NC0085731_Permit Modification_19991020

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
October 20, 1999
Mr. Gene Howard
Shorenstein Realty Investors Two, LP
227 West Trade Street, Suite 330
Charlotte, North Carolina 28202
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit Modification
Permit NumberNC0085731
The Carillon Building
Mecklenburg County
Dear Mr. Howard:
The Division issued NPDES permit NCO085731 to the Shorenstein Realty Investors Two, LP
on November 1, 1996. The Division has reviewed your request for the following NPDES permit
modifications at the subject facility.
• Use of a totalizer flow meter for monitoring flow.
• 2/month flow monitoring.
• Bi-monthly effluent monitoring for analytes.
• Remove iron and manganese monitoring.
In accordance with your permit modification request, the Division is forwarding herewith a
modification to the subject permit. Each request has been reviewed and is discussed below:
The `Effluent Limitations and Monitoring Requirements' page of the NPDES permit has
been changed to allow monthly measurement of flow using a totalizer flow meter. Flow
measurement for this facility provides little useful information and unnecessarily drains resources.
General permit NCG510000 contains the minimum requirements for petroleum
contaminated groundwater and similar wastewater discharges. Though discharges originating from
groundwater contaminated with organic solvents are not permitted under the general permitting
system the conditions of general permit are considered minimum requirements for groundwater
remediation systems. As such, the division will continue to require monthly iron and manganese
monitoring.
Iron and manganese monitoring is additionally relevant for the following reasons:
Charlotte is located within the Kings Mountain Belt, which has a variety of mineral
deposits, including iron and manganese. With iron and manganese deposits present
throughout the area it is common for influent groundwater to contain significant
concentrations of these minerals.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617; TELEPHONE [phone]; FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 1 0% POST -CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Mr. Gene Howard
Shorenstein Realty Investors Two, LP
The unit processes include a carbon filter. It is the divisions understanding that this unit
is not equipped with differential pressure measurement. Differential pressure is useful
in determining the condition of the media in the carbon filter. Without pressure
measurement, iron and manganese monitoring can be useful in determining when the
carbon filter media needs replacement or regeneration.
As a class I facility, monthly monitoring is required as indicated on the `Effluents Limitation
and Monitoring Requirements' page of the NPDES permit. Therefore, your request for bimonthly
monitoring cannot be granted.
The division agrees that resubmittal of an amended/corrected DMR for July 1999 would
provide no additional information. Therefore, resubmittal is not warranted.
Enclosed please find the modified effluent limitations page. This page should be inserted
into your permit and the old one discarded. This permit modification is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U. S. Environmental Protection Agency dated December 6, 1983.
Please take notice that this permit is not transferable. Part II, EA addresses the
requirements to be followed in case of change in ownership or control of this discharge. This permit
does not affect the legal requirement to obtain other permits which may be required by the Division
of Water Quality or permits required by the Division of Land Resources, Coastal Area Management
Act or any other Federal or Local government permit that may be required.
If any parts , measurement frequencies or sampling requirements contained in this permit
modification 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 a written petition
conforming to chapter 150B of the North Carolina General Statutes, filed with the Office of
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless
such demand is made, this decision shall be final and binding.
If you have any questions concerning this permit, please contact Mr. Michael Myers at
telephone number [phone], extension 508.
Sincerely
-r,d2iferr T. Stevens
cc: Central Files
NPDES Permit File
Mr. Derrick A. Harris, Mecklenburg County Department of Environmental Protection
Mooresville Regional Office Regional Office
Point Source Compliance/Enforcement Unit
Jim Ponder S&ME — P.O. Box 7668
Charlotte, NC 28241-7668

Permit: NCO085731
A. (I.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Final
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be
limited and monitored by the Permittee as specified below:
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Iron
Monthly
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Manganese
Monthly
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Footnotes:
1. Sample Location: E — Effluent
2. All volumes of wastewater leaving the facility shall be monitored. If continuous flow monitoring is
not feasible, then the discharger shall record the approximate time that discharge began and
ended, along with the instantaneous flow at the time of the effluent sampling.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

