Ltr to A. Pitner, NCDEQ RE Linco Response and Lagoon Closure Plan 05 04 23.PDF

STITES & HARBISON PLLC
A T T O R N E Y S
May 4, 2023
VIA EMAIL TO: andrew.Pitner(&ncdenr.gov
Andrew H. Pitner, P.G.
Acting Regional Supervisor
Morehead Regional Office
Division of Water Resources
North Carolina Department of Environmental Quality
512 North Salisbury Street
1611 Mail Service Center
Raleigh, NC 27699-1611
250 West Main Street
Suite 2300
Lexington, KY 40507-1758
[phone]
[phone] FAX
www.stites.com
William T. Gorton III
[phone] DIRECT
[phone] MOBILE
[phone] FAX
Wgorton(c.Stites.com
KY Bar #: 83623
PA Bar #: 53009
RE: Response and Lagoon Closure Plan
Linco Partnership Permit No. WQ0003924 Wastewater Irrigation System
Lincoln County, North Carolina
Dear Mr. Pitner,
On behalf of Linco Partnership ("Linco"), owner of property located at 288 Whitehouse
Drive, Lincolnton, North Carolina 28093 ("Site" or "Property"), this letter responds to your April
5, 2023 letter. The discussions describe the rationale behind the sequencing and provide a status
report of the full spectrum of remedial activities at the property, including those of concern to the
NCDEQ Division of Water Resources ("Division"), along with plans for addressing remaining
Site conditions including the lagoon closure. Finally, we respond to the NOVs cited in your
letter.
The recent letter regarding the status of conditions at the Property and NOVs seems to
presume that the wastewater facilities, formerly operated and abandoned by former tenant,
Celadon Recycling Solutions ("Celadon"), was/is operational rather than a component in the
comprehensive Property remediation project once Linco was contracted. The letter does not
recognize the necessary orderly approach undertaken by Linco in remediating the many
environmental violations that Celadon was allowed to accumulate during its tenure at the Site
and the significant work and expense that Linco, as the Property owner, has and continues to
experience since becoming aware of actual Site conditions and violations.
It wasn't until January 22, 2021 that Linco was even informed of Site and operational
violations by Celadon until requested to attend a conference call with numerous state and federal
agencies who had been observing and investigating Celadon's activities for several years. It was
only during that conference call that Linco became aware of an open floodgate of environmental -
related violations and Site conditions created by Celadon requiring investigation, planning and
ultimately, costly remediation.
www.stites.com

STITES &HARBISONPLLC
A T T 0 H N E Y 5
Andrew H. Pitner, P.G.
May 4, 2023
Page 2
As a result of those investigations, upon learning of the Celadon practices, and in order to
get its Property in compliance and to protect its investment, Linco engaged this firm and North
Carolina engineering/environmental consultants to immediately began investigations to
understand the situation and develop an economically feasible and practicable framework to
comprehensively address the multimedia concerns. Those initial efforts included extensive
discussions and interviews with representatives of the U.S. Environmental Protection Agency
("EPA") including Region 4 attorneys and multiple divisions within the North Carolina
Department of Environmental Quality ("NCDEQ") resulting in Linco agreeing to undertake the
obligations as described below, in good faith as a remediation/abatement context, not as the
operator.
Apparently, it was well known by the regulatory agencies that the Celadon operation was
problematic, as we were also informed that state and federal environmental criminal
investigations of Celadon were being conducted. It appears, however, that no administrative,
civil or criminal charges were brought against Celadon or its operating officials, rather, the
agencies decided to eventually engage Linco. Nevertheless we are pleased to say that many of
the concerns originally expressed by the Division have been addressed and the remaining ones,
as discussed below, are scheduled for active remediation or closure this year.
REMEDIATION PLAN TASKS AND STATUS
The following discussions address the sequencing of tasks undertaken, underway and
planned by Linco in remediating Site conditions left by Celadon.
• Orderly Investigations: Triage Remediation Projects.
From a starting point of not understanding anything about the Site conditions and to
address the multiple issues associated with the Celadon operation in an orderly fashion, the
Linco representatives discussed with EPA officials and EPA Region 4 counsel along with senior
administrators at NCDEQ (including your Division) that in cooperation with regulatory officials,
Linco would triage the Property conditions in order to determine which concerns were of highest
priority. As a matter of fact, the plan was the subject of a letter to Cory Bassinger dated May 3,
2021 (See Attachment A). It was very difficult to understand not only the history and business
operations of Celadon (and its relationships to similar sites), but the nature and extent of
Celadon's malfeasance in general and question how Celadon was able to improperly operate such
regulated activities.
• NCDEQ Suspected Hazardous Waste Totes.
With the recommendation of the state and federal agencies, it was decided that the first
issues to be addressed would be the NCDEQ-identified z300 totes on -site suspected by NCDEQ
of containing hazardous waste similar to the Hudson Site. After significant study of the

