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HomeMy WebLinkAboutNC0036641_Final Wastewater Lagoon Closure Report_20220214 Wastewater Treatment Lagoon Fletcher Academy, PJs Place Fletcher, North Carolina Headwater Project # A19-146-01 Prepared for: Fletcher Academy, Inc 185 Fletcher Academy Drive Fletcher, North Carolina 28732 February 14, 2022 Lagoon Closure Report Lagoon Closure Report Wastewater Treatment Lagoon Fletcher Academy, PJs Place Fletcher, North Carolina Headwater Project # A19-146-01 February 14, 2022 Prepared for Fletcher Academy, Inc 185 Fletcher Academy Drive Fletcher, North Carolina 28732 Prepared by Headwater Geology, PLLC 30 Westgate Pkwy, #356 Asheville, North Carolina 28806 __________________________ Adam M. Tripp, PG Senior Geologist Firm License # C-566 Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology i TABLE OF CONTENTS 1 Introduction ............................................................................................................... 1 1.1 Lagoon Background Information ........................................................................................ 1 1.2 Lagoon Assessment and Closure Plan Summary .............................................................. 2 2 Lagoon Closure ........................................................................................................ 4 2.1 Lagoon Dewatering ............................................................................................................ 4 2.2 Sludge Solidification and Disposal ..................................................................................... 7 2.3 Lagoon Structure and Liner Demolition .............................................................................. 7 2.3.1 Additional Structure Demolition .............................................................................. 8 3 Conclusions and Recommendations ........................................................................ 9 4 References ............................................................................................................. 10 FIGURES Figure 1 Location Map Figure 2 Sediment Thickness Map Figure 3 Surface and Groundwater Sample Location Map APPENDICES Appendix A Photographic Log Appendix B James and James Laboratory Analytical Report Appendix C Waste Manifests Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology 1 1 Introduction Headwater Geology PLLC. (Headwater), on behalf of Fletcher Academy, Inc. (Fletcher Academy), prepared this Lagoon Closure Report documenting closure activities for a wastewater treatment lagoon located on PJs Place Road, in Fletcher, North Carolina (the Site). The lagoon location is shown on the attached Figure 1, Figure 2, and Figure 3. The Fletcher Academy connected to a municipal sewer system on March 5, 2021, and therefore has closed the existing lagoon and wastewater treatment system. Headwater submitted the Lagoon Assessment Plan—Revision 3 on February 12, 2020 (Headwater 2020a) to the North Carolina Department of Environmental Quality (DEQ) Division of Water Resources (DWR). The sludge/residuals assessment portion of the plan was approved by DEQ on November 13, 2019, and the full Assessment Plan was approved by email on February 13, 2020. Following assessment activities, Headwater submitted a Lagoon Assessment Report to DEQ on June 11, 2020 (Headwater 2020b). Following review and correspondence with DEQ, the DEQ requested that a dewatering plan be prepared to describe the plan to drain and ultimately close the lagoon. A dewatering plan was submitted to DEQ and to the Buncombe County Metropolitan Sewerage District (MSD) on September 22, 2020. The dewatering plan was approved in an email from DEQ sent on October 2, 2020. Subsequently, the Lagoon Assessment Report and Closure Plan (Headwater 2020c), dated October 6, 2020, was revised to include both the assessment results, the dewatering plan, and additional detail regarding sludge removal. Lagoon closure activities were performed in general accordance with the Lagoon Assessment Report and Closure Plan. Any variations to the plan were performed in coordination with DEQ and MSD. Lagoon dewatering, sludge removal, and lagoon closure activities are documented herein. 