WQ0003924_WPSOCC Letter regarding ORC Requiremnts for the permitted facility_20220923

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
September 23, 2022
Mr. W. Corey Basinger, Chairman (via email)
Water Pollution Control System Operators Certification Commission (WPCSOCC)
1618 Mail Service Center
Raleigh, NC 27699-1618
Subject: Linco Partnership
Non -Discharge Permit #WQ0003924
288 White House Drive, Lincolnton
Lincoln County
Dear Mr. Basinger,
The Division of Water Resources' (DWR) Mooresville Regional Office (MRO) is aware of a recent petition
to request a waiver for the requirement of an Operator in Responsible Charge (ORC) and Backup ORC for
the subject facility. The DWR-MRO requests that the waiver be denied because the facility is still
actively using portions of the permitted wastewater system.
Despite applying for this permit (copy attached) and being aware of the conditions within, Linco has
chosen not to employ the services of an ORC since the permit was obtained and this has, in part, led to
compliance issues at the facility beyond just the requirement for designating an ORC. Compliance issues
include wastewater discharges to surface water, failure to maintain the components of the wastewater
system, and failure to maintain records as required in the permit.
While DWR-MRO can confirm the spray irrigation portion of the system has been rendered unusable,
the DWR-MRO is aware that other components of the wastewater treatment system are actively used.
As their letter references, Linco still utilizes a 300,000-gallon EQ tank. In addition, Linco actively uses
other portions of the permitted wastewater system that were not referenced, namely a 2,000,000-
gallon storage lagoon with a failing liner, a 12,000-gallon surge tank, and a variety of associated pumps,
piping, controls, and appurtenances.
DWR-MRO has been made aware that Linco plans to close the wastewater treatment system, but to
date and despite requests, Linco has not submitted a closure plan or timeline to the Division specifying
the steps they intend to take during this process.
In summary, DWR-MRO believes it is premature to relieve Linco of the requirement to designate an ORC
while components of the wastewater system are still active and contain wastewater. Should you have
any questions regarding this matter, please feel free to contact Edward Watson at 704-235-2199 or
edward.watson@ncdnergov.
North Carolina Department of Environmental Quality I Division of Water Resources
D � Mooresville Regional Office 1 601 East Center Avenue, Suite 301 1 Mooresville, NC 28115
NORTHCARCUNA 704.663.1699

Sincerely,
EA
DocuSigned by:
#-.uw N P44-ft
F161 F969AMUAI..
Andrew H. Pitner, P.G., Assistant Regional Supervisor
Division of Water Resources
Water Quality Regional Operations Section
Mooresville Regional Office
Attachment: Permit #WQ0003924
CC: Ronald Buck, Linco (via email)
Thomas W. Witner, P.G., Shield Engineering (via email)
William T. Gordon, III, Stites and Harbison, PLLC (via email)
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 601 East Center Avenue, Suite 301 1 Mooresville, NC 28115
NCRrHCAaouNA I/ 704.663.1699
oeo+ro�.m m F,mro���w n�si