WQ0003924_Historical_20191231

Permit Number WQ0003924
Program Category
Non -discharge
Permit Type
Wastewater Irrigation
Primary Reviewer
erickson.saunders
60,000
Facility
-� Central Files: APS _ SWP
3/25/2019
Permit Tracking Slip
Status
Project Type
In draft
Renewal
Version
Permit Classification
C
Individual
Permit Contact Affiliation
Facility Name Major/Minor Region
Linco Partnership - Lincolnton WWTF Major Mooresville
Location Address County
288 Whitehouse Dr Lincoln
PO Box 916 Facility Contact Affiliation
Lincolnton NC 28093
Owner
Owner Name
Linco Partnership
Owner Type
Non -Government
Owner Affiliation
Ronald Buck
5200 Old Harding Rd
Dates/Events
Franklin
TN 37064
Scheduled
Orig Issue App Received Draft Initiated Issuance
Public Notice Issue Effective
Expiration
12/11/1986 8/29/2018 9/5/2018
31Z&17 3/2G /1"Y
—71S�IZY
Regulated Activities
Requested /Received Events
Food and kindred products manufacture
Region comments on draft requested
3M19
Region comments on draft received
3/15/19
RO staff report received
11/7/18
RO staff report requested
8/29/18
Additional information requested
11/19/18
Additional information received
1/25/19
Additional information requested
1/30/18
Additional information received
315/19
Outfall
Waterbody Name Streamindex Number Current Class Subbasin

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
PERRY R. KEISTER — PARTNER
LINCO PARTNERSHIP
5200 OLD HARDING ROAD
NASHVILLE, TENNESSEE 37064
Dear Mr. Keister:
NORTH CAROLINA
Environmental Quality
March 26, 2019
Subject: Permit No. WQ0003924
Linco Partnership — Lincolnton
WWTF
Wastewater Irrigation System
Lincoln County
In accordance with your_ permit change of ownership request received August 29, 2018, and
subsequent additional information received January 25, 2019 and March 5, 2019, we are forwarding
herewith Permit No. WQ0003924 dated March 26, 2019, to Linco Partnership for the continued operation
of the subject wastewater treatment and irrigation facilities.
This permit shall be effective from the date of issuance until July 31, 2024, shall void Permit No.
WQ0003924 issued April 7, 2014, and shall be subject to the conditions and limitations as specified therein.
Please pay particular attention to the monitoring requirements listed in Attachments A, B, and C. Failure
to establish an adequate system for collecting and maintaining the required operational information shall
result in future compliance problems.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall 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 at 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding.
If you need additional information concerning this permit, please contact Erick Saunders at (919)
707-3659 or erickson.saunders{dncdenr.gov.
Sincerely,
Dcoda Culpepper, Director
ivision of Water Resources
'2- North Carolina Department of Environmental Quality I Division of Water Resources
/g 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617

Mr. Perry R. Keister
March 26, 2019
Page 2 of 2
cc: Lincoln County Health Department (Electronic Copy)
Morrisville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
WASTEWATER IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules and Regulations
PERMISSION IS HEREBY GRANTED TO
Linco Partnership
Lincoln County
FOR THE
continued operation of a 60,000 gallon per day (GPD) wastewater treatment and wastewater irrigation
facility consisting of
a 12,000 gallon surge tank; a 300,000 gallon storage tank; a 2,000,000 gallon storage lagoon; dual 585
gallon per minute (GPM) irrigation pumps; a 21.5 acre spray irrigation area with six fields; a manual
controller; and all associated piping, valves, controls, and appurtenances
to serve the Linco Partnership — Lincolnton WWTF, with no discharge of wastes to surface waters, pursuant
to the application received August 29, 2018, and subsequent additional information received by the Division
of Water Resources, and in conformity with the project plans, specifications, and other supporting data
subsequently filed and approved by the Department of Environmental Quality and considered a part of this
permit.
This permit shall be effective from the date of issuance until July 31, 2024, shall void Permit No.
WQ0003924 issued April 7, 2014, and shall be subject to the following specified conditions and limitations:
I. SCHEDULES
1. Prior to resuming wastewater treatment and irrigation operations, the Mooresville Regional Office,
telephone number [phone], shall inspect the two million gallon storage lagoon liner to determine
its acceptability for use. The regional office shall be notified at least 48 hours prior to the installation
or repair of the liner, and such notification to the regional supervisor shall be made from 8:00 a.m. until
5:00 p.m. on Monday through Friday, excluding State Holidays. [15A NCAC 02T .0108(b)(2)]
2. Prior to resuming wastewater treatment and irrigation operations, the Permittee shall notify the Division
in writing. This notification shall be sent to the Division of Water Resources, Non -Discharge Branch,
1617 Mail Service Center, Raleigh, NC 27699-1617, or Non- Discharge.Reports ncdenr.gov. [15A
NCAC 02T .0108(b)(2)]
3. The Mooresville Regional Office, telephone number [phone], shall be notified at least 48 hours
in advance (excluding weekends and holidays) of operation of the reopened facilities such that an in -
place inspection can be made. Notification to the regional supervisor shall be made from 8:00 a.m.
until 5:00 p.m. on Monday through Friday, excluding State Holidays. [15A NCAC 02T .0108(b)(2)]
WQ0003924 Version 3.1 Shell Version 180711 Page 1 of 8

4. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal application.
[15A NCAC 02T .0105(d), 02T .0106, 02T .0109, 02T .0115(c)]
H. PERFORMANCE STANDARDS
The subject non -discharge facilities shall be effectively maintained and operated at all times so there is
no discharge to surface waters, nor any contravention of groundwater or surface water standards. In
the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due
to improper operation and maintenance, or failure of the irrigation areas to adequately assimilate the
effluent, the Permittee shall take immediate corrective actions including Division required actions, such
as the construction of additional or replacement wastewater treatment or irrigation facilities. [G.S. 143-
215.1, 143-213.3(a)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [15A NCAC 02B .0200, 02L .0100]
3. All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with
15A NCAC 02C .0108 (Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction. [15A NCAC 02C .0108]
4. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T
.0108(b)(1)]
5. Application rates, whether hydraulic, nutrient or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T .0505(c), 02T .0505(n)]
6. This disposal system was individually permitted on or after December 30, 1983; therefore, the
compliance boundary is established at either 250 feet from the effluent disposal area, or 50 feet within
the property boundary, whichever is closest to the effluent disposal area. An exceedance of
groundwater standards at or beyond the compliance boundary is subject to remediation action according
to 15A NCAC 02L .0106(d)(2) as well as enforcement actions in accordance with North Carolina
General Statute 143-215.6A through 143-215.6C. [15A NCAC 02L .0106(d)(2), 02L .0107(b)]
7. In accordance with 15A NCAC 02L .0108, the review boundary is established midway between the
compliance boundary and the effluent disposal area. Any exceedance of groundwater standards at the
review boundary shall require action in accordance with 15A NCAC 02L .0106. [15A NCAC 02L
.0106, 02L .0108]
8. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary. [15A NCAC 02L .0107(c)]
9. In accordance with 15A NCAC 02L .0107(d), no wells, excluding Division approved monitoring wells,
shall be constructed within the compliance boundary except as provided for in 15A NCAC 02L
.0107(g). [15A NCAC 02L .0107]
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10. Except as provided for in 15A NCAC 02L .0107(g), the Permittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the Lincoln
County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .4107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary; and
c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary
for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
[15A NCAC 02L .0107(f)]
11. The facilities permitted herein shall be constructed according to the following setbacks:
a. The irrigation sites permitted herein have no setbacks. The original permit (Permit No. 3917R2)
pre -dates administrative code 15A NCAC 02H .02190), which was effective October 1, 1987.
Since no modifications or expansions have been made to the originally permitted irrigation sites,
they are still covered under the 15A NCAC 0211 .0200 rules effective February 1, 1976, which
contain no setback requirements. [ 15A NCAC 02H .0200]
b. The 2,000,000 gallon storage lagoon was modified January 17, 1996. The setbacks for storage and
treatment units originally permitted or modified from February 1, 1993 to August 31, 2006 are as
follows (all distances in feet):
i. Each private or public water supply source: 100
ii. Surface waters: 50
iii. Each well with exception of monitoring wells: 100
iv. Each property line: 50
v. Nitrification field: 20
I Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02H .02190)(5)]
M. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively
maintained and operated as a non -discharge system to prevent the discharge of any wastewater resulting
from the operation of this facility. The Permittee shall maintain an Operation and Maintenance Plan,
which at a minimum shall include operational functions, maintenance schedules, safety measures and
a spill response plan. [15A NCAC 02T .0507]
2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non -discharge facilities, in accordance with 15A NCAC 08G .0200 the
Permittee shall designate and employ a certified operator in responsible charge (ORC) and one or more
certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the
previously cited rules. [15A NCAC 02T .0117]
A suitable year round vegetative cover shall be maintained at all times, such that crop health is
optimized, allows for even distribution of effluent and allows inspection of the irrigation system. [ 15A
NCAC 02T .0108(b)(1)]
4. Adequate measures shall be taken to prevent effluent ponding in or runoff from the irrigation sites listed
in Attachment B. [15A NCAC 02T .0108(b)(1)]
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5. Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause ponding or runoff. [15A NCAC 02T .0108(b)(1)]
6. All irrigation equipment shall be tested and calibrated at least once per permit cycle. Calibration records
shall be maintained at the facility for a period of no less than five years, and shall be made available to
the Division upon request. [15A NCAC 02T .0108(b)(1)]
7. Only effluent from the Linco Partnership - Lincolnton WWTF shall be irrigated on the sites listed in
Attachment B. [G.S. 143-215.1]
8. No automobiles or machinery shall be allowed on the irrigation sites except during equipment
installation or while maintenance is being performed. [15A NCAC 02T .0108(b)(1)]
9. Public access to the irrigation sites and wastewater treatment facilities shall be prohibited. [ 15A NCAC
02T .0505(q)]
10. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in
accordance with 15A NCAC 02T .1100. The Permittee shall maintain a residual management plan
pursuant to 15A NCAC 02T .0508. [15A NCAC 02T .0508, 02T .1100]
11. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is
prohibited. [15A NCAC 02T .05050)]
12. Freeboard in the 2,000,000 gallon storage lagoon and 300,000 gallon storage tank shall not be less than
two feet at anytime. [15A NCAC 02T .0505(d)]
13. Gauges to monitor waste levels in the 2,000,000 gallon storage lagoon and 300,000 gallon storage tank
shall be provided. These gauges shall have readily visible permanent markings, at inch or tenth of a
foot increments, indicating the following elevations: maximum liquid level at the top of the temporary
liquid storage volume; minimum liquid level at the bottom of the temporary liquid storage volume; and
the lowest point on top of the dam. [ 15A NCAC 02T .0108(b)(1)]
14. A protective vegetative cover shall be established and maintained on all earthen embankments (i.e.,
outside toe of embankment to maximum allowable temporary storage elevation on the inside of the
embankment), berms, pipe runs, erosion control areas, and surface water diversions. Trees, shrubs, and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankment areas shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02T
.0108(b)(1)]
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IV. MONTTORING AND REPORTING RE UIRPAHNTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water analyses)
necessary to ensure groundwater and surface water protection shall be established, and an acceptable
sampling reporting schedule shall be followed. [15A NCAC 02T .0108(c)]
2. A Division certified laboratory shall conduct all laboratory analyses for the required effluent,
groundwater or surface water parameters. [15A NCAC 02H .0800]
3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be
reported on Form NDMR.
The Permittee shall install and maintain an appropriate flow measurement device to ensure the accuracy
and reliability of flow measurement consistent with accepted engineering and scientific practices.
Selected flow measurement devices shall be capable of measuring flows with a maximum deviation of
less than ten percent from true flow; accurately calibrated at a minimum' of once per year; and
maintained to ensure the accuracy of measurements is consistent with the selected device's accepted
capability. The Permittee shall maintain records of flow measurement device calibration on file for a
period of at least five years. At a minimum, documentation shall include:
a. Date of flow measurement device calibration,
b. Name of person performing calibration, and
c. Percent from true flow.
[15A NCAC 02T .0105(k)]
4. The Permittee shall monitor the effluent from the subject facilities at the frequencies and locations for
the parameters specified in Attachment A. [ 15A NCAC 02T .0108(c)]
5. The Permittee shall maintain adequate records tracking the amount of effluent irrigated. At a minimum,
these records shall include the following information for each irrigation site listed in Attachment B:
a. Date of irrigation;
b. Volume of effluent irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings;
f. Loading rates to each infiltration site listed in Attachment B;
g. Continuous monthly and year-to-date loadings for any non -hydraulic parameter specifically
limited in Attachment B;
h. Weather conditions; and
i. Maintenance of cover crops.
[15A NCAC 02T .0108(c)]
6. Freeboard (i.e., waste level to the lowest embankment elevation) in the 2,000,000 gallon storage lagoon
and 300,000 gallon storage tank shall be measured to the nearest inch or tenth of a foot, and recorded
weekly. Weekly freeboard records shall be maintained at the facility for a period of no less than five
years, and shall be made available to the Division upon request. [15A NCAC 02T .0108(c)]
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Three copies of all monitoring data (as specified in Conditions IV.3. and N.4.) on Form NDMR for
each PPI and three copies of all operation and disposal records (as specified in Conditions IV.5. and
IV.6.) on Form NDAR-1 for every site in Attachment B shall be submitted on or before the last day of
the following month. If no activities occurred during the monitoring month, monitoring reports are still
required documenting the absence of the activity. All information shall be submitted to the following
address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .0105(1)]
8. A record shall be maintained of all residuals removed from this facility. This record shall be maintained
at the facility for a period of no less than five years, and shall be made available to the Division upon
request. At a minimum, this record shall include:
a. Name of the residuals hauler;
b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15A NCAC 02T .0108(b)(1)]
9. A maintenance log shall be maintained at this facility. This log shall be maintained at the facility for a
period of no less than five years, and shall be made available to the Division upon request. At a
minimum, this log shall include:
a. Date of calibration of flow measurement device;
b. Visual observations of the plant and plant site; and
c. Recordofpreventative maintenance (e.g., changing of equipment, adjustments, testing, inspections
and cleanings, etc.).
[15A NCAC 02T .0108(b)(1)]
10. Monitoring wells shall be sampled at the frequencies and for the parameters specified in Attachment
C. All ma in well construction forms, -well abandonment forms and monitoring data shall refer to
the permit number and the well nomenclature as rovided in Attachment C and Fissure 1. [15A NCAC
02T .0105(m)]
11. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form (GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .0105(m)]
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VA
12. An annual representative soils analysis (i.e., 'Standard Soil Fertility Analysis) shall be conducted on
each irrigation site listed in Attachment B. These results shall be maintained at the facility for a period
of no less than five years, and shall be made available to the Division upon request. At a minimum, the
Standard Soil Fertility Analysis shall include the following parameters:
Acidity
Exchangeable Sodium Percentage
Phosphorus
Base Saturation (by calculation)
Magnesium
Potassium
Sodium
Calcium
Manganese
Cation Exchange Capacity
Percent Humic Matter
Zinc
Copper
pH
[I 5A NCAC 02T .0108(c)]
13. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone number (704)
663-1699, as soon as possible, but in no case more than 24 hours, or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons,
rendering the facility incapable of adequate wastewater treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
e. Ponding in or runoff from the irrigation sites.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone]. Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
betaken to ensure the problem does not recur. [15A NCAC 02T .0105(1), 02T .0108(b)(1)]
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and irrigation facilities. [15A NCAC 02T .0108(b)]
2. The Permittee or their designee shall inspect the wastewater treatment and irrigation facilities to prevent
malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the
release of wastes to the environment, a threat to human health or a public nuisance. The Permittee shall
maintain an inspection log that includes, at a minimum, the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this
inspection log for a period of five years from the date of the inspection, and this log shall be made
available to the Division upon request. [15A NCAC 02T .0108(b)]
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the wastewater treatment and irrigation facilities
permitted herein at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records required to be maintained under the terms and conditions of this permit,
and may collect groundwater, surface water or leachate samples. [G.S. 143-21.5.3(a)(2)]
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V1. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statutes 143-215.6A to
143-215.6C. [G.S. 143-215.6A to 143-215.6C]
2. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, Division approved plans and specifications, and other supporting documentation. No
variances to applicable rules governing the construction or operation of the permitted facilities are
granted, unless specifically requested and approved in this permit pursuant to 15A NCAC 02T .0105(n).
[G.S. 143-21.5.1 ]
The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules in
15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under General Permit NCGO10000; any requirements pertaining to wetlands under 15A NCAC 02B
.0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter 143 of the
General Statutes. [15A NCAC 02T .0105(c)(6)]
4. In the event the permitted facilities change ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate property ownership documentation and other supporting
documentation as necessary. The Permittee of record shall remain fully responsible for maintaining
and operating the facilities permitted herein until a permit is issued to the new owner. [15A NCAC
02T .0104]
5. The Permittee shall retain a set of Division approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T .0108(b)(1)]
6. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority. [15A NCAC 02T
.01050)]
7. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110. [ 15A NCAC 02T .0110]
8. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein
shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b). [15A
NCAC 02T .0120]
9. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay
the annual fee accordingly shall be cause for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 261' day of March 2019
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
iLmda Culpepper, Director j
a Division of Water Resources J
By Authority of the Environmental Management Commission
Permit Number WQ0003924
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ATTACHMENT A — LIMITATIONS AND MONITORING REQUIREMENTS
Permit Number: WQ0003924 Version: 3.1
PPI 001— WWTF Effluent
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
PCS
Code
Parameter Description
BOD, 5-Day (20 °C)
Units of
Measure
Monthly
Average
Monthly
Geometric Mean
Daily Minimum
Daily Maximum
Measurement
Frequency
Sample
Type
00310
mg/L
4 x Year
Grab
00940
Chloride (as Cl)
mg/L
3 x Year z
Grab
31616
Coliform, Fecal MF, M-FC Broth, 44.5 °C
#/100 mL
4 x Year
Grab
50050*
Flow, in Conduit or thru Treatment Plant
GPD
60,000
Continuous
Recorder
00610
Nitrogen, Ammonia Total (as N)
mg/L
4 x Year
Grab
00625
Nitrogen, Kjeldahl, Total (as N)
mg/L
4 x Year
Grab
00620
Nitrogen, Nitrate Total (as N)
mg/L
4 x Year
Grab
00600
Nitrogen, Total (as N)
mg/L
4 x Year
5 x Week
Grab
Grab
00400
pH
su
00665
Phosphorus, Total (as P)
mg/L
4 x Year
Grab
70300
Solids, Total Dissolved — 180 °C
mg/L
3 x Year z
Grab
00530
Solids, Total Suspended
mg/L
4 x Year
Grab
1. 4 x Year sampling shall be conducted in March, May, July, and November.
2. 3 x Year sampling shall be conducted in March, July, and November.
WQ0003924 Version 3.1 Attachment A Page 1 of 1

THIS PAGE BLANK

ATTACHMENT B — APPROVED LAND APPLICATION SITES AND LINIITATIONS
Permit Number: WQ0003924 Version: 3.1
Linco Partnership — Linco Partnership — Lincolnton WWTF
IRRIGATION AREA INFORMATION APPLICATION LIMITATIONS
Field
Owner
County
Latitude
Longitude
Net
Dominant
Parameter
Hourly
Yearly
Units
Acreage
Soil Series
Rate
Max
I
Linco Partnership
Lincoln
35.5149430
-81.246961°
4.6
PmB — Pacolet-Madison-Urban
01284 — Non -Discharge Application Rate
0.5
45.5
inches
Land Complex 2% - 8 /° slopes
2
Linco Partnership
Lincoln
35.515737'
-81.247074'
2.7
PmB — Pacolet-Madison-Urban
01284 — Non -Discharge Application Rate
0.5
45.5
inches
Land Complex 2% - 8 /a slopes
3
Linco Partnership
Lincoln
35.516460'
-81.247561 °
4.0
AaA -Altavista sandy loam
01284 — Non -Discharge Application Rate
0.5
45.5
inches
0% - 2% slopes
4
Linco Partnership
Lincoln
35.516963°
-81.247910'
3.8
LdC2 — Lolloyd clay loam
01284 — Non -Discharge Application Rate
0.5
45.5
inches
osandy
8 /° - l 5 /o slopes
5
Linco Partnership
Lincoln
35.517402'
-81.247875°
3.1 LdB2 — Lloyd sandy clay loam
01284 — Non -Discharge Application Rate
0.5
45.5
inches
2% - 8% slopes
6
Linco Partnership
Lincoln
35.517558°
-81.246421 °
3.3 LdB2 — - 8/o lo syd clay loam
2 /o 8 loes
01284 — Non -Discharge Application Rate
0.5
45.5
inches
Totals
21.5
45.5
WQ0003924 Version 3.1 Attachment B Page 1 of 1

THIS PAGE BLANK

ATTACHMENT C — GROUNDWATER MONITORING AND LIMITATIONS Permit Number: WQ0003924 Version: 3.1
Monitoring wells: MW-1, MW-2, MW-3, and MW-4
GROUNDWATER CHARACTERISTICS GROUNDWATER STANDARDS MONITORING REQUIREMENTS
PCS Code Parameter Description Daily Maximum Frequency Measurement Sample Type Footnotes
00680 Carbon, Tot Organic (TOC) mg/L 3 x Year Grab 1,4
00940 Chloride (as Cl) 250 mg/L 3 x Year Grab I
31616 Coliform, Fecal MF, M-FC Broth, 44.5 °C #/100 mL 3 x Year Grab I
00610 Nitrogen, Ammonia Total (as N) 1.5 mg/L 3 x Year Grab I
00620 Nitrogen, Nitrate Total (as N) 10 mg/L 3 x Year Grab I
00400 pH su 3 x Year Grab 1,2
00665 Phosphorus, Total (as P) mg/L 3 x Year Grab I
70300 Solids, Total Dissolved - 180 °C 500 mg/L 3 x Year Grab I
82546 Water Level, Distance from measuring point 1 feet 3 x Year Calculated 1, 2, 3
_I
1. 3 x Year monitoring shall be conducted in March, July, and November; Annual monitoring shall be conducted every November.
2. The measurement of water levels shall be made prior to purging the wells. The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement of
pH shall be made after purging and prior to sampling for the remaining parameters.
3. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points (top qf
casing) of all monitoring wells shall be surveyed relative to a common datum.
4. If TOC concentrations greater than 10 mg/L are detected in any downgradient monitoring well, additional sampling and analysis must be conducted to identify the individual constituents comprising
this TOC concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/L, this concentration will be taken to represent the naturally occurring TOC
concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient wells shall be subject to the additional sampling and analysis as described above.
5. Monitoring wells shall be reported consistent with the nomenclature and location information provided in Monitoring Well Location Map (previously provided in the permit issuance of March 9,
2005 as Attachment A) and this attachment.
NOTE: Monitor well sampling is not required as long as the treatment system remains inactive. Sampling shall resume when the system becomes active.
WQ0003924 Version 3.1 Attachment C Page 1 of 1

WQ0003924 Site Ma
I
4
� Legend
Llcndcring .ee113
Re;te;vBcundan
,
QUmphance Bcundam?
t - Q Parcel Boundaries
- Q Vie 8ed A rea
fraa 'CC.000-yal Storage Tank
]+ir
Lagccn
T
s-n _
nR
. n{
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R =i
Am
4.. »
ti -r

Central Files: APS _ SWP
3/25/2019
Permit Number W00003924 Permit Tracking Slip
Program Category
Status 'roject Type
Non -discharge
In draft Renewal
Version Permit Classification
Wastewater Irrigation
C Individual
Primary Reviewer
Permit Contact Affiliation
erickson.saunders
60,000
Facility
Facility Name MajorlMinor Region
Linco Partnership - Lincolnton WWTF Major Mooresville
Location Address County
288 Whitehouse Dr Lincoln
PO Box 916 Facility Contact Affiliation
Lincolnton NC 28093
Owner
Owner Name Owner Type
Linco Partnership Non -Government
Owner Affiliation
Ronald Buck
5200 Old Harding Rd
Dates/Events Franklin TN 37064
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
12111/1986 8/29/2018 9/5/2018
Regulated Activities Requested /Received Events
Food and kindred products manufacture Region comments on draft requested 317/19
Region comments on draft received 3115/19
RO staff report received 11/7/18
RO staff report requested 8/29/18
Additional information requested 11/19/18
Additional information received 1/25/19
Additional information requested 1/30/18
Additional information received 3/5/19
Outfall
Waterbody Name Streamindex Number Current Class Subbasin

