NC0086517_Permit Issuance_20010531

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
May 31, 2001
Ms. Jerri Tuck
Cousins Real Estate Corporation
101 North Tymn Street
Charlotte, North Carolina 28246
Dear Ms. Tuck:
ern
NCDENR
Subject: NPDES Permit Issuance
Permit NCO086517
Gateway Village
Mecklenburg County
Division personnel have reviewed and approved your application for renewal 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 May 9, 1994 (or as subsequently amended).
The following changes have been incorporated into the final permit based on comments received from the
LawGibb Group:
➢ Note 2 in Section A. (1.) has been modified indicate that the grab sample for oil and grease should be
taken at Outfall 001 (effluent location).
➢ The flow measurement method has been modified to weekly (instantaneous). The use of a totalizing
flow meter is permitted, however, be advised that all flow discharged from the facility must be
monitored and reported on the monthly Discharge Monitoring Reports.
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 (6714 Mail Service Center, Raleigh, North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. 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, the Coastal Area Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Michael Myers at telephone number [phone],
extension 508.
Sincerely,
Original Signed By
David A Goodrich
Kerr T. Stevens
cc: Mooresville Regional Office/Water Quality Section NPDES Files
Point Source Compliance and Enforcement Central Files
Mecklenburg County DEP Aquatic Toxicology Unit
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER -r RECYCLED/ 10% POST -CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.ent.state.nc.us/NPDES

- Permit Number: NC0086517
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 of West Trade Street
Charlotte
Mecklenburg 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 July 1, 2001.
This permit and authorization to discharge shall expire at midnight on May 31, 2005.
Signed this day May 31, 2001.
Original Signed BY
David A. -Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Number: NCO086517
is hereby authorized to:
1. Continue operation of a 0.05 MGD dewatering treatment plant consisting of the following
treatment units:
• 700 gallon transfer tank
• Dual bag filters
• Two 1000 lb. Activated carbon canisters (operated in series)
• Effluent flow measurement using a totalizing flow meter
The facility is located on the 800 block of West Trade Street, Charlotte, Mecklenburg County, and;
2. Discharge treated wastewater from said treatment works at the location specified on the attached
map through outfall 001 into Irwin Creek (via storm sewer), which is classified C water, in the
Catawba River Basin.

Permit Number: NC0086517
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge treated dewatering wastewater from outfall(s) 001. Such
discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Limits
Monitoring Requirements
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Locationl
Flow
0.05 MGD
Weekly
Instantaneous
I or E
Total Suspended Residue
30.0 m /L
45.0 m /L
Monthly
Composite
E
Oil and Greasez
Monthly
Grab
E
1,2 Dichloroethane
Monthly
Grab
E
Chloroform
Monthly
Grab
E
Iron
Monthly
Composite
E
Manganese
Monthly
Composite
E
Trichloroethene
Monthly
Grab
E
Tetrachloroethene
8.85 /L
2/Month
Grab
E
Chronic Toxici 3
Quarter)
Com osite
E
Footnotes:
1. Sample Location: I- Influent, E — Effluent
2. The grab sample for oil and grease should be taken from the effluent and skimmed from the
surface of a quiescent zone if possible.
3. Chronic Toxicity (Ceriodaphnia) at 90%: January, April, July, October (see Part I. A. (2.)).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Defintions:
MGD — Million gallons per day mg/ L — Milligram per liter
µg/L— Microgram per liter

Permit Number: NC0086517
A. (2.) CHRONIC -TOXICITY PERMIT LIMIT (QRTRLY)
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, quarterl 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, 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: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch 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 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 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.
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.

Department of Environment and Natural Resources dWAtpq
Division of Water Quality 9
Fact Sheet For NPDES Permit NCO086517 lrt
: r__
P��Alj
Facility Information
Applicant/Facility Name4:
Applicant Address4:
Facility Address4:
Permitted Flowz4•7:
Type of Wastez9•7:
Facility/Permit Status4:
Countyz4,7:
Miscellaneous
Receiving Streamz4:
Stream Classification',2:
303(d) Listed?5:
Subbasin2:
Drainage Area (mi2): [calculated]
Summer 7Q10 (cfs)6:
Winter 7Q10 (cfs)6:
Average Flow (cfs)6:
IWC (%):
Primary SIC Code:
Regional Office:
USGS Topo Quad:
Permit Writer:
Date:
Summary
Cousins Real Estate - Gateway Village
101 North Tyron Street, Suite 1700, Charlotte
800 West Trade Street, Charlotte
0.05 MGD
Dewatering/groundwater remediation
Renewal
Mecklenburg
Stormdrain to Irwin Creek
C
Yes (Irwin Creek)
03-08-34
< 0.1 miz
0.0 (stormdrain)/ 0.49 cfs (Irwin Creek)
N/A
N/A
100%
N/A
Mooresville
G 15 NE - Charlotte: East
Michael Myers
November 30, 2000
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Law Engineering acting on behalf of the permittee has submitted an application for renewal of
NPDES permit NC0086517. Cousins Real Estate - Gateway Village requires a NPDES discharge
permit to dispose of permanent dewatering/remediated groundwater to waters of the state.
Cousins Real Estate's NPDES permit has expired and they have requested renewal of their
permit. The Division of Water Quality's NPDES Unit issues the permits for individually
permitted facilities, and determines the conditions that must be achieved prior to discharging
wastewater. This fact sheet summarizes the rationale used to determine permit limits and
conditions.
The discharge permit is required to dispose of groundwater that has been contaminated with
both petroleum byproducts and chlorinated solvents at a site in downtown Charlotte.
Alternatives to discharge are limited to disposal to POTW because the surrounding area is
highly developed. Charlotte -Mecklenburg Utilities has indicated that they are unwilling to
Fact Sheet
NPDES Renewal
Page t

