Loading...
HomeMy WebLinkAboutNC0086517_Permit Issuance_20111128NCDEE R North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director November 28, 2011 David L. Edwards Cousins Property, Inc. 800 West Trade Street, Suite 100 Charlotte, NC 28202 Subject: Issuance of NPDES Permit Permit NCO086517 Dee Freeman Secretary Gateway Village Groundwater Remediation Facility Class I Mecklenburg County Dear Mr. Edwards: Division personnel have reviewed and approved your application for reinstatement of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). Please note that the receiving stream is listed as an impaired waterbody on the North Carolina 303(d) Impaired Waters List. Addressing impaired waters is a high priority with the Division, and instream data will continue to be evaluated. If there is noncompliance with permitted effluent limits and stream impairment can be attributed to your facility, then mitigative measures may be required. Summary Final Permit Requirements 1) Instantaneous flow monitoring with a monthly limit. 2) Monthly monitoring for Total Suspended Solids, Tetrachloroethene, and Cis-1,2 dichloroethene with monthly and daily limits. 3) Monthly monitoring for pH with a daily limit range. Page 1 of 2 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919.807-6300 \ FAX: 919-807.6492 \ Customer Service: 1-877-623.6748 Internet: w .nmaterquality.org An Equal Opportunity \ Aflirmabve Action Employer NorthCarolina Naturally, 4) Quarterly monitoring for Total Copper, Total Lead, Total Zinc, Chloroform, 1,2 dichloroethane, Trichloroethene, Oil and Grease, Total Iron, and Total Manganese. 5) Quarterly monitoring for Chronic Toxicity with a limit narrative. 6) Submittal of influent Volatile Organic Compounds analysis with the next permit renewal application. 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 aftennotice 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 permits that may be required. If you have any questions concerning this permit, please contact Ron Berry at telephone number (919) 807-6396 or at email ron.berry@ncdenr.gov. Sincerely, �, Q oleen H. Sullins Attachments Cc: Mooresville Regional Office/Surface Water Protection Section (email with Fact Sheet) Environmental Sciences Section/Aquatic Toxicology Unit/Susan Meadows (email) Hunter Hicks E.I. AMEC (emaiL•HMHICKS@mactec,com) Mecklenburg County/ Erin Hall (email:erin.hall@mecklenburgcountync.gov) NPDES Files Central Files Page 2 of 2 Permit: 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, Gateway Village LLC 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 an unnamed tributary to 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 January-1, 2012. This permit and authorization to discharge shall expire at midnight on June 30, 2015. Signed this day November 28, 2011. en H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission Permit: NC0086517 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Gateway Village LLC is hereby authorized to: 1. To operate a 0.05 MGD ground water treatment facility discharging treated groundwater, and consisting of: 0 1200 gallon collection tank with pump o Two (2) bag filters o Two (2) 1000 lb activated carbon canisters (in series) o Effluent meter with recorder Facility is located in Charlotte on the 800 block of West Trade Street in Mecklenburg County. 2. Discharge from said treatment works at the location specified on the attached map through outfall 001 (via a storm sewer) to an unnamed tributary to Irwin Creek, which is classified C water in the Catawba River Basin. � �. 1 fi , , J 4 • •�.♦ �1 i ° Gateway Village Facility NC40$6517'in ` ljl t(`•afI V dt NC0086517� 66 Discharge th "Y / NJ l ` 1r i .i� `&•\* 'SIY t Trade :tt F_Yt c�4 : X. _ i J� 7� f r"' 1 / USGS Quad: G15NE Charlotte, East, NC Outfall Facility Latitude: 35' 14' 4.2" N 350 14' 4.4" N r Longitude: 80051' 6" W 800 51' 5.7" W Facility Location Stream Class: C North Subbasin: 03-08-34 HUC: 03050103 Gateway Village NC0086517 Receiving Stream: Unnamed tributary to Irwin Creek Mecklenburg County Permit N0008651.7 A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge treated groundwater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily .` Maximum Measurement Frequency- Sample Type Sample Location Flow 0.05 MGD WeeklyInstantaneous Effluent Tetrachloroethene 8.9 µg1l 8.9 jLg1l Monthly Grab Effluent Cis 1,2 dichloroethene 4.9 µg/l 4.9 µg/1 Monthly Grab Effluent Total Suspended Solids (TSS) 30.0 m 1 45.0 mg/1 Monthly Grab Effluent pH Not greater than 9.0 S.U. nor less than 6.0 S.U. Monthly Grab Effluent Total Copper, Ag1l Quarterly Grab Effluent Total Lead, g/l Quarterly Grab Effluent Total Zinc, µg/1 Quarterly Grab Effluent Chloroform, µg/1 Quarterly Grab Effluent 1,2 dichloroethane, µg/1 Quarterly Grab Effluent Trichloroethene (TCE), AgIl Quarterly Grab Effluent Oil and Grease, mg/1 Quarterly Grab Effluent Total Iron, µ 1 Quarterly .'Grab Effluent Total Manganese, µg/1 Quarterly Grab Effluent Chronic Toxicity Quarterly Grab Effluent Footnotes: 1. Flow must be determined by an effluent meter. 2. A minimum detection limit of 1.0 µg/l is required. 3. The sample to be skimmed from the surface of a quiescent zone if possible. 4. Chronic Toxicity (Ceriodaphnia), P/F at 90 °Io, January, April, July, and October; or first month in each quarter that a discharge occurs. A quarter is defined as January — March, April — June, July — September, and October — December. See Special Condition A. (2) Chronic Toxicity Permit Limit (Qrtrly). Sample to be collected at same time as monitored pollutants samples. There shall be no discharge of floating solids or visible foam in other than trace amounts. There shall be no oily sheen traceable from the receiving stream to this outfall. Permit NCO086517 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, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of January, April, July, and October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised - February 1998) or subsequent versions. All toxicity testing results required as . part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed. If reporting pass/fail results using the parameter code TGP3B, DWQ Form AT-1 (original) is sent to the below address. If reporting Chronic Value results using the parameter code THP3B, DWQ Form AT-3 (original) is to be sent to the following address: Attention: NC DENR / DWQ I Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured 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 Section at the address cited above. Permit NCO086517 (Continued from A. (2) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)) Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. If the Permittee monitors any pollutant more frequently then required by this permit, the results of such monitoring shall be included in the calculation and reporting of the data submitted on the DMR and AT Forms. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. A. (3) INFLUENT VOLATILE ORGANIC COMPOUND ANALYSIS The Permittee shall perform an analysis of the influent Volatile Organic Compound (VOC) and submit the analysis as an addendum in the next permit renewal application. This VOC analysis shall be from a representative influent sample taken in the same calendar year the application is submitted. DENR/DWQ , FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES Permit NCO086517 Facility Information Applicant/Facility Name: Gateway Village, LLC GWR Applicant Address: 800 West Trade Street; Charlotte, NC 28202 Facility Address: 800 West Trade Street; Charlotte, NC 28202 Permitted Flow 0.05 MGD Type of Waste: GW dewatering treated wastewater Facility/Permit Status: Class I /Deactivated; Activation/Renewal County: Mecklenburg County Miscellaneous Receiving Stream: UT to Irwin Creek Stream Classification: C Subbasin: 03-08-34 Index No. 11-137-1 Drainage Area (mi): - HUC: 03050103 Summer 7Q10 (cfs) 0 303(d) Listed? Yes , see History Winter 7Q10 (cfs): 0 Regional Office: Mooresville 30Q2 (cfs) 0 State Grid / USGS Quad: G15NE Charlotte East, NC Average Flow (cfs): 0 Permit Writer: Ron Berry IWC (%): 100 Date: 9/14/11 Irwin Creek has 7Q 10s = 0.49 cfs (2000 fact sheet) History Development and construction at the Gateway Village site was begun in 1998, the site previously had other commercial businesses including a gas station and a meat processing facility. Consequently, the site ground water was identified as being impacted by petroleum and chlorinated solvents. During the construction dewatering phase and temporary dewatering after construction, and until a permanent remediation system could be permitted with the state, the Charlotte Mecklenburg Utility Department accepted the waste water discharge. A slurry wall to stop the migration of contaminates off site, collection sumps, and the approved ground water treatment system to remove contaminates were installed. The local utility agreed to allow the direct discharge of the parking garage dewatering sump that contained relatively clean ground water to the storm drain. A NPDES permit was granted in 2001 to discharge treated wastewater from the treatment system to the storm drain which eventually flows into Irwin Creek via an unnamed tributary. The unnamed tributary is considered a "zero" flow stream. The ground water treatment operation consisted of a single collection sump and pump that conveyed captured contaminated ground water intermittently to the treatment system 1200 gal collection tank. Once the collection tank was full, it was pumped at a maximum rate of 50 GPM through bag -type particle filters, through replaceable GAC filters, and through an effluent flow meter. Then the treated wastewater was discharged into the local storm drain. With the extremely low flow from the sump and large storage capacity of the collection tank this system did not run very often. From 2001 to 2005, the discharge from the treatment system had only occurred a few days a year. Beginning in 2005 and until the permit's scheduled 2010 renewal there had been no Fact Sheet NPDES NCO086517 Page 1 of 3 discharges. The Permittee requested the permit not be revewed but rescinded which was granted in June 2010. As part of the City of Charlotte green initiative, the property owner incorporated the parking garage dewatering sump water as a water supply to its building cooling systems. However, 2010 analyses of the parking garage dewatering sump water indicated chlorinated solvent intrusion had occurred. The owner rerouted the parking garage dewatering sump to the idle groundwater remediation system for pre-treatment prior to recycling to internal users. The treatment system present operation is to collect wastewater from multiple sumps, remove contaminates, and provide treated wastewater as cooling tower make up, or if needed divert the treated wastewater to the NPDES outfall. The Permittee has requested re -activation of the NPDES permit and submitted a NPDES permit application. Irwin Creek and its unnamed tributaries are currently impaired for copper, lead, zinc, turbidity, fecal coliform, and ecological/biological integrity to the fish community. A TMDL has been completed for turbidity and fecal coliform but are not applicable to this discharge at this time. Permitting Strategy EAA Review The Permittee was asked to re -submit the original EAA with any changes that may apply. There were no changes to the treatment system or alternative non -discharge options. The numbers provided indicate the typically influent rate is anticipated to be less than 5 gpm. The Permittee will be reminded in the cover letters that any planned equipment changes or influent changes need to be reviewed by the Division. Also, the Permittee will be instructed to provide new influent data as part of his next permit renewal. Data Review As part of the permit application, the Permittee was required to submit analyses on the wastewater influent. Because of the limited historical DMR data points and anticipated continued long periods of no discharge, the rescinded permit requirements will be adopted with additions/changes to monitoring frequency and parameters based on the latest sump influent data and Division guidelines. Mooresville Regional Office conducted a site inspection in April 2011, and recommends re -activating this permit contingent on their review and approval of its requirements. Oil and Grease; 1,2 dichloroethane; chloroform; iron; manganese; and