August 19, 1999
Mr. Richard Bridgeman
North Carolina Department of
Environment and Natural Resources
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
/ 4� -1S
D
DENR - WATER OUALITY
POINT SOIIRf.F RReNru
Reference: Response to July 1,1999 NOV Letter &
June 1999 NPDES Monthly Flow Monitoring (MR-1)
and Request for Permit Modifications
NPDES Permit #NC0085731 (Groundwater Treatment System)
Shorenstein Realty Investors Two, L.P.
Carillon Building
227 West Trade Street, Mecklenburg County, Charlotte, NC
S&ME Project 1354-96-111
Mr. Richard Bridgeman:
T�t7' CtI 27
S&ME, Inc. (S&ME), on behalf of Shorenstein Realty Investors Two, L.P., submits this
response letter and request for minor modifications to the existing NPDES Permit in accordance
with a telephone conversation on August 9, 1999 between S&ME (Jim Ponder) and Division of
Water Quality (Mr. Richard Bridgeman). Responses to the July 1, 1999 Notice of Violation are
discussed below, followed by a request to modify the existing NPDES Permit.
According to Mr. Charles Weaver (DWQ NPDES Unit), there is no form for minor permit
modifications. Instead, a detailed letter describing the desired modifications is sufficient. Since
the discovery of impacted groundwater during building construction in 1988, this site is
monitored by the Division of Waste Management Inactive Hazardous Sites Branch Superfund
Section (Ms. Charlotte V. Jesneck). Shorenstein Realty Investors Two, L.P. is performing the
groundwater capture and treatment on a voluntary basis. Due to the uniqueness of the site and
S&ME, Inc. Mailing address: )704) 523-4726
9751 Southern Pine Blvd. P.O. Box 7668 )704) 525-3953 fax
Charlotte, North Carolina 28273 Charlotte, North Carolina 28241-7668 w .smeinc.com

NCDENR, Central Files, NPDES Permit No. NCO085731 S&ME Job No. 1354-96-111
Response to 7/01 /99 NOV & June 1999 MR-1 Aupust 19, 1999
voluntary action on part of Shorenstein Realty Investors Two L.P., a site description is provided
below.
Site Description
The site, known as the Carillon Building, is located in downtown Charlotte, North Carolina at 227
West Trade Street. The office building contains an underground parking garage. Due to shallow
groundwater table, approximately ten feet below ground surface, a permanent de -watering system
was installed to prevent uplift of the lowest floor slab and flooding of the underground portion of
the parking garage. De -watering systems for similar facilities (i.e. office buildings) are located in
the downtown area. We do not know if these facilities are not required to treat the groundwater
prior to discharge.
The subject groundwater treatment was initially installed (adjacent to the building) in order to treat
groundwater generated by de -watering activities during construction of the building in 1988. The
decision to continue treatment of the discharged groundwater was based on laboratory analyses of
groundwater samples (obtained during construction) that indicated low levels of chlorinated
solvents. The solvents originated from a former dry cleaners located up gradient of the Carillon
Building. A permanent treatment system has since been installed to treat the groundwater recovered
from eight de -watering wells.
Design details of the groundwater treatment system are included in the March 1996 National
Pollutant Discharge Elimination System Application for Permit Discharge. The system consists of a
vertical polyethylene holding tank (est. 850-gallons), two transfer pumps and two poly -glass
adsorbers containing 1,100 pounds of activated carbon each. Eight de -watering wells deliver
recovered groundwater to the holding tank at an average rate of 13 to 22-gallons per minute. The
float controlled transfer pumps move water from the influent holding tank through the adsorbers
and the totalizer flow meter with discharge to the storm -water sewer.
2

NCDENR, Central Files, NPDES Permit No. NCO085731 S&ME Job No. 1354-96-111
Response to 7/01/99 NOV & June 1999 MR-1 August 19, 1999
Responses to July 1,1999 Notice of Violation
During the May 7, 1999 on -site inspection with MCDEP personnel (Mr. Derrick A. Harris) and
S&ME personnel (Mr. Jim Ponder), no negative comments regarding our records/reports, flow
measurement or self -monitoring program were mentioned, nor were any non-compliance's or
violations mentioned to us by the MCDEP. Also, NCDENR NPDES Section has provided no
comments, helpful or otherwise, regarding monthly reports submitted since the first DMR in
April 1998.
S&ME has reviewed the July 1, 1999 Notice of Violation (NOV), the March 1996 National
Pollutant Discharge Elimination System Application for Permit Discharge, and the NPDES Permit
No. NCO085731. Based on our review of those documents, we present the following responses to
the NOV, labeled and/or numbered according to the corresponding sections of the NOV.
FLOW MEASUREMENT
The Plans and Specifications submitted with the NPDES permit application included a totalizing
flow meter, which measures flow continuously. The permit was issued by NCDENR without
comment regarding the totalizing flow meter. Although the totalizing flow meter does not have a
chart recorder, the meter does measure the total flow leaving the treatment system. Instantaneous
flow can be calculated by timing the meter.
The permit (Part I. A.) states that "All volumes of wastewater leaving the facility shall be
monitored", and the current equipment satisfies this requirement. Part I. A. also provides an
alternative method of continuous flow monitoring by recording the instantaneous flow over a
course of time (when the discharge began and ended). The current equipment provides for this
method of flow measurement. Based on our interpretation of the permit, and in the absence of
any NCDENR comment regarding the totalizing flow meter as proposed and approved by the
State in the Plans and Specification, we did not understand that a chart recorder device was