1.1 Lagoon Background Information Wastewater generated by the Fletcher Academy, Captain Gilmer Christian School, Fletcher Park Inn Retirement Community, AdventHealth Hendersonville Hospital, and multiple private residences was treated by the Site lagoon and associated infrastructure. The Site wastewater treatment system (WWTS) is associated with National Pollutant Discharge Elimination System (NPDES) permit number NC0036641. Treated wastewater was discharged to Byers Creek. A new municipal sewer line, associated with the Cane Creek Sewer District, was constructed to connect this waste stream to the Buncombe County MSD municipal sewer system. The new sewer line was connected on March 5, 2021. Headwater understands that the original permit was issued in October 1988. According to the permit, the Site lagoon is composed of a 2.094 million-gallon, clay-lined, earthen lagoon subdivided into four cells, separated by floating curtains. Floating aerators were also present in the lagoon. Influent would enter the lagoon on the eastern end where it was aerated and would Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology 2 progress westward through the lagoon. Prior to discharge, wastewater was chlorinated and subsequently de-chlorinated by infrastructure located at the southwestern corner of the lagoon. The lagoon is approximately 400 feet long by 100 feet wide. Headwater was provided a sludge monitoring data prepared by the Fletcher Academy that indicated sludge thickness was measured at approximately 0 to 60 inches between 2007 and 2014. This report indicated that the lagoon water depth ranges from approximately 7 to 10 feet. A probiotic solution had been applied during this time period to reduce sludge thickness. Three monitoring wells located adjacent to the lagoon were installed in 1986 and sampled annually or bi-annually until the requirement to monitor groundwater was removed from the permit in September 1998. According to a memo sent on September 16, 1998 from Kay Dechant to Bob Cheek, through Don Link (representatives of the North Carolina Department of Environment and Natural Resources, Division of Water Quality), the facility has shown no exceedances of groundwater standards except for sporadic coliform. Surface water and groundwater sampling performed during Headwater’s assessment also did not indicate the presence of contaminants in surface or groundwater (Headwater 2020c). 1.2 Lagoon Assessment and Closure Plan Summary Lagoon assessment activities were performed in general accordance with the July 2007 North Carolina Department of Environment and Natural Resources (DENR) Guidelines for the Closure of Treatment Ponds and Lagoons (DENR 2012) as well as the Lagoon Assessment Plan— Revision 3 (Headwater 2020a). Results of this assessment are documented in the Lagoon Assessment Report and Closure Plan (Headwater 2020c), dated October 6, 2020. Assessment activities included:  Assessment for the presence and thickness of sludge in the lagoon  Collection of sludge samples for laboratory analysis  Collection of surface water and groundwater samples for laboratory analysis Based on the sludge thickness evaluations, approximately 2,500 cubic yards of sludge were estimated to be present in the lagoon. The majority of sludge was observed in Cell #3 and measured up to 6 feet thick, with lesser amounts in Cell #4 and Cell #2. Only trace amounts of sludge were observed in Cell #1. Approximate sludge thickness is shown on Figure 2. Analytical results indicated that the sludge does not have the potential to leach constituents at Resource Conservation and Recovery Act (RCRA) hazardous concentrations. The sludge is rich in nitrogen compounds and phosphorous and contains elevated concentrations of fecal coliform bacteria. There were no constituents detected above applicable standards in surface water or groundwater. The results of the surface and groundwater sampling indicate that the lagoon liner was functioning Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology 3 properly, and surface and groundwater have not been impacted by the lagoon. Surface and groundwater sample locations are shown on Figure 3. Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology 4 2 Lagoon Closure Lagoon closure included the following primary steps:  Lagoon dewatering  Sludge Removal  Lagoon berm, structures, and clay liner demolition and Site stabilization Lagoon dewatering began after the lagoon was disconnected from additional effluent on March 5, 2021 (when the new sewer line connection occurred). Dewatering was substantially completed by mid-April 2021 when additional water floating on sludge could not feasibly be removed without entraining sludge in the discharge. Sludge management, solidification, and transport was performed by Advanced Environmental Options (AEO), located in Spartanburg, South Carolina and was performed from mid-March until June 3, 2021, when sludge removal was completed. Spading of the clay liner of the bottom of the lagoon began in mid-May 2021. The lagoon berm was collapsed and grading of the lagoon area, to provide positive drainage, was completed by AEO the week of June 14, 2021. A detailed summary of these steps is included in the following subsections. A photographic log is included as Appendix A. 2.1 Lagoon Dewatering The lagoon was disconnected from additional influent on March 5, 2021, when the facility was connected to the municipal sewer. Discharge of effluent continued through the NPDES permitted discharge during March 5, 6, and 7, 2021 until the water level in the lagoon was at the same level as the highest effluent collection line in the lagoon. This line was located at a depth of about 2 feet below the former lagoon surface. Discharge of lagoon wastewater to the sewer system began on the afternoon of March 8, 2021. This discharge was performed using a pump connected to an intake floating in the middle of Cell #1 of the lagoon. Initially, a filter fabric box was placed around the intake of the pump. However, based on turbidity measurements of the effluent and in the lagoon itself, the filter fabric box was removed, as it was contributing to a reduced flow rate and the filter fabric was difficult to replace with clean fabric. Water was pumped from the lagoon to former sewer piping infrastructure that previously discharged to the lagoon. Using this infrastructure, wastewater could be metered through the existing weir meter. After the meter, additional pipe infrastructure diverted the discharge into a sewer manhole associated with the newly constructed sewer line. Turbidity of the discharge was measured approximately every 30 minutes using a Hach turbidity meter to ensure water clarity was 75 Nephelometric Turbidity Units (NTUs) or less. Note that in coordination with Mr. Roger Edwards (MSD), the turbidity limit was later raised as described Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology 5 herein. Biological oxygen demand (BOD) was measured approximately bi-weekly and total suspended solids (TSS) was measured approximately weekly by James and James Environmental Mgt. Inc. during discharge events. A second pump was soon added to the dewatering system so that initial pumping rates ranged from about 85 to 170 gallons per minute (GPM). However, pumping was stopped on March 12, 2021, due to increasing turbidity levels. As sludge was exposed in the middle of the lagoon, it began migrating outward. Also, small streams of water were observed flowing from water that had pooled in Cell #4, across sludge mounded in the middle of the lagoon, and toward the pump intake in Cell #1. This resulted in increased turbidity levels. The water and sludge level in the lagoon was measured at about 4.5 feet deep at this point. By March 17, 2021, pumping was performed using small sump pumps at a rate of about 5 GPM. Prior to discharge, the effluent was pumped through drum filter systems consisting of an approximately 50-gallon plastic drum with the top cut off, filled from the bottom with a layer of stone, filter fabric, washed sand, and an additional layer of filter fabric. The top layer of filter fabric would need to be replaced every 4 to 6 hours of pumping. The drum filters reduced the turbidity of the water in the lagoon from approximately 250 to 170 NTUs. However, TSS samples collected of this effluent and the corresponding lagoon source water indicated that TSS was reduced from 276 milligrams per Liter (mg/L) to 14 mg/L as indicated by samples collected on March 17 and 18, 2021. Mr. Adam Tripp with Headwater discussed these results with Mr. Roger Edwards with MSD on March 19, 2021. Mr. Edwards suggested that turbidity measurements for water pumped through the sand filter could be used as a subjective guide since they were not well correlated with TSS, and ultimately TSS was a better measurement of solids/sludge being entrained in the effluent. Mr. Jason McDonald with FAI and Mr. Tripp had previous conversations with Mr. Edwards regarding challenges removing water and meeting the initial turbidity limits of 75 NTUs. Mr. Edwards had suggested increasing