1. Outfall #9 has been moved from the location specified in the NOI. This is a violation of 3.6 of your permit.

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1 March 6, 2013 Rick Grisinger, Regional Vice President, US - Northern Halliburton Energy Services, Inc. PO Box 42810, MC 91 1NE-16K Houston, TX RE: Compliance Inspection (Sebastian Co) AFIN: NPDES Permit No.: ARR00B114 Dear Mr. Grisinger: On February 11, 2013, I performed a routine Industrial Stormwater compliance inspection of your facility in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. This inspection revealed the following violations: 1. Outfall #9 has been moved from the location specified in the NOI. This is a violation of 3.6 of your permit. 2. The SWPPP did not contain the general permit tracking number or the facility s SIC and NAICS codes. This is a violation of of your permit. 3. The facility s site map did not contain all the required items. This is a violation of of your permit. 4. The SWPPP did not contain a summary of existing discharge sampling data. This is a violation of of your permit. 5. The SWPPP did not contain a section on risk identification and summary of potential pollutant sources. This is a violation of of your permit. 6. The SWPPP did not address the management of run-on and runoff. This is a violation of of your permit. 7. Authorized non-stormwater discharges were not listed in the SWPPP. This is a violation of of your permit.

2 Page 2 8. The findings of the visual site inspections were not documented. This is a violation of of your permit. 9. The SWPPP did not contain a certification. This is a violation of of your permit. Please submit a written response to these findings to the Water Division Inspection Branch of this Department. This response should be mailed to the address at the bottom of the first page of the letter or ed to Water-Inspection-report@adeq.state.ar.us. This response should contain documentation describing the course of action taken to correct each item noted. This corrective action should be completed as soon as possible, and the written response with all necessary documentation (i.e. photos) is due by March 20, It has also been noted that only Outfall #1 and #2 are listed in your permit as permitted outfalls. However, nine outfalls were listed in your NOI submitted to ADEQ, and sampling is occurring for all nine outfalls. Please contact Jamal Solaimanian, Engineer Supervisor, in the Permits Branch at to discuss this permitting issue. If I can be of any assistance, please contact me at or Coats@adeq.state.ar.us. Sincerely, Angela Coats Oil & Gas Field Inspector Water Division cc: Water Division Permits Branch Greg Roberts, HSE Coordinator, greg.roberts@halliburton.com Chris Allison, Facility Supervisor, chris.allison@halliburton.com Steve D. San Miguel, Environmental Specialist, steve.sanmiguel@halliburton.com

3 ADEQ Water NPDES Inspection AFIN: Permit #: ARR00B114 Form Approved OMB No UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C NPDES Compliance Inspection Report Section A: National Data System Coding Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N A R R 0 0 B W 19 S 20 2 Remarks A F I N S E B A S T I A N C O Inspection Work Days Facility Evaluation Rating BI QA Reserved N 71 N 72 N Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Halliburton Energy Services, Inc South Zero Street Fort Smith, AR Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Greg Roberts, MS, CSP / HSE Coordinator / Phone Chris Allison / Facility Supervisor / Phone Name, Address of Responsible Official/Title/Phone and Fax Number Rick Grisinger, Regional Vice President, US - Northern Halliburton Energy Services, Inc. PO Box 42810, MC 91 1NE-16K Houston, TX Entry Time/Date 1315 / February 11, 2013 Exit Time/Date 1500 / February 11, 2013 Yes Contacted No Permit Effective Date July 1, 2009 Permit Expiration Date June 30, 2014 Other Facility Data Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) M Permit N Flow Measurement S Operations & Maintenance M Sampling M Records/Reports N Self-Monitoring Program N Sludge Handling/Disposal U Pollution Prevention (SWPPP) S Facility Site Review N Compliance Schedules N Pretreatment N Multimedia N Effluent/Receiving Waters N Laboratory S Storm Water N Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) Permit - The permit only has Outfall #1 and #2 listed as permitted outfalls; however, nine outfalls were listed in the submitted NOI, and nine outfalls are being sampled. Records/Reports The findings of the visual inspections have not been documented. Sampling Outfall #9 has been moved from the location submitted in the NOI. Pollution Prevention The SWPPP needs to be updated to include all required items. PDS # Name(s) and Signature(s) of Inspector(s) Angela Coats Agency/Office/Telephone/Fax Arkansas Department of Environmental Quality / Fort Smith / Phone / Fax Date February 27, 2013 Signature of Reviewer Kerri McCabe Agency/Office/Phone and Fax Numbers ADEQ / NLR / Date March 5, 2013 NPDES Report Page 3