accept the wastewater on a permanent basis. Therefore discharge is still the only option
available for disposal of the wastewater generated.
A 0.074 MGD treatment system has been installed to handle a permitted flow of 0.05 MGD.
The treatment facility is a class I system and consist of the following treatment units:
• 700 gallon transfer tank
• dual bag filters
• Two 1000 lb. Activated carbon canisters (operated in series)
Residual disposal is contracted to Barnaby Sutcliffe.
Current Stream Conditions
The receiving stream is a stormdrain that discharges to Irwin Creek in the Catawba River Basin.
The stormsewer is considered water of the state and has a drought condition flow 0.0 cfs. Irwin
Creek is a class C water and is listed in the 2000 303(d) list as impaired for fecal coliform, with
possible causes coming from industrial and municipal wastewater treatment system, and
nonpoint sources.
The source of water for the discharge is remediated groundwater. Remediated groundwater is
not a source for fecal coliform and is not expected to contribute to the cause of impairment to
Irwin Creek.
Instream Monitoring
No instream monitoring is currently required7.
No instream monitoring is recommended during this permit cycle.
Compliance Summary: (see Appendix B)
April 1999 - Toxicity violation - NOV issued June 23, 2000.
May 1999 - Toxicity violation - NOV issued July 22, 2000.
October 1999 - Toxicity violation - NOV issued December 22,1999.
December 1999 - Toxicity violation - NOV issued
May 2000 - Failed to sign toxicity report - NOD issued July 10, 2000.
Due to the repeated toxicity failures in 1999 the facility was assessed in the amount of $3,097.77
on February 25, 2000.
Toxicity Testing
Current Requirement: Quarterly Chronic Toxicity @ 90 % Jan, Apr, Jul, Oct.
Recommended Requirement: Quarterly Chronic Toxicity @ 90% Jan, Apr, Jul, Oct.
Proposed Changes
Based on the reasonable potential analysis it is recommended that the following requirements
be removed from the permit:
Benzene limit and monitoring
Toluene limit and monitoring
Ethylbenzene monitoring
Xylene monitoring
MTBE monitoring
TCE monitoring
Lead monitoring
Fact Sheet
NPDES Renewal
Page 2

The 30mg/L limit for TSS will be implemented as monthly average instead of a daily
maximum. The daily maximum TSS limit will be set at 45 mg/L.
The limit for Tetrachloroethene shall remain at 8.85 ug/L. However, the limit will be
implemented as a weekly average. The limit is based on the EPA Criteria for this pollutant of
concern and the carcinogenicity risk based on a life time exposure. Since the limit is based on a
life time exposure the weekly average limit is appropriate. Limits for carcinogens are
determined using a mass balance approach with the mean annual average flow. However,
since this discharge is to a stormdrain the mean annual average flow cannot be determined
with the available information. The Division's policy is to treat stormdrains as zero flow
streams with a average flow of zero. Using an assumed average flow of zero the limit is set at
the criteria of 8.85 ug/ L.
The sample type for TSS and Toxicity shall be modified to composite. The permitted flow rate
is 50,000 gpd. DWQ policy states that for permitted flows greater than 30,000 gpd samples shall
be composite. Though the facilities actual flows have never exceeded 0.023 MGD unless the
facility request a permit flow reduction to <= 30,000 gpd, composite samples shall be required.
Proposed Schedule for Permit Issuance
Draft Permit to Public Notice: December 13, 2000.
Permit Scheduled to Issue:
References
1. Division of Water Quality's Basinwide Information Management System, September 22,
2000, hUp://h2o.enr.state.nc.us/bims/reports/basinsan.dwaterbodies/alpha/Neuse.pdf
2. 2000. NPDES Regional Staff Report and Recommendations for the Renewal of Cousins
Real Estate Gateway Village NPDES Permit NC0086517, March 14, 2000, Mooresville
Regional Office
3. 19998. Catawba River Basinwide Water Ouality Plan. North Carolina Division of Water
Quality, Water Quality Section.
4. 1999. NPDES Permit Application Short Form C - GW, Cousins Real Estate - Gateway
Village.
5. 2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of
Water Quality, Water Quality Section. Copies obtained through Planning Branch,
Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina.
6. 1993. Low Flow Characteristics of Streams in North Carolina, United States Geological
Survey Water -Supply Paper 2403. Copies obtained at U.S. Geological Survey, Map
Distribution, Box 25286, MS306, Federal Center, Denver, CO 80225.
7. 1996. NC0086517 NPDES Permit. Issued to Cousins Real Estate Corporation, expiration
May 31, 2000. Copies obtained through The Division of Water Quality, Central Files,
Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina.
State Contact
If you have any questions on any of the above information or on the attached permit, please
contact Michael Myers at [phone] ext. 508.
NAME: DATE:
Fact Sheet
NPDES Renewal
Page 3

Regional Office Comment
REGIONAL REVIEWER
REGIONAL SUPERVISOR
t
- Ai2�2� d?� /17
71710
Fact Sheet
NPDES Renewal
Page 5

LAwGIBB
GROUP
January 19, 2001
s=.MrMi haekb*hLYeW� (VIA FACSIMILE)
NPDES Permit Unit
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: NPDES Draft Permit #0086517
Gateway Village - Charlotte, North Carolina
LAW Project No. 30100-7-3245
Dear Mr. Myers:
1 r
J JAN 2 2 2001
DENR - WATER QUALITY
POINT SOURCE BRANCH
Law Engineering and Environmental Services, Inc. (LAW), on behalf of our client, is pleased to submit our
comments to the Division of Water Quality's (DWQ) draft NPDES discharge permit dated December 13,
2000. LAW and Cousins Real Estate wish to thank the division for completing the draft permit, and the
removal of the monitoring for constituents typically found with a petroleum release. We have reviewed the
draft permit and offering the following comments and requests:
• Clarification on either the location of the Oil & Grease sample point, or
removal/editing of Note 2 in Section A. (L). LAW thinks that the effluent location is
the most suitable point to monitor this parameter since the system does remove some
Oil & Grease.
• LAW will be using EPA Method 601 to monitor the effluent concentration of the
tetrachloroethene and trichloroethene. This continues the method we have been using
since the original pen -nit was issued.
• LAW will be using standard EPA methods to monitor the other specific parameters
specified.
LAW Engineering and Environmental Services, Inc.
2801 Yorkmont Road, Suite 100 • Charlotte, NC 28208
704-357-8600 • Fax: [phone]
Serving the Charlotte area for over 50 years

