NC0089206_Permit (Issuance)_20121116

NPDES DOCUMENT SCANNING COVER :SHEET
NC0089206
Claire Sprayway
remediation site
NPDES Permit:
Document Type:
cPermit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Staff Report
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
November 16, 2012
This document is printed on reuse paper - izore any
content on the resrerse side

Beverly Eaves Perdue
Governor
Mr. Gary Myers
Safety and Environmental Manager
Plaze Incorporated
105 Boldt Lane
St. Claire, Mo 63077
Dear Mr. Myers:
ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Charles Wakild, P. E. Dee Freeman
Director Secretary
November16, 2012
Subject: Issuance of NPDES Permit
NC0089206
Claire Sprayway Site Remediation
Mecklenburg County, NC
Division personnel have reviewed and approved your application for issuance of the subject
permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15,
2007 (or as subsequently amended)
There are two changes from the draft permit sent to you on September 26, 2012:
1. Due to changes in NC Statutes, an Authorization to Construct, and an Engineer's
Certification are no longer required for this facility. The Supplement to Permit Cover
Sheet has been revised to reflect this.
2. The Daily Maximum limit for Tetrachloroethene has been corrected to 1,800 µg/ L
(from 18,000 µg/ L).
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable, you have the right to an adjudicatory hearing upon written request within thirty (30) days
after receiving this letter. Your request must take the form of a written petition conforming to Chapter
150B of the North Carolina General Statutes, and must be filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such demand is made,
this permit remains final and binding.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwaterquaiitv.orq
An Equal Opportunity l Affirmative Action Em loyer
1
None Carolina
Xatura/Iij

This permit is not transferable except after notifying the Division of Water Quality. The Division
may modify and re -issue, or revoke this permit. Please notice that this permit does not affect your legal
obligation to obtain other permits required by the Division of Water Quality, the Division of Land
Resources, the Coastal Area Management Act, or other federal or local governments.
If you have questions, or if we can be of further service, please contact Jim McKay at
[e-mail] or call [phone].
Sincerely,
Y LgArk
g.,7Charles Wakild, P.E.
cc: Mooresville Regional Office/Surface Water Protection
Central Files
Aquatic Toxicity Unit - via email
NPDES Unit
Mecklenburg County, Mr. Erin Hall - via email: [e-mail]
Liesch Associates, Inc. attn: Mr. Bruce Rehwaldt - via email: [e-mail]
Mr. Dave Cole - via email: [e-mail]

Permit NC0089206
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Plaze Incorporated
is hereby authorized to discharge wastewater from a facility located at the
Claire Sprayway, Inc. Remediation Project
2100 North Church Street
Charlotte
Mecklenburg County
to receiving waters designated as an unnamed tributary to Little Sugar Creek in the Catawba River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and
IV hereof.
The permit shall become effective January 1, 2013.
This permit and the authorization to discharge shall expire at midnight on June 30, 2015.
Signed this day November 16, 2012.
les Wakild, P.E., Director
ei4
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0089206 _
SUPPLEMENT TO PERMIT COVER SHEET
Plaze Incorporated is hereby authorized to:
1. To construct a 0.05 MGD groundwater remediation system to be located at the Former Claire Sprayway,
Inc. Remediation Facility [Now owned by Swofford Associates Epoxy Flooring] at 2100 North Church
Street, Charlotte in Mecklenburg County.
2. Discharge from said treatment works at the location specified on the attached map into an unnamed
tributary to Little Sugar Creek, a class C water in the Catawba River Basin.

Permit NC0089206
Fourier Claire lifg. GiiR
Latitude: 35 14' 3S' ti State GridtOuad: G15 NE/Charlotte East
Londtude: 80 49'14' V! }D-DideHOC: 0305010301
Rec.eivrngStream: UTtoUttleSurar SsreamCtass; C
Creek
Drainage Basin: Catawba River Basin Sub -Basin: 03-08-34
nwa To+: JT•
NortFhacility
Location
not to snR:
0. ,%Che,ry0 10 Ldtk)
UOar Cr40k
OLMe!I 001
[Discharge to
Storm Sewer
NPOrE Permit No. NC0089206
Me ale nburg County

Permit NC0089206
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge treated
groundwater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below:
11 t 1�,�(c
' P E� r f�.j
-. ' {'-.
! �� ...
�;. u.
0. ®.ltll\G
.
�� '�� i .- p ,: r
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t
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REQ
e..1i..�, c � -t-,. .�... 'Stl
�, t -
- ,,,���
Mon` hly
`ge
t - "` a' yt-
(:'_lY�easureol ent
• rAcif envy '
I 2 ;... ..
, 5,amplgv ype�
_
r.L_.__.:3..4.,_.
Sample
, v Location
.�" ..-G.
#� +Maxiimui
it•i......
Abe
L.. 1....__1MS...r-.n
.. .. .. .. ...._.. ,x•.—
Flow 1
0.05 MGD
_..__J.L✓ �. ....
Continuous
____— _.
Recording
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Monthly
Grab
Effluent
1,1,1-Trichloroethane
2,500.0 µg/L
25,000 µg/L
Monthly
Grab
Effluent
1,1 - Dichloroethane
100.014/L
300 µg/L
Monthly
Grab
Effluent
1,1 - Dichloroethene
1,500.0 µg/L
15,000 µg/L
Monthly
Grab
Effluent
Naphthalene
12.0 µg/L
120 µg/L
Monthly
Grab
Effluent
Tetrachloroethene
3.3 µg/L
1,800 µg/L
Monthly
Grab
Effluent
Toluene
11.0 µg/L
33.0 µg/L
Monthly
Grab
Effluent
1,2 - Dichloroethane
Quarterly
Grab
Effluent
Trichloroethene
Quarterly
Grab
Effluent
Chronic Toxicity 2
Quarterly
Grab
Effluent
Notes:
1. Flow may be measured using a totalizing flow meter.
2. Chronic Toxicity (Ceriodaphnia) limit at 90% with testing in January, April, July and October (see A. (2)).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Quarterly samples for monitored parameters shall coincide with the chronic toxicity test.

f-
Permit NC0089206
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
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 February 1998, or subsequent versions or "North Carolina
Phase II Chronic Whole Effluent Toxicity Test Procedure (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of January, April, July and October. Effluent sampling for this testing shall be performed
at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as
described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions.
The chronic 'value for multiple concentration tests will be determined using the geometric mean of the highest concentration
having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable
impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes,
and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring
Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and
THP3B for the Chronic. Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the
end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response
data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the
effluent toxicity sample must be measured andreported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee
will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit
number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the.comment area of the
form. The report shall be submitted to the Environmental Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required
during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality
indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring
requirements or limits.
If the Permittee monitors any pollutant more frequently then required by this permit, the results of such monitoring shall be
included in the calculation & reporting of the data submitted on the DMR & all AT Forms submitted.
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.

jVlckay, James
From: Mckay, James
Sent: Friday, November 09, 2012 8:19 AM
To: 'Bruce Rehwaldt'
Cc: David Jerde; [e-mail]
Subject: RE: Former Claire Sprayway GWR permit NC0089206
Thank you for your reply, Bruce. The Whole Effluent Toxicity test (WET) is applied consistently across the State for all
dischargers of "complex" waste. This includes industrial waste, municipal wastewater with significant industrial
contribution, and Major Municipals with discharges over 1.0 MGD. We currently do not have a provision for ending TOX
testing based on historical performance, but we are looking deeper at the system at this time.
Actually, having a history of passing WET tests can be an asset if a legal case is made against a facility. There is
documented evidence that the effluent was tested consistently over the life of the project.
Best regards,
Jim McKay, Environmental Engineer
NC DENR / Division of Water Quality / Surface Water Protection Section
Point Source Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6404 (work); 919/807-6489 (fax)
**Please note, my email address has changed to [e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be
disclosed to third parties.
From: Bruce Rehwaldt[mailto:[e-mail]]
Sent: Thursday, November 08, 2012 7:21 PM
To: Mckay, James
Cc: David Jerde; gmyersCc�plaze.com
Subject: RE: Former Claire Sprayway GWR permit NC0089206
Jim —Thanks again. We have completed our review of the draft permit and have no comments. The proposed effluent
limitations are consistent with our expectations, as we had outlined in the permit application. The quarterly chronic
toxicity testing is new to me, but from what 1 can tell is applied consistently for all permits. Is that something that we
could eventually tests out of after some number of tests?
Bruce Rehwaldt, PE, LEED API Project Manager/Engineer I Liesch Associates, Inc.
Phone: [phone] I Mobile: [phone]
Fax: [phone] I E-Mail: [e-mail]
Please consider the environment before printing this email.
The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or
privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this
information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the
sender and delete the material from any computer.
1

DENR / DWQ / NPDES
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NC0089206
Facility Information
Applicant/Facility Name
Plaze Inc./ Former Claire Sprayway Inc. Remediation Site
Applicant Address
105 Boldt Lane,St. Claire, Mo. 63077
Facility Address
2100 North Church Street, Charlotte, NC 28206
Permitted Flow (MGD)
0.050
Type of Waste
Treated Groundwater
Facility Class
PC 1
County
Mecklenburg
Facility Status
New
Regional Office
MRO
Stream Characteristics
Receiving Stream
UT to Little Sugar
Creek
Stream Classification
C
Drainage Area (sq. mi.)
NA
Drainage basin
Catawba
Summer 7Q10 (cfs)
0
Subbasin
03-08-34
Winter 7Q10 (cfs)
NA
State Grid
G15NE
30Q2 (cfs)
NA
USGS Topo Quad
Charlotte East
Average Flow (cfs)
NA
Permit Writer
Jim McKay
IWC (%)
100 (Capped at 90)
Date
11/8/2012
303(d) Listed
Yes Impaired for
Copper in the 2012
fina1303(d) list.
•
Summary
Plaze Corporation applied for a groundwater remediation permit at their former Claire Sprayway
facility in Charlotte, NC to remove numerous volatile organic compounds that have been found in the
groundwater. The most concentrated chemicals are believed to have come from a metal cleaning
solvent, 1,1,1-Trichloroethane and it's decomposition products, including 1,1-dichloroethene. There
are other compounds believed to have come from other plumes of contamination off -site.
There has been significant work to determine the scope of contamination of groundwater. There have
been two failed attempts in the past to remediate the contamination. A list of 22 different compounds.
along with concentration data from several monitoring wells was submitted with the permit request.
Three of the compounds have no listed Water Quality Standards, so are not included in the permit
draft.
The former business site has been sold, and is now owned and operated by Swofford Associates
Epoxy Flooring, which is not directly involved in the remedial program for the site. The Ground
Water Remediation facility will be constructed entirely underground for the monitoring and
extraction wells; an air stripping facility will be aboveground in a treatment building.
The dual -phase extraction system will consist of ten (10) recovery wells, each equipped with an
automatic pneumatically -actuated total fluids recovery pump piped to a manifold leading to the water
treatment system. The water will go to a low profile air stripper to reduce contamination, through a
sampling port and then to the City of Charlotte's storm sewer system. Each well will also have an air
Fact Sheet
NPDES Permit NC0089206
Page 1