trichloroethene monitoring were reduced to quarterly to be consistent with Division guidelines. Tetrachloroethene and cis-1,2 dichloroethene were present in the influent data is excess of water quality standards, monthly limits with monthly monitoring will be required. Tetrachloroethene and cis-1,2 dichloroethene have no acute standard or daily limit criteria. To be in compliance with EPA guidance the tetrachloroethene and cis-1,2 dichloroethene monthly limit will also be assigned as the daily limit. Monthly pH monitoring with a daily limit range will be added to this permit. Flow and TSS monitoring and limits remain unchanged from the rescinded permit. Toxicity Review Only one chronic toxicity test had ever been completed during the history of this discharge and was failed. To define the unknown toxic nature of the new effluent and assist with this permit Fact Sheet NPDES NC0086517 Page 2 of 3 f. development, the owner was required to provido the results of a chronic toxicity test at 90% concentration. The new effluent passed its chronic toxicity test. Will continue to require quarterly chronic toxicity testing with narrative limit. Will update narrative in footnote to remind Permittee that the first discharge in any given quarter is subject to the required quarterly chronic test. Will update the special condition narrative to the current version. Impairment Review Copper, lead, and zinc are listed impairments for this watershed. New influent data for copper, lead, and zinc and effluent chronic toxicity test were requested and provided. The effluent chronic toxicity test was passing. Reported copper and zinc levels were above 300 µg/L, but copper and zinc are action level so quarterly monitoring will be required. The influent lead level did not exceed WQS so only quarterly monitoring will be required. The reported data will be reviewed at the next renewal. Turbidity and fecal coliform are also listed impairments for this watershed but are not considered parameters of concern from this discharge. The Division impairment notification statement will be included in all cover letters. Other Regulatory Authority Review Since this discharge is in Charlotte Mecklenburg Utility Department jurisdiction, they will be sent this permit for review. SUMMARY OF PROPOSED REQUIREMENTS In keeping with Division policies the following will be incorporated into the permit: • Quarterly monitoring for Oil and Grease; 1,2 dichlorethane; chloroform; copper; iron; lead; manganese; trichlorethene; and zinc; will be established. • Monthly monitoring for TSS, pH, tetrachloroethene, and cis-1,2 dichloroethene with limits will be established. • Quarterly chronic toxicity testing with narrative limit will be established. • A footnote narrative defining the minimum report limit for various pollutants will be established. • A special condition narrative defining chronic toxicity testing and reporting will be established. • A special condition requiring submittal of influent VOC with the next renewal application will be established. PROPOSED SCHEDULE FOR PERMIT ISSUANCE Draft Permit to Public Notice: September 28, 2011 Permit Scheduled to Issue: November 2011 NPDES DIVISION CONTACT If you have questions regarding any of the above information or on the attached permit, please contact Ron Berry at (9121807-6396 or email ron.berry@ncdenr.gov. REGIONAL OFFICE COMMENTS SUPERVISOR: DATE: Fact Sheet NPDES NCO086517 Page 3 of 3 NPDES Permit NCO086517 From: Hicks, Hunter [HMHICKS@mactec.com] sent: Wednesday, March 23, 2011 11:22 AM To• Berry, Ron subject: NPDES Permit NCO086517 Attachments: system Schematic.pdf; original Permit Application.pdf Mr. Berry, I found the original permit application with the EAA on page 4. I will attach this and a schematic of the system to this email. I will also mail a hard copy of the original permit application with EAA for your records. For clarification, the water reuse program is proposed and no changes have been made to the system. At some point in the future, Gateway plans to tap into the system after the flow meter and use water for part of the buildings cooling system. This is reflected in the attached schematic. If you need any more information, please let me know. Thanks Hunter M. Hicks IV, E.I. ? staff Engineer II MACTEC Engineering and Consulting, Inc.1 Charlotte, NC office 704-357-5554 ? Fax 704-357-8638 Email hmhicks@mactec.com? web www.mactec.com Page 1 • r a i NC 2010 Integrated Report Categories 4 and 5 Impaired Waters =Alll§§ 23 Watemin NC are in Category 5-303(0) List for Mercury du:e to statewide fish. consumption advice for several fish species AU ,Number ALIName ALIDescription LengthArea AU_Units Classification Category Parameter Reason for Rating Use Category Collection Year 303(d)year Catawba River Basin Catawba River Basin Sugar Creek Watershed 030SO10301 Catawba River Subbasin 03050103 Catawba River Basin Q 11-137-1 Irwin Creek 5 Copper From source to Sugar Creek Standard Violation Sugar Creek Watershed 0305010301 11.8 FW Miles C Aquatic Life 2006 2010 4s Ecological/biological Integrity FishCom Poor Bioclassification Aquatic Life 2004 1998 4t Fecal Coliform (recreation) Standard Violation Recreation 2008 2008 S Lead Standard Violation Aquatic Life 2006 2008 4t Turbidity Standard Violation Aquatic Life 2008 2000 5 Zinc Standard Violation Aquatic Life 2006 2010 Q 11-137-8a Little Sugar Creek 5 Copper From source to Archdale Rd Standard Violation Aquatic Life 11.6 FW Miles 2008 C 2008 4s Ecological/biological Integrity Benthos Poor Bioclassification Aquatic Life 2008 2008 4s Ecological/biological Integrity FishCom Fair Bioclassification Aquatic Life 2007 2010 4t Fecal Coliform (recreation) Standard Violation Recreation 2008 1998 4t Turbidity Standard Violation Aquatic Life 2008 2010 5 Water column Mercury Standard Violation Fish Consumption 2008 2010 Q 11-137-8b Little Sugar Creek 5 Copper From Archdale Rd to NC 51 Standard Violation Aquatic Life S.S FW Miles 2006 C 2010 4s Ecological/biological Integrity Benthos Fair Bioclassification Aquatic Life 2007 1998 4s Ecological/biological Integrity FishCom Fair Bioclassification Aquatic Life 2007 2010 4t Fecal Coliform (recreation) Standard Violation Recreation 