STITES &HARBISONPLLC
A T T 0 H N E Y 5
Andrew H. Pitner, P.G.
May 4, 2023
Page 3
situation, Linco addressed that situation by contracting with two hazardous -waste testing and
disposal entities, U.S. Waste Inc. and HazMat. Those suspected totes were sampled, tested,
classified, and disposed at significant expense to abate the immediate concerns raised by both
agencies.
Along with addressing the "suspect" 300 totes, Linco continued Site analysis to locate
many other suspected hazardous waste totes and barrels scattered and hidden throughout the
entire facility and other buildings and to inventory, classify, and organize over 2,800 totes.
Many "open" top totes containing various unidentified viscous and sludge materials found in the
main building and other out -buildings were also identified, tested and ultimately disposed.
• Initial Lagoon Testing.
In response to the Division and EPA's expressed initial concerns about the lagoon, which
your staff (and EPA) suspected of containing hazardous constituents, concurrently with finding
and organizing other suspect totes, Linco engaged Shield Engineering to conduct water quality,
sludge sampling and laboratory testing of the on -site lagoon and EQ Tank. The report, dated
July 2021, was submitted to EPA and NCDEQ. Those results demonstrated that the fluids were
not hazardous and actually meet the North Carolina requirements for wastewater treatment
facilities. With that positive demonstration, activities continued according to the sequence of
dealing with high NCDEQ/EPA priority issues.
• Pits Waste Disposal/Remediation.
As part of the protocols for addressing water -related features at the facility, Linco
engaged HazMat to sample, test, drain, de -sludge and clean the two -chamber pit at the rear of the
facilities, which was completed on June 14, 2021, as reported by Shield Engineers to Ed Watson.
Shortly thereafter, and following further discussions with Mr. Watson, Linco engaged HEPACO
to sample, test and address the major water and sludge over -capacity concrete pit at the front of
the structure, which was remediated between February 10-23, 2022. Both projects are described
in the report dated September 22, 2022 (See Attachment B and pictures).
• EQ Tank.
Continuing with the orderly sequence of the remediation/closure plans, the next major
task in addressing concerns at the facility, particularly one of primary concern within your
jurisdiction, was addressing the EQ Tank, which contained approximately 350,000 gallons of
fluids. Those efforts included sampling, testing, planning, seeking qualified vendors and
ultimately contracting with Shamrock Environmental for fluids and sludge testing and disposal.
Those significant efforts abated any danger of overflow addressing one of the major fluids -
related facilities on the Property. Those efforts were described in a letter report from Linco's
engineers dated January 24, 2023 (See Attachment C and pictures). The EQ Tank stainless steel