DWR
Division of Water Resources
State of North Carolina
Department of Environmental Quality
Division of Water Resources
NON -DISCHARGE PERMIT OWNERSHIP/NAME CHANGE REVIEW
FORM: NDPONCR 10-15
March 26, 2019
Permit Number: WQ0039266 Permit Type: Single -Family Residence Wastewater Irrigation
Applicant: Richard P. and Christine B. Gianni Project Type: Change of Ownership
Facility Name: 422 W. Hardaway Trl. SFR Primary Reviewer: Select
Permit Reviewer: Nathaniel Thornburg Regional Reviewer: Joan Schneier
Staff Report
N/A
Yes
No
1. All comments addressed:
❑
Application
N/A
OK
Not OK
A. Permit Ownership/Name Change Application:
❑
B. Existing Permit:
❑
C. Property Ownership Documentation:
❑
D. Certificate of Public Convenience and Necessity:
®
❑
E. Operational Agreement:
®
❑
F. Operation and Maintenance Agreement:
®
❑
BIMS:
N/A
OK
Not OK
1. Owner:
❑
2. Facility:
❑
3. Details 1:
❑
❑
Changed from Renewal to Minor Modification (i.e.,
Change of Ownership).
4. Details 2:
❑
5. Billing:
❑
®
Overdue fee needs to be waived because this is a CoO.
6. Classification / Designation:
❑
®
Need ORCs prior to resuming operations.
7. Events:
❑
❑
Corrected second AI request date.
8. Regulated Activities:
❑
9. Structures:
❑
❑
Added freeboard for both storage structures.
10. Affiliations:
❑
11. Reviewers:
❑
12. Related Permits:
®
❑
13. Points Prior to Irrigation:
❑
14. Wells:
❑
15. Fields:
❑
FORM: NDPONCR 10-15 Page 1 of

16. Sites:
[�]
❑
17. Comments:
®
❑
18. History:
❑
19.Inspections:
❑
®
15
20.Incidents:
❑
®
0
21. Enforcements:
❑
®
0
22. Violations:
❑
®
83
Draft Permit:
N/A
OK
Not OK
1. Cover Letter:
❑
❑
This is a change of ownership, not a renewal;
Corrected effective date.
2. Facility Description:
❑
❑
See draft for edits.
3. Schedules:
❑
❑
Unique conditions should come first in this section;
See draft for edits to 1. 1., 1. 2., and 1.3;
Added rule citation to 1.4.
4. Performance Standards:
❑
❑
11.11.b. - Storage lagoon is not facultative - removed
setback;
Added setback for private/public water supply sources.
5. Operation and Maintenance Requirements:
❑
6. Monitoring and Reporting Requirements:
❑
7. Inspections:
❑
8. Local Program Approval:
®
❑
9. General Conditions:
❑
®
Deleted VI.2. - this condition has to come out.
10. Engineering Certification:
®
❑
11. Attachment A:
❑
12. Attachment B:
❑
13. Attachment C:
❑
14. Attachment D:
®
❑
15. Maps:
❑
16. Operation and Maintenance Agreement:
®
❑
17. Operational Agreement:
®
❑
Reporting Forms:
N/A
OK
Not OK
1. NDMR:
❑
2. NDAR-1:
❑
3. NDAR-2:
®
❑
4. NDMLR:
®
❑
FORM: NDPONCR 10-15 Page 2 of 2

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.: (WQ0003924)
Attn: (Erick Saunders) Facility name: National Fruit Spray Irrigation
County: Lincoln
From: (Edward Watson)
Mooresville Regional Office
Note: This form has been adapted from the non -discharge facility 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 RECEIVED
1. Was a site visit conducted? ® Yes or ❑ No NCDEQ/DWR
a. Date of site visit: 10/30/2018 ] NOV 2018
b. Site visit conducted by: Edward Watson
c. Inspection report attached? ❑ Yes or ® No Non -Discharge
d. Person contacted: Perry Keister and their contact inform ion: lX## a dit
e. Driving directions:
2. Discharge Point(s): N/A This is a spray irrigation permit and it should not discharge to surface waters.
Latitude: Longitude:
Latitude: Longitude:
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Lynn Aldrich Certificate #:993778 Backup ORC: Certificate #:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: This facility has not actively operated since October of 2008. The last
application event was December of 2016. The facility has been up for sale for several years. The property was
recently sold to Linco Properties in October 2018.
Proposed flow: 60,000 GPD
Current permitted flow: 60,000 GPD
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.) Since the sale, the irrigation system has been isolated form the storage tank so the liquid now in the tank is
not able to be transferred to the spray irrigation application fields.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? The system has not had a spray event since 2016
FORM: WQROSSR 04-14 Page 1 of 3

4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ® Yes or ❑ No
If yes, please explain: The new property owner has no plan to re -activate the spray irrigation system currently in
place. The new property owner has a pre-treatment permit to transfer wastewater to the Town of Lincolnton
WWTP.
5. Is the residuals management plan adequate? ❑ Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ® Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or X No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or ® No
If no, please explain: The 300,000 gal tank has been repurposed for storage of other materials and has been
disconnected from the wastewater system. It should be removed from the permit description.
10. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
If no, please explain: The wells will need to be abandoned as part of the system closure activities.
11. 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: This system has not operated since late 2016, MW-59s
are current and have shown no exceedances.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
12. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
13. 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:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
15. Possible toxic impacts to surface waters: N/A
16. Pretreatment Program (POTWs only): N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain:
2. 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
FORM: WQROSSR 04-14 Page 2 of 3

❑ Issue
❑ Deny (Please state reasons: )
Signature of report preparer: 11/06/20128
r Docuftned by:
I A#4% w H Pzu"
Signature of regional supervisor: L F'e'FBESA2DUA3...
Date: 11/7/18
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The property has recently been sold from National Fruit to LINCO Properties. The renewal of this permit is to
provide time and coverage for the new owner to be able to properly perform the required activities to be able to close
the existing spray irrigation system and eventually rescind the permit.
The new owner has been provided with the name change form and been instructed to complete this paperwork
immediately so the permit can be renewed.
Linco has also been provided with a copy of the existing permit, the WWIS I 1-13. Docx for irrigation system for
irri ation system closure and links to these documents to be used fors stem closure.
The permit has been discussed with Central Office Non-Dischar a Permitting Groun and CO will rpquest the
additional information.
FORM: WQROSSR 04-14 Page 3 of 3

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ATTACIIMENT A — LIMITATIONS AND MONITORING REQUIREMENTS
PPI 002 — WWTF Effluent
EFFLUENT CHARACTERISTICS
PCs
Code Parameter Description
Units of
Measure
50050* Flow, in conduit or through treatment plant
GPD
00310 BOD, 5-day (20 deg. C)
mg/l
31616 Coliform, Fecal MF, M-FC Broth, 44.5 C #/100 mI
00610 Nitrogen, Total Ammonia (as N)
mg/l
00400 pH
s. u.
00530 Solids, Total Suspended
mg/l
006202 Nitrogen, Total Nitrate (as N)
mg/l
006252 Nitrogen, Kjeldahi, Total (as N)
mg/l
*Flow (PCS Code 50050) may be monitored in the influent stream_
1. Semi-annual sampling shall occur in the months of April
and October.
Monthly
Average
60,000
Permit Number: WQ0003924
EFFLUENT LIMITS
Monthly Geometric Mean i Daily inimum Daily Maximum
2. Sampling for Nitrate Nitrogen (00620) and TKN (00625) will commence after September 1, 2014.
Version: 3.0
MONITORING REQUIREMENTS
Measurement
Sample
Frequency
Type
Monthly
Recorder
Semi-annually'
Grab
Semi-annually'
Grab
Semi-annually'
Grab
Semi-annually'
Grab
nually'
ESemi-an
Grab
nually'
Grab
Semi-annually'
Grab +
NOTE: Effluent sampling is not required if the treatment system remains inactive_ Sampling shalt resume when the -­ qem becomes is ri
-Vud h ;,ve,,J bri-115- N- �h, - C 1 0k d , I, a eJ /V Ser 11' 1 e. {� y�
,- �, G- � f� u,.
-S r
,,�letiJ � �. pal-c,, ts k �
WQ0003924 Version 3.0
Attachment A
C/O c S A &
Page l of 1

�►, ` Vim` .�_ '
WIfTEHOUSE`
�{:ti(f i3un
Nathaniel D. Thornburg
Division of Water Resources
Non -Discharge Branch
Department of Environmental Quality
1627 Mail Service Center
Raleigh, NC 27699-1617
Mr. Thornburg:
NATIONAL FRUIT PRODUCT COMPANY, INC.
701 FAIRMONT AVENUE
WINCHESTER, VIRGINIA 22601
PHONE: [phone]
FAX: [phone] (SALES)
FAX: [phone] (OTHER DEPTS.)
August 28, 2018
RECEIVED/NCDM/DWR
AUG 2 9 2018
Non -Discharge
Permitting Unit
We are writing concerning the Non -Discharge Permit renewal application for our Lincoln
County Plant located at 288 Whitehouse Road.
We have not operated the Apple Processing Facility for a number of years and are currently
leasing the property to a Company which does not use the Non -Discharge Spray Irrigation
Wastewater System. We are not planning to restart the processing any time but wish to renew the
Non -Discharge Permit. The renewal documentation is enclosed. Since the Non -Discharge
System is not operating, can the ORC only be required to visit the Plant every other month or
less? We appreciate you considering this change.
If you have any questions please contact me. You may call me at 540-974-6873 which is my
cell phone or contact me by e-mail.
Sincerely,
NFP Holdings, LLC
�r1CAq &�
James C. Zombro, Jr.
Environmental Director
cc: David C. Gum, Jr.
From Our House to Yours... White House 0

ll�1fY R -
State of North Carolina
Department of Environmental Quality
Division of Water Resources
NON -DISCHARGE SYSTEM RENEWAL
Division of Water Resources INSTRUCTIONS FOR FORM: NDSR 06-16 & SUPPORTING DOCUMENTATION
i
This form is for renewal without modification for all non -discharge system permits, except R{:siduals Management permits.
For more h1l6 matiun. visit the 11"ater Ouality Permittin,L> Sections
A. Non -Discharge System Renewal (FORM: NDSR 06-16) Application (All Application Packages):
Submit one original and one cope of the completed and appropriately executed Non -Discharge Systcm Rcncwal (FORM:
NDSR 06-16) application.
❑ The Applicant's Certification shall be signed in accordance with Per an
alternate person may be designated as the signing official if a delegation letter is provided from a person who meets the
criteria in
B. Existing Permit (Ail Application Packages,►:
Submit tAvo copies of the most recently issued pennit.
C. Certificate of Public Convenience and NLcessity t All Application Packages for Privately -Owned Public Utilities):
❑ Per , proN ide tao copies of the Certificate of Public Convenience and Necessity from the
detnonstritina; th Applicant is authorized to hold the utility franchise for the area to be served
b} the non -discharge system.
D. Operation and Maintenance Agreement (All Application Packages for Single -Family Residences):
❑ Submit one original and one copy of the signed Operation and Maintenance Agreement (
E. Operational Agreements (All Application Packages for Home/Property, Owners' Associations and Developers of lots to be sold):
r llottte/Proocrty 0,%vners' Associations
❑ Per . submit av ortuinal and ouc ,:opt of the priperI% executed
❑ Per , submit an original and one coPy of the proposed or approved Articles of Incorporation.
Declarations and By-la%Ns.
Developers of lots to be sold
❑ Per . submit an original and one cope of the properly executed
F Site flap (All Application Packages for permits originalh issued or modified after September 1. 2006):
❑ Submit two copies of an updated site map in accordance with
THE COMPLETED APPLICATION AND SUPPORTING DOCUMENTATION SHALL BE SUBMITTED TO:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NON -DISCHARGE PERMITTING UNIT
By U.S. Postal Service:
1.617 i1TAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
TELEPHONE NUMBER: [phone]
Bi Courier/Special Delivery:
$12 fit. S..kI.Uttt ST,
RAL IGH, NORTH CAROLINA 2704
FAX NUMBER: [phone]
RECEIVED/NCDEQ/DWR
AUG 2 9 2918
Non -Discharge
Permitting Unit
INSTRUCTIONS FOR FORM: NDSR 06-16 & SUPPORTING DOCUMENTATION Page I of I

Divlsion of Water Resources
1. PERMITTEE INFORMATION:
1. Permittee's name: NFP Holdings. LLC.
2 Signature authority's name: James C. Zombro. Jr. per
Pennittee s mailing address. 701 Fairnioiit Avenue
City: Winchester State: Virginia Zip: 22601-_
4. Permittee's contact information: Phone number: [phone]
IL FACILITY INFORMATION:
Facility name: NFP Holdings. LLC - Lincolnton Plant
2. Facility's physical address: 288 Whitehouse Road (NCSR 1558)
State of North Carolina
Department of Environmental Quality
Division of Water Resources
NON -DISCHARGE SYSTEM RENEWAL
FORM: NDSR 06-16
Title: En iromnental Director
Email Address: jzombroAi,1 fpc.com
City: State: NC Zip: 28092- County: Lincoln
III. PERMIT INFORMATION:
1. Existing permit number: WQ0003924 and most recent issuance date: Auril 7. 2014
2. Existing permit type: Wastewater Irrigation
3. Has the facility been constructed? ® Yes or ❑ No
Applicant's Certification per
1, James C. Zombro, Jr. Environmental Director
Authority's name & title from Application Item 1.2.)
NFP Holdings, LLC - Lincolnton Plant
(Facility name from Application Item 1I. I )
RECEIVED/NCDE61/DWR
AUG 2 9 2018
Non -Discharge
Permitting Unit
attest that this application for
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that any discharge of wastewater
from this non discharge system to surface waters or the land will result in an itninediate enforcement action that may include civil
penalties, injunctive relief and/or criminal prosecution. I will make no claim against the Division of Water Resources should a
condition of this permit be violated. I also understand that if all required parts of this application package are not completed and that
if all required supporting information and attachruents are not included. this application package will be returned to me as incomplete.
I further certifi- that the Applicant or any affiliate llas not been comicted of an environmental chime, has not abandoned a wastewater
facility° -without proper closure. does not have an outstanding civil penalty wfiere all appeals have been exhausted or abandoned. are
compliant with anp- active compliance schedule. and do not have any overdue annual fees per
NOTE — In accordance witli Gencral Statutes and any person who knowingly makes any false statement.
representation. or certification in any application package shall be guilty of a Class 2 misdemeanor, which may include a fine not to
exceed S 10.000 as well as civil penalties up to $25.000 per violation.
Signature:
Date: � f,2 �
FORM: NDSR 06-16 Page 1 of I

A
tA.
CDENR
North Carolina Department of Environment and Natural resources
Division of baler Quality
Beverly D-aves Perdue Coleen H. Sullins
=Coverrlor Director
August 25, 2011
DAVID C. GUM, III — MEMBER/MANAGER
NFP HOLDINGS, LLC
701 FAIRMONT AVE
WINCHESTER, VIRGINIA 22601
Dear Mr. Gum:
Dee Freeman
Secretary
Subject: Permit No. WQ0003924
National Fruit Product Co.,
Inc.
Wastewater Irrigation System
Lincoln County
In accordance with your permit change of ownership request received July 29, 2011, we are
forwarding herewith Permit No. WQ0003924 dated August 25, 2011, to NFP Holdings, LLC for the
continued operation of the subject wastewater treatment and wastewater irrigation facilities. Please
note the Permittee has been changed from National Fruit Product Company, Inc. to NFP Holdings,
LLC.
This permit shall be effective from the date of issuance until February 28, 2014, shall void
Permit No. WQ0003924 issued March 9, 2005, and shall be subject to the conditions and limitations
as specified therein. Please familiarize yourself with the revised format of this permit and its updated
requirements including a number of additional setback (buffer) requirements. Also, pay particular
attention to the monitoring requirements now listed in Attachments A, B and C instead of the body of
the permit with the previous permit issuance. Note that failure to establish an adequate system for
collecting and maintaining the required operational information shall result in future compliance
problems.
If any parts, requirements or limitations contained in this permit are unacceptable, the
Permittee has the right to request an adjudicatory hearing upon written request within 30 days
following receipt of this permit. This request shall 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 at 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made,
this permit shall be final and binding.
1RECENED/NCDE61/DWR
AUG 2 9 Zola
Non -Discharge
Permitting Unit
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location : 2728 Caaital Boulevard, Raleigh; North Carolina 27604 �n4
ww
Phone: 9 i 9-733-3221 ', FAX 1: 919-7` 5-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748�Iii
Internet: wricwatergualitv.org
: "e-,ia1 Gppor;::r'.y'11F.mrrnaGue,4ction _n plover A a a

Mr. David Gum
August 25, 2011
Page 2 of 2
If you need additional information concerning this matter, please contact Cory Larsen at
[phone] or [e-mail].
Sincerely,
a
/Coleen H. Sullins
cc: Lincoln County Health Department
Mooresville Regional Office, Aquifer Protection Section
Permit File WQ0003924
Notebook File WQ0003924

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
WASTEWATER IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General. Statutes of North Carolina as
amended, and other applicable Laws, Rules and Regulations
PERMISSION IS HEREBY GRANTED TO
NFP Holdings, LLC
Lincoln County
FOR THE
continued operation of a 60,000 gallon per day (GPD) wastewater treatment and wastewater irrigation
facility consisting of:
a 12,500 gallon capacity surge tank, a 300,000 gallon capacity storage tank, a 2,000,000 gallon storage
capacity lagoon, dual 585 GPM irrigation pumps, a six zone, 21.5 acre irrigation disposal area, manual
controller, and all associated piping, valves, and appurtenances,
to serve National Fruit Product Company, Inc., with no discharge of wastes to surface waters, pursuant to
the application received July 29, 2011, and in conformity with the project plans, specifications, and other
supporting data subsequently filed and approved by the Department of Environment and Natural
Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until February 28, 2014, shall void Permit No.
WQ0003924 issued March 9, 2005 and shall be subject to the following specified conditions and
limitations:
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I. SCHEDULES
No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
II. PERFORMANCE STANDARDS
The subject non -discharge facilities shall be effectively maintained and operated at all times so there
is no discharge to surface waters, nor any contravention of groundwater or surface water standards.
In the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions
due to improper operation and maintenance, or failure of the irrigation areas to adequately assimilate
the effluent, the Permittee shall take immediate corrective actions including Division required actions,
such as the construction of additional or replacement wastewater treatment or disposal facilities.
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting from the operation of this facility.
3. All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with
15A NCAC 02C .010.8 (Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction.
4. Effluent limitations shall not exceed those specified in Attachment A.
5. Application rates, whether hydraulic, nutrient or other pollutant, shall not exceed those specified in
Attachment B.
6. The compliance boundary for the disposal system shall be specified in accordance with 15A NCAC
02L .0107(b). This disposal system was individually permitted on or after December 30, 1983;
therefore, the compliance boundary is established at either 250 feet from the effluent disposal area, or
50 feet within the property boundary, whichever is closest to the effluent disposal area. An
exceedance of groundwater standards at or beyond the compliance boundary is subject to remediation
action according to 15A NCAC 02L .0106(d)(2) as well as enforcement actions in accordance with
North Carolina General Statute 143-215.6A through 143-215.6C.
7. In accordance with 15A NCAC 02L .0108, the review boundary is established midway between the
compliance boundary and the effluent. disposal area. Any exceedance of groundwater standards at the
review boundary shall require action in accordance with 15A NCAC 02L .0106.
8. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary.
9. In accordance with 15A NCAC 02L .0107(d), no wells, excluding Division approved monitoring
wells, shall be constructed within the compliance boundary except as provided for in 15A NCAC 02L
.0107(g).
WQ0003924 Version 2.1 Shell Version 101229 Page 2 of 8

10. Except as provided form 15A NCAC 02L .0107(g), the Permittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the
Lincoln County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as al'lowed in 15A NCAC 02L .0107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary; and
c. Reserves the right of the Permittee or the State to enter the property within the compliance
boundary for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
11. The facilities permitted herein shall be constructed according to the following setbacks:
a. The setbacks for irrigation sites shall be as follows (all distances in feet):
i. Any habitable residence or place of public assembly under separate ownership:
400
ii. Any habitable residence or place of public assembly owned by the Permittee:
200
iii. Any private or public water supply source:
100
iv. Surface waters:
100
v. Groundwater lowering ditches:
100
vi. Surface water diversions:
25
vii. Any well with exception of monitoring wells:
100
viii. Any property line:
150
ix. Top of slope of embankments or cuts of two feet or more in vertical height:
15
x. Any water line from a disposal system:
10
xi. Subsurface groundwater lowering drainage systems:
100
xii. Any swimming pool:
100
xiii. Public right of way:
50
xiv. Nitrification field:
20
xv. Any building foundation or basement:
15
x,,ri. Impounded public water supplies:
500
xvii. Public shallow groundwater supply:
500
b. The setbacks for storage and treatment units shall be as follows (all distances in feet):
i... Any habitable residence or place of public assembly under separate ownership: 100
ii. Any private or public water supply source: 100
iii. Surface waters: 50
iv. Any well with exception of monitoring wells: 100
v. Any property line: 50
III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively
maintained and operated as a non -discharge system to prevent the discharge of any wastewater
resulting from the operation of this facility. The Permittee shall maintain an Operation and
Maintenance Plan pursuant to 15A NCAC 02T .0507, which at a minimum shall include operational
functions, maintenance schedules, safety measures and a spill response plan.
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2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non -discharge facilities, in accordance with 15A NCAC 08G .0200 the
Permittee shall designate and employ a certified operator in responsible charge (ORC) and one or
more certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the
previously cited rules.
A suitable year round vegetative cover shall be maintained at all times, such that crop health is
optimized, allows for even distribution of effluent and allows inspection of the irrigation system.
4. Adequate measures shall be taken to prevent effluent ponding in or runoff from the irrigation sites
listed in Attachment B.
5. Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause ponding or runoff.
6. All irrigation equipment shall be tested and calibrated at least once per permit cycle. Calibration
records shall be maintained at the facility for a period of no less than five years, and shall be made
available to the Division upon request.
Only effluent from National. Fruit Product Company, Inc. shall be irrigated on the sites listed in
Attachment B.
No automobiles or machinery shall be allowed on the irrigation sites except during equipment
installation or while maintenance is being performed.
9. Public access to the irrigation sites and wastewater treatment facilities shall be prohibited
10. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in
accordance with 15A NCAC 02T .1100. The Permittee shall maintain a residual management plan
pursuant to 15A NCAC 02T .0508.
11. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is
prohibited.
12. Freeboard in the lagoon shall not be less than two feet at any time.
13. A gauge to monitor waste levels in the lagoon shall be provided. This gauge shall have readily visible
permanent markings indicating the following elevations: maximum liquid level at the top of the
temporary liquid storage volume; minimum liquid level at the bottom of the temporary liquid storage
volume; and the lowest point on top of the dam.
14. A protective vegetative cover shall be established and maintained on all earthen embankments (i.e.,
outside toe of embankment to maximum allowable temporary storage elevation on the inside of the
embankment), berms, pipe runs, erosion control areas, and surface water diversions. Trees, shrubs,
and other woody vegetation shall not be allowed to grow on the earthen dikes or embankments.
Earthen embankment areas shall be kept mowed or otherwise controlled and accessible.
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sampling reporting schedule shall be followed.
2. Per 15A NCAC 02H .0800, a Division certified laboratory shall conduct all laboratory analyses for
the required effluent, groundwater or surface water parameters.
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3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be
reported on Form NDMR.
The Permittee shall install and maintain an appropriate flow measurement device to ensure the
accuracy and reliability of flow measurement consistent with accepted engineering and scientific
practices. Selected flow measurement devices shall be capable of measuring flows with a maximum
deviation of less than ten percent from true flow; accurately calibrated at a minimum of once per year;
and maintained to ensure the accuracy of measurements is consistent with the selected device's
accepted capability. The Permittee shall maintain records of flow measurement device calibration on
file for a period of at least five years. At a minimum, documentation shall include:
a. Date of flow measurement device calibration,
b. Name of person performing calibration, and
c. Percent from true flow.
4. The Permittee shall monitor the effluent from the subject facilities at the frequencies and locations for
the parameters specified in Attachment A.
The Permittee shall maintain adequate records tracking the amount of effluent irrigated. At a
minimum, these records shall include the following information for each irrigation site listed in
Attachment B:
a. Date of irrigation;
b. Volume of effluent irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly, monthly, and year-to-date hydraulic(inches/acre) loadings;
f. Loading rates to each infiltration site listed in Attachment B;
g. Continuous monthly and year-to-date loadings for any non -hydraulic parameter specifically
limited in Attachment B;
h. Weather conditions; and
i. Maintenance of cover crops.
6. Freeboard (i.e., waste level to the lowest embankment elevation) in the lagoon shall be recorded
weekly. Weekly freeboard records shall be maintained at the facility for a period of no less than five
years, and shall be made available to the Division upon request.
7. Three copies of all monitoring data (as specified in Conditions IV.3. and IV.4.) on Form NDMR for
each PPI and three copies of all operation and disposal records (as specified in Conditions IV.5. and
IV.6.) on Form NDAR-2 for every site in Attachment B shall be submitted on or before the last day of
the following month. If no activities occurred during the ..monitoring month, monitoring reports are
still required documenting the absence of the activity. All information shall be submitted to the
following address:
Division of Water Quality
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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9. A record shall be maintained of all residuals removed from this facility. This record shall be
maintained at the facility for a period of no less than five years, and shall be made available to the
Division upon request. At a minimum, this record shall include:
a. Name of the residuals hauler;
b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
10. A maintenance log shall be maintained at this facility. This log shall be maintained at the facility for
a period of no less than five years, and shall be made available to the Division upon request. At a
minimum, this log shall include:
a. Date of calibration of flow measurement device;
b. Visual observations of the plant and plant site; and
c. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing,
inspections and cleanings, etc.).
11. Monitoring wells shall be sampled after construction and within 3 months prior to initiating non -
discharge disposal operations. Monitoring wells shall be sampled thereafter at the frequencies and for
the parameters specified in Attachment C. All mgpping. well construction forms well abandonment
forms and monitoring, data shall refer to the permit number and the well nomenclature as provided in
Attachment C and the Monitoring Well Location Map (previouLly provided in the last permit issuance
as Attachment A).
12. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form (GW-
59) shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Quality
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
13. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each irrigation site listed in Attachment B. These results shall be maintained at the facility for a
period of no less than five years, and shall be.made available .to the Division upon request. At a
minimum, the Standard Soil Fertility Analysis shall include the following parameters:
Acidity
Exchangeable Sodium Percentage
Phosphorus
Base Saturation (by calculation)
Magnesium Potassium
Calcium
Manganese
Sodium
Cation Exchange Capacity
Percent Humic Matter
Zinc
Copper
pH
WQ0003924 Version 2.1 Shell Version 101229 Page 6 of 8

14. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone number (704)
663-1699, as soon as possible, but in no case more than 24 hours, or on the next working day
following the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the facility resulting in the treatment of significant amounts of wastes that is
abnormal in quantity or characteristic, including the known passage of a hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons,
rendering the facility incapable of adequate wastewater treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
e. Ponding in or runoff from the irrigation sites.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].
Persons reporting such occurrences by telephone shall also file a written report in letter form within
five days following first knowledge of the occurrence. This report shall outline the actions taken or
proposed to be taken to ensure the problem does not recur.
V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and disposal facilities.
The Permittee or their designee shall inspect the wastewater treatment and disposal facilities to
prevent malfunctions, facility deterioration and operator errors resulting in discharges, which may
cause the release of wastes to the environment, a threat to human health or a public nuisance. The
Permittee shall maintain an inspection log that includes, at a minimum, the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken. The
Permittee shall maintain this inspection log for a period of five years from the date of the inspection,
and this log shall be made available to the Division upon request.
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the wastewater treatment and disposal facilities
permitted herein at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records required to be maintained under the terms and conditions of this
permit, and may collect groundwater, surface water or leachate samples.
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statutes 143-
215.6A to 143-215.6C.
2. This permit shall become voidable if the permitted facilities are not constructed in accordance with
the conditions of this permit, the Division approved plans and specifications, and other supporting
documentation.
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3. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, Division approved plans and specifications, and other supporting documentation. No
variances to applicable rules governing the construction or operation of the permitted facilities are
granted, unless specifically requested and approved in this permit pursuant to 15A NCAC 02T
.0105(n).
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules
in 15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4
and under the Division's General Permit NCGO10000; any requirements pertaining to wetlands under
15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of
Chapter 143 of the General Statutes.
5. In the event the permitted facilities change ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate property ownership documentation and other supporting
documentation as necessary. The Permittee of record shall remain fully responsible for maintaining
and operating the facilities permitted herein until a permit is issued to the new owner.
6. The Permittee shall retain a set of Division approved plans and specifications for the life of the
facilities permitted herein.
7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority pursuant to 15A NCAC
02T .01050).
8. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110.
9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein
shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b).
10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to
pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15A
NCAC 02T .0105(e)(3).
Permit issued this the 25th day of August 2011
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
1�,r Veen ullins, Director
ivisio of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0003924
WQ0003924 Version 2.1 Shell Version 101229 Page 8 of 8

ATTACHMENT A - L.IMITATIONS AND MONITORING REQUIREMENTS Permit Number: WQ0003924 Version: 2.1
PPI 001— WWTF Inffluent
INFLUENT CHARACTERISTICS INFLUENT LIMITS MONITORINGREQUIREMENTS
PCs Parameter Description Monthly Monthly Geometric Daily Daily Measurement Sample
Code Average Mean Minimum Maximum Frequency Type
50050 Flow, in conduit or through treatment plant 60,000 1 GPD Monthly Recorder
PPI 002 — WWTF Effluent
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
J
MONITORING
REQUIREMENTS
Measurement Sample
Frequency Type
Semi-annually Grab
PCs
Code
Parameter Description
BOD, 5-day (20 deg. C)
Calcium, Total (as Ca)
I Monthly
Average
Monthly Geometric
Mean
Daily
Minimum
Daily
Maximum
00310
mg/1
00916
mg/l
Semi-annually'
Grab
31616
Coliform, Fecal MF, M-FC Broth, 44.5 C
#/100
Semi-annually'
Grab
00927
Magnesium, Total (as Mg)
mg/l
Semi-annually'
Grab
00400
pH
S.U.
Semi-annually'
Grab
00931
Sodium Adsorption Ratio
ratio
Semi-annually'
Grab
00929
Sodium, Total (as Na)
mg/1
Semi-annually'
Grab
00530
Solids, Total Suspended
mg/1
Semi-annually'
Grab
Notes:
1. Semi-annual sampling shall occur in the months of April and October.
WQ0003924 Version 2.1 Attachment A Page 1 of 2

1 M �1� i t : ►'.
WQ0003924 Version 2.1 Attachment A Page 2 of

ATTACHMENT R - APPROVED LAND APPLICATION SITES AND LIMITATIONS
Permit Number: WQ0003924 Version: 2.1
NFP Holdings, LLC — National Fruit Product Company, Inc.
IRRIGATION AREA INFORMATION
APPLICATION LIMITATIONS
Feld
Owner
County
Latitude
Longitude
Net
Acreage
Dominant
Soil Series
Parameter
Hourly
Rate
Pearly
Max
Units
01
National Fruit Product Company, Inc.
Lincoln
35°30'52"
8I°14'48"
4.6
01284 - Application Surface Irrigation
0.5
45.5
inches
02
National Fruit Product Company, Inc.
Lincoln
35°30'54"
81°14'48"
2.7
01284 - Application Surface Irrigation
0.5
45.5
inches
03
National Fruit Product Company, Inc.
Lincoln
35°30'56"
81°]4'49"
4.0
01284 - Application Surface Irrigation
0.5
45.5
inches
04
National Fruit Product Company, Inc.
Lincoln
35°30'59"
81°14'50"
3.8
01284 - Application Surface Irrigation
0.5
45.5
inches
05
National Fruit Product Company, Inc.
Lincoln
3591'01"
81°14'52"
3.1
01284 - Application Surface Irrigation
0.5
45.5
inches
06
National Fruit Product Company, Inc.
Lincoln
3591'03"
81°14'47"
3.3
01284 - Application Surface Irrigation
0.5
45.5
inches
Totals
21.5
45.5
This permit allows a total maximum hydraulic loading of 45.5 inches per year at a rate not to exceed 0.5 inches per hour.
WQ0003924 Version 2.1 Attachment B Pagel of2

W00003924emails19
From: Saunders, Erickson G
Sent: Wednesday, September 05, 2018 3:49 PM
To: Buffington, Beth
Subject: RE: ORC Status for W00011655 and WQOOOS173
Mr. Medford is the camp ranger who signed the application and his personal email is
given as [e-mail] <mailto:[e-mail]> . The phone is (252)
947-0008, though I'm unsure if that's his personal phone number. As for the other,
the permittees contact information is [phone] and [e-mail]
<mailto:[e-mail]> . Mr. Cannon's personal contact information is given as
tcannon@boguebankswater. cam <mailto:[e-mail]> and [phone]
as his work number.
Thanks for looking into this, and I have another quick question. I have another
permit (W00003924) which doesn't currently utilize their facility (but it's built),
and only has one ORC. Is this an issue that would require them to get a backup ORC?
Thanks again for any help you might be able to give and sorry for throwing it all an
you at once!
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Buffington, Beth
Sent: Wednesday, September 05, 2018 3:38 PM
To: Saunders, Erickson G <[e-mail]>
Subject: RE: ORC Status for WOCOI1655 and WQ0805173
Page 1
W00003924emailsl9
Division of Water Resources, Dept of Environmental Quality
1619 Mail Service Center, Raleigh NC 27699-1618
PH: 919-7e7-9105 FX: 919-715-2726
http://deq.nc.gov/about/divisions/water-resources/operator-certification
<http://deq.nc.gov/about/divisions/water-resources/operator-certification>
-------------------------------------------
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: Saunders, Erickson G
Sent: Wednesday, September 5, 2018 10:52 AM
To: Buffington, Beth <[e-mail] <mailto:[e-mail]>
Subject: ORC Status for W0001265S and W00005173
Hey Beth,
I was reviewing a few wastewater irrigation and high rate infiltration facilities
and I noticed that two of them had an invalid ORC.
The first one is the backup ORC for W00005173, and the operator is Roy T. Cannon.
His WW-2 certificate #24019 is invalid, and it looks like he's $100 overdue for a
certification renewal 1n 2012. That may be why he's invalid as a WW-2 operator, but
Page 3
W00003924emailsl9
Hey Erick,
About W00005173 and Roy Cannon. This one is a bit of a mess. I'm impressed that you
figured out his WW-2 has been invalid since 2012 for not paying his renewal fee.
This is probably way more than you want to know (I just said that in an email to
Emily), but both his WW-2 and his subsurface certification (SS) were invalidated in
early 2013. Once certificates are invalid for more than 2 years, they cannot be
renewed. An operator has to go back to a training school and retake the exam. That
$100 sitting out there in RIMS should have been voided since he can't pay it.
Then he gets a PC-1 certificate in Dec of 2015, then doesn't renew it at the end of
2016 so that certificate goes invalid. He paid his renewal and late fee in early
February 2017 and we reinstated the PC -I. I think we also mistakenly reinstated his
long invalid SS certificate at the same time by mistake. Not really sure what to do
about that, but the bottom line is that he can't pay the $100 and renew his WW-2.
The owner may have another backup and just hasn't submitted an updated designation
form.
About WW0011655 and James Medford. He has only been invalid since the beginning of
this year so he does owe the $1ee.00 that BIMS is showing (and he owes us some
continuing ad). Do you have any information indicating he's still the ORC? If he is,
he needs to get his certificate reinstated. If not, the facility needs to designate
a new ORC.
I'll be glad to email or call both facilities and find out what's up. Do you have
current contacts and info?
Thanks, Beth
Beth Buffington
Environmental Specialist II, NC Operator Certification Program
Page 2
W00003924emailsl9
I'm new so I'm not that knowledgeable about ORC stuff yet.
The second one is the main ORC for W0001165, James N, Medford. His SI certification
#995478 is also invalid, and he's also $100 overdue for a certification renewal this
year. That's probably also why but could you check just so I know and can get to
them about it?
Thanks in advance for any help you can give,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Thornburg, Nathaniel
Sent: Monday, October 15, 2818 10:43 AM
To: Saunders, Erickson G
Cc: Watson, Edward M; Pitner, Andrew
Subject: RE: Status Update on Non -Discharge Staff Reports
Erick,
Please see Andrew's email below. Please scan and email the renewal package to MRO
ASAP.
Page 4

W00003924emailsl9
WQ0003924emailsl9
Thank you,
Nathaniel D. Thornburg
Branch Chief
Non -Discharge Branch
Department of Environmental Quality
919 707 3653 office (NEW)
[e-mail] <mailto:[e-mail]>
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pitner, Andrew
Sent: Monday, October 15, 2018 10:41 AM
To: Thornburg, Nathaniel<[e-mail]>
Cc: Watson, Edward M <[e-mail]>
Subject: RE: Status Update on Non -Discharge Staff Reports
Hi Nathaniel,
MRO doesn't appear to have received the renewal package/staff report request. The
last email record I have was from 8/28 where Mr. Zombro was in the process of
submitting the renewal. I couldn't identify the renewal package in Laserfiche
either. We'd be glad to fast track a review as this one is due for re -inspection.
Page 5
W00003924emailsl9
Please provide me a status update on the following. Also, if staff are sending
reports directly to the reviewer using email, please have them copy me so I can be
sure to update my tracking.
Statutory?
Statutory Date
Stat / AI Due
Total Days
Reviewer
Application Number
Status
Facility Name
Owner
Permit Type
Application Type
County
Region
Regional Reviewer
No
27-Nov-18
43
47
Saunders
W00003924
Waiting on RO Comments
Page 7
Andrew
Andrew Pitner, P.G.
Assistant Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources
Department of Environmental Quality
704 235 2180 direct office
704 663 1699 MRO main line
704 663 6040 fax
DWR website: http://www.ncwater.org <http://www.ncwater.org/>
610 East Center Avenue, Suite 301, Mooresville, NC 28115
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
From: Thornburg, Nathaniel
Sent: Monday, October 15, 2018 7:24 AM
To: Pitner, Andrew <[e-mail] <mailto:[e-mail]> >
Subject: Status Update on Non -Discharge Staff Reports
Page 6
W00003924emails19
National Fruit Product Company - Lincolnton WWTF
NFP Holdings, LLC
Wastewater Irrigation
Renewal
Lincoln
MRO
Thank you!
Nathaniel D. Thornburg
Branch Chief
Non -Discharge Branch
Department of Environmental Quality
919 807 6453 office
[e-mail] <mailto:[e-mail]>
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Page 8

WQBB03924emails19 W00003924emailsl9
ASAP.
From: Saunders, Erickson G
Sent: Monday, October 15, 2018 10:53 AM
To: Watson, Edward M; Pitner, Andrew
Cc: Thornburg, Nathaniel
Subject: RE: Status Update on Non -Discharge Staff Reports
Attachments: W00003924app18.pdf
I have attached everything in the application except the previous permit because I
assume your office has it and it would make the file huge. Let me know if you would
like it.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Thornburg, Nathaniel
Sent: Monday, October 15, 2018 10:43 AM
To: Saunders, Erickson G <[e-mail]>
Cc: Watson, Edward M <[e-mail]>; Pitner, Andrew
<[e-mail]>
Subject: RE: Status Update on Non -Discharge Staff Reports
Erick,
Please see Andrew's email below. Please scan and email the renewal package to MRO
Page 9
W00003924emailsl9
MRO doesn't appear to have received the renewal package/staff report request. The
last email record I have was from 8/28 where Mr. Zombro was in the process of
submitting the renewal. I couldn't identify the renewal package in Laserfiche
either. We'd be glad to fast track a review as this one is due for re -inspection.
Andrew
Andrew Pitner, P.G.
Assistant Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources
Department of Environmental Quality
704 235 2180 direct office
784 663 1699 MRO main line
704 663 6040 fax
DWR website: http://www.ncwater.org <http://www.ncwater.org/>
610 East Center Avenue, Suite 301, Mooresville, NC 28115
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Thank you,
Nathaniel D. Thornburg
Branch Chief
Non -Discharge Branch
Department of Environmental Quality
919 707 3653 office (NEW)
[e-mail] <mailto:[e-mail]>
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pitner, Andrew
Sent: Monday, October 15, 2018 10:41 AM
To: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >
Cc: Watson, Edward M <edward. [e-mail] <mailto:[e-mail]> >
Subject: RE: Status Update on Non -Discharge Staff Reports
Hi Nathaniel,
Page 10
WQ6603924emails19
Sent: Monday, October 15, 2018 7:24 AM
To: Pitner, Andrew <[e-mail] cmailto:[e-mail]> >
Subject: Status Update on Non -Discharge Staff Reports
Please provide me a status update on the following. Also, if staff are sending
reports directly to the reviewer using email, please have them copy me so I can be
sure to update my tracking.
Statutory?
Statutory Date
Stat / AI Due
Total Days
Reviewer
Application Number
Status
Facility Name
Owner
Permit Type
Application Type
County
Region
Regional Reviewer
No
27-Nov-18
43
47
From: Thornburg, Nathaniel
Page 11 Page 12

W00003924emails19
Saunders
W000B3924
Waiting on RO Comments
National Fruit Product Company - Lincolnton WWTF
NFP Holdings, LLC
Wastewater Irrigation
Renewal
Lincoln
MRO
Thank you!
Nathaniel D. Thornburg
Branch Chief
Non -Discharge Branch
Department of Environmental Quality
919 807 6453 office
[e-mail] <mailto:[e-mail]>
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Page 13
W00003924emailsl9
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Thornburg, Nathaniel
Sent: Monday, October 15, 2018 10:43 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Cc: Watson, Edward M <[e-mail] <mailto:[e-mail]> >;
Pitner, Andrew <[e-mail] <mailto: and raw. pitner@ncden r. gov> >
Subject: RE: Status Update on Non -Discharge Staff Reports
Erick,
Please see Andrew's email below. Please scan and email the renewal package to MRO
ASAP.
Thank you
Nathaniel D. Thornburg
Branch Chief
Non -Discharge Branch
Department of Environmental Quality
W00003924emailsl9
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Watson, Edward M
Sent: Monday, October 15, 2018 11:49 AM
To: Saunders, Erickson G
Cc: Pitner, Andrew; Thornburg, Nathaniel
Subject: RE: Status Update on Non -Discharge Staff Reports
Erick,
I have sent an email and left a phone message to set-up a site visit for this
facility. It is my understanding that National Fruit has found a buyer for the
site. I will submit the staff report as soon as I can get access to the facility.
Regards,
Ed
From: Saunders, Erickson G
Sent: Monday, October 15, 2018 10:53 AM
To: Watson, Edward M <[e-mail]>; Pitner, Andrew
<andrew. [e-mail]>
Cc: Thornburg, Nathaniel <nathaniel. [e-mail]>
Subject: RE: Status Update on Non -Discharge Staff Reports
I have attached everything in the application except the previous permit because I
assume your office has it and it would make the file huge. Let me know if you would
like it.
Erick Saunders
Department of Environmental Quality
Page 14
WQe003924emails19
919 707 3653 office (NEW)
[e-mail] <mailto:[e-mail]>
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pitner, Andrew
Sent: Monday, October 15, 2018 10:41 AM
To: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >
Cc: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Subject: RE: Status Update on Non -Discharge Staff Reports
Hi Nathaniel,
MRO doesn't appear to have received the renewal package/staff report request. The
last email record I have was from 8/28 where Mr. Zombro was in the process of
submitting the renewal. I couldn't identify the renewal package in Laserfiche
either. We'd be glad to fast track a review as this one is due for re -inspection.
Andrew
Andrew Pitner, P.G.
Assistant Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Page 15
Page 16

W00003924emailsl9
W00003924emails19
Division of Water Resources
Total Days
Department of Environmental Quality
Reviewer
Application Number
704 235 2180 direct office
Status
704 663 2699 MRO main line
Facility Name
704 663 6040 fax
Owner
DWR website: http://www.ncwater.org <http://www.ncwater.org/>
Permit Type
Application Type
610 East Center Avenue, Suite 301, Mooresville, NC 28115
County
Region
Email correspondence to and from this address is subject to the North Carolina
Regional Reviewer
Public Records Law and may be disclosed to third parties.
No
27-Nov-18
43
47
From: Thornburg, Nathaniel
Sent: Monday, October 15, 2018 7:24 AM
Saunders
To: Pitner, Andrew <[e-mail] <mailto:[e-mail]> >
Subject: Status Update on Non -Discharge Staff Reports
W00003924
Waiting on RD Comments
Please provide me a status update on the following. Also, if staff are sending
National Fruit Product Company - Lincolnton WWiF
reports directly to the reviewer using email, please have them copy me so I can be
sure to update my tracking.
NFP Holdings, LLC
Wastewater Irrigation
Statutory?
Renewal
Statutory Date
Lincoln
Stat / AI Due
MRO
Page 17
Page 18
W00003924emails19
WQB003924emails19
After having conversations with the representative of the new site owner, they will
renew the permit pending the completion of closure activities. Eventually, they plan
to rescind the permit, has their operation does not have a need for an irrigation
Thank you!
system. I have a site visit scheduled for 10/30/2018 to review the system with the
owner's consultant. The consultant has already received the name change and Lagoon
Closure information.
Nathaniel D. Thornburg
Branch Chief
They wish to use the lagoon as a recycle pond, so I have requested information
regarding their treatment process. However, it appears the new owner has already
Non -Discharge Branch
received a POTW from the City of Lincolnton. I will have more information after the
meeting on the 36th.
Department of Environmental Quality
919 907 6453 office
[e-mail] <mailto:[e-mail]>
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Watson, Edward M
Sent: Tuesday, October 23, 2018 2:22 PM
To: Saunders, Erickson 6
Subject: National Fruit Permit renewal
Erik,
Page 19
If there is anything additional paperwork the new owner will need to complete in
order to complete system closure and rescind the permit, please let me know, so I
can get those documents to the new owner
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 235 2198 Office
704 235 6040 Fax
[e-mail] <mailto:[e-mail]>
Page 20

W00003924emailsl9
W00003924emailsl9
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Saunders, Erickson G
Sent: Tuesday, October 23, 2018 3:37 PM
To: Watson, Edward M
Subject: RE: National Fruit Permit renewal
Attachments: Lagoon Closure.pdf
Hey Ed,
I don't think there's any other documentation other than this lagoon closure
document that you've probably already sent them. Permit rescission would just be the
permittee emailing Nathaniel that they want to get rid of the permit. If you could
get a timeline we could see if the current permittee could just close the lagoon and
the rest of the facility themselves and not have to do a name change. But if they
can't close it before the permit expires on March 1, 2019, then a name change will
be required. In that case, this application with be withdrawn and a new name change
permit application will have to be submitted, including the NDSR 06-16 and the
NDPONC 06-16 forms. Then the new permittee could close and rescind the permit.
Let me know what the plan is for the lagoon and if it will be repurposed for. It may
still need a permit depending on what it's used for.
Thanks,
Page 21
W00003924emails19
If there is anything additional paperwork the new owner will need to complete in
order to complete system closure and rescind the permit, please let me know, so I
can get those documents to the new owner.
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 235 2198 Office
704 235 6040 Fax
[e-mail] <mailto:[e-mail]>
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Tuesday, October 23, 2018 2:22 PM
To: Saunders, Erickson G <[e-mail]>
Subject: National Fruit Permit renewal
Erik,
After having conversations with the representative of the new site owner, they will
renew the permit pending the completion of closure activities. Eventually, they plan
to rescind the permit, has their operation does not have a need for an irrigation
system. I have a site visit scheduled for 10/30/2018 to review the system with the
owner's consultant. The consultant has already received the name change and Lagoon
Closure information.
They wish to use the lagoon as a recycle pond, so I have requested information
regarding their treatment process. However, it appears the new owner has already
received a POTW from the City of Lincolnton. I will have more information after the
meeting on the 30th.
Page 22
W00003924emailsl9
From: Saunders, Erickson G
Sent: Monday, November 05, 2018 9:25 AM
To: Watson, Edward M
Subject: RE: National Fruit Permit renewal
Ed,
What's the status on this one?
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Tuesday, October 23, 2018 3:37 PM
To: Watson, Edward M <[e-mail]>
Subject: RE: National Fruit Permit renewal
Email correspondence to and from this address is subject to the Hey Ed,
North Carolina Public Records Law and may be disclosed to third parties.
Page 23
Page 24

W00003924emailsl9
W00003924emailsl9
I don't think there's any other documentation other than this lagoon closure
document that you've probably already sent them. Permit rescission would just be the
permittee emailing Nathaniel that they want to get rid of the permit. If you could
get a timeline we could see if the current permittee could just close the lagoon and
the rest of the facility themselves and not have to do a name change. But if they
can't close it before the permit expires on March 1, 2019, then a name change will
be required. In that case, this application with be withdrawn and a new name change
permit application will have to be submitted, including the NDSR 06-16 and the
NDPONC 06-16 forms. Then the new permittee could close and rescind the permit.
Let me know what the plan is for the lagoon and if it will be repurposed for. It may
still need a permit depending on what it's used for.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Tuesday, October 23, 2018 2:22 PM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: National Fruit Permit renewal
Page 25
W00003924emailsl9
704 235 6040 Fax
[e-mail] <mailto:[e-mail]>
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Watson, Edward M
Sent: Monday, November 05, 2018 9:58 AM
To: Saunders, Erickson G
Cc: Pitner, Andrew
Subject: RE: National Fruit Permit renewal
Erick,
I visited this site on Tuesday, October 30, 2018. I have verified that they have
the required information and advised the ORC to focus on the permit renewal.
Eventually, this permit will be rescinded once all of the documentation and the
Lagoon Closure has been completed. This includes the abandonment of the spray
irrigation system.
The new owner has a permit to send their pretreated WW to the Town of Lincolnton.
Eventually they will not require our permit. I expect this could take as much as a
year to complete the transition away from our permit.
Page 27
Erik,
After having conversations with the representative of the new site owner, they will
renew the permit pending the completion of closure activities. Eventually, they plan
to rescind the permit, has their operation does not have a need for an irrigation
system. I have a site visit scheduled for 10/30/2018 to review the system with the
owner's consultant. The consultant has already received the name change and Lagoon
Closure information.
They wish to use the lagoon as a recycle pond, so I have requested information
regarding their treatment process. However, it appears the new owner has already
received a POTW from the City of Lincolnton. I will have more information after the
meeting an the 30th.
If there is anything additional paperwork the new owner will need to complete in
order to complete system closure and rescind the permit, please let me know, so I
can get those documents to the new owner.
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of water Resources
North Carolina Department of Environmental Quality
704 235 2198 Office
Page 26
W00003924emails19
Best Regards,
Ed
From: Saunders, Erickson G
Sent: Monday, November 5, 2018 9:25 AM
To: Watson, Edward M <[e-mail]>
Subject: RE: National Fruit Permit renewal
Ed,
What's the status on this one?
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Tuesday, October 23, 2018 3:37 PM
To: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Page 28