2008 1998 Q 11-137-8c Little Sugar Creek 4s Ecological/biological Integrity Benthos From NC 51 to North Carolina -South Carolina State Line Poor Bioclassification Aquatic Life 3.0 FW Miles 1983 C 2000 4t Fecal Coliform (recreation) Standard Violation Recreation 2008 1998 4t Turbidity Data Inconclusive Aquatic Life 2008 2000 Q 11-137-9a 5 McAlpine Creek (Waverly Lake) Ecological/biological Integrity Benthos From source to SR 3356, (Sardis Rd) Fair Bioclassification Aquatic Life 8.5 FW Miles 1987 C 1998 4t Fecal Coliform (recreation) Standard Violation Recreation 2008 1998 NC 2010 Integrated Report Category 4 and 5 303(d) List EPA Approved Aug 31, 201 9/20/2010 Page 28 of 145 RE Gateway village reply comment From: Berry, Ron Sent: Monday, October 17, 2011 3:22 PM To: 'Hicks, Hunter' subject: RE: Gateway village Hunter, No problem, the narrative will be amended to "if possible". Ron Ron Berry ron.berry@ncdenr.gov Engineer I DWQ/Point Source/NPDES Complex Permitting unit NCDENR Phone: (919) 807-6396 Fax: (919) 807-6495 office: Archdale Building Room 925N Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Hicks, Hunter [mailto:HMHICKS@mactec.com] Sent: Thursday, October 13, 2011 1:49 PM To: Berry, Ron Cc: Reed, Kerry Subject: RE: Gateway village Ron, In looking over the permit (NC0086517) we had a question about the oil and grease sampling: In the permit, it states that "the sample must be skimmed from the surface of the quiescent zone." Due to the setup at our facility, there is not a quiescent zone. Can we get the language changged to "the sample must be skimmed from the surface of the quiescent zone if possible." This would be the same as the previous permit. I have attached a picture of the sampling location and there is not an open area to "skim" a sample. The flow goes through the flow meter into a closed storm drain. Please excuse the MS Paint graphics. Thanks Hunter M. Hicks IV, E.I. ? staff Engineer II AMEC E & I office 704-357-5554 ? Fax 704-357-8638 Email Hunter.Hicks@amec.com? web www.amec.com From: Berry, Ron [mailto:ron.berry@ncdenr.gov] sent: Tuesday, October 04, 2011 3:28 PM To: Hicks, Hunter subject: RE: Gateway village Hunter, I regret I had not sent you a copy as promised, but attached is the draft permit and Page 1 RE Gateway village reply comment cover letter. Ron Ron Berry ron.berry@ncdenr.gov Engineer I DWQ/Point Source/NPDES Complex Permitting unit NCDENR Phone: (919) 807-6396 Fax: (919) 807-6495 office: Archdale Building Room 925N Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Hicks, Hunter [mailto:HMHICKs@mactec.com] Sent: Tuesday, October 04, 2011 11:24 AM To: Berry, Ron subject: Gateway village Ron, we just saw the Gateway village notice on the DENR website posted 9/28/11. Can we get a copy of the draft permit? Thanks Hunter M. Hicks IV, E.I. ? Staff Engineer II AMEC E & I office 704-357-5554 ? Fax 704-357-8638 Email Hunter.Hicks@amec.com? web www.amec.com Page 2 The Charlotte Observer Publishing Co. Charlotte, NC North Carolina ) ss Affidavit of Publication Mecklenburg County) THE CHARLOTTE OBSERVER NCDENR/DWD/POINT SOURCE B 1617 MAIL SERVICE CENTER RALEIGH NC 27699 REFERENCE: 40508896 D.SPRINKLE 031155/6604641 GATEWAY - NPDES Before the undersigned, a Notary Public of said County and State, duly authorized to administer oaths affirmations, etc., personally appeared, being duly sworn or affirmed according to law, doth depose and say that he/she is a representative of The Charlotte Observer Publishing Company, a corporation organized and doing business under the laws of the State of Delaware, and publishing a newspaper known as The Charlotte Observer in the city of Charlotte, County of Mecklenburg, and State of North Carolina and that as such he/she is familiar with the books, records, files, and business of said Corporation and by reference to the files of said publication, the attached advertisement was inserted. The following is correctly copied from the books and files of the aforesaid Corporation and Publication. PUBLISHED ON: 09/30 Public Notim NaM Cerollaa Emironmanfal Managerneat CommsebnJNPDES Unit 1617 Mee Service Canter aelelgh, NC 27SO W 7 Nabial of Intent in Iwue a NPDES WaetawaUX Parma Nolan Carolina Environrtreniel Management Commvsslon ogee to weal a NPDES wagtevwd rdacharge Permit to the ,ntgt all babes. .... 100. ChafbnG. 17 for Gateway q County; the an uanabled Woman, quaiay e In this partion AD SPACE: 64 LINE FILED ON: 10/06 1 ________ ____ __ _ _________%� ( /� NA TITLE: fJ�I�n"L� CS ✓ DATE: In Tes mony Whereof I have hereunto set my hand and affixed my seal, the ` day and yfir aforesaid./,/J� ����J,(/, _ Nota / 6� 1� V ""' M Okni sMn Expires: My CommmW EXPWVS MW V, 2016 August 15, 2011 Mr. Ron Berry North Carolina Department of Environment and Natural Resources DWQ/Point Source/NPDES Complex Permitting Unit 1628 Mail Service Center Raleigh, NC 27699-1628 Subject: Additional Information for NPDES Permit Developmer Gateway Village 800 West Trade Street Charlotte, Mecklenburg County, North Carolina 28202 AMEC Project: 6228-08-4564 =D n�_AUG-..22 NRQUALITY Dear Mr. Berry: On behalf of Gateway Village, LLC care of Cousins Properties, Inc., AMEC submits the additional information as requested by the NCDENR to complete the NPDES permit. On July 18, 2011, AMEC collected a sample from the effluent of the system for analyses of chronic toxicity by the LC50/Acute Toxicity Test method. The effluent sample passed with 0% mortality at all analyzed concentrations. The results are attached. As stated in an email on July 11, 2011 from Mr. Berry to Mr. Hunter Hicks of AMEC, "The purpose of passing this toxicity test is to demonstrate the current dewatering sources can be successfully treated and thus eliminate the addition of copper and zinc limits based on the current Division policy for NPDES permit development." Additionally, as an engineering alternative analysis, Mr. Berry requested that AMEC contact Charlotte -Mecklenburg Utilities to determine if Charlotte -Mecklenburg Utilities would accept effluent from the system. On August 2, 2011, Mr. Hicks spoke with Mr. Bill Gintert of the Systems Protection, Environmental Management Division of Charlotte -Mecklenburg Utilities. Mr. Gintert informed AMEC that Charlotte -Mecklenburg Utilities does not accept groundwater and therefore, would not accept effluent from the system since it originates from a groundwater sump. A letter from Mr. Gintert summarizing the conversation is attached. Additional Information for NPDES Permit Development Gateway Village AMEC Project. 