4 ADEQ Water NPDES Inspection AFIN: Permit #: ARR00B114 Inspection Form Legend: S = Satisfactory, M = Marginal, U = Unsatisfactory, Y = Yes, N = No, NI = Not Implemented, NA = Not Applicable, NE = Not Evaluated If Y and a NI are check it means it is in the SWPPP but not implemented in the field which is a violation. SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS S M U NA NE 1. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: Y N NA NE 2. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: Y N NA NE 3. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: Y N NA NE 4. ALL DISCHARGES ARE PERMITTED: Y N NA NE Comments: The permit only has Outfall #1 and #2 listed as permitted outfalls; however, nine outfalls were listed in the submitted NOI. SECTION B: STORM WATER POLLUTION PREVENTION PLAN EVALUATION PERMITTEE SWPPP MEETS PERMIT REQUIRMENTS S M U NA NE 1. Is the SWPPP available for review by ADEQ? (Part 4.2) Y N NI NA NE 2. Does the SWPPP contain facility name, general permit tracking number, facility physical address, and SIC and NAICS codes? (Part 4.6.1) 3. Pollution Prevention Team Y N NI NA NE A. Does the SWPPP identify specific individuals or positions?(part 4.6.2) Y N NI NA NE B. Does the SWPPP outline the responsibilities of each member of the Pollution Prevention Team? (Part 4.6.2) Y N NI NA NE 4. Does the SWPPP contain a facility description (process diagram, general layout, storage of raw materials, the flow of goods and materials through the facility and seasonal variations)? (Part 4.6.3) 5. Does the facility site map contain the following items? Y N NI NA NE A) The size of the property in acres? (Part a) Y N NI NA NE B) The location and extent of significant structures and impervious surfaces? (Part b) Y N NI NA NE C) The direction of stormwater flow using arrows? (Part c) Y N NI NA NE D) The locations of all existing structural control measures? (Part d) Y N NI NA NE E) The locations of all receiving waters in the immediate vicinity of the facility? (Part e) Y N NI NA NE F) The locations of all stormwater conveyances including ditches, pipes, and swales? (Part f) Y N NI NA NE G) The locations of potential pollutant sources? (Part g) Y N NI NA NE H) The locations of all stormwater monitoring points? (Part h) Note: Outfall #9 has been moved. Y N NI NA NE I) The locations of stormwater inlets and outfalls with unique identification code for each outfall with indications if one or more outfall is being treated as substantially identical and an approximate outline of Y N NI NA NE the areas draining to each outfall? (Part i) Note: Outfall #9 has been moved. J) Where the stormwater discharges to municipal separate storm sewer system (MS4), if applicable? (Part j) Y N NI NA NE K) The locations and descriptions of all non-stormwater discharges identified in the SWPPP? (Part k) Note: Authorized Non-stormwater Discharges not included in SWPPP. Y N NI NA NE L) The locations of the following activities if they are exposed to precipitation? (Part l) Y N NI NA NE Fueling Stations Vehicle and equipment maintenance and/or cleaning areas Loading and unloading areas Locations used for the treatment, storage, or disposal of waste Liquid storage tanks Processing and storage areas Immediate access roads and rail lines used or traveled by carriers of raw materials, manufactured products, waste material, or by-byproducts used or created by the facility Transfer areas for substances in bulk Y N NI NA NE Y N NI NA NE Y N NI NA NE Y N NI NA NE Y N NI NA NE Y N NI NA NE Y N NI NA NE Y N NI NA NE NPDES Report Page 4

5 ADEQ Water NPDES Inspection AFIN: Permit #: ARR00B114 Machinery M) The locations and sources of run-on to the site from adjacent property that contains significant quantities of pollutants? (Part m) 6. A description of potential pollutant sources Y N NI NA NE Y N NI NA NE A) An inventory of industrial activities which have been or may potentially be sources of significant amounts of pollutants? (Part ) Y N NI NA NE B) An inventory of all types of materials handled at the site that might potentially be exposed to precipitation? (Part ) Y N NI NA NE C) A list of significant spills and significant leaks of toxic or hazardous pollutants that have occurred in areas exposed to precipitation or drained to a stormwater conveyance for three years prior to the effective date of the permit. (Part ) Note: SWPP needs to be updated to reflect hydrochloric acid Y N NI NA NE spill that occurred recently on February 7, D) A summary of existing discharge sampling data (Part ) Y N NI NA NE E) Risk Identification and Summary of Potential Pollutant Sources (Part ) Y N NI NA NE 7. Measures and Controls SWPPP must describe how these are used. A) Best Management Practices (BMPs) (Part ) Y N NI NA NE B) Exposure Minimization (Part ) Y N NI NA NE C) Good Housekeeping (Part ) Y N NI NA NE D) Preventative Maintenance (Part ) Y N NI NA NE E) Spill Prevention and Response Procedures (Part ) Y N NI NA NE F) Employee Training Procedures (Part ) Y N NI NA NE G) Erosion and Sediment Control (Part ) Y N NI NA NE H) Management of Run-on and Runoff (Part ) Y N NI NA NE I) Additional Requirements for Salt Storage (Part ) Y N NI NA NE 8. Authorized Non-stormwater Discharges (Part 4.6.7) list must be in SWPPP Y N NI NA NE 9. Evaluations and Inspections (Part ) A) Visual Site Inspections (minimum 4/year) (Part ) Note: Not documented Y N NI NA NE At least one visual inspection conducted during a rain event Inspections recorded and include: date of inspection, person doing inspection; major observations, and corrective actions required. Y N NI NA NE Y N NI NA NE B) Comprehensive Site Compliance Evaluation (Annual) (Part ) Y N NI NA NE Comments: The SWPPP needs to be updated to include the above mentioned items. SECTION C: MONITORING PERMITTEE MONITORING MEETS PERMIT REQUIRMENTS 1. Is the facility one of the four Effluent Guideline Facilities in the Permit? (Cement MFG, Fertilizer MFG, Steam Electric coal pile, or Paving and Roofing Materials)(Part 3.1.1) S M U NA NE Y N NI NA NE A) Are all outfalls from the regulated process being sampled? (Part 3.1.3) Y N NI NA NE B) If coal pile run off is monitored, are all other stormwater flows excluded? (Part 3.1.1) Y N NI NA NE 2 Which of the monitoring categories is this facility subject to: (Part 3.3) A) Are samples being collected for each semi-annual monitoring period (Part 3.5) Y N NI NA NE C) Are samples being collected from the location specified in the NOI and SWPPP (Part 3.6) Note: Outfall #9 has moved. Y N NI NA NE C) Has the permittee determined that some of the outfalls are similar? (Part 3.7.1) Y N NI NA NE Are the conditions on the ground still the same as documented for the similar outfalls (Part 3.7.1) Y N NI NA NE D) Are all parameters for the monitoring category being sampled and analyzed? (Part 3.7.2) Y N NI NA NE E) Were the samples collected during a measureable storm event? (Part b) Y N NI NA NE F) Were the samples properly preserved and analyzed? (Part 3.7.2) Y N NI NA NE G) Are the sample locations suitable for the collection of a representative sample? (Part 3.3) Y N NI NA NE 3. Has any of the monitoring revealed an exceedance of the benchmark values for this facility?(part ) Y N NI NA NE A) Has a process to develop a corrective action plan been started within 30 days of exceedances? (Part ) Y N NI NA NE B) If four monitoring periods have passed without an exceedance of a benchmark value, has the permittee requested a reduction in monitoring? (Part ) Y N NI NA NE Comments: Outfall #9 has been moved from the original location described in the NOI. It has been relocated by NPDES Report Page 5

