NC0086517_Permit Issuance_19990329

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
Ms. Jerri L. Tuck
Cousins Real Estate Corp.
One Independence Center
101 North Tryon Street, Suite 1700
Charlotte, N.C. 28246
Dear Ms. Tuck:
ffl�.'�VA
IT
A&
D E N R
March 29, 1999
Subject: NPDES Permit Issuance
Authorization to Construct
NPDES Permit No. NCO086517
ATC No. 086517ACA
Gateway Village Phase I
Mecklenberg County
In accordance with the application for discharge permit received on November 17, 1997, the
Division is forwarding herewith the subject state - NPDES permit. In addition, authorization is
concurrently granted for the operation of the existing dewatering remediation system (which currently
discharges to the CMUD wastewater treatment system), following construction of a new effluent
pipeline to a surface water discharge point. Specific conditions and limitations are listed below.
NPDES Permit Issuance
This NPDES 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 December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the office of Administrative
Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such a demand is
made, this permit shall be final and binding.
Please take notice that this permit is not transferable. Part II, EA. addresses the requirements to
be followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be required
by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area
Management Act, or any other Federal or Local governmental permits may be required.
Authorization to Construct
A letter of request for an Authorization to Construct was received by the Division on February 11,
1999, and final plans and specifications for the subject project have been reviewed and found to be
satisfactory. Authorization is hereby granted for the construction of an effluent pipeline from the
existing 0.050 MGD dewatering remediation system at the NationsBank Operations Center, Gateway
Village Phase 1, with discharge of treated groundwater into Irwin Creek (via a storm sewer system) in
the Catawba River Basin.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Cousins Real Estate Corp.
NPDES No. NC0086517
ATC No. 086517ACA
March 29, 1999
Page 2 of 4
Specifically, this authorization is for the following construction and operation activities:
• Construction of a new effluent pipeline from the existing dewatering remediation system, to a
storm sewer system discharging into Irwin Creek.
• Installation of a continuous flow recording unit.
• Following construction activities, operate the dewatering remediation system consisting of the
following treatment components: surge/transfer tank; dual bag filters; dual liquid -phase granular
activated carbon vessels; flow metering devise; control panel; transfer/sump pumps; and
associated piping/appurtenances.
This Authorization to Construct is issued in accordance with Part III.A. of NPDES Permit No.
NC0086517 issued March 29, 1999, and shall be subject to revocation unless the wastewater treatment
facilities are constructed in accordance with the conditions and limitations specified in Permit No.
NC0086517. Failure to abide by the requirements contained in this Authorization to Construct may
subject the Permittee to an enforcement action by the Division of Water Quality in accordance with
North Carolina General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from complying
with any and all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction. The sludge generated from these treatment
facilities must be disposed of in accordance with G.S. 143-215.1 and in a manner approved by the North
Carolina Division of Water Quality. The Operational Agreement between the Permittee and the
Environmental Management Commission is incorporated herein by reference and is a condition of this
permit. Noncompliance with the terms of the Operational Agreement shall subject the Permittee to all
sanctions provided by G.S. 143-215.6 for violation of or failure to act in accordance with the terms and
conditions of this permit.
Upon classification of the facility by the Certification Commission, the Permittee shall employ a
certified wastewater treatment plant operator to be in responsible charge (ORC) of the wastewater
treatment facilities. The ORC must hold a certificate of the type and grade at least equivalent to or
greater than the classification assigned to the wastewater treatment facilities by the Certification
Commission. The Permittee must also employ a certified back-up operator of the appropriate type and
grade to comply with the conditions of Title 15A, Chapter 8A, .0202.
In the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions, the Permittee shall take immediate corrective action, including those as may be required by
this Division, such as the construction of additional or replacement wastewater treatment or disposal
facilities.
The Mooresville Regional Office, telephone number [phone], shall be notified at least
forty-eight (48) hours in advance of operation of the installed facilities so that an on -site inspection can
be made. Such notification to the regional supervisor shall be made during the normal office hours from
8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays.
Upon completion of construction and prior to operation of this permitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been installed in
accordance with the NPDES Permit, this Authorization to Construct, and the approved plans and
specifications. Mail -the completed certification to: North Carolina DENR-DWQ, NPDES Unit, P.O
Box 29535, Raleigh, NC 27626-0535.
One (1). set of approved plans and specifications is being forwarded to you. A copy of the
approved plans and specifications shall be maintained on file by the Permittee for the life of the facility.

Cousins Real Estate Corp.
NPDES No. NCO086517
ATC No. 086517ACA
March 29, 1999
Page 3 of 4
If you have any questions concerning this NPDES permit or Authorization to Construct/Operate,
please contact Tom Belnick at telephone number [phone], extension 543.
Miffififtgned By
David A Goodrich
Kerr T. Stevens
cc: NPDES Unit
Aquatic Toxicology Unit
Mecklenberg County
Central Files
Mooresville Regional Office, WQ
Technical Assistance and Certification Unit
Michael Armour, LAW Engineering, 2801 Yorkmont Road, Charlotte, NC 28208
U.S.EPA, Roosevelt Childress

Permit No. NCO086517
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Cousins Real Estate Corporation
is hereby authorized to discharge wastewater from a facility located at
Gateway Village
800 Block -West Trade Street
Charlotte, North Carolina
Mecklenberg County
to receiving waters designated as Irwin Creek in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, III, and IV hereof.
This permit shall become effective April 1, 1999.
This permit and authorization to discharge shall expire at midnight on May 31, 2000.
Signed this day March 29, 1999.
Original Signed By
David A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NC0086517
SUPPLEMENT TO PER UT COVER SHEET
Cousins Real Estate Corporation
is hereby authorized to:
1. Construct and operate, after receiving an Authorization to Construct, a 0.050 MGD
dewater treatment system for treatment of petroleum and solvent contaminated
f groundwater, from a facility located at Gateway Village, 800 Block- West Trade
Street, Charlotte, Mecklenberg County, and
2. Discharge treated wastewater from said treatment works at the location specified on
the attached map into Irwin Creek (via storm sewer system), which is classified C
waters in the Catawba River Basin.