6228-10-5369 August 15, 2011 AMEC, on behalf of Gateway Village, requests that NCDENR considers the above information for permit development. If the NCDENR has additional questions or comments, please contact Hunter Hicks or Kerry Reed at AMEC at 704-357-8600. AMEC respectfully requests that the NCDENR provides both Cousins Properties and AMEC with a copy of the draft permit when it is issued for public notice. Sincerely, AMEC E & I, INC. Kerry A. Reed, P.E., LEED AP Senior Engineer , �h ; Robert C. Foster, L.G. Project Manager cc: Mr. Samar Bou-ghazale, NCDENR — Mooresville Regional Office Mr. David Edwards, Cousins Properties Attachments: Laboratory Report Letter from Charlotte Mecklenburg Utilities, dated Aug 10, 2011 aceAnalytical e w pawlaasmff. July 29, 2011 Mr. Hunter Hicks AMEC-Charlotte 2801 Yorkmont Road, Ste 100 Charlotte, NC 28208 Pace Analytical Services, Inc. 205 East Meadow Road - Suite ' Eden, NC 27288 (336)623-8921 RE: Project: EFFLUENT Pace Project No.: 9298459 Pace Analytical Services, Inc. 2225 Riverside Dr. Asheville, NC 28804 (828)254-7176 b� 1�lz Pace Analytical Services, Inc. 9800 Kincey Ave. Suite 100 Hunlersville, NC 28078 (704)875-9092 Dear Mr. Hicks: Enclosed are the analytical results for sample(s) received by the laboratory on July 18, 2011. The results relate only to the samples included in this report. Results reported herein conform to the most current TNI standards, where applicable, unless otherwise narrated in the body of the report. Analyses were performed at the Pace Analytical Services location indicated on the sample analyte page for analysis unless otherwise footnoted. If you have any questions concerning this report, please feel free to contact me. Sincerely, r:l Kevin Godwin kevin.godwin@pacelabs.com Project Manager Enclosures REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc.. Page 1 of 2 01 • ' ® Pace Analytical Services, Inc. Vace Analytical Services, Inc. Pace Analytical Services, Inc. ice Analytical 205 East Meadow Road - Suite A 2225 Riverside Dr. 9800 Kincey Ave. Suite 100 I -- www.pacelabs.com Eden, NC 27288 Asheville, NC 28804 Huntersville, NC 28078 (336)623-8921 (828)254-7176 (704)875-9092 PROJECT NARRATIVE Project: Pace Project No.: Method: Description: Client: Date: This data package has been reviewed for quality and completeness and is approved for release. REPORT OF LABORATORY ANALYSIS Page 2 of 2 This report shall not be reproduced, except in full. without the written consent of Pace Analytical Services, Inc.. Effluent Toxicity Report Form- Chronic Pass/Fail and Acute LC50 Date Facility O(A- l 11 NPDES#NC Pipe # C?)I County Laboratory Performing Test r, izn Comments UA I 1 t�=4 -C of Operator Signature of LaboratorK*9 rvisor 61 I MAIL ORIGINAL TO- Div.ironmental ofWaterQu Sciences Branch N.C. DENR 1621 Mail Service Center North Carolina Ceriodaphnia Chronic Pass/Fail Reproduction Toxicity Test Raleigh, North Carolina 27699.1621 CONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 . I Chronic Test Resuits Calculated t # Young Produced Tabular t Reduction Adult (L )ive (D )ead Effluent% '.1 TREATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 9 Young Produced Adult (L )ive (D )ead 1st sample 1st samole 2nd sample Control PH Treatment 2 s s s t e t e t e a n a n a n r d r d r d t t t 1st sample 1st sample 2nd sample Control D.O. Treatment 2 LC501Acute Toxicity Test (Mortality expressed as %, combining replicates) . M LC50= � I 00 °/, 95% Confidence Limits %- % Organism Tested DWQ form AT-1 (3/87) rev. 11195 Sample 1 11 12 Control Cv PASS FAIL pmoudrp 3rt1 isrn Check One Sample 2 Sample Type/Duration Grab lComo. IDuration 3ampie.1 t/ O 3ampie 2 _ Hardness(mgA) 3� Spec.Cond.(pmhos) idt. Chlodne(mgA) Sample temp. at receipt Method of Determination Moving Average ❑ Probit ❑ Spearman Kerber ❑ Other" Duration R w a o 0i X -n X U) e. CO Concentration Mortality Note; Please Complete This ���i Section Also start/end starVend 7Z Gs Control I.aS (4 ?. KS li High ui'i .$ Cone. PH D.O. Acute Fish Test-24 Hr Survival Start Date: 7/19/2011 Test ID: NCO086517 Sample ID: Gateway End Date: 7/20/2011 Lab ID: TRITEST -NC Lab#016 Sample Type: Effluent Sample Date: 7/18/2011 Protocol: EPAA 91-EPA Acute Test Species: PP-Pimephales promelas Comments: Cone-% 1 2 Control 1.0000 1.0000 12.5 1.0000 1.0000 25 1.0000 1.0000 50 1.0000 1.0000 75 1.0000 1.0000 100 1.0000 1.0000 Transform: Aresin Square Root Isotonic Conc-% Mean N-Mean Mean Min Max CVO/0 N Mean N-Mean Control 1.0000 1.0000 1.4120 1.4120 1.4120 0.000 2 1.0000 1.0000 12.5 1.0000 1.0000 1.4120 1.4120 1.4120 0.000 2 1.0000 1.0000 25 1.0000 1.0000 1.4120 1.4120 1.4120 0.000 2 1.0000 1.0000 50 1.0000 1.0000 1.4120 1.4120 1.4120 0.000 2 1.0000 1.0000 75 1.0000 1.0000 1.4120 1.4120 1.4120 0.000 2 1.0000 1.0000 100 1.0000 1.0000 1.4120 1.4120 1.4120 0.000 2 1.0000 1.0000 Auxiliary Tests Statistic Critical Skew Kurt Normality of the data set cannot be confirmed Equality of variance cannot be confirmed Linear Interpolation (200 Resamples) Point % SD 95% CL(Exp) Skew IC05 >100 IC10 >100 IC15 >100 1.0 IC20 >100 0.9 IC25 >100 IC40 >100 0.8 IC50 >100 0.7 00.6 c Q 0.5 0.4 0.3 0.2 0.1 0.0 0 50 100 150 Dose % Page 1 ToxCalc v5.0.23 Reviewed by: 1 Tritest, Inc. Data Sheet for Acute Definitive Test (24hrs) - Fathead minnow Pimephales promelas Client:CYx4ew��. NDPES #: NC tx&� Test Organism Source: �zur.�vx Test Organism: < , P_ a _ Organism Born (Date/Time): )i I,/ I O Age of Organism: N t< Time Fed: 16�13oy # Replicates per Treatment: _Z Total Organisms per Vessel: i d Test Vessel Size: 53DIL Volume/Vessel: PG - Dilution Water Batch: SSit'S� Start Date: A(Rilk End Date: A 2,,'�,L__ Comments: Temperature: Q6.2 Time: IQ Time: .