6 ADEQ Water NPDES Inspection AFIN: Permit #: ARR00B114 Outfall #1. SECTION D: RECORD KEEPING AND REPORTING PERMITTEE RECORD KEEPING AND REPORTING MEETS PERMIT REQUIRMENTS 1. Have DMRs for the previous year of monitoring been submitted to ADEQ and is a copy in the file? (Part a) Note: Mr. Allison advised that the DMR was submitted to the company s headquarters for signature and for them to then submit to ADEQ. Are the DMRs properly completed? Does the permittee have copies of lab reports and chain of custody records? Are the appropriate records of the measureable storm event and sampling being kept? (Part e) 2. Has a copy of the annual comprehensive evaluation been submitted to the agency and is a copy on file? (Part b) Note: Mr. Allison advised that the DMR was submitted to the company s headquarters for signature and for them to then submit to ADEQ. S M U NA NE Y N NI NA NE Y N NI NA NE Y N NI NA NE Y N NI NA NE Y N NI NA NE 3. Is permittee keeping copies of inspections and corrective actions on file? (Part ) Y N NI NA NE 4. Are copies of training records being kept on file? (Part ) Y N NI NA NE 5. Is there a list of significant spills and leaks being maintained? (Part ) Note: SWPP needs to be updated to reflect hydrochloric acid spill that occurred recently on February 7, Y N NI NA NE Comments: The findings of the visual inspections have not been documented. SECTION E: FACILITY TOUR PERMITTEE FACILITY TOUR MEETS PERMIT REQUIRMENTS S M U NA NE 1. Any evidence of spills or leaks that have not been properly cleaned up as required by the SWPPP? Y N NI NA NE 2. Any evidence of erosion or un-stabilized ground? Y N NI NA NE 3. Any controls, structures, or storage areas that are not as identified in the SWPPP? Y N NI NA NE 4. Any non-stormwater discharges not identified in the SWPPP? (see Part 1.7 of permit for list of allowable non-stormwater discharges) 5. Any non-stormwater discharges that are not allowed under this permit? (see Part 1.7 of permit for list of allowable non-stormwater discharges) Y N NI NA NE Y N NI NA NE 6. Are BMPs being properly operated and maintained? Y N NI NA NE 7. Are housekeeping procedures being implemented and are they sufficient? Y N NI NA NE Comments: The filtration controls around Outfall #2 and #3 should be cleaned out to prevent water from backing up and going over the berm and bypassing your outfalls. NPDES Report Page 6

7 ADEQ Water NPDES Inspection AFIN: Permit #: ARR00B114 Location: Water Division NPDES Photographic Evidence Sheet Halliburton Energy Services, Inc., 5901 South Zero Street, Fort Smith, AR Photographer: Angela Coats Witness: None Photo # 1 Of 6 Date: Time: 1325 Description: View to the north of the facility. This area drains to outfalls #2 through #8. The ponding of water to the right in the photo drains to outfalls #2 and #3. Photographer: Angela Coats Witness: None Photo # 2 Of 6 Date: Time: 1327 Description: The berm built to contain and redirect stormwater to the designated outfalls before flowing in the Little Massard Creek. This creek runs through the middle of the property. NPDES Report Page 7

8 ADEQ Water NPDES Inspection AFIN: Permit #: ARR00B114 Water Division NPDES Photographic Evidence Sheet Location: Halliburton Energy Services, Inc., 5901 South Zero Street, Fort Smith, AR Photographer: Angela Coats Witness: None Photo # 3 Of 6 Date: Time: 1327 Description: An example of a stormwater outfall point. Photographer: Angela Coats Witness: None Photo # 4 Of 6 Date: Time: 1339 Description: The cement bulk plant that is no longer in operation. NPDES Report Page 8

