WQ0003924_Lagoon CLosure Plan_20230505

QCDG
4301 Taggart Creek Road
Charlotte, NC 28208
Tel [phone]
License No. F-0856
cdge.com
May 4, 2023
Ed Watson
Hydrogeologist
Division of Water Resources
NCDEQ-Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Re: Former Celadon Recycling Facility Lagoon Closure Plan
Dear Mr. Watson,
On behalf of Linco Partnership (Linco), the property owner of the former
Celadon Recycling Solutions operation site in Lincolnton, North Carolina, CDG,
Inc. submits this closure plan for the wastewater lagoon at the facility. As the
DEQ is aware, the wastewater treatment system has been out of operation since
Celadon abandoned the property. In an orderly fashion Linco has addressed
various water -related and containing components of the former Celadon
operation including open wastewater pits, processing equipment, and water
storage facilities and mobile equipment. The purpose of this closure plan is to
provide the steps and procedures for closure of the on -site lagoon including
removal of wastewater from the lagoon, and water application to the e isdng
permitted spray field, owned by Linco, removal and appropriate disposal of the
sludge, removal and disposal of the liner, complete removal of the lagoon
embankment, and reclamation of the site.
Consistent with your advice, the lagoon closure will be conducted in accordance
with the June 22, 2012 Guidelines for the Closure of Permitted Wastewater Ponds
and Lagoons (Memorandum from Ted Bush, Deputy Director Division of Water
Quality to the Aquifer Protection Section Staff) hereinafter referred to as
"Guidance."
FACILITY OVERVIEW
The former Celadon Recycling Solutions facility operations were permitted under
NCDEQ- Permit No. WQ003924-1rastewater Irrigation System Permit. The former
Celadon Recycling Solutions facility is located at 288 Whitehouse Drive,
Lincolnton, North Carolina (see Figure 1) and owned by Linco Partnership. As of
early 2021, all Celadon's operations have been discontinued, including use of the
wastewater lagoon at the facility (see Figure 2). Rather than refurbishing the lagoon

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for future use, Linco has determined to completely remove it and reclaim its
footprint area.
Recall that in response to your immediate concerns about the lagoon water quality
after Celadon abandoned the site, Linco engaged this firm to sample and test its
water quality and sludge. A report dated July 2021 described the testing protocols
and acceptable laboratory results. Since then, only rainwater has entered the
lagoon.
APPLICABLE REGULATIONS
The wastewater system has not been in operation since Celadon abandoned the
property in early 2021 and many of its components have been dismantled and/or
dewatered and sludge disposed leaving the lagoon as the last major site feature to
address.
LAGOON CLOSURE PLANNED ACTIONS
Summary
The completed Checklist and Instruction Items from the Guidance is attached.
The lagoon system is classified as a Tertiary Wastewater Pond System for the
purpose of determining the preferred closure and disposal options.
The initial steps of the lagoon closure process will include re -sampling and
laboratory analysis of the lagoon water, followed by dewatering of the lagoon
wastewater via spray application to Linco's adjacent spray field located to the
northwest. The spray field monitoring wells will be sampled and analyzed for the
permit parameters prior to applying lagoon water to the spray field.
Following dewatering the lagoon, the sludge will be re -sampled (Figure 3)
followed by removal and on -site stockpiling. Next, the lagoon liner will be
removed and properly disposed. Soil samples will then be obtained from beneath
the liner and analyzed. If sludge sampling results allow, the dewatered sludge will
be placed back into the lagoon basin and be covered with or integrated in the soil
materials excavated from the embankment. Depending on laboratory results,
Linco would consider land application. Alternatively, it will be allowed to dewater
and be disposed in a landfill.
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Material Analysis and Testing
Water. The lagoon water samples will be obtained at several locations as shown
on Figure 3 and composited for laboratory analysis. Analysis will be conducted in
accordance with the permit parameters.
Sludge. Based on previous field measurements, the sludge is approximately 0.5
feet thick. After dewatering, the sludge will be sampled at the location shown on
Figure 3 and composited. The composite sample will be analyzed for the
parameters in Item C in the Guidance.
Soil. Because the liner is damaged, the guidance recommends soil samples should
be taken at representative locations (Figure 3). Following the sludge and liner
removal the soil samples obtained will be composited prior to laboratory analysis.
The samples will be analyzed for the parameters in Item C of the Guidance.
Data. The Division will be provided with all analytical data.
Groundwater monitoring is not currently proposed as part of this lagoon closure
plan. Laboratory results of soil samples from the lagoon will be evaluated to
determine if monitoring wells and groundwater sampling are required.
Final Closure Activities
As discussed above, to complete this action, the sludge will be returned to the
lagoon basin, land applied on site if laboratory results allow or disposed at a solid
waste landfill. The embankment structure will then be breached, deconstructed
and graded to reasonably blend with the surrounding grade and create a positive
drainage pattern. Following final grading, the total area of disturbance will be
revegetated.
On behalf of Linco, we look forward to hearing from you and initiating the
lagoon closure activities discussed above.
Sincerely,
CDG, Inc.
TJ Gladden, GIT
Project Geologist
Cc: Andrew Pitner, PG
Thomas W. Witner, PG
Principal
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Attachments:
Figures-1 Topo Map
Figures-2 Facility Site Map
Figures-3 Proposed Sampling Map
Appendix A
Checklist and Instruction Items
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APPENDIX A

ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS
Checklist and Instruction Items
The purpose of the following checklist and instruction items is to aid in the development of a closure plan for
a permitted Non -Discharge wastewater pond or lagoon to be submitted to the appropriate APS Regional
office for approval.
The following checklist allows the applicant to identify the type of lagoon to be closed, and the preferred closure
and disposal options. The selected options include references to instruction items (e.g. Item A) found on
subsequent pages of this attachment. The instruction items describe what steps are expected to be complete prior to
approval of the closure plan, including expected sampling and monitoring, and final certifications of complete
closure. Note that the following steps are not all inclusive, as each site is unique and may have varying site
conditions. In addition, flowcharts (Attachment B) have been provided as an alternate to the instructional Items A-
H. These charts contain the same information, but give a visual representation of the closure process. For
questions, contact the approving APS Regional Supervisor. Please check all items below that apply and submit a
completed copy with the lagoon closure plan.
1. Type of Pond or Lagoon System
a. Primary and Secondary Biological Wastewater Lagoon Systems (examples: food processing treatment
lagoons, municipal treatment systems without pretreatment programs, neighborhood treatment systems).
b. Primary and Secondary Industrial Wastewater Lagoon Systems(examples: non-food type industrial
treatment systems, municipal treatment systems with pretreatment program).
V c. Tertiary Wastewater Pond Systems ( examples: wastewater biological treatment systems with tertiary
treatment to include infiltration disposal pond systems, effluent polishing pond systems).
II. Closure Options — Structure
a. Conversion to Non -Wastewater Pond — Change of Use (Item B)
✓b. Complete or partial removal of structure (Items G)
c. Site Reclamation (Item F and H)
Ill. Final Liquid and Solid Content Disposal Options
yell, a. Wastewater Disposal to Onsite Permitted Field (Item A)
b. Wastewater Disposal through Pump and Haul (Item A)
c. Sludge Disposal to Permitted Site (Items C and D)
d. Sludge Left in Place (Items C and E)
IV. Sampling and Monitoring Requirements
✓ a. Wastewater Sampling Required (Items A and B)
f_ b. Soil and Sludge Sampling Required (Items C and F)
c. Groundwater Monitoring Required (Item G)
V. Final Certification Required for Closure Activities, as required in Item I.
f a. Structural Deconstruction (Professional Engineer or Hydrogeologist)
b. Wastewater Disposal (Facility ORC)
c. Sludge Disposal (ORC / Licensed Sludge Land Application Contractor)
d. Other(Explain: — - -
A-1
Attachment A June 22, 2012