� Randomized: ✓ Analyst: ?8C- Analyst: DBL Incubator: 'M --�- Reviewed by: Tritest, Inc. Bioassay Chain of Custody Form Facility Name: 2g 6ci�-_W*x Address: F O. Box Phone # .3 7 (cc5 O Contact County : mecate.ti Sr NPDES permit # pipe: % Effluent Dilution (IWC): Test Method: .5s Plant Flow: Sample Collector: print signature Sample Type: Composite Date Started Time: AM Qr PM Date Ended Time: AM or PM ` Samples per Hr: # Hrs: Grab Date: JI�ZltTime: J� AM or PM Sample Volume: Chilled during Collection? Yes or No Method of Transportation to the Lab: Chain of Custody Release Relinquoi he Received By imam IN. WWI Work Order Number Lo I -dIq-73 Received By: Receiving Temperature: For Laboratory Use Only Residual Chlorine: COMMENTS: Conductivity: �,?,2q.g� &p pH: # of Bottles TriTest, Inc. Address: 6701 Conference Or., Raleigh, NC 27607 Phone: (919)8344984 0 Z3 Chain of Custody(�5aceAnalyAcal- %-mv.pacvMb1q.00M •.,__�___�_� L1_ Y_. MCI 1 ICAI'i' Results Reauested 7/25/2011 - VVU1 KulUU1.VAW :'Re Kevin Godwin P.O. C l�.5 f�� (Z- Pace Analytical Charlotte 4- 9800 Kincey Ave. Suite 100 Huntersville, NC 28078 Phone (704)875-9092 Email: kevin.godwin@pacelabs.com �?t o1-- ST3Co- of vl f L `rO� V 1 t it w r �,� t.. •f .t�� y.5, �+rw i rf3 A�+�tfi- t�'9 'M } �� T� ..•,fin i� � ..< r., CPT L � w ,�•..�,�.M'�' r.r.•,.. a ! i v-..-.' �.W-t..1...<�� ......,lY•�.a^r�+�T��,'�'- !s..ai��ay. � �N^�'s"c.��� .. t / `y t i c-,. �..... %1�..aw� „ t � �i „� Y � - � 4 '+R ��� 1 ' � V�'rY t ,� � ; ♦ W1'f. 1 l,i".1 4+ f i � ���{fit ts�-/►.+w� ��������j�j�r rR�1xn Y "�'-"i.�a,.�.ni'Te .ai±iMi�d'r > yR,i�-� � - K � Q z \r � �► v LAB USE ONLY Item:,.- iS8 I� 1 b � 2 .,_� ,ti �.t: t .,r�.��� ,..�..�.- ;: _.� � �. .�� .x� ..,� ..►} r Water lr 1 EFFLUENT 7/18/201115:20 9298459001 2 3 4 5 r .,.....�... ,t ,i7tf.: aa•. Ar:: �,.. -'+�.y.`..":w-..`a+`..`.cV' .(.illw+i.K�•ra 4 - � �K � tt. S.: �, if"'•J. �..i"2C�'�iiK«.�H'�tit'!Ir� Transfers Released By Date/Time eceived B IJ A:- Date m za4y:6 2 ! I! - i 3 • 4 5 `.4onday, July 18, 2011 4:21:42 PM FMT-ALL-C-002rev.00 24Marcnzuuu Page 1 of CHARLOTTEmi August 10, 2011 Mr. Hunter Hicks AMEC Environment and Infrastructure Dear Mr. Hicks, This letter is in response to your request of August 2, 2011 to discharge treated groundwater to the Charlotte -Mecklenburg Utilities' (CMU) sanitary sewer on behalf of the owners of the Gateway Village located at 800 West Trade Street, Charlotte, NC. The City of Charlotte Sewer Use Ordinance prohibits discharge of groundwater in Section 23-79 (b)(14) "....unless specifically authorized by CMU". At this time CMU-System Protection (SP) is unable to grant discharge privileges. When staffing levels allow, CMU has issued Local Control Document s (permits) for long tern remediation projects in the past. The permit acts as a control mechanism for monitoring non -domestic discharges into the sanitary serer. However, hi more recent history, CMU-SP has required other groundwater remediation projects to obtain NPDES permits. CMU-SP understands you are requesting discharge to the CMU system to reduce costs for your client. For information purposes, based upon typical remediated groundwater discharges, we would anticipate the following costs associated with discharge to the CMU system: • Due to flow volume and concentration levels of organic compounds discharge would require continued treatment and testing on a regular basis under a permit with CMU. • The flow would have to be metered. • The standard sewer charge of $4.14 per CCF would apply along with Industrial Waste Control Charge of $0.24 per CCF. • In addition high strength charges may apply based upon monitoring performed. However, as stated previously, we are unable to issue a permit and accept the groundwater discharge at this time. If you have any questions you may contact me at 704-336-4636 or Tim Downs at 704-336-5042. esp c ull , Bill Gintert Environmental. Compliance Manager System Protection Environmental Management Division Charlotte -Mecklenburg Utilities System Protection 4222 Westmont Drive Charlotte, NC 28217 Phone: 7041336-4407 Fax: 704/336-5077 Charlotte -Mecklenburg Utilities SOC PRIORITY PROJECT: Yes No X To: Western NPDES Program Unit Surface Water Protection Section Attention: Ron Berry Date: April 12, 2011 NPDES STAFF REPORT AND RECOMMENDATION County: Mecklenburg Permit No. NCO086517 PART I - GENERAL INFORMATION 1. Facility and Address: Gateway Village, LLC c/o Cousins Properties, Inc. 800 West Trade Street Charlotte, North Carolina 28034 2. Date of Investigation: March 30, 2011 3. Report Prepared By: Samar Bou-Ghazale, Env. Engineer II 4. Persons Contacted and Telephone Number: Mr. Hunter Hicks, with MACTEC, Tel# (704) 357-5554. 5. Directions to Site: From the intersection of I-77 and West Trade Street, travel west on West Trade Street to the 800 block. The facility is located in the basement of the 800 West Trade building. 6. Discharge Point(s). List for all discharge points: Latitude: 350 14' 03" Longitude: 80° 51' 03" Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on map. USGS Quad No.: G 15 NE 7. Site size and expansion are consistent with application? 4cl Yes X No If No, explain:8. Topography (relationship to flood plain included): The facility is locn ` e underground parking area of the building. o 9. Location of nearest dwelling: This facility is located in the parking area of building in downtown Charlotte. 10. Receiving stream or affected surface waters: Irwin Creek a. Classification: C b. River Basin and Subbasin No.: Catawba and 03-08-34 C. Describe receiving stream features and pertinent downstream uses: Discharge into a Charlotte storm drain system. The receiving stream is approximately 10- 20 feet width and ranges from 6" to 3' in depth. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of wastewater to be permitted: 0.05 MGD (Ultimate 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)? 0.05 MGD. d. Date(s) and construction activities allowed by previous Authorizations to Construct issued in the previous two years: N/A. e. Please provide a description of existing or substantially constructed wastewater treatment facilities: The existing facilities consist of one transfer tank, one dual bag filter for sediment filtration, and two 1,000 pound activated carbon canisters connected in series. f. Please provide a description of proposed wastewater treatment facilities: N/A. g. Possible toxic impacts to surface waters: This discharge is known to be toxic in nature. 