W00003924emails19
Subject: RE: National Fruit Permit renewal
Hey Ed,
I don't think there's any other documentation other than this lagoon closure
document that you've probably already sent them. Permit rescission would just be the
permittee emailing Nathaniel that they want to get rid of the permit. If you could
get a timeline we could see if the current permittee could just close the lagoon and
the rest of the facility themselves and not have to do a name change. But if they
can't close it before the permit expires on March 1, 2019, then a name change will
be required. In that case, this application with be withdrawn and a new name change
permit application will have to be submitted, including the NDSR 06-16 and the
NDPONC 06-16 forms. Then the new permittee could close and rescind the permit.
Let me know what the plan is for the lagoon and if it will be repurposed for. It may
still need a permit depending on what it's used for.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Page 29
W00003924emailsl9
North Carolina Department of Environmental Quality
704 235 2198 Office
704 235 6040 Fax
[e-mail] <mailto:[e-mail]>
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Saunders, Erickson G
Sent: Monday, November 05, 2018 10:05 AM
To: Watson, Edward M
Subject: RE: National Fruit Permit renewal
Ed,
Would it be wise to do a name change for this site so that the new owners can close
it at their leisure? Also, who are the new owners?
Erick Saunders
Department of Environmental Quality
Page 31
W00003924emails19
Sent: Tuesday, October 23, 2018 2:22 PM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: National Fruit Permit renewal
Erik,
After having conversations with the representative of the new site owner, they will
renew the permit pending the completion of closure activities. Eventually, they plan
to rescind the permit, has their operation does not have a need for an irrigation
system. I have a site visit scheduled for 10/30/2018 to review the system with the
owner's consultant. The consultant has already received the name change and Lagoon
Closure information.
They wish to use the lagoon as a recycle pond, so I have requested information
regarding their treatment process. However, it appears the new owner has already
received a POTW from the City of Lincolnton. I will have more information after the
meeting on the 30th.
If there is anything additional paperwork the new owner will need to complete in
order to complete system closure and rescind the permit, please let me know, so I
can get those documents to the new owner.
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
Page 30
WQBB03924emailsl9
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Monday, November 05, 2018 9:58 AM
To: Saunders, Erickson G <[e-mail]>
Cc: Pitner, Andrew <[e-mail]>
Subject: RE: National Fruit Permit renewal
Erick,
I visited this site on Tuesday, October 30, 2018. I have verified that they have
the required information and advised the ORC to focus on the permit renewal.
Eventually, this permit will be rescinded once all of the documentation and the
Lagoon Closure has been completed. This includes the abandonment of the spray
irrigation system.
The new owner has a permit to send their pretreated WW1 to the Town of Lincolnton.
Eventually they will not require our permit. I expect this could take as much as a
year to complete the transition away from our permit.
Best Regards,
Ed
Page 32

W00093924emailsl9
W00003924emailsl9
From: Saunders, Erickson G
Sent: Monday, November 5, 2018 9:25 AM
To: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Subject: RE: National Fruit Permit renewal
Ed
What's the status on this one?
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Tuesday, October 23, 2018 3:37 PM
To: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Subject: RE: National Fruit Permit renewal
Hey Ed,
Page 33
W00003924emailsl9
Erik,
After having conversations with the representative of the new site owner, they will
renew the permit pending the completion of closure activities. Eventually, they plan
to rescind the permit, has their operation does not have a need for an irrigation
system. I have a site visit scheduled for 10/30/2018 to review the system with the
owner's consultant. The consultant has already received the name change and Lagoon
Closure information.
They wish to use the lagoon as a recycle pond, so I have requested information
regarding their treatment process. However, it appears the new owner has already
received a POTW from the City of Lincolnton. I will have more information after the
meeting an the 30th.
If there is anything additional paperwork the new owner will need to complete in
order to complete system closure and rescind the permit, please let me know, so I
can get those documents to the new owner
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 235 2198 Office
Page 35
I don't think there's any other documentation other than this lagoon closure
document that you've probably already sent them. Permit rescission would just be the
permittee emailing Nathaniel that they want to get rid of the permit. If you could
get a timeline we could see if the current permittee could just close the lagoon and
the rest of the facility themselves and not have to do a name change. out if they
can't close it before the permit expires on March 1, 2019, then a name change will
be required. In that case, this application with be withdrawn and a new name change
permit application will have to be submitted, including the NDSR 06-16 and the
NDPONC 06-16 forms. Then the new permittee could close and rescind the permit.
Let me know what the plan is for the lagoon and if it will be repurposed for. It may
still need a permit depending on what it's used for.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Tuesday, October 23, 2018 2:22 PM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: National Fruit Permit renewal
Page 34
W00003924emailsl9
704 235 5040 Fax
[e-mail] <mailto:[e-mail]>
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Watson, Edward M
Sent: Monday, November 05, 2018 10:17 AM
To: Saunders, Erickson G
Cc: Pitner, Andrew
Subject: RE: National Fruit Permit renewal
Erik,
I spoke to Nathaniel about this permit prior to the site visit. His recommendation
was to have the new owner complete the name change so they have coverage during the
process required to perform the closure activities. The amount of work required to
perform these closure activities may take as much as a year with the required
laboratory analytical analysis for the sludge present in the lagoon and the rest of
the closure activities. Closure activities may be completed in less than a year.
However, a year seems reasonable due to the amount of work we are requiring them to
perform to complete closure.
The new owner is Linco Partnership. Their home address is 5200 Old Harding Road,
Nashville, TN 37064.
Page 36

W00003924emails19
There is a renter on site called Celadon. However, Linco is the actual property
owner.
Perry Keister is the contact person for Linco and the new permit will be addressed
to him. Perry's contact information is 828-638-5032, if you need to contact him.
Regards,
Ed
From: Saunders, Erickson G
Sent: Monday, November 5, 2018 10:05 AM
To: Watson, Edward M <[e-mail]>
Subject: RE: National Fruit Permit renewal
Ed,
Would it be wise to do a name change for this site so that the new owners can close
it at their leisure? Also, who are the new owners?
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
Page 37
W00003924emailsl9
Ed,
What's the status on this one?
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Tuesday, October 23, 2018 3:37 PM
To: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Subject: RE: National Fruit Permit renewal
Hey Ed,
I don't think there's any other documentation other than this lagoon closure
document that you've probably already sent them. Permit rescission would just be the
permittee emailing Nathaniel that they want to get rid of the permit. If you could
get a timeline we could see if the current permittee could just close the lagoon and
the rest of the facility themselves and not have to do a name change. But if they
W00003924emailsl9
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Monday, November 05, 2018 9:58 AM
To: Saunders, Erickson G <[e-mail]
<mallto:[e-mail]> >
Cc: Pitner, Andrew <[e-mail] <mailto:[e-mail]> >
Subject: RE: National Fruit Permit renewal
Erick,
I visited this site on Tuesday, October 30, 2018. I have verified that they have
the required information and advised the ORC to focus on the permit renewal.
Eventually, this permit will be rescinded once all of the documentation and the
Lagoon Closure has been completed. This includes the abandonment of the spray
irrigation system.
The new owner has a permit to send their pretreated WW to the Town of Lincolnton.
Eventually they will not require our permit. I expect this could take as much as a
year to complete the transition away from our permit.
Best Regards,
Ed
From: Saunders, Erickson G
Sent: Monday, November 5, 2018 9:25 AM
To: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Subject: RE: National Fruit Permit renewal
Page 38
W00003924emails19
can't close it before the permit expires on March 1, 2019, then a name change will
be required. In that case, this application with be withdrawn and a new name change
permit application will have to be submitted, including the NDSR 06-16 and the
NDPONC 06-16 forms. Then the new permittee could close and rescind the permit.
Let me know what the plan is for the lagoon and if it will be repurposed for. It may
still need a permit depending on what it's used for -
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Tuesday, October 23, 2018 2:22 PM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: National Fruit Permit renewal
Erik,
Page 39 Page 40

W00003924emails19 W00003924emailsl9
After having conversations with the representative of the new site owner, they will 620 E. Center Ave.
renew the permit pending the completion of closure activities. Eventually, they plan
to rescind the permit, has their operation does not have a need for an irrigation Suite 301
system. I have a site visit scheduled for 10/30/2018 to review the system with the
owner's consultant. The consultant has already received the name change and Lagoon Mooresville, NC 28115
Closure information.
They wish to use the lagoon as a recycle pond, so I have requested information
regarding their treatment process. However, it appears the new owner has already
received a POTW from the City of Lincolnton. I will have more information after the
meeting on the 3eth.
If there is anything additional paperwork the new owner will need to complete in
order to complete system closure and rescind the permit, please let me know, so I
can get those documents to the new owner.
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 235 2198 Office
704 235 6040 Fax
[e-mail] <mailto:[e-mail]>
Page 41
W00003924emailsl9
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Monday, November 05, 2018 10:17 AM
To: Saunders, Erickson G <[e-mail]>
Cc: Pitner, Andrew <[e-mail]>
Subject: RE: National Fruit Permit renewal
Erik,
I spoke to Nathaniel about this permit prior to the site visit. His recommendation
was to have the new owner complete the name change so they have coverage during the
process required to perform the closure activities. The amount of work required to
perform these closure activities may take as much as a year with the required
laboratory analytical analysis for the sludge present in the lagoon and the rest of
the closure activities. Closure activities may be completed in less than a year.
However, a year seems reasonable due to the amount of work we are requiring them to
perform to complete closure.
The new owner is Linco Partnership. Their home address is 5200 Old Harding Road,
Nashville, TN 37064.
There is a renter on site called Celadon. However, Linco is the actual property
owner.
Perry Keister is the contact person for Linco and the new permit will be addressed
to him. Perry's contact information is 828-638-5032, if you need to contact him.
Regards,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Saunders, Erickson G
Sent: Monday, November 05, 2018 10:25 AM
To: Watson, Edward M
Cc: Pitner, Andrew
Subject: RE: National Fruit Permit renewal
Would you happen to know if Linco has already bought or has an agreement to buy the
property? If so, I can add info it to have the change of ownership done now. If not,
then I can proceed.
Also, are Celadon the ones leasing the site now, or will they be.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
Page 42
W00003924emailsl9
Ed
From: Saunders, Erickson G
Sent: Monday, November 5, 2018 10:05 AM
To: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Subject: RE: National Fruit Permit renewal
Ed,
Would it be wise to do a name change for this site so that the new owners can close
it at their leisure? Also, who are the new owners?
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Monday, November 05, 2018 9:58 AM
To: Saunders, Erickson G <Ericks.9n:5 [e-mail]
<mailto:[e-mail]> >
Cc: Pitner, Andrew <[e-mail] <mailto:[e-mail]> >
Subject: RE: National Fruit Permit renewal
Page 43 Page 44

W00003924emailsl9
Erick,
I visited this site on Tuesday, October 30, 2018. I have verified that they have
the required information and advised the ORC to focus on the permit renewal.
Eventually, this permit will be rescinded once all of the documentation and the
Lagoon Closure has been completed. This includes the abandonment of the spray
irrigation system.
The new owner has a permit to send their pretreated WA to the Town of Lincolnton.
Eventually they will not require our permit. I expect this could take as much as a
year to complete the transition away from our permit.
Best Regards,
Ed
From: Saunders, Erickson G
Sent: Monday, November 5, 2018 9:25 AM
To: Watson, Edward M [e-mail] <mailto:[e-mail]> >
Subject: RE: National Fruit Permit renewal
Ed,
What's the status on this one?
Thanks,
Page 45
W00003924emails19
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] (mailto:[e-mail]>
From: Watson, Edward M
Sent: Tuesday, October 23, 2018 2:22 PM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: National Fruit Permit renewal
Erik,
After having conversations with the representative of the new site owner, they will
renew the permit pending the completion of closure activities. Eventually, they plan
to rescind the permit, has their operation does not have a need for an irrigation
system. I have a site visit scheduled for 10/30/2018 to review the system with the
owner's consultant. The consultant has already received the name change and Lagoon
Closure information.
They wish to use the lagoon as a recycle pond, so I have requested information
regarding their treatment process. However, it appears the new owner has already
received a POTW from the City of Lincolnton. I will have more information after the
meeting on the 30th.
Page 47
W00003924emails19
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
(919) 7e7-3659 Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Tuesday, October 23, 2018 3:37 PM
To: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Subject: RE: National Fruit Permit renewal
Hey Ed,
I don't think there's any other documentation other than this lagoon closure
document that you've probably already sent them. Permit rescission would just be the
permittee emailing Nathaniel that they want to get rid of the permit. If you could
get a timeline we could see if the current permittee could just close the lagoon and
the rest of the facility themselves and not have to do a name change. But if they
can't close it before the permit expires on March 1, 2019, then a name change will
be required. In that case, this application with be withdrawn and a new name change
permit application will have to be submitted, including the NDSR 06-16 and the
NDPONC 06-16 forms. Then the new permittee could close and rescind the permit.
Let me know what the plan is for the lagoon and if it will be repurposed for. It may
still need a permit depending on what it's used for
Thanks,
Page 46
WQ0003924emailsl9
If there is anything additional paperwork the new owner will need to complete in
order to complete system closure and rescind the permit, please let me know, so I
can get those documents to the new owner.
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 235 2198 Office
704 235 6040 Fax
[e-mail] <mailto:[e-mail]>
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
Page 48

W00003924emailsl9
North Carolina Public Records Law and may be disclosed to third parties.
From: Pitner, Andrew
Sent: Wednesday, November 07, 2018 3:00 PM
To: Saunders, Erickson G
Cc: Watson, Edward M
Subject: W00003942 National Fruit staff report
Attachments: W00003924_20181107_STFRPT.PDF
Hi Erick,
MRO's staff report is attached. A recent inspection is available in RIMS and will
soon be in laserfiche too. Let Ed or I know of any questions.
Andrew
Andrew Pitner, P.G.
Assistant Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources
Department of Environmental Quality
704 235 2180 direct office
704 663 1699 MRO main line
704 663 6040 fax
DWR website: http://www.ncwater.org <http://www.ncwater.org/>
610 East Center Avenue, Suite 361, Mooresville, NC 28115
Page 49
W00003924emailsl9
From: Saunders, Erickson G
Sent: Friday, November 09, 2018 4:00 PM
To: Watson, Edward M
Subject: W00003924 Additional Information Review
Attachments: W00003924a118XXXX.docx
Hey Ed,
I've drafted an additional information request for the facility. Let me know what
you think. I think I'm going to address both James Zombro and the new LINCO contact
when I eventually send it out so they can both be aware of the name change form, and
what we need from them.
Let me know what you think.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Tuesday, November 13, 2018 7:46 AM
To: Saunders, Erickson G
Subject: RE: W00003924 Additional Information Review
Eric,
W00003924emailsl9
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
From: Saunders, Erickson G
Sent: Friday, November 09, 2018 3:57 PM
To: Buffington, Beth
Subject: W00003924 ORC status
Hey Beth,
I think we talked about the ORC status of this one, but I wanted to email you about
it again because I got the staff report. This facility doesn't have a back-up ORC,
but the irrigation system has been isolated from the storage tank so the liquid
never goes into the spray irrigation field at all. In fact, they haven't irrigated
since 2016 and their new owners evidently are getting a municipal hookup now. They
are in the process of undergoing a name change before they close the facility for
good. I was wondering, because the irrigation system is never used anymore, if we
didn't need a backup ORC for this system. It seems relatively pointless, as they
estimated that the permit will be rescinded within the year, and the only water in
the system is coming from rainfall.
Let me know what you think.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 50
W000e3924emails19
It seems fine. Let's get them to get that name change paperwork in process as well.
We need that to be able to continue the process.
Ed
From: Saunders, Erickson G
Sent: Friday, November 9, 2018 4:00 PM
To: Watson, Edward M <[e-mail]>
Subject: W00003924 Additional Information Review
Hey Ed,
I've drafted an additional information request for the facility. Let me know what
you think. I think I'm going to address both James Zombro and the new LINGO contact
when I eventually send it out so they can both be aware of the name change form, and
what we need from them.
Let me know what you think.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 51 Page 52

W00003924emailsl9 W00003924emailsl9
Ed
From: Saunders, Erickson G
Sent: Tuesday, November 13, 2018 10:02 AM
To: Watson, Edward M
Subject: RE: W00003924 Additional Information Review
Thanks Ed. Do you have an email for Perry Keister? I called the number to no avail
Thanks
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Tuesday, November 13, 2018 7:46 AM
To: Saunders, Erickson G <[e-mail]>
Subject: RE: W00003924 Additional Information Review
Eric,
It seems fine. Let's get them to get that name change paperwork in process as well.
We need that to be able to continue the process.
Page 53
W00003924emails19
Cc: Watson, Edward M
Subject: W00003924 Contact Info
Hey Perry,
Just wanted to send an email so it's in my records and I don't have to add it to my
sticky notes.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Tuesday, November 13, 2018 10:20 AM
To: Saunders, Erickson G
Subject: [External] RE: W00003924 Contact Info
CAUTION: External email. Do not click links or open attachments unless verified.
Send all suspicious email as an attachment to Report Spam.
<mailto:[e-mail]>
Thanks
Appreciate the extra time as fully loaded till week after Thanksgiving.
Page 55
From: Saunders, Erickson G
Sent: Friday, November 9, 2018 4:00 PM
To: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Subject: wQee03924 Additional Information Review
Hey Ed,
I've drafted an additional information request for the facility. Let me know what
you think. I think I'm going to address both James Zombro and the new LINCO contact
when I eventually send it out so they can both be aware of the name change form, and
what we need from them.
Let me know what you think.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Tuesday, November 13, 2018 10:13 AM
To: '[e-mail]'
Page 54
W00003924emails19
Perry Keister
828.638.5632
From: Saunders, Erickson G <[e-mail]>
Sent: Tuesday, November 13, 2018 10:13 AM
To: [e-mail]
Cc: Watson, Edward M <[e-mail]>
Subject: W00003924 Contact Info
Hey Perry,
Just wanted to send an email so it's in my records and I don't have to add it to my
sticky notes.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 56

W00003924emails19
W00003924emailsl9
From: Watson, Edward M
Sent: Tuesday, November 13, 2018 3:27 PM
To: Saunders, Erickson G
Subject: RE: W00003924 Additional Information Review
[e-mail]
From: Saunders, Erickson G
Sent: Tuesday, November 13, 2018 10:02 AM
To: Watson, Edward M <[e-mail]>
Subject: RE: W00003924 Additional Information Review
Thanks Ed. Do you have an email for Perry Keister7 I called the number to no avail.
Thanks.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Tuesday, November 13, 2018 7:46 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: RE: W00003924 Additional Information Review
Page 57
W00003924emailsl9
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail]'; '[e-mail]'
Cc: Thornburg, Nathaniel; Watson, Edward M; Pitner, Andrew
Subject: W00003924 Additional Information Request
Attachments: Signature authority designation letter 171103.docx; NDPONC
06-16.docx; W00003924ai181119.pdf
It has come to my attention that this permit has changed hands from NFP Holdings,
LLC to LINCO Partnership. This additional information request is set to address this
ownership change, as well as other issues. I have included the formal additional
information request in this email, along with a few other documents that have
already been partially filled out that you will need to execute. I'm also sending a
physical copy to the mailing address that the regional inspector gave me which is
5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister, but I
don't have a mailing address for him specifically. If this address is incorrect,
please tell me and I can resend it.
Please address all of the items of this request before the end of the day an
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Eric,
It seems fine. Let's get them to get that name change paperwork in process as well.
we need that to be able to continue the process.
Ed
From: Saunders, Erickson G
Sent: Friday, November 9, 2018 4:00 PM
To: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Review
Hey Ed,
I've drafted an additional information request for the facility. Let me know what
you think. I think I'm going to address both lames Zombro and the new LINCO contact
when I eventually send it out so they can both be aware of the name change form, and
what we need from them.
Let me know what you think.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
Page 58
W00003924emailsl9
From: Saunders, Erickson G
Sent: Monday, December 31, 2018 9:45 AM
To: [e-mail]
Subject: RE: W00003924 Additional Information Request
Perry,
I wanted to get an update on the status of this additional information request. I
know that this was delayed by both the Thanksgiving and Christmas holiday seasons.
Thanks and have a great New year,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail]' <[e-mail]>; '[e-mail]'
<[e-mail]>
Cc: Thornburg, Nathaniel<[e-mail]>; Watson, Edward M
<[e-mail]>; Pitner, Andrew <[e-mail]>
Subject: W00003924 Additional Information Request
Page 59 Page 60

W00003924emailsl9
It has come to my attention that this permit has changed hands from NFP Holdings,
LLC to LINCO Partnership. This additional information request is set to address this
ownership change, as well as other issues. I have included the formal additional
information request in this email, along with a few other documents that have
already been partially filled out that you will need to execute. I'm also sending a
physical copy to the mailing address that the regional inspector gave me which is
5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister, but I
don't have a mailing address for him specifically. If this address is incorrect,
please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Monday, December 31, 2018 10:13 AM
To: Saunders, Erickson G
Subject: [External] Re: WQB003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you verified.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Out of office till Wednesday will contact you then
Page 61
W00003924emailsl9
<mailto:nathaniel.thornburg@ncdenr. gov> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP
Holdings, LLC to LINCO Partnership. This additional information request is set to
address this ownership change, as well as other issues. I have included the formal
additional information request in this email, along with a few other documents that
have already been partially filled out that you will need to execute. I'm also
sending a physical copy to the mailing address that the regional inspector gave me
which is 5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister,
but I don't have a mailing address for him specifically. If this address is
incorrect, please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Thursday, January 10, 2019 2:37 PM
To: Perry Keister
Cc: Watson, Edward M
Subject: RE: [External] Re: W00003924 Additional Information Request
W00003924emails29
Perry Keister
Consulting
On Dec 31, 2018, at 9:45 AM, Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> > wrote:
Perry,
I wanted to get an update on the status of this additional information
request. I know that this was delayed by both the Thanksgiving and Christmas holiday
seasons.
Thanks and have a great New year,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: ' [e-mail] <mailto:[e-mail]> ' <[e-mail]
<mailto: [e-mail]> >; '[e-mail] <mailto:[e-mail]> '
<[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
Page 62
W00003924emails19
Mr. Keister,
I wanted to reach out again about the status of the additional information request
for the old National Fruit Product wastewater irrigation permit that we're changing
to LINED Partnership located in Lincolnton, NC.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister [mailto:[e-mail]]
Sent: Monday, December 31, 2018 10:13 AM
To: Saunders, Erickson G <[e-mail]>
Subject: [External] Re: WQ0003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you verified.
Send all suspicious email as an attachment to [e-mail]
<mallto:[e-mail]>
Out of office till Wednesday will contact you then
Page 63
Page 64

W00003924emailsl9
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Thursday, January 10, 2019 2:49 PM
To: Watson, Edward M
Subject: RE: [External] Re: W00003924 Additional Information Request
Thanks,
I just wanted to copy you on the email. He responded a few minutes before you saying
he's looking into it currently.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
Page 73
W00003924emailsl9
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister [mailto:[e-mail]]
Sent: Monday, December 31, 2019 10:13 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] Re: W00003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you verified.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Out of office till Wednesday will contact you then
Perry Keister
Consulting
On Dec 31, 2018, at 9:45 AM, Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> > wrote:
Perry,
I wanted to get an update on the status of this additional information
request. I know that this was delayed by both the Thanksgiving and Christmas holiday
seasons.
W00003924emailsl9
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Thursday, Sanuary 10, 2019 2:48 PM
To: Saunders, Erickson G <[e-mail]>
Subject: RE: [External] Re: W00003924 Additional Information Request
I have not received any information.
Ed
From: Saunders, Erickson G
Sent: Thursday, January 10, 2019 2:37 PM
To: perry Keister <[e-mail] <mailto:[e-mail]> >
Cc: Watson, Edward M <[e-mail] <mailto:[e-mail]> >
Subject: RE: [External] Re: W00003924 Additional Information Request
Mr. Keister,
I wanted to reach out again about the status of the additional information request
for the old National Fruit Product wastewater irrigation permit that we're changing
to LINCO Partnership located in Lincolnton, NC.
Thanks,
Erick Saunders
Department of Environmental Quality
Page 74
W00003924emails19
Thanks and have a great New Year,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail] <mailto:[e-mail]> ' <[e-mail]
<mailta:[e-mail]> >; '[e-mail] <mailto:[e-mail]>
<[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP
Holdings, LLC to LINGO Partnership. This additional information request is set to
address this ownership change, as well as other issues. I have included the formal
additional information request in this email, along with a few other documents that
have already been partially filled out that you will need to execute. I'm also
sending a physical copy to the mailing address that the regional inspector gave me
which is 5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister,
but I don't have a mailing address for him specifically. If this address is
incorrect, please tell me and I can resend it.
Page 75
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W00003924emailsl9
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Tuesday, January 22, 2019 10:22 AM
To: Perry Keister
Cc: Thornburg, Nathaniel
Subject: Lincolnton WWTF Additional Information Due Date - W00003924
Mr. Keister,
I want to email again about the status of this additional information request, as it
is now over a month overdue. If we do not receive a response to our additional
information request by the close of business on Friday, January 25th, the
application will be returned. As this facility is now in the ownership of Linco
Partnership, there will be a corresponding Notice of Violation for operating without
a permit, and we will assess civil penalties.
Thank you,
Erick Saunders
Page 77
W00003924emailsl9
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail]' <[e-mail]>; '[e-mail]'
[e-mail]>
Cc: Thornburg, Nathaniel <[e-mail]>; Watson, Edward M
<[e-mail]>; Pitner, Andrew <[e-mail]>
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP Holdings,
LLC to LINCO Partnership. This additional information request is set to address this
ownership change, as well as other issues. I have included the formal additional
information request in this email, along with a few other documents that have
already been partially filled out that you will need to execute. I'm also sending a
physical copy to the mailing address that the regional inspector gave me which is
5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister, but I
don't have a mailing address for him specifically. If this address is incorrect,
please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail]<mailto:[e-mail]>
W00003924emails19
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
(919) 7e7-3659 Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Wednesday, January 23, 2019 1:57 PM
To: 'Perry Keister'
Subject: FW: W00003924 Additional Information Request
Attachments: Signature authority designation letter 171103.docx; NDPONC
06-16.docx; W00003924ai181119.pdf
The signature authority designation letter is what we discussed on the phone. Get
one of the majority shareholders of Linco to sign it so that you may become an
appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 78
WQ0003924emailsl9
To: Saunders, Erickson G
Subject: [External] RE: WQ0803924 Additional Information Request
Attachments: image001.emz; Signature authority designation letter 171103
1.16.19.docx; o9o9_0001.pdf; Parnership Agreements.pdf
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to report. spam@nc. gov
<mailto:[e-mail]>
Erickson
I am waiting on copy of the deed and register of deed info
From: Saunders, Erickson G <[e-mail]>
Sent: Wednesday, January 23, 2019 1:57 PM
To: Perry Keister <[e-mail]>
Subject: FW: W00003924 Additional Information Request
The signature authority designation letter is what we discussed on the phone. Get
one of the majority shareholders of Linco to sign it so that you may become an
appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
From: Perry Keister <[e-mail]>
Sent: Friday, January 25, 2019 10:15 AM [phone] Office
Page 79 Page 80