STITES &HARBISONPLLC
A T T 0 H N E Y 5
Andrew H. Pitner, P.G.
May 4, 2023
Page 4
is a subject of interest to various scrap metal recycling vendors and will be addressed for removal
later this year. It is disconnected from any internal building facilities.
Along with the EQ Tank, Celadon stored (hid) wastewater in numerous vessels and tanks
throughout the Property including a tanker truck, two portable frac tanks and other above -ground
storage tanks. As part of the EQ Tank remediation project, those vessels were also addressed.
• 2.800 Totes Disnosal.
Since engaging the remediation project, Linco had been studying the nature and extent of
the 2,800 IBC fluid and sludge -containing totes that had been illegally accumulated on the
Property. A major aspect of this task has been inventorying, classifying, moving the totes and
organizing them for handling by contractors. Linco consulted with numerous technical
professionals, interviewed former Celadon employees, other tote wastewater treatment
companies and experienced contractors (including those involved at the Hudson site), developed
tote testing protocols in cooperation with NCDEQ, solicited and evaluated proposals ultimately
contracting with HEPACO for the sampling, testing, fluids, sludge handling and tote disposal.
Those intensive multi -task efforts are presently underway and are expected to be completed this
summer.
• Celadon Facilitv/Eauibment Dismantling and Removal.
Concurrently with the initiation of the tote sampling, testing and materials disposal, Linco
arranged for the dismantling and removal of the Celadon water and wastewater facilities and
equipment housed in the structure. After dewatering the equipment, all but one piece has been
removed from the building, all of which will be moved offsite by sale or scrapping (See pictures,
Attachment D).
• Laizoon Closure.
As has been discussed with you and members of your staff numerous times, it was and
continues to be Linco's intention to pursue Site remediation in good -faith by addressing the
priority issues and economically feasible manner. Once it was determined that the lagoon had
good water quality and was only subject to receiving precipitation, it was logical to defer the
lagoon closure task until the other high -priority and expensive waste -related issues were
addressed. Linco is now turning its attention to the closure plan for the lagoon and the proposed
Lagoon Closure Plan, which will be forwarded by Linco's engineers.
• Summary.
As discussed above, you can see that Linco has demonstrated good faith and cooperation
and been more than responsive to regulatory obligations in order to abate environmental risks,

STITES &HARBISONPLLC
A T T 0 H N E Y 5
Andrew H. Pitner, P.G.
May 4, 2023
Page 5
bring the Property into environmental compliance and protect economic interests that it may still
have in the Property given the facts and circumstances of this entire matter. Although it was not
the operator that created the violating conditions on the Property, nobody can doubt that Linco
has stepped up to address them and plans to continue the process until the Property is restored to
its pre-Celadon condition.
NOV-,
The following discussions address the "continuing" violations cited in your April 5, 2023
letter and also provide information related to how Linco will address those relevant and
applicable concerns as appropriate for the Site conditions. It is clear that most of the violations
preceded Linco's remediation efforts and are the result of Celadon's non-compliance activities.
Violation No. 1 - Operator in Responsible Charge. As we have discussed several times,
there have been no operations on the Site of which to be in charge. As noted above, Linco's
activity on its Property is a 100% remediation project and no operations under the permit have
taken place at all since remediation activities began. Further, the activities taken by Linco to
have the Celadon systems dismantled and removed, the EQ Tank disconnected, dewatered and
de-sludged, clearly indicate that there have not been and are no permit -related active operations
whatsoever at this time. Notwithstanding those facts, when the lagoon closure activities do
begin, as discussed in the attached Lagoon Closure Plan, Linco intends to acquire the services of
an appropriate certified professional to be responsible for those efforts.
Violation No. 2 - Operation and Maintenance.
a) Equipment. As discussed above, the mechanical portions of the Celadon facilities
ceased operations prior to Linco's remediation project. Fluids were removed and disposed and
the system has been totally dismantled with the exclusion of the pump house below the EQ Tank.
There were no operations at all after Celadon abandoned the Site and maintenance of those
aspects of the system is moot.
Linco has taken every step to prevent the discharge of any wastewater that might have
been contained in the system from being discharged. Those activities included pumping and
cleaning the external pits and draining and disposing all the materials in the EQ Tank, which was
at capacity and other vessels. Linco has worked in good faith to address the potential of
diverting or bypassing wastewater.
b) Sump Pits. The sump pits identified in the April 5, 2023 letter at the rear of the
building have been tested and cleaned and are being retested at the request of the Division to
demonstrate that any water in them is rainwater from the parking lot and not wastewater. Those
results should be available in the very near future. As part of its final internal building cleanup,
Linco plans to have the floor drains washed following the ongoing tote removal program.