9 ADEQ Water NPDES Inspection AFIN: Permit #: ARR00B114 Location: Water Division NPDES Photographic Evidence Sheet Halliburton Energy Services, Inc., 5901 South Zero Street, Fort Smith, AR Photographer: Angela Coats Witness: None Photo # 5 Of 6 Date: Time: 1347 Description: View of the facility to the northwest. The Little Massard Creek is shown flowing through the property. Photographer: Angela Coats Witness: None Photo # 6 Of 6 Date: Time: 1352 Description: Outfalls #1 and #9. NPDES Report Page 9

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11 Health, Safety and Environment P O Box Houston, TX April 12, 2013 Ms. Angela Coats Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR Dear Ms. Coats: This letter serves as the corrective action response to the results of your compliance inspection conducted on February 11, 2013, at the Halliburton Energy Services, Inc. Ft. Smith, AR Zero Street Facility; AFIN: , NPDES Permit No: ARROOB114. This letter will accompany the revised Storm Water Pollution Prevention Plan (SWPPP). All of the findings that were identified as violations of the facility s permit have been corrected as follows: 1. Outfall #9 has been moved from the location specified in the NOI. The original NOI specified nine outfalls, but for some reason, only two were indicated in our permit records. We are in contact with Jamal Solaimanian, Engineer Supervisor, to correct our permit records. The correct location for Outfall #9 is indicated in our SWPPP. 2. The SWPPP did not contain the general permit tracking number or the facility s SIC and NAICS codes. This information has been added to Section 1.1 of the SWPPP. 3. The facility s site map did not contain all the required items. The site map in the SWPPP has been revised. 4. The SWPPP did not contain a summary of existing discharge sampling data. This data has been added to Attachment I in the SWPPP. 5. The SWPPP did not contain a section on risk identification and summary of potential pollutant sources. This information has been added to Section 2 of the SWPPP. 6. The SWPPP did not address the management of run-on or runoff. This information has been added to Section of the SWPPP.

12 Health, Safety and Environment P O Box Houston, TX Authorized non-stormwater discharges were not listed in the SWPPP. There are no authorized or unauthorized non-stormwater discharges. This information has been added to Section 2.2 of the SWPPP. 8. The findings of the visual site inspections were not documented. This information has been added to Attachment G of the SWPPP. 9. The SWPPP did not contain a certification. This information has been added to Section 7 of the SWPPP. We believe these modifications have brought us into compliance with the General Permit. If you have any questions or concerns, please contact me. Sincerely, Steve D. San Miguel, REM, CSEM Environmental Specialist Halliburton Energy Services, Inc Bellaire Blvd. Houston, TX cc: David Dumond, Global HSE Manager Environment Greg Roberts, HSE Technical Professional

13 Environment Submitted to: Submitted by: Halliburton Energy Services AECOM Fort Collins, Colorado April 2013 Storm Water Pollution Prevention Plan Halliburton Energy Services 5801/5901 South Zero Street Fort Smith, Arkansas

14 AECOM Environment AA-1 List of Acronyms ACA ADEQ AECOM BMPs CFR LERP NOI SIC SPCC SWPPP U.S. USEPA Arkansas Code Annotated Arkansas Department of Environmental Quality AECOM Environment Best Management Practices Code of Federal Regulations Local Emergency Response Plan Notice of Intent Standard Industrial Classification Spill Prevention, Control, and Countermeasures Storm Water Pollution Prevention Plan United States Unites States Environmental Protection Agency

15 AECOM Environment i Contents 1.0 Introduction Facility Identification Storm Water Pollution Prevention Team Facility Characteristics General Location Map Site Map Potential Pollutant Sources Description of Potential Pollutants and Sources Non-Storm water Discharges Storm Water Controls Best Management Practices Minimize Exposure Good Housekeeping Maintenance of Structural and Non-Structural Controls Spill Prevention and Response Measures General Prevention Measures General Response Procedure Erosion and Sediment Controls Miscellaneous/Additional BMPs Preventive Maintenance Dust Generation and Vehicle Tracking Management of Run-on and Runoff Salt Storage Piles Employee Training Recordkeeping Inspections Quarterly Inspections Comprehensive Site Compliance Evaluation Annual Report Monitoring Representative Outfalls Visual and Analytical Monitoring Rainfall Volume Calculation

16 AECOM Environment ii 6.0 SWPPP Revisions Certification List of Appendices Attachment A General Permit Attachment B General Location Map Attachment C Site Map Attachment D Certification of Non-Storm water Discharges Attachment E Local Emergency Response Plan Attachment F Training Records Attachment G Quarterly Inspections Attachment H Visual Monitoring Attachment I Analytical Results Attachment J Corrective Action and SWPPP Amendment Log