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
Permit No. NC0086517
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall serial number
001. Such discharges shall be limited and monitored by the Permittee as specified below:
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Flow
0.050 MGD
Continuous
Recorder
I or E
Total Suspended Residue
30.0 mg/I
Monthly
Gra
E
Oil and Grease2
Monthly
ra
E
Benzene
71.4 ug/I
2/Month
Grab
E
Toluene
11.0 ug/I
2/Month
Grab
E
Ethylbenzene
Monthly
Grab
E
Xylene
Monthly
Grab
E
Methyl Tert Butyl Ether (MTBE)
Monthly
Grab
E
1,2 Dichloroethane .
Monthly
Grab
E
Chloroform
Monthly
Grab
E
Tetrachloroethene
8.85 ug/I
2/Month
Grab
E
Trichloroethene
Monthly
Grab
E
Iron
Monthly .
Grab
E
Manganese
Monthly
Grab
'E
Lead3
Monthly
Grab
E
Chronic Toxicity4
Quarterly
Grab
E
Notes:
1. Sample locations: E - Effluent, I - Influent
2. The grab sample for oil and grease should be skimmed from the surface of a quiescent zone (e.g., holding tank) if possible.
3. If lead is not detected above laboratory quantitation levels during the first eight sampling events, then lead monitoring may be discontinued after submitting
written request and receiving subsequent approval from DENR.
4. Chronic (Ceriodaphnia) Pass/Fail Toxicity Limit at 90% - refer to Special Condition A(2).
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit No. NCO086517
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A (2). CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November
1995, or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 90% (defined as treatment two in the procedure document). The permit
holder shall perform quarterly monitoring using this procedure to establish compliance with the
permit condition. The tests will be performed during the months of January, April, July,
October. Effluent sampling for this testing shall be performed at the NPDES permitted final
effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the
parameter code TGP3B. Additionally, DWQ Form AT-1 (original) is to be sent to the following
address:
Attention: Environmental Sciences Branch
North Carolina Division of Water Quality
4401 Reedy Creek Road
Raleigh, North Carolina 27607
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported 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 Branch at the address cited
above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
then monthly monitoring will begin immediately until such time that a single test is passed.
Upon passing, this monthly test requirement will revert to quarterly in the months specified
above.

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.
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. -

/Z 22 98 k. Charlej ScSwerliz, MR , Wale,-
qLn, Trri6ElIVICK, X&ES
J DENR/DWQ
Piwe Cuaukvr% d� /zo/9`l ��atil�i.
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO085617
Facility Information
Facility Name
Gateway Village
Permitted ow:
max at start-up
Facility ass:
Facility/PermitStatus:
(i.e. New, Modification,
Existing or Renewal)
New
County:
MecKlenberg
Stream Characteristics
Receiving tream:
Stormdram to Irwin Creek
Stream Classification:
u asm:
(Catawba ver asm
Drainage Area (mi ):
ummer (cis)
or Irwin Creek; however, treat as zero -flow since discharge is to
stormdrain prior to creek
Winter c s :
c s :
or IrwinCreek; but treat storm ram as zero- ow
verage ow c s
o ;__
Ireat as zero -flow; theretore, use max permit limit o o
Miscellaneous
Regional ice:
Mooresville
opo Quad:
Changes Incorporated into New Permit
Proposed Changes arameters Affected
asrs for change(s)
None I None
New Permit
Summary. The subject site, located in downtown Charlotte, is the proposed location for a
multi -story commercial, retail, and residential complex, with construction scheduled to begin
September 1998. Due to previous activities at the site (including a gas station), groundwater
has been impacted by dissolved -phase petroleum and chlorinated solvent constituents.
Proposed discharge to surface water will include construction dewatering, followed by long-
termpermanent building dewatering. Since the collected groundwater maybe contaminated,
the applicant plans to install a groundwater remediation treatment system to treat aworst-case
flow of 0.05 MGD. A bentonite slurry wall is proposed to be installed around the planned
construction excavation area. The applicant has received a temporary 6-month discharge
permit from the local POTW (CMUD), on the condition that they secure an NPDES permit for
the long-term operation.
Receiving Stream. The proposed discharge is to a storm sewer, with indirect discharge to
Irwin Creek, located 1700 feet northwest of the site. NPDES policy is to treat storm sewers as a
zero -flow discharge. Irwin Creek is classified C water in the Catawba River Basin. Irwin Creek
is not listed in the 1998 303(d) list. However, Irwin Creek is listed as impaired (PS) in the 1995
Basm Plan. The Basin Plan reports that Subbasin 34 is impacted by urban stormwater from the
Charlotte area, as well as wastewater inputs from three major municipal dischargers. The
Regional staff report noted the presence of several fish (>50) at the storm sewer discharge point,
and a public park with limited access to Irwin Creek located directly downstream of the
proposed discharge point. Irwin Creek flows to Sugar Creek, then across NC/SC border.

Engineering Alternatives Analysis (EAA). As part of the NPDES application for a new
discharge (received 9/9/98), LAW Engineering briefly evaluated other discharge alternatives.
Due to site location in downtown Charlotte, nondischarge options are not feasible. CMUD is
allowing discharge to their POTW on an interim basis only. Therefore, surface water discharge
appears to be the only discharge option.
Waste Load Allocation (WLA). Evaluate as discharge to zero -flow stream; therefore, no
WLA is necessary. Permit limits will be same as applicable WQStd/criteria (see Table 1
below). Max GW concentrations based on single sampling round at several monitoring wells.
Detections of BTEX were from well located outside of proposed construction slurry wall.
Although consultant claims slurry wall will retard BTEX migration to site, I have included
BTEX in permit as a conservative approach. Chemical data is too limited at this time, and
effectiveness of slurry wall is still unproven.
TABLE 1. Parameters to limit and/or monitor in NPDES Permit
Parameter
Max UW Conc
(119/1)
t riteria
(ug l)
Decision
Chloroform
-
onrtor-mon y
-wonitor-monthly
1,2-ijictiloroethane
-EPA)
etrac oroe ene
-Limit-
on
ric oroet ene
-
Monitor -monthly
is(2-
ethylhexyl)phthalate
-
Monitor -monthly
. 6
None
Monitor -monthly
Benzene
-Limit-2/Month
Toluene
q-Limit-2/Month
EthylbenzeneMonitor-
monthly
y ene
3130
None
onrtor- monthly
Lead
of analyzed
q-
onrtor-mon y
Not analyzed
oneLimit-
m
t rease
Not analyzed
one
Monitor -monthly
Iron
Not analyzed
one
Monitor -monthly
Manganese
Not ana yze
onemonitor-mon
y
tits- Human neann critcna oaxu un utgin umn wilmunpuVii
AQ- Aquatic life
208* Max GW concentration exceeds WQStd/criteria.
Max concentrations reported for BTEX collected from well located outside of proposed slung wall.
Draft Permit Highlights
• Limited Parameters — See Table 1. Toxicants (benzene, toluene, tetrachloroethene) will be
monttore 2/Month, non -toxicants (TSS) will be monitored monthly.
• Monitor -only Parameters- See Table 1. Monthly monitoring since facility is considered
equivalent to class I.
• Toxicity Testing — Require Quarterly Chronic P/F Tox limit at 90% (per zero -flow policy).
• am a e- Grab samples are specified in permit. Discharge may. initially be as high as
509000 gp , but average is expected to be 28,800 gpd. Most monitong parameters are
volatile, which require grab sampling..
• Flow- Require continuous flow recording, since discharge will be > 10,000 gpd.
• wit Expiration Date- Set at 5/31/2000 to align with 030834 basin renewals; shortened
permit length should not be a problem, since the new permit fee schedule effective 1/99
does not charge a renewal fee.
Regional Staff Report. The MRO prepared a SR dated 10/19/98. The Region recommended
issuance of NPDES permit, and potential need for toxicity testing.

