WQ0003924_Rescission Request_20240425

From:
ron ronalddbuck.com
To:
Thornbura. Nathaniel
Cc:
Tom Witner
Subject:
[External] Permit recission WQ0003924
Date:
Wednesday, April 24, 2024 7:46:53 PM
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Mr. Thornburg,
As Owner of Linco Partnership (Linco), I would like to make a request for the recission of the subject non
discharge permit.
I would like to make it clear that there was never any spray irrigation performed at this property since the
original permittee (National Fruit Product Co.) operated there.
The former tenant of the subject property, Celadon Recycling Solutions (Celadon), abandoned the facility
wastewater system (Pretreatment Permit issued by the City of Lincolnton) approximately 3 years ago and
left large quantities of solid and liquid waste in various parts of the facility including approximately 2800
intermediate bulk containers (IBCs) that contained various amounts of apparent industrial process
wastewater and semi-solid/sludge materials on the property. To maintain environmental compliance and
protect its investment interests, Linco has been addressing the numerous concerns associated with
Celadon's abandoned operations.
After a thorough characterization of all waste (solids, liquid, sludges) left onsite, Linco has conducted
removal of legacy wastes at the property including, with the exception of the imminent disposal of the last
few dozen, the approximately 2,800 IBCs containing wastewater from the Celadon operations and all of
its equipment and facilities have been removed from the site. Other water -containing vessels (e.g. tanks,
pits and sumps) have been emptied and cleaned. Coordination and progress reporting with DWR and the
Hazardous Waste Section of DWM have been an integral part of the site cleanup.
Anticipating that closure of the lagoon that is part of the non -discharge system would be required, Linco
has been actively pursuing lagoon closure. Characterization of the lagoon included samples of water and
sludge collected in May 2021, June 2023 and November 2023. Linco believes that the most
environmentally sound method of disposal of the water would be to discharge it to the City of Lincolnton
sewer. Therefore, an UP Survey and Application was submitted to the City of Lincolnton Pretreatment on
February 15, 2024. Alternatives are being evaluated should the Lincolnton discharge permit not be
approved.
Thank you,
Ron Buck
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:•I :. A
mai[to:ron(a)ronaIddbuck. com
5200 Old Harding Road
Franklin, TN 37064
Cel I - 615-579-3815