17 AECOM Environment Introduction This Storm Water Pollution Prevention Plan (SWPPP) has been developed per the requirements of the General Permit ARR000000, Authorization to Discharge Storm Water Under the National Pollutant Discharge Elimination System and the Arkansas Water and Air Pollution Control Act, issued by the Arkansas Department of Environmental Quality (ADEQ), Water Division. (See Attachment A for a copy of this permit.) This permit originally became effective on July 1, 2009, and expires on June 20, State regulations on the issuance of general discharge permits are located at A.C.A and ADEQ Regulation in the state administrative code. The applicability of these regulations is determined by a facility s Standard Industrial Classification (SIC) code United States (U.S.) Environmental Protection Agency s (USEPA s) regulations on storm water, which are located at 40 Code of Federal Regulations (CFR) and the Arkansas General Permit ARR000000, Part I, Section 1.5 identify the SIC codes that are subject. These regulations identify specific industrial sectors (by SIC code) that must comply with the requirements if they discharge storm water. If a facility s SIC code is on this sector list, the facility must submit a Notice of Intent (NOI), implement a SWPPP, and comply with the permit requirements. Under the provisions of the General Permit, Halliburton Energy Services facility at Zero Road (SIC code 1389) is categorized under Sector I and is required to develop and implement a SWPPP prior to submittal of the initial NOI. The site-specific storm water permit number is ARR00B114. This SWPPP will be retained on-site and made available to ADEQ, USEPA, or local government officials upon request. This SWPPP has been prepared by AECOM Technical Services, Inc. (AECOM) on behalf of Halliburton Energy Services. The SWPPP was prepared following guidance provided by: ADEQ s General Permit ARR000000, Authorization to Discharge Storm water Under the National Pollutant Discharge Elimination System and the Arkansas Water and Air Pollution Control Act. ADEQ s Industrial Storm Water General Permit SWPPP Template. The USEPA s Storm water Management for Industrial Activities Developing Pollution Prevention Plans and Best Management Practices (BMPs). The USEPA s Storm water Management for Industrial Activities Developing Pollution Prevention Plan and BMPs Summary Guidance. The USEPA s Guidance Manual for Developing BMPs. In accordance with the requirements of the General Permit, this SWPPP details the following: Storm water pollution prevention team Facility identification Facility description General location and site map with required features indicated Evaluation for non-storm water discharges and certification Description of receiving waters Description of potential pollutants and sources

18 AECOM Environment 1-2 Storm water control measures (BMPs) Maintenance of BMPs Employee training program Inspections and monitoring Annual reporting 1.1 Facility Identification Facility Information Name: Halliburton Energy Services Address: 5801/5901 South Zero Street Fort Smith, Arkansas Sebastian County Latitude: 35º N Longitude: -94º W Method for determining latitude/longitude: Google Earth Estimated area of industrial activity: acres Discharge Information Does this facility discharge storm water into a city storm drain or sewer? No Name of water(s) that receive storm water from your facility: Little Massard Creek Are any of your discharges directly into any segment of impaired water? No Are any of your storm water discharges subject to effluent guidelines? No Primary SIC code: 1389 NAICS code: Permit Number: ARR00B114 Contact Information Facility Owner/Operator: Halliburton Energy Services 5801/5901 South Zero Street Fort Smith, Arkansas (479) Person responsible for implementation of SWPPP and permit compliance: Chris Allison, Facility Supervisor (479) Chris.Allison@halliburton.com Greg Roberts, HSE Technical Professional (479) Greg.Roberts@halliburton.com

19 AECOM Environment Storm Water Pollution Prevention Team The facility s Storm Water Pollution Prevention Team and their responsibilities are as follows: Chris Allison, Facilities Supervisor and SWPPP Team Co-Leader Team co-leader and responsible for implementing the SWPPP, overseeing the inspection and maintenance of BMPs, ensuring that corrective actions are implemented and adequate resources are available for compliance with the general permit. Greg Roberts, HSE Technical Professional and SWPPP Team Co-Leader Team co-leader and responsible for implementing the SWPPP, overseeing the inspection and maintenance of BMPs, ensuring that corrective actions are implemented and adequate resources are available for compliance with the general permit. Billy Copeland, Coordinator DME, Team Member Team member, and responsible for preventing and responding to spills and leaks. Responsible for implementation of response and clean-up procedures. Responsible for overseeing day-to-day implementation of BMPs including inspections and visual monitoring. Meets with other team members periodically to review SWPPP and evaluate effectiveness of BMPs. Thel Renfro, Material Specialist, Team Member Team member, and responsible for preventing and responding to spills and leaks. Responsible for implementation of response and clean-up procedures. Responsible for overseeing day-to-day implementation of BMPs including inspections and visual monitoring. Meets with other team members periodically to review SWPPP and evaluate effectiveness of BMPs. Shawn Beshears, Admin Associate, Team Member Team member, and responsible for preventing and responding to spills and leaks. Responsible for implementation of response and clean-up procedures. Responsible for overseeing day-to-day implementation of BMPs including inspections and visual monitoring. Meets with other team members periodically to review SWPPP and evaluate effectiveness of BMPs. Chris Hilliard, Tool Tech, Team Member Team member, and responsible for preventing and responding to spills and leaks. Responsible for implementation of response and clean-up procedures. Responsible for overseeing day-to-day implementation of BMPs including inspections and visual monitoring. Meets with other team members periodically to review SWPPP and evaluate effectiveness of BMPs. 1.3 Facility Characteristics Halliburton Energy Services in Fort Smith, Arkansas (also referred to as the Zero Street facility) provides various types of services to the oil and gas industry, including cementing, fracturing, nitrogen, service tools, equipment and electronic repairs. HESI also operates a vehicle maintenance and repair shop for oil field service equipment. The facility historically operated a sand plant, a bulk cement blending and load-out facility and nitrogen storage tanks. The equipment for these operations are still in place, however, these activities have been discontinued. The southern half of the property is used for parking oilfield vehicles when they are not being used in the field and vehicles/equipment awaiting repair. There is an iron storage area on the east side of the property where spare parts and piping (some painted and some unpainted) are stored.