Gateway Village NPDES Draft Permit NC0086517
Charlotte, North Carolina
LAW Project No. 30100-7-3245
Page 2 of 2
January 19, 2001
• LAW is requesting the change on the flow measurement method to weekly manual
I. recording of the total flow from the system flow meter totalizer. These weekly values
bv"
will then be used to calculate the daily flows and the subsequent monthly average
flows. The purpose and justification for this request are detailed in the following
paragraphs.
The draft NPDES permit requires "continuous recording flow" measurement of the effluent. Additionally,
the draft permit presents a limit on the Monthly Average {Daily} Flow (0.05 MGD). LAW would like to
recommend that the "continuous recording" provision of the permit be modified to reflect the weekly
recording in the System Logbook of the totalized flow as recorded by the system effluent flow meter. This
total flow then will be used to calculate the daily total flow and the subsequent monthly average flow
stipulated in the permit. Our justifications for the use of this method are:
• Flow from the remediation system is batch mode,
• Flow rate from the system is limited by the capacity of the transfer pump,
Both the instantaneous and total flow rates are available with the installed meter, and
• Expected flow rate is to remain relatively constant.
The important issue here is the measurement of the total volume of wastewater leaving the facility so that
DWQ can assess the facility's operations with respect to the permit required monthly average flow limit.
The NPDES permit does not have any limitations on the daily maximum flow rate; hence there is no
rationale for the more costly installation of a chart type flow recording instrument.
Thank you for taking the time to review our comments and requests. If you have any questions or need
further clarification, please contact us at [phone].
Sincerely,
LAW ENGINEERING AND ENVIRONMENTAL SERVICES, INC. a J-4
tiux�C
Bruce D. Reilly, P.E. Michelle B. Richards, P.E.
Senior Engineer Principal Engineer
GCc: Ms. Jerri Tuck, Cousins Real Estate
Attachments: NPDES Draft Permit No. NC0086517

The Knight Publishing Co., Inc.t�
Charlotte, NC `
North Carolina } ss Affidavit of Publication
Mecklenburg County}
THE CHARLOTTE OBSERVER
--------------------------------------------------+---------------------------
NC DEHNR
ACCOUNTS PAYABLE
PO BOX 29535
RALEIGH NC 27626
REFERENCE: 20076833
3949501 COUSINS REAL ESTATE
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: 12/12
Pa.. Nona
STATE O NOmn Cu atala
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Mown, NC 270W1617
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NPOES Pemlt Number NOgtR8517 CouNns Real estate - mamkay --,
tilt North Tryon St. Solt. 171, CM1etote, NC 2S24 ❑ to eppfaE for apart
retake! foralaatrylocetetl in Mecklenburg Courtytlilo ergTng takeetlweet.
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LP3949501
AD SPACE: 72 LINE
FILED ON: 12/16/00
----- — - -- --ppp----- ----------------------(-�----+-- -- ,---------
NAME: ( I`Il hd TITLE: 1+
DATE:
In Testimony Whereof I have hereunto set my hand and affixed my seal the
day and year aforesaid.
Notary: 4 LJ..� My Commission Expires:

SOC PRIORITY PROJECT: Yes
To: Permits and Engineering Unit
Water Quality Section
Attention: Charles Weaver
Date: March 14, 2000
NPDES STAFF REPORT AND RECOMMENDATION
County: Mecklenburg
Permit No.
MRO No.799,753PART I - GENERAL INFORMATION UYj�s/7
1. Facility and Address
No X
MAR 16 2000
i
DENR - WATER QUALITY
Gateway Village I PDI"T SOURCE BRANCH
800 Block -West Trad
Charlotte, North Carolina 28216
2. Date of Investigation: February 29, 2000
3. Report Prepared By: Samar Bou-Ghazale, Env. Engineer I
4. Persons Contacted and Telephone Number: Mr. Richard
Donaldson, project Engineer with Law Engineering and
Environmental Services, Inc., Tel# [phone].
5. Directions to Site: 800 West Trade Street is approximately
400 yards east of I-77 on the north side of West Trade St.
6. Disposal Site(s), List for all disposal sites:
Latitude: 35°14'03" Longitude: "
Attach a USGS Map Extract and indicate treatment plant site
and discharge point on map.
USGS Quad No.: 00dAmlift U.S.G.S. Name: Charlotte East
7. Size (land available for expansion and upgrading): Limited
area is available for expansion and upgrading.
8. Topography (location or topographic map indicating
relationship to 100 year 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: The nearest dwelling is

approximately 300 feet from the Northwest corner of the
site.
10. Watershed Stream Basin Information: 300M WMN�
a. Watershed Classification: 0
b. River Basin and Subbasin No.: Catawba 030809
C. Describe receiving stream features and pertinent
downstream uses: Irwin Creek is 10-20 feet in width and
6"-3' in depth. A public park with limited access to
Irwin Creek is located directly downstream of the
discharge.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted: 0.05-MGD,(Design
Capacity)
b. What is the current permitted capacity of the
wastewater treatment facility? 0.05 MGD
C. Actual treatment capacity of the current facility
(current design capacity)? 0.072 MGD
d. Description of existing or substantially constructed
wastewater treatment facilities: The existing
facilities consist of one 7M gallon transfer tank, one
dual bag filter1for sediment filtration, and two, 1000
pound activated carbon canisters: connected in series.
2. Residuals Handling and Utilization/Disposal Scheme:
Management of the spent carbon has been contracted to
Barnaby Sutcliffe for disposal, tel# [phone].
The sediment collected during filtration is not
contaminated with volatile organic according to the
soil analysis by Prism Laboratories.
3. Treatment Plant Classification: 39FON 9 (based on proposed
facilities.)
4. SIC Code(s): 9999 Wastewater Code(s):22
5. Main Treatment Unit Code: 42018
6. Is this facility being constructed with Construction Grant
Funds (municipals only)? N/A
7. Important SOC/JOC or Compliance Schedule Dates: N/A

PART IV - EVALUATION AND RECOMMENDATIONS
The Permittee, Gateway Village, is requesting permit renewal
for the treatment and discharge of contaminated groundwater and
permanent de -watering of a below -ground service area for a
multiple story mixed -use building.
The discharge from the facility failed the toxicity test
during October, November and December of 1999. Toxicity test
passed during January 2000. The next test will take place in
April 2000. According to Richard Donaldson, if the test fails
during April, a multiple concentration test will be conducted.
(they suspect heavy metals to be the cause of the toxicity
failure).
It is recommended that the permit be renewed pending review
and approval by P & E and the Groundwater Section.
Date
j -/s 0 0
Water Qualit Regional Supervisor Date

3
i
Memorandum
To: Mike Myers
From: Valery Stephens
Date: 11 / 16/00
Re: Town of Gateway Village (NC0086517)
1

,j
Facility Name =
Gateway Village
NPDES # =
NCO086517
Ow MGD =
0.05
7010s cfs =
0
I wC (%) =
100.00
Rec'ving Stream
UT to Irwin Creek
Stream Class
C
FINAL RESULTS
Benzene
Max. Pred Cw
5
Allowable Cw
0.0
Max Value
2.5
Iron
Max. Pred Cw
5810
Allowable Cw
1.0
Max Value
830
Toluene
Max. Pred Cw
5
Allowable Cwl
11.0
Max Value
2.5
Trichloroethene
Max. Pred Cw
8.25
Allowable Cw
92.4
Max Value
2.5
Tetrachloroethene
Max. Pred Cw
6
Allowable Cw
1 8.9
Max Value
2.5
Manganese
Max. Pred Cw
50
Allowable Cw
50.0