W00003924emailsl9
WQ0003924emailsl9
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail]' <[e-mail] <mailto:[e-mail]> >;
' [e-mail]' [e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: WQ0893924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP Holdings,
LLC to LINCO Partnership. This additional information request is set to address this
ownership change, as well as other issues. I have included the formal additional
information request in this email, along with a few other documents that have
already been partially filled out that you will need to execute. I'm also sending a
physical copy to the mailing address that the regional inspector gave me which is
5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister, but I
don't have a mailing address for him specifically. If this address is incorrect,
please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
Page 81
W00003924emailsl9
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Wednesday, September 05, 2018 3:49 PM
To: Buffington, Beth <[e-mail]>
Subject: RE: ORC Status for W00011655 and WQGGGS173
Mr. Medford is the camp ranger who signed the application and his personal email is
given as [e-mail] <mailto:[e-mail]> . The phone is (252)
947-0008, though I'm unsure if that's his personal phone number. As for the other,
the permittees contact information is [phone] and [e-mail]
<mailto:[e-mail]> . Mr. Cannon's personal contact information is given as
[e-mail] <mailto:[e-mail]> and (252) 354-33e7
as his work number.
Thanks for looking into this, and I have another quick question. I have another
permit (W00003924) which doesn't currently utilize their facility (but it's built),
and only has one ORC. Is this an issue that would require them to get a backup ORC?
Thanks again for any help you might be able to give and sorry for throwing it all
Page 83
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Friday, January 25, 2019 10:32 AM
To: Saunders, Erickson G
Subject: [External] Linco
Attachments: NDPONC 06-16 1.16.19.pdf
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Will send deed and ownership data as acquired
From: Saunders, Erickson G
Sent: Monday, January 28, 2019 12:28 PM
To: Buffington, Beth
Subject: ORC Status for W00003924
Importance: High
Beth,
I sent you an email some months back about a permit where the wastewater facility is
inactive, and the system had only one ORC. It's been out for additional information
for a while because there was a change of ownership during the permit cycle which I
did an additional information request for. In that additional information request, I
asked the new owners to contact you about this ORC issue. We recently got the
additional information back, but we didn't hear anything about if they contacted you
about the ORC situation. What's more is that the region says that the only current
ORC (Lynn Aldridge) no longer works on the system because of something to do with
the old owners not paying.
I'm doing a new additional information request for this one essentially asking them
to contact you about the issue, as well as another unrelated issue. I wanted to give
you a heads up, and I also want to get your opinion on having a main and backup ORC
an an inactive system. Let me know what you think or if you have any more questions.
Page 82
W00003924emailsl9
you at once!
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Buffington, Beth
Sent: Wednesday, September 05' 2018 3:38 PM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: RE: ORC Status for W00011655 and W00005173
Hey Erick,
About W00005173 and Roy Cannon. This one is a bit of a mess. I'm impressed that you
figured out his WW-2 has been invalid since 2012 for not paying his renewal fee.
This is probably way more than you want to know (I just said that in an email to
Emily), but both his WW-2 and his subsurface certification (SS) were invalidated in
early 2013. once certificates are invalid for more than 2 years, they cannot be
renewed. An operator has to go back to a training school and retake the exam. That
$100 sitting out there in BIMS should have been voided since he can't pay it.
Then he gets a PC-1 certificate in Dec of 2015, then doesn't renew it at the end of
2016 so that certificate goes invalid. He paid his renewal and late fee in early
February 2017 and we reinstated the PC -I. I think we also mistakenly reinstated his
long invalid 5S certificate at the same time by mistake. Not really sure what to do
Page 84

W00003924emailsl9 WQ0603924emailsl9
about that, but the bottom line is that he can't pay the $100 and renew his WW-2. to third parties unless the content is exempt by statute or other regulation.
The owner may have another backup and just hasn't submitted an updated designation
form._____________________________________________________________________________
About WWO01165S and James Medford. He has only been invalid since the beginning of
this year so he does owe the $100.00 that RIMS is showing (and he owes us some
continuing ad). Do you have any information indicating he's still the ORC? If he is,
he needs to get his certificate reinstated. If not, the facility needs to designate
a new ORC.
I'll be glad to email or call both facilities and find out what's up. Do you have
current contacts and info?
Thanks, Beth
Beth Buffington
Environmental Specialist II, NC Operator Certification Program
Division of Water Resources, Dept of Environmental Quality
1618 Mail Service Center, Raleigh NC 27699-1618
PH: 919-707-9105 FX: 919-715-2726
http://deq.nc.gov/about/divisions/water-resources/operator-certification
<http://deq.nc.gov/about/divisions/water-resources/operator-certification>
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed
Page 85
W00003924emailsl9
Water Quality Permitting
[phone] Office
[e-mail] cmailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, January 28, 2019 12:50 PM
To: 'Perry Keister'
Cc: Thornburg, Nathaniel; Watson, Edward M; Buffington, Beth
Subject: W00003924 Additional Information Request 2
Attachments: W00003924ai190128.pdf
Perry,
Thanks for the submission last Friday. I was out in the field on a last minute site
visit so I may have missed if you called. We are accepting the response and will not
issue an NOV at this time. However, we are sending a second additional information
request to get the Certificate of Assumed Name filed in the Lincoln County Register
of Deeds and to get the ORC situation sorted out. Our systems require one main ORC
and another backup ORC according to 15A NCAC e8G .e201. This system did not have a
backup ORC at the time of permitting, and the region has indicated that Lynn
Aldridge no longer serves the system. Beth Buffington of the Wastewater Operator
Certification group should be the person to contact about this. It would be up to
her to see how this should be handled.
This additional information request is going to be a bit more strict. If we don't
receive these items before the expiration date of February 27, 2019, then we will
rescind the application and issue an NOV to LINCO. If you have any questions, don't
hesitate to contact me.
Thanks you,
Erick Saunders
From: Saunders, Erickson G
Sent: Wednesday, September 5, 2018 18:52 AM
To: Buffington, Beth <[e-mail] <mailto:[e-mail]>
Subject: ORC Status for W00011655 and W00005173
Hey Beth,
I was reviewing a few wastewater irrigation and high rate infiltration facilities
and I noticed that two of them had an invalid ORC.
The first one is the backup ORC for W00005173, and the operator is Roy T. Cannon.
His WW-2 certificate #24019 is invalid, and it looks like he's $100 overdue for a
certification renewal in 2012. That may be why he's invalid as a WW-2 operator, but
I'm new so I'm not that knowledgeable about ORC stuff yet.
The second one is the main ORC for W0001165, James N. Medford. His SI certification
#995478 is also invalid, and he's also $100 overdue for a certification renewal this
year. That's probably also why but could you check just so I know and can get to
them about it?
Thanks in advance for any help you can give,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Page 86
W00003924emails19
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Friday, January 25, 2019 10:15 AM
To: Saunders, Erickson G <[e-mail]>
Subject: [External] RE: W00003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
I am waiting on copy of the deed and register of deed info
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Wednesday, January 23, 2019 1:57 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Page 87
Page 88

W00003924emailsl9
Subject: FW: W00003924 Additional Information Request
The signature authority designation letter is what we discussed on the phone. Get
one of the majority shareholders of Linco to sign it so that you may become an
appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail]' <[e-mail] <mailto:[e-mail]> >;
'[e-mail]' <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP Holdings,
LLC to LINCO Partnership. This additional information request is set to address this
ownership change, as well as other issues. I have included the formal additional
information request in this email, along with a few other documents that have
already been partially filled out that you will need to execute. I'm also sending a
physical copy to the mailing address that the regional inspector gave me which is
5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister, but I
don't have a mailing address for him specifically. If this address is incorrect,
Page 89
W00003924emailsl9
is to close the lagoon and have the permit rescinded.
Thanks and let me know if you want me to contact them.
Beth
Beth Buffington
Environmental Specialist II, NC Operator Certification Program
Division of Water Resources, Dept of Environmental Quality
1618 Mail Service Center, Raleigh NC 27699-1618
PH: 919-707-9105 Fx: 919-715-2726
http://deq.nc.gov/about/divisions/water-resources/operator-certification
<http://deq.nc.gov/about/divisions/water-resources/operator-certification>
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: Saunders, Erickson G
Sent: Monday, January 28, 2019 12:28 PM
Page 91
W00003924emails19
please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Buffington, Beth
Sent: Monday, January 28, 2019 12:51 PM
To: Saunders, Erickson G
Subject: RE: ORC Status for W00003924
Eric,
I'm sorry I haven't gotten back to you an this. I don't recall anyone contacting me.
I'll be glad to email or send them a letter telling them they have to designate if
you can give me the best contact information.
There is nothing in the operator rules that provides any kind of variance for
designating both an ORC and a Backup, even if there is no spray irrigation going on.
The only thing that can be modified is the minimum frequency of ORC visitation. Our
rules allow for alternate visitation to be established in the permit via a
modification. The only way for them to get out of designating both an ORC and Backup
Page 90
W00003924emailsl9
To: Buffington, Beth <[e-mail]>
Subject: ORC Status for W00003924
Importance: High
Beth,
I sent you an email some months back about a permit where the wastewater facility is
inactive, and the system had only one ORC. It's been out for additional information
for a while because there was a change of ownership during the permit cycle which I
did an additional information request for. In that additional information request, I
asked the new owners to contact you about this ORC issue. We recently got the
additional information back, but we didn't hear anything about if they contacted you
about the ORC situation. What's more is that the region says that the only current
ORC (Lynn Aldridge) no longer works on the system because of something to do with
the old owners not paying.
I'm doing a new additional information request for this one essentially asking them
to contact you about the issue, as well as another unrelated issue. I wanted to give
you a heads up, and I also want to get your opinion an having a main and backup ORC
on an inactive system. Let me know what you think or if you have any more questions.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 92

W00003924emails19
From: Saunders, Erickson G
Sent: Wednesday, September 05, 2018 3:49 PM
To: Buffington, Beth <[e-mail] <mailto:[e-mail]>
Subject: RE: ORC Status for W00011655 and W00005173
Mr. Medford is the camp ranger who signed the application and his personal email is
given as [e-mail] <madlto:[e-mail]> . The phone is (252)
947-0008, though I'm unsure if that's his personal phone number. As for the other,
the permittees contact information is [phone] and [e-mail]
<mailto:[e-mail]> . Mr. Cannon's personal contact information is given as
[e-mail] <mailto:[e-mail]> and [phone]
as his work number.
Thanks for looking into this, and I have another quick question. I have another
permit (W00003924) which doesn't currently utilize their facility (but it's built),
and only has one ORC. Is this an issue that would require them to get a backup ORC?
Thanks again for any help you might be able to give and sorry for throwing it all on
you at once!
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 93
W00003924emailsl9
Beth Buffington
Environmental Specialist II, NC Operator Certification Program
Division of Water Resources, Dept of Environmental Quality
1618 Mail Service Center, Raleigh NC 27699-1618
PH: 919-707-9185 FX: 919-715-2726
http://deq.nc.gov/about/divisions/water-resources/operator-certification
<http://deq.nc.gov/about/divisions/water-resources/operator-certification>
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: Saunders, Erickson G
Sent: Wednesday, September 5, 2018 10:52 AM
To: Buffington, Beth <[e-mail] <mailto:[e-mail]>
Subject: ORC Status for W00011655 and W00005173
Hey Beth,
W00003924emailsl9
From: Buffington, Beth
Sent: Wednesday, September 05, 2018 3:38 PM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: RE: ORC Status for W00011655 and W00005173
Hey Erick,
About W00005173 and Roy Cannon. This one is a bit of a mess. I'm impressed that you
figured out his WW-2 has been invalid since 2012 for not paying his renewal fee.
This is probably way more than you want to know (I just said that in an email to
Emily), but both his WW-2 and his subsurface certification (SS) were invalidated in
early 2013. Once certificates are invalid for more than 2 years, they cannot be
renewed. An operator has to go back to a training school and retake the exam. That
$100 sitting out there in BINS should have been voided since he can't pay it.
Then he gets a PC-1 certificate in Dec of 2015, then doesn't renew it at the end of
2016 so that certificate goes invalid. He paid his renewal and late fee in early
February 2017 and we reinstated the PC-1. I think we also mistakenly reinstated his
long invalid SS certificate at the same time by mistake. Not really sure what to do
about that, but the bottom line is that he can't pay the $100 and renew his WW-2.
The owner may have another backup and just hasn't submitted an updated designation
form.
About WW0011655 and James Medford. He has only been invalid since the beginning of
this year so he does owe the $100.00 that BIMS is showing (and he owes us some
continuing ad). Do you have any information indicating he's still the ORC? If he is,
he needs to get his certificate reinstated. If not, the facility needs to designate
a new ORC.
I'll be glad to email or call both facilities and find out what's up. Do you have
current contacts and info?
Thanks, Beth
Page 94
W00003924emailsl9
and I noticed that two of them had an invalid ORC.
The first one is the backup ORC for W00005173, and the operator is Roy T. Cannon.
His WW-2 certificate #24019 is invalid, and it looks like he's $100 overdue for a
certification renewal in 2012. That may be why he's invalid as a WW-2 operator, but
I'm new so I'm not that knowledgeable about ORC stuff yet.
The second one is the main ORC for W0001165, James N. Medford. His SI certification
#995478 is also invalid, and he's also $100 overdue for a certification renewal this
year. That's probably also why but could you check just so I know and can get to
them about it?
Thanks in advance for any help you can give,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, January 28, 2019 1:00 PM
To: Buffington, Beth
Subject: RE: ORC Status for W00003924
Thanks Beth,
I was reviewing a few wastewater irrigation and high rate infiltration facilities
Page 95 Page 96

W00003924emailsl9
They are in the process of getting the permit rescinded and getting a lagoon
closure, but first the permit has to go into their name. Their contact is Perry
Keister. His contact email is [e-mail] <mailto:[e-mail]> . His
phone is (828)-638-5032.
Erick Saunders
Departmert of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Buffington, Beth
Sent: Monday, January 28, 2019 12:51 PM
To: Saunders, Erickson G <[e-mail]>
Subject: RE: ORC Status for W00003924
Eric,
I'm sorry I haven't gotten back to you on this. I don't recall anyone contacting me
I'll be glad to email or send them a letter telling them they have to designate if
you can give me the best contact information.
There is nothing in the operator rules that provides any kind of variance for
designating both an ORC and a Backup, even if there is no spray irrigation going on.
The only thing that can be modified is the minimum frequency of ORC visitation. Our
rules allow for alternate visitation to be established in the permit via a
modification. The only way for them to get out of designating both an ORC and Backup
Page 97
W00003924emailsl9
To: Buffington, Beth <[e-mail] <mailto:[e-mail]>
Subject: ORC Status for W00003924
Importance: High
Beth,
I sent you an email some months back about a permit where the wastewater facility is
inactive, and the system had only one ORC. It's been out for additional information
for a while because there was a change of ownership during the permit cycle which I
did an additional information request for. In that additional information request, I
asked the new owners to contact you about this ORC issue. We recently got the
additional information back, but we didn't hear anything about if they contacted you
about the ORC situation. What's more is that the region says that the only current
ORC (Lynn Aldridge) no longer works on the system because of something to do with
the old owners not paying.
I'm doing a new additional information request for this one essentially asking them
to contact you about the issue, as well as another unrelated issue. I wanted to give
you a heads up, and I also want to get your opinion on having a main and backup ORC
on an inactive system. Let me know what you think or if you have any more questions.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
W00003924emails19
is to close the lagoon and have the.permit rescinded.
Thanks and let me know if you want me to contact them.
Beth
Beth Buffington
Environmental Specialist II, NC operator Certification Program
Division of Water Resources, Dept of Environmental Quality
1618 Mail Service Center, Raleigh NC 27699-1618
PH: 919-707-9105 FX: 919-715-2726
http://deq.nc.gov/about/divisions/water-resources/operator-certification
<http://deq.nc.gov/about/divisions/water-resources/operator-certification>
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: Saunders, Erickson G
Sent: Monday, January 28, 2019 12:28 PM
Page 98
W00003924emailsl9
From: Saunders, Erickson G
Sent: Wednesday, September 05, 2818 3:49 PM
To: Buffington, Beth <[e-mail] <mailto:[e-mail]>
>
Subject: RE: ORC Status for W00011655 and W00005173
Mr. Medford is the camp ranger who signed the application and his personal email is
given as [e-mail] <mailto:[e-mail]> . The phone is (252)
947-0008, though I'm unsure if that's his personal phone number. As for the other,
the permittees contact information is [phone] and [e-mail]
<mailto:[e-mail]> . Mr. Cannon's personal contact information is given as
[e-mail] <mailto:[e-mail]> and [phone]
as his work number.
Thanks for looking into this, and I have another quick question. I have another
permit (W00003924) which doesn't currently utilize their facility (but it's built),
and only has one ORC. Is this an issue that would require them to get a backup ORC?
Thanks again for any help you might be able to give and sorry for throwing it all on
you at once!
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 99 Page 100

W00003924emailsl9
From: Buffington, Beth
Sent: Wednesday, September 65, 2018 3:38 PM
To: Saunders, Erickson G <Erickson. Saunders@ncdenr. gov
<mailto:[e-mail]> >
Subject: RE: ORC Status for W00011655 and W00005173
Hey Erick,
About W00005173 and Roy Cannon. This one is a bit of a mess. I'm impressed that you
figured out his WW-2 has been invalid since 2012 for not paying his renewal fee.
This is probably way more than you want to know (I just said that in an email to
Emily), but both his WW-2 and his subsurface certification (55) were invalidated in
early 2013. Once certificates are invalid for more than 2 years, they cannot be
renewed. An operator has to go back to a training school and retake the exam. That
$100 sitting out there in BIMS should have been voided since he can't pay it.
Then he gets a PC-1 certificate in Dec of 2015, then doesn't renew it at the end of
2016 so that certificate goes invalid. He paid his renewal and late fee in early
February 2017 and we reinstated the PC-1. I think we also mistakenly reinstated his
long invalid SS certificate at the same time by mistake. Not really sure what to do
about that, but the bottom line is that he can't pay the $100 and renew his WW-2.
The owner may have another backup and just hasn't submitted an updated designation
form.
About WWO011655 and James Medford. He has only been invalid since the beginning of
this year so he does owe the $100.00 that BIMS is showing (and he owes us some
continuing ed). Do you have any information indicating he's still the ORC? If he is,
he needs to get his certificate reinstated. If not, the facility needs to designate
a new ORC.
I'll be glad to email or call both facilities and find out what's up. Do you have
current contacts and info?
Page 101
W00003924emailsl9
I was reviewing a few wastewater irrigation and high rate infiltration facilities
and I noticed that two of them had an invalid ORC.
The first one is the backup ORC for W00005173, and the operator is Roy T. Cannon.
His WW-2 certificate m24019 is invalid, and it looks like he's $100 overdue for a
certification renewal in 2012. That may be why he's invalid as a WW-2 operator, but
I'm new so I'm not that knowledgeable about ORC stuff yet.
The second one is the main ORC for W0001165, lames N. Medford. His SI certification
#995478 is also invalid, and he's also $100 overdue for a certification renewal this
year. That's probably also why but could you check just so I know and can get to
them about it?
Thanks in advance for any help you can give,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
(919) 707-36S9 Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Monday, January 28, 2019 2:30 PM
To: Saunders, Erickson G
Cc: Thornburg, Nathaniel; Watson, Edward M; Buffington, Beth
Subject: [External] Re: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify.
Page 103
W00003924emailsl9
Thanks, Beth
Beth Buffington
Environmental Specialist II, NC Operator Certification Program
Division of Water Resources, Dept of Environmental Quality
1618 Mail Service Center, Raleigh NC 27699-1618
PH: 919-707-9105 FX: 919-715-2726
http://deq.nc.gov/about/divisions/water-resources/operator-certification
<http://deq.nc.gov/about/divisions/water-resources/operator-certification>
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: Saunders, Erickson G
Sent: Wednesday, September 5, 2018 10:52 AM
To: Buffington, Beth <[e-mail] <mailto:[e-mail]>
Subject: ORC Status for W00011655 and W00005173
Hey Beth,
Page 102
W00003924emailsl9
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Thank you
Perry Keister
Consulting
On ]an 28, 2019, at 12:50 PM, Saunders, Erickson G <[e-mail]
<mallto:[e-mail]> > wrote:
Perry,
Thanks for the submission last Friday. I was out in the field on a last
minute site visit so I may have missed if you called. We are accepting the response
and will not issue an NOV at this time. However, we are sending a second additional
information request to get the Certificate of Assumed Name filed in the Lincoln
County Register of Deeds and to get the ORC situation sorted out. our systems
require one main ORC and another backup ORC according to 15A NCAC 08G .0201. This
system did not have a backup ORC at the time of permitting, and the region has
indicated that Lynn Aldridge no longer serves the system. Beth Buffington of the
Wastewater Operator Certification group should be the person to contact about this.
It would be up to her to see how this should be handled.
This additional information request is going to be a bit more strict. If we
don't receive these items before the expiration date of February 27, 2019, then we
will rescind the application and issue an NOV to LINCO. If you have any questions,
don't hesitate to contact me.
Thanks you,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Page 104