line connected to a blower to provide vacuum extraction of air from the screened intervals of the
recovery wells. Air from the wells will go to a manifold connected to a condensate knockout drum
followed by an air filter, then to the blower and vented to the atmosphere. Approximately 3,000 to
5,000 gallons per day of treated groundwater from the air stripper will be discharged through the
outfall to a stormwater drainage system owned by the City of Charlotte. The water will drain through
an underground storm sewer to an unnamed tributary to Little Sugar Creek, eventually discharging
aboveground to Little Sugar Creek.
Whole Effluent Toxicity (WET) Test
WET requirement is a Quarterly Chronic Toxicity Pass/Fail test using Ceriodaphnia at 90%.
Reasonable Potential Analysis (RPA)
RPA analysis (please see attached) was based on the assumption that the system will operate with
95% removal efficiency, using the maximum reported contaminant concentration for each
component. Maximum predicted effluent concentrations were determined based on a coefficient of
variation of 0.6 and multiplier of 13.2 (as outlined in NC's RPA procedure based on EPA's Technical
Support Document, n = 1). If the predicted effluent concentration was equal to or greater than the
WQ standard, a limit equal to the WQ standard was assigned based on zero flow of the receiving UT,
with Monthly Monitoring. If the predicted concentration was less than the WQ standard, but greater
than 50% of the standard, Quarterly Monitoring was assigned with no limit. If the predicted
concentration was less than 50% of the WQ standard, or if there is no WQ standard for that chemical,
no monitoring was required.
Limits
As a result of the RPA, those chemicals showing Reasonable Potential to exceed the Water Quality
Standard were given limits equal to the WQ standard as a chronic, or Monthly Average limit. For
these compounds, the Standards Group was consulted to determine any published acute standards,
which were given as acute, or Daily Maximum limits. For the two without published acute standards,
a Daily Maximum limit of three times the chronic standard was given as an acute limit in keeping
with EPA requirements.
Proposed Schedule of Issuance
Draft Permit to Public Notice:
Permit Scheduled to Issue:
Permit Effective Date:
NPDES UNIT CONTACT
September 26, 2012 (est.)
November 16, 2012 (est.)
January 1, 2013 (est.)
If you have questions regarding any of the above information or on the attached permit, please
contact Jim McKay at [phone], or by email at [e-mail].
Name: ,r,yr► /!t /47
REGIONAL OFFICE COMMENTS:
Fact Sheet
NPDES NC0089206
Page 2
Date:

North Carolina } ss
Mecklenburg County }
The Charlotte Observer Publishing Co.
Charlotte, NC
Affidavit of Publication
Charlotte Observer
REFERENCE: 145583 NCDENR/DWQ/POINT SOURCE
0000209019 City of Lincolnton, Lincoln County, requested a
permit modification of permit NC0025496
discharging treated wastewater to the South
Before the undersigned, a Notary Public of said County and
State, duly authorized to administer oaths affirmations, etc.,
personally appeared, being duly sworn or affirmed according
to law, doth depose and say that he/she is a representative of
The Charlotte Observer Publishing Company, a corporation
organized and doing business under the laws of the State of
Delaware, and publishing a newspaper known as The
Charlotte Observer in the city of Charlotte, County of
Mecklenburg, and State of North Carolina and that as such
he/she is familiar with the books, records, files, and business
of said Corporation and by reference to the files of said
publication, the attached advertisement was inserted. The
following is correctly copied from the books and files of the
aforesaid Corporation and Publication.
PUBLISHED ON: 09/28/2012
AD SPACE: 12 LINES
FILED ON: 11/02/2012
NAME:
cat!)41
In Testimony Whereof I have hereunto set m
Notary:
My Comm
+on Expires May 27, 2018
•
City of Uncolnton, Lincoln County. requested a
permit modrftcallon of permit NC0025498 dis.
charging troated wastewater to the South Fork
Catawba River. Catawba River Basin.
Plaza, Inc. requested new permit NC0089206
for groundwater romediation In Mecklenburg
County; this permitted discharge Is treated
groundwater to UT to Little Sugar Creek, Cata-
wba River Basin.
LP209019
TITLE:
DATE:
CLAh.
hand and affixed my seal, the day and year aforesaid.
My commission Expires: / /

Catawba River Basin
> AU Number
Name
2012 North Carolina 303(d) List -Category 5
10-digit Watershed 0305010206
Description
Lower South Fork of the Catawba River
Length or Area Units Classification
Category Rating
Use
Reason for Rating
Parameter
Year
> 11-129-15-5
Mauney Creek
From source to Hoyle Creek
4.4
FW Miles
Category
WS-IV 5
5 Impaired Aquatic Life
Poor Bioclassification Ecological/biological Integrity Benthos
2000
12-digit Subwatershed 030501020603
> 11-129-(15.5)
South Fork Catawba
River
From a point 0.4 mile upstream of Long Creek to Cramerton Dam and LakI 18.1
Wylie at Upper Armstrong Bridge
FW Miles
ws-v
Lower Long Creek
5
5 Impaired Aquatic Life
Standard Violation Turbidity
2008
> 11-129-16-(4)
Long Creek
From Mountain Creek to South Fork Catawba River
15.3
FW Miles C
5 Impaired Aquatic Life
Standard Violation Turbidity
2012
5
> 11-129-16-7b
Dallas Branch
From Dallas WWTP to Long Creek
0.8 FW Miles C
5 Impaired Aquatic Life
Fair Bioclassification Ecological/biological Integrity Benthos
1998
Catawba River Basin
Catawba River Basin
8-digit Subbasin 03050103
10-digit Watershed 0305010301
12-digit Subwatershed 030501030104
5
Catawba River
Sugar Creek
Irvins Creek
> 11-137-9a
McAlpine Creek
(Waverly Lake)
From source to SR 3356, (Sardis Rd)
8.5 FW Miles C
5 Impaired
Aquatic Life
Fair Bioclassification Ecological/biological Integrity Benthos
1998
> 11-137-8a
Little Sugar Creek
12-digit Subwatershed
030501030102
From source to Archdale Rd
11.6
FW Miles
C
5
Little Sugar Creel.
5
5 Impaired Aquatic Life
5 Impaired
Fish Consumption
Standard Violation Copper
Standard Violation Water column Mercury
2008
2010
Friday, August 24, 2012
Approved by EPA August 10, 2012
Page 34 of 170

DENR / DWQ / NPDES
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NC0089206
Facility Information
Applicant/Facility Name
Plaze Inc./ Former Claire Sprayway Inc. Remediation Site
Applicant Address
105 Boldt Lane,St. Claire, Mo. 63077
Facility Address
2100 North Church Street, Charlotte, NC 28206
Permitted Flow (MGD)
0.050
Type of Waste
Treated Groundwater
Facility Class
PC 1
County
Mecklenburg
Facility Status
New
Regional Office
MRO
Stream Characteristics
Receiving Stream
UT to Little Sugar
Creek
Stream Classification
C
Drainage Area (sq. mi.)
NA
Drainage basin
Catawba
Summer 7Q10 (cfs)
0
Subbasin
03-08-34
Winter 7Q10 (cfs)
NA
State Grid
G15NE
30Q2 (cfs)
NA
USGS Topo Quad
Charlotte East
Average Flow (cfs)
NA
Permit Writer
Jim McKay
IWC (%)
100 (Capped at 90)
Date
9/11/2012
303(d) Listed
Yes Impaired for
Copper in the 2012
final 303(d) list. All
NC waters are
impaired for Hg by
fish consumption
advisories.
Summary
Plaze Corporation applied for a groundwater remediation permit at their former Claire Sprayway
facility in Charlotte, NC to remove numerous volatile organic compounds that have been found in the
groundwater. The most concentrated chemicals are believed to have come from a metal cleaning
solvent, 1,1,1-Trichloroethane and it's decomposition products, including 1,1-dichloroethene. There
are other compounds believed to have come from other plumes of contamination off -site.
There has been significant work to determine the scope of contamination of groundwater. There have
been two failed attempts in the past to remediate the contamination. A list of 22 different compounds.
along with concentration data from several monitoring wells was submitted with the permit request.
Three of the compounds have no listed Water Quality Standards, so are not included in the permit
draft.
The former business site has been sold, and is now owned and operated by Swofford Associates
Epoxy Flooring, which is not directly involved in the remedial program for the site. The Ground
Water Remediation facility will be constructed entirely underground for the monitoring and
extraction wells; an air stripping facility will be aboveground in a treatment building.
The dual -phase extraction system will consist of ten (10) recovery wells, each equipped with an
automatic pneumatically -actuated total fluids recovery pump piped to a manifold leading to the water
treatment system. The water will go to a low profile air stripper to reduce contamination, through a
Fact Sheet
DRAFT -- NPDES Permit NC0089206
Page 1

sampling port and then to the City of Charlotte's storm sewer system. Each well will also have an air
line connected to a blower to provide vacuum extraction of air from the screened intervals of the
recovery wells. Air from the wells will go to a manifold connected to a condensate knockout drum
followed by an air filter, then to the blower and vented to the atmosphere. Approximately 3,000 to
5,000 gallons per day of treated groundwater from the air stripper will be discharged through the
outfall to a stormwater drainage system owned by the City of Charlotte. The water will drain through
an underground storm sewer to an unnamed tributary to Little Sugar Creek, eventually discharging
aboveground to Little Sugar Creek.
Whole Effluent Toxicity (WET) Test
WET requirement is a Quarterly Chronic Toxicity Pass/Fail test using Ceriodaphnia at 90%.
Reasonable Potential Analysis (RPA)
RPA analysis (please see attached) was based on the assumption that the system will operate with
95% removal efficiency, using the maximum reported contaminant concentration for each
component. Maximum predicted effluent concentrations were determined based on a coefficient of
variation of 0.6 and multiplier of 13.2 (as outlined in NC's RPA procedure based on EPA's Technical
Support Document, n = 1). If the predicted effluent concentration was equal to or greater than the
WQ standard, a limit equal to the WQ standard was assigned based on zero flow of the receiving UT,
with Monthly Monitoring. If the predicted concentration was less than the WQ standard, but greater
than 50% of the standard, Quarterly Monitoring was assigned with no limit. If the predicted
concentration was less than 50% of the WQ standard, or if there is no WQ standard for that chemical,
no monitoring was required.
Limits
As a result of the RPA, those chemicals showing Reasonable Potential to exceed the Water Quality
Standard were given limits equal to the WQ standard as a chronic, or Monthly Average limit. For
these compounds, the Standards Group was consulted to determine any published acute standards,
which were given as acute, or Daily Maximum limits. For the two without published acute standards,
a Daily Maximum limit of three times the chronic standard was given as an acute limit in keeping
with EPA requirements.
Proposed Schedule of Issuance
Draft Permit to Public Notice:
Permit Scheduled to Issue:
Permit Effective Date:
NPDES UNIT CONTACT
September 26, 2012 (est.)
November, 2012 (est.)
December 1, 2012 (est.)
If you have questions regarding any of the above information or on the attached permit, please
contact Jim McKay at [phone], or by email at [e-mail].
Name:
1i'L Date:
REGIONAL OFFICE COMMENTS:
Fact Sheet
DRAFT -- NPDES NC0089206
Page 2

