trans-1,2-Dichloroethene ug/L ND 1.0 09/19/13 23:10 trans-1,3-Dichloropropene ug/L ND 1.0 09/19/13 23:10 Trichloroethene ug/L ND 1.0 09/19/13 23:10 Trichlorofluoromethane ug/L ND 1,0 09/19/13 23:10 Vinyl acetate ug/L NO 2.0 09/19/13 23:10 Vinyl chloride ug/L ND 1.0 09/19/13 23:10 Xylene (Total) ug/L ND 2.0 09/19/13 23:10 1,2-Dichloroethane-d4 (S) % 93 70-130 09/19/13 23:10 4-Bromofluorobenzene (S) % 102 70-130 09/19/13 23:10 Toluene-d8 (S) % 98 70-130 09/19/13 23:10 LABORATORY CONTROL SAMPLE: 10 0647 Spike LCS LCS % Rec Parameter Units Conc. Result % Rec Limits Qualifiers 1,1,1,2-Tetrachloroethane ug/L 50 53,5 107 70-130 1,1,1-Trichloroethane ug/L 50 53.8 108 70-130 1,1.2,2-Tetrachloroethane ug/L 50 52.3 105 70-130 1,1,2-Trichloroethane ug/L 50 55,7 111 70-130 1,1-Dichloroethane ug/L 50 54.4 109 70-130 1,1-Dichloroethene ug/L 50 57.3 115 70-132 1,1-Dichloropropene ug/L 50 60.6 121 70-130 1,2,3-Trichlorobenzene ug/L 50 39.8 80 70-135 1,2,3-Trichloropropane ug/L 50 55.0 110 70-130 1,2,4-Trichlorobenzene ug/L 50 46.8 94 70-134 1,2-Dibromoethane (EDB) ug/L 50 56.5 113 70-130 1,2-Dichlorobenzene ug/L 50 58.2 116 70-130 1.2-Dichloroethane ug/L 50 48.4 97 70-130 1,2-Dichloropropane ug/L 50 61.7 123 70-130 1,3-Dichlorobenzene ug/L 50 57.4 115 70-130 1,3-Dichloropropane ug/L 50 59.5 119 70-130 1,4-Dichlorobenzene ug/L 50 58.0 116 70-130 2,2-Dichloropropane ug/L 50 53,9 108 58-145 2-Butanone (MEK) ug/L 100 128 128 70-145 2-Chlorotoluene ug/L 50 59.4 119 70-130 2-Hexanone ug/L 100 117 117 70-144 Date: 09/23/2013 05:06 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 9 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: WELLS FARGO MONTHLY Pace Project No: 92172624 Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 QUALITY CONTROL DATA Pace Analytical Services, Inc. 9800 Kincey Ave, Suite 100 Huntersville, NC 28078 (704)875-9092 LABORATORY CONTROL SAMPLE: 1050647 Parameter Spike LCS LCS % Rec Units Conc. Result % Rec Limits Qualifiers 4-Chlorotoluene ug/L 50 61.3 123 70-130 4-Methy1-2-pentanone (MIBK) ug/L 100 117 117 70-140 Acetone ug/L 100 115 115 50-175 Benzene ug/L 50 57,3 115 70-130 Bromobenzene ug/L 50 58.3 117 70-130 Bromochioromethane ug/L 50 54.6 109 70-130 Bromodichloromethane ug/L 50 52.7 105 70-130 Bromoform ug/L 50 53,1 106 70-130 Bromomethane ug/L 50 47.9 96 54-130 Carbon tetrachloride ug/L 50 50.2 100 70-132 Chlorobenzene ug/L 50 55.2 110 70-130 Chloroethane ug/L 50 55.0 110 64-134 Chloroform ug/L 50 54.2 108 70-130 Chloromethane ug/L 50 66.0 132 64-130 F3,L0 cis-1,2-Dichloroethene ug/L 50 57.0 114 70-131 cis-1,3-Dichloropropene ug/L 50 58.7 117 70-130 Dibromochloromethane ug/L 50 53,9 108 70-130 Dibromomethane ug/L 50 53,4 107 70-131 Dichlorodifluoromethane ug/L 50 51.5 103 56-130 Diisopropyl ether ug/L 50 64.3 129 70-130 Ethylbenzene ug/L 50 54.4 109 70-130 Hexachloro-1,3-butadiene ug/L 50 44.5 89 70-130 m&p-Xylene ug/L 100 111 111 70-130 Methyl-tert-buryl ether ug/L 50 58,1 116 70-130 Methylene Chloride ug/L 50 58.7 117 63-130 n-Butyibenzene ug/L 50 54.9 110 70-130 Naphthalene ug/L 50 42.3 85 70-138 o-Xylene ug/L 50 58.2 116 70-130 p-Isopropyltoluene ug/L 50 58.0 116 70-130 Styrene ug/L 50 56.1 112 70-130 Tetrachloroethene ug/L 50 58.7 117 70-130 Toluene ug/L 50 56.0 112 70-130 trans-1,2-Dichloroethene ug/L 50 57,4 115 70-130 trans-1,3-Dichloropropene ug/L 50 60.8 122 70-132 Trichloroethene ug/L 50 54,6 109 70-130 Trichlorofluoromethane ug/L 50 47.6 95 62-133 Vinyl acetate ug/L 100 120 120 66-157 Vinyl chloride ug/L 50 58.7 117 69-130 Xylene (Total) ug/L 150 169 113 70-130 1,2-Dichloroethane-d4 (S) % 97 70-130 4-Bromofluorobenzene (S) % 99 70-130 Toluene-d8 (S) % 103 70-130 Date: 09/23/2013 05:06 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 10 of 16 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc, Pace Analytical Services, Inc. 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA Project: WELLS FARGO MONTHLY Pace Project No.: 92172624 MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1051178 1051179 MS MSD 92172624001 Spike Spike MS MSD MS MSD °/© Rec Parameter Units Result Conc, Conc. Result Result % Rec % Rec Limits RPD Qua) 1,1-Dichloroethene ug/L ND 50 50 60.4 58.8 121 118 70-166 3 Benzene ug/L ND 50 50 54,4 55.4 109 111 70-148 2 Chlorobenzene ug/L ND 50 50 53.0 55.0 106 110 70-146 4 Toluene ug/L ND 50 50 50:8 51,3 102 103 70-155 1 Trichloroethene ug/L ND 50 50 57.3 58,6 115 117 69-151 2 1,2-Dichloroethane-d4 (S) % 101 98 70-130 4-Bromofluorobenzene (S) % 103 103 70-130 Toluene-d8 (S) % 96 96 70-130 Date: 09/23/2013 05:06 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,, Page 11 of 16 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Project: WELLS FARGO MONTHLY Pace Project No.: 92172624 Pace Analytical Services, Inc- Pace Analytical Services, Inc, 2225 Riverside Dr, 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA QC Batch: WET/27188 QC Batch Method: SM 2540D Associated Lab Samples: 92172624001 Analysis Method: Analysis Description: METHOD BLANK: 1050110 Matrix: Associated Lab Samples: 92172624001 Parameter Total Suspended Solids mg/L SM 2540D 2540D Total Suspended Solids Blank Reporting Units Result Limit Analyzed Qualifiers ND 2,5 09/19/13 09:55 LABORATORY CONTROL SAMPLE: 1050111 Parameter Total Suspended Solids SAMPLE DUPLICATE: 1050112 Parameter Total Suspended Solids Units mg/L Spike LCS LCS % Rec Conc, Result % Rec Limits Qualifiers 250 248 92172595001 Dup Units Result Result 10 4 10,2 99 RPD 80-120 Qualifiers SAMPLE DUPLICATE: 1050113 Parameter Units 92172426001 Dup Result Result RPD Qualifiers Total Suspended Solids mg/L ND ND Date: 09/23/2013 05:06 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in fut, without the written consent of Pace Analytical Services, Inc.. Page 12 of 16 Pace Analytical Services, Inc, 205 East Meadow Road - Suite A Eden, NC 27286 (336)623-8921 QUALIFIERS Project WELLS FARGO MONTHLY Pace Project No.: 92172624 Pace Analytical Services, Inc, Pace Analytical Services, Inc. 2225 Riverside Dr. 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 DEFINITIONS DF - Dilution Factor, if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of the sample aliquot, or moisture content, ND - Not Detected at or above adjusted reporting limit, J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit, MDL -Adjusted Method Detection Limit, PRL - Pace Reporting Limit. RL - Reporting Limit, S - Surrogate 1,2-Diphenylhydrazine (8270 listed analyte) decomposes to Azobenzene. Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values. LCS(D) - Laboratory Control Sample (Duplicate) MS(D) - Matrix Spike (Duplicate) DUP - Sample Duplicate RFD - Relative Percent Difference NC - Not Calculable, SG - Silica Gel - Clean -Up U Indicates the compound was analyzed for, but not detected: N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for each analyte is a combined concentration, Acid preservation may not be appropriate for 2-Chloroethylvinyl ether, Styrene, and Vinyl chloride, Pace Analytical is TNI accredited, Contact your Pace PM for the current list of accredited analytes. TNI - The NELAC Institute. LABORATORIES PAS) -A Pace Analytical Services - Asheville PASI-C Pace Analytical Services - Charlotte ANALYTE QUALIFIERS F3 The recovery of the second source standard used to verify the initial calibration curve for this analyte is outside the laboratory's control limits. The result is estimated, LO Analyte recovery in the laboratory control sample (LCS) was outside QC limits, Date: 09/23/2013 05:06 PM REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc., Page 13 of 16 Pace Analytical Services, Inc. 205 East Meadow Road - Suite A Eden, NC 27288 (336)623-8921 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr. 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 QUALITY CONTROL DATA CROSS REFERENCE TABLE Project WELLS FARGO MONTHLY Pace Project No.: 92172624 Lab ID Sample ID QC Batch Method Analytical QC Batch Analytical Method Batch 92172624001 001 EPA 1664B GCSV/15567 92172624001 001 EPA 200.7 MPRP/14219 EPA 200.7 92172624001 001 EPA 8260 MSV/24304 92172624001 001 SM 2540D WET/27188 Date: 09/23/2013 05:06 PM REPORT OF LABORATORY ANALYSIS ICP/12936 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Page 14 of 16 Client Name: 5 Where Received: [. Huntersvi uuwvnrOrtt ivame: Condition Udrn Receipt SCU Document Num F-CHR-CS-03-rev.11 LJOCUrnerit rkevist,U. JUUt IA, AV I Pace10l2 heviile 0 Eden [j Raleigh Courier: [j Fed Ex 0 UPSD USPSD Client 0 Commercle6 Pace Custody Seal on Cooler/Box Present: [. yes [ no Seals intact: 0 yea 0 Packing Material 0 Bubble Wrap Bubble Bags © None Q Other Thermometer Used: IR Gun T1102 Temp Correction Factor Corrected Cooler Temp.: Temp should be abovefreerin Chain of Cu .aChain of Custody Filled Chelrt Cust dv R lin of Type of Ice: no Blue None El Samples an ice, cooling process has begun T1:10Z: No Correction T1301: No Correction nature pan CCt c Biological Ttssue Is Frozen: Yes i A Comments: ee Alt l 1N/A • 1, NtA2. Yes C No ON/A 5, Hold Time 'hrl F Turn Around Tire Requested: Sufficient Volume: Correct Containers Used: -Pace Containers Used: Containers intact: d volume rece ved for Di COC: des date/lime/ID/Analyst is needing preservation have b needing preservation are found to be in th EPA recommendation, ems, a : vriA olio,,, TOC, i&a. WI-DR4 (war Samples Wicked for deehiorination: Headspace in VOA Vials S >6mm :. Trip Blank Present: Trip Blank Custody Seeis Present Client NotlResolu Person Contacted: Comments/ Resolution: SCURF Review: SRF Review: Note: Whenever there I a discrepancy aferting N samples, a copy of this form will be sent ttr the North Carolina Certification Office (1.e out of hold, incorrect pervattve, out of incorrect containers) NIA 8 N/A 7, Yes DNa ©N/A 8, Yes ONo DNA 1, Yes ©No ON/A .•,..s..,a .., . a. 4 Yee DNo ©N/A 10, CJY °Yes No °Yes ONo A % NIA 14. A 15, A 16, A Date/Time: R P. Flail Data Required? Y I N 0 caI Ssc kxi A R Section Rquired Ciaent ttemraiim SAMPLE ID (A-Z. 0-9 t <.) Sample Os MUST BE 1JNtQUE, ORIGINAL CHAIN -CIF -CUSTODY / Analytical Request Document The Chain-dr-Custody os a LEGAL i 1CUMENT, AN relevant lulls mum be completed accurately, SIGNATURE of SAMPLER Ouote RefftiltsC f nt4e " e,.. yet ).rule: 2 July 2,2U13 Ms. Marcia Allooco Mr. Michael LParker N[OENR Division ofWater Quality Mooresville Regional Office 61OEast Center Ave.,Suite 3O1 Mooresville, NC2811S 'Corporate Properties Group Charlotte, NC 282N Subject: NOTICE OFVIOLATION Tracking Number: NOV-2013'PC-0211 Compliance Evaluation Inspection Wells Fargo Tryon Street Groundwater Renmediatkun NPDE3Permit No. N[0OD8Z3O Mecklenburg County, N[ Dear Ms. Allocco and Mr. Parker We received your above referenced Notice ofViolation listed deficiencies. The Operator in Responsible Charge find enclosed their letter addressing each deficiency in deficiencies have either been corrected orwill soon be E[Sintheir letter. If any deficiency isnot satisfactorily noeknow right away. Sincerely, Suzan'eFountain Vice President, Property Portfolio Manager Wells Fargo Bank cc/encksure! Rusty RozzeUe,K4CVVQP Brian T.Olin, E[5 David Valentine, EC5 Ron Roach, Childress Klein Properties Wells Fargo Bank, NA and have been working diligently turesolve the (ORC) for this site isE[SCarolinas, LB\ Please detail. VVebelieve that all ofthe noted corrected based onthe time frames indicated bv resolved bvthe bvenclosed responses please let Together we'��m�r �'' � July 3, 2013 Suzanne Fountain Vice President, Property Portfolio Manager Wells Fargo Bank NA 550 South Tryon St 30th Floor Charlotte, NC 28202 suzanne.fountain(c�wellsfargo.com Reference: Notice of Violation, dated June 10, 2013 Tracking Number: NOV-2013-PC-0211 NPDES Permit No. NC0088226 Wells Fargo -Tryon Street Charlotte, North Carolina ECS Project 08-7008 Dear Ms. Fountain: ECS Carolinas, LLP (ECS) has prepared this letter to address the comments outlined in the Notice of Violation, dated June 10, 2013. 1) ORC Visitation — DWQ classified the WWTP as a grade l Physical -Chemical (PC) system in August 2012; Class I facilities require weekly visitation by the ORC at a minimum. Please refer to Section C. Operations and Maintenance of Pollution Controls of Part II Standard Conditions For NPDES Permits in NC0088226 & 15A NCAC 08G .204 Responsibilities of an Operator in Responsible Charge. (ORC) (2) (h) for more information. The QRC should immediately begin weekly visits to the facility and record the visits in the ORC log book and on the respective DMR. The ORC is visiting the site weekly which will be documented in the future DMR's. 2) DMRs — The DMRs received by NCDENR — DWQ for 1/12, 3/12, 6/12, 9/12 and 1/13 were not signed by the ORC. Amended DMRs with the ORC signature should be submitted to DWQ. DMRS for 2/12 and 2/13 were not received by DWQ. The missing DMRs need to be submitted to DWQ. As ECS previously indicated these reports have been submitted and signed as required. Copies of the missing reports were forwarded to you via email on May 10, 2013. You have been added to the routing list so you receive a copy directly in the future. 3) Delegation of Authority — The back of the DMR needs to be signed by the permittee or duly authorized representative that has been delegated authority by the permittee. Please refer to 15 NCAC 02B .0506 "Reporting Requirements" (b)(2)(D) and NC0088226 Part 1I Standard Conditions for NPDES permits, Section 8, paragraph 11 Signatory Requirements . The Division of Water Quality Mooresville Regional Office has no record that Wells Fargo has delegated signature authority for DMRs and other documentation required by the permit to Mr. Ronald Roach of Childress Klein. if a delegation letter exists please forward it to the inspector. A delegation letter dated June 3, 2013 was submitted. Notice of Violation Wells Fargo — Tryon Street Charlotte, North Carolina ECS Project No, 08-7008 July 3, 2013 4) Flow reporting - NC0088226 requires that the flow be monitored continuously but reported weekly (one value for each week running from Sunday through Saturday). The value reported shall be the total flow discharged for that 7-day period. A monthly average flow (total flow reported for the month divided by the number of days in that month) should also be calculated and reported on the corresponding DMR. Please refer to A. (1) Effluent Limitations and Monitoring Requirements of the Permit. Flow recorded on the DMR should reflect the information collected from the meter to be installed. Other deficiencies noted on all DMRs reviewed were missing EPA parameter codes, no average value has been reported for each parameter and the maximum and minimum values for all parameters have not been reported. To comply with 15 NCAC 02B .0506 REPORTING REQUIREMENTS (b)(3)(H) and (K) the missing information referenced above must be added to al! future DMRs. The DMR's are now reporting weekly flow as well as the monthly average. Once the new meter is installed by August 2, 2013, this meter shall be used for weekly and monthly readings. The missing reporting information on the reviewed DMR forms will be added on future DMRs. 5) The second stage reverse osmosis system was down at the time of the inspection. This shutdown has resulted in increased flow to the CMUD sanitary sewer system. The second stage reverse osmosis system should be repaired as it is noted as a required treatment unit on the "supplement to permit cover sheet" page in NC0088226. The second stage reverse osmosis system (R02) has been repaired and is being maintained regularly. 6) Flow meter - Sump Pump (SP) 4 is the primary location of the discharge from the WWTP. NC0088226 required that a flow meter be installed on the discharge by April 2012. From my inspection it does not appear that a flow meter has been installed to measure the discharge authorized under the permit. A flow meter needs to be installed after the convergence of all dewatering streams and prior to the point of connection with the storm sewer. Please refer to A. (1) Effluent Limitations and Monitoring Requirements of the Permit (see attached documents: NC0088226 Permit & NPDES Permit Standard Conditions). Please be aware the meter must be calibrated annually (.maximum deviation of <10%) and that documentation shall be available for review during the inspection (as per Part 11 Standard Conditions for NPDES permits, Section D, paragraph 3). The meter should be installed in a location that can accommodate the need for annual calibration. Childress Klein met with Mecklenburg County Water Quality and discussed the meters and locations. The meter will be calibrated as necessary and documentation of calibration will be maintained. They are being obtained and will be installed by August 2, 2013. 7) pH Monitoring - 15A NCAC 02H .0802 are the requirements for laboratory certification and it notes that all classified systems must adhere to the rules under this section. When NC0088226 was designated as a classified WWTP (PC-1) this designation triggered the requirement that all analyses performed for reporting of data on the DMR be conducted by a certified laboratory. This includes all pH analyses and reporting. In addition, NC0088226 Part 11 Standard Conditions for NPDES permits, Section D, Monitoring and Records, paragraph 4 notes that facilities that are conducting testing of field -certified parameters only must hold the appropriate field parameter laboratory certification. Since the WWTP is a Class 2 Notice of Violation Wells Fargo — Tryon Street Charlotte, North Carolina ECS Project No, 08-7008 July 3, 2013 I facility, the pH monitoring must be conducted by a certified field laboratory and follow standard methods. DWQ has no record that ECS holds field certification under the NC Laboratory Certification Program; steps must be taken immediately to gain field certification and perform the pH analyses as per standard methods, Please see NC Laboratory Certification group's website for additional information (Field Lab Certification and Technical Assistance) and the attached guidance for field analysis of pH. If you have any questions regarding the required field lab certification, please contact Chet Whiting at (704) 235-2201 or Gary Frances at (828) 296-7043. If any pH calibration logs are available or a Field Lab Certification has been obtained, the information needs to be provided to me by email, fax or a scheduled meeting. Lab Analysis & Bench sheets (pH calibration, flow meter calibration etc.) — I am requesting the information that corresponds with the DMRs from 1/12 to present. ECS has been working with Metwater, which employs the ORC for the site which does have a Field Lab Certification. ECS contracts the ORC, Richard Woodburn from Metwater, Inc. Metwater is field lab certified for pH and they are on site during sampling events conducted for the permit. Metwater's Field Lab license number is NC01976. A pH meter calibration book is now being maintained and kept on site. The calibration for the pH has been checked and recorded for recent events, but a calibration log was not available. A new pH meter was purchased and a certified calibration obtained. These records are being maintained in a log book on site. The flow meter was installed approximately a year ago. Based on the recent meeting, the current meter does not record the flow as needed for the permit. Once installed by August 2, 2013, the new meter will be calibrated annually, or per the manufacturers recommended specifications (whichever is sooner) and these records will be maintained with the log book. If you have any questions concerning this report or this project, please contact us at (704) 525-5152. Sincerely, ECS CAROLINAS, LLP Brian T. Olin, P.G. Environmental Project Manager Stephen J. Gosselin, P.G. Principal Geologist cc: Mr. Gary Smith — Childress Klein Properties (via email) Mr. Ron Roach — Childress Klein Properties (via email) Ms. Lisa Olender — Childress Klein Properties (via email) NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrory Thomas A. Reeder Governor Acting Director John E. Skvarla, III Secretary Suzanne Fountain Vice President, Property Portfolio Manager Wells Fargo Bank, NA 550 South Tryon Street, 30th Floor Mail Code D1086-300 Charlotte, NC 28202 SUBJECT: Dear Ms. Ballard: June 10, 2013 NOTICE OF VIOLATION Tracking Number: NOV-2013-PC-0211 Compliance Evaluation Inspection Wells Fargo Tryon Street Groundwater Remediation NPDES Permit No. NC0088226 Mecklenburg County, NC On April 24, 2013, Jeff Mitchell of the Mecklenburg County Water Quality Program (MCWQP) conducted an inspection at the subject facility. Subsequent inspections/meetings were made on May 1, 2013 and May 23, 2013, (Ms. Marcia Allocco of the Division of Water Quality was in attendance). These inspections were conducted as part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality (DWQ). The enclosed report should be self-explanatory. It is requested that a written response be submitted to this Office by July 10, 2013, addressing the noted deficiencies in the enclosed report. In responding to the deficiencies, please address your comments to the attention of Ms. Allocco of this Office at the letterhead address. Additionally, please send a copy of your response to Mr. Rusty Rozzelle of MCWQP at 700 N. Tryon Street, Suite 205, Charlotte, NC 28202. If you have any questions concerning this report or any other matters, please do not hesitate to call Ms. Allocco or me at this office. Sincerely, 1 1 - r Michael L. Parker Regional Supervisor Surface Water Protection Mooresville Regional Office Enclosure cc: Rusty Rozzelle, MCWQP MLP/JGM Mooresville Regional Office Location: 610 East Center Ave„ Suite 301, Mooresville, NC 28115 Phone: (704) 663-1699 Fax: (704) 663-6040 Customer Service; 1-877-623-6748 Internet: htlp://portatncdenrorgivieblwg EPA Transaction N Code 5 Inspection Work Days United States Environmental Protection Agency Washington , DC 20460 Water Compliance Inspection Report NPDES NC0088226 Yr/Mo/Day 13/04/13 13/05/01 13/05/23 Form Approved. OMB No, 2040-0057 Approval Expires 8/31/98 Inspection Type S Remarks: Inspector: Mecklenburg County Water Quality Program Facility Self -Monitoring Rating 2 Name and Location of Facility Inspected: Wells Fargo Tryon Street Groundwater Remediation 500 Block of South Tryon Street Mecklenburg County, NC B1 QA N N Entry Time/Date: 2:30 pm / April 24, 2013 10:00 am / May 1, 2013 10:00 am / May 23, 2013 Exit Time/Date: 5:30 pm / April 24, 2013 12:00 pm / May 1, 2013 11:30 am / May 23, 2013 Name(s) of On -Site Rep resentatives/TitlelPhone Number: David Valentine ECS Carolinas, LLP (704) 634-9238 Richard Woodburn Metwater Inc. Ron Roach Childress Klein Properties (704) 429-1155 Wayne Way Childress Klein Properties Name and Address of Responsible Official: Rhonda Ballard, LEED AP Wells Fargo Bank, NA 550 South Tryon Street,30th Floor Mail Code D1086-300 Charlotte, NC 28202 Inspector C Facility Type Reserved Permit Effectiv October 1, 2011 Permit Expires: June 0, 2015 DValentine@ecslimited.com WoodburnR@hughes.net Ron.Roach@Childressklein,com Wayne.Way@Childressklein.com Title: VP, Regional Property Manager Phone Number: (704) 374-4761 Contacted: Yes Permit ® Records/Reports ® Facility Site Review Effluent/Receiving Waters Flow Measurement • Self -Monitoring Program © Compliance Schedules ® Laboratory ® Operations & Maintenance © Sludge Handling Disposal © Pretreatment Program © Stormwater See Attached Summary © Sewer Overflow El Pollution Prevention © Multimedia ® Other: Sianatu itche of lnspector(s): Agency/Office/Telephone: arcia Allocc© MCWQP / (980) 721-3565 Agency/Office: NC,JOENR — Division of Water Quality Surface Water Protection — Mooresville Regional Office Date: June 5. 2013 Dater I CA June 10, 2013 EPA Form 3560- Rev 9-94) Previous editions are obsolete Page 2 NC0088226 — 6/10/13 PERMIT: The current permit became effective on October 1, 2011, and expires on June 30, 2015. The permit authorizes the discharge of surplus treated groundwater. The 0.087 MGD groundwater remediation reclaim/recycle treatment facility consists of an influent transfer pump, one 2,500-gallon influent equalization tank, one 6-stage air stripper system, intermediate transfer pump, one zeolite media filter, anti-scalant and other pretreatment chemical systems, one ultra -filtration system, first stage reverse osmosis system, one 350-gallon reject water collection tank, one 350-gallon permeate collection tank, second stage transfer pump, second stage reverse osmosis system, effluent/reuse pump, treated wastewater/reuse meter, storage tanks, and support equipment. The groundwater remediation reclaim/recycle treatment facility was classified as a grade I Physical -Chemical (PC) facility in August 2012; a Class I facility requires weekly visitation by the ORC (at a minimum). Please refer to NC0088226 Part II Standard Conditions for NPDES permits, Section C. Operations and Maintenance of Pollution Controls & 15A NCAC 08G .204 Responsibilities of an Operator in Responsible Charge (ORC) (2) (h) for more information. The ORC has only been visiting the facility once or twice per month. The ORC should immediately begin weekly visits to the system and record the visits in the ORC log book and on the respective Discharge Monitoring Reports (DMRs). RECORDS/REPORTS: DMRs were reviewed for the period of December 2010 through March 2013. The February 2013 DMR was not available for review and the Division has no record of receipt at our Central Files. As required by NC0088226 Part II Standard Conditions for NPDES permits, Section D Monitoring and Records, paragraph 2 and 15 NCAC 02B .0506 Reporting Requirements (a)(1)(A) and (B) DMRs are to be submitted to the Division no later than the last calendar day of the month following the completed reporting period. Please submit two original copies of the February 2013 DMR to the Division. The DMRs submitted to DWQ for September 2012 and January 2013 were not signed by the ORC. A review of the electronic files provided by ECS, shows the signature of the ORC was on the above referenced DMRs. An amended DMR for both reports with the signature of the ORC should be submitted to DWQ. None of the DMRs reviewed were properly signed by the permittee. The back of the DMR must be signed by the permittee or their duly authorized representative, Please refer to NC0088226 Part II Standard Conditions for NPDES permits, Section B. General Conditions, paragraph 11 and 15 NCAC 02B .0506 Reporting Requirements (b)(2)(D). DWQ-Mooresville Regional Office (MRO) has no record that Wells Fargo has delegated signature authority for DMRs, and other documentation required by the permit to Mr. Ronald Roach of Childress Klein. A delegation letter was submitted to the Division through the county inspector on June 6, 2013. If the duly authorized representative changes in the future please ensure that a new delegation letter is sent to the MRO. The NC0088226 permit requires that flow be monitored continuously, but reported weekly (one value for each week running from Sunday through Saturday). The value reported shall be the total flow discharged for that 7- day period. A monthly average flow (total flow reported for the month divided by the number of days in that month) should also be calculated and reported on the corresponding DMR. Please refer to A. (1) Effluent Limitations and Monitoring Requirements of the Permit. Please ensure that the flow reported on future DMRs adheres to these requirements. Other deficiencies noted on all DMRs reviewed were missing EPA parameter codes (should be noted at the top of each column; only flow has been reported with an EPA parameter code), no average value has been reported for each parameter (an average cannot be reported for pH), and the maximum and minimum values Page 3 NC0088226 — 6/10/13 for all parameters have not been reported (maximum and minimum values are not reported for flow). To comply with 15 NCAC 02B .0506 REPORTING REQUIREMENTS (b)(3)(H) and (K) the missing information referenced above must be added to all future DMRs. Please refer to the effluent limitations and monitoring requirements page of NC0088226 for the correct EPA parameter codes for use on your DMRs (for example, the EPA parameter reporting code for oil and grease - hexane extractable material is 00552). FACILITY SITE REVIEW: The second stage reverse osmosis system was down at the time of the inspection. This shutdown has resulted in increased flow to the CMUD sanitary sewer system. The second stage reverse osmosis system should be repaired as it is noted as a required treatment unit on the "supplement to permit cover sheet" page in NC0088226. EFFLUENT/RECEIVING WATERS: The permittee discharges to the City of Charlotte municipal separate storm sewer system (MS4), which subsequently discharges to an unnamed tributary to Little Sugar Creek, a Class C water, within the Catawba River Basin. The discharge point was not observed during the inspection because it is located within a stormwater sewer junction box (stormwater manhole) in the middle of South Tryon Street. FLOW MEASUREMENT: At the time of the inspections, a flow meter had not been installed (required by April 1, 2012) that measures the total volume discharged to the MS4, only partial flow is currently monitored. A flow meter shall be installed after the convergence of all dewatering streams and prior to the point of connection with the MS4 or additional flow meters shall be added to enable flow reporting for all discharge streams. Please refer to A. (1) Effluent Limitations and Monitoring Requirements of the NC0088226 permit for additional information. Please be aware that any installed flow meters must be calibrated annually (maximum deviation of <10%) and that documentation shall be available for review during the inspection (as per Part II Standard Conditions for NPDES permits, Section D, paragraph 3). The meter(s) should be installed in a location that can accommodate the need for annual calibration. LABORATORY: The permittee contracts with Pace Analytical Services, Inc. to perform all chemical analyses (NC Laboratory Certification # 12) and Chronic Toxicity testing (NC Laboratory Certification #9) specified in the permit. Pace Analytical Services, Inc. was not evaluated during the inspection. At the time of the inspections, it appears that pH analyses were not being properly conducted. NC Administrative Code 15A NCAC 02H .0802 states the requirements for laboratory certification and notes that all classified systems must adhere to the rules under this section. When the groundwater remediation reclaim/recycle treatment facility was designated as a classified WWTP (PC-1) this designation triggered the requirement that all analyses performed for reporting of data on the submitted DMRs be conducted by a certified laboratory. This includes all pH analyses and reporting. In addition, NC0088226 Part II Standard Conditions for NPDES permits, Section D, Monitoring and Records, paragraph 4 notes that facilities that are conducting testing of field -certified parameters only, must hold the appropriate field parameter laboratory certification. Since the WWTP is a PC-1 facility, the pH monitoring must be conducted by a certified field laboratory and follow the requirements of standard methods (see attached information). DWQ has no record that ECS holds field certification under the NC Laboratory Certification Program. Steps must be taken immediately to gain field certification or subcontract the work with an entity that holds the appropriate field laboratory certification. Please see the Laboratory Certification group's website for additional information (http://portal.ncdenr.orq/web/wq/lab/cert/field and Page 4 NC0088226 — 6/10/13 http://portal.ncdenr.orq/web/wq/lab/cert/field/policy). If you have any questions regarding the required field lab certification, please contact Chet Whiting at (704) 235-2201 or Gary Frances at (828) 296-7043. OPERATIONS & MAINTENANCE: No issues with operations or maintenance of the facility were observed at the time of the inspections with the exception of the second stage reverse osmosis system noted in the Facility Site Review section of this report. OTHER: During a meeting with facility personnel on May 23, 2013, it was discovered that treated groundwater could be diverted to a 140,000-gallon rain harvesting tank that is primarily used for surface irrigation. Please contact Andrew Pitner with DWQ Aquifer Protection section at (704) 235-2180 to determine if a separate reuse permit is required for this activity. Mr. Pitner will need to know the location of the extraction wells, extraction volumes, known groundwater contaminants, and the type/location of vegetation the irrigation water will be supporting. Preliminary discussions with Mr. Pitner noted that a permit may not be required but he would need the additional information to make a final determination. Page 5 NC0088226 — 6/10/13 United States Environmental Protection Agency Washington, ID,C„ 20460 Water Compliance Inspection Report Section A: National Data System Coding (Le., PCS) Form Approved, OMB No, 2040-0057 Approval expires 8-31-98 Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 El 2 151 NC0088226 111 12 1 18/01/09 117 18 Is] 19 ILI 2011 211 1 1 1 1 1 1 1 I I 1 1 1 I I 1 1 1 1 1 1 I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 I I 1 1 re Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 67110 1 70 13 I 71 Li 72 Lt1 731 1 174 751 1 I 1 180 Section B. Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Duke Energy Center dewatering system 550 S Tryon St Charlotte NC 28202 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Christopher David Orrell/ORC/704-200-3436/ Name, Address of Responsible Official/Title/Phone and Fax Number Rhonda F Ballard,550 S Tryon St 30th Floor Charlotte NC 2820211704-374-4761/ Contacted No Entry Time/Date 10:30AM 18/01/09 Exit Time/Date 12:50PM 18/01/09 Other Facility Data Perrnit Effective Date 15/09/01 Permit Expiration Date 20/06/30 Section C: Areas Evaluated During Inspection (Check only those areas evaluated) • Permit • Self -Monitoring Program Flow Measurement Facility Site Review II Operations & Maintenance III Effluent/Receiving VVaters Records/Reports 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 Inspector(s) Agency/Office/Phone and Fax Numbers Date Edward Watson MRO GW/// Signature of Management Q A Reviewer EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete, Agency/Office/Phone and Fax Numbers Date Page# NPDES 31 NC0088226 12 yr/mo/day 18/01 /09 Inspection Type 18 tr.i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On January 9, 2018, a representative of MRO conducted a compliance inspection under permit NC0088226 for the Duke Dewatering system located at 530 S. College Street, Charlotte, Mecklenburg County. The system was in operation during the site visit and system components were able to be reviewed. The system has a bypass component, but all bypass water is routed throught the air stripper prior to being released to assure that no C.©.C.'S enter into the recieving stream. Historic Chronic Toxicity records indicate the sytem regularly passes wet testing. Analytical data indicates the system is operating within permitted conditions. During the site visit it was mentioned that although not required in the permit; influent and midpoint sampling would be helpful for understanding breakthrough of the Zeolite and overall system effectiveness. ChildressKlein indicated that they wouild consider the additional sampling and if the additional sampling was performed, the analytical data would be shared with MRO. Reuse water from a secondary system not in this permit, captured from the permitted system and is run through the secondary system which also employs UV treatment. The reuse water is utilized for cooling water for the building HVAC system. Page# 2 Permit: NC0088226 Inspection Date: 01/09/2018 Owner. Facility: Duke Energy Center dewatering system Inspection Type: Compliance Evaluation Permit (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Yes No NA NE El El • El • El El 0100 • El D El • El El El Comment: This permit does not expire unitl 6/30/2020. Permit renewal applications must be received 180 days prior to the expiration of the current permit. Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Yes No NA NE • El El 001110 Comment: The system treats water collected trough the dewaterinq sump. The operator views the system daily and records flow measurements. Certain system alarms are sent to the operator via email. The system runs a 40 minute cycle period that runs a backwash for 1.5 minutes. The back wash alarm has to be re -set manually. The last waste manifest for the Zeolite was available for review, however, the manifest does not indicate final destination for the spent zeolite. Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Yes No NA NE 1000 • El El El El El II Comment: The effluent pipe is not able to be observed as the system design has the pipe situated in an position that in not accessable. However, a sample was collected prior to the discharge point and no odors, foam or solids were observed. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 1111 El El 0 Is flow meter calibrated annually? 111 ED El Is the flow meter operational? El El 0 El (If units are separated) Does the chart recorder match the flow meter? 0 0 II 0 Comment: This system does not use a chart recorder. The flow meter was calibrated on 12/28/2017. Page# Permit: NC0088226 Inspection Date: 01/09/2018 Owner - Facility: Duke Energy Center dewatering system Inspection Type: Compliance Evaluation Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Yes No NA NE O 0 0 II II El 0 0 NI 0 El El IN 0 0 0 El El II 0 O El II 0 Comment: Laboratory data was reviewed for 2017 during the site visit. The analytical data is current and there were no constituents reporting above permitted limits. Sampling was not observed during this site visit. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: Sample collection was not observed during the site visit. A mention was made to be sure that Chain of Custody reflects that samples are preserved on ice. Yes No NA NE 0 El • 0 • 0 0 El O El 0 MI O El El II II El 0 0 MI 0 El 0 Page# 4 ECS CAROL N A S, L L P "Setting the Standard far Service" Oeotechnical • Construction Materials • Environmental ► Faci 'es NC ErxgimecinyFan F-10rn Jeff Mitchell, Environmental Specialist Charlotte -Mecklenburg Storm Water Services Mecklenburg County Water Quality 700 North Tryon Street Charlotte, NC 28202 Jefferv.Mitchell cr MecklenburgCountvNC.gov Reference: Mecklenburg County Site Visit Comments Response NPDES Permit No. NC0088226 Wells Fargo -Tryon Street Charlotte, North Carolina ECS Project 08-7008 Dear Mr. Mitchell: May 14, 2013 MAY 2 0 2013 ECS Carolinas, LLP. {ECS) has prepared this letter to address your comments regarding the site visit in April, 1) Flow meter — Sump Pump (SP) 4 is the primary location of the discharge from the VVWTP. NC0088226 required that a flow meter be installed on the discharge by April 2012. From my inspection it does not appear that a flow meter has been installed to measure the discharge authorized under the permit. A flow meter needs to be installed after the convergence of all dewatering streams and prior to the point of connection with the storm sewer. Please refer to A. (1) Effluent Limitations and Monitoring Requirements of the Permit (see attached documents: NC0088226 Permit & NPDES Permit Standard Conditions). Please be aware the meter must be calibrated annually (maximum deviation of <10%) and that documentation shall be available for review during the inspection (as per Part 11 Standard Conditions for NPDES permits, Section D, paragraph 3). The meter should be installed in a location that can accommodate the need for annual calibration. Childress Klein on behalf of the permit holder is currently evaluating the system to determine an appropriate location for installation and the proper meter type to satisfy this requirement. Once this determination has been made you will be provided with details on the location and meter installed. The meter will be calibrated as necessary and documentation of calibration will be maintained. 2) Flow reporting — NC0088226 requires that the flow be monitored continuously but reported weekly (one value for each week running from Sunday through Saturday). The value reported shall be the total flow discharged for that 7-day period. A monthly average flow (total flow reported for the month divided by the number of days in that month) should also be calculated and reported on the corresponding DMR. Please refer to A. (1) Effluent Limitations and Monitoring Requirements of the Permit. Flow recorded on the DMR should reflect the information collected from the meter to be installed. A system for measuring flow rates is in place and readings have been recorded on the DMR. Based on the recent meeting, the current meter does not appear to be placed to properly record the flow rates needed for the permit. Once the new meter is installed values shall be recorded and reported as required. 1812 Center Park Drive, Suite D, Charlotte, NC 28217 • T: 704-525-5152 F: 7 3 7-0023 • www..ecslimit Services; PI.LC • EcS Caro S, LLP • ECS RIG • ECS Fire, LI.0 • EOS IU�tt. <,s sc LLC • ECS MAyes ICC • ;" s S utt si, LLG • {.=".CS Tivts, LIP 3) Delegation of Authority — The back of the DMR needs to be signed by the permittee or duly authorized representative that has been delegated authority by the permittee. Please refer to 15 NCAC 02B .0506 "Reporting Requirements" (b)(2)(D) and NC0088226 Part ll Standard Conditions for NPDES permits, Section 8, paragraph 11 Signatory Requirements . The Division of Water Quality Mooresville Regional Office has no record that Wells Fargo has delegated signature authority for DMRs and other documentation required by the permit to Mr. Ronald Roach of Childress Klein. If a delegation letter exists please forward it to the inspector. Childress Klein is responsible for operating the system on behalf of the permit holder. Childress Klein in conjunction with the permit holder is preparing a letter of delegation. 4) ORC Visitation — DWQ classified the WWTP as a grade I Physical -Chemical (PC) system in August 2012; Class I facilities require weekly visitation by the ORC at a minimum. Please refer to Section C. Operations and Maintenance of Pollution Controls of Part II Standard Conditions For NPDES Permits in NC0088226 & 15A NCAC 08G .204 Responsibilities of an Operator in Responsible Charge (ORC) (2) (h) for more information. The ORC should immediately begin weekly visits to the facility and record the visits in the ORC log book and on the respective ©MR. The visits by the ORC will be increased to provide weekly visits. 5) pH Monitoring — 15A NCAC 02H .0802 are the requirements for laboratory certification and it notes that all classified systems must adhere to the rules under this section. When NC0088226 was designated as a classified WWTP (PC-1) this designation triggered the requirement that all analyses performed for reporting of data on the DMR be conducted by a certified laboratory. This includes all pH analyses and reporting. in addition, NC0088226 Part 11 Standard Conditions for NPDES permits, Section D, Monitoring and Records, paragraph 4 notes that facilities that are conducting testing of field -certified parameters only must hold the appropriate field parameter laboratory certification. Since the WWTP is a Class I facility, the pH monitoring must be conducted by a certified field laboratory and follow standard methods. DWQ has no record that ECS holds field certification under the NC Laboratory Certification Program; steps must be taken immediately to gain field certification and perform the pH analyses as per standard methods. Please see NC Laboratory Certification group's website for additional inforrnation (Field Lab Certification and Technical Assistance) and the attached guidance for field analysis of pH. If you have any questions regarding the required field lab certification, please contact Chet Whiting at (704) 235-2201 or Gary Frances at (828) 296- 7043. If any pH calibration logs are available or a Field Lab Certification has been obtained, the information needs to be provided to me by email, fax or a scheduled meeting. ECS does not have Field Lab Certification but has obtained the forms for Field Lab Certification and is working on preparing an application. ECS also has been working with another firm that employs the ORC for the site which does have a Field Lab Certification.. They can also provide the pH monitoring as an alternative and documentation of their field lab certification can be provided. The pH calibration will be kept with the log book going forward. 6) Bypass — Based off visual observations and the information that I received on May 1, 2013, Groundwater SP1 &2 pumps have two automated valves that can bypass the flow from the treatment system to a vault that is pumped directly to the storm sewer system (SP3). SP3 was the sample monitoring location approximately two years ago and received the treated groundwater at one point, but now collects and pumps stormwater that enters drains in the parking deck. All illicit oYonha/gea of untreated groundwater shall ceases; all groundwater should be treated prior to discharging to the storm sewer system as per the requirements efNCO088226' Childress Khan on behalf of the permit holder has obtained a contractor to reconfigure the bypass system. This work is scheduled to be completed within the next week, 7\ DMRs—Tha DyNFfa received by NCOENR—OVVQfor 1/12. 3V12. 8/12. 3/12 and 1/13vveoo not signed by the C)RC. Amended DyNRs with the [JRC signature should be submitted to DWQ. DyVIRGfor 2/12and 2/13were not received bvOVVQ. The missing DKNRmneed to be submitted to DWQ. As ECS previously indicated these reports have been submitted and signed as required. Copies of the rniaainQ reports were forwarded to you vim ennoi) on May 10. 2013. You will be added tothe routing |s|taoyou receive acopy directly inthe future. 0 Lab Analysis & Bench sheets (pH calibration, flow meter calibration etc.)—/aOn requesting the information that corresponds with the D&0Rofrom 1112 to present. The calibration for the pH has been checked and recorded for recent evento, but a calibration log ionot available. These will bemaintained going forward and addressed inconjunction vxith the Field Lab Certification. The flow meter was installed approximately a year ago and a calibration has not yet been needed. Based onthe recent meeting, the current meter does not record the flow as needed for the permit. Unum inata|(ed, the new meter will be calibrated annua||y, or per the manufacturers recommended specifications (whichever is sooner) and these records will bamaintained with the log book. If you have any questions concerning this report orthis project, please contact unat (704) 525-5152� BhonT. O|in, P.G. Environmental Project Manager W Principal Geologist co Mr. Gary Smith _ Childress Klein Properties (via email) Mr. Ron Roach — Childress Klein Properties (via email) Ms. Lisa [)|ender— Childress Klein Properties (via ennmi0 Allocco, Marcia From: Ron Roach klei ] Sent: Monday, May 13.2U13 9p45AM To: Mitchell, Jeffery G. Cc: All0000 Marcia; Brian Boleoky Matt Jernigan; Wayne Way; OValentine BO|in; Gavin Hhbar; WoodburnR@hughes.net Subject: RE: Wells Fargo Ground Water Remediation System - Tryon Street (NCO088226) Jeff, | was out of town on Friday so | am just now responding. | will be speaking to E[S later today to assist in their response. In regards to the meter and bypass; we are actively engaging our plumbing vendor to repair the bypass issue immediately. The meter issue is a bit more perplexing. Since SP4 has multiple sources of which some are in dispute between drawings and reality we are trying to determine what type ofmeter and at what location to install it to only capture what iocoming from the tanks. We do take these issues seriously and are applying the necessary resources to ensure compliance and accuracy. Thank You Ron H.Roach FMA Childress Klein Properties Chief Engineer/Duke Energy Center uffiue7O4-3]O-254O ocU704'293-l\55 From: y4KzheL Jeffery G. [nlaUto Mitchdl@n1ecklenburQcVuntync.00v] Sent: Fhday, May 10,2013 8:46AM To: Ron Roach; Wayne Way; DVa|enUne; BO|in; VVoodburnR@hughes.ne± Cc: AJlocco, Marcia Wells Fargo Ground Water Rennediation System 'Tryon Stneet( Good morning, this is a follow-up email to the email that was sent last Friday (5/3/2013). At this time, | have not received a response or any comments concerning the email sent on Friday. My expectations are the following: 1\ ORC visitation — The Groundwater Remediation System is a Class I facility and should be receiving weekly visits at minimum. Z\ Flow meter —Alocation for the meter should have been determined. Pricing and ordering ofthe meter should be underway. 3) Bypass —The facility should be actively working on rerouting the pipes from SP3 and removing the bypass valves. 4\ pH rnonitoring—ECSshqu|d be working towards obtaining the required Field Lab Certification or providing documentation that they are properly certified, The remaining four points that were listed in the previous email are important as well. All involved parties should be working towards addressing all the points listed in the previous email. Atthis time, | plan tofinalize the inspection report onMonday. | have not received corresponds from ECSconcerning pHmonitoring, |annrequesting that ECS notify me whether they have a Field Lab Certification for monitoring of pH, and send me any records they may have for calibration ofthe pHmeter that has been used for pHmonitoring. | also requested lab analysis for the OMRsfrom January 2O12topresent. |f|have not received the data byTuesday, the inspection report will be finalized without the information, and it will be noted the permnittee was unable orunwilling to provide the necessary information. l Sincerely, Jeff Mitchell, Environmental Specialist Charlotte -Mecklenburg Storm Water Services Mecklenburg County Water Quality 700 North Tryon Street Charlotte, NC 28202 Office 704,336.3926 Cell 980.721.3565 Fax 704.336.4391 Jefferv.Mitchell@MecklenburgCountyNC.gav NA Consider the environment before printing this email or the attachment. Alt NC©ENR North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCory Charles Wakild, P.E. John E. Skvarla, III Governor Director Secretary January 23, 2013 Wells Fargo Bank, NA 550 South Tryon St, 30th Floor Mail Code D1086-300 Charlotte, North Carolina 28202 Attention: Rhonda Ballard Subject: Rescission of Notice of Violation — Monitoring Violations Tracking #: NOV-2012-MV-0131 Wells Fargo Tryon Street Groundwater Remediation WWTP NPDES Permit No. NC0088226 Mecklenburg County Dear Ms. Ballard: On January 7, 2013, this Office received an electronic response (via e-mail) to the above referenced Notice of Violation (NOV). The NOV was issued for failing to monitor flow weekly during the month of August 2012. Based on the electronic copies of amended DMRs for August 2012 through November 2012 submitted to the Division's Central Files this office is rescinding the above referenced Notice of Violation. If you have questions concerning this matter, please do not hesitate to contact Ms. Marcia Allocco at (704) 663-1699. Sincerely, Michael L. Parker Regional Supervisor Surface Water Protection cc: Point Source Branch R. Rozzelle, MCWQP MA Mooresville Regional office Location; 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: http://portal.ncdenr,org/web/wq An Equal Opportunity 1 Affirmative Action Employer— 30% Recycled}l ©°% Post Consumer paper N©rthCarolir a Naturally Aif NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, RE. Governor Director Dee Freeman Secretary December 21, 2012 Wells Fargo Bank, NA 550 South Tryon St, 30th Floor Mail Code D1086-300 Charlotte, North Carolina 28202 Attention: Rhonda Ballard Subject: Notice of Violation — Effluent Limitations Tracking #: NOV-2012-MV-0131 Wells Fargo Tryon Street Groundwater Remediation WWTP NPDES Permit No, NC0088226 Mecklenburg County Dear Ms. Ballard: A review of the August 2012 self -monitoring report for the subject facility revealed a violation of the following parameter at Outfall 001: Date Parameter Reported Value Permit Limit Week ending 8/4/12 Flow None Continuous monitoring (Reported weekly) Week ending 8/11/12 Flow None Continuous monitoring (Reported weekly) Week ending 8/18/12 Flovv None Continuous monitoring (Reported weekly) Week ending 8/25/12 Flow None Continuous monitoring (Reported weekly) Remedial actions, if not already implemented, should be taken to correct the noted any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent (SOC). If you have questions concerning this matter or to apply for a SOC, please do not hesitate to contact Ms. Marcia Allocco at (704) 235-2204. Sincerely, VV Marcia Allocco Surface Water Protection Acting Regional Supervisor cc: Point Source Branch R. Rozzelle, MCWQP MA Mooresville Regional Office Location: 610 East Center Ave:, Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: http:I/portal,ncdenrorg/web/wq An Equal Opportunity Affirmative Action Employer 30% Recycledfl 0% Post Consumer paper NOAhCarolina Naturally NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakiid, P.E. Governor Director Dee Freeman Secretary December 17, 2012 Wells Fargo Bank, NA 550 South Tryon St, 30th Floor Mail Code D1086-300 Charlotte, North Carolina 28202 Attention: Rhonda Ballard Mr. Roger Smith ECS Carolinas, LLP 8702 Red Oak Boulevard, Suite A Charlotte, North Carolina 28217 Subject: Discharge Monitoring Report Submission Wells Fargo - Duke Energy Center Dewatering System NPDES Permit No. NC0088226 Mecklenburg County Dear Ms. Ballard and Mr. Smith: This correspondence is to review the Discharge Monitoring Report (DMR) submission requirements under NC0088226. Historically, ECS Carolinas,. LLP has submitted one original and one copy of the relevant DMRs to the Division's Central files as required by your NPDES permit. ECS Carolinas, LLP has also been providing a courtesy paper copy to John Lesley of the Mooresville Regional office along with an electronic copy to Bob Sledge of the NPDES permitting group. It is our understanding that John Lesley of this office previously contacted ECS Carolinas, LLP personnel to communicate that the two copies sent to the Division's Central files are the only copies required by the division. This was done as a cost -savings effort for Wells Fargo Bank, NA because the copy provided to this office is recycled; our official copy comes the Division's Central files (one of your submitted copies is kept in Raleigh and the other forwarded to staff in this office). Mr. Lesley has since retired and therefore we are formalizing our correspondence to you regarding the required reporting (courtesy copies not required). If you have questions concerning this matter, please do not hesitate to contact me at (704) 235-2204 or marcia.allocco@ncdenr.gov. Sincerely, Marcia Allocco, MS Senior Environmental Specialist Surface Water Protection Point Source Branch — Bob Sledge Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: http://portal.ncdenr.org/web/wq N©rthCarolina Naturally An Equal Opportunity t Affirmative Action Employer — 30% Recycled/10% Pm! Consumer paper NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Chharles Wakild, P.E. Governor Director Dee Freeman Secretary Wellls Fargo Bank, NA 550 South Tryon St, 30th Floor Mail Code D1086-300 Charlotte, North Carolina 28202 Attention: Rhonda Ballard Subject: Dear Ms. Ballard: August 16, 2012 Notice of Violation — Monitoring Violations Tracking #: NOV-2012-MV-0073 Wells Fargo - Duke Energy Center Dewatering System NPDES Permit No. NC0088226 Mecklenburg County A review of the May 2012 self -monitoring report for the subject facility revealed a violation of the following parameter at Outfall 001: Date Parameter Reported Value Monitoring Requirement 5/12 Chloroform Not Sampled Monthly Sampling 5/12 Tetrachloroethene Not Sampled Monthly Sampling 5/12 Trichloroethene Not Sampled Monthly Sampling Remedial actions, if not already implemented, should be taken to correct any problems. Since the comments section on the reverse of the relevant Discharge Monitoring Report provided an explanation for the noted effluent limit violation, a response to this notice is not required; however, should you have additional information concerning the violations or comments which you wish to present, please submit them to the attention of Ms. Marcia Allocco. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Ms. Marcia Allocco of this Office for additional information. Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Internet: http://portal.ncdenr,org/web/wq NOirthCarolina tura!!ij An Equal Opportunity 1 Affirmative Action Employer — 30% Recycled/10% Post Consumer paper Wells Fargo — Duke Energy Center �PTage Two iV OV-2012-MV-0O /^7 3 If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at (704) 663-1699. Sincerely, Robert B. Krebs Surface Water Protection Regional Supervisor cc: Point Source Branch Ron Roach, Childress Klien Properties Rusty Rozzelle, MCWQP RBK �M.r1►�.ww..r.r. NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Chharles Wakild, RE. Governor Director Dee Freeman Secretary Well's Fargo Bank, NA 550 South Tryon St, 30th Floor Mail Code D1086-300 Charlotte, North Carolina 28202 Attention: Rhonda Ballard Subject: Dear Ms. Ballard: August 7, 2012 Notice of Violation — Monitoring Violations Tracking #: NOV-2012-MV-0065 Wells Fargo - Duke Energy Center Dewatering System NPDES Permit No. NC0088226 Mecklenburg County A review of the April 2012 self -monitoring report for the subject facitity revealed a violation of the following parameter at Outfall 001: Date Parameter Reported Value Monitoring Requirement 4/26/12 Chloroform Not Sampled Monthly Sampling 4/26/12 Tetrachloroethene Not Sampled Monthly Sampling 4/26/12 Trichloroethene Not Sampled Monthly Sampling Remedial actions, if not already implemented, should be taken to correct any problems. Since the comments section on the reverse of the relevant Discharge Monitoring Report provided an explanation for the noted effluent limit violation, a response to this notice is not required; however, should you have additional information concerning the violations or comments which you wish to present, please submit them to the attention of Ms. Marcia Allocco. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Ms. Marcia Allocco of this Office for additional information. Moxresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 P hoe: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 In tenet http://portal.ncdenr.org/web/wq NoohCarolina An Eival Opportunity \ Affirmative Action Employer — 30% Recycled/10% Post Consumer paper Wells Fargo — Duke Energy Center Page Two N©V-2012-MV-0065 If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at (704) 663-1699. Sincerely, Robert B. Krebs Surface Water Protection Regional Supervisor cc: Point Source Branch Ron Roach, Childress Klien Properties Rusty Rozzelle, MCWQP RBK Beverly Eaves Perdue Governor A A FCDENR North Carolina Department of Environment and Natural Division of Water Quality Charles Wakild, P. E. Director Ms. Ronda Ballard, LEED AP Vice President, Regional Property Manager Wells Fargo Bank, NA 550 South Tryon St., 30 Floor Mail Code D1086-300 Charlotte, NC 28202 VF: Q tTER ouALiTy Resources,;) st c"rloN MQORRE u3 i.t.E REGIONAL OFFICE Dee Freeman Secretary March 29, 2012 System: Tryon Street Groundwater Remediation Facility (Mecklenburg County) Classification: Grade 1 Physical Chemical System Subject: Designation of ORC and Backup ORC for Physical / Chemical Permit: NC0088226 Dear Ms. Ballard: The Water Pollution Control System Certification Commission has classified the subject facility as a Grade 1 Physical Chemical Pollution Control Treatment System based upon your permit, the Water Pollution Control System Certification Commission Rules 15A NCAC 8G .0306 (a). In accordance with 15A NCAC 8G .0201 and your permit, you must designate an Operator in Responsible Charge (ORC) and Back -Up Operator who has a current physical chemical certification of the appropriate level. Your facility requires a Grade 1 or higher Physical Chemical Treatment Plant Operator in Responsible Charge and Grade 1 or higher Back -Up Operator. Failure to designate a properly certified operator and back-up operator constitutes a violation of the permit issued for this facility. Our records indicate that this facility does not have a certified Physical Chemical Grade 1 operator as ORC and Backup designated at this time. An ORC and a Backup ORC with the required certification must be designated within 120 of receiving notice of the classification of this system. Enclosed is a new designation form. Please complete this designation form and submit it to the Technical Assistance and Certification. Unit. If individuals managing this system do not have a Physical Chemical Grade I certification then they must complete a Commission approved school and take the state's certification examination. Contact NCAWWA/WEA (919) 784-9030 or Laws and Company (888) 793-6266 or your local Cornmunity College. If you have any questions concerning this facility classification and ORC requirement, please reference to our website (http://portal.ncdenr.org/web/wq/admin/tac) and search under "Wastewater 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St, Raleigh, North Carolina 27604 Phone: 9194807.63001 FAX 919407.6492 Internet :lh t myreterqualilv.om An Equal Opportunity t Atirmratrve Action Employer Oil_ or't -1Caroiina limy Rules" or call 919-733-0026 ext 341. Sincerely, es Pugh, Educatiofi and Training Specialist 'cal Assistance and Certification Unit cc: Central Files TAC Files A77N:Jeff Mitchell Division ofWater Quality lO17Mail Service Center Raleigh, NC27699'I617 RE: Project: Duke Energy Center — Wells Fargo, Monthly DK8R NPDE3Permit No. NCO8O8226 Delegation of Authority Dear Mr. Mitchell, Corporate Properties Group MAC D1086-300 550 South Tryon Street, sih Floor Charlotte, mcxoaou iUN 9013 U�` 7,�� MOOR"", - On behalf of Wells Fargo Bank, (the Pennktee)weare delegating signing authority mxthe position of 'Chief Engineer' of the Duke Energy Center of Childress Klein Properties for DIVIR's and other documentation required byNPD3Permit No. NCO08Q2Z6. The position nf'Chief Engineer' shall hereby beknown osthe authorized representative for these matters. |naddition there has been achange inthe PemmitteeOwner/Office Name. Please remove Rhonda Ballard as the Permitee Owner and add Suzanne Fountain. Si' e Title V1,, [c Ron Roach Gary Smith Jim Patterson Together we'li go far Wells Fargo Bank, NA EF.:, QUALITY CDENR North Carolina Department of Environment and Natural Resources,,..., Division of Water Quality OOEGIONAL OFFICE Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman Governor Director Secretary Ms. Ronda Ballard, LEED AP Vice President, Regional Property Manager Wells Fargo Bank, NA 550 South Tryon St., 30 Floor Mail Code D1086-300 Charlotte, NC 28202 March 29, 2012 System: Tryon Street Groundwater Remediation Facility (Mecklenburg County) Classification: Grade 1 Physical Chemical System Subject: Designation of ORC and Backup ORC for Physical / Chemical Permit: NC0088226 Dear Ms. Ballard: The Water Pollution Control System Certification Commission has classified the subject facility as a Grade 1 Physical Chemical Pollution Control Treatment System based upon your pennit, the Water Pollution Control System Certification Commission Rules 15A NCAC 8G .0306 (a). In accordance with 15A NCAC 8G .0201 and your permit, you must designate an Operator in Responsible Charge (ORC) and Back -Up Operator who has a current physical chemical certification of the appropriate level. Your facility requires a Grade 1 or higher Physical Chemical Treatment Plant Operator in Responsible Charge and Grade I or higher Back -Up Operator. Failure to designate a properly certified operator and back-up operator constitutes a violation of the permit issued for this facility. Our records indicate that this facility does not have a certified Physical Chemical Grade 1 operator as ORC and Backup designated at this time. An ORC and a Backup ORC with the required certification must be designated within 120 of receiving notice of the classification of this system. Enclosed is a new designation form. Please complete this designation form and submit it to the Technical Assistance and Certification Unit. If individuals managing this system do not have a Physical Chemical Grade I certification then they must complete a Commission approved school and take the state's certification examination. Contact NCAWWA/WEA (919) 784-9030 or Laws and Company (888) 793-6266 or your local Community College. If you have any questions concerning this facility classification and ORC requirement, please reference to our website (http://portal.ncdenr.org/web/wq/admin/tacu) and search under "Wastewater 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St Raleigh, North Carolina 27604 Phone: 919-807-6300 \ FAX: 919-807-6492 Internet www.ncwaterouality.org One. NorthCaroli„na „Naturally M Equal Opportunity \ Affirmative Action Empbyer Rules" or call 919-733-0026 ext 341. Sincerely, es Pugh, Education and Training Specialist Technical Assistance and Certification Unit cc: Central Files TAC Files NCDENR North Carolina Department of Environment and Natural. Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P.E. Governor Director March 13, 201 Mr. Chris Sutherland ECS Carolinas 8702 Red Oak Blvd. Suite A Charlotte, North Carolina 28217 NZ©)Z- YYIh • 00)) Notice of Deficiency Monthly Monitoring Reports Wells Fargo Bank — Duke Energy Center NPDES Permit No. NC0088226 Mecklenburg County, NC Dear Mr. Sutherland: Dee Freeman Secretary A review of the December 2011 Discharge Monitoring Report (DMR) revealed discrepancies on the report foiiu. Be advised that improper reporting is a violation of NPDES Pei mit conditions and may be subject to enforcement action, including civil penalty assessment, by the Division of Water Quality. The following problems were found on the DMR for December 2011: * Quarterly monitoring for copper was added to the peiniit effective October 1, 2011. Quarterly monitoring for copper should be conducted concurrently with the quarterly monitoring for chronic toxicity. The monitoring was not reported as required in December 2011. * Be advised that copper monitoring is required in. March 2012. Failure to monitor for copper per permit requirements may be assessed civil penalties. If the copper analysis was conducted in December 2011, an amended December 2011 Discharge Monitoring Report must be submitted by no later than March 25, 2011. Send the amended report to Central Files, Division of Water Quality, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617. A copy should also be sent to this office to the address at the bottom of this correspondence. Cc: Central Files Bob Sledge, Point Source Compliance Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 2 11 Phone: (704) 663-1699 4 Fax: (704) 663-6040 i Customer Service: Internet: httpa/portaLngdenr.org/weblwq Sincerely, Robert B. Krebs Surface Water Protection Section Regional Supervisor 77-623-6748 Chle NorthCaroli.na Naturally An Equal Opportunity Alhir PI Beverly Eaves Perdue Governor ALLEN HOLLOWAY WACHOVIA BANK NA 301 S COLLEGE ST STE 2800 CHARLOTTE NC 28202 SUBJECT: Dear Mr. Holloway: North Carolina Departmt of Environment and Natural Resources Division of Water Quality Coleen H. Suins Dee Freeman Director Secretary May 11, 2011 Payment Acknowledgment Civil Penalty Assessment Wachovia Tryon Street BTS Permit Number: NC0088226 Case Number: TX-2011-0002 Mecklenburg County RECEIVED EMS OF WATER QUALITY MA“ 2 Z011 • SECTION MOORE:6 iLLE REGIONAL OFFICE This letter is to acknowledge receipt of check number 3490 in the amount of $2,069.26 received from you dated May 9, 2011. 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 Permits. If you have any questions, please call Robert L Sledge at 919-807-6398. Sincerely, ovonah Weeden cc: Central Files DWQ:,,MoaresyiapacgioridlOffie6Superyjsor 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Locatw: 512 N. Salisbury St, Raleigh, North Carolina 27604 Phone: 919-807-6300 \ FAX 919-80'7-64921 Customer Service: 1-877-623-5748 Internet; www,ncyvaterquality:org An Equal Opportunity \ Affirmative Action Eat -Inlayer . One Nort Carolina titieff NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director April 1.9, 2011 CERTIFIED MAIL: 7007 1490 0004 5533 5748 RETURN RECEIPT REQUESTED Mr. Chris Sutherland ECS Carolinas 8702 Red Oak Blvd, Suite A Charlotte, North Carolina 28217 Dee Freeman Secretary RECEIVED DIVISION OF • ATER QUALITY APR 2 1 20r1 SWF' SECTION MODNESVILLE REGIONAL OFFICE SUBJECT: Assessment of Civil Penalty for Violations of NC General Statute 143-215.1(a)(6) and NPDES Permit No. NC0088226 Wachovia Tryon St. BTS Mecklenburg County TX-2011-0002 Dear Mr. Sutherland: This letter transmits a Civil Penalty assessment aaainst Wachovia Tryon St. BTS in the amount of $ 0 ($ 2.' (?7 civil penalty + $ 6 q/.6 enforcement costs). This assessment is based upon the following facts. A review of the facility's toxicity self -monitoring data from February 2011 has been conducted. The review has shown Wachovia Tryon St. BTS to be in violation of the 90 % chronic toxicity effluent discharge limitation found in NPDES Permit No. NC0088226. The facility's toxicity self -monitoring reports for December 2010 through February 2011 revealed the following effluent toxicity permit limit violations. December 14, 2010 January 25, 2011 January 25, 2011 January 25, 2011 February 22, 2011 Fail (chronic P/F) 63.6% % 7 day chronic value, not run for compliance >100% 7 day chronic value, not run for compliance 63.6% 7 day chronic value, non -compliant 92.5% 7 day chronic value, compliant Based upon the above fact(s), I conclude as a matter of law that Wachovia Tryon St. BTS violated the terms, conditions or requirements of NPDES Permit No. NC0061182 and N.C.G.S 143-215.1(a)(6) in the manner and extent shown above. A civil penalty in accordance with the maximum established by N.C.G.S. 143-215.6A(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). Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 I FAX 919-743-8517 t Customer Service: 1-877-623-6748 Internet: http://h2mnrstate.nc,usiesbi One North Carolina aturally An Equal Opportunity I Affirmative Action Employer 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, I, Cindy Moore, Supervisor, Aquatic Toxicology Unit, hereby make the following civil penalty assessment against Wachovia Tryon St. BTS. For of violation(s) of G.S. 143-215.1(a)(6) and NPDES Permit No. NCO 88226, by discharging waste into the waters of the State in violation of the facility's permit effluent limit for chronic toxicity for June 15, 2010. For of violation(s) of G.S. 143-215.1(a)(6) and NPDES Permit o. NC0088226, by discharging waste into the waters of the State in violation of the facility's permit effluent limit for chronic toxicity for September 28, 2010. 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 Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are: (1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the 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. Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-84001 FAX: 919-743-8517 1 Customer Service: 1-877-623-6748 Internet: http;//h2o.enr. state.nousiesb/ One NorthCarolina Naturally An Equal Opportunity \ Affirmative Action Employer Within thirty days receipt of this notice, you must do one of the following: 1. Submit payment of the penalty: Payment should be made directly to the Department of Environment and Natural Resources (do not include waiver form). Payment of the penalty will not foreclose enforcement action for any continuing or new violation(s). Please submit payment to the attention of: Point Source 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 inform 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 further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty Remissions (Committee). Please be advised that the Committee cannot consider infoimation that was not part of the original remission request considered by the Director. Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 \ FAX 919-743-8517 \ Customer Service: 1-877-623-6748 Internet http/h2o,enrstate.nc.usiesb/ One NorthCarolina Naturally An Equal Opportunity Affirmative Action Employer Therefore, it is very important that you prepare a complete and thorough statement in support of your request for remission. In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties Waiver of Right to an Administrative Hearing and Stipulation of Facts" form within thirty (30) days of receipt of this notice. The Division of Water Quality also requests that you complete and submit the enclosed "Justification for Remission Request." Both forms should be submitted to the following address: Environmental Sciences Section Division of Water Quality 1621 Mail Service Center Raleigh, NC 27699-1621 OR 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. You must file the petition with the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state holidays. The original and one (1) copy of the petition must be filed with the Office of Administrative Hearings. The petition may be faxed - provided the original and one copy of the document is received in the 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 (919) 733-2698 Facsimile: (919) 733-3478 A copy of the petition must also be served on DENR as follows: Ms. Mary Penny Thompson, General Counsel Department of Environment and Natural Resources 1601 Mail Service Center Raleigh, NC 27699-1601 Please indicate the case number (as found on page one of this letter) on the petition. Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an 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. Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 FAX: 919-743-85171 Customer Service: 1-877-623-6748 Internet: http://h2o.enr.state.nc.us/esb/ NorthCarolina Naturally An Equal Opportunity 1 Affirmative Action Employer 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 919 743-8442 or Mr. John Giorgino at 919-743-8441. Date A 11ACHMENTS cc: Cindy Moore Supervisor, Aquatic Toxicology Unit s —Mooresville Regional Office w/attachments John Lesley- Mooresville Regional Office w/attachments Point Source Branch File w/attachments John Giorgino -Aquatic Toxicology Unit w/attachments Central Files w/attachments Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 1 FAX: 919-743-8517 I Customer Service: 1-877-623-6748 Internet http://h2o.enrstatemc.usiesb/ One NorthCarolina Naturally An Equal Opportunity I Affirmative Action Employer JUSTIFICATION FOR REMISSION REQUEST DWQ Case Number: TX-2011-0002 County: Mecklenburg Assessed Party: Wachovia Tryon St. BTS Permit No. (if applicable): NC0088226 Amount Assessed: $ Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation 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.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only when one or more of the following five factors applies. Please check each factor that you believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the factor applies (attach additional pages as needed). (a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document); (b) the violator promptly abated continuing environmental 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 or prepare for); (d) the violator had not been assessed civil penalties for any previous violations; (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i. e., explain how payment of the civil penalty will prevent you from performing the activities necessary to achieve compliance). EXPLANATION: rATE OF NORTH CAROLINA COUNTY OF MECKLENBURG IN THE MATTER OF ASSESSMENT OF CIVIL PENALTIES AGAINST WACHOVIA TRYON ST. BTS NPDES PERMIT NO, NC0088226 DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES ) WAIVER OF RIGHT TO AN ADMINISTRATIVE HEARING AND STIPULATION OF FACTS FILE NO. TX-2011-0002 Having been assessed civil penalties totaling for violation(s) as set forth in the assessment document of the Director of the Division of Water Quality dated , the undersigned, desiring to seek remission of the civil penalties, does hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be submitted to the Director of the Division of Water Quality within 30 days of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after 30 days from the receipt of the notice of assessment. This the day of , 2011. BY ADDRESS TELEPHONE NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director March 16, 2011 CERTIFIED MAIL: 7007 1490 5533 5519 RETURN RECEIPT REQUESTED Mr. Chris Sutherland ECS Carolinas. 8702 Red oak Blvd, Suite A Charlotte, North Carolina 28217 Subject: NOTICE OF VIOLATION Effluent Toxicity Testing NPDES Permit No. NC0088226 Wachovia Tryon St. BTS Mecklenburg County Dear Mr. Sutherland: Dee Freeman Secretary RECEIVED DlV1RI0 OF WATER QUALITY 18 SWin SECTION MOOREVILLEREGIONDAL OFFICE This is to inform you that a review of your toxicity self -monitoring report form for the month of January 2011 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), 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 addresses for submitting your Discharge Monitoring Reports (DMRs) 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 Mr. John Giorgino with this office at (919) 743-8441, cc: Sincerely, Cindy A. Moore Supervisor, Aquatic Toxicology Unit bs/ Mooresville Regional Office John Lesley/ Mooresville Regional Office Aquatic Toxicology Unit Central Files Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-84001 FAX: 919-743-85171 Customer Service: 1-877-623-6748 Internet: http:/Ih2o.enr.state.nc.us/esbl N orthC olina An Equal Opportunity \ Affirmative Action Employer 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 include all the toxicity testing and reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity testing requirement, please contact Mr. John Giorgino with the Aquatic Toxicology Unit at (919) 743-8401 or another Unit representative at the same number. > The permittee 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 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 Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 D Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days 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 Section 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 Section at (919) 743-8401 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 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, you may consider submitting your toxicity test results certified mail, return receipt requested to the Environmental Sciences Section. Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 \ FAX: 919-743-8517 \ Customer Service: 1-877-623-6748 Internet: http://h2o.enr,state.nc.usiesb/ One NorthCarolina Naturally An Equal Opportunity \ Affirmative Action Employer Ai* NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary February 23, 201 I CERTIFIED MAIL: 7007 1490 0004 5533 5434 RETURN RECEIPT REQUESTED Mr. Chris Sutherland ECS Carolinas. 8702 Red Oak Blvd, Suite A Charlotte, North Carolina 28217 Subject: NOTICE OF VIOLATION Effluent Toxicity Testing NPDES Permit No, NC0088226 Wachovia Tryon St. BTS Mecklenburg County Dear Mr, Sutherland: RECEIVED DIVISION OF WATER QUALITY FEB, 2 5 2011 StA/P SECTION MOORESVILLE REGIONAL OFFICE This is to inform you that a review of your toxicity self -monitoring report form for the month of December 2010 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), 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 addresses for submitting your Discharge Monitoring Reports (DMRs) 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 Mr. John Giorgino with this office at (919) 743-8441. CC: Sincerely, Cindy A. Moore Supervisor, Aquatic Toxicology Unit s/ Mooresville Regional Office John Lesley/ Mooresville Regional Office Aquatic Toxicology Unit Central Files Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 1 FAX 919-743-85171 Customer Service: 1-877-623-6748 Internet http://h2aenr,statenc.usiesb/ One NorthCarolina Naturally An Equal Opportunity !Affirmative Acton Employer 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 include all the toxicity testing and reporting requirements contained in your NPDES permit If you should have any questions about your toxicity testing requirement, please contact Mr. John Giorgino with the Aquatic Toxicology Unit at (919) 743-8401 or another Unit representative at the same number. > The permittee 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 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 Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 > Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days 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 Section 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 Section at (919) 743-8401 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 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, you may consider submitting your toxicity test results certified mail, return receipt requested to the Environmental Sciences Section, Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location; 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-84001 FAX: 919-743-85171 Customer Service: 1-877-623-6748 Internet: http://h2o,enr,state.nc.usiesb/ One . NorthCarolina Naturally An Equal Opportunity I Affirmative Action Employer North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Odeon H, Sullins Governor Director January 18, 2011 ALLEN HOLLOWAY, CONSTRUCTION MANAGER WACHOVIA BANK N A 301 S COLLEGE ST STE 2800 CHARLOTTE NC 28202 SUBJECT: Payment Acknowledgment Civil Penalty Assessment Wachovia Tryon Street BTS Permit Number: NC0088226 Case Number: TX-2010-0008 Mecklenburg County Dear Mr, Holloway: Dee Freeman Secretary RECEIVED DIVISION OF. WATER (DUALITY JAN 2 0 2011 SWF MOORESVILLE REGIONAL OFFICE This letter is to acknowledge receipt of check number 3455 in the amount of $2,069.26 received from you dated January 13, 2010. 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 Permits. If you have any questions, please call Robert L Sledge at 919-807-6398. cc: Central Files 1617 Mail Servic-e, Center, Raleigh, North Carolina 27009-1617 Location: 512 N, Salisbury St, Raleigh, North Carolina 27604 Phone: 919-807-6300 1 FAX: 919.-807-6492 ;Customer Service: 1-877-623-6748 Internet: www,ncwaterquality,org An Equal Opportunity Affirmative Action Employer one .N orth Carolina 712aturally NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor CERTIFIED MAIL: 7002 3150 0003 7052 4047 RETURN RECEIPT REQUESTED Mr. Roger A. Smith Wachovia Bank N.A. 8702 Red Oak Blvd, Charlotte, North Carolina 28217 Division of Water Quality Coleen H. Suns Dee Freeman Director Secretary RECEIVED DIVISION OF WATER QUALITY November 29, 2010 DEC 0 1 2010 SWP SECTION MOORESVILLE REGIONAL OFFICE SUBJECT: Assessment of Civil Penalty for Violations of NC General Statute 143-215.1(a)(6) and NPDES Permit No, NC0088226 Wachovia Tryon St, BTS Mecklenburg County TX 2010-0008 Dear Mr. Smith: This letter transmits a Civil Penalty assessment against Wachovia Tryon St, BTS in the amount of $ 2 C6'44 Z 0 0 0, G-6 civil penalty + $ 6.7 enforcement costs). This assessment is based upon the .following facts. A review of the facility's toxicity self -monitoring data from September has been conducted.' -File review has shown Wachovia Tryon St. BTS to be in violation of the 90 % chronic toxicity effluent discharge limitation found in NPDES Permit No, NC0088226. The facility's toxicity self -monitoring reports for June through September 2010 revealed the following effluent toxicity permit limit violations. June 15, 2010 July 27, 2010 August 24, 2010 September 28, 2010 Fail (chronic P/F)) 97,5 % (7 day chronic value) Compliant Invalid Test <30% (7 day chronic value) Non -Compliant Based upon the above fact(s), I conclude as a matter of law that Wachovia Tryon St. BTS violated the terms, conditions or requirements of NPDES Permit No. NC006.1182 and N.C.G.S 143-215.1(a)(6) in the manner and extent shown above, A civil penalty in accordance with the maximum established by N.C.G.S. 143-215.6A(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), Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location:4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 I FAX 919-743-8517 I Customer Service: 1-877-623-6748 Internet: http://h2o:enr,statemc:ustesbi One NorthCarolina aturally An Equal Opportunity Affirmative Action Employer 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, I, Cindy Moore, Supervisor, Aquatic Toxicology Unit, hereby make the 'following civil penalty assessment against Wachovia Tryon St. BTS. 3 ct' 2_6 For of violation(s) of G.S. 143-215.1(a)(6) and NPDES Permit No. NC0088226, by discharging waste into the waters of the State in violation of the facility's permit effluent limit for chronic toxicity for June 15, 2010. For of violation(s) of G.S. 143-215.1(a)(6) and NPDES Permit No, NC0088226, by discharging waste into the waters of the State in violation of the facility's permit effluent limit for chronic toxicity for September 28, 2() l 0. Enfircenient 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 Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are: (1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the 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 railing to comply with programs over which The Environmental Management Commission has regulatory authority; and (8) The cost to the State of the enforcement procedures. Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location:. 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 FAX: 919-743-8517 \ Customer Service: 1-877-623-6748 Internet: http://h2oenr:state.nc.usiesb/ One NorthCarolina atumlly Ar Equai Deporlunily Affirmntive Action Employer Within thirty days receipt of this notice, you most doone ufthe following: Submit payment of the penalty. Payment should bemade directly k/the DepartmentofEnvironment and Natural Resources (do not include wuker/orm). Payment ofthe penalty will riot foreclose enforcement action for any continuing or- new Please submit payment to the attention of, Point Source Branch Division ofWater Quality 1617Mai| Service Center Raleigh, North Carolina 27699-l6l7 OR 2. Submit written request for remission or mitigation including a detailed justification for such rcgomo1. ° Please heaware that urequest horremiosion is hmitedlo consideration o[<ho live factors listed below usthey may relate tothe reasonableness oF1hu amount o[the, Civil penalty oxocoed. Kcuucohng rconisxinu is riot the propel' procedure for contesting whether- the vin|adon(s)occurred or, the accuracy ofany oftke tuo\uu| statements contained in the civil penalty uoueyymentdooumcnt. Because o remission rrqocg k/rc6osco the option ufun administrative hearing, such urequest must be accompanied by uwaiver- ofYour- right k/mn administrative hearing and axUpu|adox and agreement that no factual or |cgu| issues are in dispute. P|oouu prepare udotuiled statement that establishes why you believe the civil penalty should be remitted, and submit itk)the Division ofWater Ouu|iiya1tbeuddn*oo listed below. In dct*co\iuiug whether ncnnixuioo request will be approved, the following factors uhuU be considered: one ovmore ofthe civil penalty assessment factors in G.S. |438'282.l(k)were wrongfully applied Nthe detriment ofthe petitioner; the violator promptly abated continuing environmental damage resulting from the violation; the violation was inadvertent or- uncmvko[unaccident; the violator had been assessed civil penalties for any previous violations; payment of the civil penalty will prevent payment for the remaining necessary remedial actions. Please note that all evidence presented in auppoU Of your request for remission must be submitted in `v,hiog. The Director o[the Division ofthe Division ofWater Quality will review your- cvidcnccand in[unn you ofhis decision in the mmttezofyour remission requcci. The response will provide details regarding the cuxc Status, directions |br puymen(, and provision for further appeal Of the penalty to the Fnvirnnmcn\o| Muna0crncntCummisxiox`s Committee onCivil Penalty Remissions (CommiUce). Please boadvised dmlthe Cnnimic1ccCannot consider ixk/rnm|ionthat was not part of the original remission request considered by the Director� [hco6,rc,hisvery Important that You prepare ucomplete and thorough statement insupport ofyourrequest for remission, Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina x7s99-1sz1 LD�auon: 4401Reedy Creek Road, Raleigh, North Carolina 27V07 Phone: 919-743-8wV0\FAX: o1S�43-851r�Customer Service: 1'877-623-6748 mtemetomp://h2uwn,,mmtuncusimb/ One NorthCarolina ;Vatural4i An Equal Opportunity � Affirm3tive Action Efnpioyer 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) days 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: Environmental Sciences Section Division of Water Quality 1621 Mail Service Center Raleigh, NC 27699-1621 File a petition for an admit OR ive hcaring with the C)ffice of Administrative Hearings: ou wish to contest any statement in the attached assessment document you must file a petition for an administrative You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with the Office of Administrative Hearings within thirty (30) clays rrfreceipt of this notice. A petition is considered filed when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state holidays. The original and one (1) copy of the petition must be filed with the Office of Administrative Hearings. The petition may be faxed - provided the original and one copy of the document is received in the 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 (919) 733-2698 Facsit A copy of the petition tnust also be served on DENR as follows: Please indicate the case number Failure to exercise one of the opti date/time received stamp (not a po collection of the penalty through a that occur after the review period o e: (919 733-3478 Ms. Mary Penny Thompson, General Counsel Department of Environment and Natural Resources 1601 Mail Service Center Raleigh, NC 27699-1601 found on page one of this letter) on the petition. s above within thirty (30) days of receipt ofthis letter, as evidenced by an internal ark), will result in this being referred to the Attorney General's Office for action. Please he advised that additional penalties may be assessed for violations is assessment. Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-84091 FAX: 919-743.85171 Customer Service: 1.877--623.6748 Internet: http:llh2o.enr.state,nc.uslesbl One NortliCarolina 7atturally rOnpertunity? bdilrmativr Action Please headvised that any continuing vio|u,ion(o)may be the subject ofunew enforcement action, including an additional penalty. If you have any questions about this civil penalty assessment, please contact me at 919 743-8442 or Mr. John (]iorginng9l9-743-844l. CiodyMkx)nc Supervisor, &quutioTouico|ogyUni ATTACHMENTS cc —Mooresville Regional Office w/utuachmcn(o xviUoRegional Offiuexya1ha bmun\n Point Source Branch File wymttaobnncn\s John Giorgino-Aquatic Toxicology Unit u/atluohmctits Central Files nv/uttnchments Environmental Sciences Section 1,621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401Reedy Creek Road, Raleigh,North Carolina 2760r Phone: o/O'743-8408\FAX: V19-74J-8517\Cvnm=e,Service: 1-87r�2J-67*8 NorthCarolina Ali Equa�l Opportunily � Affirmative Action Employer STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES COUNTY OF MECKLENBURG ) ) ) ) ) ) ) ) ) FILE NO. IN THE MATTER OF ASSESSMENT OF CIVIL PENALTIES AGAINST WACHOVIA TRYON ST. BTS NPDES PERMIT NO. NC0088226 WAIVER OF RIGHT TO AN ADMINISTRATIVE HEARING AND STIPULATION OF FACTS TX-2010-0008 Having been assessed civil penalties totaling for violation(s) as set forth in the assessment document of the Director of the Division of Water Quality dated , the undersigned, desiring to seek remission of the civil penalties, does hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be submitted to the Director of the Division of Water Quality within 30 days of receipt of the notice of assessment, No new evidence in support of a remission request will be allowed after 30 days from -the receipt of the notice of assessment. This the day of , 2010. BY ADDRESS EPHONE JUSTIFICATION FOR REMISSION REQUEST DWQ Case Number: TX-2010-0008 County: Mecklenburg Assessed Party: Wachovia Tryon St. BTS Permit No. (if applicable): NC0088226 Amount Assessed: S Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation 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 oithe 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 1\1.C.G.S § 143B-282.1(c), remission of a civil penalty may be granted only when one or more of the following five factors applies. Please check each factor that you believe applies to your case and provide a detailed. explanation, including copies of supporting documents, as to why the factor applies (attach additional pages as needed). (a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in the civii penalty assessment docutnent); (b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the steps that you took to correct the violation and prevent futuie 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 or prepare for); (d) the violator had not been assessed civil penalties for any previous violations; (e) payment of the civil penalty will prevent payment tor the remainini2, neccssary remedial actions (i.e„ explain how payment of the civil penalty will prevent you the activities necessary to achieve compliance). EXPLANATION: Beverly Eaves Perdue Governor ALLEN HOLLOWAY WACH©VIA BANK 301 S COLLEGE ST STE 2800 CHARLOTTE NC 28202 North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director January 18, 2011 SUBJECT: Payment Acknowledgment Civil Penalty Assessment Wachovia Tryon Street BTS Permit Number: NC0088226 Case Number: LT-2010-0003 Mecklenburg County Dear Mr. Holloway: Dee Freeman Secretary RECEIVED V ION OF WATER QUALITY JAN 2 0 2011 SWP SEC t iON MOORESVILLE REGIONAL OFFICE This letter is to acknowledge receipt of check number 3454 in the amount of $1,069.26 received from you dated. January 13, 2011. 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 Permits. If you have any questions, please call Robert L Sledge at 919-807-6398. cc: D Central Files p rvisor 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Saishut St. Raleigh, North Carolina 27604 Phone: 919-807-6300! FAX: 9'19-807-6492 !Customer Service: • Internet: www.ncwaterquaiity.org An Equal Opportunity i Affirmative Action Employer Sincerely, ovonah Weeden 77-623-5748 One NorthCafoina !'atiira//j Beverly Eaves Perdue Governor NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Dee Freeman Director Secretary December 30, 2010 CERTIFIED MAIL: 7002 3150 0003 7052 3972 RETURN RECEIPT REQUESTED Mr. Chris Sutherland ECS Carolinas 8702 Red Oak Blvd. Suite A Charlotte, North Carolina 28217 SUBJECT: Civil Penalty Assessment for Reporting Requirement Violations NPDES Permit No. NC0088226 Wachovia Tryon St. BTS Mecklenburg County LT 2010-000 5 Dear Mr. Sutherland: RECEIVED DIVISION OF WATER QUALITY JAN 0 6 2011 SWpF-FOTiON MOORES ViLLE REGIONAL OFFICE This letter transmits a Civil Penalty assessed against Wachovia Tryon St. BTS in the amount of $ ($ MOt -08vil penalty + enforcement costs). This assessment is based upon the following facts: the September and October 2010 toxicity self -monitoring report forms were not filed with the Environmental Sciences Section of the Division of Water Quality within the thirty (30) day reporting period in accordance with the monitoring and reporting requirements contained in your NPDES Permit. Notices of Violations dated December 24, 2010 and December 30, 2010 were sent to the facility by certified mail for failure to report the September and October 2010 toxicity self -monitoring report forms to our office within the reporting deadline. Both Notices stated, "Note that late/non-reporting of toxicity self -monitoring data subjects you to the enforcement authority of the Division." Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 I FAX: 919-743-8517 \ Customer Service: 1-877-623-6748 Internet: http://h2o.enr,state,nc.uslesbl One orthCarolina Naturally An Equal Opportunity \Affirmative Action Employer Based upon the above fact(s), I conclude as a matter of law that Wachovia Tryon St. BTS violated or failed to act in accordance with the requirements of G.S. 143-215.65. A civil penalty of not more than $10,000.00 may be assessed against a person who fails to file, submit or make available any documents, data or reports required by G.S. 143-215.65. The State's enforcement costs in this matter may be assessed against Wachovia Tryon St. BTS pursuant to NCGS 143-215.3(a)(9) and NCGS 143B-282.1(b)(8). Based upon the above fact(s) and the conclusions of law, and pursuant to the authority delegated to me by the Secretary of the Department of Environment and Natural Resources, I hereby make the following civil penalty assessment against Wachovia Tryon St. BTS / it96q- 762 For this second violation of NCGS 143-215.65 and NPDES Permit No. NC0028614, for failing to timely submit Aquatic Toxicity Self -Monitoring Report Forms for the months of September and October 2010 to the Environmental Sciences Section. Enforcement Costs TOTAL CIVIL PENALTY Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are: (1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; (2) The duration and gravity of the violation; (3) The effect on ground or surface water quantity or quality or on air quality; (4) The cost of rectifying the damage; (5) The amount of money saved by noncompliance; (6) Whether the violation was committed willfully or intentionally; (7) The prior record of the violator in complying or failing to comply with programs over which The Environmental Management Commission has regulatory authority; and (8) The cost to the State of the enforcement procedures. Within thirty days receipt of this notice, you must do one of the following: 1. Submit payment of the penalty: Payment should be made directly to the Department of Environment and Natural Resources (do not include waiver form). Payment of the penalty will not foreclose enforcement action for any continuing or new violation(s). Please submit payment to the attention of: Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 I FAX 919-743-8517 I Customer Service: 1-877-623-6748 Internet: http://h2o.enr.state.no.usiesb/ One NorthCarolina Naturally An Equal Opportunity \Affirmative Action Employer Point Source Branch Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 OR 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 inform 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 further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the original remission request considered by the Director. Therefore, it is very important that you prepare a complete and thorough statement in support of your request for remission. In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties Waiver of Right to an Administrative Hearing and Stipulation of Facts" form within thirty (30) days Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 1 FAX 919-743-8517 \ Customer Service: 1-877-623-6748 Internet http://h2o,enr.state,nc,usiesb/ One NorthCarolina Naturally An Equal Opportunity Affirmative Action Employer 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: Environmental Sciences Section Division of Water Quality c/o John Giorgino 1621 Mail Service Center Raleigh, NC 27699-1621 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. You must file the petition with the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state holidays. The original and one (1) copy of the petition must be filed with the Office of Administrative Hearings. The petition may be faxed - provided the original and one copy of the document is received in the 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 (919) 733-2698 Facsimile: (919) 733-3478 A copy of the petition must also be served on DENR as follows: Ms. Mary Penny Thompson, General Counsel Department of Environment and Natural Resources 1601 Mail Service Center Raleigh, NC 27699-1601 Please indicate the case number (as found on page one of this letter) on the petition. Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal date/time received stamp (not a postmark), will result in this matter being referred to the Attorney Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-84001 FAX: 919-743-8517 \ Customer Service: 1,877-623-6748 Internet: http://h2oenr,statencws/esb/ One NorthCarolina Naturally An Equal Opportunity \ Affirmative Action Enrip 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 Mr. John Giorgino at (919) 743-8441. ATTACHMENTS CC: Sincerely., Cindy Moore Supervisor, Aquatic Toxicology Unit J. Mooresville Regional Office w/attachrnents John Lesley- Mooresville Regional Office w/attachments Point Source Branch File w/attachments Aquatic Toxicology Unit File w/attachments Central Files w/attachments Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 I FAX: 919-743-8517 I Customer Service: 1-877-623-6748 Internet: http://h2o,enr,state.nc,us/esb/ One NorthCarolina aturally An Equal Opportunity I Affirmative Action Employer Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-84001 FAX: 919-743-85171 Customer Service: 1-877-623-6748 Internet: http:llh2o.enr.state.nc.uslesbl N©rthCarolina Naturally An Equal Opportunity \ Affirmative Action Employer F NORTH CAROLINA OUNTY OF MECKLENBURG IN THE MATTER OF ASSESSMENT OF CIVIL PENALTIES AGAINST NCDOT T-77 REST AREA NPDES PERMIT NO. NC0028614 DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES WAIVER OF RIGHT TO AN ADMINISTRATIVE HEARING AND STIPULATION OF FACTS FILE NO. LT--2010-0003 Having been assessed civil penalties totaling for violation(s) as set forth in the assessment document of the Director of the Division of Water Quality dated , the undersigned, desiring to seek remission of the civil penalties, does hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be submitted to the Director of the Division of Water Quality within 30 days of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after 30 days from the receipt of the notice of assessment. This the day of , 2011.. BY ADDRESS TELEPHONE JUSTIFICATION FOR REMISSION REQUEST DWQ Case Number: LT-2010-0003 County: Mecklenburg Assessed Party: Wachovia Tryon St. BTS Permit No. (if applicable): NC0088226 Amount Assessed: $ Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation 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.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only when one or more of the following five factors applies. Please check each factor that you believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the factor applies (attach additional pages as needed). (a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document); (b) the violator promptly abated continuing environmental 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 or prepare for); (d) the violator had not been assessed civil penalties for any previous violations; (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain how payment of the civil penalty will prevent you from per orming the activities necessary to achieve compliance). EXPLANATION: Beverly Eaves Perdue Governor ar�rr� NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H, Sullins Dee Freeman Director Secretary December 30, 2010 CERTIFIED MAIL RETURN RECEIPT REQUESTED: 7002 3150 0003 7052 3965 Mr. Chris Sutherland ECS Carolinas 8702 Red Oak Blvd. Suite A Charlotte, NC 28217 Subject: Dear Mr. Southerland: NOTICE OF VIOLATION Effluent Toxicity Testing NPDES Permit No. NC0088226 Wachovia Tryon St. BTS Mecklenburg County RECEIVED DIV!SlON OF WATER QUALITY JAN 0 6 2011 (ION GIONAL OFFICE This is to inform you that the Environmental Sciences Section has not received your regular quarterly toxicity self -monitoring report form for the months of September or October 2010.. This is in violation of Title 15A of the North Carolina Administrative Code, Chapter 2, Subchapter 2B, Section .0506 (a)(1)(A) which states that "monthly monitoring reports shall be filed no later than 30 days after the end of the reporting period for which the report was made." Please remember that reporting of toxicity self -monitoring data is a dual requirement. Toxicity test results must be entered on your Discharge Monitoring Report and the Toxicity Reporting Form (AT Report Form). The AT report form must be submitted to: DWQ/ESS, 1621 Mail Service Center, Raleigh NC 27699-1621 within the required time frame. Your NPDES permit requires you to submit an Aquatic Toxicity Self -Monitoring Form to this office during a month in which toxicity testing is required, regardless of whether a discharge occurs from the Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 \ FAX: 919-743-85171 Customer Service: 1-877-623-6748 Internet: http:l/h2o.enr,state.nc.us/esbl One Norti Caro .'na An Equal opportunity 1 Affirmative Action Employer facility. Please ensure that AT test forms labeled "No Flow" are sent to this office during months when no discharge occurs and the facility is required to perform toxicity testing. This is the second non -reporting violation in two months, which subjects the facility to the enforcement authority of the Division. Attached to this Notice, you will find a summary of important toxicity monitoring and reporting requirements. Please read this summary. If you have any questions concerning this Notice, please contact Mr. John Giorgino with the Aquatic Toxicology Unit at (919) 743-8441. Sincerely, Cindy Moore Supervisor, Aquatic Toxicology Unit ooresville Regional Office John Lesley- Mooresville Regional Office Aquatic Toxicology Unit Central Files Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Ready Creek Road, Raleigh, North Carolina 27607 Phone: 919.743-84001 FAX: 919-743-8517 \ Customer Service: 1-877-623-6748 Internet: httpalh2o.enr.state,nc.usiesb/ NorthCarol_ina 7Vaturaa/4y An Equal Opportunity 1 Affirmative Action Employer 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 include all the toxicity testing and reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity testing requirement, please contact Mr. John Giorgino with the Aquatic Toxicology Unit at (919) 743-8401 or another Unit representative at the same number. > The permittee 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 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 Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 • Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days 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 Section 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 Section at (919) 743-8401 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 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, you may consider submitting your toxicity test results certified mail, return receipt requested to the Environmental Sciences Section, Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 I FAX: 919-743-8517 \ Customer Service: 1-877-623-6748 Internet: http://h2o.enrstate,nc.us/esb/ One North Carolina Willey An Equal Opportunily \ Affirmative Action Employer Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-84001 FAX 919-743-85171 Customer Service: 1-877-623-6748 Internet: http://h2o.enr.state.nc.usiesbl One NorthCarolina Naturally An Equal Opportunity 1 Affirmative Action Employer NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary RECEIVED D VISION OF WATER QUALITY ember 24, 2010 CERTIFIED MAIL RETURN RECEIPT REQUESTED: 7002 3150 0003 7052 3873 Mr. Chris Sutherland ECS Carolinas 8702 Red Oak Blvd. Suite A Charlotte, NC 28217 Subject: Dear Mr. Southerland: NOTICE OF VIOLATION Effluent Toxicity Testing NPDES Permit No. NC0088226 Wachovia Tryon St. BTS Mecklenburg County JAN 0 6 2011 SWP EC'"ION MOORESViLLE REG ONAL OFFICE This is to inform you that the Environmental Sciences Section has not received your regular uarterl toxicit self-monitorin re ort form for the month of Se tember 2010. This is in violation of Title 1.5A of the North Carolina Administrative Code, Chapter 2, Subchapter 2B, Section .0506 (a)(1)(A) which states that "monthly monitoring reports shall be filed no later than 30 days after the end of the reporting period for which the report was made." Please remember that reporting of toxicity self -monitoring data is a dual requirement. Toxicity test results must be entered on your Discharge Monitoring Report and the Toxicity Reporting Form (AT Report Form). The AT report form must be submitted to: DWQ/ESS, 1621 Mail Service Center, Raleigh NC 27699-1621 within the required time frame. Your NPDES permit requires you to submit an Aquatic Toxicity Self -Monitoring Form to this office during a month in which toxicity testing is required, regardless of whether a discharge occurs from the Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone; 919.743-8400I FAX: 919.743.85171 Gustorner Service: 1.877-623-6748 Internet: http:/1h2o.enr.state.nc.ustesb/ One horthCarolina 2atura//jt An Equal Opportunity Affirmative Action Employer cc: facility. Please ensure that AT test forms labeled "No Flow" are sent to this office during months when no discharge occurs and the facility is required to perform toxicity testing. Additional reporting and/or monitoring violations within a twelve (12) month period subjects the facility to the enforcement authority of the Division. Attached to this Notice, you will find a summary of important toxicity monitoring and reporting requirements. Please read this summary. If you have any questions concerning this Notice, please contact Mr. john. Giorgino with the Aquatic Toxicology Unit at (919) 743-8441. Sincerely, Cindy Moore Supervisor, Aquatic Toxicology Unit ooresville Regional Office John. esley- Mooresville Regional Office Aquatic Toxicology Unit Central Files Environmental Sciences Section 1521 Mail Service Center, Raleigh, North Carolina 27699-1521 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27507 Phone: 919-743-8400 \ FAX: 919-743-8517 \ Customer Service: 1-877-623-6748 Internet: http:t/h2o,enrstate.nc,usiesbi One North Carolina Natural!!! An Eqtial Dpportunily \ Affirmative Action Employer 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 include all the toxicity testing and reporting requirements contained in your NPDES permit If vou should have any questions about your toxicity testing requirement, please contact Mr, John Giorgino with the Aquatic Toxicology Unit at (919) 743-8401 or another Unit representative at the same number. • The permittee 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 testresults u, 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 Wate Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 > Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days 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 Section 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 Section at (919) 743-8401 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 tn whtch 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 he signed by the facility's Operator in Responsible Charge (ORC) 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. Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location:4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 1 FAX: 919-743-8517 I Customer Service: 1-877-623-6748 Internet http://h2o.enr.state.nc.usiesbl One North Carolina Vat:ira//jj An Equal opportunity \Affirmative Action Employer 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 Section, Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27599-1621 Location: 4401 Reedy Creek Road, Raleigh. North Carolina 2750'7 Phone: 919-743-8400 I FAX 919-743-8517 1 Customer Service: 1-877-623-6748 Internet: http://h2o.enr.state.nc.usiesb/ North aturally An Equal Opportunity 1 Affirmative Acton Employer North Carolina De Beverly Eaves Perdue Governor NCDENR Jartment of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director December 8, 2010 CERTIFIED MAIL RETURN RECEIPT REQUESTED: 7002 3150 0003 7052 4085 Mr. Chris Southerland Wachovia Bank N.A. 8702 Red. Oak Blvd. Charlotte, NC 28217 Subject: Dear Mr. Southerland: NOTICE OF VIOLATION Effluent Toxicity Testing NPDES Permit No. NC0088226 Wachovia Tryon St. BTS Mecklenburg County DIv MOORE Dee Freeman Secretary RECEIVED ON OF WATER QUALITY DEC 09 2010 REG ANAL OFFICE This is to inform you that the Environmental Sciences Section has not received your regular quarterly toxicity self. -monitoring report form for the month of September 2010..This is in violation of Title 15A of the North Carolina Administrative Code, Chapter 2, Subchapter 2B, Section .0506 (a)(1)(A) which states that "monthly monitoring reports shall be filed no later than 30 days after the end of the reporting period for which the report was made." Please remember that reporting of toxicity self -monitoring data is a dual requirement. Toxicity test results must be entered on your Discharge Monitoring Report and the Toxicity Reporting Form (AT Report Form). The AT report form must be submitted to: DWQ/ESS, 1621 Mail Service Center, Raleigh NC 27699-1621 within the required time frame. Your 'NPDES permit requires you to submit an Aquatic Toxicity Self -Monitoring Form to this office during a month in which toxicity testing is required, regardless of whether a discharge occurs from the facility. Please ensure that AT test forms labeled "No Flow" are sent to this office during months when no discharge occurs and the facility is required to perform toxicity testing. Environments! Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh„ North Carolina 27607 Phone: 919-743-84001 FAX: 919-743-85171 Customer Service: '1-877-623-6748 Internet: httpalh2o,enr.state.nc.us/eshi One NorthCarolina Naturaif An Equal Opportunity :Affirmative Action Employer cc: Additional reporting and/or monitoring violations within a twelve (12) month period subjects the facility to the enforcement authority of the Division. Attached to this Notice, you will find a summary of important toxicity monitoring and reporting requirements. Please read this summary. If you have any questions concerning this Notice, please contact Mr. John Giorgino with the Aquatic Toxicology Unit at (919) 743-8441. Sincerely, Cindy Moore Supervisor, Aquatic Toxicology Unit Mooresville Regional Office John Lesley- Mooresville Regional Office Aquatic Toxicology Unit Central Files Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 \ FAX: 919-743-8517 \ Customer Service: 1-877-623-6748 Internet: http://h2o.enr,state.nc,usiesb/ One North Carolina Na hire" An Equal' Opportunity 1 Affirmative Acton Employer 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 include all the toxicity testing and reporting requirements contained in your NPDES permit, If you should have any questions about your toxicity testing requirement, please contact Mr. John Giorgino with the Aquatic Toxicology Unit at (919) 743-8401 or another Unit representative at the same number. • The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report forms are appropriately filed. S;,• 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 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 Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 • Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days 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 Section 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 Section at (919) 743-8401 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 mouth 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 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, you may consider submitting your toxicity test results certified mali, return receipt requested to the Environmental Sciences Section, Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 1 FAX: 919-743-8517 \Customer Service: 1-877-623-6748 Internet: http://h2o,enr.state.nciusiesb/ One NorthCarolina. .7aturallff An Equal OpPortu AffirnTnative Ation Employer NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director RECEIVED Secretary DVNSION OF WATER QUALITY November 29, 2010 CERTIFIED MAIL: 7002 3150 0003 7052 3866 RETURN RECEIPT REQUESTED Mr. Chris Sutherland Wachovia Bank N.A. 8702 Red Oak Blvd. Charlotte, North Carolina 28217 DEC 1 6 2010 SWP SEL "s'iON MOORESVILLE REGIONAL OFFICE SUBJECT: Assessment of Civil Penalty for Violations of NC General Statute 143-215.1(a)(6) and NPDES Pen -nit No. NC0088226 Wachovia Tryon St. BTS Mecklenburg County TX 2010-0008 ._;. Dear Mr. Smith: This letter transmits a Civil Penalty assessment age ($ "2- 000. OD civil penalty -+- $ b ' el ov1 t l,. e on St. BTS i costs). e amou This assessment is based upon the following facts. A review of the facility's toxicity self -monitoring data from September has been conducted. The review has shown Wachovia Tryon St. BTS to be in violation of the 90 % chronic toxicity effluent discharge limitation found in NPDES Permit No. NC0088226. The facility's toxicity self -monitoring reports for June through September 2010 revealed the following effluent toxicity permit limit violations. June 15, 2010 July 27, 2010 August 24, 2010 September 28, 2010 Fail (chronic P/F)) 97.5 % (7 day chronic value) Compliant Invalid Test <30% (7 day chronic value) Non -Compliant Based upon the above fact(s), I conclude as a matter of law that Wachovia Tryon St. BTS violated the terms, conditions or requirements of NPDES Permit No. NC0061 182 and N.C.G.S 143-215.1(a)(6) in the manner and extent shown above. A civil penalty in accordance with the maximum established by N.C.G.S. 143-215.6A(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). Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location. 4401 Reedy Creek Road, Raleigh. North Carolina 27607 Phone:919.743.8400 \ FAX:919-743-85171 Customer Service: 1-877-623-6748 Internet: http:/lh2o.enr.state.nc.uslesbl One NorthCaR lit , Naturally An Equal Opportunity ! Affirmative Action Employer 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, I, Cindy Moore, Supervisor, Aquatic Toxicology Unit, hereby make the following civil penalty assessment against Wachovia Tryon St. BTS. For of % violation(s) of G.S. 143-215.1(a)(6) and NPDES Permit No. NC0088226, by discharging waste into the waters of the State in violation of the facility's permit effluent limit for chronic toxicity for June 15, 2010. For ( of / violation(s) of G.S. 143-215.1(a)(6) and NPDES Permit No. NC0088226, by discharging waste into the waters of the State in violation of the facility's permit effluent limit for chronic toxicity for September 28, 2010. 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 Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282.1(b), which are: (1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the 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. Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-743-8400 `FAX: 919-743-85171 Customer Service: 1-877-623-6748 Internet: httpalh2o.enr.state.nc.usiesbi One NorthCarolina ;Vat/tray An Eoual Oepartunity 1 Affirmative Action Employer Within thirty days receipt of this notice, you must do one of the following: 1. Submit payment of the penalty: Payment should be made directly to the Department of Environment and Natural Resources (do not include waiver form). Payment of the penalty will not foreclose enforcement action for any continuing or new violation(s). Please submit payment to the attention of: Point Source Branch Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 OR 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: one or more of the civil penalty assessment factors in G.S. 143B-282.1(b) were wrongfully applied to the detriment of the petitioner; the violator promptly abated continuing environmental damage resulting from the violation; the violation was inadvertent or a result of an accident; the violator had been assessed civil penalties for any previous violations; payment of the civil penalty will prevent payment for the remaining necessary remedial actions. 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 inform you of his decision in the rnatter of your remission request. The response will provide details regarding the case status, directions for payment, and provision for further appeal of the penalty to the 'Environmental Management Commission's Committee on Civil Penalty Remissions (Committee). Please be advised that the Committee cannot consider intimation that was not part of the original remission request considered by the Director. Therefore, it is very important that you prepare a complete and thorough statement in support of your request for remission. Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh, North Carorma 27607 Phone: 919-743-8400 \ FAX: 919-743-8517 \ Customer Service: 1-877-623-6746 Internet: http://h2o,enr,state,nc.usiesb/ One No-111-C aro 1i An Equal Opportunity \ Affirmative Action Employer lnorder Lorequest remission, you must complete and submit the enclosed "Request for Remission ofCivil Penalties Waiver of Right to an Administrative Hearing and Stipu lation of Facts" form within thirty (30) days of receipt of this notice. The Division ofWater Quality also requests that you comp|cteand submit tile enclosed "Justification for Remission Request." Both forrils should be submitted to the following address: Environmental Sciences Section Division of Water Quality 1021 Mail Service Center Raleigh, NC27699'l02l OR 3. File upetition for an administrative hearing with the Off -ice o[&dminisUativn Hearings: lfYOU wish 0/contest any statement in the attached assessinent document YOU Must file a petition for an administrative hearing. You may obtain the petition form hnmthe Office o[Administrative Hearings. YOU Must file the petition with the Office o[Administrative Hearings within thirty (30)days ofreceipt ofthis notice, /\petition ixconsidered filed v/hcn' it is received inthe Office ofAdministrative Hearings during normal office hours. The Office of&dnui i tru\i }��ng .' accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official . The original and one (l)copy ofthe petition must be filed with the Office o{ �hninisira1ivc8oudngu. Tilr'odtionmay be faxed - provided the original and one copy of 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 nfAdministrative Hearings 0714Mui\ Service Center Raleigh, NC 27699'6714 A copy of the petition must also be served on DENR as follows: Ms. Mary Penny Thompson, General Counsel Department of Environment and Natural Resources 1601 Mail ScrviceCun»cr Raleigh, NC27699'|60 Please indicate the case number (as found oil page otic ofthis letter) oil tile petition. Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal date/time received starrip (not a postmark), will result in this matter being referred to the Attorney General's Office for collection of the penalty through u civil action. P\cuxe be advised that additional pcnuhica may be assessed for violations that occur after the review period ofthis assessment. Environmental Sciences Section 1G31Mail Service Center, Raleigh, North Carolina 2nBg1Oc1 Location: 4401 Reedy Greek Road, Raleigh, North Carolina 27607 Phone: 919-743'84OO\FAX: 819-74J'S517\Customer Service: 1'0rr-623'nr^8 One NoiihCarohn Natutully 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 919 743-8442 or Mr. John Giorgino at 919-743-8441. Date ATTACHMENTS cc: Cindy Moore Supervisor, Aquatic Toxicology Unit eg"anal Office w/attachments John Lesley- Mooresville Regional Office w/attachments Point Source Branch File w/attachments John Giorgino -Aquatic Toxicology Unit w/attachments Central Files w/attachments Environmental Sciences Section 1621 Mail Service Center, Raleigh, North Carolina 276991621 Location:4401 Reedy Creek Road, Raleigh. North Carolina 27607 Phone: 919.743-84001 FAX: 919-743-85171 Customer Service: 1877-623.6748 Internet: http:/lh2o.enr.state.nc.uslest l One NorthCarolina. Natural l t An Equal Opportunity t Affirmative Action Er Pr STATE OF NORTH CAROLINA COUNTY OF MECKLENBURG IN THE MATTER OF ASSESSMENT OF CIVIL PENALTIES AGAINST WACHOVIA TRYON ST. BTS NPDES PERMIT NO. NC0088226 DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES WAIVER OF RIGHT TO AN ADMINISTRATIVE HEARING AND STIPULATION OF FACTS FILE NO. TX-2010-0008 Having been assessed civil penalties totaling for violations) as set forth in the assessment document of the Director of the Division of Water Quality dated , the undersigned, desiring to seek remission of the civil penalties, does hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be submitted to the Director of the Division of Water Quality within 30 days of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after 30 days from the receipt of the notice of assessment. This the day of , 2010. BY ADDRESS. TELEPHONE JUSTIFICATION FOR REMISSION REQUEST DWQ Case Number: TX-2010-0008 County: Mecklenburg Assessed Party: Wachovia Tryon St. BTS Permit No. (if applicable): NC0088226 Amount Assessed: $ Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation 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.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only when one or more of the following five factors applies. Please check each factor that you believe applies to your case and provide a detailed, explanation, including copies of supporting documents, as to why the factor applies (attach additional pages as needed). (a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document); (b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the steps that you took to correct the violation and prevent fulure 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 or prepare fot); (d) the violator had not been assessed civil penalties for an_ previous violations; (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e„ explain how payment of the civil penalty will prevent you . per!' — ing the activities necessary to achieve compliance). EXPLANATION: NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary AuPust 17, 2010 CERTIFIED MAIL: 7006 2760 0001 9282 0860 RETURN RECEIPT REQUESTED Mr. Roger A. Smith Wachovia Bank N.A. 8702 Red Oak Blvd. Charlotte, North Carolina 28217 Subject.: NOTICE OF VIOLATION Effluent `Toxicity Testing NPDES Permit No, NC0088226 Wachovia Tryon St. BTS Mecklenburg County Dear Mr. Smith: This is to inform you that a review of your toxicity self -monitoring report form for the month of June 2010 indicates a violation ofthe toxicity limitation specified in your NPDES Permit. You should take whatever remedial actions are necessary to elitninate the conditions causing the ettluent toxicity violation(s), Your efforts may include conducting a Toxicity Reduction Evaluation (TRE), 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 he 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 contair'ts important tnTormation concerning your Whole Effluent "Toxicity Nlonitorin9. and IZeporti Requirements. Please note appropriate mailing addre.tises g your Discharge Monitoring Reports (1)A:f/4) and Aquatic 1"rricitt° (t Test Forms. We encourage you to review this information; if it would he helpful to discuss this situation or possible solutions to resolve toxicity noncompliance, please contact Mr. John Giorgino with this office at (919) 743-8441. cc: Sincerely, Cindy A. Moore Supervisor, Aquatic ooresville Regional Office John Lesley/ Mooresville Regional Office .Aquatic Toxicology Unit Central Files Environmental Sciences Section 1821 Mail Service Center, Raleigh, North Carolina 27699 1621 Location: 44©1 Reedy Creek Road. Raleigh, North Carolina 27507 Phone: 919-743.8400 \ FAX: 919=743.8517 t Customer Service! 1-877-62 •8748 Internet: http,l/h2o.enrstate.nc.uslesht icology Unit On North. r( An Equal Opportumly i r 1`!'rrrnarlve Acuor Erapir„ WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION ➢ The following items are provided in an effort to assist yott 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 include all the toxicity testing and reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity testing requirement, please contact Mr. John Giorgino with the Aquatic Toxicology Unit at (919) 743-8401 or another Unit representative at the same number. ➢ The permittee 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 nest 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 Quail Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 y C"oxicity test resutts shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period (eg. Jant.rary test result is due by the end of February). • Toxicity test condition language contained in your 'NPDES permit may require use of multiple concentration toxit;.ity 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, .tune, September, and December, then toxicity testing must he conducted during these months). it you Section at (919) 743-8401 and provide written documentation occur. NPDES Permit specifies episodic monitoring. and your facility does not have a discharge from January 1-June 30, then you must provide notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months of the calendar 1 from your contract laboratory that a test was invalidated, you should immediately notify the Environmental Sciences 'dated and the date when follow-up testing will ➢ 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 forrn, 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 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, you may consider submitting your toxicity test results certified mail, return receipt requested to the Environmental Sciences Section. Environmental Sciences Section 1621 Mail Service Center,, Raleigh, North Carolina 27699-1621 Location: 4401 Reedy Creek Road, Raleigh. North Carolina 27607 Phone:919-743.F400FAX:919•743.8517. Customer Service: 1-877-623-6748 internee: hall:,'th2o.enr.statc,.nc.usleshl One Nort Carolii Naturally Beverly Eaves Perdue Governor NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Dee Freeman Director Secretary February 25, 2010 CERTIFIED MAIL ITEM 7009 1680 0002 2464 6364 - RETURN RECEIPT REQUESTED . Mr. Allen Holloway Wachovia Bank N A 301 S College St Ste 2800 Charlotte, NC 28202 Subject: Notice of Violation Failure to Submit Renewal Application NPDES Permit NC0088226 Wachovia Tryon Street BTS Mecklenburg County Dear Peree: The subject permit's expiration date is July 31, 2010. Federal [40 CFR 122] and state (15A NCAC 2H.0105 (e)) regulations require that an application for permit renewal be filed at least 180 days prior to expiration of the current permit. To satisfy this requirement, your renewal package should have been sent to the Division postmarked no later than February 1, 2010. As of this date, the Division has not received your renewal application. This is a violation of Part II. B. 10. of your permit, which states "Any permittee that has not requested renewal at least 180 days prior to expiration...will subject the permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.". To prevent an assessment of civil penalties you must submit a completed permit ap'plication (see enclosed forms) no later than March 12, 2010. Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must submit with the permit renewal application. If all wastewater discharge from your facility has ceased and you wish to rescind this permit [or if you have any questions] please contact Charles H. Weaver of my staff. His telephone number, fax number and e-mail address are listed at the bottom of this page. Sinferely, G1 een H. Sullins ec Central Fi 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 512 North Salisbury Street, Raleigh, North Carolina 27604 Phone: 919 807-6391 / FAX 919 807-6495 / charles.weaver@ ncdenr.gov NorthCr©lina Naturally An Equal Opportunity/Affirmative Action Employer— 50% Recycled/1O% Post Consumer Paper CHARLOVIEiN August 1, 200B Lisa Latham Klein ProperNn :NI S. College St Suite 2800 0.harleilte. NC 213202 Subject: Reuse of Grotindwater in the ilii‘aehovie First Street Goering towers, Dear Me. Latham,: Your request submitted by Tempest Erivimnrrientai Systeins; fnc, to discharge treated groundwater, for use in 'Wac.hovia's Flist, Street Project located at 550 South Tryon, Street, Charlotte, North Carolina, is granted 'Cased upoq the lowininformation and conditions, The Special Use discharge to the sanitary sewer will originate from the use of treated ci-oritaminated groundwater as inakeu,p water fr.i,r cooling towers. This inoy result in bieetioff from those cooling tz.miers 7,3 rid up to ;.i% of treated contaminated groundwater being discharged directly to the sanitary sewer, It is stated in the request letter that up to 67,1140 gallons- Per clay .gpr.i) of groundwater will be pumped art ttoateid with the installed treatment System, ft was projected that: 83t.443 gpd.or 95% of this water will be recovered for use as makeup wet.er in the cooling towers and the remaining 5% at the -groundwater or 4392 gokil will tie &lischerged directly to the sanitary sewer, All 'contaminated groundwater discharge to the sanitary sewer shall bo treated before discharge roey take place, The contaminated; groundwater is currently beirig dithered to the Stormwat.ar sewer under NPDES permit No. NCODB13.20 and tested for thi;. volatile organic ohoroicels (\TOG) and other pollutants listed on the Dryprovided. It was indicated in the request letter that clirOnic toxicity had failed twice due to volatile organic: chemicals, The removal rate by the treatment system, indicated in the request letter, for these VOC s will be, greater than The treatment system consists of the following equipment: 11) Air Stripper system ill Zeolite filter System.; ill. Ariti-Scatant Dosing System: 11 Sodium Metabisulfite Dosing stn UUltra-Filtration aystem; (2) Reverse Osmosis i,no;, sv,T*; t4) fie:pressurization. Punips 124 Water Meter/Totalizer; (al —3E0 gallon ED Storce Tank:it:1 —250Q gallon EQ Storage Tank for feed to entire system- A Roos ilcw diagram and waLer treatment tayoUL plat were submitted with the request. The conditions for discharge of treated groundwater to the i&anitery sewer consist of th-e following: Insullaion errs rnaintentnce of Charlotra-Mockleriburg tftilitiesICN1U1 approved water matte.s; i21 Operation and maintenance of the tteettnent system consisting of tine equipment Itstc1.1 above so the VOC parameters listed in the request letter and the NPOES. permit riinon below ND 21 threshold, Any discharge-, WthowL permissionr to the sanitary sewer exceeding the NC 2L bi the VOC parameter& shall be considatCd a 'Violation of 'The Sewer Use OrClinenCe(81301' System Protection .4222 VJestetont alive Cherlotte, NO 28.21't Phone: 70,11330-4407 Fax MO3543-5077 Charlcitte-MecklenCurg UlfliLio (31 An init ell pararn ere oornrnencernei HART Esm d groundwater veatitr being discharged to the sanitary sewer for P }ES .Derrnit shall t:e performed within 30 days of startup and The testing shaft be performed using approved watiewatvr methods kund in M.r{"R 136 and submitted to System Protection at the address listed 14} Upon 5IJt5nlT,g,. trclud.e a staternent certifying that no hat-tre-awl gv undwal r has been or yi{l h dig Ght it ed to the sanitary sewer_ This certification shall by an authorized representative of Wachovia First Project. This certification of Proper riper •tisan card ma nter ,nce shall he resubinitu3d annually as assurance that the treatment system to i(5,t Wsehovi s authoriaud represent account based on the appropriate the discharge of the treated-:roun6vater to the sani U in- the estabhishrnertt of a Willing These rasters will be used to record ewer far billing. If peat have any questions or need further asssistenos, please call tyre at { O4.}336-5Q4?. Thank you for your cooperation. nmeritel GQrnpl''anes Supervisor mental Management -System Prat Mecklentwrg l tinter s Dobson Cousar, EnvirtfiR l ent rl :tirnoffence. Manager System Prate4222 Westmont give CGhanattp, NC 17 Ph ne. 7041335-4407 r-ax; 7O4 336• 077 Ght+rlRite-Mec,k ri:iatsre U IIt3eS NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director Mr. Allen James Holloway, III Childress Klein Properties 301 South College Street, Suite 2800 Charlotte, North Carolina 28208 Subject: Dear Mr. Holloway,: November 17, 2009 Notice of Violation - Effluent Limitations Tracking #: NOV-2009-LV-0502 Wachovia Tryon Street BTS NPDES Permit No, NC0088226 Mecklenburg County Dee Freeman Secretary A review of the August 2009 self -monitoring report for the subject facility revealed a violation of the following parameter: Pipe Parameter Reported Value Permit Limit 001 Total Suspended 170 mg/1 30 mg/1 daily maximum Solids Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Mr. John Lesley of this Office for additional information, cc: If you have questions concerning this matter, please do not hesitate to contact Mr. Lesley or me at 704/663-1699. Sincerely, Robert B. Krebs Surface Water Protection Regional Supervisor Point Source Branch Mecklenburg County Water Quality Protection Mooresville Regional Office Location: 610 East Center Ave:, Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 1 Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Internet: www,ncwaterquality,org An Equal Opportunity \Affirmative Action Employer — 50% Recycled/10% Post Consumer paper One NorthCarolina Naturally NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director September 22, 2009 Mr. Roger A. Smith ECS Carolinas, LLP 8702 Red Oak Blvd.; Suite A Charlotte, North Carolina 28217 Subject: Notice of Violation - Effluent Limitations Tracking #: NOV-2009-LV-0413 Wachovia Tryon Street BTS NPDES Permit No. NC0088226 Mecklenburg County Dear Mr. Smith: Dee Freeman Secretary A review of the June 2009 self -monitoring report for the subject facility revealed a violation of the following parameter: Pipe Parameter Reported Value Permit Limit 001 Total Suspended Solids 45.7 mg/1(daily maximum) 30 mg/1 (daily maximum) Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Mr. John Lesley of this Office for additional information. If you have questions concerning this matter, please do not hesitate to contact Mr. Lesley or me at 704/663-1699. Sincerely, Robert B. Krebs Surface Water Protection Regional Supervisor cc: Point Source Branch Mecklenburg County Water Quality Protection Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 \ Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity \ Affirmative Action Employer - 50% Recycledrt 0% Post Consumer paper One NorthCarolina 1-aturally Atif NCDENR North Carolina Department of Environment and Natural Resources Division of:Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director Mr. Allen J. Holloway III Construction Manager Childress Klein Properties 301 South College Street, Suite 2800 Charlotte, North Carolina 28202 Subject: Dear Mr. Holloway July 1, 2009 Notice of Violation - Effluent Limitations Tracking #: NOV-2009-LV-0282 Wachovia Tryon Street BTS NPDES Peintit No. NC0088226 Mecklenburg County Dee Freeman Secretary A review of the March 2009 self -monitoring report for the subject facility revealed a violation of the following parameter: Pipe Parameter Reported Value Permit Limit 001 Total Suspended 212 mg/1 (daily maxim' 30 mg/1 (daily maximum Solids Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance, problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Mr. John Lesley of this Office for additional information. cc: If you have questions concerning this matter, please do not hesitate to contact Mr, Lesley or me at 704/663-1699. Sincerely, Robert B. Krebs Surface Water Protection Regional Supervisor Point Source Branch Mecklenburg County Water Quality Protectio Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 1 Fax: (704) 663-6040 \ Customer Service: 1-677-623-6748 Internet: wwwmcwaterquality.org An Equal Opportunity \ Affirmative Action Employer — 50% Recycled/10% Post Consumer paper One NorthCaroltna iaturailli Beverly Eaves Perdue Governor NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H, Sullins Director Dee Freeman Secretary June 1, 2009 Mr. Allen J. Holloway III, RPA, Construction Manager Childress Klein Properties 301 South College Street, Suite 2800 Charlotte, North Carolina 28202 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2009-PC-0488 Compliance Evaluation Inspection Wachovia Tryon Street NPDES Permit No. NC0088226 Mecklenburg County, NC Dear Mr. Holloway: Enclosed is a copy of the Compliance Evaluation Inspection report for the inspection conducted at the subject facility on March 12, 2009, by Mr. Jeff Mitchell of the Mecklenburg County Water Quality Program (MCWQP) and the inspection conducted April 13, 2009, by Mr. Jeff Mitchell of MCWQP, Ms. Marcia Allocco and Mr. John Lesley of the North Carolina Department of Environment & Natural Resources (NCDENR). This inspection was conducted as part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality. Please provide the facility's Operator in Responsible Charge with the findings of the inspection by forwarding a copy of the enclosed report. This report is being issued as a Notice of Violation (NOV) due to the noted violations of the subject NPDES permit and North Carolina General Statute (G.S) 143-215.1, as detailed in the Records/Reports, Flow Measurement and Self Monitoring Program sections of the attached report. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per violation, per day, may be assessed against any person who violates or fails to act in accordance with the term, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. Mooresville Regional Office Location: 610 East Center Ave, Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity \ Affirmative Action Employer — 50°/0 Recyciedill0% Post C,onsurner paper ne NoOrthCarolina laturallff Mr. A. Holloway, Wachovia Tryon Street NOV-2009-PC-0488, Page 2 June 2, 2009 It is requested that a written response be submitted to this Office by no later than July 3 2009, addressing the above noted violations in the attached report. In responding to the violations, please address you're your comments to the attention of Ms. Marcia Allocco at the letterhead address. Additionally, please send a copy of your response to Mr. Rusty Rozzelle of MCWQP at 700 North Tryon Street, Suite 205, Charlotte, NC 28202. The enclosed report should be self-explanatory; however should you have any questions concerning this report or any other matters please do not hesitate to call Ms. Marcia Allocco at (704) 663-1699 or Mr. Jeff Mitchell at (704) 336-3926. Sincerely, or Robert B. Krebs Regional Supervisor Surface Water Protection Enclosure cc: Rusty Rozzelle, MCWQP RBKIJGM File: WQ Wachovia BIS 00882260809 United States Environmental Protection Agency, Washington, DC 20460 Form Approved NPDES Compliance Inspection Report AV OMB No, 2040-0003 North Carolina Department of Environment and Natural Resources Approval Expires Division of Water Quality, Mooresville Regional Office NCDENR 7/31/85 Section A: National Data S steni Coding Transaction N Code NPDES Permit No, 5 NC0088226 pection Work Days 1.25 Yr/Mo/Day 09/03/12 09/04/13 Inspection Type Inspector Facility Type N/A Remarks: Inspector: Mecklenburg County WaterQua a Facility Self -Monitoring Evaluation Rating BI QA 1 Section B: Facility Data Name and Location of Facility Inspected: Wachovia Site Childress Klein Properties 500 South Tryon Street Mecklenburg County, NC Entry Time: 9:00 am & 10:00 am Exit Time: 10:20 am & 10:45 am Date: 3/12/2009 & 4/13/2009 Name(s) of On -Site Representatives -------Title(s)--------Phone No(s): Travis 0' Quinn Operator in Responsible Charge (ORC) (704) 903-8057 Roger A. Smith, RG,, R.B. P. Manager, Environmental Services (704) 525-5152 Todd Patterson Assistant Construction Manager (704) 342-9000 Name and Address of Responsible Official: Mr. Allen Holloway III, RPA Childress Klein Properties 301 South College Street, Suite 2800 Z Permit Z Records/Reports Z Facility Site Review E nt/Ree iving Waters Permit EffectiveDate: July 1, 2006 Permit Expiration Date: June 30, 2010 ECS Carolinas, LLP Representative ECS Carolinas, LLP Representative Childress Klein Properties (Permittee Title: Construction Manager Phone No. (704) 343-4387 Contacted? Yes Section C: Areas Evaluated During Inspection Flow Measurement Z Operations & Maintenance Self -Monitoring Program LJ Sludge Handling/Disposal El Compliance Schedules El Pretreatment Program 1114 Laboratory - Z Stormwater Section D: Summary of Findings/Comments Sewer Overflow El Pollution Prevention [1] Multimedia [1] Other: All areas are rated satisfactory unless otherwise indicated. See Attached Sheet(s) for Summary Signature(s) of Inspector(s): y Mitchell Agency/Office/Telephone: Mecklenburg County Water Quality Program (704) 336-3926 Signature of Revie e larcia Al oc 0 Date: May 7, 2009 cy/Office: DriNR on ofWater Quality - Surface Water Protection oresville Regional Office (704) 663-1699 Date: ay 22, 2009 GENERAL: The facility was last inspected by Mr. Christopher Elmore of the Mecklenburg County Water Quality Program (MCWQP) on November 2, 2007. A Compliance Evaluation Inspection was issued on December 10, 2007. PERMIT: The current permit became effective on July 1, 2006, and expires on June 30, 2010. The permit authorizes the discharge of groundwater from Outfall 001 and Outfall 002. The location is a construction site and the permit allows the discharge of the site's groundwater through a dewatering operation. Currently the water from the dewatering wells is pumped to a central location where the water is then pumped to a stonnwater sewer junction box (stormwater manhole) in the middle of South Tryon Street. Therefore, the current permit does reflect the changes made by the permittee. Outfall 002 is no longer in use and Outfall 001 has been moved from the original location. The facility is not classified and therefore an Operator in Responsible Charge (ORC) is not required. The permittee has had Outfall 002 removed from the permit since the inspections occurred. Part III, Section A of the permit NC0088226 requires that an Authorization to Construct (AtC) permit be issued before the construction of wastewater treatment facilities. During the inspection it was noted that an in -line filtering system was installed at the facility and may be put into operation in the near future. The permittee plans to reuse the filtered water from the system. The Mooresville Regional Office of the Division of Water Quality does not possess a copy of the required Authorization to Construct (AtoC) approval letter or associated engineering documentation to discharge water from the installed filter system. If the permittee cannot reuse the filtered water and needs to discharge the effluent from the filter system, the permittee must submit the appropriate paperwork (for an AtoC and permit modification) before any discharges occur. RECORDS/REPORTS: Discharge Monitoring Reports (DMRs) were reviewed for the period of July 2007 through December 2008. All of the DMRs submitted for review during the inspection indicate the sample date for each collected sample is the first of the month and the DMRs only contain one day of monitoring information (modified from, the original format). The dates on the DMRs do not coincide with the dates of the analytical reports submitted for review. The permittee shall not modify the DMR (unless there are less than 31 days in a particular month) and shall begin recording the correct sample dates on the DMRs. The permittee shall document on the DMR and in a facility logbook when personnel perform any tasks (facility visitation, sample collection, maintenance, etc.) associated with the wastewater permit and report all effluent analyses (i.e. temperature and pH) on the relevant DMR even if they are not required by the permit as per Part II Standard Conditions Sections D and E. Finally, the permittee needs to remove monthly limit designations on the DMR that do not appear as Daily maximum limits in A.(1). Effluent Limitations and Monitoring Requirements section of the NC0088226 permit for Outfall 001. FACILITY SITE REVIEW: All of the components of the facility appeared to be operating properly at the time of the inspection. FLOW MEASUREMENT: Permit NC0088226 states, in Section A. (1) and (2) Effluent Limitations and Monitoring Requirements that flow is to be measured on a monthly basis using an appropriate flow meter at both Outfall 001 and Outfall 002. The permit further states, in Part II Standard Conditions Section D, that flow meters are to be calibrated at minimum of once per year. As indicated on the reviewed DMRs flow monitoring is not being performed/reported as required by the permit and no data was reported for Outfall 002 beginning in May 2008 (reporting violation). Documentation for the calibration date for the flow meter was not provided during the inspection. The permittee's contractor provided documentation that the Division of Water Quality was notified on July 2, 2008, that Outfall 002 is no longer discharging as a dewatering activity associated with the ongoing construction. The pennittee's request did not appear to be a request for the permit to be modified to have Outfall 002 removed. Therefore the permittee should have been marking the appropriate "No Flow / Discharge from Site" box for Outfall 002 until such time as it was removed from the permit. The permittee has had Outfall 002 removed from the permit since the inspections occurred. The permittee needs to report the flow from Outfall 001 as required by the permit. LABORATORY: The permittee contracts with Pace Analytical Services, Inc. to perform all chemical analyses (NC Laboratory Certification # 12) and Chronic Toxicity testing (NC Laboratory Certification #9) specified in the penult. Pace Analytical Services, Inc. was not evaluated during the inspection. EFFLUENT/RECEIVING WATERS: The permittee discharges to the City of Charlotte municipal separate storm sewer system (MS4), which subsequently discharges to a unanamed tributary to Little Sugar Creek, a Class C water, within the Catawba River Basin. The discharge from Outfall 001 was not observed during the inspection due to the relocation of the discharge point. The discharge location for Outfall 001 has been plumbed to a stormwater sewer junction box (stormwater manhole) in the middle of South Tryon Street. Due to asphalt around the rim of the manhole lid prohibiting the removal of the lid, the effluent from Outfall 001 was not directly observed. The inspector did observe the dewatering wells and central collection location that pumps the water to Outfall 001. The water contained in the dewatering wells was clear and had no odor, the water in the central collection location did not appear as clear as the water from the dewatering wells. SELF-M©NIT©RING PROGRAM: Discharge Monitoring Reports (DMRs) were reviewed for the period July 2007 through December 2008. The following deficiencies were found during the review: 1) The permittee has not monitored the discharge flow at either Outfall 001 or 002 as required by Permit NC0088226 Section A. (1) and (2) Effluent Limitations and Monitoring Requirements. The permittee shall complete all prior DMRs with the missing flow data and ensure all future DMRs contain the required flow data. 2) The permittee failed to submit a DMR for either Outfall 001 or 002 for the November 2008 monitoring period as required by Permit NC0088226 Section A. (1) and (2) Effluent Limitations and Monitoring Requirements. Please submit a DMR for Outfall 001 and 002 to the Division of Water Quality. 3) The permittee did not sign any of the DMRs that were reviewed by the inspector. The permittee shall begin signing the back of each DMR before the DMRs are submitted as required by Permit NC0088226 Part II, Section B 11. Signatory Requirements. The permittee also needs to sign all prior DMRs without a signature and keep them on file for future reference by the Division of Water Quality. 4) The discharge from Outfall 001. and 002 failed the Chronic Toxicity test for September 2007. This violation was noted in the previous inspection report and has been or will be addressed under separate cover by the Aquatic Toxicity Unit of the Division of Water Quality. Multiple —concentration testing should have been performed at minimum, in each of the two following months after the peg r littee received the failed test results for the Chronic Toxicity test. The permittee should reference the Section A. (3) & (4) Chronic Toxicity Pass/Fail Permit Limit (Quarterly) of Permit NC0088226. 