W00003924emailsl9 W00003924emailsl9
Water Quality Permitting The signature authority designation letter is what we discussed on the
phone. Get one of the majority shareholders of Linco to sign it so that you may
become an appropriate signing official.
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Friday, January 25, 2019 10:15 AM
To: Saunders, Erickson G ([e-mail]
<mailto:[e-mail]> >
Subject: [External] RE: WQ0003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
I am waiting on copy of the deed and register of deed info
<image003.pn6>
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Wednesday, January 23, 2019 1:57 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: FW: WQ0003924 Additional Information Request
Page 105
W00003924emailsl9
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
4W00003924ai190129.pdf>
From: Perry Keister <[e-mail]>
Sent: Tuesday, January 29, 2019 10:05 AM
To: Saunders, Erickson G
Subject: [External] FW: W00003924 Additional Information Request 2
Attachments: 00110001.pdf
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
Will this suffice on missing documentation and I have reached out to Beth concerning
ORC
From: [e-mail] <[e-mail]>
Sent: Tuesday, January 29, 2019 10:01 AM
To: 'Perry Keister' ([e-mail]>
Page 107
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail] <mailto:[e-mail]> ' <[e-mail]
<mailtc:[e-mail]> >; '[e-mail] <mailto:[e-mail]>
<[e-mail] <mailto:[e-mail]> )
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP
Holdings, LLC to LINCO Partnership. This additional information request is at to
address this ownership change, as well as other issues. I have included the formal
additional information request in this email, along with a few other documents that
have already been partially filled out that you will need to execute. I'm also
sending a physical copy to the mailing address that the regional inspector gave me
which is 5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister,
but I don't have a mailing address for him specifically. If this address is
incorrect, please tell me and I can resend it.
Page 106
W00003924emailsl9
Subject: RE: W00003924 Additional Information Request 2
Please see attached.
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 8:48 AM
To: [e-mail] <mailto:[e-mail]>
Subject: FW: W00003924 Additional Information Request 2
Would you look at part A of the attached, I need a bit of help with that. I will
contact about ORC
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Monday, January 2B, 2019 12:50 PM
To: Perry Keister <[e-mail] <mailtc:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:nathan iel. [e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Buffington, Beth
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request 2
Perry,
Thanks for the submission last Friday. I was out in the field on a last minute site
visit so I may have missed if you called. We are accepting the response and will not
Page 108

w00003924emailsl9
issue an NOV at this time. However, we are sending a second additional information
request to get the Certificate of Assumed Name filed in the Lincoln County Register
of Deeds and to get the ORC situation sorted out. Our systems require one main ORC
and another backup ORC according to 15A NCAC 98G .0201. This system did not have a
backup ORC at the time of permitting, and the region has indicated that Lynn
Aldridge no longer serves the system. Beth Buffington of the Wastewater Operator
Certification group should be the person to contact about this. It would be up to
her to see how this should be handled.
This additional information request is going to be a bit more strict. If we don't
receive these items before the expiration date of February 27, 2019, then we will
rescind the application and issue an NOV to LINCO. If you have any questions, don't
hesitate to contact me.
Thanks you,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Friday, January 25, 2019 10:15 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] RE: W00003924 Additional Information Request
Page 109
WQ0003924emailsl9
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail]' <[e-mail] <mailto:[e-mail]> >;
'[e-mail]' <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP Holdings,
LLC to LINGO Partnership. This additional information request is set to address this
ownership change, as well as other issues. I have included the formal additional
information request in this email, along with a few other documents that have
already been partially filled out that you will need to execute. I'm also sending a
physical copy to the mailing address that the regional inspector gave me which is
5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister, but I
don't have a mailing address for him specifically. If this address is incorrect,
please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
W00003924emailsl9
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
I am waiting on copy of the deed and register of deed info
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Wednesday, January 23, 2019 1:57 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: FW: WQ0003924 Additional Information Request
The signature authority designation letter is what we discussed on the phone. Get
one of the majority shareholders of Linco to sign it so that you may become an
appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 110
W00003924emailsl9
From: Saunders, Erickson G
Sent: Tuesday, January 29, 2019 11:23 AM
To: Perry Keister
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Perry,
What we want to see is that your Partnership is registered to do business in the
county/state. I've been researching this for the better part of the morning and it
looks like the Certificate of Assumed Name might not be the only form you'll need
(if you need it at all). you may have to register your partnership in the NC
Secretary of State as well.
According to this
<https://www.ncleg.net/EnactedLegislation/Statutes/PDF/ByArtiCle/Chapter_66/Article_
14A.pdf> general statute, you must file an assumed business name certificate into
the office of the register of deeds of the county you will be engaged in business if
your business name is different than either the real names of the general partners,
or the name registered in the Secretary of State (SOS). This means that depending on
what kind of partnership this is, you will also have to register in the NC SOS. It
appears that limited liability partnerships (LLPs) and limited partnerships (LPs)
have to registered with the secretary of state (refer to § 66-71.3. of the general
statute). This
<https://www.sosnc.gov/Guides/register_a_foreign_business/requirements> link may be
helpful if you are looking for information on the Secretary of State's requirements.
So just to clarify, if LINCO is an LLP or an LP, then you must register with the
SOS. For this case, if your assumed business name is different than what is on the
SOS, then an assumed business name certificate will have to be registered in the
Lincoln County Register of Deeds (ROD). If the assumed business name is the same,
then documentation that you have registered to the SOS is adequate. If LINCO is not
an LP or LLP, then you will only have to register the assumed business name
certificate in the Lincoln ROD.
I'm sorry for not getting this clarified earlier, all this legal stuff can be a
Page Ill
Page 112

W00003924emailsl9
little much for my math oriented mind. If you have any questions, I'll be in the
office until S. I'm aiming to go to lunch at around 12 today so I might not be back
until 1.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Tuesday, January 29, 2019 10:05 AM
To: Saunders, Erickson G <[e-mail]>
Subject: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
Will this suffice on missing documentation and I have reached out to Beth concerning
ORC
Page 113
W00003924emails19
Thanks for the submission last Friday. I was out in the field on a last minute site
visit so I may have missed if you called. We are accepting the response and will not
issue an NOV at this time. However, we are sending a second additional information
request to get the Certificate of Assumed Name filed in the Lincoln County Register
of Deeds and to get the ORC situation sorted out. Our systems require one main ORC
and another backup ORC according to 15A NCAC 08G .0201. This system did not have a
backup ORC at the time of permitting, and the region has indicated that Lynn
Aldridge no longer serves the system. Beth Buffington of the Wastewater Operator
Certification group should be the person to contact about this. It would be up to
her to see how this should be handled.
This additional information request is going to be a bit more strict. If we don't
receive these items before the expiration date of February 27, 2019, then we will
rescind the application and issue an NOV to LINCO. If you have any questions, don't
hesitate to contact me.
Thanks you,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Friday, January 25, 2019 10:15 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
W00003924emailsl9
From: [e-mail] <mailto:[e-mail]> <[e-mail]
<mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:01 AM
To: 'Perry Keister' <[e-mail] <mailto:[e-mail]> >
Subject: RE: W00003924 Additional Information Request 2
Please see attached.
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 8:48 AM To: [e-mail] <mailto:[e-mail]>
Subject: FW: W00003924 Additional Information Request 2
Would you look at part A of the attached, I need a bit of help with that. I will
contact about ORC
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Monday, January 28, 2019 12:50 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Buffington, Beth
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request 2
Perry,
Page 114
W00003924emailsl9
Subject: [External] RE: W00003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
I am waiting on copy of the deed and register of deed info
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Wednesday, January 23, 2019 1:57 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: FW: W00003924 Additional Information Request
The signature authority designation letter is what we discussed on the phone. Get
one of the majority shareholders of Linco to sign it so that you may become an
appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
Page 115 Page 116

WQ0003924emails19
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail]' <[e-mail] <mailto:[e-mail]> >;
' [e-mail]' <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP Holdings,
LLC to LINCO Partnership. This additional information request is set to address this
ownership change, as well as other issues. I have included the formal additional
information request in this email, along with a few other documents that have
already been partially filled out that you will need to execute. I'm also sending a
physical copy to the mailing address that the regional inspector gave me which is
5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister, but I
don't have a mailing address for him specifically. If this address is incorrect,
please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
Page 117
W00003924emails1
9
appears that limited liability partnerships (LLPs) and limited partnerships (LPs)
have to registered with the secretary of state (refer to § 66-71.3. of the general
statute). This
<https://www.sosnc.gov/Guides/register_a_foreign business/requirements> link may be
helpful if you are looking for information on the Secretary of State's requirements.
So just to clarify, if LINCO is an LLP or an LP, then you must register with the
SoS. For this case, if your assumed business name is different than what is on the
SoS, then an assumed business name certificate will have to be registered in the
Lincoln County Register of Deeds (RoD). If the assumed business name is the same,
then documentation that you have registered to the SoS is adequate. If LINCO is not
an LP or LLP, then you will only have to register the assumed business name
certificate in the Lincoln ROD.
I'm sorry for not getting this clarified earlier, all this legal stuff can be a
little much for my math oriented mind. If you have any questions, I'll be in the
office until S. I'm aiming to go to lunch at around 12 today so I might not be back
until 1.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
W00003924emailsl9
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Tuesday, January 29, 2019 11:26 AM
To: Saunders, Erickson G
Subject: RE: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to report. [e-mail]
<mailto:[e-mail]>
Have Teresa working on it with her legal beagles
From: Saunders, Erickson G <[e-mail]>
Sent: Tuesday, January 29, 2019 11:23 AM
To: Perry Keister <[e-mail]>
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Perry,
What we want to see is that your Partnership is registered to do business in the
county/state. I've been researching this for the better part of the morning and it
looks like the Certificate of Assumed Name might not be the only form you'll need
(if you need it at all). You may have to register your partnership in the NC
Secretary of State as well.
According to this
<https://www.ncleg.net/EnactedLegislation/Statutes/PDF/ByArticle/Chapter_66/Article_
14A.pdf> general statute, you must file an assumed business name certificate into
the office of the register of deeds of the county you will be engaged in business if
your business name is different than either the real names of the general partners,
or the name registered in the Secretary of State (SoS). This means that depending on
what kind of partnership this is, you will also have to register in the NC SoS. It
Page 118
W00003924emailsl9
From: Perry Keister <[e-mail] cmailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:05 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] FW: W00093924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
Will this suffice on missing documentation and I have reached out to Beth concerning
ORC
From: [e-mail] <mailto:[e-mail]> <[e-mail]
<mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:01 AM
To: 'Perry Keister' <[e-mail] <mailto:[e-mail]> >
Subject: RE: W00003924 Additional Information Request 2
Please see attached.
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 8:48 AM
To: [e-mail] <mailto:[e-mail]>
Subject: FW: W00003924 Additional Information Request 2
Page 119 Page 120

W00003924emailsl9
Would you look at part A of the attached, I need a bit of help with that. I will
contact about ORC
From: Saunders, Erickson G ([e-mail]
<mailto:[e-mail]> >
Sent: Monday, January 28, 2019 12:50 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Buffington, Beth
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request 2
Perry,
Thanks for the submission last Friday. I was out in the field on a last minute site
visit so I may have missed if you called. We are accepting the response and will not
issue an NOV at this time. However, we are sending a second additional information
request to get the Certificate of Assumed Name filed in the Lincoln County Register
of Deeds and to get the ORC situation sorted out. Our systems require one main ORC
and another backup ORC according to 15A NCAC 08G .0201. This system did not have a
backup ORC at the time of permitting, and the region has indicated that Lynn
Aldridge no longer serves the system. Beth Buffington of the Wastewater Operator
Certification group should be the person to contact about this. It would be up to
her to see how this should be handled.
This additional information request is going to be a bit more strict. If we don't
receive these items before the expiration date of February 27, 2019, then we will
rescind the application and issue an NOV to LINCO. If you have any questions, don't
hesitate to contact me.
Thanks you,
Erick Saunders
Page 121
WQ0003924emailsl9
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: FW: WQ0003924 Additional Information Request
The signature authority designation letter is what we discussed on the phone. Get
one of the majority shareholders of Linco to sign it so that you may become an
appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail]' <[e-mail] <mailto:[e-mail]> >;
'[e-mail]' <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP Holdings,
LLC to LINCO Partnership. This additional information request is set to address this
ownership change, as well as other issues. I have included the formal additional
information request in this email, along with a few other documents that have
already been partially filled out that you will need to execute. I'm also sending a
physical copy to the mailing address that the regional inspector gave me which is
5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister, but I
Page 123
W00003924emailsl9
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Friday, January 25, 2019 10:15 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] RE: W00003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
I am waiting an copy of the deed and register of deed info
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Wednesday, January 23, 2019 1:57 PM
Page 122
WQ0003924emailsl9
don't have a mailing address for him specifically. If this address is incorrect,
please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Buffington, Beth
Sent: Wednesday, January 30, 2019 1:13 PM
To: Perry Keister
Cc: Saunders, Erickson G
Subject: RE: [External] Linco, Lincolnton NC
Attachments: _ W00003924 Designation Form.pdf; Contract Operator List 1-30-2019.pdf
Hello Perry,
As required by NCAC 15A 8G .0201 and your permit, you must designate one Operator in
Responsible Charge (ORC) and at least one Back-up ORC for this facility. Both the
ORC and Backup ORC(s) must hold active Surface Irrigation certificates.
When there are vacancies in both ORC and Back-up ORC positions, the rule also
requires the permittee to designate one of these positions within seven days. Please
Page 124

WQB003924emailsl9
return the attached designation form to me (preferably by email) by February 6th. If
only one position is designated at that time, please complete and return an updated
form designating appropriately certified operators in both positions by February
28th.
I have attached a list of contract operators as you requested. You need to look for
operators or operations firms that have the code "SI" (for surface irrigation) and
that service the county in which the facility is located.
Please let me know if you have any questions about the designation requirement or
the contract operators list.
Thanks,
Beth Buffington
Environmental Specialist II, NC Operator Certification Program
Division of Water Resources, Dept of Environmental Quality
1618 Mail Service Center, Raleigh NC 27699-1618
PH: 919-707-9105 FX: 919-715-2726
http://deq.nc.gov/about/divisions/water-resources/operator-certification
<http://d.q.nc.gov/about/divisions/water-resources/operator-certification>
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.
Page 125
w00003924emai1s19
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Tuesday, January 29, 2019 11:26 AM
To: Saunders, Erickson G <[e-mail]>
Subject: RE: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Have Teresa working on it with her legal beagles
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 11:23 AM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Perry,
W00003924emailsl9
From: Perry Keister [mailto:[e-mail]]
Sent: Tuesday, Ianuary 29, 2019 9:49 AM
To: Buffington, Beth <[e-mail]>; Saunders, Erickson G
<[e-mail]>
Subject: [External] Linco, Lincolnton NC
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Beth
Do you have a list of active ORC for our permit type at Linco?
Spray field
From: Saunders, Erickson G
Sent: Monday, February 18, 2019 9:17 AM
To: 'Perry Keister'
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Perry,
I know you've gotten into contact with Beth but I just wanted to get a status update
for the second additional information request and remind you that it is due in 9
days on February 27th.
Thanks,
Erick Saunders
Page 126
W00003924emails19
(if you need it at all). You may have to register your partnership in the NC
Secretary of State as well.
According to this
<https://www.ncleg.net/EnactedLegislation/Statutes/PDF/ByArticle/Chapter_66/Article_
14A.pdf> general statute, you must file an assumed business name certificate into
the office of the register of deeds of the county you will be engaged in business if
your business name is different than either the real names of the general partners,
or the name registered in the Secretary of State (SoS). This means that depending on
what kind of partnership this is, you will also have to register in the NC SoS. It
appears that limited liability partnerships (LLPs) and limited partnerships (LPs)
have to registered with the secretary of state (refer to § 66-71.3. of the general
statute). This
<https://www.sasnc.gov/Guides/register_a_Foreign_business/requirements> link may be
helpful if you are looking for information on the Secretary of State's requirements.
So just to clarify, if LINCO is an LLP or an LP, then you must register with the
SoS. For this case, if your assumed business name is different than what is on the
SoS, then an assumed business name certificate will have to be registered in the
Lincoln County Register of Deeds (RoD). If the assumed business name is the same,
then documentation that you have registered to the SoS is adequate. If LINCO is not
an LP or LLP, then you will only have to register the assumed business name
certificate in the Lincoln RoD.
I'm sorry for not getting this clarified earlier, all this legal stuff can be a
little much for my math oriented mind. If you have any questions, I'll be in the
office until S. I'm aiming to go to lunch at around 12 today so I might not be back
until 1.
Thanks,
Erick Saunders
Department of Environmental Quality
What we want to see is that your Partnership is registered to do business in the
county/state. I've been researching this for the better part of the morning and it Division of Water Resources
looks like the Certificate of Assumed Name might not be the only form you'll need
Page 127
Page 128

W00003924emailsl9
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:05 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify
Send all suspicious email as an attachment to report.spa*nc.gov
<mailto: report. [e-mail]>
Erickson
Will this suffice on missing documentation and I have reached out to Beth concerning
ORC
From: [e-mail] <mailto:[e-mail]> <[e-mail]
<mailto: teresa@buckinvest. com> >
Sent: Tuesday, January 29, 2019 10:01 AM
To: 'Perry Keister' <[e-mail] <mailto:[e-mail]> >
Subject: RE: W00003924 Additional Information Request 2
Please see attached.
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
Page 129
W00003924emailsl9
This additional information request is going to be a bit more strict. If we don't
receive these items before the expiration date of February 27, 2019, then we will
rescind the application and issue an NOV to LINGO. If you have any questions, don't
hesitate to contact me.
Thanks you,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Friday, January 25, 2019 10:15 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] RE: W00003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
I am waiting on copy of the deed and register of deed info
W00003924emailsl9
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 9:49 AM
To: [e-mail] <mailto:[e-mail]>
Subject: FW: W00003924 Additional Information Request 2
Would you look at part A of the attached, I need a bit of help with that. I will
contact about ORC
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Monday, January 28, 2019 12:50 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Buffington, Beth
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request 2
Perry,
Thanks for the submission last Friday. I was out in the field on a last minute site
visit so I may have missed if you called. We are accepting the response and will not
issue an NOV at this time. However, we are sending a second additional information
request to get the Certificate of Assumed Name filed in the Lincoln County Register
of Deeds and to get the ORC situation sorted out. Our systems require one main ORC
and another backup ORC according to 1SA NCAC 08G .0201. This system did not have a
backup ORC at the time of permitting, and the region has indicated that Lynn
Aldridge no longer serves the system. Beth Buffington of the Wastewater Operator
Certification group should be the person to contact about this. It would be up to
her to see how this should be handled.
Page 130
W00003924emailsl9
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Wednesday, January 23, 2019 1:57 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: FW: W00003924 Additional Information Request
The signature authority designation letter is what we discussed on the phone. Get
one of the majority shareholders of Linco to sign it so that you may become an
appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail]' <[e-mail] <mailto:[e-mail]> >;
'[e-mail]' <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
Page 131 Page 132

W00003924emailsl9
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP Holdings,
LLC to LINGO Partnership. This additional information request is set to address this
ownership change, as well as other issues. I have included the formal additional
information request in this email, along with a few other documents that have
already been partially filled out that you will need to execute. I'm also sending a
physical copy to the mailing address that the regional inspector gave me which is
5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister, but I
don't have a mailing address for him specifically. If this address is incorrect,
please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] cmailto:[e-mail]>
From: Saunders, Erickson G
Sent: Friday, March 01, 2019 10:05 AM
To: Perry Keister
Cc: Thornburg, Nathaniel; Watson, Edward M
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Perry,
Page 133
W00003924emails19
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality_Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 11:26 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
5ubject: RE: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Have Teresa working on it with her legal beagles
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 11:23 AM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
w00003924emails19
The additional information request is now 2 days overdue. Please respond to this
email with a status update for the additional information response. We are preparing
an application return letter and if we do not hear from you by the end of next
Monday, we will proceed with returning the application which will be followed by
issuing you a Notice of Violation (NOV).
Regards,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, February 18, 2019 9:17 AM
To: 'Perry Keister' <[e-mail]>
Subject: RE: [External] FW: WQ0003924 Additional Information Request 2
Perry,
I know you've gotten into contact with Beth but I just wanted to get a status update
for the second additional information request and remind you that it is due in 9
days on February 27th.
Page 134
wQee63924emailsl9
Perry,
What we want to see is that your Partnership is registered to do business in the
county/state. I've been researching this for the better part of the morning and it
looks like the Certificate of Assumed Name might not be the only form you'll need
(if you need it at all). You may have to register your partnership in the NC
Secretary of State as well.
According to this
<https://www.ncleg.net/EnactedLegislation/Statutes/PDF/ByArticle/Chapter_66/Article_
14A.pdf> general statute, you must file an assumed business name certificate into
the office of the register of deeds of the county you will be engaged in business if
your business name is different than either the real names of the general partners,
or the name registered in the Secretary of State (SoS). This means that depending on
what kind of partnership this is, you will also have to register in the NC SoS. It
appears that limited liability partnerships (LLPs) and limited partnerships (LPs)
have to registered with the secretary of state (refer to § 66-71.3. of the general
statute). This
<https://www.sosnc.gov/Guides/register_ a_foreign—business/requirements) link may be
helpful if you are looking for information on the Secretary of State's requirements.
So just to clarify, if LINGO is an LLP or an LP, then you must register with the
SOS. For this case, if your assumed business name is different than what is on the
SOS, then an assumed business name certificate will have to be registered in the
Lincoln County Register of Deeds (RoD). If the assumed business name is the same,
then documentation that you have registered to the SoS is adequate. If LINCO is not
an LP or LLP, then you will only have to register the assumed business name
certificate in the Lincoln RoD.
I'm sorry for not getting this clarified earlier, all this legal stuff can be a
little much for my math oriented mind. If you have any questions, I'll be in the
office until 5. I'm aiming to go to lunch at around 12 today so I might not be back
until 1.
Thanks,
Page 135 Page 136

W00003924emailsl9
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:05 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
Will this suffice on missing documentation and I have reached out to Beth concerning
ORC
From: [e-mail] <mailto:[e-mail]> <[e-mail]
<mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:01 AM
To: 'Perry Keister' <[e-mail] <mailto:[e-mail]> >
Subject: RE: W00003924 Additional Information Request 2
Page 137
W00003924emailsl9
of Deeds and to get the ORC situation sorted out. Our systems require onmain ORC
and another backup ORC according to 15A NCAC 08G .ml. This system did not have a
backup ORC at the time of permitting, and the region has indicated that Lynn
Aldridge no longer serves the system. Beth Buffington of the Wastewater Operator
Certification group should be the person to contact about this. It would be up to
her to see how this should be handled.
This additional information request is going to be a bit more strict. If we don't
receive these items before the expiration date of February 27, 2019, then we will
rescind the application and issue an NOV to LINCO. If you have any questions, don't
hesitate to contact me.
Thanks you,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Friday, January 25, 2019 10:15 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] RE: W00003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
Page 139
W00003924emailsl9
Please see attached.
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 8:49 AM
To: [e-mail] <mailto:[e-mail]>
Subject: FW: W00003924 Additional Information Request 2
Would you look at part A of the attached, I need a bit of help with that. I will
contact about ORC
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Monday, January 29, 2019 12:50 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Buffington, Beth
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request 2
Perry,
Thanks for the submission last Friday. I was out in the field on a last minute site
visit so I may have missed if you called. We are accepting the response and will not
issue an NOV at this time. However, we are sending a second additional information
request to get the Certificate of Assumed Name filed in the Lincoln County Register
Page 138
W00003924emails19
<mailto:[e-mail]>
Erickson
I am waiting on copy of the deed and register of deed info
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Wednesday, January 23, 2019 1:S7 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: FW: WQ0603924 Additional Information Request
The signature authority designation letter is what we discussed on the phone. Get
one of the majority shareholders of Linco to sign it so that you may become an
appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 140

W00003924emailsl9
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail]' <[e-mail] <mailto:[e-mail]> >;
'[e-mail]' <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP Holdings,
LLC to LINCO Partnership. This additional information request is set to address this
ownership change, as well as other issues. I have included the formal additional
information request in this email, along with a few other documents that have
already been partially filled out that you will need to execute. I'm also sending a
physical copy to the mailing address that the regional inspector gave me which is
5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister, but I
don't have a mailing address for him specifically. If this address is incorrect,
please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 141
W00003924emailsl9
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, February 18, 2019 9:17 AM
To: 'Perry Keister' <[e-mail] <mailto:[e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Perry,
I know you've gotten into contact with Beth but I just wanted to get a
status update for the second additional information request and remind you that it
is due in 9 days on February 27th.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
W00003924emailsl9
From: Perry Keister <[e-mail]>
Sent: Friday, March 01, 2019 11:01 AM
To: Saunders, Erickson G
Subject: Re: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto: report. [e-mail]>
I have ask linco lawyer to get the info as they have told me they are a GP in TN
He is suppose to be reaching out to you to gather what to do on corporate side as
this is past my pay grade of understanding.
Perry Keister
Consulting
On Mar 1, 2019, at 10:04 AM, Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> > wrote:
Perry,
The additional information request is now 2 days overdue. Please respond to
this email with a status update for the additional information response. We are
preparing an application return letter and if we do not hear from you by the end of
next Monday, we will proceed with returning the application which will be followed
by issuing you a Notice of Violation (NOV).
Regards,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
Page 142
W00003924emailsl9
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 11:26 AM
To: Saunders, Erickson G <[e-mail]
<mailto: [e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto: [e-mail]>
Have Teresa working on it with her legal beagles
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 11:23 AM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Perry,
What we want to see is that your Partnership is registered to do business in
the county/state. I've been researching this for the better part of the morning and
it looks like the Certificate of Assumed Name might not be the only form you'll need
(if you need it at all). You may have to register your partnership in the NC
Secretary of State as well.
According to this
<https://www.ncleg.net/EnactedLegislation/Statutes/PDF/ByArticle/Chapter_66/Article_
14A.pdf> general statute, you must file an assumed business name certificate into
the office of the register of deeds of the county you will be engaged in business if
your business name is different than either the real names of the general partners,
or the name registered in the Secretary of State (So5). This means that depending on
what kind of partnership this is, you will also have to register in the NC SoS. It
appears that limited liability partnerships (LLPs) and limited partnerships (LPs)
Page 143 Page 144