the turbidity limits incrementally, eventually up to 175 NTUs for water that did not pass through the sand filter. Additionally, certain exceptions to the 175 NTU limit were made for specific dewatering periods based on discussions between Mr. McDonald and Mr. Edwards. On March 17, 2021, an earthen dam was constructed in the middle of Cell #1. The contents of the eastern side of the earthen dam were pumped into two sludge dewatering bags. The rate of filtration through the dewatering bags decreased rapidly. The eastern portion of Cell #1 was then converted into a sludge solidification pit. The filter bags used were an Interstate Products Ultra- Dewatering Bag 9725-O/S Oil & Sediment Model, 10' x 15' with pore rating of 80 Microns. By March 23, 2021, the majority of accessible water had been removed from the remainder of the lagoon. After rain events, water was pumped directly from the surface of the lagoon at a rate of about 85 GPM. When pumping in this manner was no longer feasible, water was pumped though sand filters using small sump pumps at about 5 GPM. Although there were still areas of ponded water above sludge, it was difficult to pump this water as the sludge layer was very close to the Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology 6 surface of the water and pumping could not easily be performed without entraining sludge in the effluent. The sludge/water depth at this point was approximately 4 feet deep. Subsequent pumping of wastewater was performed only after rain events. On April 4-5, 2021, water that had accumulated on top of sludge in Cell #4 that could not flow to the other end of the lagoon was pumped to the eastern end of the lagoon, adjacent to Cell #1. After a period of settling, this water was then pumped into an additional filter bag. The filter bag performed better by keeping the inlet hose at the surface of the water, connected to the back of a boat partially anchored to the bank to modulate the depth of the hose intake. Using the filter bag in this manner was much more successful for filtering water. A sample of the filtered water was collected on April 5, 2021 and TSS was measured at 642 mg/L. Mr. McDonald discussed these results with Mr. Edwards and estimated that less than 10,000 gallons of wastewater may be removable in this manner. Based on the relatively low volume, Mr. Edwards suggested that water pumped through the filter bag was acceptable for discharge to the sewer. A summary of TSS, turbidity, and BOD measurements is as follows, as shown in the attached lab reports provided by James and James Environmental (Appendix B). Date TSS (mg/L) Turbidity (NTU) BOD (mg/L) March 10 25.0 55 42 March 11 78.0 66.5 March 12 144.0 75 March 17 276.0 (lagoon water, prior to pumping, not filtered) >1000 417 March 18 14.0 (after sand filter) 144 March 22 26.0 132 March 26 97.3 326 >85.0 March 29 10.4 153 41.7 March 30 34.7 198 April 2 81.5 >1000 April 5 642 (after pumping through filter bag) >1000 Notes: TSS – Total Suspended Solids mg/L – milligrams per Liter NTU - Nephelometric Turbidity Units BOD – Biological Oxygen Demand A total of 1,017,100 gallons of water was discharged from the lagoon to the new sewer system for eventual treatment by MSD. Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology 7 2.2 Sludge Solidification and Disposal Sludge solidification, transport, and disposal was performed by AEO between mid-March to June 3, 2021. During the dewatering process, on March 17, 2021, an earthen dam was constructed in the middle of Cell #1. After the water on the eastern side of the berm was substantially removed, this area was used as a solidification pit. It was later modified into two solidification pits to allow for solidification and loading to occur simultaneously in separate pits. The first pit was located directly adjacent to the berm so that sludge could be moved from the lagoon by excavator bucket directly into this pit. A second pit was located adjacent to the access road to the north of the first solidification pit so that the second pit could be used for loading. Solidification was performed by adding a super absorbent polymer (SAP) that was a byproduct of the manufacture of diapers. Generally, sludge would be placed in the first solidification pit and would be mixed with SAP and allowed to solidify overnight. The solidified sludge would then be moved to the second pit used for loading and would be loaded into dump trucks for