Mckay, James
From: David Jerde [[e-mail]]
Sent: Thursday, August 23, 2012 12:21 PM
To: Mckay, James
Cc: Bruce Rehwaldt
Subject: NPDES permit application for former Claire Mfg, Charlotte
Mr. McKay -
Following is the summary promised in our teleconference last Thursday...
Liesch is the Registered Environmental Consultant (REC) for the site, assisting with site investigation, remedial action
planning, and remediation services for the facility. The purpose of this submittal is to provide supplemental information
pertaining to site investigation; previous remedial efforts; and the scope of the feasibility evaluation completed as part
of the Remedial Action Plan (RAP) development.
SUMMARY OF INVESTIGATION AND REMEDIATION (PRE-LIESCH)
The release at the facility occurred circa 1989; after the release, an initial round of site investigation was completed to
evaluate hydrogeologic conditions and to identify the extent and magnitude of volatile organic compounds (VOCs) to the
soil and groundwater. Results from the initial round of investigation indicated there were three, primary contaminants
of concern (COCs) at the site: 1,1-dichloroethene (11DCE); 1,1,1-trichloroethane (111TCA); and trichlorofluoromethane
(CI3FC). Of the three, 111TCA was the principal COC.
The findings from this initial, site investigation led to the installation of a groundwater pump -and -treat (P&T) system -
with groundwater recovery from a single well; on -site treatment using aeration; and discharge to the sanitary sewer for
polishing at the municipal wastewater facility. In the first phase of P&T-system operation, which lasted from October
1991 until April 1993, the remediation was augmented by a soil -vapor extraction (SVE) system in the groundwater -
recovery well; a vacuum blower was connected to the recovery well to draw air through the vadose-zone and dewatered
soils, recovering vapor -phase impacts from the soils which, in turn, resulted in additional soil-remediation through
volatization. There are a few important takeaways related to the first phase of the site remediation:
A.1 Emissions from the SVE system accounted for nearly 50% of the mass of 111TCA removed from the
subsurface;
A.2 The release occurred at the surface; contamination migrated downwards, through the vadose-zone soil,
resulting in significant impacts in the groundwater system; and
A.3 Operation of the SVE system was the sole remediation technology which directly impacted contamination in
the vadose-zone soils.
The second phase of remediation, implementing exclusively groundwater P&T (no SVE) with discharge to the sanitary
sewer, began in February 1994. A second pumping well was added to enhance groundwater recovery; operation of the
P&T system from March 1998 through May 2001 included pumping from both recovery wells. Operation of the
groundwater P&T system was discontinued in May 2001 when the Charlotte -Mecklenburg Utility Department (CMUD)
disallowed any further discharge of treated effluent to the sanitary sewer.
At the close of the second phase of remediation, supplemental site investigation was completed to screen for VOC
impacts in vadose-zone soils in the source area soils. Significantly, the results of the field investigation indicated that
there were no residual VOC impacts in soils above the NCDENR action limits; in short, the vadose-zone soils had been
remediated. As noted in item A.3 above, the short-term (1-yr, 6-mo) operation of the SVE system was the only
technology which directly remediated these vadose zone soils; the key takeaway from the results of this field
investigation is:
B.1 SVE was proven to be an effective technology for remediating the COCs in unsaturated soils.
Owing to the decision by CMUD to stop accepting groundwater-remediation-system discharges, an alternate
groundwater remediation system was implemented. This system, which was termed two-phase vacuum extraction
1

(TPVE), operated by alternately using (a) an air compressor to force air into a sealed well; and (b) a high -vacuum, liquid -
ring pump to extract water and air from the same well. The TPVE system went on-line in spring 2003; in fall 2005, rising
concentrations of COCs were detected in some groundwater -monitoring wells which were considered to be side- to up -
gradient of the residual impacts. A decision was reached to supplement the TPVE remediation by implementing the
technology in one of the wells near the rising impacts. Operation of the TPVE system was discontinued in January 2007.
Based on the similarity in relative concentrations of the primary COCs (comparing source -area analytical testing results
with those from other areas), it is apparent that - in addition to potential soil and groundwater remediation - the TPVE
was also redistributing COC impacts in the saturated zones. The key takeaway from observations related to operation of
the TPVE system is:
C.1 The saturated media has a relatively low permeability; the air -injection phase of TPVE did not produce clear
evidence for groundwater remediation via the air sparging.
RECENT INVESTIGATION / REMEDIAL ACTION PLANNING
With the entry of the site into the REC program, additional soil and investigation was necessary to provide baseline
characterization because the foregoing remedial efforts had not achieved the soil and groundwater cleanup objectives.
Accordingly, a series of investigation were completed, beginning in the source area and extending radially downgradient
from the source. The investigation efforts ultimately led to the installation of four, off -site, downgradient monitoring
wells - in addition to several new on -site wells. The results of the baseline and routine groundwater analytical testing
from the monitoring -well network provides a framework defining the horizontal and vertical extent of COC impacts in
groundwater.
A conceptual site model (CSM) was developed, incorporating both the historic and recent site -investigation results as
well as information compiled during operation of the various remedial systems. The CSM provided the framework for
evaluation of the technical and economic feasibility of remedial alternatives. The specific goal of the remediation is to
reduce the mass of COCs in soil and groundwater to a point where natural attenuation will be sufficiently protective of
human health and the environment.
Several remedial technologies which involve injection were deemed to be not technically feasible. Summary discussions
of a few, more -common remedial technologies which are infeasible for site remediation are presented below:
• Aquifer Air Sparging (AAS): While the COCs can be removed from solution by aeration, monitoring results
indicated that TPVE was not an effective remedial technology. In practice, the compressed -air injection served
to redistribute impacts from source areas into cleaner areas. The nature of the saturated media (low -
permeability) renders AAS infeasible for soil and groundwater remediation at the site.
• - In Situ Chemical Oxidation (ISCO): ISCO is a contact -oriented remedial technology, meaning that the oxidant
needs to come into contact with the COCs in order to be effective. In theory, the COCs at the site could be
effectively remediated by exposure to appropriate oxidant chemistries. In practice, however, ISCO is not a
feasible technology for site remediation. In part, this is a result of similar challenges as are presented for AAS;
specifically, the data generated during TPVE confirms that the injection of a fluid into the subsurface has the
effect of translating COCs. In essence, if one were attempting to remediate by ISCO, the oxidant could not come
into contact with all of the COCs because the oxidant solution would displace the dissolved -phase COCs from the
points of injection into other areas.
In the final analysis, Liesch determined that the combination of groundwater P&T with high -vacuum SVE was both
technically and economically feasible, and represented the optimal remedial approach to achieve the goal for site
remediation. There were several considerations that made up the determination; two highlights pertaining to the
design objectives are presented below:
• SVE Effectiveness: The operation of an SVE system, using a single extraction point during the first phase of
remediation, was successful in reducing the residual concentrations of COCs to levels that were below the
regulatory cleanup objectives.
• Dewatering: While SVE proved to be effective in the vadose zone, in could not be effective in areas where the
media remains saturated. In order to be effective, the groundwater must be extracted so that the SVE system
can pull air through the soils. There are two primary factors that will be implemented to achieve dewatering
objectives:
2

1. A network of ten, groundwater -extraction wells will be used across the site. Two of these are already in
place (RW01 and RW02); the other eight monitoring wells across the property. The wells will be placed
with relatively close spacing, so that overlapping drawdown cones -of -influence will enhance drawdown
in the aquifer.
2. Each dewatering well will also be used by the SVE system. The vacuum in the well will increase well
efficiency, helping to more -rapidly achieve a dewatered state. Further, the extraction wells will be
screened only in the sections of the aquifer where elevated levels of COC impacts have been observed.
This means that in the downgradient areas, where impacts occur exclusively in the deeper horizon, the
effect of the high -vacuum on attaining the dewatered state will be even more accentuated.
SIDEBAR: One concern that the state has raised, when considering the NPDES application for this project, is the
concept of reinjection of treated water. Owing to the limited space available on the property (e.g. the
dewatering system will affect a substantial percentage of the property), the reinjection would be incompatible
with the dewatering. In essence, reinjection would limit the amount of drawdown in the aquifer and prevent
remediation by SVE.
In summary, Liesch has been working the site toward closure through the REC program. In pursuit of closure, we have
completed site investigation, feasibility evaluations, and remedial action planning. We have completed these phases of
work and have found that the proposed remedial system, groundwater P&T with SVE, would provide the optimal
approach to attaining the remedial objective. Off -site discharge of water is an integral component of the plan.
We hope that this brief summary of the site history and our involvement in investigation and remediation will give you a
better understanding of the challenges presented by soil and groundwater impacts at the site. Furthermore, should you
need anything else as you evaluate the application for the NPDES permit, we would invite a conversation to address
these concerns. Please feel free to contact either Bruce or myself with any questions in the interim.
David .Jerde I Project Manager/Hydrogeologist I Liesch Associates, Inc.
Phone: [phone] x123 1 Mobile: [phone]
Fax: [phone] E-Mail: [e-mail]
The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or
privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this
information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the
sender and delete the material from any computer.
3

In a meeting with Connie Brower and Nikki Schimizzi of the Standards group on 9/19/2012, we discussed acute standards for some
compounds involved in the Plaze GWR project in Charlotte. Some of the compounds are Human Health parameters, and
have no standards corresponding to the chronic values used to set Monthly Average Limits in the draft permit. For these
we will use our NPDES fallback and use 3 times the Monthly Average for a Daily Maximum Limit.
Material
Acute Standard to use
Comments
1,1,1-Trichloroethane
25 mg/ L
1/2 FAV
1,1-Dichloroethane
300 µg/ L
Carcinogen, use 3 X Chronic
1,1-Dichloroethene
15 mg/ L
Naphthalene
120 µg/ L
Acute
Tetrachloroethene
1.8 mg/ L
Acute
Toluene
33 µg/ L
3 X Chronic Limit.