W00003924emailsl9
have to registered With the secretary of state (refer to § 66-71.3. of the general
statute). This
<https://www.sosnc.gov/Guides/register_a_foreign_business/requirements) link may be
helpful if you are looking for information on the Secretary of State's requirements.
So just to clarify, if LINCO is an LLP or an LP, then you must register with
the 505. For this case, if your assumed business name is different than what is on
the SOS, then an assumed business name certificate will have to be registered in the
Lincoln County Register of Deeds (ROD). If the assumed business name is the same,
then documentation that you have registered to the SOS is adequate. If LINGO is not
an LP or LLP, then you will only have to register the assumed business name
certificate in the Lincoln ROD.
I'm sorry for not getting this clarified earlier, all this legal stuff can
be a little much for my math oriented mind. If you have any questions, I'll be in
the office until S. I'm aiming to go to lunch at around 12 today so I might not be
back until 1.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Page 145
WQ0003924emailsl9
Would you look at part A of the attached, I need a bit of help with that. I
will contact about ORC
From: Saunders, Erickson G <[e-mail]
(mailto: Erickson. Saunders@ncdeo r. gov> >
Sent: Monday, January 28, 2019 12:50 PM
To: Perry Keister ([e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<edward.waI [e-mail] <mailto:[e-mail]> >; Buffington, Beth
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request 2
Perry,
Thanks for the submission last Friday. I was out in the field on a last
minute site visit so I may have missed if you called. We are accepting the response
and will not issue an NOV at this time. However, we are sending a second additional
information request to get the Certificate of Assumed Name filed in the Lincoln
County Register of Deeds and to get the ORC situation sorted out. Our systems
require one main-ORC and another backup ORC according to 15A NCAC 08G .0201. This
system did not have a backup ORC at the time of permitting, and the region has
indicated that Lynn Aldridge no longer serves the system. Beth Buffington of the
Wastewater Operator Certification group should be the person to contact about this.
It would be up to her to see how this should be handled.
This additional information request is going to be a bit more strict. If we
don't receive these items before the expiration date of February 27, 2019, then we
will rescind the application and issue an NOV to LINCO. If you have any questions,
don't hesitate to contact me.
Thanks you,
Erick Saunders
Page 147
W00003924emailsl9
Sent: Tuesday, January 29, 2019 10:05 AM
To: Saunders, Erickson G < [e-mail]
<mailto:[e-mail]> >
Subject: [External] FW: WQB003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
Will this suffice on missing documentation and I have reached out to Beth
concerning ORC
From: [e-mail] <mailto:[e-mail]>
<[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:01 AM
To: 'Perry Keister' [e-mail] <mailto:[e-mail]> >
Subject: RE: W00003924 Additional Information Request 2
Please see attached.
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 8:48 AM
To: [e-mail] <mailto:[e-mail]>
Subject: FW: W00003924 Additional Information Request 2
Page 146
WQ0003924emailsl9
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Friday, January 2S, 2019 10:15 AM
To: Saunders, Erickson G ([e-mail]
<mailto:[e-mail]> >
Subject: [External] RE: W00003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
I am waiting on copy of the deed and register of deed info
<image001.png>
From: Saunders, Erickson G <[e-mail]
<mailto: [e-mail]> >
Sent: Wednesday, January 23, 2019 1:57 PM
TO: Perry Keister <[e-mail] <mailto:[e-mail]> >
Page 148

W00003924emailsl9
Subject: FW: W00003924 Additional Information Request
The signature authority designation letter is what we discussed an the
phone. Get one of the majority shareholders of Linco to sign it so that you may
become an appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: '[e-mail] <mailto:[e-mail]> ' <[e-mail]
<mailto:[e-mail]> >; '[e-mail] <mailto:[e-mail]>
<[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP
Holdings, LLC to LINCO Partnership. This additional information request is set to
address this ownership change, as well as other issues. I have included the formal
additional information request in this email, along with a few other documents that
have already been partially filled out that you will need to execute. I'm also
sending a physical copy to the mailing address that the regional inspector gave me
which is 5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister,
Page 149
WQe003924emails19
On Mar 1, 2019, at 10:04 AM, Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> > wrote:
Perry,
The additional information request is now 2 days overdue. Please respond to
this email with a status update for the additional information response. We are
preparing an application return letter and if we do not hear from you by the end of
next Monday, we will proceed with returning the application which will be followed
by issuing you a Notice of Violation (NOV).
Regards,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, February 18, 2019 9:17 AM
To: 'Perry Keister' <[e-mail] <mailto:[e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
W00003924emails19
but I don't have a mailing address for him specifically. If this address is
incorrect, please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Friday, March 61, 2019 11:03 AM
To: Saunders, Erickson G
Cc: Thornburg, Nathaniel; Watson, Edward M; [e-mail]
Subject: Re: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Ron has your reached out on the info the state has requested to clarify what we need
to do ?
See below
Perry Keister
Consulting
Page 150
W00003924emai1519
I know you've gotten into contact with Beth but I just wanted to get a
status update for the second additional information request and remind you that it
is due in 9 days on February 27th.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 11:26 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Have Teresa working on it with her legal beagles
Perry,
Page 151 Page 152

W00003924emails19
From: Saunders, Erickson G <[e-mail]
<mailto: Erickson. [e-mail]> >
Sent: Tuesday, January 29, 2019 11:23 AM
TO: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Perry,
What we want to see is that your Partnership is registered to do business in
the county/state. I've been researching this for the better part of the morning and
it looks like the Certificate of Assumed Name might not be the only form you'll need
(if you need it at all). you may have to register your partnership in the NC
Secretary of State as well.
According to this
<https://www.ncleg.net/Enacted Legislation/Statutes/PDF/ByArticle/Chapter_66/Article_
14A.pdf> general statute, you must file an assumed business name certificate into
the office of the register of deeds of the county you will be engaged in business if
your business name is different than either the real names of the general partners,
or the name registered in the Secretary of State (SoS). This means that depending on
what kind of partnership this is, you will also have to register in the NC SoS. It
appears that limited liability partnerships (LLPs) and limited partnerships (LPs)
have to registered with the secretary of state (refer to § 66-71.3. of the general
statute). This
<https://www.sosnc.gov/Guides/register_ a_ foreign_ business/requirements> link may be
helpful if you are looking for information on the Secretary of State's requirements.
So just to clarify, if LINGO is an Lip or an LP, then you must register with
the SoS. For this case, if your assumed business name is different than what is on
the SoS, then an assumed business name certificate will have to be registered in the
Lincoln County Register of Deeds (RoD). If the assumed business name is the same,
then documentation that you have registered to the SoS is adequate. If LINGO is not
an LP or Lip, then you will only have to register the assumed business name
certificate in the Lincoln RoD.
I'm sorry for not getting this clarified earlier, all this legal stuff can
be a little much for my math oriented mind. If you have any questions, I'll be in
Page 153
W00003924emails19
From: [e-mail] <mailto:[e-mail]>
<[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:01 AM
To: 'Perry Keister' <[e-mail] <mailto:[e-mail]> >
Subject: RE: W00003924 Additional Information Request 2
Please see attached.
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 8:48 AM
To: [e-mail] <mailto:[e-mail]>
Subject: FW: W00003924 Additional Information Request 2
Would you look at part A of the attached, I need a bit of help with that. I
will contact about ORC
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Monday, January 28, 2019 12:50 PM
To: Perry Keister ([e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Buffington, Beth
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request 2
Perry,
W00003924emails19
the office until S. I'm aiming to go to lunch at around 12 today so I might not be
back until 1.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister ([e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:05 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
Will this suffice on missing documentation and I have reached out to Beth
concerning ORC
Page 154
W00003924emailsl9
Thanks for the submission last Friday. I was out in the field on a last
minute site visit so I may have missed if you called. We are accepting the response
and will not issue an NOV at this time. However, we are sending a second additional
information request to get the Certificate of Assumed Name filed in the Lincoln
County Register of Deeds and to get the ORC situation sorted out. Our systems
require one main ORC and another backup ORC according to 15A NCAC 08G .0201. This
system did not have a backup ORC at the time of permitting, and the region has
indicated that Lynn Aldridge no longer serves the system. Beth Buffington of the
Wastewater Operator Certification group should be the person to contact about this.
It would be up to her to see how this should be handled.
This additional information request is going to be a bit more strict. If we
don't receive these items before the expiration date of February 27, 2019, then we
will rescind the application and issue an NOV to LINCO. if you have any questions,
don't hesitate to contact me.
Thanks you,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Friday, January 25, 2019 10:15 AM
To: Saunders, Erickson G <[e-mail]
<mailto: [e-mail]> >
Page 155 Page 156

W00003924emails19
Subject: [External] RE: WQ0003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
I am waiting on copy of the deed and register of deed info
<image601.png>
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Wednesday, January 23, 2019 1:57 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: FW: WQe003924 Additional Information Request
The signature authority designation letter is what we discussed on the
phone. Get one of the majority shareholders of Linco to sign it so that you may
become an appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
Page 157
WQ0003924emailsl9
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Buffington, Beth
Sent: Friday, March 01, 2019 11:15 AM
To: Saunders, Erickson G
Subject: RE: [External] Linco, Lincolnton NC
No, I haven't heard from him.
Beth Buffington
Environmental Specialist II, NC Operator Certification Program
Division of Water Resources, Dept of Environmental Quality
1618 Mail Service Center, Raleigh NC 27699-1618
PH: 919-707-9105 FX: 919-715-2726
http://deq.nc.gov/about/divisions/water-resources/operator-certification
<http://deq.nc.gov/about/divisions/water-resources/operator-certification>
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.
W00003924emailsl9
[phone] Office
[e-mail] cmailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: ' [e-mail] <mailto:[e-mail]> ' <[e-mail]
<mailto:[e-mail]> >; '[e-mail] cmailto:[e-mail]> '
<[e-mail] cmailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP
Holdings, LLC to LINCO Partnership. This additional information request is set to
address this ownership change, as well as other issues. I have included the formal
additional information request in this email, along with a few other documents that
have already been partially filled out that you will need to execute. I'm also
sending a physical copy to the mailing address that the regional inspector gave me
which is 5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister,
but I don't have a mailing address for him specifically. If this address is
incorrect, please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
Page 1S8
W00003924emails19
From: Saunders, Erickson G
Sent: Friday, March 1, 2019 11:13 AM
To: Buffington, Beth <[e-mail]>
Subject: RE: [External] Linco, Lincolnton NC
Importance: High
Beth,
Has Mr. Keister gotten back to you on this one?
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Buffington, Beth
Sent: Wednesday, January 30, 2019 1:13 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Cc: Saunders, Erickson G [e-mail]
<mailto:[e-mail]> >
Subject: RE: [External] Linco, Lincolnton NC
Hello Perry,
Page 159 Page 160

N00003924emailsl9
As required by NCAC 1SA BG .0201 and your permit, you must designate one Operator in
Responsible Charge (ORC) and at least one Back-up ORE for this facility. Both the
ORC and Backup ORC(s) must hold active Surface Irrigation certificates.
When there are vacancies in both ORC and Back-up ORC positions, the rule also
requires the permittee to designate one of these positions within seven days. Please
return the attached designation form to me (preferably by email) by February 6th. If
only one position is designated at that time, please complete and return an updated
form designating appropriately certified operators in both positions by February
28th.
I have attached a list of contract operators as you requested. You need to look for
operators or operations firms that have the code "SI" (for surface irrigation) and
that service the county in which the facility is located.
Please let me know if you have any questions about the designation requirement or
the contract operators list.
Thanks,
Beth Buffington
Environmental Specialist II, NC Operator Certification Program
Division of Water Resources, Dept of Environmental Quality
1618 Mail Service Center, Raleigh NC 27699-1628
PH: 919-707-9105 FX: 919-715-2726
http://deq.nc.gov/about/divisions/water-resources/operator-certification
<http://deq.nc.gov/about/divisions/water-resources/operator-certification>
Page 161
W00003924emailsl9
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: Perry Keister [mailto:[e-mail]]
Sent: Tuesday, January 29, 2819 9:49 AM
To: Buffington, Beth <[e-mail] <mailto:[e-mail]>
>; Saunders, Erickson G <[e-mail]
cmailto:[e-mail]> >
Subject: [External] Linco, Lincolnton NC
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Beth
Do you have a list of active ORC for our permit type at Linco?
Spray field
From: Perry Keister <[e-mail]>
Sent: Friday, March 01, 2019 11:19 AM
To: Saunders, Erickson G
Subject: [External] Fwd: NC Filing
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
See below
Hopefully they will be forwarding info very soon
Page 162
W00003924emailsl9 W00003924emails19
Department of Environmental Quality
Perry Keister
Consulting Division of Water Resources
Begin forwarded message: Water Quality Permitting
From: <[e-mail] <mailto:[e-mail]> >
Date: March 1, 2019 at 11:11:22 AM EST
To: "'Perry Keister"' <[e-mail] <mailto:[e-mail]> >
Cc: "'Ron Buck"' <[e-mail] <mailto:[e-mail]> >
Subject: NC Filing
Perry; our attorney filed this document this week. I have an email out to
him to confirm and will circle back to you once confirmed.
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Friday, March 01, 2019 11:23 AM
To: 'Perry Keister'
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Regarding the ORC issue, the email that Beth Buffington sent back to you did require
you to get an ORE and a backup ORE for the system. I have not spoken to Beth about
this specific permit in a while, but our system still doesn't have an ORC for the
system. Can you confirm that you have taken further steps toward designating an ORC
for this facility?
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Friday, March 01, 2019 11:01 AM
To: Saunders, Erickson G <[e-mail]>
Subject: Re: [External] FW: WQ0003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
I have ask linco lawyer to get the info as they have told me they are a GP in TN
He is suppose to be reaching out to you to gather what to do on corporate side as
this is past my pay grade of understanding.
Perry Keister
Consulting
On Mar 1, 2019, at 10:04 AM, Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> > wrote:
Perry,
Erick Saunders
Page 163 Page 164

W00003924emailsl9
The additional information request is now 2 days overdue. Please respond to
this email with a status update for the additional information response. We are
preparing an application return letter and if we do not hear from you by the end of
next Monday, we will proceed with returning the application which will be followed
by issuing you a Notice of Violation (NOV).
Regards,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Monday, February 18, 2019 9:17 AM
To: 'Perry Keister' <[e-mail] <mailto:[e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Perry,
I know you've gotten into contact with Beth but I just wanted to get a
status update for the second additional information request and remind you that it
is due in 9 days on February 27th.
Page 165
W00003924emailsl9
Perry,
What we want to see is that your Partnership is registered to do business in
the county/state. I've been researching this for the better part of the morning and
it looks like the Certificate of Assumed Name might not be the only form you'll need
(if you need it at all). you may have to register your partnership in the NC
Secretary of State as well.
According to this
<https://www.ncleg.net/EnactedLegislation/Statutes/PDF/ByArticle/Chapter_66/Article_
14A.pdf> general statute, you must file an assumed business name certificate into
the office of the register of deeds of the county you will be engaged in business if
your business name is different than either the real names of the general partners,
or the name registered in the Secretary of State (SoS). This means that depending on
what kind of partnership this is, you will also have to register in the NC SoS. It
appears that limited liability partnerships (LLPs) and limited partnerships (LPs)
have to registered with the secretary of state (refer to § 66-71.3. of the general
statute). This
<https://www.sosnc.gov/Guides/register_ a_ foreign_ business/requirements> link may be
helpful if you are looking for information on the Secretary of State's requirements.
So just to clarify, if LINGO is an LLP or an LP, then you must register with
the SoS. For this case, if your assumed business name is different than what is on
the SoS, then an assumed business name certificate will have to be registered in the
Lincoln County Register of Deeds (RoD). If the assumed business name is the same,
then documentation that you have registered to the SOS is adequate. If LINCO is not
an LP or LLP, then you will only have to register the assumed business name
certificate in the Lincoln RoD.
I'm sorry for not getting this clarified earlier, all this legal stuff can
be a little much for my math oriented mind. If you have any questions, I'll be in
the office until S. I'm aiming to go to lunch at around 12 today so I might not be
back until 1.
Thanks,
WQee03924emailsl9
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] (mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 11:26 AM
To: Saunders, Erickson G <[e-mail]
<mailto: Eric [e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto:report. [e-mail]>
Have Teresa working on it with her legal beagles
From: Saunders, Erickson G <[e-mail]
<mailto: Erick [e-mail]> >
Sent: Tuesday, January 29, 2019 11:23 AM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: RE: [External] FW: W00003924 Additional Information Request 2
Page 166
WQ0003924emailsl9
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:05 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] FW: W00003924 Additional Information Request 2
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Erickson
Will this suffice on missing documentation and I have reached out to Beth
concerning ORC
From: [e-mail] <mailto:[e-mail]>
<[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 10:01 AM
To: 'Perry Keister' <[e-mail] <mailto:[e-mail]> >
Subject: RE: W00003924 Additional Information Request 2
Page 167 Page 168

W00003924emails19 W00003924emailsl9
Please see attached. system did not have a backup ORC at the time of permitting, and the region has
indicated that Lynn Aldridge no longer serves the system. Beth Buffington of the
Wastewater Operator Certification group should be the person to contact about this.
It would be up to her to see how this should be handled.
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
611-970-8111
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Tuesday, January 29, 2019 9:48 AM
To: [e-mail] <mailto:[e-mail]>
Subject: FW: WQ0003924 Additional Information Request 2
Would you look at part A of the attached, I need a bit of help with that. I
will contact about ORC
From: Saunders, Erickson G ([e-mail]
<mailto: [e-mail]) >
Sent: Monday, January 28, 2019 12:50 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Buffington, Beth
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request 2
Perry,
Thanks for the submission last Friday. I was out in the field on a last
minute site visit so I may have missed if you called. We are accepting the response
and will not issue an NOV at this time. However, we are sending a second additional
information request to get the Certificate of Assumed Name filed in the Lincoln
County Register of Deeds and to get the ORC situation sorted out. Our systems
require one main ORC and another backup ORC according to 1SA NCAC 086 .0201. This
Page 269
W00003924emails19
Erickson
I an waiting on copy of the deed and register of deed info
<imageeal.png>
From: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Sent: Wednesday, January 23, 2019 1:57 PM
To: Perry Keister <[e-mail] <mailto:[e-mail]> >
Subject: FW: W00003924 Additional Information Request
The signature authority designation letter is what we discussed on the
phone. Get one of the majority shareholders of Linco to sign it so that you may
become an appropriate signing official.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
This additional information request is going to be a bit more strict. If we
don't receive these items before the expiration date of February 27, 2019, then we
will rescind the application and issue an NOV to LINGO. If you have any questions,
don't hesitate to contact me.
Thanks you,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Friday, January 25, 2019 10:15 AM
To: Saunders, Erickson G <[e-mail]
<mailto:[e-mail]> >
Subject: [External] RE: W00003924 Additional Information Request
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Page 170
W00003924emails19
From: Saunders, Erickson G
Sent: Monday, November 19, 2018 11:17 AM
To: ' [e-mail] <mailto:[e-mail]> ' <[e-mail]
<mailto:[e-mail]> >; '[e-mail] <mailto:[e-mail]> '
<[e-mail] <mailto:[e-mail]> >
Cc: Thornburg, Nathaniel <[e-mail]
<mailto:[e-mail]> >; Watson, Edward M
<[e-mail] <mailto:[e-mail]> >; Pitner, Andrew
<[e-mail] <mailto:[e-mail]> >
Subject: W00003924 Additional Information Request
It has come to my attention that this permit has changed hands from NFP
Holdings, LLC to LINGO Partnership. This additional information request is set to
address this ownership change, as well as other issues. I have included the formal
additional information request in this email, along with a few other documents that
have already been partially filled out that you will need to execute. I'm also
sending a physical copy to the mailing address that the regional inspector gave me
which is 5200 Old Harding Road, Nashville TN 37064. It's addressed to Mr. Keister,
but I don't have a mailing address for him specifically. If this address is
incorrect, please tell me and I can resend it.
Please address all of the items of this request before the end of the day on
December 19, 2018. Don't hesitate to contact me about any issues you may have.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Page 171 Page 172

W00003924emailsl9
From: Wicker, David <[e-mail]>
Sent: Tuesday, March 05, 2019 7:00 PM
To: Saunders, Erickson G
Subject: [External] WQ0003924 Additional Information Request
Attachments: FW: [External] FW: W00003924 Additional Information Request 2;
NASHVILLE-#1329734-VI-Buck_ _Celadon_ Recorded_Assumed_ Business_Name_NortN_Carolina
.PDF
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to report. [e-mail]
<mailto:[e-mail]>
Erick,
See attached and below but I work with Linco Partnership. In repose to your notes,
I've worked with North Carolina counsel who has advised us on a few points.
GPs do not register in Tennessee which as you've suggested is also not a requirement
in North Carolina (and why there is no mechanism for a GP to register as a Foreign
Entity in NC). Accordingly, the only recommended practice is what we have done and
is attached hereto: Sign and record our Assumed Business name.
Let me know what I can do to further help out here. I'm happy to speak to you at
your earliest convenience.
Regards,
David Wicker
O. David Wicker
Member
Direct: 615-782-2294
Mobile: [phone]
[e-mail] <mailto:[e-mail]>
Page 173
W00003924emails19
Teresa Lundine/Vice President
RONALD D. RUCK, INC.
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Wednesday, March 06, 2019 2:S6 PM
To: Perry Keister
Subject: RE: [External] Fwd: Assumed name certificate
That s what we needed. Please continue to work with Beth Buffington regarding the
ORC situation. We're going to proceed with drafting of the permit.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Wednesday, March 06, 2019 11:38 AM
To: Saunders, Erickson G <[e-mail]>
Subject: [External] Fwd: Assumed name certificate
W00003924emails19
STITES&HARBI5ON PLLC
401 Commerce Street, Suite 800, Nashville, TN 37219
About Stites & Harbison <http://www.stites.com/> I Bio
<https://www.stites.cam/attorneys/j-david-wicker> I V-Card
<https://www.stites.com/vcard/j-david-wicker>
NOTICE: This message is intended only for the addressee and may contain information
that is privileged, confidential and/or attorney work product. If you are not the
intended recipient, do not read, copy, retain or forward this message or any
attachment. Please notify the sender immediately and delete all copies of the
message and any attachments. Neither the transmission of this message or any
attachment, nor any error in transmission, constitutes a waiver of any applicable
legal privilege.
From: Perry Keister <[e-mail]>
Sent: Wednesday, March 06, 2019 11:39 AM
To: Saunders, Erickson G
Subject: [External] Fwd: Assumed name certificate
Attachments: Lincolnton registration for assumed name doc.pdf
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Will this piece of paper satisfy for permit at linco in Lincolnton NC ?
Perry Keister
Consulting
Begin forwarded message:
From: <[e-mail] <mailto:[e-mail]> >
Date: March 6, 2019 at 8:30:54 AM CST
To: "'Perry Keister"' <[e-mail] <mailto:[e-mail]> >
Subject: Assumed name certificate
Please see attached
Page 174
W00003924emailsl9
CAUTION: External email. Do not click links or open attachments unless you verify.
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Will this piece of paper satisfy for permit at linco in Lincolnton NC ?
Perry Keister
Consulting
Begin forwarded message:
From: <[e-mail] <mailto:[e-mail]> >
Date: March 6, 2019 at 8:30:54 AM CST
To: "'Perry Keister"' <[e-mail] <mailto:[e-mail]> >
Subject: Assumed name certificate
Please see attached
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail]>
Sent: Wednesday, March 06, 2019 3:20 PM
To: Saunders, Erickson G
Subject: Re: [External] Fwd: Assumed name certificate
CAUTION: External email. Do not click links or open attachments unless you verify
Send all suspicious email as an attachment to [e-mail]
<mailto:[e-mail]>
Excellent
In Texas till Friday and will reach out on operators
Perry Keister
Page 175 Page 176

W00003924emailsl9
Consulting
On Mar 6, 2019, at 1:56 PM, Saunders, Erickson G <[e-mail]
<mailto: Erickson. Saunders@ncdenr. gov> > wrote:
That's what we needed. Please continue to work with Beth Buffington
regarding the ORC situation. We're going to proceed with drafting of the permit.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Perry Keister <[e-mail] <mailto:[e-mail]> >
Sent: Wednesday, March 06, 2019 11:38 AM
io: Saunders, Erickson G <[e-mail]
<mailto: Erickson. Saunders@ncdenr. gov> >
Subject: [External] Fwd: Assumed name certificate
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to [e-mail]
<mailto: report. [e-mail]>
Will this piece of paper satisfy for permit at linco in Lincolnton NC ?
Perry Keister
Page 177
W00003924emailsl9
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Wednesday, March 13, 2019 3:48 PM
To: Saunders, Erickson G
Subject: LINCO Partnership Permit
Attachments: W00003924 Draft Permit - ahp commnets.docx
Erick,
I have attached MRO's comments for the draft permit. It looks like everything has
been addressed within the comments.
Regards,
Ed
Edward Watson
Hydrmgemlogist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 235 2198 office
704 235 6040 Fax
[e-mail] <mailto:[e-mail]>
Page 179
W00003924emailsl9
Consulting
Begin forwarded message:
From: <[e-mail] <mailto:[e-mail]> >
Date: March 6, 2019 at 8:30:54 AM CST
To: "'Perry Keister"' <[e-mail]
<mailto:[e-mail]> >
Subject: Assumed name certificate
Please see attached
Teresa Lundine/Vice President
RONALD D. BUCK, INC.
615-970-8153
[e-mail] <mailto:[e-mail]>
From: Saunders, Erickson G
Sent: Thursday, March 07, 2019 9:54 AM
To: Watson, Edward M
Cc: Thornburg, Nathaniel
Subject: W00003924 Draft Permit
Attachments: W00003924sm190306.PNG; W00003924dp18XXXX.docx
Ed,
We received a copy of the Certificate of Assumed Name, and I was told not to hold up
the process of the permit for the ORC issue. I have everything I need from them, so
here's the draft permit and site map.
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Page 179
W00003924emailsl9
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Saunders, Erickson G
Sent: Friday, March 15, 2019 12:00 PM
To: Watson, Edward M
Subject: RE: LINCO Partnership Permit
Attachments: W00003924dp18XXXX.docx; W00003924sm190315.png
Ed,
I've taken everything into account with the comments. I've taken NFP holdings
completely out, fixed the facility type (it's wastewater irrigation) and changed the
effective dates. To answer the question about reopening the facility on I.3. and
I.4., it's really only just in case they decide to keep the permit. We have to
assume that they will be using it. Spent the better part of the morning creating a
CB/RB. Here's a look at it. lust give it a look over to see if it's good enough.
Once you give me an all clear I'll send it out to Perry.
Also did you receive my draft to send to Perry regarding the future of their lagoon?
I'll send it with the draft permit but I just want to know if what I said is
adequate.
Thanks,
Page 180