Max Value
50
Eth (benzene
Max. Pred Cw
8.5
Allowable Cwl
29000.0
Max Value
2.5
1,2 Dichloroethane
Max. Pred Cw
8.5
Allowable Cw
99.0
Max Valuel
2.5
Chloroform
Max. Pred Cw
19.78
Allowable Cwl
470.0
Max Value
1 4.6

Parameter =
Benzene
Standard =
71.4
pgA
n
BDL=1/2DL
Actual Data
RESULTS
1
0.5
<1
Std Dev.
0.37331999
2
0.5
<1
Mean
0.58333333
3
0.5
<1
C.V.
0.63997713
4
0.5
<1
5
0.5
<1
6
0.5
<1
Mult Factor =
2
7
0.5
<1
Max. Value
2.5
/l
8
0.5
<1
Max. Pred Cw
5
N /l
9
0.5
<1
Allowable Cw
pg/l
10
0.5
<1
11
0.5
<1
12
0.5
<1
13
0.5
<1
14
0.5
<1
15
0.5
<1
16
1
<2
_
17
0.5
<1
18
0.5
<1
19
0.5
<1
20
0.5
<1
21
0.5
<1
22
0.5
<1
23
0.5
<1
24
0.5
<1
25
0.5
<1
26
0.5
<1
27
0.5
<1
28
2.5
<5
_
29
0.5
<1
_
301
0.51
<1
_

Parameter =
Iron
Standard =
1
Ng/I
n
BDL=1/2DL
Actual Data
RESULTS
1
50
<100
Std Dev.
Mean
248.0204
2
50
<100
161.5385
3
50
<100
C.V.
1.535364
4
50
<100
5
50
<100
6
50
<100
Mult Factor =
7
7
50
<100
Max. Value
830
NgA
8
140
140
Max. Pred Cw
5810
NgA
9
580
580
Allowable Cw
1.0
ug/l
10
50
<100
11
100
100
12
50
<100
131
8301
830

Parameter =
Toluene
Standard =
11
Ng/I
n
BDL=1/2DL
Actual Data
RESULTS
1
0.5
<1
Std Dev.
0.37331999
2
0.5
<1
Mean
0.58333333
3
0.5
<1
C.V.
0.63997713
4
0.5
<1
5
0.5
<1
6
0.5
<1
Muff Factor =
2
7
0.5
<1
Max. Value
2.5
Ng/I
8
0.5
<1
Max. Pred Cw
5
N /I
9
0.5
<1
Allowable Cw
11.0
N /I
10
0.5
<1
11
0.5
< 1
12
0.5
<1
13
0.5
<1
14
0.5
<1
15
0.5
<1
16
1
<2
17
0.5
<1
18
0.5
<1
19
0.5
<1
20
0.5
<1
21
0.5
<1
22
0.5
<1
23
0.5
<1
24
0.5
<1
25
0.5
<1
26
0.5
<1
27
0.5
<1
28
2.5
<5
_
29
0.5
<1
301
0.5
< 1

i
Parameter =
Trichloroethene
Standard =
92.4
Ng/l
n
BDL=1/2DL
Actual Data
RESULTS
1
0.5
<1
<1
Std Dev.
Mean
0.52326812
0.66666667
2
0.5
3
0.5
<1
C.V.
0.78490218
4
0.5
<1
5
0.5
<1
Mult Factor =
6
0.5
<1
3.3
7
0.5
<1
Max. Value
2.5
Ng/I
8
0.5
<1
Max. Pred Cw
8.25
Ng/l
9
1
<2
Allowable Cw
92.4
Ng/l
10
0.5
<1
11
0.5
<1
12
0.5
<1
13
2.5
<5
14
0.51
<1
151
0.51
<1

Parameter =
Tetrachloroethene
Standard =
8.85
Ng/l
n
BDL=112DL
Actual Data
RESULTS
1
0.5
<1
Std Dev.
0.54768058
2
0.5
<1
Mean
0.69333333
3
0.5
<1
C.V.
0.78992392
4
0.5
<1
5
0.5
<1
6
0.5
<1
Muff Factor =
2.4
7
0.5
<1
Max. Value
2.5
pgA
8
0.5
<1
Max. Pred Cw
6
Ng/I
9
0.5
<1
Allowable Cw
8.9
pgA
10
0.5
<1
11
0.5
<1
12
0.5
<1
13
0.5
<1
14
0.5
<1
15
0.5
<1
16
1
<2
17
0.5
<1
18
0.5
<1
19
0.5
<1
20
0.5
<1
21
2.4
2.4
22
1.9
1.9
23
0.5
<1
_
24
0.5
<1
25
0.5
<1
26
0.5
<1
27
0.5
<1
28
2.5
<5
29
0.5
<1
_
_
301
0.5
< 1

Parameter =
Manganese
Standard =
100
N
n
BDL=1/2DL
Actual Data
RESULTS
1
50
<100
Std Dev.
39.2558994
2
50
<100
Mean
69.2307692
3
50
<100
C.V.
0.56702966
4
50
<100
5
50
<100
6
50
<100
Mult Factor =
2.7
7
50
<100
Max. Value
170
Ng/I
8
50
<100
Max. Pred Cw
459
pg/I
9
50
<100
Allowable Cw
100.0
/1
10
50
<100
11
130
130
12
170
170
131
1001
100

Parameter =
Eth (benzene
Standard =
299000
Ng/l
n
BDL-1/2DL
Actual Data
RESULTS
1
0.5
<1
Std Dev.
0.54090888
2
0.5
<1
Mean
0.67857143
3
0.5
<1
C.V.
0.79712888
4
0.5
<1
5
0.5
<1
6
0.5
<1
Mult Factor =
3.4
7
0.5
<1
Max. Value
2.5
/I
8
1
<2
Max. Pred Cw
8.5
Ng/I
9
0.5
0.5
<1
<1
Allowable Cw
29000.0
N /l
10
11
0.5
<1
12
2.5
<5
13
0.5
<1
141
0.51
<1

Parameter=
1,2 Dichloroethane
Standard =
99
Ng/l
n
BDL=1/2DL
Actual Data
RESULTS
1
0.5
<1
Std Dev.
0.70621262
2
1.5
1.5
Mean
0.87857143
3
0.5
<1
C.V.
0.80381924
4
0.5
<1
5
0.5
<1
6
0.5
<1
Mult Factor
3.4
7
0.5
<1
Max. Value
2.5
g/I
8
1
<2
Max. Pred Cw
8.5
g/l
9
0.5
<1
Allowable Cw
99.0
g/I
10
2.3
2.3
11
0.5
<1
12
2.5
<5
13
0.5
<1
141
0.51
<1