2. Residuals handling and utilization/disposal scheme: N/A a. If residuals are being land applied, please specify DWQ: N/A b. Residuals stabilization: N/A C. Landfill: N/A d. Other disposal/utilization scheme (specify): N/A 3. Treatment plant classification (attach completed rating sheet): Class I. 4. SIC Code(s): 5541 Primary: 02 Wastewater Code (s): 22 Main Treatment Unit Code: 42018 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? N/A. 2. Special monitoring or limitations (including toxicity) requests: Toxicity should be limited. 3. Important SOC, JOB or Compliance Schedule dates: (please indicate) N/A. 4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options available. Please provide regional perspective for each option evaluated. Spray Irrigation: N/A. Connection to Regional Sewer System: Not evaluated. Subsurface: Not evaluated. Other Disposal Options: N/A 5. Air Quality and/or Groundwater concerns or hazardous materials utilized at this facility that may impact water quality, air quality or groundwater? No air quality concerns. groundwater is impacted already. 6. Other Special Items: N/A PART IV - EVALUATION AND RECOMMENDATIONS Cousins Properties, Inc., is applying for Permit to discharge from its facility Gateway Village located in Charlotte. The facility consists of office/retail complex. Prior to construction in 1990, a portion of the site was occupied by commercial developments that included a gasoline station, restaurant and meat processing facility. During the construction of the existing building, a portion of the site was identified as impacted by petroleum and chlorinated compounds. The finished grade elevation for the underground service structure for this building is approximately 5 to 8 feet below the static groundwater level. A permanent dewatering system was designed for the site that incorporated, an injected slurry wall in combination with an under -drain system. The purpose of the slurry wall was to impede the migration of contaminant from one side to the other. Two sump pumps were installed on either side of the slurry wall. Discharge from sump 1 was permitted in July 2001 since it was identified by being contaminated. Sump 2 was installed on the un-contaminated side of the slurry wall and the discharge was considered allowable. No flow from sump 1 has been reported on the DMR since 2006 and the permit was not renewed after it was expired in May 31, 2010. Recently, as apart of a LEED green initiative, Cousins Properties proposed using reclaimed groundwater for use in the cooling system. In January 18, 2011, MACTEC conducted groundwater quality sampling from sump 2(supposedly clean) and found it to be contaminated with Chloroform, cis-1, 2 Dichloroethene and Tetrachloroethene. Discahrge from sump 2 was directed to the existing remediation system and the effluent was noted as being ND for all three contaminants. According to MACTEC, sump 1 continued to remain at low water levels that did not trigger the need to pump. Both pumps are now directed to existing treatment system. The existing treatment system was constructed to accommodate flows up to 50gpm. Sump 1 has not produced water for several years and sump 2 has an observed flow rate of between 1-3 gpm according to MACTEC. Based on the above, Cousins properties, Inc., is requesting renewal of the permit. Raleigh has approved the renewal application. Pending review and approval by the Western NPDES Program Unit, It is recommended that the NPDES permit be renewed as requested. Signature of Rep P parer Water Quality Regional Supervisor Date I R 4,1 W C a r�I e J A 14 a,� engineering and constructing a better tomorrow February 3, 2011 Mr. Bradley Bennett N.C. Department of Environmental and Natural Resources Division of Water Quality Stormwater Permitting Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Subject: NPDES Permit Application Gateway Village 800 West Trade Street Charlotte, North Carolina MACTEC Project: 6228-10-5369 Dear Mr.Bennett: FEB 2 4 2011 Enclosed please find three copies of a completed National Pollutant Discharge Elimination System (NPDES) Permit Application - Short Form C-GW for the subject property (Attachment A). This application is being submitted on behalf of Gateway Village, LLC c/o Cousins Properties, Inc. (Cousins Properties) by MACTEC Engineering and Consulting, Inc. (MACTEC). Background Information The subject site, Gateway Village office/retail complex, is located between West Trade Street and West Fifth Street (Figures 1 and 2 in Attachment B) in downtown Charlotte. Prior to construction of Gateway Village in the late 1990's, portions of the site were previously occupied by commercial developments which included a gasoline station, restaurant, and a former meat processing facility. During construction activities, groundwater in portions of the site was identified as impacted by petroleum and chlorinated compounds. In 1998, Gateway Village was authorized by Charlotte -Mecklenburg Utilities to discharge remediated groundwater from de -watering operations during construction efforts. The finished grade elevation for the underground service structure for Gateway Village's building at 800 West Trade Street is approximately 5 to 8 feet below the static groundwater level. A permanent dewatering system was designed for the site that incorporated an injected slurry wall in combination with an under -drain system. The purpose of the slurry wall was to minimize the amount of dewatering required during excavation and construction activities and to impede migration of contaminated groundwater into the underground service structure area from on -site and off -site sources. Gateway Village, LLC, on behalf of Cousins Properties, was authorized to operate a 0.05 MGD dewatering treatment system at the site in July 2001. Treated water from the treatment system would discharge into Irwin Creek (via stone sewer) under NPDES Permit NC0086517. The dewatering treatment system was designed to treat petroleum and chlorinated contaminated groundwater from Sump 1 in the southeastern portion of the site. MACTEC, on behalf of Gateway