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0085617 (Continued)
Proposed Schedule for Permit Issuance
Draft Permit to Public Notice: O1/27/99
Permit Scheduled to Issue: 03/15/99
State Contact
If you have any questions on any of the above information or on the attached
permit, please contact Tom Belnick at [phone], extension 543.
Copies of the following are attached to provide further information on the permit
development:
• Reasonable Potential Analysis (majors only)
• Existing permit effluent sheets with changes noted (existing facilities only)
• Draft Permit
NPDES Recommendation by:
Regional Office Comments
Date: 12-22-' 1
This space is used by the Regional office personnel to identify specific concerns in
reference to issuance of the subject permit.
5���TTRC� T`t�tD
Regional Recommendation by:
Reviewed By:
Regional Supervisor:
NPDES Unit:
Date:
Date:
ate• :✓

SOC PRIORITY PROJECT: No
To: Permits and Engineering Unit
Water Quality Section
Attention: Tom Belnick
March 4, 1999
AUTHORIZATION TO CONSTRUCT
NPDES PERMIT
REPORT AND RECOMMENDATIONS
County: Mecklenberg
MRO No.: 99-037
Permit No. NCO086517
Project No.: Not Assigned (as of 3/3/99)
PART I - GENERAL INFORMATION
1. Facility and Address: Gateway Village
800 Block - West Trade Street
Charlotte, North Carolina
2. Date of On -Site Investigation (if conducted): Site previously visited on October 12, 1998,
during NPDES permit review process.
3. Report Prepared By: Charley Schwartz, Environmental Engineer I
4. Persons Contacted and Telephone Number: Michael D. Armour, P.G. at LAW
Engineering [phone]
5. Verified Discharge Point(s), List for All Discharge Points:
Latitude: 35' 14' 03"
Longitude: 80' 51' 03"
Attach a USGS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: G 15 NE
6. Site size and expansion area consistent with application? Yes.
7. Topography (relationship to flood plain included): The site is not in the 100 year flood plain.
The facility is 600-800 feet from Irwin Creek, and the land slopes toward Irwin Creek (West) at a
rate of approximately 10%.

Gateway Village ATC - MRO Staff Report
Page 2
8. Location of Nearest Dwelling: Approx. 150-300 feet from the Northwest corner of the site.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. Existing Treatment Facility
a. Current permitted capacity: An NPDES permit has not been issued for this facility.
This Office submitted a staff report to Charles H. Weaver, Jr. of the Permits and
Engineering Unit regarding the NPDES permit application on October 19, 1998.
b. Date(s) and construction activities allowed by previous ATCs issued in the previous two
years: This is a new facility.
c. Actual treatment capacity of the current facility (design volume): 72,000 GPD (based on
treatment rate through the activated carbon canisters)
d. Description of existing or substantially constructed WWT facilities: The system
described in the NPDES and ATC application has been constructed and began operation
in December 1998. The system currently discharges into the sanitary sewer system
operated by the Charlotte Mecklenberg Utilities Department (CMUD). Actual flow
through the treatment system has averaged between 35,000 and 50,000 gpd.
2. Type of Proposed Treatment Facility: The system will be used for dewatering the basement
of a building and will consist of one 700 gallon transfer tank, one dual bag filter for sediment
filtration, and two 1,000 pound activated carbon canisters connected in series.
3. Residuals Handling and Utilization/Disposal Scheme: Management of the spent carbon has
been contracted to Tetrasolv, Inc. Tetrasolv will collect the spent carbon and take it to Calgon
where it will be analyzed for hazardous materials. If the carbon is determined hazardous, it will
be disposed of at one of Calgon's hazardous waste facilities. If the carbon is not hazardous, it
will be reactivated or disposed of at a non -hazardous waste disposal facility.
a. Land applied, DWQ Permit No.: N/A
b. Residuals Stabilization: N/A
c. Landfill: N/A
d. Other disposal/utilization scheme: N/A.
4. Treatment Plant Classification: Class I (rating sheet attached)
5. SIC Code(s): 9999 Wastewater Code(s): 22
6. MTU Code(s): 42018
7. Important SOC/JOC or Compliance Schedule Dates: N/A

Gateway Village ATC - MRO Staff Report Page 3
PART III - EVALUATION AND RECOMMENDATIONS
The system described in the ATC application has been constructed and in operation for
three months (discharging to CMUD's sanitary sewer). Mr. Michael Armour stated that
contaminant breakthrough did occur for tetrachloroethene during the beginning of February
1999. The cause of the breakthrough was identified as increased levels of sediment from
construction activities which spent the carbon canisters more quickly than anticipated. Mr.
Armour stated that finer mesh bag filters were installed to further limit the amount of sediment
reaching and depleting the carbon. Increased sediment loading should not continue to be an issue
upon completion of foundation construction activities at the site.
While the system appears to be handling the current groundwater contaminant
concentrations adequately, the effluent should continue to be monitored for toxicity. Due to the
limited amount of groundwater assessment data, it is difficult to predict when and if slugs of
groundwater with higher contaminant concentrations may reach the system and cause
breakthrough. Therefore, toxicity monitoring should be required until such time that there does
not appear to be a threat to the receiving stream by way of exposure to fish and/or people visiting
the downstream public park.
This Office recommends issuing the Authorization to Construct.
3ug9
Sign e of Report Preparer Date
Water Quality Reg' al Supervisor Date
hAatc\gatevill.atc