5) The Chronic Toxicity test for December 2007 was not reported on the DMR for Outfall 001 or 002 and is assumed no testing was perforred. This violation has been or will be addressed under separate cover by the Aquatic Toxicity Unit of the Division of Water Quality. 6) The Chronic Toxicity test for December 2008 was not reported on the DMR for Outfall 001 but it was noted on the DMR that the test was performed in the first week of January 2009. This violation may be addressed, under separate cover by the Aquatic Toxicity Unit of the Division of Water Quality. 7) The permittee has not submitted DMRs for Outfall 002 since May 2008. The permittee shall complete the missing DMRs for Outfall 002, submit them to the Division of Water Quality and keep them on record, as well as request a permit modification to remove the outfall from the permit (completed since the inspection). OPERATIONS & MAINTENANCE: No problems with operations or maintenance of the facility were observed at the time of inspection. The facility and grounds appeared to be properly operated and maintained. The current overall operating strategy appears acceptable for the size and type of the facility ECS C.AROLINAS Creotechnical • Construction Materials • Environmental July 2, 2009 Ms. Marcia Allocco NCDENR — Division of Water Quality Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, North Carolina 28115 Reference: Response to Notice of Violation Tracking No.: NOV-2009-PC-0488 Compliance Evaluation Inspection Wachovia Tryon Street NPDES Permit No. NC0088226 Wachovia Site 500 South Tryon Street Charlotte, Mecklenburg County, North Carolina ECS Project 08-3515D Dear Ms. Allocco: On behalf of Wachovia/Childress Klein Properties, ECS Carolinas, LLP (ECS) is writing to respond to the Notice of Violation (NOV) issued by the North Carolina Department of Environment and Natural Resources (NCDENR), Division of Water Quality (DWQ) dated June 1, 2009. The NOV is in response to an inspection conducted at the site on March 12, 2009 by Mr. Jeff Mitchell of the Mecklenburg County Water Quality Program (MCWQP), and an inspection conducted on April 13, 2009 by Mr. Mitchell of the MCWQP, Ms. Marcia Allocco and Mr. John Lesley of the North Carolina Department of Environment and Natural Resources (NCDENR). Additionally, March 12, 2009 inspection was attended by Mr. Travis L. ©'Quinn of ECS, which is the facility's Operator in Responsible Charge (ORC). The April 13, 2009 inspection was also attended by Mr. O'Quinn and Mr. Roger Smith of ECS, Mr. Chuck Gaston of Batson Cook, the site construction superintendent, and Mr. Todd Patterson, with Wachovia/Childress Klein Properties. As a result of the above referenced site inspections, review of Permit NC0088226 requirements, and review of Discharge Monitoring Reports (DMRs) from July 2007 through December 2008, the NCDENR, DWQ issued the June 1, 2009 NOV. Below are the deficiencies stated in the NOV and responses / actions taken to address them: RECORDS/REPORTS: 1. "The permittee shall not modify the DMR (unless less than 31 days in a particular month) and shall begin recording the correct sample dates on the DMRs. The permitte shall document on the DMR and in a facility logbook when personnel perform any tasks (facility visitation, sample collection, maintenance, etc.) associated with the wastewater permit and report all effluent analyses (i.e., temperature and pH) on the relevant DMR even if they are not required by the permit as per Part II Standard Conditions Sections D and E. Finally, the permittee needs to remove monthly limit designations on the DMR that do not appear as Daily maximum limits in A.(1). Effluent Limitations and Monitoring Requirements section of the NC0088226 permit for Outfall 001." Since the April 13, 2009 site inspection, the DMRs submitted for the site include a line for each date of the month with each site visit and sampling dates noted. Additionally, previously listed constituents that had no permitted limit have been removed from the DMR forms. 8702 Red Oak Boulevard, Suite A, Charlotte, North Carolina 2 2 7.70-525-5152 • Fax: 7f1 #-525-717i1 • v .c iinaited.corn Wachovia Site — Response to June 1 2009 NOV NPDES Permit No, NC0088226 Charlotte, Mecklenburg County, North Carolina ECS Project 08-35150 July 2, 2009 FLOW MEASUREMENTS: 1. "Permit NC0088226 states, in Section A. (1) and (2) Effluent Limitations and Monitoring Requirements that flow is to be measured on a monthly basis using an appropriate flow meter at both Outfall 001 and Outfall 002. The permit further states, in Part II Standard Conditions Section D, that flow meters are to be calibrated at a minimum of once per year." Included in Attachment A is a copy of calibration records for the two flow meters installed to monitor discharge on Outfalls 001 and 002. The date of the calibration records indicate the test date for the meters was January 11, 2008; therefore, the one remaining flow meter (installed for Outfall 001) is currently scheduled to be tested and recalibrated in July 2009. 2. "As indicated on the reviewed DMRs flow monitoring is not being performed/reported as required by the permit and no data was reported for Outfall 002 beginning in May 2008 (reporting violation)." Since the April 13, 2009 inspection, the DMR's have included required flow data. Additionally, previously submitted DMRs will be revised to reflect flow data (either actual, estimated or "no flow'). The revised DMRs will be maintained within the project file at Wachovia/Childress Klein and ECS. Should the NCDENR DWQ request a copy of the revised DMRs, a copy can be provided. SELF -MONITORING PROGRAM: "The permittee has not monitored the discharge flow at either Outfall 001 or 002 as required by Permit NC0088226 Section A. (1) and (2) Effluent Limitations and Monitoring Requirements. The permittee shall complete all prior DMRs with the missing flow data and ensure all future DMRs contain the required flow data." As stated above in response number 1 concerning Flow Measurements, since the April 13, 2009 inspection, the DMR's have included required flow data. Additionally, previously submitted DMRs will be revised to reflect flow data (either actual, estimated or "no flow"). The revised DMRs will be maintained within the project file at Wachovia/Childress Klein and ECS. Should the NCDENR DWQ request a copy of the revised DMRs, a copy can be provided. 2. "The permittee failed to submit a DMR for either Outfall 001 or 002 for November 2008 monitoring period as required by Permit NC0088226 Section A. (1) and (2) Effluent Limitations and Monitoring Requirements. Please submit a DMR for Outfall 001 and 002 to the Division of Water Quality." As stated in a December 31, 2008 letter addressed to Mr. Jimmy Overton with the NCDENR, DWQ, ECS stated that "although multiple site visits were conducted in an attempt to collect the required monthly samples, during each occasion either the system was shut off due to reconfiguring of discharge piping for the ongoing site construction, or the sampling location was in accessible". ECS understands that in lieu of the December 31, 2008 letter, a DMR was to be submitted stating "no flow" Included in Attachment B is 2 Wachovia Site — Response to June 1 2009 NOV NPDES Permit No. NC0088226 Charlotte, Mecklenburg County, North Carolina ECS Project 08-3515D July 2, 2009 a revised DMR for November 2008, stating "No Flow" for Outfall 001. Additionally, since Outfall 002 was not operational at the time and the Permit had not been revised to remove Outfall 002 from the permit, ECS has also included a revised DMR for Outfall 002 stating "No Flow". 3. "The permittee did not sign any of the DMRs that were reviewed by the inspector. The permittee shall begin signing the back of each DMR before the DMRs are submitted as required by Permit NC0088226 Part II, Section B 11. Signatory Requirements. The permittee also needs to sign all prior DMRs without a signature and keep them on file for future reference by the Division of Water Quality." As requested, previously submitted DMRs that did not include permittee signatures will be revised to include the signatures and will be kept on file by Wachovia/Childress Klein and ECS. 4. "The discharge from Outfall 001 and 002 failed the Chronic Toxicity test for September 2007. This violation was noted in the previous inspection report and has been or will be addressed under a separate cover by Aquatic Toxicity Unit of the Division of Water Quality. Multiple concentration testing should have been performed at the minimum, in each of the two following months after the permittee received the failed test results for the Chronic Toxicity Pass/Fail Permit Limit (Quarterly) of Permit NC0088226. The permittee should reference the Section A. (3) & (4) Chronic Toxicity Pass/Fail Permit Limit (Quarterly) of Permit NC0088226." It is correct that the Chronic Toxicity test for Outfall 001 and 002 failed during the September 2007 sampling event. As ECS previously addressed in a Response to Notice of Violation and Recommendation for Enforcement document dated January 4, 2008 by ECS to Ms. Marcia Allocco of the NCDENR, DWQ, although the multiple concentration testing was not conducted during the subsequent two months, pass/fail chronic toxicity testing was conducted in the months of October and November 2007. The results of the subsequent pass/fail chronic toxicity testing resulted in passing tests for both months. 5. "The Chronic Toxicity test for December 2007 was not reported on the DMR for Outfall 001 or 002 and is assumed no testing was performed. This violation has been or will be addressed under a separate cover by the Aquatic Toxicity Unit of the Division of Water Quality." The December 2007 DMR for Outfall 001 and 002 states that the Chronic Toxicity testing was not conducted. However, this was marked incorrectly on the DMRs. Chronic Toxicity testing was conducted for both Outfall 001 and 002 in December 2007 and reported to Mr. Jimmy Overton of the NCDENR, DWQ on the required AT-1 forms on January 4, 2008. A copy of the January 4, 2008 chronic toxicity sampling results and AT-1 forms is included in Attachment C. As indicated on the AT-1 forms, the results of the chronic toxicity testing for both outfals resulted in passing tests. 6. "The Chronic Toxicity test for December 2008 was not reported on the DMR for Outfall 001 but it was noted on the DMR that the test was performed in the first week of January 2009. This violation may be addressed under separate cover by the Aquatic Toxicity Unit of the Division of Water Quality." Wachovia Site — Response to June 1 2009 NOV NPDES Permit No. NC0088226 Charlotte, Mecklenburg County, North Carolina ECS Project 08-3515© July 2, 2009 That is correct. As stated in response to question #2 above, due to ongoing construction activities during the months of November and December 2008 during each site visit there was no flow at Outfall 001 that would allow the collection of monthly NPDES or Chronic Toxicity testing until the last week of December 2008. Although the monthly NPDES samples were collected during the last week of December, due to the site closure for Christmas holidays and two separate sampling visits are required for the collection of chronic toxicity samples, collection of the required samples for chronic toxicity was not feasible in December. Therefore, the chronic toxicity samples were collected during the first week of January 2009 and reported in a January 28, 2009 Chronic Toxicity Sampling letter addressed to Mr. Jimmie Overton with the NCDNER, DWQ. A copy of the January 28, 2009 letter is included in Attachment D. 7. "The permittee has not submitted DMRs for Outfall 002 since May 2008. The permittee should complete the missing DRMs for Outfall 002, submit them to the Division of Water Quality and keep them on record, as well as request a permit modification to remove the outfall from the permit (completed since the inspection)." That is correct. As documented in a July 2, 2008 letter referenced as Outfall 002 Status and addressed to Mr. Jimmie Overton with the NCDENR, DWQ, discharge at Outfall 002 was discontinued prior to the May 2008 NPDES sampling. ECS understands the even though the July 2, 2008 notification letter was submitted, that DMRs were to be completed and submitted for Outfall 002 stating "No Flow", until the permit could be revised to remove the outfall. If required, ECS will complete the missing DMRs from May 2008 through April 2009 (the permit was revised on May 14, 2009) and submit to the NCDENR for their records. ECS and Wachovia/Childress Klein appreciate the NCDENR's understanding and guidance with this project and hope that the above responses successfully address the documented deficiencies. It is ECS and Wachovia/Childress Klein's intent to fully comply with the sampling and reporting requirements as stated in NPDES permit 0088226 for the site. ECS and Wachovia/Childress Klein believe that the documented deficiencies have been corrected and will be complete and correct on future DMRs and other permit requirements. If you have any questions concerning this report or this project, please contact us at (704) 525- 5152. Sincerely, ECS CAROLINAS, LLP (09-• Travis L. O'Quinn Environmental Scientist ORC Grade 1, Certification No. 992194 Attachments er A. Smith, P.G. Principal Geologist cc: Mr. Allen Holloway — Wachovia Bank, N.A. c/o Childress Klein Properties (w/attach) Mr. Rusty Rozzelle — MCWQP, 700 North Tryon Street, Suite 205, Charlotte, NC 28202 (w/attach) 4 ATTACHMENT A CALIBRATION DOCUMENTATION FOR FLOW METERS /2009 14:07 FAX 7042789616 HERSEYMETERS Meter Size & Model: Customer: Cu, Order# Stock Part #; ByPass Mainline Notes: 444e sey4 Meter Test Report Part #: 55) Spec.; ieneklevef) wio#. rsil 9 55 -3 By -Pass Position: Calibrator Restar Calibrator Register Assembler's Name: By -Pass Line # Calibrator r1foTTnatJon Meter Total Accuracy Percentage Calculation: Take the to Tank Reading Tester: Ragister(s) aduation ln Hersey Serial tO; S bC)‘0\ Cus, Serial# 001/002 No. of Meters in Line: Test Date: MFM 11 (only) 350 psi Tes: Check ox Flow Rate (9pm) er e and divideby the ountofvoLume in the•tank then multiply the result by 100. QF 00033(former QMP ell) • Revlsed 09/08/2008 05/20/2009 14:07 FAX 7042789616 HERSEYMETERS VI002/002 Meter Site & Model: Customer: Gus. Order -l-lerseyfi4et Meter Test Report Pe\ Part #: Spec.: 5 Q -XQ 1 Hersey Serial #: (end -level) W/0/f: ``Z cciSS 3 Tester: Gus. Serial# Sy -Pass Position; Line # : t No. of Meters in Line: Stock Part #: Assembler's Name- Test Date: Reglster(s) Callbrator Information : Graduation In nline ib Bypass #sinline t3yra 5 Bypass Calib R Unit of luieasu MFM II (only) 350 psi Test Chsck Box: Meter Tank n L.ine Pass Total Readin Accuracy Notes: Accuracy Percentage Calculation: Take the total meter registration and divide it by the amcunt-of volume in -the tank then multiply•the result by 100. QF 00033(formar QMP 1811) Revi5ed 08/0 /2©©e ATTACHMENT B DECEMBER 31, 2008 LETTER DOCUMENTING NO FLOW FOR NOVEMBER 2008 December 31, 2008 Mr. Jimmie Overton Chief, Environmental Sciences Section North Carolina Department of Environment and 'Natural Resources Division of Water Quality 1621 Mail Service Center Raleigh.. North Carolina 27699-1621. Rel ncc: u achstreet I3TS NPDES Permit Nt, . NC00882261001 Charlotte, Mecklenburg County, North Carolina. ECS Project 08-3515D Dear Mr, Overton: ECS Carolinas, LEP. (ECS) is w° ttngto inform the North Carolina Department of Environment and Natural Resources (NCDENR), Division of Water Quality that no effluent samples were collected at the \Vachovia- Tryon Street BTS site (NPDES Permit No. NC0088226) during the month of November, 2008. Although multiple site visits were conducted in an arteinpt to collect the required monthly samples, during each occasion either the system was shut off due to reconfiguring of discharge piping for the ongoing site construction, or the sampling location was inaccessible. The monthly sampling for December was conducted. After receipt of laboratory results, the Permit required reporting will be submitted to the NCDENR in Januamy 2009. If you have any questions concernir. Sincerely, ECS CAiROLl IAS, LLP cc: Wachovia ,13a. NCDENR NCDENR - NCDENR - NCDENR this letter or this project, please_contact us a A. c/o Mr, Allen Ili. oway - Childress Klein Properties sville Regional Office - Attn: Mr. Mike Parker Dille Regional Office - Attn: Mr, John Lesley tit Files - Division of Water Quality 8702 Red Oak lionlevar;d, Suite r1, Charlotte, Nortlln Carol na 28217 , 704-52 - 15 • l av 25-71713 + ea se° v-eesliatsited.con ATTACHMENT C CHRONIC TOXICITY SAMPLING REPORT DATED JANUARY 4, 2008 ECS CAROLINAS, LLP Geotechnical Construction MaterialsEnvironmental W4ER301D1AO January 4, 2008 Mr. Jimmie Overton Chief, Environmental Sciences Section North Carolina Department of Environment and Natural Resources Division of Water Quality 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Reference: Chronic Toxicity Sampling NPDES Permit No. NC0088226/001 Wachovia-Tryon Street NPDES PermitNo. NC0088226 Charlotte, North Carolina ECS Project 08-3515D Dear Mr. Overton: ECS Carolinas, LLP. (ECS) is pleased to provide the North Carolina Department of Environment and Natural Resources, Division of Water Quality with the original copy of the laboratory analytical results ("AT" forms) of the effluent water samples collected in the month of December 2007 from Outfall 001 and Outfall 002 at the Wachovia-Tryon Street site (NPDES Permit No. NC0088226/001). As you will see, the December 2007 sampling event resulted in passing test for chronic toxicity from each outfall. lf you have any questions concerning this report or this project, please contact us at (704) 525-5152. Sincerely, ECS CAROLINAS, LLP Brent M. Project Geologist NC WPCSOCC PhysicaUChernical Grade 1 ertificate No. 987060 air, pal Geologist Attachments: Laboratory Analytical Results and Chain of Custody Records ("AT" forms cc: Wachovia Bank, N.A. — c/o Mr. Allen Holloway — Childress Klein Properties NCDENR — Mooresville Regional Office — Attn: Mr. Mike Parker NCDNER — Mooresville Regional Office — Attn: Mr. John Lesley 8702 Red Oak Boulevard, Suite A, Charlotte, North Carolina 28217 • 704-525-S152 • Fax: 704-525-7178 - www.ecslirnited.corn Pace Analytical ServIces, Inc. 2225 Riverside Dr, Asheville, NC 28604 (828)254-7175 December 21, 2007 Mr. John Lair ECS Charlotte 8702 Red Oak Blvd, Suite A Charlotte, NC 28217 RE: Project: Wachovia Bioassay Pace Project No.: 929823 Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 Dear Mr. Lair Enclosed are the analytical results for sample(s) received by the laboratory between December 11, 2007 and December 14, 2007. The results relate only to the samples included in this report. Results reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the body of the report. Inorganic Wet Chemistry and Metals analyses were performed at our Pace Asheville laboratory and Organic testing was performed at our Pace Huntersville laboratory unless otherwise footnoted. All Microbiological analyses were performed at the laboratory where the samples were received. If you have any questions concerning this report, please feel free to contact me. Project Manager Enclosures REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Pagel of 6 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28304 (828)254-7178 CERTIFICATIONS Project Wachovia Bioassay Pace Project No.: 929823 Pace Analytical Services, Inc. 5800 Kincey Ave. Suile 100 Huntersviile, NC 28078 (704)875-9092 Charlotte Certification IDs North Carolina Drinking Water Certification Number: 37706 North Carolina Wastewater Certification Number: 12 North Carolina Field Services Certification Number: 5342 South Carolina Certification Number. 990060001 South Carolina Bioassay Certification Number: 990060003 Tennessee Certification Number. 04010 Virginia Certification Number 00213 Florida/NELAP Certification Number: E87627 Kansas Certification Number, E-10364 LouisianafLELAP Certification Number, 04034 Asheville Certification IDs Florida/NELAP Certification Number. E87648 L©uisianalLELAP Certification Number. 03095 New Jersey Certification Number. NC011 North Carolina Drinking Water Certification Number: 37712 North Carolina Wastewater Certification Number: 40 North Carolina Bioassay Certification Number. 9 Pennsylvania Certification Number: 68-03578 South Carolina Certification Number. 99030001 South Carolina Bioassay Certification Number: 99030002 Tennessee Certification Number: 2980 Virginia Certification Number. 00072 Eden Certification IDs North Carolina Drinking Water Certification Number: 37738 Virginia Drinking Water Certification Number: 00424 North Carolina Wastewater Certification Number. 633 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except In Full, without the written consent of Pace Analytical Services, Page 2of6 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr. 9800 Kincey Ave, Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)875-9092 ANALYTICAL RESULTS Project Wachovia Bioassay Pace Project No.: 929823 Sample: 001 COMPOSITE Lab ID: 929823001 Collected: 12110107 12:55 EFFLUENT Parameters Results Units Report Limit DF C.dubta Pass/Fail Chronic Date: 12(21/2007 08:54 AM PASS 1 REPORT OF LABORATORY ANALYSIS Page 3 of 6 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc., Pace Analytical Services, Inc, 2225 Riverside Dr, Asheville, NC 28804 (828)254-7176 ANALYTICAL RESULTS Project: Wechovia Bioassay Pace Protect No.: 929823 Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 (704)875-9092 Sample: 002 COMPOSITE EFFLUENT Lab ID: 929823002 Collected: 12/1 tltt37 Parameters Results Units Report Limit DF C.dubia Pass/Fail Chronic Date: 12/21/2007 08:54 AM PASS 1 REPORT OF LABORATORY ANALYSIS Page 4 of 6 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Pace Analytical Services, Inc. Pace Analytical Services, inc. 2225 Riverside Dr. 9800 Kincey Ave. Suite 100 Asheville, NC 28804 Huntersville, NC 28078 (828)254-7176 (704)675-9002 ANALYTICAL RESULTS Project Wachovia Bioassay Pace Project No,: 929823 Sample: 2ND 001 COMP. EFF. Lab ID: 32982352{ 3 oilected: 12/13/07 11:35 Parameters Results Units Report Limit DF C.dubia Pass1Fail Chronic -- 1 Date: 12/21/2007 08:54 AM REPORT OF LABORATORY ANALYSIS Page 5 of 6 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Pace Analytical Services, Inc. Pace Analytical Services, Inc. 2225 Riverside Dr. 9800 Kncey Ave. Suite 100 Asheville. NC 28804 Huntarsv#Ile, NC 28078 (826)254-7176 (704)875-9092 ANALYTICAL RESULTS Project Wachovia Bioassay Pace Project No.: 929823 Sample: 2N© 002 COMP.EFF. Parameters Lab ID: 929823004 Collected: 12113/07 11:05 Results Units Report Limit PF C•dubia Pass/Fail Chronic - 1 Date: 12/21/2007 0S:54 AM REPORT OF LABORATORY ANALYSIS Page 6 of 6 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Pace Analytical Services, Inc. 9800 Kincey Avenue, Suite 100 Huntersville, NC 28078 Phone: 784,875.9092 Fax: 704.875.9091 Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828154.7176 Fax: 828.252.4618 www.00004trirOxicity Report AT-1 Form Chronic Pass/Fail and Acute LC50 Date 12/12/07 North Carolina CerfodaphniaChronic Pass/Pail Reproduction Toxicity Test CONTROL ORGANISMS 1 2 3 4 5 6 # Young Produced Adult (L)ive (D)ead Effluent% 90 TREATMENT 2 ORGANISMS # Young Produced Adult (L)ive (D)ead PH D.O Control Treatment Control Treatment 25 1st 7.4 7.9 s t a iSt 8.1 30 7.5 _ 7.9 7.8 n 7.9 7.7 29 29 29 2 3 4 29 28 1st L7.3 7.7 S t a 1st 8.4 8.4 24 7.2 n d 8.2 8.2 28 county nbur Cmrn8nt as No1 AeratedU Environmen Div. of Water Quail N.G. DENR 1621 Mall Service Center Raleigh, North Carolina 27699-162 7 8 9 10 11 1 25 32 78 30 29 2nd 7.5 s E a 2nd 7.5 7.6 &O 8.2 7.7 7,9 8.0 LCSO/Acute Toxicity_Test (Mortality exoressed es %, comblnIna replicated LC50= 95% Confidence % - ism Tested: Ceriodaphnia dubia Asheville Certification IDs NC Wastewater 40 NG Drinking Water 37712 SC 99030 FL NELAP E87648 Meth Moving Avg, Spearman d of 04, Determination Problt Other Test Duration (Hour REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc. 28 0A, 29 26 OlhGrw1e 10 11 12 31 39 29 hronto Test R6stdts a culated t 0.96 Tabular t % Reduction Treatment 2 0,0 Ave.Re Treatment 2 29.10 ASS FAIL X Sample 2 12 Hardness(mg/1) Som. Cond, rumhos) Chlorine (mgti) Sammie temp, at teceiot (C1 Concentration Mortality 2 7 130 708 Note: Please leis, This 'on also ontrol High Conc. start/end D.O. NC Wastewater NC Drinking Wate SC FL NELAP 12 37706 99006 E87627 Pace Analytical Services, Inc. 9800 Kincey Avenue, Suite 100 Huntersville, NC 28078 Phone: 704.875,9092 Fax: 704.875.9091 Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176 Fax: 828.252.4618 wwwoTtOxicity. Report AT-1 Form Chronic Pass/Fail and Acute LC50 Date 12/12/07 MAI ORIGINAL TO: North Carolina CeriedephniaChronic Pass/Fail Reproduction Ti*city Test CONTROL ORGANISMS 1 2 3 4 5 6 # Young Produced Adult (L)ive (D)ead Effluent% 90 TREATMENT 2 ORGANISMS # Young Produced Adult(D)ead pH D.0 Control Treatment Control Treatment 29 27 lst 7.4 7.8 S t a 1st 23 29 7.4 7.7 E 8.1 8.4 7.9 8.0 28 28 4 28 1st 7.3 7.9 S t a 1st 8.4 8.5 7,5 7.9 d 8.3 8.0 25 33 les Not Aerated Unle EnvironmentalErwronmenta1 Soisnces Branch Div. of Water Quality N.C. DENR 1621 Mali Service Center Raleigh, North Carolina 27699-1621 7 8 9 10 11 , 12 31 7 28 2nd 7„5 7.9 29 28 7.5 8.0 S t E 1 n 2nd .0. 8.3 7.8 8.0 26 LC50/Acule Toxicity Test (Mortality exiaressed es % comb)nina replicates) LC50-= % 95% Confidence % Organism Tested: Ceriodaphnia dubi As v e io NC Wastewater 40 NO Drinking Water 37712 SC 99030 FL NELAP E87648 29 30 10 11 12 28, 28 erwise Noted h Resu d Tabular t % Reduction % o Mortality 2 2. Avo Rep3 Tr 2 Treat ht 11.3 CO t arrlsrns brood PASS FAIL T a at 2\12\07 ollection a Date ample 1 2 0 07 Sample 2 Samoel Type/Duration Grab Comp, Duration Sample Sample 2 x x 24hr 22hr Hardness (mg/) Seec. Cond. iumhos) Chlorine (mg/1) Same temp, at receipt (C) 2 7 <0.1 2.9 Meth Moving Avg. Spearmafl od of Determination Probit Other Concentration Mortality EP T ABO RAT RY ANALYSIS Test Duration (Hours): 0 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc, Note:Please Complete This Section also charIntte Qertific.tion !Ds NC Wastewater 12 NC Drinking Water 37706 SC 99006 FL NELAP E87627 Ti AQUATIC TOXICOLOGY LABORATORY CRAIN-OF-CUSTODY AND FIELD ANALYSIS FORM The Chain -of -Custody is a LEGAL DOCUMENT All relevant fields must be completed accurately. CLIENT/FAC NAME: ( v C UNT • NPDES INFORMATION ON THIS FORM LS REQUIRED BY STATE AND FEDERAL AGENCIES. TEST REQUIREMENTS (please check the appropriate test type and species required) Test Type Acute, circle the appropriate test duration: 24 48 96 Chronic, 7-days Pass/Fail, dilution required; Full Range Definitive, dilutions required: Other, specify; PURCHASE ORDER STA OUTFALL E#: SAMPLE TYPE Composite sample Start date: End date; Samples er Chilled during col ' ?: If chilled, specify ten Grab sample Start time: 0:7) S End time: .72 : 1,4 Date: SAMPLE CONDITIO Sa e aceAnapical flea) pro7nekls 18atheaU minnow) ysidopsis bahia (Mysid shrimp) idia boyllina (Inland silverside) PACE ANALYTICAL SERVICES, INC. 2225 RIVERSIDE DRIVE ASHEVILLE, NC 28804 PHONE: (828) 254-7176 FAX: (828) 252-4618 1.'„ 99 a t1O orination, above outfafl, a weir, effluent outfa DI/ 9'who 00 F/Nr Note: Rinse containers with the samplesainple before filling, Pack samples in loose ice, Samples must be received at PACE at or below 4°C. Samples should not be frozen, ALLCOOlrev.0, 18 Mar05 AQUATIC TOXICOLOGY LABORATORY CHAIN -OF -CUSTODY AND FIELD ANALYSIS FORM The Chain -of -Custody is a LEGAL DOCUMENT All relevant fields must be completed accurately. CLIENT/FACILIT NAME: EC PURCHASE ORDER:4 STA OUTFAL INFORMATION ON THIS FORM IS REQUIRED BY STATE AND FEDERAL AGENCIES. TEST REQUIREMENTS (please check the appropriate test type and species required.) Test Type Acute, circle the appropriate test duration: 24 48 96 Ceriodaplznia dubia (Water flea) Chronic, 7-days Pimpba1es pro:netts (Fathead minnow) PassfFail, dilution required: Mysidopsis bahia (Mysid shrimp) 11 Range Definitive, dilutions required: Mmidia beyyllina (Inland silverside) i; specify: Spe ies Analytical' PACE ANALYTICAL SERVICES, INC 2225 RIVERSIDE DRD ASHEVILLE, NC 28804 PHONE: (828) 254-7176 FAX: (828) 252-4618 13120 SAMPLE TYPE Composite sample Start date: End date: Samples per Chilled dining collection?: Start time: End time: ps If chilled, specify temperature: Date: Grab sample Time: Sample Information Sample location: (after chlorination, above outf Approximate v Number of con Iected for testing: leti for testing: Total residual chlorine (mg : Temperature at time of collection (°C) Method of transport to PACE: A)/ cl e-DrAA, Note: Rinse containers with the sample before filling. Pack samples in loose ice. Samples must be received at PACE at or below 4°C. Samples should not be frozen. All.CD01 rev, 0, 15MarOS AQUATIC TOXICOLOGY LABORATORY C1 IN-O -CUSTODY AND FIELD ANALYSIS FORM The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately. FORMATION ON TFTSS FORM IS IEQUIRPD ➢Y STATF AND FE➢EIiALAG TEST REQUIREMENTS (please check the appropriate test type and species required.) Test Type Acute, circle the appropriate test duration: 24 48 96 Chronic, 7-days Pass/Fail, dilution required: Full Range Definitive, dilutions required: Other; specify: aeeAnaiytical riodaphnia dubia (Water flea) Pimephales promelas (Fathead minnow) Mysidopsis baltia (Mysid shrimp) Meuidla berylluta (Inland silverside) PACE ANALYTICAL SERVICES, INC. 2225 RIVERSIDE DRIVE ASHEVILLE, NC 28804 PHONE: (828) 254-7176 FAX: (828) 252-4618 398 SAMPLE TYPE omposi date: 1,1 d date: la pies per hour: Chilled daring collection?: e: End time: filled, specify temperature: Date: Grab sample Received on ice Sealed Cooler arnples Intact Project Number. Sarnple Number: Time: hod of tt ansport to PACE: : Rinse containers with the sample before filling. Pack samp Samples must be received at PACE at or below 4°C, Samples should not be frozen. ALLC001rev.0,18Mer05 AQUATIC TOXICOLOGY LABORATORY CHAIN -OF -CUSTODY AND FIELD ANALYSIS FORM The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately. CLIENT/FA `I.ITY NAME: 0t1NTY: INFORMATION ON THIS FO TEST REQUIREMENTS (pleas Test Tyne Acute, circle the appropriate test duration: 24 48 96 Chronic, 7-days Pass/Fail, dilution required: Full Range Definitive, dilutions required: Other; specify: PURC TAT OUTFAL WIRED BY STATE AND FEDERAL AGENCIES. e appropriate test type and species required.) aceAnalytica °dapluiia dttbia (Water flea) phales prvmelas (Fathead minnow) Mysidopsis bakia (Mysid shrimp) rridia beryllina (inland silverside) PACE ANALYTICAL SERVIC S, I C. 2225 RIVERSIDE DRIVE ASHEVILLE, NC 28804 PHONE: (828) 254-7176 FAX: (828) 252-4618 131`9 SAMPLE TYPE Samples per hour: Chilled during collection?: Lilted, specify temperature: Grab sample Date: Time: Method of iris Note: Rinse co to PACE: s with the sample before filling. Pack samples in loose ice. Sainples must be received at PACE at or below 4°C. Samples should not be frozen. ALLC001rev.0,18Mar05 Analytical° www.pacolaks.com ( t Section A uired Email To: Requested Due Date/TAT: Section 0 Required Client Information SAMPLE ID (A-Z, 0.9 / ; ) Sample lOs MUST BE UNIQUE No ction [3 Required Prof Copy To: Purchase Order No,: Matrix Codes MATRIX / CODE Drinking Water DW Water WT Waste Water WW Product P SolVSoIid SL 011 OL Wipe WP Air Aft Tissue TS Other OT n: CHAIN -OF -CUSTODY / Analytical Request Document The Chain-of.Custody Is a LEGAL DOCUMENT. All relevant fields must be completed accurately. COLLECTED COMPOSITE START you are accepting Pace`s NET 30 day payment terms COMPOSITE END/GRAB DATE PRINT Name of SAMPLER: SIGNATURE of SAMPLER: Section C nvoica Information Company Name: Address: Pece Quote Reference: Pace Pro)e0 Manager, Pace Profile fit Page: of 1136963 REGULATORY AGENCY NPDES (- GROUND WATER ( DRINKING WATER (- UST 1- RCRA F' OTHER Requested Analysis Filtered (YIN) ACCEPTED BY /-AFFILIATION DATE Signed (MM/DD/YY): At n SAMPLE CONDITIONS ATTACHMENT D CHRONIC TOXICITY SAMPLING LETTER DATED JANUARY 28, 2009 ECS CAI Geotechn :Eq©oN rt ®Il.,INAS, L11..P cal ® Construction Materials a Environmental Mr. Jimmie Overton Chief, Envirorunental Sciences Section North Carolina Department of Environment and Natural. Resources Division of Water Quality 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Reference: Chronic Toxicity Sampling NPDES Permit No. NC0088226/001 Wachovia-Tryon Street Charlotte, North Carolina ECS Project 08-3515D January 8, 2009 Dear Mr. Overton: ECS Carolinas, LLP. (ECS) is pleased to provide the North Carolina Department of Environment and Natural Resources, Division of Water Quality with the original copy of the laboratory analytical results ("AT" forms) of the effluent water samples collected in the month of January 2009 from Outfall 001 at the Wachovia-Tryon Street site (NPDES Permit No. NC0088226/001). As you will see, the January 2009 sampling event resulted in a failing test for chronic toxicity. Pursuant to NPDES requirements, ECS will perform a complete aquatic toxicity test for multiple concentrations from Outfall 001 during each of the first week of the next two monthly sampling events (February 2009 and March 2009) and a pass/fail test at the end of March 2009. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproductive or survival and lowest concentration that does have a detectable impairment of reproduction or survival. The source of the failing chronic toxicity testing is believed to be due to new construction causing elevated turbidity. If you have any questions concerning this report or this project, please contact us at (704) 525-5152. Sincerely, ECS CAROLINAS,1 J ,P Travis O'Quinn Project Scientist NC WPCSOCC Physical/Chemical Grade 1 Certificate No. 992194 A. Smith, P.G. ipal Geologist NC Licensed Geologist 41724 Attachments: Laboratory Analytical Results and Chain of Custody Records ("AT" forms) cc: Wachovia Bank, N.A. — c/o Mr. Allen Holloway — Childress Klein Properties NCDENR — Mooresville Regional Office — Attn: Mr. Mike Parker NCDNER — Mooresville Regional Office — Attn: Mr. John Lesley 8702 Red Oak Boulevard, 3uit:..��.—_._...� e A,, Charlotte, North Carolina 28217 * 704-525-5152 * Fax: 704-525-7178 * www.ecslimited.corn Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville, NC 28804 Pace Analytical Services, Inc. 9800 Kinsey Ave. Suite 100 Huntersvi le, NC 28078 (828)254-7176 (704)875-9092 January 21, 2009 Mr. John Lair ECS Charlotte 8702 Red Oak Blvd, Suite A Charlotte, NC 28217 RE: Project: Wachovia C.dubia Chronic Pace Project No.: 9235555 Dear Mr. Lair: Enclosed are the analytical results for sample(s) received by the laboratory between January 06, 2009 and January 09, 2009. The results relate only to the samples included in this report. Results reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the body of the report. Inorganic Wet Chemistry and Metals analyses were performed at our Pace Asheville laboratory and Organic testing was performed at our Pace Huntersville laboratory unless otherwise footnoted. All Microbiological analyses were performed at the laboratory where the samples were received. If you have any questions concerning this report, please feel free to contact me. Sincerely, Jennifer Jones Project Manager Enclosures cc: Mr. Roger Smith, ECS Charlotte REPORT OF LABORATORY ANALYSIS Page 1 of 4 This report shall not be reproduced, except in tutl, without the written consent of Pace Analytical Services, Inc., eac; Pace Analytical Services, Inc. 2225 Riverside Dr, Asheville, NC 28804 CERTIFICATIONS Project: Wachovia C.dubia Chronic Pace Project No: 9235555 (828)254-7175 Pace Analytical Services, inc. 9800 Kinsey Ave. Suite 100 Huntersvllle, NC 26078 (704)675-9022 Charlotte Certification lDs West Virginia Certification it: 357 Virginia Certification #: 00213 Tennessee Certification #: 04010 South Carolina Drinking Water Cert. #: 990060003 South Carolina Certification it: 990060001 Pennsylvania Certification #: 68-00784 North Carolina Wastewater Certification it: 12 Asheville Certification Ds West Virginia Certification #: 356 Virginia Certification #: 00072 Tennessee Certification it: 2980 South Carolina Certification #: 99030001 South Carolina Bioassay Certification #: 99030002 Pennsylvania Certification #: 68-03578 North Carolina Wastewater Certification it: 40 Eden Certification lDs Virginia Drinking Water Certification it: 00424 North Carolina Wastewater Certification #: 633 North Carolina Field Services Certification #: 5342 North Carolina Drinking Water Certification #: 37706 New Jersey Certification #: NC012 Loulsiana/LELAP Certification it: 04034 Kentucky UST Certification #: 84 Florida/NELAP Certification #: E87627 Connecticut Certification #: PH-0104 North Carolina Drinking Water Certification #: 37712 North Carolina Bioassay Certification #: 9 New Jersey Certification #: NC011 Massachusetts Certification #: M-NC030 Louisiana&LEtAP Certification #: 03095 FloridalNELAP Certification #: E87648 Connecticut Certification #. PH-0106 North Carolina Drinking Water Certification #: 37738 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 2 of 4 Pace Analytical Services, Inc„ Pace Analytical Services, Inc, 2225 Riverside Dr, 9800 Kincey Ave. Suite 100 Asheville, NC 28804 Huntersvitie, NC 28075 (828)254-7175 (704)875-9092 ANALYTICAL RESULTS Project: Wachovia C.dubia Chronic Pace Project No.: 9235555 Sample: 001 grab Parameters Lab ID: 9235555001 Collected: 01/06/09 15:15 Results Units Report Limit DF C.dubia Pass Fail Chronic FAIL Date: 01121/2009 02:15 PM REPORT OF LABORATORY ANALYSIS Page 3 of 4 This report shell not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc,. Pace Analytical Services, Inc. 2225 Riverside ©r. Asheville, NC 28804 (825)254.7176 ANALYTICAL RESULTS Project: Wachovia C.dubia Chronic Pace Project No.: 9235555 Pace Analytical Services, Inc. 9800 Klncey Ave. Suite 100 Huntersville, NO 28078 (704)875-9092 Sample: 2nd grab 001 Lab ID: 9235555002 Collected: 01/09/09 16:30 Parameters Results Units Report Limit DF C.dubia Pass/Fail Chronic Date: 01 /21 /2009 02:15 PM REPORT OF LABORATORY ANALYSIS Page 4 of 4 This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Pace Analytical Services, Inc. 9800 Kincey Avenue, Suite 100 Fiuntersvilie, NC 28078 Phone: 704,875,9092 Fax: 704.875.9091 Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828,254.7176 Fax: 828,252,4618 '#'fit` iPi{a$k5.R8ity Report AT-1 Form Chronic Pass/Fail and Acute LC50 Date 1/7/2009 NPDESftNC 0088226 Pipe # 001 atory Pet#crrrnirtg Test PACE Analytical Services, Inc. for in OR NAL TO North Carolina Cerlodaphnia Chronic Pass/P CONTROL ORGANISMS 1 # Young Produced Adult (L)ive (D)ead Effluent% 90 TREATMENT 2 ORGANISMS # Young Produced Adult (L)ive (D)ead PR D.Q. Control Treatment Control Treatment 29 1 1st 7.6 8.0 S 2 23 7.5 E a d 1st 8.4 8,2 6.8 6.5 4 4 1 st 5 '1' 7.7 8.2 S 7,9 8.0 E n a 1st 8.1 7.8 6.4 6.6 County Mecklenburg Rank Sum=78.00 1-Tailed Critical=120.00 Aerated Unless Otherwise Noted Environmental Sciences Branch Div. of Water Quality N.C. DENR 1621 Mail Service Center Raleigh, North Carolina 27699-1621 6 7 26 7 2nd 7„4 8.© S E t n a 2nd 8 9 10 11 12 24 7.6 7.9 7,9 7.8 .C50/Acvte Toxicity Test (Mortality expressed as 9 LC5O 95% Confidence c/© bining replicates) Organism Tested: Ceriodaphnia dubia &sheville_certification IDs NC Wastewater 40 NC Drinking Water 37712 SC 99030 FL NELAP E87648 Meth Moving Avg. Spearman d of alnation Probit Other Test Duration (Hours): 25 27 24 Collection Start ©ate Sample f 116109 26 Chronic Test R alculated t Tabular t Reduction Treatment 2 Sample 2 Hardness (mgfl) Spec. Cone. (umhos) Chlorine (mg/1 Sample tempat receipt (C} Concentration Mortality REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc. 5 Avg. Rep n 4.20 Treatment 2 0 FAL 119\09 Please to This Section nt Charlotte Certlfitxatiot IDs NC Wastewater 12 NC Drinking Water 37706 SC 99006 FL NELAP E87627 North Ca 111 Beverly Eaves Perdue Govemor Mr, Roger A. Smith ECS Carolinas, LLP 8702 Red Oak Blvd.; Suite A Charlotte, North Carolina 28217 Dear Mr, Smith: NCDENR r ment of Environment: and Natural .Resourecs Division of Water Quality Coleen H. Sullins Director May 13, 2009 Subject: Notice of Violation - Effluent Limitations Tracking #: NOV-2009-LV-233 Wachovia Tryon Street BTS NPDES Permit No. NC0088226 Mecklenburg County Dee Freeman Secretary A review of the January 2009 self -monitoring report for the subject facility revealed a violation of the following parameter: Pipe Parameter Reported Value Permit Limit 001 Total Suspended Solids 709 mg/1 (daily maximum) 30 Ing/1 (daily maximum) Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent, You may contact Mr. John Lesley of this Office for additional information. If you have questions concerning this matter, please do not hesitate to contact Mr. Lesley or me at 704/663-1699. ly, 1->) Robert B. Krebs Surface Water Protection Regional Supervisor cc: Point Source Branch Mecklenburg County r Quality Protection Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-1699 Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 Internet: www,ncwaterquality:org An Equal Opportunity Affirmative Action Employer — 50'/o Recycled/10%Q Post Consumer paper North Carolina Natural!! Alf NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H, Sullins Director Governor TRAVIS O'QUINN ENVIRONMENTAL SC ENTIST ECS CA.ROLINAS, I.LP 5702 RED OAK BLVD SUITE A CHARLOTTE NC 28217 May 7, 2009 DWQ- ce Was Pww iien Subject: Acknowledgement of Permit Modification Request for NC0088226 Wachovia Bank NA Wachovia Tryon Street BTS Mecklenburg County Dear Mr. O'Quinn: The Division of Water Quality acknowledges receipt of your perniit modification request and has assigned it to a reviewer. The reviewer will perform a detailed review and contact you with a request for additional information if necessary. To ensure the maximum efficiency in processing permit applications, the Division requests your assistance in providing a timely and complete response to any additional information requests. Please note at this tune, processing permit applications can take as long as 60. 90 days after receipt of a complete application. If you have any questions, please contact Charles Weaver at 919-807-6391, or via email at charles.weaver@ncdenr.gov. If the reviewer is unavailable, you may leave a message, and they will respond promptly. PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT. Sincerely, Dina Sprinkle Cc: Central Files e Surface Water Protection Section Permit application file NC0088226 1617 e4 Se rice Center, Raleigh, North Carolina 27699-1617 Location: 512 N, Salisbury St, Raleiah, North Carolina 27604 AiREPOUVICOSOM ECS CAROLINAS, LLP Geotechnical •Ty Construction Mat a Environmental May 6, 2009 Mr. Tom Belnick North Carolina Department of Environment and Natural Resources Division of Water Quality 512 N. Salisbury Street Raleigh, North Carolina 27604 Reference: Outfall 2 Status Wachovia-Tryon Street BTS NPDES Permit No. NC0088226/001 Charlotte, North Carolina ECS Project 08-3515D Dear Mr. Beinick: ECS Carolinas, LLP. (ECS) is writing to inform the North Carolina Department of Environment and Natural Resources (NCDENR), Division of Water Quality (DWQ) that as of May 2008, Outfall 002 located at the Wachovia-Tryon Street BTS site (NPDES Peiiuit No. NC0088226/001) has not been discharging and will no longer be discharging. The groundwater associated with Outfall 002 is now being directed to Outfall 001. Therefore, please remove Outfall 002 from NPDES Permit No. NC0088226/001. If you have any questions concerning this report or this project, please contact us at (704) 525-5152. Sincerely, ECS CAROL AS, LLP avis ©'Quinn nvironmental Scientist 'ger Szrith, P.G. ncipal Geologist cc: Wachovia Bank, N.A. — c/o Mr. Allen Holloway NCDENR — Mooresville Regional Office — Attn: NCDENR — Mooresville Regional Office — Attn: NCDENR — Raleigh — Division of Water Quality RECEIVED DENR - WATER QUALITY POINT SOURCE BRANCH — Childress Klein Properties Ms. Marcia Allocco Mr. John Lesley — Attn: Ms. Susan Moore 8702 Red Oak Boulevard, Suite A, Charlotte, North Carolina 28217 • 704-525-5152 • Fax: 704-525-7178 • www.eeslirnited.com ECS CAROLIiA!, LLP Geotechnical • Co. 7ia • Environmental Mr. Tom Belnick North Carolina Department of Environment and Natural Resources Division of Water Quality 512 N. Salisbury Street Raleigh, North Carolina 27604 Reference: Outfall 2 Status Wachovia-Tryon Street BTS NPDES Permit No. NC0088226/001 Charlotte, North Carolina Erg Project OS-3515D Dear Mr, Belnick: May 6, 2009 MAY 7 2009 DW Surfac P i n ECS Carolinas, LLP. (ECS) is writing to inform the North Carolina Department of Environment and Natural. Resources (NCDENR), Division of Water Quality (DWQ) that as of May 2008, Outfall 002 located at the Wachovia-Tryon Street BTS site (NPDES Pen -nit No. NC0088226/001) has not been discharging and will no longer be discharging. The groundwater associated with Outfall 002 is now being directed to Outfall 001. Therefore, please remove Outfall 002 from NPDES Permit No, NC0088226/001. If you have any questions concerning this report or this project, please contact us at (704) 525-5152. Sincerely, ECS CAROL 11 lAS, LLP TT avis O'Quinn nvironmental Scientist ger Smith, P.G. incipal Geologist cc: Wachovia Bank, N.A. — c/o Mr. Allen Holloway — Childress Klein Properties NCDENR — Mooresville Regional Office — Attn: Ms. Marcia Allocco NCDENR — Mooresville Regional Office — Attn: Mr. John Lesley NCDENR — Raleigh — Division of Water Quality — Attn: Ms. Susan Moore 87it2 Red Oak C3o rlev trd, Suite A, Charlotte, North Carolina 28217 • 704-525-5 52 • Fax: 704-525-7178 • wv r eslln lted.ccnn NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary March 20, 2009 Mr. Roger A. Smith ECS Carolinas, J .T,P 8702 Red Oak Blvd.; Ste. A Charlotte, NC 28217 SUBJECT: Retraction of NOV-2009-LR-0011 Wachovia Tryon Street BTS NPDES Permit Number NC0088226 Mecklenburg County Dear Mr. Smith: D Surface of Pr Thank you for taking the time to speak with me and for your e-mail received in our office on March 20, 2009 in response to the subject notice of violation (NOV). The information you provided showed the facility made a good faith effort to submit the December 2008 discharge monitoring report (DMR) within the statutory time frame, but the DMR became lost during its transport to our Central Files office. Based upon this information the NOV has been retracted and its record has been removed from our data systems. Monitoring data provided along with your e-mail has been entered into our compliance monitoring database. As you noted in our conversation, there was a typographical error on the original NOV that placed the facility in Gaston County. The error has been corrected on this retraction letter. I apologize for any confusion this may have caused. Thank you for your prompt attention to this matter and the diligence you have shown in getting it resolved. If you have any questions about this letter, please contact me at (919) 807-6398, or via e-mail at bob.sledge@ncmail.net. Sincerely, Bob Sledge Western NPDES Unit cc: Central Files NPDES Enforcement files 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807.63001 FAX: 919.807.64921 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity \ Affirmative Action Employer One NorthCarolina Naturally • NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary March 18, 2009 CERTIFIED MAIL 7003 0500 0002 6819 3927 RETURN RECEIPT REQUESTED Mr. Roger A. Smith Wachovia Bank, NA 8702 Red Oak Blvd.; Ste. A Charlotte, NC 28217 SUBJECT: NOTICE OF VIOLATION: NOV-2009-LR-0011 Wachovia Tryon Street BTS NPDES Permit Number NC0088226 Gaston County Dear Mr. Smith: leer ; 14. This is to inform you that the Division of Water Quality has not received your discharge monitoring report (DMR) for December 2008. Water quality regulations require that monthly monitoring reports shall be filed no later than 30 days after the end of the reporting period for which the report is made. Failure to submit reports as required will subject the violator to the assessment of a civil penalty of up to $25,000 per violation. To prevent further action, please submit this report to the Division's Central Files office at the letterhead address within 15 days or notify this office as to any problem preventing its timely receipt. You will be considered noncompliant with the self -monitoring requirements of your NPDES permit until the report has been submitted. Additional action, including the assessment of civil penalties, may be taken if the report is not submitted within the time frame specified above. This letter additionally provides notice that this office will recommend the assessment of civil penalties if future reports are not received within the required time frame during the next twelve (12) reporting months. The Division must take these steps because timely submittal of discharge monitoring reports is essential to the efficient operation of our water quality programs. We appreciate your assistance in this matter. If you have any questions about this letter or discharge monitoring reports, please contact Bob Sledge at (919) 807-6398. Sincerely, Tom Belnick, Supervisor NPDES Western Unit cc: NPDES Enforcement File Central Files 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location:512 N. Salisbury St. Raleigh, North Carolina 27604 • Phone: 919-807-63001 FAX: 919-807-6492 \ Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer One I\ o:thCarolina Naturally Duke Energy Center (DEC) 550 S. Tryon St., Charlotte NC 28202 Wastewater Treatment System 10/21/09 Handouts: 1. AquaPura Wastewater Treatment System located at DEC Rm#P834 2. AquaPura Groundwater Process Diagram 3. CMUD Letter of Approval to discharge wastewater to sanitary sewer 4. MSDS for chemicals used in AquaPura Wastewater Treatment System a. Vitec 4000 Antiscalant b. TES 210 Bisulfate S. Full Size Set of Plumbing Drawings for DEC and The Green Wastewater TEMPEST ENVIRONMENTAL SYSTEMS, INC, rtk + village C,i•:r: G: Chapel HO NC '27517 (USA) weal: (a �JA E3 r`-009 150)2 (a a): ,r7,0096. WRi1 www.RquapurH.com CONFUL)1 NTIFII.i DF.S1C;N Wastewater Treatment System & Layout for "Wachovia First Street" Project / Childress Klein Properties -- Charlotte, NC Water Purification Based on 61. gpm Feed Flow Rate (95% Recovery — 5"/" Reject) 28 April 2008 Contaminated with Volatile Organic Chemicals (VOCs), Turbidity, Iron, Hardness and Silica CO NC TANK HUH Levet AIR3'.TR IPP ER AIR STRIPP ER HGri LEVEL xe LW LEVEL F R AA1KTANK Vll UV EL Fero P0IIIP CR1152 ?EG P IX L0 4O0St PERMEATE STORAGE AIR ETRIPP ER NG TANK R LEV EL P-Toonk TE SR O 13000 ANTE4C01RNT 6WU1..F ITE INJECTION 0030`TY,0N U I.TRAE 1LTPAT01 N VTART. aT00 $IG NAL 0 MY CONTACTS PERU TANK LOW LEVEL DRAIN 3.13GPM PERMEATE STORAGE Ul_ T RAEIL. T RAT I ON UNI'i lI TANR, OW' PU0AP rw tt t12- $6' ESICPNI. COPSI '!T) PCY 1J. COO LMP3 TTINI ER /tAKELIP I.NATER CONTROLLED BY BOXBGM (Feed Pumps Supplied by Others) TEMPEST ENVIRONMENTAL SYSTEMS, INC. 429 Meadow -neat Village Circle Chapel Hill, NC 275'1 7 (USA) Tel: (919) 537-0092 • Fax: (919) 537.0096 CONFIDENT"IAL DESIGN Wastewater Treatment System & Layout for "Wachovia First Street" Project / Childress Klein Properties — Charlotte, NC Water Purification Based on 61 gpm Feed Flow Rate (95% Recovery — 5% Reject) Contaminated with Volatile Organic Chemicals (VOCs), Turbidity, Iron, Hardness and Silica 2,500 Gallon EQ Tank #1 Chlorine Chemical Dosing Pump (Controlled by Motor Starters on Feed Pumps Supplied by Others) Storage Tank 4000 Gallon (Supplied by Others) Feed From Wells Pump 81 5 HP, 3 Phase, 460 V (CRI15-2-3P) Notes: 1) All lines are 3" Sch 80 PVC, and drawings 4"otfurther details 2) All repressunzatton pumps ate 61+ G 3) Pump I is controlled by float switch 4) Pumps 02, 63 & 44 are controlled by 5) Drawing not to scale. Process layout 7) Component by-pass lines not shown, ('91 "Lu s 60"W x 102"H) Air Stripper (LP-5) Blower Pump n2 10 HP, 7 5 HP, 3 Phase, 3 Phase, 460 V 460 V Solenoid Valve Bypass Ti (CRI15-4-3P) (Controlled by High In Cooling Tower T'ankl Bladder Tank 4 Reverse Osmosis (RO #1 System) TFSRO.72K (CRI I5-10-3 P-1) 20 HP, 3 Phase,460 V RO Reject'', r,::. Line (20%) unless otherwise PM L3 40-100 psi 3SOGallon EQ Tank #I (Rejec (heated See tndividuu pressure switches with bladder tanks (50-711 psi). is representational, and subject to change with conditions. but will he plumbed and metered to sanitary dram Zeolite Media Filter Reverse Osmosis (RO #2 System) TESRO-13K (CR15- 16-3 P) 5 HP, 3 Ph, 460 V Pump 43 1 HP, 3 Phase, 460 V 1 C", Hi 12- 15-3 P) oat: Permeate) 45"x45"x63 Static Mixor Antisoalant & De-Clor Chemicals &Dosing Pumps der Tank rump n4 1 HP, 3 Phase, 460 V (C1114-4 b3 P) Water Meter RO Reject 5"/ir) to Drai 28 April 2008 OF Sump Pump Reject Return 3r'4 HP I Phase, 120 V (1F 311. System (UF-Bo:-18) (171"L x 38x 60"H) 95% Treated Waste Water to the Cooling Tower 8) One System Interlock Control Panel for 3 pumps and I blower plus alarm lock -out for Arr Stripper transfer pump and an blower Control panel not shown. • Each pump will have onloff light indicator arrd an emergency shut off switch. • Breakers and motor starter according to each pump horsepower rating, • Pump 1 on/off operation will he control by a high and low level sensor, in at the feed 2,500 gallon EQ storage tank. RO 02 controlled by a high and low level sensor in EQ tank 42 0 CIIA August 1 200E; l„isa Lathetri Cnilcirese, Kelp iPtcoartos Ceireoie SeLei Chailc,fte, NC 232(12 e1-1.517, Grouridviiater n yi, First Street Gooliita tovaers DOar 145, tat hafft: *YoLir request submitted 'ttyi "Ternoest Environmental Sync tn Cli50%iirge tri3td grot,.inchw.Rter (*r LI50 Viiar.:k0Vi,a's First. Street Protect lot:Laud at South ry Sleet, harlatte, North Colin, is granter -I ria,suel upon the ic:illiotiving information and ceriaitions, The Spucial Use disiritverge to the seritary wIoriginate from -the (lista of treatlai creitternriated groundvaater 3ti inakeop water to: cooling toi.vers. tail may result in trileetic.ttl froiri thiesta canting LOwill,S and up to 5% ort treated eiontatrtinared grourucirofia,iter hieing dischurgod directly to the s:_triitany sewer. It is etate.0 in. the :coyest letter that up to 74O gallons, por day 1,9priiit rLu CWate ViI h.e pumped arid treateci v„,ith the trtotalloci treatment syStern, lt wtas. prc)joetod that Si7.3,4423 get or 957sLi cif this water will he recovered tor use .as mkup Veer r thoiIu towers and iho reinaininfj of the groLindwater or 4392 mid will Ott tlisolta.roeici directly to tine sanitary seivver, At ,coritarn'.,;nated priOunaiwate,r diaohargu to the sanstury sewer shall be treated inefere dtscharoe .rrtay tieke piaLo, Tbe contaminated proundrovialter oi,rreritty boir Crscherged to the fit"orrn-yirer sewor under NPDE$ permit No,. NCIDCIFl.Fi2( and testett for Mu volatile organic chernicalis and other pollutants listod orii the DrY1Fis provided. IL waS irtritinated in the request letter that chronic tOXiCiTV •naci tailed twice cluietn volatila organic orternlcals. Tito rentovai -ate by the tretatniont systern, indieeted in the request leiter, 'for thiesre VQCs will bo greater than 99%.„ TIre treatment system consists of the filing r uiprrient i,11 Air Stripper system: lilt Zeolite tiltel. SrsiiSterrrai I A.rti-Scalarit Dosing sytcri: 1 Sodium Metubisulfite Dosing system:. lIthrra-Filitretion system; (2) tilerireirse Osmosis i;RO) 5),,•siterris; 4i fileatiessurirratidit Puriitps.: i2 '‘1,91E.,,,,r MeteriTotalizer: (21 Li0 Storia.ge Tanks,: 11 -25-0Q gallon EO Slorai)e Tank for feed to ,einti:e system. A Lrecess tioi,ividiagyarri and ‘vaior treatment yout War vere stilitrnittoO with the request. conditions icr chrge ot treated groundwater to tftu sarlitary se.wer consist ,of ti instellabon anit maintenance ,of Chartotterifyletkleriburg tittititlesiCtilloll approved .,..;ter MItirS: 21 Operation ,irvi rriawteneince c)f. the tireutinent system nonsistirig of the ,equipment listed 'above 50 the VOC parameters Itud n the request letter and the NPOFS permit retrain beiroviii NC 2.t, thresholds, Any disctiarge, writheut permission,. to the surtitary sewer exneedIng the NC 2L limits of the \IOC paramotars shall he considered Violarir3n ot the Sower Use OrclirtannerSLIOl .Systerri Protection 42:22 'tiVesliviart Chive Charlote, NC 2U-2t Prone: 70.r11336-4407' Charotto-NlecklenhLici Utilities CHARLOTIESki .An ntItesting ,'Jf the treated groi.indweter ,..hoi:fig discharged to the s.anitary WOr far parameters listed 'HI the NPDES PerfEntlied iri 30 d'AYScfSizirtuz ar-",1 co .mrneetioniefit dischafqe, 'The. testing S'hill be befformert t,it;inq approved vi.iasWittii.trior inetriods turd in 40 CFR 136 cind submitted to 8ysteni Pietect.ioe at the addrerso listed bel 14) Upon sJOrnitid ef the testing,. inctLide a steterhent certifyi:no that no tile-tree:red croundwator h been or wilt he diseharged 'Lei the sat-Otary sewer, This GortificLitiefi shall be sighed tysi an iewhofized representative! ,c,:f Vilischovia First Projetit. This cior.ificatioil of Profter oPerKtion iheintenance shall be resikiroittrAl ariN,all'y' szisstirIrt7e that the treelnieihi sies1:0111 remeins fl service, Wachoiria'ri authorized reipresentativesi shah' assist C1U the estalatishmerit of a hIlmq Jceount based or, the approprzlu type of water meters.. These meters will be 1Jsed to record the clis,r:lerq-e of the tre;et.eid 'groundwater to. the sanitary cwr f IF 'aoaRy qi.jFstioli. or need further assietencie„ piEm-setoflhie. T !ILION y3LJ far yON.Iropoperation Sirrere.;y Tim Downs Compliance SupCevisor Fnvirortmenti rvliiAriagerneot-Systern Protee.tirsh Chatiotte-tvleckleriPirrp: Ulilitics Regina Dob5o1 Cruor, Lr1v1rorlrnnt& CornpILnc Martager ar'ilernl:'-.-3;ecir, 4222 l.Ve.,$t-nort Drive Charotte NC 28217 Phone: 704,33E-4407 F. ;?(.114:11,36-07.7 Charlitte-Mec.'entau.Tg TEMPEST ENVIRONMENTAL SYSTEMS, INC. 1414 Raleigh Road, Suite 425 • Chapel Hill, NC 27517 (USA) Tel: (919) 537-0092 • Fax: (919) 537-0096 VVeb: www.aquapura.com MSDS PRODUCT DATA TES 210 LIQUID DECHLORINATION AGENT DESCRIPTION AND USE TES 210 is a highly concentrated sulfite solution designed to react with chlorine present in various process waters, By acting as a reducing agent, the product is used to chemical neutralize chlorine. The product is not catalyzed and therefore is acceptable for use in membrane treatment systems as wet as other process water systems. TES 200 is manufactured with only NSF certified drinking water additives; ANSI/NSF Standard 60. CHEMICAL FEEDING AND CONTROL TES 210 is typically fed neat directly from the shipping container or can be prediluted in a chemical feed tank. Stainless steel or plastic is recommended for the chemical feed system. Copper, copper alloys, and aluminum metallurgies for the chemical feed system must be avoided, TES 210 can be controlled using a chlorine residual test, An ORP controller can be used to automate the feed and control of this dechlorinating agent. TES 210 is typically fed at a rate of 8.8 ppm product per ppm of chlorine residual to be neutralized for RO membrane application. Control ranges can vary depending upon both makeup water characteristics and system operating conditions and will be specified by the technical representative servicing the facility. TYPICAL PROPERTIES Appearance...............................................................................Colorless liquid Odor.............................................................................. Pungent, characteristic Specific Gravity, 1.331-1.339 FlashPoint.,...,.................................................................................. None pH(undiluted)......................................................................................2.0-5.0 FreezePoint....................................................................................0°C(32°F) SAFETY AND HANDLING TES 210 may be toxic by ingestion and because of its acidic nature, is corrosive to mucous membranes, Do not take internally. Do not induce vomiting. If ingested, drink at least two (2) glasses of water and get medical attention. Contact with eyes causes severe irritation or burns, If eyes are contacted, immediately flush with clear water for 15 minutes and get medical attention, For skin contact, wash with soap and water. For additional information, see the Material Safety Data Sheet provided with this product. PACKAGING TES 210 is packaged in 55, 30, 15 and 6 or 5 gallon, non -returnable plastic containers, www.aquapura.com MATERIAL SAFETY DATA SHEET Prepared to U.S. OSHA, CMA, ANSI and Canadian WHMIS Standards PART I What is the material and what do I need to know in an emergency? 