SOC PRIORITY PROJECT: No
To: NPDES Unit
Surface Water Protection Section
Attention: James McKay
Date: July 23, 2012
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Mecklenburg
NPDES Permit No.: NC0089206
PART I - GENERAL INFORMATION
1. Facility and address: Plaze Incorporated
105 Boldt Lane
St. Claire, MO 63077
Physical Address
2100 North Church Street
Charlotte, NC 28206
2. Date of investigation: July 17, 2012
3. Report prepared by: Michael L. Parker, Environmental Engineer II
4. Person contacted and telephone number: Bruce Rehwaldt, [phone]
5. Directions to site: The site is located at 2100 North Church Street in the City of Charlotte
6. Discharge point(s): Latitude: 35 ° 14' 35"
Longitude: 80° 49' 14"
USGS Quad No.: G15NE
7. Receiving stream or affected surface waters: UT to Little Sugar Creek
a. Classification: C
b. River Basin and Subbasin No.: Catawba 030834
c. Describe receiving stream features and pertinent downstream uses: The discharge
will enter a section of Charlotte's storm water collection system located in the
street adjacent to North Tryon Street. The wastewater will then travel underground
within the City's storm water collection system = 150 yards southeast to a point
where the SW drainage pipe intersects with an unnamed tributary to Little Sugar
Creek (also piped). From this point, the storm drain system carrying the
wastewater/UT/SW flow travels 120 yards northeast where it is piped
underground through a railroad right-of-way. It is 0.3 mile from where the SW
piping enters the RR yard to where the piping outlets into the main segment of
Little Sugar Creek.

PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
Actual treatment capacity: 0.03 MGD (Actual flow once drawdown stabilizes)
Description of existing or substantially constructed WWT facilities: There are no
existing WWT facilities.
Description of proposed WWT facilities: The proposed treatment facilities will
consist of ten GW recovery wells and a low -profile air stripper.
Possible toxic impacts to surface waters: Toxic impacts could be expected from
the proposed waste stream. Toxicity testing is expected to - • - ' - _. ent of the
permit upon issuance.
2. Treatment plant classification: Class I
3. Compliance Background: N/A (New facility)
PART III - OTHER PERTINENT INFORMATION
1. Special monitoring or limitations (including toxicity) requests:
PART IV - EVALUATION AND RECOMMENDATIONS
ROW21)
JUL 31 2012
DENR-WATER; QUALITY
POINT SOURCE BR'eNCN
C
None at this time.
The permittee has requested issuance of an NPDES Permit to authorize the discharge of
treated GW from proposed remediation facilities. The GW contamination is primarily volatile
organic compounds that originated from above ground storage facilities containing 1,1,1-
trichloroethane (TCA) and 1,1-dichloroethene (DCE). Previous attempts to remediate this site
have met with some success; however, contaminant concentrations have gone up in some wells
and appear to be moving underneath the property.
The applicant evaluated a number of alternatives for this proposed discharge, including
sending this wastewater to the City of Charlotte and their local POTW. Charlotte no longer
accepts treated GW into their sewer collection system, so a direct discharge was found to be the
most economically feasible alternative.
Pending a final review of this project by the NPDES Unit, it is recommended that an
NPDES permit be issued as requested.
` Signature of Report Preparer
7/7(24,0. /7g
Water Quality regional Supervisor
h:ldsrldsrl2lplaze.doc
ate
z3 7--
ate

2.incrirs ;IR;ghE«'..
cr.h••
\t:rn:i��.na i.
Plaze Inc.
Location
t'r •,I r1,0.!
.,r Iin;h n
a11t2U-11IIU.'t1OI
Discharge to Little
Sugar Creek
Outfall 001 to
Storm Sewer
35D 14' 37.7" ).
80D 49' 18"
•
6ar
Copyright (C) 1998, Maptech, Inc.
2 . ,.t
i•1'

OMR
LIEXH
June 21, 2012
HYDROGEOLOGISTS c ENGINEERS • ENVIRONMENTAL SCIENTISTS
North Carolina Department of Environment and Natural Resources
Division of Water Quality/NPDES Unit
•• 1617 Mail Service Center
Raleigh, NC 27699-1617
OMNI
RE: NPDES Permit Application — Short Form C-GW
Claire Sprayway, Inc. Remediation Project
2100 North Church Street, Charlotte, NC
Dear Sir/Madam:
Enclosed please find three copies of an NPDES Permit Application — Short Form C-GW for a
proposed surface water discharge from a groundwater remediation system proposed for
construction/installation at the former Claire Sprayway, Inc. property located at 2100 North
Church Street in Charlotte, NC. Included as attachments to the permit application are the
following:
A
USGS topographic map and supplemental maps from Charlotte Mecklenburg
Stormwater Services illustrtating the location of the proposed outfall.
B
Table summarizing recent groundwater analytical results and the anticipated
blended influent to the treatment system and including probable discharge limits
for the outfall assuming no dilution.
C
Engineering Alternatives Analysis, including the required local government
review form, several figures illustrating the conceptual remediation system
design, tables outlining the current and present value costs of the proposed
remediation system, which has been identified as the only feasible alternative,
correspondence from the USGS regarding low flow conditions for the proposed
outfall, and correspondence from Charlotte Mecklenburg regarding both the
prohibition on acceptance of treated groundwater discharges in the sanitary
sewer and acceptance of the proposed discharge in the municipal separate storm
sewer system (MS4).
www.liesch.com
LIESCH COMPANIES, INC. • 13400 15TH AVENUE NORTH • MINNEAPOLIS, MN 55441 763/489-3 100 ■ FAX: [phone]

REM
MEI
Page 2
June 21, 2012
I trust the enclosed information satisfies your requirements for issuance of an NPDES permit
for the proposed remediation system. Please call me at 763/489-3162 if you have any questions
regarding this application or the proposed remediation system.
Sincerely,
LIESCH ASSOCIATES, INC.
Bruce Rehwaldt, PE (AZ, CA, IA, MN, WI) LEED AP
Cc: Gary Myers, Plaze Incorporated
Dana Wagner, Liesch
w:\sa\6201781 \npdes\1tr120424npdes.doc
www.Iiesch.com 71.4
THE LIESCH COMPANIES • MINNEAPOLIS • MILWAUKEE • PHOENIX • LOS ANGELES

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment 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
NCOOf340.e(0
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Gary Myers, Safety and Environmental Manager
Plaze Incorporated
105 Boldt Lane
St. Claire
MO, 63077
[phone] ext 141
[phone]
[e-mail]
2. Location of facility producing discharge:
Check here if same as above El
Street Address or State Road
City
State / Zip Code
County
3. Operator Information:
2100 North Church Street
Charlotte
NC oZ09---
Mecklenburg
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:
Liesch Associates, Inc.
13400 15th Avenue North
[phone]
Federal E State ❑
Private
Public El
Page I of 3
C-GW 03/05

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
5. Products recovered:
Gasoline ❑ Diesel fuel ❑ Solvents ® Other
6. Number of separate discharge points: 1
Outfall Identification number(s) 001
7. Frequency of discharge: Continuous
If intermittent:
Days per week discharge occurs: Duration:
Intermittent ❑
8. Treatment System Design flow 0.05 Initial and 0.03 Sustained MGD
3 -. 1 ,7,7„
gv�y9 it
to -e O.
0 - p so- !)` ji; S F• Da'•et
9. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Upper Little Sugar Creek via stormwater collection system and unnamed tributary.
Outfall 001 is a storm sewer catch basin located off the southeast property boundary at latitude
35.243812 and longitude -80.821671 (aerial photograph with location marked attached). Maps of
storm sewer also attached showing location of discharge to both the unnamed tributary and
Upper Little Sugar Creek.
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
Treatment is air stripping for removal of trichloroethane, dichloroethene, and other volatile
organic compounds from groundwater to achieve applicable surface water standards.
No chemical additives are to be used.
11. Is this facility located on Indian country? (check one)
Yes ❑ No
12. Additional Information
All applicants (including renewals):
• A USGS topographical map (or copy of the relevant portion) which shows all outfalls
> A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only:
> Engineering Alternative Analysis
> Description of remediation treatment system components, capacities, and removal efficiency
for detected compounds.
> If the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the sewer.
> A list of any chemicals found in detectable amounts at the site, with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prior to the date of this application)
> For petroleum -contaminated sites - Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed.
Page 2of3
C-GW 03/05

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
For sites contaminated with solvents or other contaminants - EPA Method 624/625
analysis should be performed.
13. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Gary Myers Safety and Environmental Mgr.
Printed name of Person Signing Title
/17740A-x
Signat e of • pplicant Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
_ statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method 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.)
IMO
Page 3 of 3 C-GW 03/05

PM,
Source: 24k USGS Topographic Quad
Projection: NAD83 UTM Zone 17N
LIEXCH
www.liesch.com
Hydrogeologlsts • Engineers • Environmental Scientists
Minneapolis • Chicago • Los Angeles • Madison • Milwaukee • Phoenix
0
1,900 3,800 Feet
Former Claire Mfg. - Charlotte, NC
Apr 12
Property Location
Figure
1