W00003924emailsl9
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Wednesday, March 13, 2019 3:48 PM
To: Saunders, Erickson G <[e-mail]>
Subject: LINCO Partnership Permit
a'
I have attached MRO's comments for the draft permit. It looks like everything has
been addressed within the comments.
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
Page 181
W00003924emails19
Ed
From: Saunders, Erickson G
Sent: Friday, March 15, 2019 12:08 PM
To: Watson, Edward M <[e-mail]>
Subject: RE: LINCO Partnership Permit
Ed,
I've taken everything into account with the comments. I've taken NFP holdings
completely out, fixed the facility type (it's wastewater irrigation) and changed the
effective dates. To answer the question about reopening the facility on I.3. and
I.4., it's really only just in case they decide to keep the permit. We have to
assume that they will be using it. Spent the better part of the morning creating a
CB/RB. Here's a look at it. Just give it a look over to see if it's good enough.
Once you give me an all clear I'll send it out to Perry.
Also did you receive my draft to send to Perry regarding the future of their lagoon?
I'll send it with the draft permit but I just want to know if what I said is
adequate.
Thanks,
Erick Saunders
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
W00003924emailsl9
North Carolina Department of Environmental Quality
704 235 2198 Office
704 235 6040 Fax
[e-mail] <mailto:[e-mail]>
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Watson, Edward M
Sent: Friday, March 15, 2019 12:40 PM
To: Saunders, Erickson G
Cc: Pitner, Andrew
Subject: RE: LINCO Partnership Permit
Erick,
Everything appears to be in order. MRO is good with the draft permit
Regards,
Page 182
W00003924emails19
[e-mail] <mailto:[e-mail]>
From: Watson, Edward M
Sent: Wednesday, March 13, 2019 3:48 PM
To: Saunders, Erickson G <[e-mail]>
Subject: LINCO Partnership Permit
Erick,
I have attached MRO's comments for the draft permit. It looks like everything has
been addressed within the comments.
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 235 2198 Office
704 23S 6040 Fax
[e-mail] <mailto:[e-mail]>
610 E. Center Ave.
Page 183
Page 184

W00003924emailsl9
W00003924emailsl9
Suite 301
Mooresville, NC 20115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Saunders, Erickson G
Sent: Friday, March 15, 2019 2:20 PM
To: 'Perry Keister'
Cc: Watson, Edward M; Thornburg, Nathaniel
Subject: W00003924 Draft Permit and Last Questions
Attachments: W00003924dp10XXXX.docx; W00003924sm190315.png
Perry,
Attached is a draft permit and site map for your facility. Please review these items
and return to me with any questions, comments or concerns before the end of the day
on March 22, 2019.
Unrelated to the draft, but I just have one last question for you. Our office and
the regional office has an interest in what the plans are for the lagoon are moving
forward. Depending on the route that you go, reusing the pond may affect how the
rescinding of this permit will proceed. I know you had mentioned potentially reusing
the pond for other purposes a few months back but I didn't get it into writing.
Could you give us your plan for it? It would help us help you in the future for what
you have to do for the next steps.
Thanks,
Department of Environmental Quality
Division of Water Resources
Water Quality Permitting
[phone] Office
[e-mail] <mailto:[e-mail]>
Erick Saunders
Page 105 Page 106

Nowrw CAROLINA
ROY COOPER Environmental QuIghly
MICHAE.L S. REGA1%4
LINDA, CULPEPPE- R
In re6w Dar cctor
August 29, 2018
JAMES C. ZOMBRO, JR. — ENVIRONMENTAL DIRECTOR
NFP HOLDINGS, LLC
701 FAIRMONT AVE.
WINCHESTER, VA 22601
Subject: Acknowledgement of
Application No. WQ0003924
National Fruit Product Company -
Lincolnton WWTF
Wastewater Irrigation System
Lincoln County
Dear Mr. Zombro:
The Water Quality Permitting Section acknowledges receipt of your permit application and
supporting documentation received on August 29, 2018. Your application package has been assigned the
number listed above, and the primary reviewer is Erick Saunders.
Central and Regional Office staff will perform a detailed review of the provided application, and
may contact you with a request for additional information. To ensure maximum efficiency in processing
permit applications, the Division of Water Resources requests your assistance in providing a timely and
complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days
after receipt of a complete application. If you have any questions, please contact
Erick Saunders at [phone] or [e-mail].
Sincerely,
Nathaniel D. Thornburg, Supervisor
Division of Water Resources
cc: Mooresville Regional Office, Water Quality Regional Operations Section
Permit File WQ0003924
b f.Y Oci!p
North Carolina Department of Environmental Quality I Division of Water Resources I Non -Discharge Branch
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.3654

NORTH CA,ROLINA
Poy COOPER E1Qrtronwatal+QUORty
MICHAEL S. REGAN
i INDA CULPEPPER
November 19, 2018
PERRY KEISTER
LINCO PARTNERsHiP
5200 OLD HARDING ROAD
NASHviLLE, TENNEssEE 37064
Subject: Application No. WQ0003924
Additional Information Request
National Fruit Product Company —
Lincolnton WWTF
Wastewater Irrigation System
Lincoln County
Dear Mr. Keister.
Division of Water Resources' Central and Regional staff has reviewed the application package
received August 29, 2018. However, additional information is required before the review may be
completed. Please address the items on the attached pages no later than the close of business on December
19, 2018.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through G, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete. Items listed under Section H —
Recommendations are for your consideration, but do not require a response.
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with three
copies submitted to my attention at the address below.
QE
North LioN no, f,i (.1 f:nwarl rilr5� iz ; • i; . 1.1 .I ofWatgr I<esource` .14oh Utsv�r ge Brareh
5] i 1h.,tri st-hFf, 4,; StIUq! l I(^I I Alai Scivl� C:ef,ler I Raleigh, North Carolina 27699-16 17

Mr. Perry Keister
November 19, 2018
Page 2 of 3
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3659 or [e-mail]. Thank you for your cooperation.
r
Sincerely,
Erick Saunders, Environmental .ngineer
Division of Water Resources
cc: Mooresville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Permit Application File WQ0011655
James C. Zombro — NFP Holdings, LLC (Electronic Copy)

Mr. Perry Keister
November 19, 2018
Page 3 of 3
A. Non -Discharge Permit Ownership/Name Change (.FORM: NDPONC 06-16) Application:
1. The Regional Office has indicated that the facility has been bought from the current permittee NFP
Holdings, LLC by LINCO Partnership. Please have the new owner fill out a NDPONC 06-16 form
attached that includes.
a. A properly executed signature authority designation letter (FORM: NDSDAL 11-17) to
designate Perry Keister signature authority for the permit.
b. The Applicant's Certification signed by the new owner will be in accordance with 15A NCAC
02T .0106(b). In the case of a partnership, it must be signed by a general partner. Alternatively,
a designated signature authority can fill out the Applicant's Certification, provided a NSDAL
11-17 form has been submitted giving them signature authority on the permit.
B. Existing Permit:
1. No comments.
C. Prop:ert� Ownershiir Documentation:
1. Provide legal documentation of ownership such as a deed or a written notarized intent to purchase
agreement to show that LINCO Partnership owns or plans to own Parcel #426 on 288 Whitehouse
Drive.
2. Provide a Certificate of Assumed Name filed in the Lincoln County Register of Deeds. This needs
to be stamped by the Register of Deeds office with the deed book and page.
D. Certificate of Public Convenience and Necessim;
1. N/A
E. Operational &,reements:
1. N/A
F. Operation and Maintenance Agreement:
1. No comments.
G. Operator with Reasonable Charge (ORC) 115A NCAC 08G.02001:
1. Our records indicate that you don't have a backup ORC. Please contact Beth Buffington of the
Wastewater Operator Certification group at [phone] about this issue.
H. Recommendations: (Response not reQuiredi
1, No comments.

January 17th 2019
To Whom It May Concern:
Please allow Mr. Perry Keister to complete, originate and all else documents necessary to
facilitate the permitting process for requirements associated with CRS and Linco
Partnership.
If you need any clarification please contact me at 615-579-3815 or
Ronald D. Buck, Inc
5200 Old Harding Road
Franklin, Tn 37064 - RECEIVED
Your help ' ally ciate ! NCDEQ/DWR
2 b JAN 2010
—OVA Non -Discharge
Permitting Unit

Water Resources
ENVIRONMENTAL QUALITY
November 19, 2018
Division of Water Resources
Non -Discharge Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
To Whom It May Concern:
ROY COOPER
Governor
MIC14AEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Subject: Permit No. WQ0003924
Signature Authority Designation
National Fruit Product
Company - Lincolnton WWTF
Wastewater Irrigation System
Lincoln County
As an appropriate signing official for Linco Partnerships, a TN General Patnership (city/town or business
name) as designated by 15A NCAC 2T .0106, I hereby delegate authority to sign and certify all permit
applications, reports or other permit related documents to the following staff for the following permit
types (sewer, spray, land application) and/or permit numbers:
Position
Person Permit T.I1e
Currenth in or Permit
Position Number
Partner/CTO
Perry Keister
W 0003924
If you have any questions, please contact me at the following:
Permittee/Applicant name (please print): Linco/Perry Keister
Title: Partner
Complete mailing address: 5200 Old Harding Road, TN 37064
City: Franklin State: TN Zip: 37064
Telephone number: ( 828 ) 638-5032 Facsimile number: [phone]
Sincerely,
Perry R Keiv�
signature
=`'"Nothing Compares -
State of North Carolina I Environmental Quality I Water Resources I Water Quality Permitting I Non -Discharge Permitting
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-807-6332

h State of North Carolina
Department of Environmental Quality
DWR Division of Water Resources
NON -DISCHARGE PERMIT OWNERSHIP/NAME CHANGE
Division of Water Resources INSTRUCTIONS FOR FORM: NDPONC 06-16 & SUPPORTING DOCUMENTATION
This form is for ownership changes or name changes of a non -discharge system permit. Please note that "Permittee"
references the existing permit holder, and that "Applicant" references the entity applying for the ownership/name change.
For more information, visit the Water Quality Permitting Section's Non -Discharge Permitting Unit website
A. Non -Discharge Permit Ownership/Name Change (FORM: NDPONC 06-16) Application (All Applications):
❑ Submit an original completed and appropriately executed Non -Discharge Permit Ownership/Name Change (FORM: NDPONC
06-16) application.
❑ The Existing Permittee's Certification shall be signed in accordance with 15A NCAC 02T .0106fb). Per 15A NCAC 02T
.0106(c), an alternate person may be designated as the signing official if a delegation letter is provided from a person who
meets the criteria in 15A NCAC 02T .0106[ hl.
❑ The Applicant's Certification shall be signed in accordance with 15A NCAC 02T .0106(bl. Per 15A NCAC 02T .0106[cl. an
alternate person may be designated as the signing official if a delegation letter is provided from a person who meets the criteria
in 15A NCAC 02T .0106(b).
B. Existing Permit (All Applications):
❑ Submit a copy of the most recently issued permit.
C. Property Ownership Documentation (All Applications):
➢ Per 15A NCAC 02T .0` 11, 15A NCAC 02T .0604(e), 15A NCAC 02T .07041 f), 15A NCAC 02T .0804, 15A NCAC 02T
.1004(d), 15A NCAC 02T .1104td1(71, 15A NCAC 02T .1104Ie!(5), 15A NCAC 02U .0201[e1 or 15A NCAC 02U .0202(1).
the Applicant shall demonstrate they are the owner of all property containing the non -discharge system facilities:
❑ Legal documentation of ownership (i.e., GIS, deed or article of incorporation), or
❑ Written notarized intent to purchase agreement signed by both parties with a plat or survey map, or
❑ Written notarized lease agreement that specifically indicates the intended use of the property and has been signed by both
parties, as well as a plat or survey map. Lease agreements shall adhere to the requirements of 15A NCAC 02L .0107.
D. Certificate of Public Convenience and Necessity (All Applications where the Applicant is a Privately -Owned Public Utility):
❑ Per 15A NC. _C 02T .0115(aH 1): provide one copy of the Certificate of Public Convenience and Necessity from the North
Carolina Utilities Commission demonstrating the Applicant is authorized to hold the utility franchise for the area to be served
by the non -discharge system.
E. Operational Agreements (All Applications where the Applicant is a Home/Property Owners' Association or Developer of lots to
be sold):
➢ Home/Property_ Owners' Associations
❑ Per 15A NCAC 02T .0115t c I, submit an original properly executed Operational Agreement ,(FORM: HOA).
® Per 15A NCAC 02T .0115(c), submit an original proposed or approved Articles of Incorporation, Declarations and By-
laws.
➢ Developers of lots to be sold
❑ Per 15A NCAC 02T .0115.(b). submit an original of the properly executed Operational Agreement ( FORM: DEV I.
F. Operation and Maintenance Agreement (All Applications for Single -Family Wastewater Irrigation Systems):
❑ Per , NCAC 02T .0604th), submit an original of a notarized Operation and Maintenance Agreement FORM: SFRWWIS
jmiw, that has been signed and dated by all deeded property owners.
THE COMPLETED APPLICATION AND SUPPORTING DOCUMENTATION SHALL BE SUBMITTED TO:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NON -DISCHARGE PERMITTING UNIT
B■ U.S. Postal Service: By Courier/Special Delivery:
1617 MAIL SERVICE CENTER 512 N. SALISBURY ST.
RALEIGH, NORTH CAROLINA 27699-1617 RALEIGH, NORTH CAROLINA 27604
TELEPHONE NUMBER: [phone] FAX NUMBER: [phone]
INSTRUCTIONS FOR FORM: NDPONC 06-16 & SUPPORTING DOCUMENTATION Page 1 of 1

State of North Carolina
Department of Environmental Quality
DWR Division of Water Resources
NON -DISCHARGE PERMIT OWNERSHIP/NAME CHANGE
Wvislon of Water Resources FORM: NDPONC 06-16
I. EXISTING PERMITTEE INFORMATION:
1. Permittee's name: NFP Holdings LLC
2. Signature authority's name: David C. Gum III per 15A NCAC 02T .0106(bl Title: Member/Manager
3. Permittee's mailing address: 701 Fairmont Avenue
City: Winchester State: VA Zip: 22601-
4. Permittee's contact information: Phone number: 540 974-6873 Email Address: dgum(aNFPC.com
5. Demonstration of historical consideration for permit approval — 15A NCAC 02T .0120:
Has the Permittee or any parent, subsidiary or other affiliate exhibited the following?
a. Has been convicted of environmental crimes under Federal law or G.S. 143-215.613? ❑ Yes or ® No
b. Has previously abandoned a wastewater treatment facility without properly closing that facility? ❑ Yes or ® No
c. Has unpaid civil penalty where all appeals have been abandoned or exhausted? ❑ Yes or ® No
d. Is non -compliant with an existing non -discharge permit, settlement agreement or order? ❑ Yes or ® No
e. Has unpaid annual fees in accordance with 15A NCAC 02T .Ol05Ael(2]? ❑ Yes or ® No
H. FACILITY INFORMATION:
1. Facility name: National Fruit Product Company - Lincolnton WWTF
2. Facility's physical address: 288 White House Road
City: Lincolnton State: NC Zip: 28093- County: Lincoln
III. PERMIT INFORMATION:
1. Existing permit number: WQ0003924 and most recent issuance date: April 7, 2014
2. Existing permit type: Wastewater Irrigation
3. Reason for the permit application: Change of Ownership
4. Has the facility been constructed? ® Yes or ❑ No
IV. APPLICANT INFORMATION:
1. Applicant's name: LINCO
2. Signature authority's name: Perry R Keister per 15A NCAC 02T .0106(b) Title:
3. Applicant's mailing address: 52000Ld HArding Road Franklin TN 37064
City: Franklin State: TN Zip: 37064-
4. Applicant's contact information: Phone number: [phone] Email Address: prkeister(a,ainail.com
5. Demonstration of historical consideration for permit approval — 15A NCAC 02T .0120:
Has the Applicant or any parent, subsidiary or other affiliate exhibited the following?
a. Has been convicted of environmental crimes under Federal law or G.S. 143-215.613? ❑ Yes or ® No
b. Has previously abandoned a wastewater treatment facility without properly closing that facility? ❑ Yes or ® No
c. Has unpaid civil penalty where all appeals have been abandoned or exhausted? ❑ Yes or ® No
d. Is non -compliant with an existing non -discharge permit, settlement agreement or order? ❑ Yes or ® No
e. Has unpaid annual fees in accordance with 15A NCAC 02T .01051 e1t21? ❑ Yes or ® No
FORM: NDPONC 06-16 Page 1 of 2

Existing Permittee's Certification per 15A. NCAC 02T .0106(b1:
I Perry Keister /Partner/CTO attest that this application for
(Signature Authority's name & title from Application Item I.2.)
Linco Partnership
(Facility name from Application Item II.1.)
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that prior to reissuance of the permit
into the Applicant's name, any discharge of wastewater from this non -discharge system to surface waters or the land will result in an
enforcement action that may include civil penalties, injunctive relief, and/or criminal prosecution. I will make no claim against the
Division of Water Resources should a condition of the existing permit be violated. I also understand that if all required parts of this
application package are not completed and that if all required supporting information and attachments are not included, this application
package will be returned as incomplete. I further certify that the existing Permittee or any affiliate has not been convicted of an
environmental crime, has not abandoned a wastewater facility without proper closure, does not have an outstanding civil penalty where
all appeals have been exhausted or abandoned, are compliant with any active compliance schedule, and do not have any overdue annual
fees per 15A NCAC 02T .0105(e).
NOTE — In accordance with General Statutes 143-215.6A and 143-215.613, any person who knowingly makes any false statement,
representation, or certification in any application package shall be guilty of a Class 2 misdemeanor, which may include a fine not to
exceed $10,000 as well as civil penalties up to $25,000 per violation.
Signature: _ 6Mn A' Date: 01.25.2019
41
Applicant's Certification per 15A NCAC 02T .010�:
I, Perry Keister /Partner/CTO attest that this application for
(Signature Authority's name & title from Application Item IV.2.)
Linco Partnership
(Facility name from Application Item II.1.)
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that after reissuance of the permit
into the Applicant's name, any discharge of wastewater from this non -discharge system to surface waters or the land will result in an
enforcement action that may include civil penalties, injunctive relief, and/or criminal prosecution. I will make no claim against the
Division of Water Resources should a condition of this permit be violated. I also understand that if all required parts of this application
package are not completed and that if all required supporting information and attachments are not included, this application package
will be returned to me as incomplete. I further certify that the Applicant or any affiliate has not been convicted of an environmental
crime, has not abandoned a wastewater facility without proper closure, does not have an outstanding civil penalty where all appeals have
been exhausted or abandoned, are compliant with any active compliance schedule, and do not have any overdue annual fees per 15A
NCAC 02T .0105(a ).
NOTE — In accordance with General Statutes 143-215.6A and 143-215.613. any person who knowingly makes any false statement,
representation, or certification in any application package shall be guilty of a Class 2 misdemeanor, which may include a fine not to
exceed $10,000 as well as civil penalties up to $25,000 per violation.
Signature:
Date: 1.25.2019
FORM: NDPONC 06-16 Page 2 of 2

NORTH! CAROLINA
irovelow
MICHAxEL S. REGAN
se"rfoy
LINDA CULPEPPER
Interim ire avr
January 28, 2019
PERRY KEISTER
LINGO PARTNERSHIP
5200 OLD HARDING ROAD
NASHVILLE, TENNESSEE 37064
Subject: Application No. WQ0003924
Additional Information Request
National Fruit Product Company —
Lincolnton WWTF
Wastewater Irrigation System
Lincoln County
Dear Mr. Keister:
Division of Water Resources' Central and Regional staff has reviewed the application package
received August 29, 2018 and additional information received January 25, 2019. However, additional
information is required before the review may be completed. Please address the items on the attached pages
no later than the close of business on February 27, 2019.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through 13, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete. Items listed under Section C —
Recommendations are for your consideration, but do not require a response.
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with three
copies submitted to my attention at the address below.
North Carolina Department of Environmental Quality I Division of Water Resources I Non -Discharge Branch
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.3654

Mr. Perry Keister
January 28, 2019
Page 2 of 3
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3659 or [e-mail]. Thank you for your cooperation.
Sincerely,
Erick Saunders, Environmental Engineer
Division of Water Resources
cc: Mooresville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Permit Application File WQ0003924

Mr. Perry Keister
January 28, 2019
Page 3 of 3
A. Property Ownership Documentation:
1. Provide a Certificate of Assumed Name filed in the Lincoln County Register of Deeds. This needs
to be stamped by the Register of Deeds office with the deed book and page.
B. Operator with Reasonable Champ (ORC) 115A NCAC 08G .02001:
1. Our records indicate that you don't have a backup ORC, and the current ORC Lynn Aldridge no
longer works on the system. Please contact Beth Buffmgton of the Wastewater Operator
Certification group at [phone] about this issue.
C. Recommendations: (Response not reauired):
1. No comments.

STITES & HARBISON, PLLC
JSUNTRUST PLAZA
401 COMMERCE ST. SUITE 800
NASHVILLE, TN 37219-2376
A9 . no (1)
1.
BK 2800 PG 130 - 130 (1)
This document presented and filed:
02/28/2019 12:53:13 PM
ASSUMED NAME
Fee $26.00
589356 1111111111111111111111111
Lincoln County North Carolina
Danny R. H V ED
NCDEQIDWR
NAME CERTIFIC
Please print legibly.
The assumed business name is:
Linco Partnership; and _.
Linco Partnership, a Tennessee_general artnershi
(You may include no more than five (5) assumed business names on this form.)
5 MAR 2019
Non -Discharge
Permitting Unit
2. The real name of the person or entity engaging in business under the assumed business name is:
Ron Buck; Lorin Weaver= Perry Keister; Jeff Reynolds and Teresa Lundine
(Corporations, LLC's, limited partnerships must provide the exact name registered with the NC Secretary of State's office and
the SOSID number assigned at the time of formation. Go to www.sosnc.aovlbr/searc to lookup your information.)
3. The nature/type of the business is: Acquire and hold title to real property.
4. The street address of the principal place of business is: (PO Boxes are not acceptable)
5200 Old Harding Road Nashville TN 37064
5. The mailing address, if different from the street address, is:
_5200 Old Hardlng Road: Nashville, TN 37064
6. The counties where the assumed business name will be used to engage in business are:
❑ All 100 North Carolina counties
Lincoln County
This certificate is signed by the owner/legal representative of the person or entity named above,
this 26 day of February 2019
Signature:
Printed/Typed Name: Ron Buck
Title: General Partner
(See Instructions for who must sign for various business entity types.)
Assumed Busjness Name Certificate
10,03.17

ROY COOPER
Gosmeor
N11CRAEL S. REG-AN
Sweeny
LINDA CULPEPPER
Interim Director
SY
NORTH CAROLINA
Eavlroamental Quality
Certified Mail * 7018 0360 0002 2099 0928
Return Receipt Requested
July 3, 2019
Perry Keister - Partner
LINCO PARTNERSHIP
5200 Old Harding Rd.
Nashville, TN 37064
SUBJECT: NOTICE OF VIOLATION
Tracking Numbers: See Chart Below
Permit No. WQ0003924
Linco Partnership
Lincoln County
Dear Mr. Keister:
RECEIVED
NCDEQ/DWR
J JUL 2010
Non -Discharge
Permitting Unit
A review of the May 2018 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Permit Condition Violation(s):
Parameter
Date(s)
Reporting Violation
10/31/2018
Reporting Violation
11/30/2018
Reporting Violation
12/31/2018
Reporting Violation
01/31/2019
Reporting Violation
02/28/2019
Type of Violation
Late/Missing NDAR-1 and NDMR
Late/Missing NDAR-1 and NDMR
Late/Missing NDAR-1 and NDMR
Late/Missing NDAR-1 and NDMR
Late/Missing NDAR-1 and NDMR
NOV NUMBER
NOV-2019-PC-0493
NOV-2019-PC-0494
NOV-2019-PC-0495
NOV-2019-PC-0496
NOV-2019-PC-0497
A Notice of Violation is being issued for the noted violations of North Carolina General Statute (G.S.) 143-215.1
and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five
thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with
the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1.
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

If you wish to provide additional information regarding the noted violations, request technical assistance, or
discuss overall compliance please respond in writing within thirty (30) business days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 30-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Edward Watson of
the Mooresville Regional Office at 704-663-1699.
Sincerely,
Docu fined by:
Al4CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699