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1 Document ID April 27, 2016 Kendrick Ketchum Cleburne Co. Transfer Station Progressive Waste Solutions of AR, Inc. PO Box 171 Heber Springs, AR RE: Quarterly Inspection; AFIN Permit Number; 0032-STSW Dear Mr. Ketchum: On April 19, 2016, 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 stringer@adeq.state.ar.us. Sincerely, Charles Stringer ADEQ Inspector Office of Land Resources Attachment cc: Tammie Hynum, Senior Manager, Office of Land Resources, Regulated Waste Program Revised

2 Arkansas Department of Environmental Quality Solid Waste Management Division Transfer Station and Solid Waste Recovery Facility Inspection Site Name Cleburne Co./Progressive Waste Solutions of AR TS County Cleburne AFIN Facility Address Heber Springs, Hwy. 110 E. to CR 337, ¼ mile to Phone Number Permit Number Permittee Address facility. IESI, Attn. Craig Kirchhoff PO Box 171, Heber Springs, AR TS STSW Address PDS # Date 4/19/2016 Entry Time 1230 Exit Time 1305 Regulation 22 Operational Standards Category 1 Regulation Item Description Comments 904(n) Periodic reports prepared and filed with ADEQ 904(g) 904(o) 904(i) Recovery of Solid Waste Adequate employee facilities Adequate information sign posted at all access points 905 Meets design requirements 907 Maintain recordkeeping requirements Category 2 Regulation Item Description Comments 904(p) Operations in accordance with permit documents 905(b) 904(k) 904(m) Adequate unloading and loading areas Adequate facility maintenance Adequate fire protection equipment available at all times X 904(h) Adequate supervision of facility See attached Comments page. 904(e) Adequate storage space for incoming solid waste 904(j) Control of litter, insects, odors, and vectors Category 3 Regulation Item Description Comments 904(a) 904(d) 904(f) Facility accepts only allowable types of waste Processing areas adequate External storage of solid waste X 904 (l) Adequate drainage to sanitary sewers See attached Comments page. 904(b) Ultimate disposal of waste

3 Regulation 22 - Records 904(n) Date of annual report 3/31/16 Site Conditions Wet 904(p)(10) Maintains contingency plan Yes Weather Conditions Cloudy 907(c ) Last month s report waste received 2, Tons March 2016 Operator Name & Number Paula Lee & Provisional Signature of Inspector Exit Interview Conducted with Paula Lee Method On Site Date 4/19/2016 Time 1300 TS/SWRF Form 7/1/2012 (Revised and Implemented ) For ADEQ Use Only

4 Arkansas Department of Environmental Quality Solid Waste Management Division Comments Page Site Name Cleburne Co./Progressive Waste Solutions of AR TS AFIN Permit Number 0032-STSW Category 2 Comments Reg Operational Requirements (Adequate supervision of facility) (h) Supervision of Facility - The transfer station shall have a licensed on-site operator who has been certified in accordance with Regulation Number 27 of the Commission on duty at all times the facility is open. Reg Class 1 License-- Material Recycling Facility, Solid Waste Recovery Facility, Solid Waste Processing Facility, Composting Facility, Transfer Station, Municipal Solid Waste Incinerator, Or Municipal Solid Waste Disposal Facility A Class 1 license shall be required for all operators of material recycling facilities, solid waste recovery facilities, solid waste processing facilities, composting facilities, transfer stations, municipal solid waste incinerators, and municipal solid waste disposal facilities, with at least one (1) Class 1C licensed manager or supervisor on-site at all times during periods of operation (see Appendix A-2). Comment: The operator that actually handles waste, conducts screening, operates equipment, etc., Charles Jenkins, does not hold a valid Operator s license at this time. He held a Class 1 A (003537) license which expired 4/9/2014. Mr. Jenkins meets the guidelines for determining who needs a Solid Waste Operator s License as stated in Reg.27 Appendix A-2. Reg (l) - Operational Requirements (Adequate drainage to sanitary sewer) (l) Drainage - All floors must be free from standing water. All drainage from cleaning, unloading and processing areas must be discharged to sanitary sewers or permitted onsite treatment facilities. Storm water discharges from the site shall conform to Department storm water permitting requirements. Comment: The lower processing area (where trailers park for loading) has no drainage to the onsite storage tank. This deficiency was noted in the previous inspection. Mr. Jenkins stated that an engineer had been onsite the previous week to assess the drainage situation. See photos 1 & 2. Date 4/19/2016 Signature of Inspector Page 3 AdditionalComments Page7/1/2012 For ADEQ Use Only