STITES &HAR.BISONPUC
A T T 0 H N E Y 5
Andrew H. Pitner, P.G.
May 4, 2023
Page 6
c) Lagoon Liner. Regarding the lagoon, the Division was aware that the lagoon liner
was damaged when Celadon operated at the Site and as discussed above, that closing the lagoon
was deemed to be the final task in remediating the entire facility in light of the other Site
conditions creating the threat of seeps or leaks from on -site totes and drums that were allowed to
accumulate. Further, it is economically infeasible and impracticable to repair and replace the
liner and such effort would be for naught as the Lagoon Closure Plan calls for complete lagoon
liner removal including disposal of the liner once the water is drained. It is anticipated that those
activities will be completed during the 2023 construction season.
Violation No. 3 - Site Monitoring. As noted above, there has been no activity on the Site
whatsoever associated with the permit since Celadon abandoned the Site. Celadon's equipment
has not been used at all. Linco's on -site representative, Alan Lynch, has conducted monthly
lagoon water levels, which can be made available, however, the facility was and is inoperable.
Overall, there was no quantitative permit activity to monitor, and Linco's financial resources
have been used for substantive abatement and remedial activities. The EQ Tank (and numerous
other tanks and fluid storage vessels) have been completely drained of any wastewaters and any
reporting requirements related to it are also moot.
CONCLUSION
Linco, in cooperation with North Carolina and EPA officials, has engaged in a
comprehensive Site remediation program on its Lincolnton property at great expense. Many of
the conditions created by Celadon that accumulated over several years have and are being abated
in good faith by Linco. Linco respectfully requests that the Division take no further
administrative actions on this matter as it continues to make substantial progress in completing
the remediation activities remaining on the Property. As Linco prepares to address the lagoon
closure, we look forward to your support and cooperation.
Sincerely,
William T. Gorton III
WTG/lhr
Attachments
cc: Linco
CDG Engineers
Brent Burch
864677:6

Attachment A
Linco Partnership
5200 Old Harding Road
Franklin, TN 37064
Office 615-799-0933
May 3, 2021
VIA EMAIL AND USPS MAIL TO: c�►rcy.hasin��cr�n ncdcnr.�o�
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
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

Attachment B
SHIELD
ENGINEERING
September 22, 2022
Via email
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Subject: Report of Back Pit and Front Pit Closure
Former Celadon Recycling Facility
Linco Partnership
Lincolnton, NC
Shield Project No. 1210037
Dear Mr. Watson,
On behalf of Linco Partnership (Linco), the property owner of the former Celadon Recycling
Solutions operation, Shield Engineering (Shield) is presenting this report documenting the closure
of two pits (Back Pit and Front Pit) formerly containing waste at the facility.
Pit Locations and Descriptions
Back Pit
The Back Pit is located in a small outbuilding located east of the southern portion of the main
building. The pit is made up of two chambers constructed of formed concrete that were once
used by Celadon as a settling pit. Currently the pit only receives stormwater from building
downspouts and drop inlets around the building. Stormwater is accumulated by the collection
system and routed to a trunk line that enters the pit. There is no effluent piping from this pit.
Front Pit
The Front Pit is located near the facility office front door. It is uncovered and also constructed of
formed concrete. We are informed that it occasionally received wastewater from customers
tanker trucks and also waters originating inside the plant building. The Front Pit was once used
as a waste settling pit. This pit has no effluent discharge piping.
4301 Taggart Creek Road www.sliieldeneineerine.com Telephone [phone]
Charlotte, NC 28208 License No. F-0856

Report of Back Pit and Front Pit Closure
Former Celadon Recycling Facility
Linco Partnership
Llncolnton, NC
September 22, 2022
Page 2
Pit Materials Characterization
Appropriate testing to characterize the waste in the pits for disposal was performed by Linco's
contractors and by Shield. The waste in both pits was determined to be non -hazardous.
Pit Closure
Back Pit
On June 14, 2021 Shield observed the closure activities performed by Hazmat Environmental
Services (Hazmat). Hazmat used vacuum trucks to remove the solids and liquids from the pit.
The materials removed were contained within the vac trucks. A high pressure/low volume water
gun was used to break up large pieces of solids so that they could be extracted with the vacuum
hoses. As the amount of material removed was close to complete, the work required the Hazmat
personnel wearing personal protective equipment to enter the two pit chambers so that the high
pressure water gun could be used at close range to thoroughly pressure wash the sides and
bottom of the pit chambers as the remaining material was vacuumed out. Photographs providing
further documentation of the material removal and Back Pit cleaning are provide in Attachment
1.
The 3400 gallons of waste material from the Back Pit was transported to Hazmat's solidification
facility in Charlotte, NC and was then disposed at the Republic Services Subtitle D landfill in
Concord, NC.
Front Pit
From February 10 to February 23, 2022 Shield observed the Front Pit closure activities performed
by Hepaco. Hepaco used vacuum boxes to remove the solids and liquids from the Front Pit in a
similar manner to the Back Pit described above. After removing the waste, the bottom and sides
of the Front Pit were cleaned with high pressure water. Linco plans to backfill the pit with soil
following drilling drainage holes in the concrete bottom to allow drainage of rainwater that may
seep through the backfilled soil. Photographs providing further documentation of the material
removal and Front Pit cleaning are provide in Attachment 2.
Approximately 233 tons of material were removed from the front pit. The material was disposed
at the Waste Connections- Anson County, NC Subtitle D Landfill.
SHIELD
/ ENGINEERING