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
February 10, 1999
Ms. Jerri L. Tuck
Cousins Real Estate Corp.
One Independence Center
101 North Tryon Street, Suite 1700
Charlotte, N.C. 28246
Subject: NPDES Draft Permit
Permit No. NCO086517
Gateway Village Phase I
Mecklenberg County
Dear Ms. Tuck:
Please find enclosed a DRAFT NPDES permit that has been prepared for the subject facility by
the Division of Water Quality (DWQ). I encourage you to review this document very carefully to ensure
thorough understanding of the information, conditions and requirements contained herein.
Please be aware of the following items in this DRAFT permit:
• Water quality -based limits were developed for benzene, toluene, and tetrachloroethene, while
secondary limits were applied for TSS.
• Quarterly chronic toxicity testing limit at 90%.
• The permit number has been corrected to NC0086517; an incorrect permit number
(NC0085617) had been used in the DWQ acknowledgement letter.
• The permit expiration date is set at May 31, 2000, in order to align all NPDES permit renewals
within this subbasin. Under the new permit fee structure effective January 1, 1999, there will no
longer be renewal application fees. Costs of future renewals will be covered by annual permit
fees.
• This surface water discharge permit was developed solely for the protection of surface water
quality. Additional requirements may exist for facilities seeking approval of groundwater
remediation systems under the State's Underground Storage Tank (UST) program.
Please review the DRAFT permit carefully and submit any written comments to the
following address by March 10, 1999: NCDENR, DWQ/NPDES Unit, P.O.Box 29535, Raleigh,
North Carolina 27626-0535, Attn: David Goodrich. Following the 30-day comment period, the Division
will review all pertinent comments received and take appropriate action on the permit application.
If you have any questions concerning this DRAFT permit, please contact Tom Belnick at
telephone number [phone], extension 543.
aS',ely
m Belnick
NPDES Unit
cc: NPDES Unit
Aquatic Toxicology Unit
Mecklenberg County
Michael Armour, LAW Engineering, 2801 Yorkmont Road, Charlotte, NC 28208
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Permit No. NCO085617
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Cousins Real Estate Corporation
is hereby authorized to discharge wastewater from a facility located at
Gateway Village
800 Block -West Trade Street
Charlotte, North Carolina
Mecklenberg County
to receiving waters designated as Irwin Creek in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I. II, III, and IV hereof.
This permit shall become effective April XX, 1999.
This permit and authorization to discharge shall expire at midnight on May 31, 2000.
Signed this day March XX, 1999.
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NC0085617
SUPPLEMENT TO PERMIT COVER SHEET
Cousins Real Estate Corporation
is hereby authorized to:
1. Construct and operate, after receiving an Authorization to Construct, a groundwater
remediation system for treatment of petroleum and solvent contaminated groundwater,
jfrom a facility located at Gateway Village, 800 Block- West Trade Street Chazlotte,
SF� >nr16Nf Mecklenberg County, and
2. Discharge treated wastewater from said treatment works at the location specified on
the attached map into Irwin Creek (via storm sewer system), which is classified C
waters in the Catawba River Basin.

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3 i
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - DRAFT
Permit No. NC0085617
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall serial number
001. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT,CHARACTERISTICS
LIMITS
MONITORING REQUIREMENIS
on y
Average
g
Weekly
Average
g
Daily
Maximum
measurementamp
Frequency
q Y
a
Yp
Type
ample
Location 1
Flow
0.050 MGD
Continuous
Recorder
I or E
Total Suspended Residue
30 mg/l
Monthly
Grab
E
Oil and Grease2
Monthly
Grab
E
Benzene
71.4 ug/I
2/Month
Grab .
E
Toluene
11.0 ug/I
2/Month
Grab
E
Ethylbenzene
Monthly
Grab
E
Xylene
Monthly
Grab
E
Methyl Tert Butyl Ether (MTBE)
Monthly
Grab
E
1,2 Dichloroethane
Monthly
Grab
E
Chloroform
Monthly
Grab
E
Tetrachloroethene
8.85 ug/I
2/Month
Grab
E
Trichloroethene
Monthly
Grab
E
Iron
Monthly
Grab
E
Manganese
Monthly
Grab
E
Lead
Monthly
Grab
E
Chronic ToxiCity4
Quarterly
Grab
E
Notes:
1. Sample locations: E - Effluent, I — Influent
2. The grab sample for oil and grease should be skimmed from the surface of a quiescent zone (e.g., holding tank) if possible.
3. If lead is not detected above laboratory quantitation levels during the first eight sampling events, then lead monitoring may be discontinued after submitting
written request and receiving subsequent approval from DENR.
4. Chronic (Ceriodaphnia) Pass/Fail Toxicity Limit at 90% - refer to Special Condition A(2).
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit No. N00085617
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A (2). CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November
1995, or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 90% (defined as treatment two in the procedure document). The permit
holder shall perform quarteft monitoring using this procedure to establish compliance with the
permit condition. The tests will be performed during the months of January, April, July,
October. Effluent sampling for this testing shall be performed at the NPDES permitted final
effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the
parameter code TGP3B. Additionally, DWQ Form AT-1 (original) is to be sent to the following
address:
Attention: Environmental Sciences Branch
North Carolina Division of Water Quality
4401 Reedy Creek Road
Raleigh, North Carolina 27607
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported 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 Branch at the address cited
above. .
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
then monthly monitoring will begin immediately until such time that a single test is passed.
Upon passing, this monthly test requirement will revert to quarterly in the months specified
above.

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.
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.

NPDES Permit Development - Mooresville Regional Staff Comments
Prepared by Charley Schwartz
Gateway Vfte-(NP No. NC008_ 171
1) Additional comment defining "groundwater remediation system " in cover letter of permit - A
statement should be included in the cover letter that clarifies the term "groundwater remediation
system" as it applies to the subject permit. In particular, a distinction needs to be made between
the DWQ's definition and the Underground Storage Tank (UST) Section's definition. Failing to
clarify the term may generate unnecessary complications for the UST Section and possible future
litigation regarding reimbursement from the State's UST Trust Fund.
2) Page titled "Effluent Limitations and Monitoring Requirements " - From my experience in the
UST and Groundwater sections, we did not evaluate petroleum contaminated groundwater JO
samples for oil & grease. You might want to allow for discontinuation of this monitoring under
the same conditions that are presented for lead.
3) Page titled "Effluent Limitations and Monitoring Requirements" - Is it essential to monitor
for iron and manganese on a monthly basis? Are there any conditions under which the permittee
can stop or reduce monitoring of these constituents (as they can for lead)?
4) Effluent Limits - Richard Bridgeman commented that some of the effluent limits set forth in
Table 1 do not appear to meet recent guidelines (as I understand you are already addressing this
issue)
CMS/gatevillxom ,0\ � sw-4
AV 6/
S�

NPDES Permit Development - Mooresville Regional Staff Comments
Prepared by Charley Schwartz
65
Gateway Village (NPDES No. NC008#17)
1) Page titled "Supplement to Permit Cover Sheet" - The permit should not call the subject
system a "groundwater remediation system." Labeling the system as such may generate
unnecessary complications for the Underground Storage Tank (UST) Section and possible future
litigation regarding reimbursement from the State's UST Trust Fund. The applicant is seeking
approval for a "dewatering system" in an area where the groundwater happens to be
contaminated. The applicant is not seeking approval for a "groundwater remediation system"
that happens to be dewatering a building. There is a significant difference. The marked text in
the attached fact sheet should be altered to something along the following lines:
"1. Construct and operate, after receiving an Authorization to Construct, a dewatering
system capable of treating petroleum and solvent contaminated groundwater, from a
facility located at Gateway Village, 800 Block -West Trade Street, Charlotte,
Mecklenberg County, and"
2) Page titled "Effluent Limitations and Monitoring Requirements" - From my experience in the
UST and Groundwater sections, we did not evaluate petroleum contaminated groundwater
samples for oil & grease. You might want to allow for discontinuation of this monitoring under
the same conditions that are presented for lead.
3) Page titled "Effluent Limitations and Monitoring Requirements" - Is it essential to monitor
for iron and manganese on a monthly basis? Are there any conditions under which the permittee
can stop or reduce monitoring of these constituents (as they can for lead)?