NCDEN& Central Files, NPDES Permit No. NCO085731 S&ME Job No. 1354-96-111
Response to 7/01/99 NOV & June 1999 MR-1 August 19 1999
inferred, and as such, did not incorporate such a device. S&ME has operated the remediation
system for 11 years and continuously recorded approximately 127,195,200 million gallons of
treated water (discharge).
We believe that the intent of requiring a continuous record of the discharge is to monitor such
discharges from industrial facilities, where sporadic fluctuations in flow and quality could occur.
The groundwater remediation system for which the permit was issued maintains a consistent and
stable flow and is designed for continuous operation (24 hours per day, 7 days per week). Flow
may vary depending on the number of de -watering wells (maximum of eight wells). There are
no storage tanks or impoundments used to store treated water which could cause a sporadic or
peak flow conditions. "No Flow" conditions may occur when the system is temporarily shut
down for a number of reasons, mainly for maintenance (i.e. service submersible pumps). The
NPDES permitted monthly average discharge limitation is 0.0316 MGD. We have never
exceeded 0.0316 MGD in the 11 years of discharging treated water. The typical range of flow
rates during the 11 years of groundwater treatment have ranged from 13 gpm to 22 gpm. In
addition, the water quality of the recovered water is relatively consistent.
Currently, the values of the totalizing flow meter are read and recorded weekly. Based on
discharge data obtained weekly for the past 11 years, daily recordings ancyor a chart recorder are
not warranted. Daily flow rates may be calculated based on the volume of discharge divided by
the number of days between readings.
RECORDS/REPORTS
1. The "Average", "Maximum", "Minimum", and "Com/Grab" sections of future DMRs will be
completed in accordance with Comment # 1.
2. Records of weekly discharges are available since 1988 and indicate no significant
fluctuations in groundwater treated by the system. Therefore, based on existing data, daily
flow recordings are not warranted. Instead, S&ME requests that the monitoring of flow be
4

NCDENR, Central Files, NPDES Permit No. NCO085731 S&ME Job No. 1354-96-111
Resuonse to 7/01/99 NOV & June 1999 MR-1 August 19 1999
changed from weekly to bi-weekly as indicated in the permit modifications on page 6 of this
letter.
3. Calculation of the monthly average flow rate will be completed in accordance with Comment
#3.
SELF -MONITORING PROGRAM
Concerning the submittal of amended/corrected DMRs. S&ME does not believe that re-
submitting these forms would provide any additional or beneficial data than that submitted in the
j' original DMRs. We ask that you reconsider the request for amended/corrected DMRs, since the
NCDENR already has this information on the laboratory reports and on the DMRs monthly
effluent sample data. Future submittals will contain this information in the requested format, as
done on the attached July 1999 DMR report.
F

NCDENR, Central Files, NPDES Permit No. NCO085731 S&ME Job No. 1354-96-111
Response to 7/01 /99 NOV & June 1999 MR-1 August 19 1999
Request for Modifications to NPDES PERMIT No. NC0085731
In accordance with information provided on August 11, 1999 by Division of Water Quality,
NPDES Unit (Mr. Charles Weaver), S&ME, on behalf of Shorenstein Realty Investors Two, L.P.
request the following minor modifications to the existing NPDES Permit. The requests are based
on discharge information obtained for the past eleven years when de -watering began at the site.
The minor modifications are as follows:
1. That the totalizer meter, approved in the original NPDES application and dated March 1996,
remain instead of a chart recorder. Weekly flow readings obtained for the past 11 years (132
months) show nominal changes in discharge flow from the eight de -watering wells due to
seasonal fluctuations of the groundwater table.
2. That the number of monthly flow meter recordings be reduced to two readings per month.
Previously, readings were obtained weekly but discharge data recorded for the past 11 years
shows nominal seasonal changes as indicated above.
3. That effluent samples be obtained bi-monthly for analyses instead of monthly. Laboratory
results for effluent samples obtained monthly for the past 11 years (132 months) indicate that
breakthrough of existing two carbon adsorbers occurs every 8 to 12 months. Groundwater
sampling results since 1988 indicate that concentrations of tetrachloroethene, resulting from
the former dry cleaners, continue to decrease. Groundwater Monitoring results are submitted
annually to the Inactive Hazardous Sites Branch Superf ind Section (Ms. Charlotte Jesneck).
4. That the effluent monitoring requirements no longer include Iron and Manganese. These two
parameters are not related to the targeted chlorinated compound (tetrachloroethene) and are
not affected by the de -watering system. Laboratory results for monthly effluent samples,
obtained since April 1998, indicate concentrations of manganese and iron below the
laboratory quantitation limits and/or below the 15A NCAC 2B Standards.
31

