Mr. Warren Atkins Solid Waste Services Manager City of Little Rock Solid Waste Disposal Facility Ironton Cutoff Little Rock, AR 72206

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1 Document ID February 17, 2016 Mr. Warren Atkins Solid Waste Services Manager City of Little Rock Solid Waste Disposal Facility Ironton Cutoff Little Rock, AR RE: Quarterly Inspection; AFIN ; Permit Number 0266-S1. Dear Mr. Atkins On February , I conducted a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Regulation 22, and the above-referenced permit. A copy of the inspection report is enclosed for your records. Please refer to the attached inspection report to note the specific allegations. A written response for the noted allegations, describing the corrective action taken or to be taken, must be submitted to my attention at the address listed below within thirty (30) days from the date hereof. Failure to submit the written response shall be construed as an admission of any allegations. Any items noted that are neglected and/or persistent may warrant formal enforcement action. If I can be of any further assistance, feel free to contact me at or burke@adeq.state.ar.us. Sincerely, Lori Burke ADEQ Inspector Office of Land Resources Attachment Revised

2 Arkansas Department of Environmental Quality Solid Waste Management Division Class 1 Landfill Inspection Site Name City of Little Rock County Pulaski AFIN Facility Address Ironton Cutoff Road Little Rock AR Phone Number Permit Number 0266-S1 Permittee Address Same Address PDS # Date 2/16/2016 Entry Time 9:48 Exit Time 11:14 Regulation 22 Operational Standards Category 1 Regulation Item Description Comments 411(l) Adequate employee facilities 421(a)(b) Record keeping meets requirements specified by regulations 417 Access requirements 411(j) 421(d) 411(k) 423(b) Adequate provisions for backup equipment Waste receipt records, ticket system maintained Telephone system & written emergency response plan on site Annual compliance inspection by registered professional engineer 422 Facility implements operating plan and narrative 421(f) 421(g),701 Leachate disposal/recirculation records Special waste disposal and procedures records Category 2 Regulation Item Description Comments 411(a) Operations in accordance with permit documents 417(c) 411(c) 411(e) 411(f)(1) 411(p) 411(b) 411(d) 411(g) 414(a) Adequate all weather operational roads Smallest practical area, unloading supervised, single working face Salvage operations meet approved conditions Scavenging of waste prohibited Proper wet weather repairs Operations by licensed on-site personnel at all times Waste spread and compacted as unloaded Litter control provisions maintained Disease vectors controlled Category 2 (continued)

3 Regulation Item Description Comments 427 Surface Water Controls 411(h)(1) 418(a)(b) 411(h)(2) 411(i);427(f) Contouring prevents surface water flowing into or through waste Run-on/off control system present and adequate Surface water control prevents off-site sediment accumulation Adequate maintenance of intermediate/final cover vegetation 415 Gas monitoring program 411(o) Leachate leaks or evidence of leachate seepage 426 Survey controls 429 Leachate collection system 420 Liquid Restrictions Category 3 Regulation Item Description Comments 412 Implementation of hazardous/unauthorized waste exclusion plan 413(a)(b) 413(c) 416(b),411(f)(4) Satisfactory daily/alternative cover Satisfactory intermediate cover Open burning prohibited 419 Cause discharge/leachate discharge leaving landfill 411(f)(3),419(a)(4) Depositing waste in standing water prohibited X 411(o) Erosion or other cover defects resulting in exposed refuse Exposed waste due to inadequate cover and erosion cuts was noted on the eastern/western slope of cell (c) Overfill/Off lined area Regulation 22 - Records 421(a)(8), 1203(k) Date of last groundwater monitoring report 5/17/2015 Site Conditions Wet 423(b) Date of last engineering report 3/30/2015 Weather Conditions Sunny 428 Liner construction in progress Yes/No Notice of liner construction Yes/No Third party CQA on-site during construction Yes/No 412(a) Date of last random inspection for unauthorized waste 2/10/2016 Total # for month 6 for Jan 415, 421(e) Date of last quarterly methane monitoring 6/19/2015 Detection level 0 415(a) Explosive gas records current? Yes/No Y 421(g),412(a)(2),701 Date of last special waste received 10/21/2014 Disposal location None this quarter 421(d) Previous quarter waste received See attachment Tons 427(c) Surface water DMR records current? Yes/No Fayetteville Shale Related Yes/No Out of Compliance with Fayetteville Shale Yes/No Operator Name & Number Gary Bitely Signature of Inspector Exit Interview Conducted with Gary Bitely/Warren Atkins Method Onsite Date 2/16/2016 Time 11:14 Class 1Form 7/1/2012 (Revised and Implemented 10/21/2014) For ADEQ Use Only

4 Permit # 266-S1 Photo 1 & 2

5 Permit # 266-S1 Photo 3 & 4

6 Permit # 266-S1 Photo 5 & 6

7 Permit # 266-S1 Photo 7 & 8

8 I (City of Little Rock Department of Public Works March 29, IranIan Culolf little Rock, Arkansas Fax Solid Waste Division Lori Burke, Inspector MAR Arkansas Department of Environmental Quality Solid Waste Management Division 5301 Northshore Drive North Little Rock, AR Re: Quarterly Inspection, AFfN , Permit 0266-S1 Dear Ms. Burke: In response to your inspection of February 16,2016, the following is a list of comments and corrective actions to be undertaken on the City of Little Rock's Class 1 landfill: Class 1 Landfill, Permit # S 1 Exposed waste and erosion cuts on eastern/western slopes of Cell 4. Will complete this work once we have an extended dry spell where equipment can regrade the area. Would hope weather will allow this to occur in the next days. Thank you for your cooperation in this matter. If I can be ofany further assistance please contact me at your convenience. '" Warren At ins Solid Waste Services Manager