Gateway Village
Subject: Gateway Village
Date: Wed, 13 Jan 1999 19:07:59 -0400
From: "Schwartz, Charley" <[e-mail]. state. nc.us>
Organization: NC DENR - Mooresville
To: [e-mail]
Hello Tom,
I think I received a voice mail message from you regarding the
Gateway Village project, but a name and number were not left for
me to be sure. I know this project was due soon, and drafted my
comments last week. Unfortunately Rex made comments on my
comments and put them back in my in box after I began my leave
without pay??? Anyway I have attached my initial comments, as I
still think they apply. In addition Richard Bridgeman so a
note on my comments that states "The limits set forth in Table 1
do not appear to meet recent guidelines." Since I have not been in
the office during work hours I am not sure what guidelines should
be used but I felt I should pass the note on to you. I hope this
helps, if you have questions about the legal wrangling over the term
"groundwater remediation system" please call Allen Schiff at
[phone].
Charley Schwartz
Water Quality Section
[e-mail]
[phone], ext.226
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-T(,Cwti
The Knight Publishing Co., Inc.
Charlotte, NC
North Carolina } ss Affidavit of Publication
Mecklenburg County) T"
THE CHARLOTTE OBSERVER
--------------------------------------------------+---------------------------
DIVISION OF WATER QUALITY/NCDENR
PO BOX 29535
RALEIGH NC 27626
REFERENCE: 30010433 legal ad
3064548 intent to issue a st
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 Knight 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: 02/10
PUBLIC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
POST OFFICE BOX 29535
RALEIGH, NORTH CAROLINA 276264535
NOTIFICATION OF INTENT TO ISSUE
A STATE NPDES PERMIT
On the basis of thorouggh staff review and appliwtion of Article 21 of
Chapter 143, General hard" of North Carolina, Public Law 92.500
and other lawful standards and regulations, the North Carolina
Environmental Management Commission proposed to Issue a
perms to discharge to Me persons listed below effective and subject
to special conditions.
Persons wishing to comment upon or object to the proposed
determinations are invited to submit same in writing to the above
address no later than 30 days he the publish date. Al comments
received prior to that date volt be considered in the fam elation of
final determinations regarding the proposed permit. A public
hearing may be held where the Director of the Division of Water
Quality finds a significant degree of public interest in a proposed
Permit.
A copy of the drab permit is available byy writing or calling the
Division of Water Quality, P.O. Box 29535, ilaleigh, North Carolina
27626�0535,(9/9) 733-7015.
The application and other information may be inspected at these
locations during normal office hours. Copies of the Information on
file are available upon request and payments of the costs of
reproduction. All such comments a requests regarding a proposed
permit should make reference to the NPDES permit number listed
below.
'A Preston Howard, Jr., P.E. Director
Date: 2/3/99 Division of Water Quality
Public notice of intent to issue a Slate NPOES permit to the
fallowing:
1. NCD086517, Cousins Real Estate Corps., 101 N. Tryon St..
Charlotte, NC 28246 has applied for a new NPOES parmil for a
wastewater facility located at Gateway Village, 800 Block -West Trade
Sheet. Charlotte. Mecklenburg County. The proposed facility will
discharge up to 0.050 MGD of heated ground water to Irvdn Creek,
a Class C water in the Catawba River Basin. Some parameters are
water quality limited which might affect future waste load
allocations.
LP3064 18
AD SPACE: 112 LINE
FILED ON: 02/12/99
NAME: _I —Vy\� TLE :
DATE:
In Testimony Whereof I have hereunto set my hand alid'afflilced my seal, the
day and y ar aforesaid.
Notary: � 1�. _,-tLvi��— My Commission Expires: /C-// �'�

PUBLIC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
POST OFFICE BOX 29535
RALEIGH, NORTH CAROLINA 27626-0535
NOTIFICATION OF INTENT TO ISSUE A STATE NPDES PERMIT
On the bases of thorough staff review and application of Article 21 of Chapter 143, General Statutes of
North Carolina, Public Law 92-500 and other lawful standards and regulations, the North Carolina
Environmental Management Commission proposed to issue a permit to discharge to the persons listed
below effective and subject to special conditions.
Persons wishing to comment upon or object to the proposed determinations are invited to submit same in
writing to the above address no later than 30 days from the publish date. All comments received prior to
that date will be considered in the formulation of final determinations regarding the proposed permit. A
public hearing may be held where the Director of the Division of Water Quality finds a significant degree
of public interest in a proposed permit.
A copy of the draft permit is available by writing or calling the Division of Water Quality, P.O. Box 29535,
Raleigh, North Carolina 27626-0535, [phone].
The application and other information may be inspected at these locations during normal office hours.
Copies of the information on file are available upon request and payment of the costs of reproduction. All
such comments or requests regarding a proposed permit should make reference to the NPDES permit
number listed below.
Date: 114111
j6tvz.:� 14 C
. ;IrV64��
A. Preston Howard, Ar., P.E., Director
Division of Water Quality
Public notice of intent to issue a State NPDES permit to the following:
1. NC0086517. Cousins Real Estate Corp., 101 N. Tryon St., Charlotte, NC 28246 has applied for a new
NPDES permit for a wastewater facility located at Gateway Village, 800 Block- West Trade Street,
Charlotte, Mecklenberg County. The proposed facility will discharge up to 0.050 MOD of treated
groundwater to Irwin Creek, a Class C water in the Catawba River Basin. Some parameters are water -
quality limited, which might affect future wasteload allocations.

7o 1
To: Permits and Engineering Unit
Water Quality Section
Attention: Charles H. Weaver, Jr.
Date: October 19, 1998
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Mecklenberg
NPDES Permit No.: NCO085617
v,
MRO No.: 98-077
`b
n
c-,j
-
PART I - GENERAL INFORMATION
N
1.
Facility and Address: Gateway Village
T7
800 Block - West Trade Street
—
Charlotte, North Carolina
,
C;_
2.
Date of Investigation: October 12, 1998
3.
Report Prepared By: Charley Schwartz, Environmental Engineer
4.
Person Contacted and Telephone Number: Michael Armour, P.G., and Mark Adkins
with
LAW Engineering at [phone]
5.
Directions to Site: 800 West Trade Street - 400 yards east of I-77 on the north side of
West Trade St.
6.
Discharge Point(s), List for all discharge Points:
Latitude: 35' 14' 03"
Longitude: 80' 51' 03"
Attach a USGS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: G 15 NE
7. Site size and expansion area consistent with application: Yes.
8. Topography (relationship to flood plain included): The site is not in the 100 year flood
plain. The facility is 600-800 feet from Irwin Creek, and the land slopes toward Irwin
Creek (West) at a rate of approximately 10%.
9. Location of Nearest Dwelling: Approx. 150-300 feet from the Northwest comer of the
site.