NCDENR, Central Files, NPDES Permit No. NCO085731 S&ME Job No. 1354-96-111
Response to 7/01/99 NOV & June 1999 MR -I August 19, 1999
If you have any questions concerning this report, or permit modifications requests, or need
additional information, please contact Jim Ponder of S&ME, Inc. at 704-523-4726.
Sincerely,
S&ME, Inc.
Ponder
oject Manager
Al Quarles
Senior Hydrogeologist
Attachments
cc: David Dillard, Shorenstein Realty Investors Two, L.P., 227 West Trade Street, Suite 330,
Charlotte, NC 28202
Rex Gleason, NCDENR-DWQ, Mooresville, NC
Central Files (2)—NCDENR DWQ, Raleigh, NC
Mr. Rusty Rozzell, MCDEP, 700 N. Tryon Street, Suite 205, Charlotte, NC, 28202
Mr. Charles Weaver, NPDES Unit, Division of Water Quality, P.O. Box 29535, Raleigh,
NC 27626-0535'
S:\...\1999\96-11 I\NPDES Response letter.doc
7

'Yt
August 19, 1999
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
ATTENTION: CENTRAL FILES
P.O. Box 29535
Raleigh, North Carolina 27626-0535
DATE
TWO By
MAI6ED
gpNFigD
ip oNIOR AUTAOt�
FILE COPY
t"Is nnciimsr ooa Not LEAVE fltE
Reference: SUBMITTAL OF DULY MR-1 FORM
Permit No. NCO085731
Shorenstein Realty Investors Two, L.P.
The Carillon Building
227 West Trade Street
Charlotte, North Carolina
Ladies and Gentlemen:
S&ME, Inc. (S&ME) submits, on behalf of Shorenstein Realty Investors Two, L.P., this MR-1 form
for July 1999 for the above referenced site. The permit became effective September 30, 1996;
however, the system was activated on October 2, 1996. If you have any questions, please call us at
704-523-4726.
Very truly yours,
S&ME, Inc.
pot,40&
i onder, P.G.
P ject Manager
Dane A. Horna, P.E.
Environmental Services Manager
cc: Mr. David Dillard, Shorenstein Realty Investors Two, L.P., Building Manager, Carillon
Building, Charlotte, NC
sAw1996196.1 i Itipaa8991v
S&ME, Inc. Mailing address: [phone]
9751 Southern Pine Blvd. P.O. Box 7668 [phone] fax
Charlotte, North Carolina 28273 Charlotte, North Carolina 28241-7668 1 www.smeinc.com

c
• EFFLUENT
NPDES PERMIT NO. Nk"J0085 731 DISCHARGE NO. on i MONTH Tu 1-V YEAR / 9Q
FACILITY NAME Th Shcr—eastaL Cn=a*w CLASSY COUNTY htP 1 Pnhur$
OPERATOR IN RESPONSIBLE CHARGE (ORC)Ji m Pnnder GRADE -RA- PHONE_ (704) 5 _1-4776
CERTIFIED LABORATORIES (1) ,.,P,a!e__ Anal ] t ; r a 1 (2)
CHECK BOX IF ORC HAS CHANGED[:] PERSON(S) COLLECTING SAMPLES [jry rA Sw,r►e.i}'
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL FU.ES x
DIV. OF ENVIRONMENTAL MANAGEMENT (SIGNA
DEHNR BY THIS
P.O. BOX 29S3S ACCURA
RALEIGH. NC 27626-0S3S
7 OF OPERATOR IN RESPONSIBLE CHARGE)
ATURE, I CERTIFY THAT THIS REPORT IS
AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
J. J% f.
DATE
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______
ParameterEnter ,.
Above Name and Units
Below
a�®®���®®i■®��ii�
DELI Form M R-1.1
(Revised 12/94)

