NC0089885_Staff Report_20190918

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ® NPDES Unit ❑ Non -Discharge Unit Application No.: NCO089885
Attn: (Derek Denard Central Office NPDES Permitting)
Facility name: Charlotte Metro Office Tower Construction
From: (Edward Watson in MRO)
Choose an item. Regional Office
Note: This form has been adapted from the non -discharge fg acili , staff report to document the review of both non -
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or ® No
a. Date of site visit:
b. Site visit conducted by: Inspection report attached? ❑ Yes or ® No
c. Person contacted:
e. Driving directions:
2. Discharge Point(s):
Latitude:
Latitude:
and their contact information: (_)
Longitude:
Longitude:
3. Receiving stream or affected surface waters: Little Sugar Creek
Classification: C
River Basin and Subbasin No. Catawba River Basin I1-137-8
ext.
Describe receiving stream features and pertinent downstream uses: Impaired stream
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow: 0.072 MGD into two Outfalls to be determined by permittee
Current permitted flow: New Permit
2. Are the new treatment facilities adequate for the type of waste and disposal system? ® Yes or ❑ No
If no, explain: Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? ❑ Yes
❑ No ® N/A If no, please explain:
3. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ® No ❑ N/A
If no, please explain: The site diagram does not indicate a location for the treatment system.
4. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas. N/A
5. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program:
6. Possible toxic impacts to surface waters: Only if treatment system fails to work properly.
FORM: WQROSSR 04-14 Pagel of 3

7. Pretreatment Program (POTWs only): NA
1. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ❑ Yes or ❑ No
Please summarize any findings resulting from this review: NA
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
2. Check all that apply:
❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A
If no, please explain:
3. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑Yes®No❑N/A
If yes, please explain:
4. Possible toxic impacts to surface waters: High turbidity related to short term construction period; if there's a
treatment system failure low level organics like solvents and petroleum constituents could be released to
waters of the state.
5. Pretreatment Program (POTWs only):NA
REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like the NPDES Unit to obtain through an additional information request:
Item
Reason
1
The application does not indicate the use of frac tanks being employed to
capture the dewatered water. Is the Water vault on the site diagram, the point
where the dewatered water is being collected prior to treatment?
2
The site diagram does not indicate a location for the treatment system. Is the
system to be trailered on at a fixed location which should be shown on the map?
3. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Monthly Acute Toxicity
This is a short term construction project (approximately 4 months) and a close
monitoring.
monitoring schedule will be necessary to maintain effluent quality to an
impaired stream.
FORM: WQROSSR 04-14 Page 2 of 3

4. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
® Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state reasons: )
5. Signature of report preparer: Edward Watson September 18,2019
Signature of regional supervisor:
Date: 9.18.19
Docu Signed by:
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A Pre -application meeting was held reaardina this construction work on June 14.2019. DurinL the meetiniz. MRO
staff suggested using the existing treatment system from the Wells Fargo building which would only require a permit
modification to existing permit NCO088226 with the addition of a settling tank, a transfer pump and piping to feed to
alreadv permitted treatment system. Subseauent communication has indicated that thev were not able to Lyain
ermission to access the Wells Fargo treatment system.
No engineering alternative was presented in the permit application.
The system is yet to be classified and no ORC or Back-up ORC has been named for this facility.
Since timing of construction and issuance of the permit may not align well, the permittee should be advised that
industrial pump and haul, a deemed permitted activity under 2T .0203 provided a few conditions can be met, it
available to them.
FORM: WQROSSR 04-14 Page 3 of 3