Parameter=
Chloroform
Standard =
470
Ng/I
n
BDL=1/2DL
Actual Data
RESULTS
1
4.6
4.6
Std Dev.
1.3572759
2
3
3
Mean
1.3285714
3
0.5
<1
C.V.
1.0216055
4
0.5
<1
5
0.5
<1
6
0.5
<1
Mult Factor =
4.3
7
0.5
<1
Max. Value
4.6
/l
8
1
<2
Max. Pred Cw
19.78
/l
9
0.5
<1
Allowable Cw
470.0
pgA
10
3
3
11
0.5
<1
12
2.5
<5
13
0.5
<1
141
0.51
<1

Facility Name=
Gateway Village
Parameter=
Benzene
NPDES #=
NCO088517
Standard =
71.4
pg/I
Ow (MGD) =
0.05
7010s (cfs)=
0
n
BDL=1/2DL
Actual Data
RESULTS
IWC (Y) =
100.00
1
0.5
<1
1 Std Dev.
0.373319992
Rec'ving Stream
UT to Irwin Creek
2
0.5
<1
Mean
0.583333333
Stream Class
C
3
0.5
<1
C.V.
0.639977128
4
0.5
<1
5
0.5
<1
FINAL RESULTS
6
0.5
<1
Mult Factor =
2
Benzene
7
0.5
<1
Max. Value
2.5
pg/I
Max. Pred Cw
5
8
0.5
<1
Max. Pred Cw
5
pg/I
Allowable Cw
0.0
9
0.5
<1
Allowable Cw
pg/I
Max Value
2.5
10
0.5
<1
_
11
0.5
<1
Iron
12
0.5
<1
Max. Pred Cw
13
0.5
<1
Allowable Cw
14
0.5
<1
Max Value
830
15
0.5
<1
16
1
<2
Toluene
17
0.5
<1
Max. Pred Cw
5
18
0.5
<1
Allowable Cw
11.0
19
0.5
<1
_
Max Value
2.5
20
0.5
<1
21
0.5
<1
Tdchloroethene
22
0.5
<1
Max. Pred Cw
_
8.25
23
0.5
<1
Allowable Cw
92.4
24
0.5
<1
Max Value
2.5
25
0.5
<1
26
0.5
<l.
<1
Tetrachloroethene
27
0.5
Max. Pred Cwi
6
28
2.5
<5
<1
Allowable Cw
8.9
29
0.51
Max Value
2.5
_
30
0.5
<1'
Manganese
Max. Pred Cw
50
Allowable Cw
50.0
Max Value
50
Ethylbenzene
Max. Pred Cw
8.5
Allowable Cw
29000.0
Max Value
2.5
1,2 Dichloroethane
Max. Pred Cw
8.5
Allowable Cw
99.0
_
I
Max Value
2.5
Chloroform
Max. Pred Cw
19.78
Allowable Cw
470.0
Max Value
4.6

i
ammeter=
Iron
i
Parameter=
Toluene
Standard =
1
pg/I
Standard =
11
pg/I
I
n
BDL=1/2DL
Actual Data
RESULTS n BDL=1/2DL
Std Dev. 248.02 1 0.5
Mean 161.54 _ 2 0.5
C.V. ---1.54 3 0.5
4 0.5
5 0.5
Mult Factor = 7 6 0.5
Max. Value 830 pg/I 7 0.5
Max. Pred CH 5810 pg/I 8 0.5
Allowable Cw 1.0 pg/I 9 0.5
10 0.5
11 0.5
12 0.5
13 0.5
-14 0.5
15 0.5
16 1
Actual Data
RESULTS
1
50
<100
<1
Std Dev.
_
0.373
2
50
<100
<1
Mean
0.583
3
_
50
<100
<1
C.V.
0.640
4
50
<100
<1
5
50
<100
<1
6
50
<100
<l
Mult Factor=
2
7
50
<100
<1
Max. Value
2.5
pg/I
8
140
140
<t
Max. Pred Cv
5
pg/I
9
580
580
<I
Allowable Cw
11.0
pg/I
10
50
<100
<1
11
100
100
<1
12
50
<100
<1
13
830
830
<1
<1
<1
<2
17
0.5
<1
181
0.5
<1
19I
0.5
<1
20
0.5
0.5
<1
<1
- 21
22
0.5
<1
23
0.5
<1
24
0.5
<1
25
0.5
<1
26
0.5
<1
27
0.5
<1
28
2.5
<5
29
0.5
<1
30
0.5
<1

Parameter=
Trichloroethene
Parameter=
I Tetrachloroethene
Standard =
1 92.4 Ng/I
I Standard =
1 8.851
Ng/I
n BDL=1/2Dl- Actual Data
1 0.5 <1
2 0.5 <1
3 0.5 <1
IRESULTS
n
BDL=1/2DL
Actual Data
RESULTS
Std Dev.
0.5233
1
0.5
<1
Std Dev.
0.5477
Mean
0.6667
2
0.5
<1
Mean
0.6933
C.V.
0.7849
3
0.5
<l'
C.V.
0.7899
4
0.5
<1
4
0.5
<1'
5
0.5
<1
5
<1
6 0.5
<1
Mult Factor-
3.3
6
_0.5
0.5
<1
Mult Factor
2.4
7 0.5 <1
8 0.5 <1
9 1 <2
10 05 <1
11 0.5 <1
12 05 <1
13 2-5 <5
14 0.5 <1
15 0.5 <1
Max. Value
2.5
pg/I
7
0.5
<1
Max. Value
2.5
pg/I
Max. Pred Cy
8.25
pg/I
8
0.5
<7
Max. Pred Ci
6
pg/I
Allowable Cvy
92.4
pg/I
9
0.5
<1
Allowable Cm
8.9
pg/I
10
0.5
<1
11
0.5
<1
12
0.5
<1
13
0.5
<1
14
0.5
<1
15
0.5
<11
i
16
1
<2
<l
17
0.5
9
18
0.51
<1 -
19
0.51
<t
20
0.51
<1
2.4
Ib
21
2.4
22
1.9
1.9 -
23
0.5
<11
24
0.5
<1
25
0.5
<t
26
- - 0.5
<1
27
0.5
<1
28
2.5
<5
29
0.5
<1
30
0.5
<1

