WQ0003924_NOV-2021-OV-0002 Response_20210503

Linco Partnership
5200 Old Harding Road
Franklin, TN 37064
Office 615-799-0933
May 3, 2021
VIA EMAIL AND USPS MAIL TO: cored hasin er(&ncdenr.1a
W. Corey Basinger, Regional Supervisor
North Carolina Department of Environmental Quality
Division of Water Resources
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
RE: Linco Partnership, Permit No. WQ0003924
NOV-2021-OV-0002
RECEIVED/NCDEQ/DWR
MAY --52U1
WOROS
MOORESVILLE REGIONAL OFFICE
Dear Mr. Basinger,
This letter is in response to your letter dated April 13, 2021 and is intended to provide you with an
update on activities at the Lincolnton, NC property owned by Linco Partnership where a tote
washing and recycling facility has been operated by Celadon. As you know, many of the
operational and site condition concerns regarding the property came to our attention as a result of
the January 22, 2021 conference call with NC DEQ and US EPA officials. Following that call, our
representatives have been in contact with federal, state and local officials regarding the property
and plans for 1) understanding the situation and regulatory concerns; and 2) addressing them
appropriately.
Although Linco was and is not the operator of the facilities on site, Linco has every intent to
support and maintain environmental compliance on its property and protect its investment, security
interests and value. As the owner of the property, in order to understand the situation on the ground
Linco has engaged independent engineering and environmental professionals, Charlotte based
Shield Engineering. Shield Engineering is assisting regarding compliance by studying site
conditions including testing and classifying the fluids contained in the totes, storage tanks and
lagoon on the property; investigating water and waste disposal alternatives; reviewing the
condition of and developing plans for closing the lagoon on the property.
Those activities are being conducted in an orderly fashion with priority given to addressing DEQ
Division of Waste Management concerns regarding totes with questionable contents which you
can confirm with Brent Burch. Over 300 have been tested and removed from the site. A plan for
dealing with the remaining fluids on the site is well underway and water treatment technologies
and vendor proposals are pending.

W. Corey Basinger, Regional Supervisor
May 3, 2021
Page 2
Celadon is not operating the facilities at this time and it is our understanding that the wastewater
irrigation system subject to the permit was never used. We note that the violations cited in the
letter are for previous violations while Celadon operated the facility. While Linco cannot address
prior reporting lapses, it can assure the DEQ that it is making every attempt to address remaining
concerns on the property in an efficient and economic manner.
Regarding the lagoon itself, laboratory testing of the water quality is scheduled to aid in decisions
regarding not only lowering the water surface elevation to expose the liner area but to ultimately
dewater the impoundment and regrade the site.
Be assured that Linco, as property owner with significant investment in this real estate, will
continue cooperating with DEQ and local officials as site plans develop and will keep the Division
of Water Resources advised.
Sincerely,
Ron Buck
cc: Bob Griffin P.E.
Tom Witner
William T. Gorton III
Brent Burch