transport to the landfill. Additional SAP would be added as needed. The process would then be repeated. Note that a solidification pit was also constructed and used at the western end of the lagoon early in the project to remove sludge from Cell #4. However, this solidification pit was later emptied and abandoned in favor of the pits constructed at the eastern end of the lagoon in Cell #1. As sludge was removed from the lagoon and the sludge level was reduced, the sludge was pushed inward and eastward, toward the solidification pits in Cell #1. This was accomplished by using the excavator bucket to push a portion of the lagoon wall downward so that it would displace sludge and effectively move the lagoon wall inward and eastward. Solidified lagoon sludge was transported to Santek Environmental of North Carolina’s White Oak Landfill, located in Waynesville, Haywood County, North Carolina under an approved waste profile. A total of 3,393.62 tons of solidified sludge was disposed of at the White Oak Landfill. Once the lagoon or a particular cell was free of residual sludge, Headwater contacted Mr. Brett Laverty of the DEQ to visually inspect the lagoon or cell(s) and to confirm that the lagoon or cell was “closed” and no longer subject to wastewater treatment requirements. Mr. Laverty visited the Site on May 21, 2021 and June 4, 2021 to perform inspection of sludge removal progress and completion. Specifically, Mr. Laverty observed that sludge had been removed from approximately midway through former Cell #2 to the end of Cell #4 on May 21 and observed that all sludge had been removed from the entire lagoon on June 4, 2021. Note that confirmation soil samples of the base of the lagoon were determined to be unnecessary because the sludge was determined not to contain hazardous materials and therefore neither would the liner (Headwater 2020c). Waste manifests are included in Appendix C. 2.3 Lagoon Structure and Liner Demolition After sludge had been removed from the lagoon, the clay liner was compromised. The liner was “spade” which consists of scooping a bucket of clay liner and laying it to the side with the excavator Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology 8 bucket. This method meets the goal of preventing the clay liner from holding water and helped to dry the clay by better mixing it with surrounding residual soils. After compromising the liner, the lagoon structure was then properly decommissioned by breaching the southern berm of the lagoon and collapsing it inward so that the soil composing the berm was used to fill the lagoon. The fill soil was placed and graded so that the Site gently slopes to the south. Soil was compacted by tracking heavy equipment across the soil. At the completion of grading activities, the Site was stabilized with grass and straw matting. 2.3.1 Additional Structure Demolition Influent piping was removed and disconnected from the waste stream at the location where the new sewer line intersected the existing sewer infrastructure. Effluent piping was removed from the lagoon and remaining piping was abandoned in place at a location approximately 30 to 40 feet south of the former southern berm of the lagoon. The curtains used to divide the cells in the lagoon were removed and disposed of as construction and demolition debris. Additional concrete infrastructure associated with water treatment processes at the southwestern edge of the lagoon was demolished, crushed, and used as fill material within the collapsed lagoon structure. The chlorine building and main building were also demolished and disposed of as construction and demolition debris. Power poles were also removed and repurposed. Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology 9 3 Conclusions and Recommendations The lagoon was drained and a total of 1,017,100 gallons of water was discharged to the new sewer system. Lagoon residuals were solidified and properly disposed of at the White Oak Landfill located in Haywood County. A total of 3,393.62 tons of residuals/sludge were disposed. The clay liner at the base of the lagoon was compromised so that it would no longer hold water and the lagoon’s southern berm was collapsed inward and graded so that the Site would drain properly. The Site was then stabilized with seed and straw matting. Lagoon infrastructure, including influent and effluent piping, power poles, buildings, and concrete structures were demolished. Wastewater that