1— 1--- 17_ 1- 1—, 1— 1--- 1— 1—
i
•
17.1
O Storm Structures
—Storm Pipes
—••• Storm Drainage
Streams
Parcels
Building
nPaved
n Other
II
221$ ' 22Qk
Q
Unnamed tributary of Little Sugar Creek is piped in at this location.
s0
2000
Charlotte -Mecklenburg Storm Water Infrastructure - No. Tryon & W. 24th St.
1 0
101
Easting (X) 1456500.846635
Northing (Y) 548396.721543
All data ra mapping grade. or less. and set to the NAG) 1983 Slate
Plane Norio Carolina FIPS 3200 Ft Projected Coordinate System and
the GCS Nonh Amman 1983 Datum.
Charlotte -Mecklenburg Storm Water Services gives nowarranty,
eapleesed w unphed. as to the accuracy. precision. !matinee e.
completeness. or any other expect of the data pmsenl ed. These data Cannot be construed to be a legal
document and are not to be used or design purposes The deta provider shall not be held liable for any errors In
These dale or for damage mining tram then usege. Pnmary sou.ces horn which these data Here compiled must
be consulted for verification of information. These data cannot be resold in their present form
ChaderreNecOmbuq
STORM
WATER

1
1
1
1
1
1
1
1
1
1
1
1
1
1 1 1
O 2100NChurch_StormStructures
2100NChurch StormPipes
—• ••- 2100NChurch_StormDrainage
Streams
2100NChruchSt
Charlotte -Mecklenburg Storm Water Infrastructure - No. Tryon & W. 24th St.
1 Easting (X) 1458290.279949
Northing (Y) 549366.972636
All data as mapping grade. or Tess and set to the MAD 1993 State CAarren►u. k1cn9ury
Plane North Carolina 13Ft Projected caorclnare System and ri STORM
the GCS North American 91i3 Datum. Challotte-Mecldanbnrg Stone Water Services gives no warranty, �� WATER
�7N� ATER
etrpran ssed or as to the accuracy, precision, timeliness. ^��r^ Services
completeness, or any other aspect of the data presented These data cannot be constnred to be a legal
document and are not to be used for desapn purposes The data provider chap not be neld lrvbie for any errors in
these data or lcr damage arising from then usage. Pnmary sources from uhrdt these data were compled must
be consulted for verification of information. These data cannot 5e resold in their present torm.
O

I l l i ll3 1 1 1 1 1 1 1 1 1
Table 1
Summary of Recent Groundwater Analytical Results and
Anticipated Blended Effluent to Remediation System
Well ID
RW-1
RW-2
RW-3
RW-4
RW-5
RW-6
RW-7
RW-8
RW-9
RW-10
Blended
Influent
Probable
Discharge
Limit
(ug/L)
WQ like
MWO4 /
DWO2
MWO4 /
RWO2
MW09/
10/10D
MW09/
10/10D
MWO6 /
RWO2
MW09/
10/10D
MW03I /
MWO3D
MW03I /
MWO3D
MW031 /
MWO3D
MWO7 /
MWO7D
Parameter
4110
Expected concentration (ug/L)
1,1,1-Trichloroethane
9180
8540
8540
9190
8540
1130
1130
1130
188
5170
2500
1,1-Dichloroethane
26.1
17.5
151
151
16.7
151
18.6
18.6
18.6
0.9
57
20000
1,1-Dichloroethene
8510
5460
13400
13400
5540
13400
2060
2060
2060
338
6620
1500
1,2-Dichloroethane
26.3
13.7
39.9
39.9
13
_ _
39.9
5.25
5.25
5.25
1.9
19
37
1,3,5-Trimethylbenzene
25.3
25.3
2.67
2.67
25.3
2.67
5.25
5.25
5.25
0.75
10
630
2-Butanone (MEK)
126
126
13.3
13.3
126
13.3
26.3
26.3
26.3
15.8
51.3
26000
Benzene
25.3
25.3
2.67
2.67
25.3
2.67
5.25
5.25
5.25
0.75
10
51
_
Chloroform
25.3
25.3
3.53
3.53
25.3
3.53
5.25
5.25
5.25
0.75
10.3
Dichlorodifluoromethane
25.3
25.3
5.03
5.03
25.6
5.03
5.25
5.25
5.25
1.65
10.9
Isopropylbenzene (Cumene)
25.3
25.3
2.67
2.67
25.3
2.67
5.25
5.25
5.25
0.75
10
m&p-Xylene
187
50.5
5.33
5.33
50.5
5.33
10.5
10.5
10.5
1.5
33.7
800
Methylene Chloride
50.5
50.5
5.33
5.33
50.5
5.33
10.5
10.5
10.5
8.05
20.7
_
1500
12
800
Methyl-tert-butyl ether
25.3
25.3
2.67
2.67
25.3
2.67
5.25
5.25
5.25
0.75
10
Naphthalene
25.3
25.3
9.8
9.8
_
25.3
9.8
5.25
5.25
5.25
0.75
0.75
12.2
10
n-Propylbenzene
25.3
25.3
2.67
2.67
25.3
2.67
5.25
5.25
5.25
o-Xylene
25.3
25.3
4.93
4.93
25.3
4.93
5.25
5.25
5.25
0.75
10.7
p-Isopropyltoluene
25.3
25.3
2.67
2.67
25.3
_ _
2.67
5.25
5.25
5.25
0.75
10
Styrene
25.3
25.3
2.67
2.67
25.3
2.67
5.25
5.25
5.25
0.75
10
_
Tetrachloroe thene
99.3
25.3
3.87
3.87
25.3
3.87
5.25
5.25
5.25
0.75
17.8
3.3
Toluene
25.3
25.3
2.67
2.67
25.3
2.67
5.25
5.25
5.25
0.75
10
11
Trichloroethene
25.3
25.3
18.2
18.2
26.6
18.2
13.3
13.3
13.3
0.75
_ 17.2
30
Trichlorofluoromethane
87.8
32
105
105
43
105
174
174
174
48.6
105
67000
d
W:\sa\6201781\NPDES\NPDES 2k9-fwd.xlsm

IMO
LIEgH
//(�SYl4
Liesch Associates, Inc. • 13400 15th Avenue North • Minneapolis, MN 55441
Phone: [phone] • Toll Free: [phone] • Fax: [phone]
MEMORANDUM
TO: Liesch Project File SA/6201781
FROM: Bruce Rehwaldt; Jonna Bjelland
DATE: May 7, 2012
RE: Engineering Alternatives Analysis - Claire Facility, Charlotte, North Carolina
Liesch Associates, Inc. (Liesch) was retained by Claire-Sprayway, Inc. (Claire), now owned by
Plaze, Inc., as the Registered Environmental Consultant (REC) to prepare an Engineering
Alternatives Analysis (EAA) for the former Claire Manufacturing site located at 2100 North Church
Street, Charlotte, North Carolina (the Property). The Property is a rectangular plot of land consisting
of approximately 0.8 acre bordered on the southeast by North Tryon Street, on the southwest by 24th
Street, and on the northwest by North Church Street. Figures 1, 1A, and 2 show the Property
location and the Property Layout. The locations of all existing monitoring wells and proposed
remediation wells are also illustrated on Figure 2.
Preparation of this EAA has been completed in conjunction with an NPDES application for a
proposed groundwater remediation system discharge for the Property. This EAA is for a non -
municipal application, groundwater remediation treatment system; therefore, the flow projections
are based on engineering design considerations rather than population projections. A description of
the proposed project follows. Projections for flow, evaluation of technical and financial feasibility,
and Local Government Review are provided in later sections.
STEP 1. Background and Project Description
Liesch has reviewed the potential restrictions identified in the EAA guidance document and do not
believe that the identified restrictions will pose an impediment to an NPDES discharge from this
location. While the discharge is to an unnamed tributary to Little Sugar Creek that is anticipated to
have 7Q10 low -flow discharge estimates of zero, the treated groundwater discharge will be well-
^ aerated and is expected to contain insignificant concentrations of oxygen -consuming waste. A
description of the remediation system and contact information are summarized below.
A. Contact Information
Contact information for the applicant, facility, and EAA preparer (Liesch) are as follows. The
facility is currently owned and occupied by Swofford Associates Epoxy Flooring who is not directly
involved in the remedial program for the site.

Page 2
May7,2012
Applicant
Plaze, Incorporated
Attn: Gary Myers, Safety and Environmental Manager
105 Boldt Lane
St. Claire, MO 63077
Phone: [phone], ext 141
Fax: [phone]
e-mail: [e-mail]
Facility
Swofford Associates Epoxy Flooring
Attn: Mike Bis
2100 North Church Street
Charlotte, NC 28206
Phone: [phone]
,� Fax: [phone]
e-mail: [e-mail]
ran
EAA Preparer
Liesch Associates, Inc.
Attn: Bruce Rehwaldt
13400 15th Avenue North
Plymouth, MN 55441
Phone: [phone]
Fax: [phone]
Email: [e-mail]
B. Description of Proposed Project
The Property has undergone investigation into chlorinated hydrocarbon (COC) contamination of
soil and groundwater. Specifically; 1,1,1—trichloroethane (TCA) and 1,1-dichloroethene (DCE)
have consistently been reported at concentrations above their respective drinking water standards
(the NCDENR 2L Groundwater Standard). The reports have concluded that the contamination was
from an on -site source, likely the aboveground storage tank used for TCA storage or its piping. The
DCE and several other COC's present in the ground water are likely degradation products of the
TCA.
On two occasions, remediation systems were designed and operated with some initial reduction in
contaminant levels. Later, the concentrations went up in some wells and appeared to be moving
under the Property. Data collected by Liesch (Phase I Site Assessment, November 2009) indicates
that TCA contamination in groundwater significantly exceeded the groundwater standard in