aiameter=
Man anew
Parameter=
Ethylbenzene
Standard =
100
pgA
Standard =
29,000
pgA
n
BDL=1/2DL
Actual Data
RESULTS
n
BDL=1/2DL
Actual Data
RESULTS
1
_
50 <100 Std Dev. 39.256
50 <100 Mean 69.231
50 <100 C.V. 0.567
50 <100
50 <100
50 <100, Mult Factor 2.71
1
0.5
<1
Std Dev.
0.5409
2
21
0.5
<1
Mean
0.6786
3
3
0.5
<1
C.V.
0.7971
4
4
0.5
<1
5
5
0.5
<l
6
61
0.5
<1
Mult Factor
3.4
7
50 <100
Max. Value
170
pgA
7
0.5
<1
Max. Value
2.5
pgA
8
50 <100 I
I Max. Pred C
459
pgA
81
1
<2
Max. Pred C
8.5
pgA
9
50, <100
Allowable Cm
100.0
pgA
9
0.5
<1
Allowable Cyi
29000.0
pgA
10
50
<100
10
0.5
<1
11
130
130
11
0.5
<1
121
170
170
12
2.5
<5
13
100
100
13
0.5
<1
14
0.5
<1
I
I

pg/l
Actual Data RESULTS
4.6 Std Dev.
Parameter=
1,2 Dichloroethane
Parameter=
Chloroform
Standard =
99
pgn
Standard =
470
n
BDL=1/2DL
Actual Data
RESULTS
n
BDL=1/2DL
1
0.5
<1
1 Std Dev.
0.7062
1
4.61
1.3573
2
1.5
1.5I
',Mean
0.8786
2
3
3 Mean
1.3286
3
0.5
-
<l
_
C.V.
0.8038
31
0.5
<1 I C.V.
<1
1.0216
4
0.5
<1
41
0.5
5
0.5
<1
5
0.5
<1
6
0.5
<1
MultFactor=
3.4
6
0.5
<1
Mutt Factor =
4.3
7
0.5
<7
Max. Value
2.5
pg/l
7
0.5
<7
Max. Value
4.6
pg/l
8
1
<2
Max. Pred Cy
8.5
pg/l
8
1
<2
Max. Pred Cv
19.78
pg/l
9
0.5
<1
Allowable Cw
99.0
pgA
9
0.5
<1
Allowable Cw
470.0
pg/l
10
2.3
2.3
10
3
3
11
0.5
<1
11
0.5
<1
12
2.5
<5
12
2.5
<5
13
0.5
<1
13
0.5
<1
14
0.5
<1
14
0.5
<1

LAW
LAWGIBB Group Member
November 30, 1999
Mr. Charles H. Weaver, Jr.
North Carolina Department of Environment and Natural Resources
Division of Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27626-1617
Subject: Application for NPDES Permit Renewal
NPDES Permit NCO086517
Cousins Real Estate: Gateway Village
800 Block— West Trade Street
Mecklenburg County
Charlotte, North Carolina
LAW Project 30100-7-3245
Dear Mr. Weaver:
t
DENR -WATER QUALITY
POINT SOURCE BRANCH
This application is being submitted on behalf of Cousins Real Estate Corporation (Cousins) by
Law Engineering and Environmental Services, Inc. (LAW). Cousins is the responsible party -of -
record for the 800 Block — West Trade Street property. Enclosed please find three copies of a
completed National Pollutant Discharge Elimination System (NPDES) Permit Application - Short
Form C-GW for the subject property.Authorization to construct the subject treatment facility was
issued on March 29, 1999. Since construction there have been no changes to the facility.
Please note that the subject facility does not generate any solids and therefore does not require a
sludge management plan. If you have any questions regarding this submittal or require additional
information, please contact us at [phone].
Sincerely,
LAW ENGINEERING AND ENVIRONMENTAL SERVICES, INC.
Richard A. Donaldson, E.I.T. Robert C. Foster, P.G.
Project Engineer
[_: It I .I
Principal
Enclosures: NPDES Permit Renewal Application
Document of Representative Authorization
cc: Ms. Jerri Tuck
Cousins Real Estate Corporation
LAW Engineering and Environmental Services, Inc.
2801 Yorkmont Road • Charlotte, NC 28208
704-357-8600•Fax: [phone]

Report of Alternatives to Surface -Water Discharge
The following report of alternatives to surface discharge will be outlined in the same format as the
"Guidance for Evaluation of Wastewater Disposal Alternatives".
I. General Information
A. Provide the following:
1. Facility name — NationsBank Operations Center, Gateway Village,
2. County - Mecklenburg
3. facility address — 800 Block, West Trade Street, Charlotte, North Carolina
4. Report preparer's name — Richard A. Donaldson
5. Report preparer's mailing address and telephone number - LAW Engineering and
Environmental Services, Inc., 2801 Yorkmont Road, Charlotte, North Carolina
28208 [phone]
B. Detailed description of the project:
Project Description - Treat and discharge ground water recovered from construction -
related de -watering and permanent de -watering of a below -ground service area for a multi-
story mixed -use building. Water produced during short-term construction -related de -
watering and long-term permanent de -watering will be collected in a surge tank and
forwarded by transfer pumps to activated carbon vessels for treatment. Post -treated water
will be discharged directly to the storm -sewer system, with indirect discharge to Irwin
Creek (Figure 3).
Justification and Demonstration of Need - Ground water has been impacted by
petroleum constituents and chlorinated solvents. Recent laboratory analytical data from
ground -water samples obtained from fifteen monitoring wells at the site indicate that
concentrations of some of the constituents detected are above the North Carolina
Department of Environment and Natural Resources (NCDENR) limits. Due to the
impacted ground water that could be potentially produced during de -watering at the site,
initial start-up of the de -watering system will produce the maximum flow, which has been
estimated at 35 gallons per minute (gpm) or 50,400 gallons per day (gpd). The average
flow is estimated at 20 gpm (28,800 gpd). Flow during permanent de -watering will likely
be below the anticipated average.
C. Not applicable
D. Two phases - Temporary de -watering during construction with estimated maximum flow
of 35 gpm to 20 gpm average. Permanent de -watering with average flow estimate of 10
to 20 gpm or less as a function of fluctuating ground -water level.