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
Compliant
• ' frequencies do meet unit requirements
All monitoring data and sampling freq NOT permit
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who. mangge-the system, or tAose persons directly responsible for galtheaing the information, the
information submitted is, to the best of any knowledge,and belief, true, accurate, and complete. I am aware that•theie are significant
penalties for submitting false information, including the posslility of Fines and imprisonment for knowing violations."__
iznA
P 'ttee r type)
THE SHORENSTEIN COMPANY Signature of Permittee** bate,
227 WEST TRADE STREET, SUITE 3309 CHARLOTTE, NC 28202 [phone] 8/31/2001
permittee Address Phone Number Permit Exp. Date
PARAMETER CODES
00010 Temperature
00556 Oil & Grease
00951 Total Fluoride
01067 Nickel
00076 Turbidity
00600 Total Nitrogen
01002 Total Arsenic
01077 Silver
00080 Color (Pt -Co)
00610 Ammonia Nitrogen
01092 Zinc
00082 Color (ADMI)
00625 Total Kjeldhal.
01027 Cadmium
01105 Aluminum
Nitrogen
00095 Conductivity. -
00630 Nitrates/Nitrites
01032 Hexavalent Chromium
01147 Total Selenium
00300 Dissolved Oxygen
01034 Chromium
31616 .Fecal Cbtifonn
00310 BODs
00665..Total Phosphorous
32730 Total Phenolics
00340 COD
00720 Cyanide
01037 Total Cobalt
34235 Benzene
00400 pH
00745 Total Sulfide
01042 Copper
34481 Toluene
00530 Total Suspended
00927 Total Magnesium
38260 MBAS
Residue
00929 Total Sodium
01045 Iron
39516 PCBs
00545 Settleable Matter
00940 Total Chloride
01051 Lead
50050 Flow
50060 Total
Residual
Chlorine
71880 Formaldehyde
71900 Mercury
81551 Xylene
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at [phone], extension 591 or 534.
The monthly average for fecal coliform is to be reported as a GEOMETRIC mean.- Use only units designated in the reporting
facility's permit for reporting data
* ORC must visit facility and document visitation of facilityas required per 15A NCAC 8A .0202 (b) (5) (B).
** If signed by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506 (b)
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Shorenstein Realty Investors - NC0085731 - Permit modification request
Sept. 30, 1999 - Start: Review permit file
Oct. 1, 1999 - Review correspondence file and DMR.
Reasonable potential not applicable here. Review of the Catawba River Basin Plan - Irwin
Creek is listed as partially supporting of its designated uses. Contributors include fecal
coliform, turbidity, and biologically impaired. There are several dischargers in this stream
including the Irwin Creek WWTP (CMUD).
The geology of the Kings Mountain Belt and the treatment system design dictate that
monitoring for these parameters should be evaluated. The Kings Mountain Belt is
composed of metasedimentary sequences with layers of quarzite, metaconglomerate, marble
and schist. Additionally, the Kings Mountain Belt has a remarkable variety of mineral
deposits including iron and manganese. The major question here: "Is analytical data the only
means of measuring the saturation of the carbon filter?" (i.e. is there a dP measurement). If
there is no dP measurement on the carbon filter, I would be reluctant to remove iron and
manganese monitoring. The general permit for GW remediation of petroleum sites requires
that these parameters be monitored and was used as a basis for this modification. The reason
for monitoring of these parameters is that are an indication of spent carbon.
Final recommendations - change permit to reflect that a totalizer is ok to utilize and that
weekly or biweekly flow measurements should be made. The weekly flow measurement
requirement is consistent with the general permit for petroleum contaminated GW remediation
systems. Bimonthly sampling additionally should not be granted in order to remain consistent
with the general permit. Also two months between analytical sampling is to long. This
information is needed in order to monitor the carbon filter.
October 4, 1999 — Talked with Derrick Harris Mecklenburg County Department of Environmental
Protection. He and his supervisor concur that the totalizer is adequate. They would not
recommend bimonthly analyte sampling. Though they would like to see iron and manganese
remain in the permit, however they are not overly opposed to removing it.
Oct. 11, 1999 — Talk to Mike Parker Mooresville about facility. He indicated that monthly monitoring
of flow would be sufficient for this facility. The region is not overly committed to continued
iron and manganese monitoring, but would not recommend bi-monthly sampling.