formerly was treated in the lagoon now discharges to a new sewer line associated with the Cane Creek Sewer District and connected to the Buncombe County MSD municipal sewer system. Based on these results, Headwater recommends that the Site’s NPDES permit (# NC0036641), be rescinded and a letter of “No Further Action” be issued for the project. Restrictions associated with potential future Site usage are not recommended. Wastewater Treatment Lagoon—Lagoon Closure Report Headwater Geology 10 4 References DENR (North Carolina Department of Environmental and Natural Resources) 2012. North Carolina Department of Environment and Natural Resources Guidelines for the Closure of Treatment Ponds and Lagoons. June 22, 2012. Headwater 2020a. Lagoon Assessment Plan—Revision 3. February 12, 2020. Headwater 2020b. Lagoon Assessment Report. June 11, 2020. Headwater 2020c. Lagoon Assessment Report and Closure Plan. October 6, 2020. FIGURES 9/27/2019 NJC Date : Prepared by : 02,0004,0001,000 Feet ¯ Legend Site boundary FIGURE 1 LOCATION MAP Flether Academy Lagoon PJs Place Fletcher, Henderson County North Carolina Headwater Project # A19-146 SOURCE USGS 7.5-minute Topographic Quadrangle Fruitland, North Carolina (2001) Hendersonville, North Carolina (2001) Skyland, North Carolina (1991) Contour Interval = 20 feet Horse Shoe, North Carolina&RQWRXU,QWHUYDO IHHW 1 inch = 2,000 feet Approximate site location !( !( !( !( !(!( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !(!( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !(!( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !( !(1234 0.51.552.53.5 0 4.55.563.5 002 3 0.5 0 01.50 1 3 2.5 3.500.5 3.5 2300!( 3/31/2020 NJC Date : Prepared by : 0 50 10025Feet 1 inch = 50 feet¯ FIGURE 2SLUDGE THICKNESS MAP Flether Academy Lagoon PJs PlaceFletcher, Henderson County North CarolinaHeadwater Project # A19-146 Legend Cells Pipe !( Sludge probe location Contour (ft) Sludge thickness (ft) High : 6.076 Low : 0 SLG-3 SLG-2 SLG-4 Cell 1 Cell 2 Cell 3 Cell 4 SOURCE NC One MapDigital Orthoimagery (2015) Note: Composite sediment samples SLG-2, SLG-3, and SLG-4 were collected from cells 2, 3, and 4, respectively. # # ! !!SW-3 SW-2 SW-1 PZ-1 PZ-2 Byers Creek4/13/2020 NJC Date : Prepared by : 0 80 16040Feet 1 inch = 80 feet¯ FIGURE 3SURFACE AND GROUNDWATER SAMPLE LOCATION MAP Flether Academy LagoonPJs PlaceFletcher, Henderson County North CarolinaHeadwater Project # A19-146 SOURCE NC One MapDigital Orthoimagery (2015) Legend Cells Stream/River #Peizometer !Surface water sample Cell 1 Cell 2 Cell 3 Cell 4 InfluentPipe EffluentPipe APPENDIX A: Photographic Log Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 1 Photograph 1: Operating lagoon at full level (2019-08-29). Photograph 2: Lagoon after being disconnected from effluent and prior to initiating pumping to the sewer (2021-03-08). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 2 Photograph 3: Wastewater pumped from the lagoon was pumped to the concrete pad in the background. Wastewater would than flow through existing piping to the metering manhole on the right (2021-03-08). Photograph 4: Wastewater pumped from the lagoon would exit the metering manhole (out of view to the left), then enter the drum with access port for sampling, and exit the drum through piping to discharge into a new sewer manhole (2021-03-08). . Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 3 Photograph 5: Sewer manhole where former influent to the lagoon was plugged (2021-03- 10). Photograph 6: Former influent piping and pumps dewatering the lagoon (2021-03-10) Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 4 Photograph 7: Lagoon during dewatering (2021-03-10). Photograph 8: Lagoon during dewatering (2021-03-11). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 5 Photograph 9: Lagoon during dewatering, Cell #1 and #2 (2021-03-11). Photograph 10: Lagoon during dewatering at Cell #2 and #3 (2021-03-11). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 6 Photograph 11: Turbidity measurement sample during dewatering (2021-03-11). Photograph 12: Lagoon during dewatering. One of the curtains dividing the cells is in the foreground (2021-03-12). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 7 Photograph 13: Lagoon during dewatering following a rain event and during dam construction in the middle of Cell #1 (2021-03-16). Photograph 14: Lagoon during dewatering following a rain event and during dam construction in the middle of Cell #1 (2021-03-17). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 8 Photograph 15: Dewatering of the solidification pit constructed in the eastern end of Cell #1. Water and solids are being pumped into filter bags. (2021-03-22). Photograph 16: Solidification pits in Cell #1 with dewatering bags in the background (2021-03-29). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 9 Photograph 17: Solidification pit and lagoon during dewatering. Pump intake on the end of a boat can be seen in the left of the photograph (2021-03-29). Photograph 18: Temporary solidification pit adjacent to Cell #4 (2021-03-29). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 10 Photograph 19: Additional dewatering bags used to filter water pumped from the lagoon (2021-04-05). Photograph 20: Solidification pits in the foreground with lagoon in the background (2021- 04-06). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 11 Photograph 21: Solidification pits in the foreground with lagoon in the background (2021- 04-13). Photograph 22: Solidification pits in the foreground with lagoon in the background (2021- 04-13). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 12 Photograph 23: Solidification pits in the foreground with lagoon in the background (2021- 04-20). Photograph 24: Excavator pressing lagoon berm downward and inward to move sludge toward the solidification pits (2021-04-20). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 13 Photograph 25: Solidification pits with the lagoon in the background (2021-04-27). Photograph 26: Loading of sludge for transport (2021-05-06). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 14 Photograph 27: Lagoon (2021-05-06). Photograph 28: Solidification pits and lagoon (2021-05-14). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 15 Photograph 29: Solidification pits and lagoon (2021-05-18). Photograph 30: Exposed section of clay liner (2021-05-18). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 16 Photograph 31: Solidification pit and lagoon (2021-05-20). Photograph 32: Solidification pit and lagoon (2021-05-21). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 17 Photograph 33: Solidification pit and lagoon (2021-05-27). Photograph 34: Cleaning out the primary solidification pit. Sludge has been removed from the lagoon. Dewatering bags have been ruptured and solidified (2021-06-01). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 18 Photograph 35: Concrete structures on southern berm have been demolished (2021-06- 01). Photograph 36: Concrete structures on southern berm have been demolished (2021-06- 01). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 19 Photograph 37: Sludge has been removed from lagoon and solidification pits (2021-06- 04). Photograph 38: Chlorine building and additional infrastructure has been removed (2021- 06-04). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 20 Photograph 39: Southern berm has been collapsed and lagoon has been graded (2021- 06-10). Photograph 40: Straw mat and grass seed have been applied to the graded lagoon area (2021-07-15). Site Photos Fletcher Lagoon Closure—Headwater Project # A19-146-01 Photographs taken in 2019, 2020, and 2021 Page 21 Photograph 41: Grass is growing on the graded lagoon area (2021-09-24). APPENDIX B: James and James Laboratory Analytical Report James & James Environmental Management, Inc. 3801 Asheville Hwy. Hendersonville, NC 28791 Office (828) 697-0063 office@jjemi.net Client: NC PERMIT:NC0036641 Matrix:Wastewater Location:EFF Collected By: Results Units 21.5 mg/L 42 417 >85.0 41.7 ANALYTICAL RESULTS FLETCHER ACADEMY 185 FLETCHER ACADEMY DR FLETCHER, NC BOD Juanita JamesC0221 DATE FLE-BOD-MARCH 2021 Parameters Initial DAVIS JAMES Juanita JamesC1021 Juanita JamesC2621 C1721 Juanita James C2921 Juanita James James & James Environmental Management, Inc. 3801 Asheville Hwy. Hendersonville, NC 28791 Office (828) 697-0063 office@jjemi.net Client: NC PERMIT:NC0036641 Matrix:Wastewater Location:EFF Collected By: Results Units 25 mg/L 78 144 276 14 26 97.3 10.4 34.7 81.5 642D0521 Juanita James Juanita JamesD0221 C3021 Davis James Davis JamesC2921 C2621 Davis James Davis JamesC2221 C1821 Davis James Davis JamesC1721 C1221 Davis James Juanita JamesC1121 TSS Juanita JamesC1021 DATE TSS-MARCH 2021 Parameters Initial DAVIS JAMES ANALYTICAL RESULTS FLETCHER ACADEMY 185 FLETCHER ACADEMY DR FLETCHER, NC APPENDIX C: Waste Manifests