10. Receiving Stream or Affected Surface Waters: Irwin Creek
a. Classification: C
b. River Basin and Subbasin No.: Catawba 03-08-34
C. Describe receiving stream features and pertinent downstream uses: At the storm
sewer discharge point, Irwin creek is 10-20 feet in width and 6"-3' in depth.
Several fish (>50) were observed ranging in size from Y2" to 4". A public park
with limited access to Irwin Creek is located directly downstream of the discharge
point.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater: 50,400 GPD estimated at start-up
28,800GPD estimated on -going average
b. What is the current permitted capacity: N/A
c. Actual treatment capacity of current facility (current design capacity): 72,000 GPD
(based on treatment rate through the activated carbon canisters)
d. Date(s) and construction activities allowed by previous ATCs issued in the previous
two years: N/A
e. Description of existing or substantially constructed WWT facilities: N/A (The facility is
currently under construction).
f. Description of proposed WWT facilities: The system will be used for dewatering the
basement of a building and will consist of one 700-1,000 gallon transfer tank, one dual
bag filter for sediment filtration, and two 1,000 pound activated carbon canisters
connected in series.
g. Possible toxic impacts to surface waters: There are no toxic impacts expected. The
consultants estimate 99.9% removal of the volatile organic compounds and chlorinated
solvents. However, several of the contaminants are known or suspected carcinogens;
toxicity monitoring may be necessary.
h. Pretreatment Program (POTWs only): Not Needed.
2. Residual handling and utilization/disposal scheme: Management of the spent carbon has
been contracted to Tetrasoly, Inc. Tetrasoly will collect the spent carbon and take it to
Calgon where it will be analyzed for hazardous materials. If the carbon is determined
hazardous, it will be disposed of at one of Calgon's hazardous waste facilities. If the
carbon is not hazardous, it will be reactivated or disposed of at a non -hazardous waste
disposal facility.
a. If residuals are being land applied specify DEM Permit No. N/A.
Residuals Contractor: N/A
Telephone No. ( )N/A
b. Residuals stabilization: N/A
c. Landfill: N/A
3. Treatment Plant Classification: N/A

4. SIC Code(s): 9999 Wastewater Code(s): 22
5. MTU Code(s): 42018
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? No
2. Special monitoring or limitations (including toxicity) requests: The groundwater to be
treated contains several volatile organic compounds not routinely monitored in
wastewater treatment systems (i.e. Tetrachloroethene, Trichloroethene, Benzene, etc.). A
public park with limited access to Irwin Creek is located directly downstream of the
discharge point.
3. Important SOC/JOC or Compliance Schedule dates: N/A
Submission of plans and specifications
Begin Construction
Complete construction
4. Alternative Analysis Evaluation
a. Spray Irrigation: No land available for spray irrigation.
b. Connect to regional sewer system: The Charlotte Mecklenberg Utilities Department will
not allow continued disposal of the dewatering effluent into the sewer system.
c. Subsurface: No land available for subsurface application.
d. Other disposal options: None
PART IV - EVALUATION AND RECOMMENDATIONS
This office recommends that the NPDES permit be approved. Monitoring and sampling
requirements (frequency & parameters) should be coordinated with the UST and groundwater
sections as they will also be involved with evaluating the operation and management of the
treatment system. It is improbable that the proposed bentonite wall surrounding the area to be
dewatered will prevent groundwater contamination in other areas from reaching the treatment
system (unless the bentonite wall is constructed into competent bedrock). The influent
concentrations to the treatment system are unpredictable at this time, and could fluctuate
dramatically on account of the varying contaminant concentrations across the site. Therefore,
toxicity monitoring may be required until such time that there does not appear to be a threat to
the receiving stream by way of exposure to fish in the stream and/or people visiting the
downstream public park.
q u
Signa ure of Report Preparer Date
Water Quality PWonal Supervisor Date
h 9\npdes\gatevi Il.dsr

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Gateway Village Nations Bank
6/19 Mike Armour [phone] called and says there will be a groundbreaking in August for
another dewatering project. Dewatering won't be needed till mid August, so "we have some time
here" he says. He wants to have a meeting with us and CMUD.
Gateway Village will cover 5 city blocks and will go 20 feet underground. Petroleum and dry
cleaner solvents. 7 monitoring wells were put in this morning.
Told Mike he needs to get his application in ASAP.
7/7 Jackie Townsend, CMUD, [phone], calling about this project. Mike wants a temporary
CMUD permit. She will give him a 6-month maximum temporary permit only after he verifies
that an NPDES permit has been applied for.
Will put slurry wall on a diagonal line across property to treat the perchloro. contamination.
Another firm is designing the gw system and Mike is waiting on flow estimate to send in
application.
9/4 Mike Armour called and wants C-GW faxed to him, [phone]
9/8 Mike Armour called and wanted C-GW faxed again.
9/9 Mike Armour called again wanting me to call Jackie when I get the application. He said he
fedex'd it yesterday.
9/14 Mike Armour called again wanting to know if the package was here. I found it at Kim's desk and
said that I would call Jackie T.
Called Jackie to let her know that we have received the application.
9/15 Mike Armour called again wanting to know I had called Jackie T and when the ack letter would be
sent.
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Cousins Real estate/Nationsbank site
Subject: Cousins Real estate/Nationsbank site
Date: Mon, 04 Jan 1999 07:48:14 -0500
From: "Charles Weaver" <charles [e-mail]> Internal
To: Tom Belnick <[e-mail]>
Tom, this permit number was mistakenly entered on NUCC as NC0085617. It should have been entered
as NC0086517.
I have changed the permit number on NUCC to NCO086517 - if you have this one ready to notice, just
change the permit number before the permit is issued.
I'm sorry for this mistake ... with the current confusion over permit numbers between us and EPA I don't
need to cause any more.
1 of 1 1/4/99 10:00 AM