H. Evaluation of Disposal Alternatives
1. Connection to Publicly Owned Treatment Works (POTW) — POTW temporary permit will
be processed upon receipt of application with confirmation that NPDES permit application
has been received by the NCDENR. This temporary permit is anticipated to have
sufficient duration (six months) for NCDENR process and approval of this application.
2. Connection to privately owned treatment works - Site located in downtown Charlotte
3. Individual subsurface systems - septic tank - As above
4. Community subsurface systems - As above
5. Drip irrigation - both surface and subsurface - As above
6. Spray irrigation - As above
7. Reuse - As above
8. Surface water discharge through the NPDES program - Yes, see Section II.D below
9. Any possible combination of the above options - No
Section A - Not applicable
Section B - No available land for irrigation. Site is located in downtown Charlotte. Site will be
totally occupied by building structure(s).
Section C - Not applicable. Site is located in downtown Charlotte.
Section D - Per a September 8, 1998 telephone conversation with Mr. Curtis Weaver of the USGS,
the stream flow information for the receiving stream (Irwin Creek) is prorated for the
discharge point based on upgradient station data as follows: the 7Q 10 is 0.49 cubic
feet per second (cfs) and the 30Q2 is 1.57cfs.
Items 2-5 of Section D are not applicable to this project.
Section E - Not applicable
Appendix A and B - Not applicable
A Listing of Chemicals Found
This is a compilation of "worst case" concentrations of detected in site monitoring wells.
Constituent
Concentrations (ug/L)
Chloroform
2.68
1,2 - Dichloroethane
6.60
Tetrachloroethene
102
Trichloroethene
2.03
Bis(2-ethylhexyl)phthalate
3.39
Methyl-tert-butyl ether
58.6

If you have any questions regarding this submittal or require additional information, please contact
us at [phone].
Sincerely,
LAW ENGINEERING AND ENVIRONMENTAL SERVICES C.
Richard A. Donaldson, E.I.T. Robert C. Foster, P. .
Project Engineer
RAD/RCF:rad
Principal
Enclosures: NPDES Permit Renewal Application
Document of Representative Authorization
cc: Ms. Jerri Tuck
Cousins Real Estate Corporation
Charlotte, North Carolina

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STORM WATER DRAINAGE DIRECTION APPROXIMATE SCALE IN FEET
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LAW
STORM WATER DISCHARGE POINT
//� LAW NATIONSBANK OPERATIONS CENTER —GATEWAY VILLAGE
ENGINEERING AND ENMRONMENTAL SERVICES 800 BLOCK — TRADE STREET
CHARLOTTE. NORTH cARaINA CHARLOTTE, NORTH CAROLINA
y BYEP/I/ D,, D 9I3�it� CHE ED DAT / JOB N0. 30100-7-3245 FIGURE 3

0 Cousins
September 10, 1998
Law Engineering and Environmental Services
P.O. Box 11297
2801 Yorkmont Road, Suite 100
Charlotte, NC 28208
Attention: Mark Adkins
Reference: Gateway Village Phase One — NPDES Permit Application
Dear Mark:
Acting as owner agent for Charlotte Gateway Village, LLC., Cousins Real Estate
Corporation authorizes Law Engineering and Environmental Services to sign the
Gateway Village Phase One NPDES permit application on behalf of the generator,
Charlotte Gateway Village, LLC.
If you need additional information, please do not hesitate to call.
Very truly yours,
M. L. Tuck
evelopment Manager
cc: John Goff
Jim Overton
Connie Miller
Tommy Shealy
Carter Houchins
Steve Fingles
Cousins Real Estate Corporation
Cousins Real Estate Corporation
NationsBank
NationsBank
NationsBank
NationsBank
101 N. Tryon Street - Suite 1700 - Charlotte, North Carolina 28246 - 704-333-7755 - Fax [phone]

LAW
Aprils, 1999 LAWGIBB Group Member`
Mr. David Goodrich, Supervisor, NPDES Section
North Carolina Department of Environment and Natural Resources
Division of Water Quality
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Subject: Certification of Completion
Treatment System for NPDES Permit No. NCO086517
ATC No. 086517ACA
Gateway Village Phase 1
Charlotte, Mecklenburg County, North Carolina
LAW Project No. 30100-7-3245
Dear Mr. Goodrich:
As required by your Authorization to Construct for the subject project dated March 29, 1999,
Law Engineering and Environmental Services, Inc. (LAW) has completed installation of a
treatment system for ground water at Gateway Village Phase 1. This letter provides the
certification required on page 4 of the Authorization to Construct.
I, Thomas F. Beggs, P.E., as a duly registered Professional Engineer in the State of
North Carolina, having been authorized to observe periodically the construction of
the project, Gateway Village Phase 1, Charlotte, Mecklenburg County, North
Carolina for the Permittee hereby state that, to the best of my abilities, due care and
diligence was used in the observation of the construction of the dewatering
remediation system such that the construction was observed to be built within
substantial compliance and intent of the approved plans and specifications.
Please note that two elements of the approved plans have not yet been completed. Only one of
the two bag filters proposed has been installed. The automatic phone dialer system was installed,
but was temporarily removed due to construction activities at the site. The system can function
adequately without the second bag filter and the phone dialer system, however they will be
installed as soon as possible to fully meet the approved plans and specifications. The system
will be operational beginning this 5th day of April, 1999.
If you have any questions or comments regarding our work on this project, please contact us.
Sincerely,
LA ENGINEERNMENTAL SERVICES, INC.
O ; FgSSlp
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Thomas F. Begg;s, P.j;. EAL g _ Michael D. Armour, P.G.
Principal — e 13007 Principal
Registered NC A, 13`8Q7F�,___,,EQ,°�, e
Cc: Ms. Jerri L. PMc,�; ESut;i XJ I Estate Corp.
LAW Engineering and Environmental services. Inc.
2801 Yorkmont Road • Charlotte. NC 28208
704-357-8600 • Fax: [phone]