20 AECOM Environment 1-4 Oilfield chemicals are not usually stored on site for extended periods they are usually brought on site to load vehicles immediately for a specific project. There is an explosives storage area at the far north end of the property. At the northwest corner, there is an area for empty drum storage, and grit is stored on the ground with a secondary visqueen liner under cover in a dedicated area. The facility s outdoor wash bay and associated oil/water separator is on the west side of the facility and the operation is entirely contained. Just south of the wash bay is a covered and contained chemical storage area, designated for limited use, typically housing only a few chemical containers. The south end of the property has two buildings, the warehouse/office building, and Maintenance Shop. See site map in Attachment C. Storm water that contacts industrial activities on the south half of the site flows north into the Little Massard Creek which bisects the property. Storm water that contacts industrial activities on the north half of the site flows south into the creek. Both the north and south sides of the creek are bermed so that flow is directed to the outfalls. There are nine distinct outfalls, six from the south half, and three from the north half. Each outfall has an outlet pipe with a discharge valve that is normally left in the open position, but can be closed to contain a spill. Industrial activity areas are either covered by gravel or bare ground. The only impervious surfaces are the wash bay area, chemical storage loading area, nitrogen storage pad, buiildings, and employee parking lot. Annual average total precipitation at the facility is approximately 45 inches; the wettest month is May. 1.4 General Location Map Attachment B contains a USGS quadrangle map and aerial photograph of the Zero Street facility and surrounding area. 1.5 Site Map Attachment C contains a detailed site map of the facility and the required features as listed in the General Permit, where applicable.

21 AECOM Environment Potential Pollutant Sources 2.1 Description of Potential Pollutants and Sources The following table lists all the areas of industrial activity at the Zero Street facility and the activities and associated pollutants for each area. It also identifies areas with the potential for spills and leaks and those areas that have experienced spills or leaks in the last 3 years. Activity Area Warehouse and Admin Building Iron Storage Area Vehicle parking areas Grit Storage Wash Bay Chemical Storage Area Activities Occasional storage of oils and chemicals Storage of spare parts and piping Vehicle parking Stockpiling of grit (covered) Vehicle washing and collection of oil/water Storage of oils and chemicals Maintenance Shop Vehicle maintenance and repair Potential Pollutants Small quantities of oils and chemicals Trace metals Fuel or fluid from vehicles Potential for Spills/Leaks? Yes, when materials are unloaded Spills/Leaks in Previous 3 years None Yes, from exposure None Yes, from leaks None Grit material Yes, minimal None Overspray of wash water Small quantities of oils and chemicals Used oil and new oil; antifreeze Yes, minimal Yes, when materials are unloaded/unloaded Yes, when materials are unloaded/unloaded None None None 2.2 Non-Storm water Discharges There are no non-storm water discharges from the facility. A survey for potential non-storm water discharges is conducted and documented at least once a year. Any non-storm water discharges that are identified and not allowed under the General Permit will be eliminated immediately. Attachment D provides a certification log with specific details on the annual survey and any actions taken.

22 AECOM Environment Storm Water Controls Best Management Practices Through the use of BMPs, Halliburton Energy Services will, to the extent feasible, reduce the potential for the release of significant amounts of pollutants. Standard BMPs, as well as site-specific BMPs, have been adopted for the site. 3.1 Minimize Exposure Exposure to pollutant sources will be minimized at all times. Oils and chemicals will be stored indoors or within secondary containment. All material transfers will be continuously attended, and small spills and leaks will be cleaned up immediately. Vehicle and equipment cleaning is conducted only in the contained wash bay. 3.2 Good Housekeeping Good housekeeping is the cornerstone to a successful BMP program. When good housekeeping is done properly, the potential for everyday activities to release materials is greatly reduced. The site s existing operations have an informal, yet well established, housekeeping program. BMPs for housekeeping may include the following: Place drip pans under any leaking equipment. Maintain dedicated labeled containers for certain wastes, such as scrap metal, cardboard and office trash. Sweep floors of buildings regularly. Keep oils and chemicals stored indoors as much as possible. Clean up outside spills and leaks immediately, if possible, with dry absorbent materials. Keep lids closed on all dumpsters and roll-off boxes, and dispose of contents regularly. Do not add free liquids to outside trash containers. Label all containers with contents. Continuously monitor all fueling and truck loading/unloading operations. Check condition of all outside storage areas regularly. Employees will be trained annually on good housekeeping measures. 3.3 Maintenance of Structural and Non-Structural Controls The primary structural control is the grading and sloping of the site and all industrial activity areas to the nine outfalls. The outfalls each have a discharge pipe with a valve. These valves can be quickly closed in the event of a release to contain the material. The outfalls are regularly inspected to ensure they are in good condition, and that there is no evidence of oils or chemicals. Employees will note and report any unusual erosion or sediment accumulation conditions throughout the year, especially after unusually heavy storm events. These conditions will be addressed as soon as possible. Outdoor secondary containment areas also are regularly inspected to ensure there are no cracks or breaks in the containment or any evidence of leaks or spills.