Report of Back Pit and Front Pit Closure
Former Celadon Recycling Facility
Linco Partnership
Lincolnton, NC
Conclusions
September 22, 2022
Page 3
The waste material was thoroughly removed from both the Back Pit and the Front Pit using high
vacuum suction into vacuum boxes exposing the bare concrete pit walls and floors. The pit walls
and bottoms were then completely pressure washed. The removed material was properly
disposed at permitted facilities.
Based on the current facility use, the Back Pit does not receive wastewater. The Front Pit collects
precipitation only.
Please contact me 704-394-6913 if you have any questions.
Sincerely,
SHIELD ENGIkEE INC.
Thomas W. Witner, P.G.
Principal
Attachments
SHIELD
/ ENGINEERING

ATTACHMENT 1
BACK PIT PHOTOS

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Both chambers after waste removal and pressure washing.

Bottom of northern chamber after cleaning.

ATTACHMENT 2
FRONT PIT PHOTOS

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Vac boxes prior to use.

Initial stage of waste removal using vacuum hoses,

Continued Pit Vacuuming.

Pit cleaning with high pressure water.

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CDG
4301 Taggart Creek Road
Charlotte, NC 28208 January 24, 2023
Tel [phone]
License No. C-4973 Via email
cdge.com Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Attachment C
Subject: Work Plan for Back Pit, Front Pit and EQ Tank Closure
Former Celadon Recycling Facility
Linco Partnership
Lincolnton, NC
CDG Project No. R990129901
Dear Mr. Watson,
On behalf of Linco Partnership (Linco), the property owner of the former
Celadon Recycling Solutions operation, CDG, Inc. (formerly Shield Engineering,
Inc.) is presenting this work plan for the Back Pit, Front Pit and the EQ Tank
formerly containing waste at the facility. As the DEQ is aware, the waste water
treatment system has been out of operation since Celadon abandoned the
property. In an orderly fashion Linco has addressed various water -containing
components of the former Celadon operation including open pits, processing
equipment, and water storage facilities and mobile equipment. The purpose of
this work plan is to provide documentation of procedures taken and to be taken
regarding these components of the Wastewater Treatment System. We have
previously provided documentation regarding several tasks taken in the closure
process and refer to those reports for specific details including sampling
protocols and disposal records.
Previous Back Pit, Front Pit and EQ Tank Waste Removal Activities
A report of the Back Pit and Front Pit closure dated September 22, 2022, was
provided to Mr. Edward Watson with the Division of Water Resources (DWR).
Below is a summary of the activities to date for the Back Pit, Front Pit and the
EQ Ta n k.
[1]

(,'CDG
4301 Taggart Creek Road
Charlotte, NC 28208
Tel [phone]
License No. C•4973
cdge.corn
Back Pit
The Back Pit is located in a small outbuilding located east of the southern
portion of the main building. The pit is made up of two chambers constructed
of formed concrete that were once used by Celadon as a settling pit.
Underground piping runs from this pit to the EQ tank used to convey (via
pumping) liquids from the pit to the EQtank.
Currently the pit only receives stormwater from building downspouts and drop
inlets around the building. Stormwater is accumulated by the collection system
and routed to a trunk line that enters the pit.
On June 14, 2021, Shield observed the closure activities performed by Hazmat
Environmental Services (Hazmat). Hazmat used vacuum trucks to remove the
solids and liquids from the pit and high-pressure water to remove waste
material from its sides.
The 3400 gallons of waste material from the Back Pit was transported to
Hazmat's solidification facility in Charlotte, NC and was then disposed at the
Republic Services Subtitle D landfill in Concord, N.C. Waste manifests were
provided to the DWR.
Front Pit
The Front Pit is located near the facility office front door. It is uncovered and
also constructed of formed concrete. We are informed that it occasionally
received wastewater from customers' tanker trucks and also waters originating
inside the plant building. The Front Pit was once used as a waste settling pit.
We understand this pit has no effluent discharge piping.
From February 10 to February 23, 2022, Shield observed the Front Pit closure
activities performed by Hepaco. Hepaco used vacuum boxes to remove the
solids and liquids from the Front Pit in a similar manner to the Back Pit
described above. After removing the waste, the bottom and sides of the Front
Pit were cleaned with high pressure water.
Approximately 233 tons of material were removed from the front pit. The
material was disposed of at the Waste Connections- Anson County, NC Subtitle
D Landfill. Waste manifests were provided to the DWR.
[2]