LAW
FollyZr /X AC C, ivPDE j
LAWGIBB Group Member Z-I?-99
February 9, 1999
w
Mr. David Goodrich
-n
North Carolina Department of Environment and Natural Resources m
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Division of Water Quality —
Permits and Engineering Unit
512 North Salisbury Street
Raleigh, North Carolina 27626-0535 N
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Subject: Authorization to Construct
NPDES Permit Application
Permit NC008"7 $bS 17
NationsBank Operations Center
Charlotte, Mecklenburg County, North Carolina
Dear Mr. Goodrich:
On behalf of Cousins Real Estate Corporation (Cousins), Law Engineering and Environmental
Services, Inc. (LAW) requests that an Authorization to Construct (A to C) be issued for the subject
NPDES permit. It is further requested that both the A to C and NPDES permit be issued prior to
the April 5, 1999 expiration of the local POTW permit currently in place to allow treatment and
discharge of ground water recovered from construction related dewatering activities. The subject
NPDES permit application was submitted to your office on September 8. 1998. In this application
it was presented that the proposed system would be used for construction related and permanent
facility dewatering operations. and that the interim local POTW permit would only last for
approximately six months (the POTW permit expires on April 5, 1999). The duration of the
POTW permit was based on the length of time that the NCDENR approved previous permits and
A to C for a downtown Charlotte construction project(s). Based on recent discussions with Mr.
Tom Belnick of your section it is my understanding that the NPDES permit nor the A to C. even if
requested per NCDENR requirements may now not be issued prior to the POTW permit expiration
on April 5, 1999.
The original NPDES permit submitted by LAW contains the information and satisfies the
NCDENR requirements for issuance of the A to C. mth the exception of the stamped comment
"Final Plans Not for Construction" on the applicable figure. 1 have included this revised figure as
part of this A to C request. This information was submitted in an effort to expedite the review
process due to the limited permit from the local POTW [Charlotte Mecklenburg Utility District
(CMUD)]. It is imperative that this permit and A to C be provided prior to April 5. 1999 to
preclude the extremely costly option of trucking and disposal of the water of'. site.
The discussions I had with Mr. Belnick revealed that the internal NCDENR review process and
related schedule and public review period are the reasons for this unusual delay. I am sure that the
public review requirement cannot be shortened. but your assistance to accelerate the internal
NCDENR process to meet our critical time frame is requested
LAW Engineering and Environmental Services, Inc.
2801 Yorkmont Road • Charlotte, NC 28208
704-357-8600 • Fax: [phone]

Mr. David Goodrich
February 9, 1999
' Page 2
If LAW can provide any additional information/material that would further assist in accelerating
this process, please contact me at [phone].Your assistance and cooperation in this matter is
greatly appreciated.
Sincerely,
LAW ENGINEERING AND ENVIRON NTAL SERVICES, INC.
Michael D. Armour, P.G.
Principal Geologist
attachment

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NiG11 LEVEL SHUTOFF SWITCHES PUMP
CONTROL
PANEL
ESTIMATED "WORST CASE"
PUMP
114FLUENT TOTAL VOLATILE
GItGAIIIC C014CENTRATIGIIS
01753 cn(jA(ppin).
FROM
OE WA TERtNG
WELLS OR
SURGE /
OEWAIERING
TRANSFER
TANK
SYSTEM
700 -1000
COLLEC ["I
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GAt IONS
SUMP/TAIIK'
-
TRANSFER/
SUMP
PUMPS
EXPLANATION
p..l = FLOW CONTROL VALVE
CPj = PRESSURE GAUGES
QMAX — DISCHARGE MAXIMUM
QAV = DISCHARGE AVERAGE
GPM = GALLONS PER MINUTE
Fitt 0 NOTES FROM LAW
tit(A IELhIIIG PERSOUlIEL.
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-PRESSURE FLOW-�
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ACTIVATED
CARBON
- —D<)� VESSEL.
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(�J 1000
TRANSFER DUAL
PUMPS BAG
FIL IER
FINAL PLANS NOT FOR CONSTRUCTION
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AC IIVA TED
CARBON DISCHARGE
VESSEL
L Q " 20 GPM
'~ FLOW
1000 lbs. � WAMTf 33 GPM
(P)
FLOW METERING ESTIMATED EFFLUENT
DEVICE TOTAL VOLATILE ORGANIC
CONCENTRATIONS
1.753.10'5mciA.
tl4IEz
• FROM GRAVITY FEED TO GRAVEL DRAINS/SUMPS DURING BUILDING CONSTRUCTION
AND SUMP PUMPS FOR PERMANENT BELOW t,KADE DEWATERING OF
BUILDING SERVICE AREA
AAkLAW
ENGINEERING AND ENVIRONMENTAL SERVICES
CHARLOTTE. NOR RI CAROI.INA
PREPARED ' 0�►
OAT/y
DEWATERING TREATMENT
SYSTEM SCHEMATIC
NATIONSBANK OPERATIONS CENTER — GATEWAY VILLAGE
800 BLOCK —TRADE ST. CHARLOTTE, NORTH CAROLINA
.LOB NO. 30100— 7— 3245 1 FIGURE 5

ATC Review
Groundwater Remediation System
NC0086517 (086517ACA)
Cousins Real Estate Corp -Gateway Village Phase I
Prepared by: Tom Belnick, NPDES Unit
Date: March 19, 1999
Proposed Syystem: The permittee has proposed a 0.050 MGD groundwater dewatering remediation
systemsdissolved phase gasoline and chlorinated solvents. The system is based on an estimated Q..
= 0.050 MGD during initial startup of construction dewatering; a Q.,yg= 0.028 MGD for construction
dewatering; and a long-term building dewatering of Q= 0.007 MGD. Treatment components will
include:
• Surge/transfer tank; 700-1000 gal capacity.
• Dual bag filter system- 10-micron bag filters; rated to accept 0.070 MGD.
• Dual liquid -phase granular activated carbon vessels in series; each vessel contains 1000-lbs of
media; vessels have a QD of 0.070 MGD; breakthrough at worst -case concentrations expected at
33 days at 0.050 MGD, 58 days at 0.028 MGD, and 116 days at 0.014 MGD. Worst case
concentrations were determined for: chloroform, 1,2-Dichloroethane, tetrachloroethene,
trichloroethene, bis (2-ethylheyl) phthalate, and MTBE. Carbon removal efficiencies were
projected to be 99.9 % removal based on consultant experience and Calgon Carbon Corp data.
• Continuous reading flow meter.
• Control panel.
• Transfer/sump pumps and associated piping/appurtenances.
This treatment system is currently installed and being operated onsite with discharge going to CMUD
sewer on an interim basis (till April 5, 1999). After receiving ATC, permittee will relocate effluent pipe
to storm sewer drain with eventual surface water discharge.
NPDES Review: The consultant provided a thorough design package. Manufacturer's specs were
includedr for aTtreatment components. Consultant provided GAC breakthrough calculations which
indicate that even at initial Qmax= 0.050 MGD and worst case concentrations, breakthrough will not
occur until at least 33 days. Based on current operation with discharge to CMUD, consultant has stated
that the GAC components are lasting more than 30 days without breakthrough, and there is no evidence
of iron/manganese binding of the GAC unit. Both the bag filters and GAC units are conservatively
designed to handle a Q= 0.070 MGD, compared to the estimated Qmax = 0.050 MGD at startup and
Qavg = 0.028 MGD. NPDES does not anticipate any problems with this proposed system.
EEH Review. m,Ke'r6yplehA rN,ecv-V Isii4atLe le-#m.'31WgI
Region Review: MRO recommended ATC issuance in letter dated 3/4/99.