Page 3
May 7,2012
monitoring wells MW-4 and DW-02, both by the former storage tank area, as well as in monitoring
well MW-9 located on the southwestern portion of the Property. The DCE contamination is also
present in concentrations above the groundwater standard in the same wells as the TCA and in
monitoring wells MW-6 and MW-7.
Low concentrations of trichlorofluoromethane were documented by Delta (Site Characterization
Report, December 1990) in upgradient monitoring well MW-1. Groundwater samples from four on -
site wells noted dichlorodifluromethane (DCFM) in 2007, 2009, or both. Concentrations are well
below the WQS of 1,400 micrograms per liter (µg/1). Monitoring well MW-8 shows the highest
concentration of DCFM at 11.6 µg/1. Based on the very low concentrations and the presence in an
upgradient well, this contaminant appears to originate from an off -site source.
C. Summary of Remedial Action Plan
Liesch investigated potentially applicable technologies for remediating the Property. Three
alternatives appeared to be feasible and those alternatives were analyzed as required under REC
Program guidance. Additional alternatives were screened but determined to not be feasible and a
ram full evaluation was not conducted.
Remedial alternatives were evaluated using the eight evaluation criteria shown in NCAR Section
.0306(1)(3)(A) through (H), as follows: A) protection of human health and the environment,
including attainment of cleanup levels, (B) compliance with applicable federal, state and local
regulations, (C) long-term effectiveness and permanence, (D) reduction of toxicity, mobility and
0.1
volume , (E) short-term effectiveness, i.e., effectiveness at minimizing the impact of the Property
remedial action on the environment and the local community, (F) implementability, i.e., technical
and logistical feasibility, including an estimate of time required for completion, (G) cost and (H)
community acceptance.
The evaluated alternatives included: dual -phase extraction; pump -and -treat; and electrical resistance
heating. Dual -Phase Extraction was determined to be the most feasible technology given the
aforementioned criteria. Implementation of the Dual -Phase Extraction system for the Property is
expected to consist of the following elements:
• Ten recovery wells in the locations shown in Figure 2 to capture groundwater and reduce the
head in both the primary and secondary flow pathways. Each well will include an automatic,
pneumatically -actuated total fluids recovery pump plumbed to a manifold leading to the water
met treatment system. Additionally, each well will have an air line connected to a blower to provide
vacuum extraction of air from the screened intervals. All wells will be flush mount to minimize
interference with the Property owner's operations. A typical well installation schematic is
provided as Figure 3.
• A groundwater treatment system. Figure 4 illustrates a conceptual design for this system. The
water piping will exit the well casings below ground level and routed beneath the ground
surface to the treatment building. Treatment will likely consist of low profile air stripping to

Page 4
. May 7, 2012
fixl
WI
achieve a reduction in contamination levels meeting the required NPDES discharge limits.
Following the air stripper(s), there will be a sampling port to collect samples for analysis. The
water will be plumbed directly to the storm sewer for discharge.
• A vacuum/air management system. A conceptual drawing of this system is shown in Figure 5.
Piping from the well casing will lead to a manifold connected to a condensate knockout drum
followed by an air filter and then a blower. Provisions will also be made to provide makeup air
to the blower. The output from the blower will be vented to the atmosphere.
� + As specified in NCAR Section .0306(m), the final design plans and specifications will be submitted
as part of the preconstruction report.
D. Low Flow Data for Receiving Stream
Low flow data for the receiving water(s) was obtained from the US Geological Society (USGS) in
,.,, Raleigh, North Carolina. Correspondence from the USGS, including the low flow data, is provided
in Attachment A. Generally, the discharge from the remedial system will be to the storm sewer
beneath North Tryon Street. From the point of discharge, the storm sewer runs northeast along
mil
North Tryon Street for approximately one-half block. It then turns to the southeast and discharges to
an unnamed tributary of Little Sugar Creek located along or within the railroad right-of-way.
Where the storm sewer discharges to the unnamed tributary, the unnamed tributary is actually
contained within underground piping running generally northeast through the rail yard.
Approximately one block northeast of the discharge point, the unnamed tributary resumes its course
overland and discharges to Little Sugar Creek near the projection of W. 29th Street.
MR
As summarized in the USGS correspondence, the 7Q10 low flow discharge for the unnamed
tributary is very likely zero, given the small basin size and urbanized environment. Therefore, at
the USGS suggestion, formal low -flow characteristics were not determined for this location.
Formal low -flow characteristics were, however, determined for Little Sugar Creek at the point of
discharge for the unnamed tributary into Little Sugar Creek. Based on provisional low -flow
statistics at an active downstream continuous -record stream gauge on Little Sugar Creek, the low
flow estimates for Little Sugar Creek are:
Frequency Discharge
7Q10 0.83 cfs
30Q2 2.2 cfs
W7Q 10 1.3 cfs
7Q2 1.4 cfs

Page 5
'..' May 7, 2012
RIR
STEP 2. Reasonable Projections for Flow
As discussed in the EAA Guidance Document, non -municipal flow projections for groundwater
remediation projects are based on engineering design considerations and/or production projections
rather than population projections. Based on information available from the remedial investigation,
...' Liesch anticipates that discharge from the remedial system will be approximately 0.05 (35 gpm)
MGD at the initiation of operations. As drawdown stabilizes in the wells, flow from the system is
s, expected to drop to 0.03 MGD (20 gpm). Liesch anticipates constructing the remedial program in
two phases, beginning with installation and pilot testing of the recovery wells. Upon completion of
the pilot tests, more precise flow projections will be prepared and used to appropriately size the
FM
remediation equipment.
f.:, STEP 3. Evaluate Technologically Feasible Alternatives
As discussed in the EAA Guidance Document, discharges from groundwater remediation systems
..+ are required to evaluate whether wastewater treatment plant (WWTP) connection, land application,
infiltration galleries, in -situ groundwater remediation wells, or closed -loop groundwater
remediation wells are viable disposal alternatives.
A. Connection to an Existing WWTP
Pam The Charlotte -Mecklenburg Utilities (CMU) was contacted to determine whether remediated
ground water could be discharged directly to the CMU sanitary sewer. CMU responded that CMU
has discontinued accepting groundwater discharges. Specifically, the City of Charlotte Sewer Use
Ordinance prohibits discharge of groundwater in Section 23-79 (14) without the permission of the
CMU-System Protection (SP). SP stated that at this time that it cannot grant discharge privileges to
cm the owners of the former Claire Manufacturing facility making this treatment alternative infeasible.
Correspondence from CMU can be found in Attachment B. A letter from Charlotte -Mecklenburg
Stormwater Services acknowledging that it will accept the proposed discharge to the municipal
1.►
rim
separate storm sewer system (MS4), provided that the discharge is NPDES permitted.
B. Land Application
The Property is located at 2100 North Church Street, Charlotte, North Carolina. This location is
within an urban setting in Charlotte, NC. As such, land application is not a feasible alternative for
wastewater disposal from the site due to land constraints within the city.
C. Infiltration Galleries
niq
The chosen remedial alternative, dual -phase extraction, utilizes the combined processes of
groundwater depression and vapor recovery from unsaturated soils and fractured bedrock. Applying
a vacuum to the wells extracts soil vapor and also enhances groundwater recovery. Liquid flow
rates are increased due to the increased pressure gradient applied on the system. In some

FOICI
Page 6
May 7, 2012
configurations, the vacuum increases the effective drawdown locally near the pumped well without
p.
significantly lowering the water table surface away from the pumped well. Due to the above -
described processes, and because the in situ soils are relatively impermeable and the footprint of the
project site is relatively small, on -site infiltration is not a feasible alternative for wastewater disposal
from the site.
IZIM
D. In -Situ and Closed -Loop Groundwater Remediation Wells
'i.' Neither in -situ nor closed -loop groundwater remediation wells are considered feasible alternatives
for wastewater disposal from the site as these installations would conflict with the remediation
i., strategy for the site.
E. Direct Discharge to Surface Waters
Surface water discharge has been determined to be the only technically and economically feasible
alternative for disposal of treated groundwater from the on -site remediation system. Generally,
I,. discharge from the remedial system would be to the storm sewer beneath North Tryon Street. From
the point of discharge, the storm sewer runs northeast along North Tryon Street for approximately
,M one-half block. It then turns to the southeast and discharges to an unnamed tributary of Little Sugar
Creek located along or within the railroad right-of-way. Where the storm sewer discharges to the
unnamed tributary, the unnamed tributary is contained within underground piping running generally
.' northeast through the rail yard. Approximately one block northeast of the discharge point, the
unnamed tributary resumes its course overland and discharges to Little Sugar Creek near the
projection of W. 29th Street. Refer to Figure 1 for the location of Little Sugar Creek with respect to
the Property. Figures 6 and 7 were provided by the City of Charlotte and illustrate the routing of
the storm sewer to the unnamed tributary that discharges to Upper Little Sugar Creek. Coordinates
I
MR
for each location are provided on the figures.
STEP 4. Evaluate Technologically Feasible Alternatives
fam
Surface water discharge has been determined to be the only technically feasible alternative for
disposal of treated groundwater from the on -site remediation system. The 20-year, present value
cost analysis (PVCA) is, therefore, limited to assessment of the costs for surface water discharge
under an NPDES permit. The costs are also limited to those elements specific to the discharge, e.g.
'.., design, connection to the storm sewer, and operational requirements of NPDES permitting, such as
monitoring costs. As only one alternative is considered to be technically feasible, potential lost
„_, opportunity costs are considered to be zero. All costs are outlined, with references, in the enclosed
tables and summarized below.

Page 7
MR May 7, 2012
Description
Current Value
(2012 only)
20-Yr Present Value
(inflated only,
not discounted)
NPDES Discharge Construction Estimate
$14,720
$14,720
2012 Recurring Cost Estimate
$36,568
$915,250
2012 Lost Opportunity Costs
$0
$0
Total Costs
$51,288
$929,970.00
11CyRO\prj$1sa162017811NPDESIEAA.doc

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aa7
Page 8
May 7, 2012
Attachment A. Local Government Review Ponn
General Statute Overview: North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in
the issuance of NPDES Permits for non -municipal domestic wastewater treatment facilities. Specifically, the
Environmental Management Commission (EMC) may not act on an application for a new non -municipal
domestic wastewater discharge facility until it has received a written statement from each city and county
government having jurisdiction over any part of the lands on which the proposed facility and its appurtenances ate
to be located. The written statement shall document whether the city or county has a zoning or subdivision
ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the
ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined
to be inconsistent with zoning or subdivision ordinances unless the apptoval of such application is determined to
have statewide significance and is in the best interest of the State.
rag instructions to the Applicant: Prior to submitting an application for a NPDES Permit for a proposed facility, the
applicant shall request that both the nearby city and county government complete this form. The applicant must:
• Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the
city and the county by certified mail, return receipt requested.
r=+ • If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the postmark on the
certified mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the
application to the NPDES Unit. A
▪ As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall
ramsubmit a copy of the certified mail card along with a notarized letter stating that the local governtncnt(s) failed to
respond within the '15-day period.
Instructions to the Local Government: The nearby city and/or county government which may have or has
jurisdiction over any part of the land on which the proposed facility or its appurtenances are to be located is
required to complete and return this form to the applicant within 15 days of receipt. The form must be signed and
notarized.
n
OBI
run
AMR
Name of local government
0+1 of Out ()4te,i ecaeNI Qi &
J
(City/County)
Does the city/county have jurisdiction over any part of the land on which the proposed facility and its appurtenances arc to
be located? Yes No [ J lino, please sign this form, have it notarized, and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes [ ' No [ j
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance?
Yes
No[ j
Date JLQ\1)iO(L
Sign
ature �1--koavvyvv.eck-
ton;Dl
tl(anager/ �►
State of 1) m , County of f EGk�� Qu a 4
"� On this 1 9111 day ofjIA YLQ_ , 2. 12 a eared before me,the said
personally Pp
name I Rave‘ Y OCk to me known and known to me to be the person
PM described in and wh executed the foregoing document and he (or she) acknowledged that he o d the si me
and being duly sworn by me, made oath that the statements in the foregoing document ,'e NA,' ►, W� -rSD
My Commission expires �Ay Pt 2°l3 .(Signature of Notary Public) sal ,
rI I •,
am