C CDG
4301 Taggart Creek Road EQ Tank
Charlotte, NC 28208 The EQ Tank is located near the former wastewater lagoon. It is constructed of
Tel [phone] stainless steel and is approximately 15 feet high and 63 feet in diameter with a
License No. C•4973 nominal capacity of 350,000 gallons. The EQtank was part of the previous non-
cdge.corn discharge wastewater system operated by an applesauce and fruit drink
processing operation prior to Linco's ownership of the facility. We understand
that during Celadon's occupation of the facility, the tank received rainwater
and stored wastewater prior to discharge to the Lincolnton POTW.
Between September 12, 2022, and October 19, 2022 the contents of the EQ
Tank were pumped out by Shamrock Environmental. The waste was disposed
at their wastewater facility in Brown's Summit NC. Waste manifests have been
previously provided to Ed Watson with the DWR. According to the waste
manifests, 348,425 gallons of waste were removed from the EQ tank.
The piping from the bottom of the EQ tank to the recirculation pump in the
nearby pump house is currently connected and the liquids will be collected as
part of the recently awarded "tote disposal contract" with Hepaco.
Miscellaneous Wastewater Treatment Plant Vessels
Following sampling and analysis, on January 12, 2023, all liquids were removed
from the Celadon wastewater treatment vessels in the tote rinse room and
properly disposed by Hepaco. That equipment is the subject of on -going sales
processes and will be removed.
Proposed Closure Activities
Presented below are the general procedures for taking the subject wastewater
treatment plant components out of use.
Back Pit
The underground piping from the pit to the EQ tank should be emptied, if found
to contain liquids, and properly plugged at the pit end. Any removed materials
should be disposed at a permitted facility.
As previously described, the pit has been cleaned. Moreover, the only influent
the pit receives is rainwater from the roof drains and parking lot runoff. Since
water entering the pit is no longer in contact with a component of the
wastewater treatment system, it should not be considered wastewater. In
order to manage the stormwater that enters the pit, a sump pump system will
[31

(,'CDG
4301 Taggart Creek Road be configured to control the water accumulating in the pit. The pump should
Charlotte, NC 28208 be connected to a discharge line that leads to the floodplain of Carpenter Creek
Tel [phone] to the southeast. Rip -rap or similar outfall protection should be placed at the
License No. C-4973
discharge point.
cdge.com
Front Pit
As previously described, the Front Pit has been cleaned. Accumulated
rainwater should be removed from the pit to allow worker access and safe use
of electrical tools. Or if a dry environment cannot be maintained, air powered
tools should be used. Approximately sixteen 1 to 2 inch diameter holes will be
drilled with a percussion drill or similar tool in order to penetrate the bottom
concrete to provide drainage. The pit can then be backfilled with soil to present
grade and then planted with grass or other landscaping vegetation.
EQ Tank
Linco is in negotiations for demolition and removal of the tank which will
include the walls and bottom. The vendor will remove for recycling or proper
disposal. Prior to demolition, any piping connected to the tank will be drained
of remaining liquids and removed. Drainage of remaining water between the
tank and pumphouse is presently under contract as noted above. Prior to
demolition, in order to manage precipitation that falls inside the tank, the
piping from the center drain of the tank will be disconnected at the
recirculation pump and the pipe extended over the ground to the flood plain
of Carpenter Creek to the southeast. Rock rip -rap or similar outfall protection
should be placed at the outfall point.
Miscellaneous Wastewater Treatment Vessels
The vessels are planned for removal and is the subject of ongoing sales
processes.
Please contact me 704-394-6913 if you have any questions.
Sincerely,
CDG, Inc.
Thomas W. Witner, P.G.
Team Leader
[41

Attachment D

f r4/
2

864902:1