1. PRODUCT IDENTIFICATION TRADE NAME (AS LABELED): CHEMICAL NAME/CLASS: SYNONYMS: PRODUCT USE: SUPPLIER/MANUFACTURER'S NAME: ADDRESS: CHEMTREC EMERGENCY NO.: BUSINESS PHONE: DATE OF PREPARATION: VITEC® 4000 Not Applicable Organic Acid, Terpolymer Antiscalant/Antifoulant AVISTA TECHNOLOGIES 140 Bosstick Blvd San Marcos, CA 92069 1-800-424-9300 (United States) 1-703-527-3887 (International) (760) 744-0536 May 13, 1999, Reviewed April 6, 2009 CHEMICAL NAME Acrylic Polymer bis-phosphonic Acid Inorganic Acid Aromatic Carboxylic Acid Salt 2. COMPOSITION and INFORMATION ON INGREDIENTS CAS # % wAv Proprietary Proprietary Proprietary Water and Sodium Hydroxide. Sodium Hydroxide is added for pH adjustment only and does not contribute any additional hazards to this product. ACG1H-TLV TWA STEL mg/m3 mg1m3 10-20 NE 1-10 NE < 0.1 < 1 NE Balance NE NE NE NE NE EXPOSURE LIMITS IN AIR OSHA-PEL TWA mg/m3 NE NE NE NE STEL mg/rn3 NE NE 3 (vacated 1989 PEL) NE NE IDLH rrig/m3 NE NE 1000 NE NE OTHER mg/m3 NE NE NIOSH REL: TWA 1 STEL = 3 NE NE NE = Not Established. C = CeiIing Lmit. See Section 16 for Definitions of Terms Used, NOTE: All WHMIS information is included; it is located in appropriate sections based on the ANSI Z400.1-1998 format. SF DRINKING WATER TREATMENT ADDITIVES CLASSIFIED BY NATIONAL SANITATION FOUNDATION' TO ANSI/NSF 60 ON SEPTEMBER, 2004 AS STANDARD DRINKING WATER TREATMENT CHEMICAL FOR USE IN REVERSE OSMOSIS SYSTEMS AT A MAXIMUM LEVEL OF 7 mg/I (11 KN) VITEC 4000 NSF PROPRIETARY MSDS PAGE 1 OF 8 3^HAZARD UDENTIFICATION EMERGENCY OVERVIEW: This product baclear, amber liquid with mild odor, This product may slightly irritate contaminated tissue, This product is neither reactive nor flammable, Emergency responders must wear personal protective equipment (and have appropriate fire -extinguishing protection) suitable for the situation to which the are responding, SYMPTOMS OF OVEREXPOSURE BY ROUTE OF EXPOSURE: The most significant routes are inhalation and contact with akin and eyes. The symptoms of overexposure iothis product are eofollows: INHALATION: Inhalation of mists o/ sprays of this product may irritate the noso, thnoa, or other tissues of the respiratory system, Symptoms of such mxpuouna may include hng|ing, coughing, sneezing, and difficulty breathing. CONTACT WITH SKIN or EYES: Depending on the duration and concentration of overexposure, eye or skin contact may cause slight irritation. Symptoms of skin contact may include redness and irritation, Prolonged or repeated overexposure tothis product may cause dermatitis (dry, red skin), Repeated overexposure to this product may cause sensitization; subsequent exposures tovery small amounts may cause allergic reaction, Symptoms may include hng||ng, redneos, and rapid development of eczema. Symptoms of eye contact may include irritation, tingling, and tearing. 30N ABSORPTION: Skin absorption is not o significant mute of exposure for any component ofthis product, INGESTION: Ingestion is not anticipated to be a likely route of exposure to this product, If this product is swo|lowad, it may cause gastric discomfort. Symptoms may include stomach painn, cramps, and gastritis. INJECTION: Accidental injection of this product can cause burning, reddening, and swelling inaddition tothe wound, HEALTH EFFECTS OR RISKS FROM EXPOSURE: An Explanation inLay Terms. ACUTE: Inhalation exposure may cause hng|ing, coughing, sneezing, and difficulty breathing, Symptoms of skin and eye contact may include redness and irritation, Ingestion may cause stomach pains, cramps, and gastritis, CHR0NkC� Prolonged or repeated skin overexposure to this product may cause dermatitis (dry. red skin), Repeated akin overexposure may cause sensitization, Symptoms may include tingling, redness, and rapid development ofeczema. TARGET ORGANS: Acute� Skin, eyes. Chronic: Skin. ofoccupational overexposure HAZARDOUS MATERIAL IDENTIFICATION SYSTEM ��W / /�-x-w_r / / (BLUE) A� ]7-»� (RED) � �r�,vuxx-�u�ou-x / o ` ' REACTIVITY PROTECTIVE . . ^.~ . .-.�. . .^- EQUIPMENT RESPIRATORY SEE SECTION o For routine induutria applications O See Section 16 for Definition of Ratinqs 8������~ UU ���o on What should /dbifahazardous situation occurs? 4,FIRST-AID MEASURES SKIN EXPOSURE* If this product contaminates the skin, immediately begin decontamination with running water, Remove exposed nrcontaminated clothing, taking care not tocontaminate eyes. Victim should seek immediate medical attention if any adverse exposure symptoms develop, EYE EXPOSURE: If this product enters the eyes, open victim's eyes while under gently running water. Use sufficient force to open eyelids, Have victim "roll" eyes. Minimum flushing is for 15 minutes, Victim must seek medical attention, INHALATION: If vapors, mists, or sprays of this product are inhaled, remove victim 10fresh air, If neoossary, use artificial respiration 10support vital functions, Remove orcover gross contamination toavoid exposure to rescuers. NTEC4000 NSF PROPRIETARY MSDS 4. FIRST -AID MEASURES (Continued) INGESTION: If this product is swallowed, CALL PHYSICIAN OR POISON CONTROL CENTER FOR MOST CURRENT INFORMATION. DO NOT INDUCE VOMITING. Have victim rinse mouth with water, if conscious. Never induce vomiting or give a diluent (e.g., water) to someone who is unconscious, having convulsions, or unable to swallow, If contaminated individual is convulsing, maintain an open airway and obtain immediate medical attention. Victims of chemical exposure must be taken for medical attention if any adverse effects occur. Rescuers should be taken for medical attention if necessary. Take a copy of label and MSDS to physician or health professional with victim. MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: Preexisting dermatitis, other skin conditions, and respiratory conditions may be aggravated by exposures to this product. RECOMMENDATIONS TO PHYSICIANS: Treat symptoms and eliminate exposure. 5. FIRE -FIGHTING MEASURES FLASH POINT: Not applicable. AUTOIGNITION TEMPERATURE: Not applicable. FLAMMABLE LIMITS (in air by volume, %): Lower: Not applicable. Upper: Not applicable. FIRE EXTINGUISHING MATERIALS: This material will not contribute to the intensity of a fire. Use extinguishing material suitable to the surrounding fire. Water Spray: YES Carbon Dioxide: YES Foam: YES Dry Chemical: YES Halon: YES Other: Any "ABC" Class UNUSUAL FIRE AND EXPLOSION HAZARDS: When involved in a fire, this material may decompose and produce irritating fumes and toxic gases (e.g„ carbon monoxide, carbon dioxide, and phosphorus and sodium oxides). Explosion Sensitivity to Mechanical Impact: Not applicable. See Section 16 for Explosion Sensitivity to Static Discharge: Not applicable. Definition of Ratings SPECIAL FIRE -FIGHTING PROCEDURES: Incipient fire responders should wear eye protection. Structural firefighters must wear Self -Contained Breathing Apparatus and full protective equipment, Move containers from fire area if it can be done without risk to personnel. If possible, prevent runoff water from entering storm drains, bodies of water, or other environmentally sensitive areas. NFPA RATING HEALTH OTHER REACTIVITY 6. ACCIDENTAL RELEASE MEASURES SPILL AND LEAK RESPONSE: Uncontrolled releases should be responded to by trained personnel using pre -planned procedures, Proper protective equipment should be used, In case of a spill, clear the affected area and protect people, Releases of this material may be slippery. In the event of an incidental release of this product, personnel should wear gloves and safety glasses (or goggles). In the event of a non -incidental release, Minimum Personal Protective Equipment should be Level D: lab -gloves, chemical resistant apron, boots, and splash goggles. Respiratory protection should not be necessary. Level B, which includes the use of Self -Contained Breathing Apparatus, should be worn when oxygen levels are below 19.5% or are unknown. Absorb spilled liquid with polypads or other suitable absorbent materials, Decontaminate the area thoroughly. Prevent spill rinsate from contamination of storm drains, sewers, soil or groundwater. Place all spill residue in a suitable container and seal. Dispose of in accordance with applicable U.S. Federal, State, or local procedures or appropriate standards of Canada (see Section 13, Disposal Considerations). PART III How can I prevent hazardous situations from occurring? 7. HANDLING and STORAGE WORK PRACTICES AND HYGIENE PRACTICES: As with all chemicals, avoid getting this product ON YOU or IN YOU. Wash thoroughly after handling this product. Do not eat or drink while handling this material. Avoid generating mists and sprays of this product. Remove contaminated clothing immediately. STORAGE AND HANDLING PRACTICES: All employees who handle this material should be trained to handle it safely. Open containers carefully on a stable surface. Empty containers may contain residual liquid; therefore, empty containers should be handled with care. VITEC 4000 NSF PROPRIETARY MSDS PAGE 3 OF 8 7.HANDUUNG and STORAGE (Cont'nued) STORAGE AND HANDLING PRACTICES (continued): Store containers in a coo` dry louobon, away from direct sunlight, sources of intense heat, or *here freezing is possible, Shzm away from incompatible materials (nee Section 10. Stability and Reactivity), Material should be stored in secondary uontoinern, or in a diked area. an appropriate. Storage and use areas should be covered with impervious materials. Storage areas should be made offire-resistant materials, Keep container tightly closed when not in use, If appropriata, post warning signs in storage and use areas. Inspect all incoming containers before storage, toensure containers are properly labeled and not damaged, PROTECTIVE PRACTICES DURING MAINTENANCE OF CONTAMINATED EQUIPMENT: Follow practices indicated in Section G (Accidental Release Measures). Make certain that application equipment is locked and tagged -out safely if necessary. Collect all hnsatesand dispose ufaccording 1oapplicable U.S. Federal, State, orlocal procedures mrappropriate Canadian standards, MAXIMUM USE LEVEL: 7?mg/L 8^ EXPOSURE CONTROLS ~ PERSONAL PROTECTION VENTILATION AND ENGINEERING CONTROLS: Use with adequate ventilation hoensure exposure levels are maintained below the limits provided inSection 2(Composition and Information on|ngnedients), Ensure eyewash/safety shower stations are available near areas where this product |oused. RESPIRATORY PROTECTION: None needed under normal conditions of use, Use N|C)SH approved respirators if ventilation is inadequate to control mints. Maintain airborne contaminate concentrations below guidelines listed in Section 2 (Composition and Information on Ingredients). If respiratory protection is neaded, use only protection authorized in the U�S. Federal OSHA Standard (29 CFR 1910134), applicable U,S. State regulations, or the Canadian CSA Standard Z94.4-93 and applicable standards of Canadian Provinces, Oxygen |evo|n below 19.5% are considered 0LH by OSHA. In such eUmoopharen, use of afuUfacepieoopressure/demand SCBAnrefull facepiene. supplied air respirator with auxiliary self- contained air supply is required under OSHA's Respiratory Protection Standard (1910,134-1998), EYE PROTECTION: Use approved safety goggles or safety g|osueo, as described in OSHA 29 CFR 1910.133, Splash goggles with ufooeshio|dmay beneeded 8splash hazards exist, HAND PROTECTION- Wear chemical impervious gloves (e.g,rubber, Neop»ene), BODY PROTECTION: Use body protection appropriate for task (e.g., Tyvek suit, rubber apron) to protect from splashes and sprays, HK4|3PERSONAL PROTECTIVE EQUIPMENT RATING: C 9, PHYSICAL and CHEMICAL PROPERTIES RELATIVE VA'ORDENS��� DENSITY SPECIFIC GRAVITY: 11-12 SOLUBILITY |NWATER: Soluble. VAPOR PRESSURE, mmHq6D2OcC� 18 ODOR THRESHULD�Not available, COEFFICIENT OFO|LIWATER DISTRIBUTION (PARTITION COEFFICIENT): Not available, APPEARANCE AND COLOR: This product isaclear, amber liquid with amild odor, HOW |ODETECT THIS SUBSTANCE hyaminqpnnPer1iea>: The color and odor may act aawarning pnaperUosassociated with this product, water, EVAPORATION RATE (water =1):Approximately I. MELT|NG/FREEZ|NGPO|NT: AppmxhnatelyO"C BOILING POINT: Approximately 1OO"C pH: 5G—G1 10, STABILITY and REACTIVITY STABILITY: Stable. DECOMPOSITION PRODUCTS: Thermal decomposition cdthis product may generate carbon monoxido`carbon dioxide, phosphorus and sodium oxides, MATERIALS WITH WHICH SUBSTANCE |SINCOMPATIBLE: Strong bases, oxidizers, water reactive materials. HAZARDOUS POLYMERIZATION: Will not occur, CONDITIONS TO AVOID: Avoid contact with incompatible chemicals, VITEC4DWONSF PROPRIETARY K8SDS PAGE 4OF8 PART IV Is there any other useful information about this material? 11. TOXICOLOGICAL INFORMATION TOXICITY DATA: The following toxicology information is available for components greater than 1 % in concentration, ACRYLIC POLYMER: 1-(HYDROXETNYLIDENE)-BIS-PHOSPHONIC ACID (continued): LD50 (oral, rat) > 5000 mg/kg TDLo (subcutaneous, mouse) 200 mg/kg/female 13 days after LD50 (dermal, rabbit) > 2000 mg/kg conception; Reproductive. Specific Developmental Abnormalities: l Eye irritation -rabbit inconsequential ir musculoskeletasystem TDLo (subcutaneous, mouse) = 1400 mg/kg/female 11-17 days after Skin irritation -rabbit: practically non -irritating conception; Reproductive: Effects on Embryo or Fetus: fetotoxicity 1-(HYDROXETHYLIDENE)-BIS-PHOSPHONIC ACID: (except death, e,g., stunted fetus), Specific Developmental TDLo (intraperitoneal, mouse) = 200 mg/kg/female 7 days post; Teratogenic Abnormalities: musculoskeletal system effects LD50 (oral, mouse) = 1800 mg/kg TDLo (intraperitoneal, mouse) - 40 mg/kg/female 7 days post; Reproductive effects SUSPECTED CANCER AGENT: The other components of this product are not found on the following lists: FEDERAL OSHA Z LIST, NTP, IARC, and CAL/OSHA, and therefore are neither considered to be nor suspected to be cancer -causing agents by these agencies, IRRITANCY OF PRODUCT: This product can be irritating to contaminated tissue, SENSITIZATION TO THE PRODUCT: This product may cause sensitization; subsequent exposures to very small amounts may cause allergic reaction. REPRODUCTIVE TOXICITY INFORMATION: Listed below is information concerning the effects of this product and its components on the human reproductive system. Mutagenicity: This product is not reported to produce mutagenic effects in humans. Animal mutation data are available for the Aromatic Carboxylic Acid Salt component of this product; these data were obtained during clinical studies on specific animal tissues exposed to high doses of this compound, Embryotoxicity: This product is not reported to produce embryotoxic effects in humans. Teratoclenicity: This product is not reported to cause teratogenic effects in humans. Clinical studies on test animals exposed to relatively high doses of the Aromatic Carboxylic Acid Salt component of this product provided teratogenic data. Reproductive Toxicity: This product is not reported to cause reproductive effects in humans. Clinical studies on test animals exposed to relatively high doses of the Aromatic Carboxylic Acid Salt component of this product provided reproductive toxicity data. A mutagen is a chemical which causes permanent changes to genetic material (DNA) such that the changes will propagate through generational lines. An embryotoxin is a chemical which causes damage to a developing embryo (Le, within the first eight weeks of pregnancy in humans), but the damage does not propagate across generational lines. A teratogen is a chemical which causes damage to a developing fetus, but the damage does not propagate across generational lines. A reproductive toxin is any substance which interferes in any way with the reproductive process. BIOLOGICAL EXPOSURES INDICES (BEIsl: Currently, there are no Biological Exposure Indices (BEIs) for any component of this product. tatio 12a. ECOLOGICAL INFORMATION ALL WORK PRACTICES MUST BE AIMED AT ELIMINATING ENVIRONMENTAL CONTAMINATION. ENVIRONMENTAL STABILITY: The components of this product will decompose into other organic and inorganic compounds over time under normal environmental conditions. Additional environmental data for components are as follows: INORGANIC ACID: Food Chain Concentration Potential: Very Low Chronic Hazard Level: The abundance of phosphates threatens algal blooms in fresh and some salt waters Waterfowl toxicity: No data available Biological Oxygen Demand (BOD): None Water solubility: 548 g/ 100 cc (cold). Persistence: If released to bodies of water, while acidity may be reduced readily by natural water hardness minerals, the phosphate may persist indefinitely. If released to soil, the acid will be neutralized to some degree with adsorption of the proton and phosphate ions also possible. However, significant amounts of acid will remain for transport down toward the groundwater table. Mobility\Soil Adsorption: When spilled onto soil, this acid will infiltrate downward, the rate being greater with lower concentration because of reduced viscosity. During transport through the soil, this acid will dissolve some of the soil material, in particular, carbonate -based materials. This acid will be partially neutralized; however, some will remain to leach to groundwater. Upon reaching the groundwater table, the acid will continue to move in The direction of groundwater flow. A contaminated plume will be produced with dilution and dispersion serving to reduce the acid concentration, EFFECT OF MATERIAL ON PLANTS or ANIMALS: This product may be harmful to animal life if large volumes of it are released into the environment. Refer to section 11 (Toxicological Information) for information on the effects of components of this product on test animals. VITEC 4000 NSF PROPRIETARY MSDS PAGE 5 OF 8 12a. ECOLOGICAL INFORMATION (Continued) EFFECT OF CHEMICAL ON AQUATIC LIFE: This product may be harmful to contaminated aquatic life (especially if large volumes of it are released into an aquatic environment. Additional aquatic toxicity data are available as follows: ACRYLIC POLYMER: EC50 (algae) = 72.4 mg/Li 72 hours ECK (Daphnia magna) > 1040 mg/Li 48 hours LC50 (Salm° gairdnen) > 1100 mg/L/ 96 hours 1-(HYDROXETHYLIDENE)-BIS-PHOSPHONIC ACID: NOEC (rainbow trout) 96 hours = 180 mg/L NOEC (Daphnia magna water flea) 48 hours = 125 mg!L NOEC (Selenastrum algae) 96 hours = 5.2 mg/L 1-(HYDROXETHYLIDENE)-BIS-PHOSPHONIC ACID (continued): EC50 (Daphnia magna water flea) 48 hours = 242 rng/L EC50 (Selenastrum algae) 96 hours = 1.9 mg/L INORGANIC ACID: TLm (immersion, mosquito fish) = 138 ppm/ 24-96 hours/ turbid water Chronic Hazard Level: The abundance of phosphates threatens algal blooms in fresh and some salt waters 12b. AQUATIC TOXICITY INFORMATION Ceriodaphnia 48-hour renewal bioassay; No mortality was observed at the highest concentration tested: 0% mortality at 1000 mg/L Fathead minnow 96-hour renewal bioassay. No mortality was observed at the highest concentration tested: 0°4, mortality at 1000 mg/L Daphnia 48-hour static renewal bioassay: No mortality observed at the highest concentration tested: 0% mortality at 1000 mg/L. 13. DISPOSAL CONSIDERATIONS PREPARING WASTES FOR DISPOSAL: Waste disposal must be in accordance with appropriate U.S. Federal, State, and local regulations or with regulations of Canada. This product, if unaltered by the handling, may be disposed of by treatment at a permitted facility or as advised by your local waste regulatory authority. EPA WASTE NUMBER: Not applicable to wastes consisting only of this product. 14. TRANSPORTATION INFORMATION THIS MATERIAL IS NOT HAZARDOUS AS DEFINED BY 49 CFR 172.101 BY THE U.S. DEPARTMENT OF TRANSPORTATION, PROPER SHIPPING NAME: Not applicable. HAZARD CLASS NUMBER and DESCRIPTION: Not applicable. UN IDENTIFICATION NUMBER: Not applicable. DOT LABEL(S) REQUIRED: Not applicable. PACKAGING GROUP: Not applicable. NORTH AMERICAN RESPONSE GUIDEBOOK NUMBER (1996): Not applicable. NATIONAL MOTOR FREIGHT CLASSIFICATION: # 70 MARINE POLLUTANT: No component of this product is listed as a marine pollutant by the D.O.T. (49 CFR 172.101, Appendix B). TRANSPORT CANADA TRANSPORTATION OF DANGEROUS GOODS REGULATIONS: THIS MATERIAL IS NOT CONSIDERED AS DANGEROUS GOODS. 15. REGULATORY INFORMATION ADDITIONAL U.S. REGULATIONS: U.S. SARA REPORTING REQUIREMENTS: The components of this product are subject to the reporting requirements of Sections 302, 304 and 313 of Title III of the Superfund Amendments and Reauthorization Act, as follows: COMPONENT SARA 302 (40 CFR 355, Appendix A) SARA 304 (40 CFR Table 302.4) SARA 313 (40 CFR 372.65) Formaldehyde Yes Yes Yes Inorganic Acid No No Yes U.S. SARA THRESHOLD PLANNING QUANTITY: There are no specific Threshold Planning Quantities for the components of this product. The default Federal MSDS submission and inventory requirement filing threshold of 10,000 Ibs (4,540 kg) therefore applies, per 40 CFR 370.20, U.S. CERCLA REPORTABLE QUANTITY (RQ): Inorganic Acid = 5000 Ib (2268 kg). VITEC 4000 NSF PROPRIETARY MSDS PAGE 6 OF 8 15. REGULATORY INFORMATION (Continued) U.S. TSCA INVENTORY STATUS: The chemicals in this product that are listed by CAS # are listed on the TSCA Inventory, OTHER U.S. FEDERAL REGULATIONS: Not applicable. U.S. STATE REGULATORY INFORMATION: Components of this product are covered under specific State regulations„ as denoted below: Alaska - Designated Toxic and Hazardous Substances: Inorganic Acid. California - Permissible Exposure Limits for Chemical Contaminants: Inorganic Acid. Florida - Substance List: Inorganic Acid. Illinois - Toxic Substance List: Inorganic Acid. Kansas - Section 302/313 List: Inorganic Acid, Massachusetts - Substance List: Inorganic Michigan - Critical Materials Register None. Minnesota - List of Hazardous Substances: Inorganic Acid. Missouri - Employer Information/Toxic Substance List: Inorganic Acid, New Jersey - Right to Know Hazardous Substance List: Inorganic Acid. North Dakota • List of Hazardous Chemicals, Reportable Quantities: Inorganic Acid. Acid, Substances: Inorganic Acid. CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65): This product contains trace amounts of Formaldehyde (less than 0.1%). Formaldehyde (gas) is on the California Proposition 65 lists. Because Formaldehyde is present in this product as a liquid in solution and is below the action level, the requirements of California Proposition 65 are not applicable. ANSI LABELING (Z129.1): CAUTION! MAY CAUSE SENSITIZATION, MAY BE IRRITATING IF INHALED OR SWALLOWED. MAY CAUSE SKIN AND EYE IRRITATION, Do not taste or swallow, Do not get on skin or in eyes, Avoid breathing mists or sprays. Keep container closed, Use only with adequate ventilation. Wash thoroughly after handling. Wear gloves, goggles, and suitable body protection if necessary. FIRST -AID: In case of contact, immediately flush skin or eyes with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. If inhaled, remove to fresh air. If ingested, do not induce vomiting. Get medical attention if any adverse effects occur, IN CASE OF FIRE: Use water fog, dry chemical, CO2, or "alcohol" foam. IN CASE OF SPILL: Absorb spill with inert material and place in suitable container, Consult Material Safety Data Sheet for additional information. ENVIRONMENTAL HAZARDS: Do not discharge effluent containing this product into streams, ponds, estuaries, oceans or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance, contact your State Water Board or Regional Office of the EPA. ADDITIONAL CANADIAN REGULATIONS: CANADIAN DSUNDSL INVENTORY STATUS: The chemicals in this product that are listed by CAS # are listed on the DSUNDSL Inventory. OTHER CANADIAN REGULATIONS: Not applicable. CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA) PRIORITY SUBSTANCES LISTS: Formaldehyde (a trace component of this product) is on the Second Priority Substances List, CANADIAN WHMIS SYMBOLS: Not applicable. Pennsylvania - Hazardous Substance List: Inorganic Acid, Rhode Island - Hazardous Substance List: Inorganic Acid. Texas - Hazardous Substance List: Inorganic Acid. West Virginia - Hazardous Substance List: Inorganic Acid. Wisconsin - Toxic and Hazardous PREPARED BY: DATE OF PRINTING 16. OTHER INFORMATION CHEMICAL SAFETY ASSOCIATES, Inc. 9163 Chesapeake Drive, San Diego, CA 92123-1002 619/565-0302 July 23, 2009 VITEC 4000 NSF PROPRIETARY MSDS PAGE 7 OF 8 DEFINITIONS OF TERMS A large number of abbreviations and acronyms appear on a MSDS. Some of these which are commonly us CAS #: This is the Chemical Abstract Service Number which uniquely identifies each compound. ACGIH - American Conference of Governmental Industrial Hygienists, a professional association which establishes exposure limits. TLV - Threshold Limit Value - an airborne concentration of a substance which represents conditions under which it is generally believed that nearly all workers may be repeatedly exposed without adverse effect. The duration must be considered, including the 8-hour Time Weighted Average (TWA), the 15-minute Short Term Exposure Limit, and the instantaneous Ceiling Level (C). Skin absorption effects must also be considered. OSHA - U.S. Occupational Safety and Health Administration. PEL - Permissible Exposure Limit - This exposure value means exactly the same as a TLV, except that it is enforceable by OSHA. The OSHA Permissible Exposure Limits are based in the 1989 PELs and the June, 1993 Air Contaminants Rule (Federal Register: 58: 35338-35351 and 58: 40191). Both the current PELs and the vacated PELs are indicated. The phrase, "Vacated 1989 PEL," is placed next to the PEL which was vacated by Court Order. IDLH - Immediately Dangerous to Life and Health - This level represents a concentration from which one can escape within 30-minutes without suffering escape -preventing or permanent injury. The DFG - MAK is the Republic of Germany's Maximum Exposure Level, similar to the U.S. PEL NIOSH is the National Institute of Occupational Safety and Health, which is the research arm of the U.S. Occupational Safety and Health Administration (OSHA). NIOSH issues exposure guidelines called Recommended Exposure Levels (RELs). When no exposure guidelines are established, an entry of NE is made for reference. HAZARD RATINGS: HAZARDOUS MATERIALS IDENTIFICATION SYSTEM: Health Hazard: 0 (minimal acute or chronic exposure hazard); 1 (slight acute or chronic exposure hazard); 2 (moderate acute or significant chronic exposure hazard); 3 (severe acute exposure hazard; onetime overexposure can result in permanent injury and may be fatal); 4 (extreme acute exposure hazard; onetime overexposure can be fatal). Flammability Hazard: 0 (minimal hazard); 1 (materials that require substantial pre -heating before burning); 2 (combustible liquid or solids; liquids with a flash point of 38-93°C [100-200°F)); 3 (Class IB and IC flammable liquids with flash points below 38°C [100°F9); 4 (Class IA flammable liquids with flash points below 23°C [73°F] and boiling points below 38°C [100°F]. Reactivity Hazard: 0 (normally stable); 1 (material that can become unstable at elevated temperatures or which can react slightly with water); 2 (materials that are unstable but do not detonate or which can react violently with water); 3 (materials that can detonate when initiated or which can react explosively with water); 4 (materials that can detonate at normal temperatures or pressures). NATIONAL FIRE PROTECTION ASSOCIATION: Health Hazard: 0 (material that on exposure under fire conditions would offer no hazard beyond that of ordinary combustible materials); 1 (materials that on exposure under fire conditions could cause irritation or minor residual injury); 2 (materials that on intense or continued exposure under fire conditions could cause temporary incapacitation or possible residual injury); 3 (materials that can on short exposure could cause serious temporary or residual injury); 4 (materials that under very short exposure could cause death or major residual injury). Flammability Hazard and Reactivity Hazard: Refer to definitions for "Hazardous Materials Identification System". d include the following: FLAMMABILITY LIMITS IN AIR: Much of the information related to fire and explosion is derived from the National Fire Protection Association (NFPA). Flash Point - Minimum temperature at which a liquid gives oft sufficient vapors to form an ignitable mixture with air. Autoignition Temperature: The minimum temperature required to initiate combustion in air with no other source of ignition. LEL - the lowest percent of vapor in air, by volume, that will explode or ignite in the presence of an ignition source. UEL - the highest percent of vapor in air, by volume, that will explode or ignite in the presence of an ignition source. TOXICOLOGICAL INFORMATION: Possible health hazards as derived from human data, animal studies, or from the results of studies with similar compounds are presented. Definitions of some terms used in this section are: LD50 - Lethal Dose (solids 8 liquids) which kills 50% of the exposed animals; LC50 - Lethal Concentration (gases) which kills 50©% o1 the exposed animals; ppm concentration expressed in parts of material per million parts of air or water; mg/m3 concentration • expressed in weight of substance per volume of air; mg/kg quantity of material, by weight, administered to a test subject, based on their body weight in kg. Data from several sources are used to evaluate the cancer -causing potential of the material. The sources are: IARC - the International Agency for Research on Cancer; NTP - the National Toxicology Program, RTECS - the Registry of Toxic Effects o1 Chemical Substances, OSHA and CAL/OSHA. IARC and NTP rate chemicals on a scale of decreasing potential to cause human cancer with rankings from 1 to 4. Subrankings (2A, 2B, etc.) are also used. Other measures of toxicity include TDLo, the lowest dose to cause a symptom and TCLo the lowest concentration to cause a symptom; TDo, LDLo, and LDo, or TC, TCo, LCLo. and LCo, the lowest dose (or concentration) to cause lethal or toxic effects. BEI - Biological Exposure Indices, represent the levels of determinants which are most likely to be observed in specimens collected from a healthy worker who has been exposed to chemicals to the same extent as a worker with inhalation exposure to the TLV. Ecological Information: EC is the effect concentration in water. REGULATORY INFORMATION: This section explains the impact of various laws and regulations on the material, EPA is the U.S. Environmental Protection Agency. WHMIS is the Canadian Workplace Hazardous Materials Information System. DOT and TC are the U.S. Department of Transportation and the Transport Canada, respectively. Superfund Amendments and Reauthorization Act (SARA); the Canadian Domestic/Non-Domestic Substances Last. (DSLNDSL); the U.S. Toxic Substance Control Act (TSCA); Marine Pollutant status according to the DOT; the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund); and various state regulations. This section also includes information on the precautionary warnings which appear on the material's package label, VITEC 4000 NSF PROPRIETARY MSDS PAGE 8 OF 8