FIGURES
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0 1,900 3,800 Feet
www.liesch.com
LIEYCH
Hydrogeologists • Engineers • Environmental Scientists
Former Claire Mfg. - Charlotte, NC
Apr 12
Property Location
Figure
1
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www.liesch.com
Hydrogeologists • Engineers • Environmental Scientists
North Tryon Street
MW-1 5
Former Claire Mfg. Site - Charlotte, NC
Remediation Well Map
Apr 12
Figure
2
Minneapolis • Chicago • Los Angeles • Madison • Milwaukee • Phoenix
MilEMIENIMIESEMMEIP

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LIEYCH
www.Iiesch.com
Former Claire Mfg. Site - Charlotte, NC
Apr 12
HydrogeoingIsts • Engineers FnvIronmeota l Sclentlfts
Minneapolis • Chicago • Los Angeles • Madison • Milwaukee • Phoenix
Remediation Well Conceptual Design
Figure
3

1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
ATMOSPHERE
AIR
VALVE
(TYP)
EXHAUST TO
ATMOSPHERE
W/ SVE
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WATER TO 1t
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LI'eS:CH
www.liesch.com
Hydrogeologlsls • Cnclne crs • Environmental Scientists
Minneapolis • Chicago • Los Angeles • Madison • Milwaukee • Phoenix
Former Claire Mfg. Site - Charlotte, NC
Apr 12
Groundwater Conceptual Recovery System
Figure
4

1 1 j l 1 l 1 1 1
TO
ATMOSPHERE
4"0 PIPE
4"0 PIPE
VACUUM—\
GAUGE \
(TYP)
RW-1
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www.liesch.com
drogeologists • Engl ncers Environmental Snlenlls is
Minneapolis • Chicago • Los Angeles • Madison • Milwaukee • Phoenix
RW-10
ATMOSPHERE
MAKEUP
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Former Claire Mfg. Site - Charlotte, NC
Apr 12
Conceptual
Vacuum / Air Management System
Figure
5

1 l— 1— 1 1 l 1 -- L— 1
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Charlotte -Mecklenburg Storm Water Infrastructure - No. Tryon & 1At. 24th St.
2141
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Easting (X) 1456500.846635
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LIEXH
www.liesch.com
Hydrogeologists • Engineers • Environmental Scientists
Minneapolis Los Angeles Milwaukee = Phoenix
Former Claire Mfg. Site - Charlotte, NC
Storm Water Conveyance System at Site
Figure
6

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www.liesch.com
Hydrogeologlsts • Engineers • Environmental Scientists
Minneapolis • Los Angeles • Milwaukee • Phoenix
Former Claire Mfg. Site - Charlotte, NC
Storm Water Conveyance System
in Surrounding Area
Apr 12
Figure
7

TABLES
fl

I 1 1 I 1 1 I I I 1 1 1 1 I 1 1 1 1 1
CLAIRE MANUFACTURING 2012 NPDES DISCHARGE CONSTRUCTION ESTIMATE
B. REHWALDT - 4/3/2012
Engineer's Estimate
No.
Sub. Item
Unit
Quantity
Unit Price
Total Price
'Capital Costs
1
Connection Fees
L.S.
1
$
860.00
$
860.00
2
Equipment, Labor, and Installation Costs
a Mobilization (-10% of Construction)
L.S.
1.0
$
500.00
$
500.00
b Excavation/Trenching (2 feet wide by 3 feet deep)
L.F.
260
$
3.75
$
975.00
c Discharge Piping (4-inch PVC)
L.F.
160
$
5.80
$
928.00
d Pipe Bedding
L.F.
160
$
4.75
$
760.00
e Backfill Trench (12-inch backfill over bedding, on -site materials)
L.C.Y.
15
$
2.75
$
41.25
f Base Coarse (6-inch over trench length, compacted)
C.Y.
6
$
20.00
$
120.00
g Connection to Storm Sewer (including asphalt roadway repair/restoration)
L.S.
1
$ 2,500.00
$
2,500.00
h Miscellaneous Site Work/Restoration
L.S.
1.0
$
250.00
$
250.00
3
Engineering Design/Construction Observation Costs
L.S.
1.0
$
7,786
$
7,786.00
TOTAL
$14,720.25
W:1sa162017811NPDESI[Claire NC EAA Engineers Estimates.xls]Construction

I l i 1 1 1 1 1 1 1 1 1 1 i 1 1 1
CLAIRE MANUFACTURING - CHARLOTTE, NC CONSTRUCTION
ENGINEERING BUDGET
B. REHWALDT - 4/3/2012
PROFESSIONAL FEES BY TASK
Hourly Rate:
$I65.00
S 100.00
$126.00
$95.00
$82.00
$65.00
$
TASK
Liesch Staffi
Pmject •
Project
Project
Senior
Project
Clerical
Direct/
SUBTOTAL
Manager
Engineer
Designer
Technician
Technician
Subcontract
1. Plans and Specifications
1
6
12
2
$200
52,607
I7. Bid Administration/Pre-Bid/Response to Contractor Inquiries
1
4
S50
$615
III. Construction Quality Assurance (Job Site Coordination/Documentation)
1. Project Management/Site Meetings/Safety
4
2
$100
$960
2. Construction Observation (1 days at 10 hours/day)
16
$500
51,812
IV. Construction Certification Report
I
2 I
4 I
4 I
I
4
2 I
$1001
$1,464
Subtotal Hours
8
16
16
0
20
4
Subtotal Costs
$1,320
S 1,600
$2,016
$0
$1,640
$260
S950
$7,786
Notes:
W:1sa162017811NPDESI[Claire NC EAA Engineers Estimates.xls]Construction
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CLAIRE MANUFACTURING - CHARLOTTE, NC
RECURRING COST ESTIMATES
B. Rehwaldt 4/3/2012
PROFESSIONAL FEES BY TASK Hourly Rate: S 165.00 5100.00 S 126.00 S95.00
Liesch StafE Project Project Project Senior
Manager Engineer Designer Technician
$82:00 565.00 " - �5 - — - TASK
Project Clerical Direct/ SUBTOTAL
Technician Subcontract
I. Project Management
24
S3,960
II. Weekly Operation and Maintenance Labor
208
S2,500
S19.556
III. Annual Permit and Compliance Fees
S860
S860
IV. Reporting (Assumes Quarterly and Annual)
2
4
4
4
2
5100
51.464
Subtotal Hours
26
4
4
0
212
2
Subtotal Costs
54,290
5400
5504
50
S17.384
SI30
53.460
S26,168
V. Laboratory Analytical Fees
# Samples
Cost
a. VOC Analysis (weekly per EAA Guidance)
52
S150
57.800
b. BOD
52
$25
51.300
c. Ammonia
52
$25
$1.300
Subtotal Laboratory Costs
510,400
Total Annual Recurring Costs
536,568
W:.sa162017811NPDES\ECIaire NC EAA Engineers Estimates.xls]Construction

Table 3A
2012 PRESENT VALUE ESTIMATING TABLE ? I
Project: Claire Manufacturing Facility, 2100 North Church St, Charlotte, NC 7
1 i 1 I
Note: prior to entering 2010 cost est. into formulas in cells HT, F37 and F39, you will need to delete the space prior to the "=" sign.
Projected Costs Over 20-yearPeriod
1
2012 Annual Operation and Maintenance Cost Estimate (enter 2012 cost estimate in column H formula)
$
36,568
Inflation Factor =
2.09%
Discount Rate =
0.75%, l
I
Year n
Inflated Annual Inflated and Discounted
Cost
Annual Cost
2012 1
$37,332
$37,054
2013 2
$38,113
$37,547
2014 3
$38,909
$38,047
2015, 4
$39,722
$38,553
2016 5
$40,552
$39,065
2017
6
$41,400
$39,585
2018
7
$42,265
$40,111
2019
8
$43,149
$40,645
2020
9
$44,050
$41,186
2021
10
$44,971
$41,733
2022
11
$45,911
$42,288
�-
2023 12
$46,871
$42,851
2024 13
$47,850
$43,421
2025
14
$48,850
$43,998
2026
15
$49,871
$44,583
2027
16
$50,913
$45,176
2028
17
$51,978
$45,777
2029
18
$53,064
$46,386
2030
19
$54,173
$47,003
2031
20
$55,305
$47,628
Totals
$915,250
$842,639
(Current Value -not discounted)
(Present Value -discounted)
Basis for this years payments
Current Value
Present Value
2012 Capital Cost Estimate (refer to accompanying table)
$14,720
$14,720
2012 Recurring Cost Estimate (from above)
$915,250
$842,639
2012 Lost Opportunity Cost Estimate (enter 2012 cost estimate in column F formula,
$0
$0
TOTAL
1
$929,970 $857,3591
.-
__i_
I
1
1
I
Page 1