Village, LLC, designed and supervised construction of the dewatering treatment system, has performed operations and maintenance of the treatment system, provided an Operator in Responsible Charge (ORC) to supervise system operations, MACTEC Engineering and Consulting, Inc, 2801 Yorkmont Road, Suite 100 • Charlotte, NC 28208 • Phone: 704.357.8600 • Fax: 704.357.8638 www.mactec.com &Oned,Fifl�fmlmnmenmlly-Rerry+nTlA(e Pmdun. P(eyeRmele' NPDES Permit Application Gateway Village — Charlotte, North Carolina MACTEC Project: 6228-10-5369 February 3, 2010 and prepared monthly Discharge Monitoring Reports (DMRs) since 2001. Due to prolonged dewatering system inactivity as a result of no flow through the system, the permit was not renewed after it expired on May 31, 2010. Sump 1 is located within the building hydraulically up -gradient of the slurry wall. It was designed to collect groundwater from the under -drains used to dewater the site's underground structures in the southeastern portions of the 800 block between West Trade Street and West Fifth Street. The impacted groundwater would be pumped to the treatment system before discharge to the storm system. Since the slurry wall was installed at the site, groundwater levels in the sump have not triggered the high level pump switch. Sump 2 is located adjacent to the dock office hydraulically down -gradient of the slurry wall. It was designed to dewater the site's underground structures located in the northwestern portions of the 800 block between West Trade Street and West Fifth Street. The northwestern portion of the 800 block between West Trade Street and West Fifth Street was previously identified as "uncontaminated". Considered an "allowable non-stormwater discharge", uncontaminated groundwater from Sump 2 could be discharged to the storm system without treatment or a NPDES permit. In 2010, Cousins Properties proposed using reclaimed groundwater as a non -potable water supply for the site as part of a LEED green initiative. Cousins Properties requested an investigation of the potential to use components of the current dewatering and remediation system (i.e. sumps, pumps, piping, holding tank, and filters) for this purpose. In December 2010, plumbing retrofit designs were completed for the proposed use of groundwater for alternative uses at the site, specifically for use in the cooling system. Assessment Activities On January 18, 2010, MACTEC conducted groundwater quality sampling of the groundwater from Sump 2 (Influent). Groundwater from Sump 1 continued to remain at low water levels that did not trigger the need to pump from the sump. During the sampling event, Cousins Properties was testing the plumbing retrofits and groundwater from Sump 2 was pumped through the remediation system. MACTEC collected an effluent sample after the groundwater was pumped through the system to assess the continued remediation efficiency of the system. The influent and effluent samples were analyzed for volatile and semi -volatile organic compounds using EPA Method 624/625 as well as Lead by EPA Method 200.7 and Phenol by EPA Method 420.4. The results of the influent and effluent sampling are summarized below. The laboratory analytical report is provided in Attachment C. Table 1: Summary of Influent/Effluent Analytical Results Constituen FINFLUENT EFFLUENT Chloroform 5.6 ND cis-1,2-Dichloroethene 5.0 ND Tetrachloroethene 58.8 ND Notes: Prepared by: 41h * s-sT 1. Concentrations in µg/L Checked by: JAq_, s, J I t 2. ND is below laboratory detection limits. NPDES Permit Application Gateway Village — Charlotte, North Carolina MACTEC Project: 6228-10-5369 Conclusions February 3, 2010 The sampling results identified chlorinated solvents in the influent sample from Sump 2. Since the sampling results indicate that groundwater from Sump 2 has been impacted by chlorinated solvents, Cousins Properties is requesting a NPDES permit for treatment and discharge of the groundwater to the stormwater system. No compounds were identified above laboratory detection limits in the effluent sample. Based on the results of the sampling, it appears that the remediation system will effectively treat the groundwater at the site. The plumbing system will be retrofitted to pump groundwater from both Sumps 1 and 2 through the remediation system prior to use at the site for the cooling tower and potentially discharge, if necessary based on the quantity used by the cooling tower, to the stormwater system. The groundwater quantity and quality both for influent to and effluent from the remediation system will remain similar to the permitted discharge under NPDES Permit NC0086517. The difference is that groundwater from both Sumps 1 and 2 will be pumped through the system whereas the system was previously only connected to Sump 1. MACTEC anticipates that groundwater levels in Sump 1 will continue to remain low enough not to trigger the high level pump switch. Therefore, the current 0.05 MGD dewatering system consisting of a 700-gallon holding tank, dual bag filters, dual 1,000-pound activated carbon canisters, and effluent flow meter is sufficient and a new NPDES permit, similar to NPDES Permit NC0086517 is requested per the attached application. A copy of the previous permit is included in Attachment D. If you have questions concerning this report, please contact the undersigned at (704) 357-8600. Sincerely, MACTEC ENGINEERING AND CONSULTING, INC. Hunter M Hicks E.I. re ark, .G. Staff Engineer Principal Geologist Attachments A- Permit Application B- Figures C- Laboratory Analytical Report D- Previous NPDES Permit NC0086517 27 / r"Vil MOTs i Source: USGS 7.5-Minute Topographical Map, Derita, North Carolina Quadrangle, dated 1994 Q Site Location * Discharge to Stream 0 500 1,000 2,000 3,000 4,000 Feet OMACTEC SITE LOCATION 800 WEST TRADE STREET IN-jCHARLOTTE, NORTH CAROLINA PREpp1�R D D T CHECKED DATE JOB NUMBER FIGURE By H n )� By A- p >, 6228-10-5369 1 Source: POLARIS MECKLENBURG COUNTY 2009 Q Site Location * Storm Sewer Discharge Location 0 125 250 500 750 1,000 Feet /J��MACTEC AERIAL PHOTOGRAPH 800 WEST TRADE STREET CHARLOTTE, NORTH CAROLINA BY"=4 I V L/ 3 //I IBYcL,� 1 Ivnic/ 5 r I% Iwo rvLimo�rt 6228-10-5369 Irluumc 2