MAR-01-99 MON 16:11 LAW ENGINEERING FAX NO, 704-357-1622 P,01/06
LAW
LAWGlBB Group Mombor.AL
FACSIMILE TRANSMITTAL SHEET
LAW ENGINEERING & ENVIRONMENTAL SERVICES, INC.
2801 Yorlmiout Road
Charlotte, North Carolina 28208
704-3574 00
To:_ f17 13lGIy,vI From: Z&r�
Company: 'Alex Le' Date transmitted' �/19' 2
Fax Number: 3 — 3 -V / Telephone:[phone]
Subjear:&/ja,.,//A 4 `/i/GCYIS't'iSC2 Fax Number: 704-3 57-1622
No. pages transmitted Cmd cover) Hard Copy to Follow: Yes _ No
Urgent For Review _ Please Comment ! Ple. -e Reply _ Please Recvele
COMWNTS:
C0—NMD9NTIALM NariCF- This m mis i ters" only £or the use of the individ'ml � emityto which 3 is addr=4 and may
majah mfpmatiom did is privilcxod, cordidmtial, and =0 from disoloame under appheable taw. It ftT Bder etm1S M=AFR nmme
intarrlCl redpimt, or the employee m agent rcapcmable for delivering the mtssageto the itttmded sectsiem, yw aro Umeby nodflw tha y
dis,eminalia4 rb$rbtmmn, of copyhtgofthis ommmmicatim is strictly pmhibm ttyw nave cetxivmmu mnrmrniwim m �, plax
notify us knodatelybytelome and=a theaeigmal musasetous atrhe above address vm me U.S. Pwwl saw= Thankyw,
If4mLsmisdon is not rvodwd in g�d oMc, pkaw and

MAR-01-99 MON 16:12 LAW ENGINEERING FAX NO, 704-357-1622 P,02/06 _
Mar •01-99 11:43A
P . 07
Lab Report
Froms NC Certili,cation No. 402
SC Certification Na. 99012
HC Drinking Water Cort. He, 37735 Fuson{:o A,s.Wknis tn'nronremai �mnn,no
FL Certification No. E67519
i
Hash 1. L999
,
Tvq hr. Mike Armour I
Law Eng L Env Ser ices, Inc
PO Box 11297
Charlotte, NC 282.(D
Prot': Geuming ReAl Estate Corp {
The following analytica+ results have been obtained for the
111alwZted sample which as submitted to this laboratory:]
i
Sample I.D. AB1B752 pCustomer Code: LAW-C
Login Graup 3615E2 Customer Reference: COUSINS
Phone Number; t704)357-1747/1axt7%V 357-8639
Customer Sample I, D#: INFLURNT-G - na/s h ' 4;'04 .
Sample collection date: 02/04/99 Timex 12220
Lab submittal date: 02/04/90 Time: 13:00
Received by: RJE Validated by: SMM
Paramotore pH, FIELD ANALYSIS
Method reference: Sh 4500-H B
Result: 7.3 S. U.
Date started: 02/04/99
Time started: 12:2e i
Paesmeter: VOLATILES BY�601/502
Method reference; EPA 6 1/60Z
Ronulta aaq baler
Date started: 02/14/99
Time started: 08:27 I
Data for VOLATIL&S BY 6e1/602
component Name
CHLOROFORM
1,2-DICHLOROETHANE
TETRAOHLOROETHENE
TRICHLOROETHENE
MTBE
BEN22HE
TOLUZUE
ETHYLBENZENE
XYLEN$8
Sample comments:
A11 rnnhainmr• indiratrart in
ac0arding to 40 CPR Part 13
449 SWughln
Phnne: 704/529 43
- LAW
NDL or sensitivity:
Date finished: 02/®4/99
Analyatt CPM
Unit: ug/L
Date iinimhed: 62/15/94
Analyst: JMV
LAW ug/L:
Result
Not detoctPd
2
37
Not detected
Not detected
Not detected
Not detected
Not detected
Not detected
a nrnryarly pravrr,rarl and hn1dina ?1p u
Table It.
Road ,a, P_0. pax 7411543 � (MV16tte X28224d7543
+F. I6ANhn: n4m)nr. 1.8001529-6364 w ran.. M)91]25-01"
Component MDL
1
1
1
1
5
i
i
1
1

I
MAR-01-99 MON 16:12 LAN ENGINEERING FAX NO, 704-357-1622 P,03/06
, Mar-04-99 111-43A i P,(,7R
Lab Report
i
nr. nike Armour Sample I.D. ABIG752 fennti_nucd)
Page! 2
March 1, 1999 FUN SeN1W ARSy4ul a CA,wwa,,& Sci,,o,s
If there are any quastinna regarding this data, please coil.
i
Angela A, Overcash
I Laboratory Director j
I
I
444 speim#m?k howl s. R 1. M . 24bs 42 — Cbdrlafle. NC 29224-IK44
vhone:704/52463d11. Toll P. t—Imp. 1 hx: YVVS 2 S4)4114�

MAR-01-99 MON 16:12 LAW ENGINEERING
MA 99 11:43A j
Lab Report j
FAX K 704-367-1622
From: NO Certification 86. 402
SC Certification No. 99012
NC Drinking Watar!Cort_ No, 27725
FL Certiiiaatian Ne. =7819
Moron 1, 1999
To: Mr. Mike Armour
Law Eng & Env Services. Inc ,
PO Box 11297
Charlotte, NO 2a220
Proj: Causing Real Estate Corp
i
Thd following ana.lytlaa re4ults have been obtained for ho
indicated onmp]a wh4oh 00 submitted to this laboratory:
3awple z.». AS18753 Customer Cadet LAM-C
Login Group p: 3615E2 Customer Reference: COUSINS
P. 04/06
Phone Humbert (704)357-i747/fass(704)357-AG39
Customer Samplw I. D(f; INFLUENT-C — Nora t C
sample Collection date:102/04/99 Time; 12;25 i
Lab submittal date: 02/04/99: Times 13:00
Received bys K3E Validated by: SMM
Parameter) METALS DTCF,StxaN
Kethod rrfarrncr: EPA 200.7
Result: Completed
Date started: 02/09/99
Time started: 09:30
Parameter: CADMIUM, TOTAL
Method reference: EPA 200.7
Result: Lees than
Date started: 02/09/99
Time started: 14:00
Pa ametor, CHROMIUM, TO AL
Ke hod references EPA 2 0.7
Result: Lees than
Date started: 02/09/99
Time started: 141,D0
i
Parametor: COPPER, TOTAL
Method referessue: EPA 200.7
Result; Less than
Date started: 02/09/99
Time started: 14:00 i
Parameter. LEAD. TOTAL
Method reference, EPA 200.7
Result: Lela than
Data sminr4pds 02/09/99
Time started: 14:00
Unit:
MDL or sensitiVltye
Date finished; 02/09/99
Analyst: MSP
Unit: mg/L
MDL or sensitivity, 0,005
Date finlehed; 02/09/99
Analyst: DR2
r
Unit: mD/L !
MDL or ©enuitivity1 Q.00S
Date finished: 0219IW59
Analyst: DR2
Units my/L
KDL or sent;itivlty; 0.010
Date finished; 02/09/99
Analyst: DR2
Unit, mg/L
MDL or oenwitivitys 0.006
Date finished: 02/09/59
Analysts DR2
449 RpriupFr9ok Rod a P.O. Raw 240.54:( � (7i4flnitc 1PC.211229.OS43
P)I®c 704/52911164 a 1bft I4.r 81mhew 1.NOn15294"(4 y Wx: %n¢/515AI4U9
i