ATTACHMENT A

Man
• Bruce Rehwaldt
From:
Sent:
To:
Cc:
Subject:
John C Weaver [e-mail])
Thursday, March 22, 2012 8:10 AM
Bruce Rehwaldt
John C Weaver; Jeanne C Robbins; James C Finnerty; Rose D Pinnix
Low -flow characteristics for Sta. 0214640525 Little Sugar Creek at SRR bridge at Charlotte,
NC...Re: Low Flow Request - Upper Little Sugar Creek
ag4 US S
science for a changing world
U.S. Geological Survey North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, North Carolina 27607
Date: March 22, 2012
To: Mr. Bruce Rehwaldt, PE, LEED AP, Project Manager
Liesch Associates, Inc.
13400 15th Ave N
Minneapolis, MN 55441
Mr. Rehwaldt,
In response to your inquiry about the low -flow characteristics for Little Sugar Creek at SRR bridge at Charlotte, NC
(station id 0214640525, drainage area 6.53 sqmi) in Mecklenburg County, the following information is provided:
A check of the low -flow files here at the USGS North Carolina Water Science Center does not indicate a previous
determination of low -flow characteristics for this location on Little Sugar Creek. No USGS discharge records are known to
exist for the point of interest; however, USGS discharge records are available at a downstream continuous -record
streamgage on Little Sugar Creek at Medical Center Drive at Charlotte (station id 02146409, drainage area 11.8 sqmi).
Where no or insufficient data is available for a low -flow analysis, a determination of low -flow characteristics is based on
assessment of low -flow yields at nearby location(s) where such statistics have previously been determined. The low -flow
characteristics that are provided have been computed by correlating the runoff characteristics at the downstream
streamgage on Little Sugar Creek.
-- Previously published low -flow information for streams in your area of interest...
For streams in Mecklenburg County, the most recently published low -flow information is a statewide report completed in
the early 1990's. It is USGS Water -Supply Paper 2403, 'Low -flow characteristics of streams in North Carolina" (Giese and
Mason, 1993). An online version of the report is available through http://pubs.usgs.00v/wsp/2403/report.pdf. The report
provides the low -flow characteristics (based on data through 1988) via regional relations and at -site values for sites with
drainage basins between 1 and 400 sqmi and not considered or known to be affected by regulation and/or diversions.
However, please note the data and relations provided in the above -referenced report are applicable for ungaged rural
basins unaffected by development in the basin and thus should not be used for ungaged urban basins. No formal USGS
study on the effects of development and urbanization on low -flow characteristics has been completed in North Carolina.
1

MI
PM
Sta. 0214640525 Little Sugar Creek at SRR bridge at Charlotte, NC (drainage area 6.53 sqmi, at railroad bridge
downstream from Matheson Avenue)
"m Updated provisional low -flow statistics at an active downstream continuous -record streamgage on Little Sugar Creek at
Medical Center Drive at Charlotte (station id 02146409, drainage area 11.8 sqmi) were used to determine the low -flow
characteristics at your point of interest:
Based on the provisional low -flow analyses determined for the streamgage, the low -flow yields are as follows:
7Q10 low -flow yield estimated at 0.13 cfsm
'.' 30Q2 low -flow yield estimated at 0.34 cfsm
W7Q10 low -flow yield estimated at 0.19 cfsm
7Q2 low -flow yield estimated at 0.21 cfsm
igm
Average annual discharge or mean annual runoff (MAR) estimated at 1.63 cfsm
"" estimates:
Applying the above low -flow and mean annual runoff yields to a drainage area of 6.53 sqmi results in the following flow
7Q10 low -flow discharge estimated at 0.83 cfs
mg 30Q2 low -flow discharge estimated at about 2.2 cfs
W7Q10 low -flow discharge estimated at about 1.3 cfs
7Q2 low -flow discharge estimated at about 1.4 cfs
▪ Average annual discharge or mean annual runoff estimated at 10.6 cfs
Please be aware that a degree of uncertainty exists in the above low -flow estimates for this location because of urbanized
ma development in the basin upstream from the site. While no formal USGS study has been conducted in North Carolina to
examine the effects of development on low -flow characteristics, the general thought within the hydrologic community is
that development has the potential to reduce base flow characteristics. Base flow is the portion of the streamflow
sustained by discharge from the adjacent surficial aquifers into the streams and is governed by the amount of runoff that
mil infiltrates into the ground for later discharge to streams.
A check of the provisional low -flow characteristics at other nearby streamgaging stations in Charlotte indicates a wide
m► variability in the low -flow yields at those sites, re -enforcing a recognition of the complexity in low -flow characteristics in
developed basins. Because of the wide variability in the low -flow yields among the sites, it was deemed reasonable and
appropriate to use just the low -flow yields at the downstream streamgage on Little Sugar Creek to estimate the low -flow
characteristics at the ungaged site.
OW
Per previous discussion, no formal low -flow characteristics were determined for the two small basins on an unnamed
tributary to Little Sugar Creek (identified in your initial request via email dated February 24, 2012). Both basins have
PEI drainage areas less than 0.3 sqmi. Even though no formal low -flow characteristics were determined, it is my judgment
that 7Q10 low -flow discharge estimates for these two locations are very likely zero flow given the combination of small
basin size and urbanized basin conditions upstream from these points of interest.
FOR
Invoice information...
'a' A charge of $250.00 for accessing and processing information has been assessed to partially offset these costs. An
invoice covering the processing costs for these data will be sent via regular mail from the U.S. Geological Survey to the
billing address shown below. Instructions for sending your payment will be shown on the invoice.
pm
Mr. Bruce Rehwaldt, PE, LEED AP, Project Manager
Liesch Associates, Inc.
13400 15th Ave N
"1 Minneapolis, MN 55441
This information is considered preliminary and subject to revision pending further analysis as further data were to become
Pig
2

rag
Fag
Pal
PIR
available, and is made available through our cooperative program of water -resources
Carolina Department of Environment and Natural Resources.
Hope this information is helpful. If you have any questions regarding this information,
number or email address listed below.
Thank you.
Curtis Weaver
*************************************************************
J. Curtis Weaver, Hydrologist, PE
USGS North Carolina Water Science Center
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] Fax: [phone]
Mobile: [phone]
E-mail address — [e-mail]
Internet address — http://nc.water.usos.gov/
*************************************************************
From:
To:
Date:
Subject:
"Bruce Rehwaldt" <[e-mail]>
<[e-mail]>
02/24/2012 12:41 PM
Low Flow Request - Upper Little Sugar Creek
investigations with the North
please contact me at the phone
Curtis —
We are preparing an Engineering Alternatives Analysis (EAA) for a site located at 2100 North Church Street in Charlotte, NC. An
aerial photo of the property is provided for reference. As you know, we are required to submit summer 7010 and 30Q2 low flow
data with our submittal. The latitude and longitude for the property off Google Earth is:
35°14'39.03"N
80°49'20.16"W
The discharge from the property would likely enter Upper Little Sugar Creek approximately 2000 feet southeast of the above
address. Please let me know what my options are for delivery, and also the costs. I reviewed Water Supply Paper 2403, but didn't
see the information there. Please call me on either phone below if you have any questions or need additional information.
Bruce Rehwaldt, PE, LEED API Project Manager/Engineer I Liesch Associates. Inc.
Phone: [phone] I Mobile: [phone]
Fax: [phone] I E-Mail: bruce.rehwaldtaliesch.com
Please consider the environment before printing this email.
The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged
material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or
entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from
any computer.
[attachment "locationlatlon.pdf" deleted by John C Weaver/WRD/USGS/D0I]
INN
3

ATTACHMENT B

F�1
lalrl
rag
1CHARLOTTEsM
April 21, 2010
Mr. David A. Jerde; Hydrologist
Desch Associates, Inc.
Dear Mr. Jerde,
This letter is in response to your request of April20, 2010 to discharge treated groundwater to the Charlotte -Mecklenburg
Utilities' (CMU) sanitary .sewer on behalf of -the owners of the former Claire Manufacturing facility Iodated atthe confer of
North Tryon Street and West .24 t' Street, Charlotte; NC.
The siterequires remediation of both soil and groundwater contaminated by Volatile -Organic Compounds (VOC) .The site
re9
was previously En remtrdietion from 1991 to.2001. A groundwater discharge perrnit, #G013, was issued to`dlschar a to the
CMU`s stem. This _-. � y permit was not renewed in 2001 because- CMU had discontinued acceptinggroundwater discharges.
TheCity of Charlotte Sewer Use Ordinance prohibits discharge of groundwater. in Sectiort:23-79 (14) `.:..unless specifically
authorized orized by WV'. ft this time CMU-System Protection (SP isunable toygrant=discharge privileges.
W'(permit)long
ens Staffing levels al ow, CMU has: ssued Local Control Documents ermit for:term remediation projects:in the
past. The permit acts a control mechanism for monitoring non -domestic discharges into the sanitary sewer. However, in
more recent history, CMUShas required other :-aroutdwaterremediaon projects -to obtain NP1)ES permits.
Alto, the,time frame you mentioned_ in` your email of August 8, 2009 Was 1 5 to 2 years, The original project lasted almost
10 years-, thus; we are concerned about -the actual length this rernedietion project may take.
CMU-SP understands you are requesting discharge to the CMU system to reduce costs_ for your client. For information
purposes, based upon- the data you provided, -we would anticipate the following costs associated with discharge: to the
CMU system:
• Due to flow volume and concentration levels of organic compounds discharge would require continued treatment
and
testing on la regular basis -under-a permit with CMU.
• The flow would .have to be metered:
• The standard sewer charge of S4,00 per OCF wouldapply along with industrial Waste Control Charge of $0.30 per
CCF
• In addition high strength charges may apply based upon monitoring performed.
However, as stated previously, we are unable to issue a permit and accept the groundwater discharge at this time:
If you have any questions you may contact me at704,336-4962.orTim Downs at 704-336-5042,
Res » tfully,
Reg' a pbson. Cousar, MSCh
En ironmental Compliance Manager
System Protection
Environmental Management Division
Charlotte -Mecklenburg Utilities
System Protection 4222 Westmont Drive. Charlotte, NC 28217 Phone: [phone] Fax: [phone]
Charlott-Mecklenburg Utilities

NI
NMI
Charlotte -Mecklenburg
STORM
WATER
Services -
September 30, 2010
600 E. Fourth Street
Charlotte, NC 28202
Tel 70 }.336.2191
Mr. Larry Christensen
Liesch Associates, Inc.
13400 151" Avenue N.
Minneapolis, MN 55441
Re: Groundwater Remediation System
Claire-Sprayway, Inc
2100 North Church Street
Charlotte, NC
Dear Mr. Christensen:
Charlotte Storm Water Services is the agency responsible for the management and
operation of the City of Charlotte's municipal separate storm sewer system (MS4). The
system operates under NPDES permit NCS000240 which requires the City to maintain
and enforce a local pollution control ordinance. The City's pollution control ordinance
allows for the discharge of treated contaminated groundwater to the MS4 provided that it
is properly treated and discharged via a NPDES permitted facility.
We have reviewed the NPDES permit application for the above referenced facility site
and have no objection to the facility discharging to our MS4 provided that the discharge
is NPDES permitted and that it is properly treated such that it meets all of the
requirements and effluent discharge limitations as defined in the facility NPDES permit.
Should you have any questions or need additional information, please contact Steve
Jadlocki at 704-336-4398.
Sincerely,
"' Daryl Hammock, PE
Water Quality and Environmental Permitting Manager
•
(:II1lttlf 1TI
To report pollution, call: 704.336.5500
To report drainage problems. call: .all
http:i/stormwatcr.charmcck.nrg