23 AECOM Environment Spill Prevention and Response Measures General Prevention Measures In addition to the BMPs already described, the following general BMPs are applied facility-wide: Spill response materials will be stored in readily accessible areas. The plant has Material Safety Data Sheets for all hazardous materials on site, and electronically. Employees are trained annually on spill prevention and response procedures. The plant is a small quantity generator (SQG) of hazardous waste. Hazardous waste is generated very occasionally, and is managed according to applicable regulations. Operating and storage areas are inspected daily for leaks and spills. Spill kits are maintained in several areas of the plant. Employees are trained on their location and the use of response materials. The kits are regularly inspected to ensure that adequate materials are available. Truck staging and loading areas are informally inspected daily, and formally inspected quarterly for accumulation of solids or liquid leaks. Spills and leaks will be cleaned up immediately. The site s Spill Prevention, Control, and Countermeasures (SPCC) Plan details site-specific measures to reduce the potential for an oil or chemical spill and contains procedures for spill response. The SPCC Plan should be used in conjunction with this SWPPP for pollution prevention to the best extent practicable General Response Procedure In case of a spill or emergency, facility employees are trained to use the Local Emergency Response Plan (LERP). Attachment E contains a copy of the LERP. The LERP is reviewed periodically to ensure it is appropriate to all emergency situations, including spills. All spill residue and used clean-up materials will be disposed of according to applicable federal, state, and local regulations. 3.5 Erosion and Sediment Controls The facility site slopes to the Little Massard Creek on both sides the northern half slopes south and the southern half slopes north. During a rain event, storm water would sheet flow to the nine outfalls on both sides of the creek. Due to the topography and gravel cover, the potential for significant erosion and sediment transport is relatively low. The property is regularly evaluated for loss of soil and gravel, and re-grading and gravel replacement are conducted when necessary. No areas with ongoing soil erosion have been identified during inspections; however, if such an area develops, the area would be re-graded and additional structural controls such as vegetative cover, riprap or other stabilization will be evaluated and implemented. 3.6 Miscellaneous/Additional BMPs Preventive Maintenance Preventive maintenance activities are essential for the efficient operation of the facility. Currently, HESI performs preventive maintenance on a regular schedule to maintain mechanical equipment and systems in proper, good working condition. In addition to the regularly scheduled equipment maintenance, the preventive maintenance program includes the following:

24 AECOM Environment 3-3 Checking tanks and piping for leaks and spills. Maintaining written updated procedures for maintenance and operation of all equipment. Labeling all containers and equipment reservoirs with contents. Regularly checking equipment and vehicles for leaks and proper operation. Calibrating operating instrumentation according to manufacturer s specifications, and maintaining a written calibration log identifying the date, time, and person who performed the calibration Dust Generation and Vehicle Tracking The entrances/exits for the facility are regularly inspected to ensure that material is not being tracked off the property. If accumulated material is found, facility personnel will be assigned to removing the material and disposing of it properly Management of Run-on and Runoff There is a minimal volume of storm water that runs off the adjacent roadway on the south side onto the property. Some of it is collected in and directed toward the creek in a vegetated swale between the warehouse/office building and the maintenance shop. All storm water run-on and storm water from industrial activity areas is directed to the nine outfalls along both sides of the creek Salt Storage Piles There are no storage piles of salt or salt-containing piles on the facility property. 3.7 Employee Training In order for this SWPPP and described BMPs to be effective, both management and staff must work together to meet the objectives of the SWPPP. To achieve this, employee training will take place relative to the contents of this document at least annually. Upon hiring, new employees also will receive training on the SWPPP. Initial and refresher training sessions may include, but are not limited to, the following: Purpose and objectives of the SWPPP and BMPs Reminders on the importance of good housekeeping Material handling and storage procedures Spill prevention practices Results of recent BMP inspections Location and use of spill response materials Spill response and reporting Site security Preventive maintenance The specific content of training sessions will be decided by the Storm Water Pollution Prevention Team depending upon the experience of the personnel in attendance, the results of annual reviews, modifications since the last training and past performance of employees in implementing the SWPPP.

25 AECOM Environment 3-4 Records of training are maintained electronically in Halliburton University Training Center, on the HESI Intranet. 3.8 Recordkeeping All records associated with General Permit compliance will be maintained in this SWPPP in various attachments at the end of the main Plan. A minimum of 3 years of records will be maintained.

26 AECOM Environment Inspections 4.1 Quarterly Inspections Once per quarter, facility personnel, who are trained on storm water inspections, will conduct a full inspection of the following site requirements. A minimum of one inspection a year will be conducted during a storm event (defined as an event that results in an actual discharge from the facility). Each inspection will include: 1. Observations made at the discharges from all nine outfalls; 2. Observations for the presence of floating materials, visible oil sheen, discoloration, turbidity, odor, etc. in the discharges; 3. Observations of the condition of the storm water outfalls; 4. Observations for the presence of non-storm water discharges; 5. Verification that the descriptions of potential pollutant sources are accurate; 6. Verification that the site map reflects current conditions; and 7. An assessment of all control measures and BMPs for effectiveness, need for maintenance/repair, reasons for maintenance/repair and an associated schedule, and locations where additional or different BMPs are needed. A site-specific checklist, which is located in Attachment G, will be used to document the evaluation of the BMPs and any corrective actions necessary to ensure effectiveness. Completed checklists also are maintained in Attachment G. When revisions to the SWPPP are recommended due to the quarterly inspections, a description of the proposed changes will be attached to the completed inspection checklist within 14 days of the inspection. The proposed timeframe for implementing any changes also will be identified. Revisions will be made within 60 days after the inspection. 4.2 Comprehensive Site Compliance Evaluation A comprehensive site-wide compliance evaluation will be conducted at least once a year. The following activities will be included: Visual inspection of areas with industrial activities for evidence of pollutants. Evaluation of adequacy of control by BMPs. Evaluation of proper implementation and maintenance of BMPs. Visual inspection of spill response equipment. Accuracy of SWPPP in description of the facility and BMPs. A report summarizing the inspection details, observations and corrective actions will be written and retained with this SWPPP. 4.3 Annual Report An annual report summarizing the site inspections and the comprehensive site compliance evaluation will be prepared and submitted to ADEQ. The reporting period will be January 1 through December 31 of the previous year, and it will be submitted by the following January 31. The Annual Report will include:

27 AECOM Environment 4-2 Name of permittee, address, phone number Permit tracking number Facility name and physical address Contact person name, title and phone number Summary of inspection dates Corrective action documentation and status of any outstanding corrective actions The signed copy of each annual report will be submitted to: General Permits Section Water Division Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR 72118

28 AECOM Environment Monitoring 5.1 Representative Outfalls The facility has a total of nine outfalls that discharge storm water that is exposed to industrial activities. (See facility layout). Only four outfalls are sampled because of certain outfalls that basically discharge storm water exposed to similar activities. The selection of those representative outfalls was conducted as follows: Outfalls 1 and 9 are adjacent to one another and discharge storm water from the southeast portion of the facility where equipment and vehicles are parked, iron and piping are stored, and the warehouse and offices are located. Discharge volumes are roughly equivalent, and the potential pollutants are most likely fuel and oil, oilfield chemicals, and corrosion products residue from the iron storage. Both discharges have a valve that can be quickly closed, and both drainage areas are partially covered in gravel. Outfall 1 is designated as the representative outfall. Outfalls 2-5 discharge storm water from the southwest portion of the plant where equipment and vehicles are parked, drums and scrap iron are stored, as well as a used oil tank and maintenance shops. Discharge volumes are roughly equivalent, and the potential pollutants are most likely fuel, oil, and oilfield chemicals residue. All four discharges have a valve that can be quickly closed, and all drainage areas are partially covered in gravel. Outfall 4 is designated as the representative outfall. Outfalls 6 and 7 discharge storm water from part of the northwest portion of the facility where there is grit storage, the wash bay, and the covered chemical storage area. Discharge volumes are roughly equivalent, and the potential pollutants are most likely fuel and oil, oilfield chemicals, wash bay overspray and grit. Both discharges have a valve that can be quickly closed, and both drainage areas are partially covered in gravel. Outfall 6 is designated as the representative outfall. Outfall 8 discharges storm water from part of the northwest portion of the facility where there is an iron maintenance shop, grit storage, the wash bay, and the covered chemical storage area. It is situated in a different section than Outfalls 6 and 7 so it has been selected as an outfall to be sampled. As a result of this analysis, Outfalls 1, 4, 6, and 8 are the outfalls to be monitored on a semi-annual basis. 5.2 Visual and Analytical Monitoring The facility will collect at least one storm water sample at the discharge from the four representative outfalls during a rain event twice a year. One sample will be collected in the period January - June, and the second sample will be collected in the period July December. Sample collection will be scheduled for a storm event that results in a discharge from the outfalls and is at least 72 hours since the previous storm event. At least once a year, a sample will be taken in a clean, clear glass or plastic container during daylight hours, and it will be examined for the following: Color Odor Clarity Floating solids

29 AECOM Environment 5-2 Settled solids Suspended solids Foam Oil sheen Other obvious indicators of storm water pollution The results of this examination will be noted on the visual monitoring report form that can be found in Attachment H. Previous visual monitoring reports also are located in Attachment H. For both semi-annual sampling events, a sample of storm water will be collected and a ph will be measured within 15 minutes of sample collection. The samples will then be sent to an analytical laboratory for measurement of oil and grease (O&G), total suspended solids (TSS) and Chemical Oxygen Demand (COD). The analytical results will be compared against the benchmark values cited in the general permit which are as follows: Parameter ph COD TSS O&G Benchmark Value Minimum 6.0 s.u. Maximum 9.0 s.u. 120 mg/l 100 mg/l 15 mg/l All results will be compared to the benchmark values and will be maintained in this SWPPP. If the analytical result is less than the benchmark value for a parameter for four consecutive monitoring periods, the facility may request, in writing, to ADEQ that the facility can forego additional sampling for that parameter for the remaining permit period. If a benchmark value is exceeded, the facility will investigate the cause or source of the elevated levels and will develop a corrective action plan to address the exceedance. The results of analytical monitoring are located in Attachment I. 5.3 Rainfall Volume Calculation For each sampling event, the approximate volume of rainfall from each outfall is calculated. This volume is calculated by multiplying the inches of rainfall for the storm event by the square footage of the property and then dividing by nine (the number of outfalls). The cubic feet of water is then converted to total gallons. The flow is multiplied by the run off coefficient. Runoff coefficients used for calculations vary depending on substrate composition such as gravel, concrete, asphalt, etc.