MAR-01-99 MON 16:13 LAW ENGINEERING
,Mar-01-1i
99 11:44A
Lab Report
Mr. Mike Armour Sample T.
Page: 2
14as"ch 1, 1999
Parameter! NICKEL, TOTA4
Method reference: EPA 260.7
Result: Less than
Date starteds 02/09/99
Time started: 14s00
FAX NO. 704-357-1622
D. AS1a753 (continued)
Parameters 2INC, TOTAL
Method reference: EPA 200.7
RODUlts 0.14 mq/L
Date started: 02/09/99
Time starteds 14:00
Parameter: SILVER, TOTAL
Method references EPA 200.7
Res3ults Lpsa than
Date started: 02/09/99
Time started: L4s00
Parameter: MERCURY, TO*
Method reference: EPA 2�5.1
Result: Less than
Date started: 02/12/99
Time started: 14:30
Parameter: MERCURY DIGESTION
Method reference; EPA 245.1
Result: Completed
Date starteds 02/11/99
Time started: 16;Ge
Parameter: ARSERIC, TOTAL
Mpfhnd roforoncos EPA 200.7
Results Leas than
Date started: OZ/09/99
Time started: 14;00
I
Parameter: SELENIUM, TO AL
Method reference: EPA 2 W.7
Results Leas than
Date otarted: 02/09/99
Time starteds 14s00
Parameter: MULYBDENUII, 'UTAL
Method reference: EPA 2)0.7
Result: Loss than
Date starteds 02/09/99
Time started: 14;00
Parameter: PREP. METHOD;625
Method reference: EPA 625
Result: Completed
Dutm otarted: 02/10l99
TIM esf.d7'Le0: 11:30
P. 05/08
Nil q.M. a ."w 1. Envirennavoi Selntb•••,
Units mg/L
MDL or sen®itivitya 0.010
Date finished: 02/09/99
Analylat l DR2
MDL or evamitivity: 0,010
Date finifthdd! 021bg/99
Assalye{= DR2 I
1
Unit: mg/L I
MDL or sensitivity'*, 0,005
Date iinishedt 02/09/99
Analyst; DR2
,
s
Unit: mg/L
MDL dr aenaitivity�r 0,0002
Date finished: 024 2/99
Analysts MOP
Unit:
MDL or sensitivity::
Date finished: 02/11/99
Analyst: MSP
Units mg/L
MDL or aenoittvity 0,010
Date linisheds H10,9/99
Analysts DRZ
Units mg/L
MDL or sensitivity: 0.010
Data fi.niahed: 0219/99
Analyst: DR2
Unit: mg/L )
MDL or eenoitivity.s 0.020
Date finished: 02/0h/99
Analyst: DR2
Unit:
MDL or sensitivity:
Doty finiehcds 02/10/99
Analyst: LAC .
a49 tipri„gbmolr Hnad .L V.A. 11.240.943... Charlene, NC 28224 9543
1'Hpuc: Y/14/SA•>-4:144+'full YM AYmlrcr 1 •H90/Y2.9-6564 a F"; 704/Y'LY•0109

MAR-01-99 MON 16:13 LAW ENGINEERING FAX NO.
. Mar-Ol -�99 11:44q
Lab Report
704-357-1622
?fr. hike Armour Semple I. D. A8187!5:1 (continued)
Page: 3
March 1, 1999
:
Parameter: SENT-VOLATIL$ ORGANICS BY 625 -
Method r9ference; EPA 625 Unit: ug/L
Result: see below i
r 1 4 Iy
AnN ft'l Q,°nr ranmcm:d
Date :started: 02/1z/99 , Date finished: 02/12/99
Time Started: 07:35 Analyst: HWC
PBriameter: IRON, TOTAL
method reference: EPA 200.7
R410ulti 3.4 mg/L
Date started: 02/09/99
Time started; 14100
Par:smoter: MANGANESE, T TAL
_NBthOd reference: -EPA 200.7
Result: 0.27 mg/L
Date Started: 02/09/99
Time started: 14100
Data for SEMI -VOLATILE RGANICS BY
i
Component Name
AIS(2-ETHYLNHXYL)PHTHALATE
NAPRTHA42ME
MDL or sensitivity: 0.10
Date finich®dt 02/09/99 .
Analyat; DR2
NDL or ncnsitivityL`• 0.10I
Date finished: 02/09/99
Analyst: DR2 i
62S - ug/L:
v
Result Component "L
Nat detected 10
Nat detected 10 -
Sample eommentae
All eehtainers indicated to be properly preserved and holding timeR4vere met
according to 40 CFR Part 136, Table II.
If thpro aro any
questions regarding this data.
Angela D. Overcash
Laboratory Director
please call
449 Sp[ingbmuk Rwd � Am au. 24u543 w CAuAotte. VC ]8224 0543
pAone: Yne Nwnlro. 1.800/529 6361 �.. PaX: 704/575-4)49)1)

f LAW
LAWGIBB Group Member
September 17, 1998
Mr. Tom Belnick
NPDES Unit
Division of Water Quality
North Carolina Department of Environment and Natural Resources
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Subject: Application for NPDES Permit
NationsBank Operations Center
Underground Service Area
Gateway Village Phase One
800 Block — West Trade Street
Charlotte, North Carolina
LAW Project30100-7-3245
Dear Mr. Belnick:
The following is provided in response to the September 17, 1998 letter from Mr. Charles Weaver of the
North Carolina Department of Environment and Natural Resources (NCDENR) NPDES Unit. This letter
(copy attached) requested documentation from Cousins Real Estate Corporation (CERC) designating Law
Engineering and Environmental Services, Inc. (LEES) as the duly authorized representative for purposes of
obtaining the subject permit.
co
Attached please find a letter from CERC's Ms. Jerri L. Tuck, dated September 10, 1998, which provides there
requested authorization. Based on this information, please revise the title for the permit application to thalq
presented for the above subject. Any future related correspondence, including the approved permit should be --
forwarded to the address presented below, with LEES as carbon copy recipient. If you have any technicaP
issues or questions you wish to discuss regarding the permit application, please contact LAW's Mr. Michae[:�
D. Armour or Mr. Thomas F. Beggs at [phone]. ro
Your assistance and cooperation in this matter is greatly appreciated.
Sincerely,
LAW ENGINEERING AND
Michael D. Armour, P.G. :� 1209
Principal Geologist F
Registered, NC 4 1209 �'•r�S' ti�ZOO,
Cc: Ms. Jerri L. Tuck
Cousins Real Estate Corporation
SERVICES, INC.
Send Future Correspondence To
Ms. Jerri L. Tuck
Development Manager
Cousins Real Estate Corporation
One Independence Center
101 North Tryon Street, Suite 1700
Charlotte, NC 28246
[phone]
LAW Engineering and Environmental Services, Inc.
2801 Yorkmont Road • Charlotte, NC 28208
704-357-8600•Fax: [phone]