5 Permit# 0032-STSW-B Photo 1 & 2

6 Taylor, Dianna From: Sent: To: Subject: Attachments: Stringer, Charles Tuesday, May 24, :51 AM Taylor, Dianna FW: Second Quarter Cleburne County TS Inspection Response HSTS Q Insp Response Letter.pdf Rec d Digitally Here is the response for the Cleburne County TS 2q insp. Charles Stringer ADEQ Inspector Office of Land Resources From: Brady Stewart [mailto:brady.stewart@progressivewaste.com] Sent: Monday, May 23, :29 PM To: Stringer, Charles Cc: Ronnie E. Black Sr.; Kendrick Ketchum Subject: Second Quarter Cleburne County TS Inspection Response AFIN: PMT#: 0032-STSW By Dianna Taylor at 7:58 am, May 24, 2016 DOC ID#: TO: CS>File S W M D Mr. Stringer, Attached is the Cleburne County Transfer Station inspection response for the second quarter 2016 inspection on April 19, The hard copy has been overnighted to you. Thanks! Brady Stewart Associate Engineer Progressive Waste Solutions of MO, Inc. (Formerly IESI-BFC Ltd.) E: brady.stewart@progressivewaste.com T: Creve Couer Mill Road Maryland Heights, MO, NYSE, TSX: BIN 1

7 CLEBURNE CO. TRANSFER STATION May 20, 2016 Mr. Charles Stringer ADEQ Inspector Arkansas Department of Environmental Quality (ADEQ) Solid Waste Management Division (SWMD) 5301 Northshore Drive North Little Rock, Arkansas RE: Quarterly Inspection, AFIN; , Permit; # 0032 STSW IESI Cleburne County Transfer Station, Solid Waste Transfer Station Dear Mr. Stringer: Cleburne Co. Transfer Station (IESI) has prepared this response to the ADEQ letter entitled Quarterly Inspection, CSN; Permit Number 0032 STSW, dated April 27, This response letter addresses the observations made during the April 19, 2016 facility inspection. ADEQ comments are shown below in italics with IESI responses in bold. Category 2 Comments 1. Comment: The operator that actually handles waste, conducts screening, operates equipment, etc., Charles Jenkins, does not hold a valid Operator's license at this time. He held a Class 1 A (003537) license which expired 4/9/2014. Mr. Jenkins meets the guidelines for determining who needs a Solid Waste Operator's License as stated in Reg.27 Appendix A 2. A former licensed operator is located at the Cleburne Co. Transfer Station (IESI). As noted on the inspection, that operator allowed their license to lapse. The operator is currently enrolled in the August 16 18, 2016 course/training for the Class 1A operator in Little Rock, Arkansas. IESI has contacted ADEQ to determine if a Provisional Certificate is necessary until Mr. Jenkins passes the class. IESI was advised a Provisional Certificate would not be required in this case. PO BOX 171 HEBER SPRINGS, ARKANSAS PHONE # (870)

8 Category 3 1. The lower processing area (where trailers park for loading) has no drainage to the onsite storage tank. This deficiency was noted in the previous inspection. Mr. Jenkins stated that an engineer had been onsite the previous week to assess the drainage situation. See photos 1 & 2. IESI has met with a third party contractor and made improvements to the drainage in the loading pit (lower processing area). Asphalt curbing was installed to collect and route liquids falling into the loading pit into a grated sump. A pump was installed in the sump to move collected liquids to the leachate tank, along with liquids from the floor drains in the tipping floor. See attached Photo Log for the loading pit repairs. Should any questions or clarification be necessary, please call me at (314) Sincerely, Brady Stewart Associate Engineer MO/AR Area Attachment: Photo Log cc: Ronnie Black, IESI Kendrick Ketchum, IESI PO BOX 171 HEBER SPRINGS, ARKANSAS PHONE # (870)

9 1. Curb repairs to the loading pit (lower processing area). 2. Looking into the loading pit (looking west).

10 3. Sump area for moving liquids from loading pit to leachate holding tank (looking west). 4. Sump pump connected to move liquids from loading pit to leachate holding tank (looking west).