May 12, Josh Crittenden, Environmental Engineer Allens, Inc. P.O. Box 250 Siloam Springs, AR Dear Mr. Crittenden:

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1 May 12, 2011 Josh Crittenden, Environmental Engineer Allens, Inc. P.O. Box 250 Siloam Springs, AR RE: AFIN: Permit No.: 3484-WR-2 Dear Mr. Crittenden: On April 21, 2011, I performed a compliance inspection of the waste treatment and disposal system at your facility in response to a reported line break. The inspection was performed in accordance with the provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated thereunder. This inspection revealed the following violation: An unpermitted discharge of processed waste water entered the waters of the State due to a line break in the force main from the plant to the lagoon. The break occurred west of Highway 59 on Port Road. By definition, this is considered to have placed or caused to be placed waste in a location where it likely to cause pollution to any waters of the State. This is a violation of Section (a) (2) of the Arkansas Water and Air Pollution Control Act 472 and condition number 1 of the permit. The above item requires your immediate attention. Please submit a written response to this finding to Cindy Garner, Water Division Enforcement Branch Manager at the address below. In your response, please include your detailed summary of the incident along with sample results and the plan of action to prevent any future line breaks. This corrective action should be completed as soon as possible, and the written response is due by May 22, If I can be of any assistance, please contact me at Sincerely, District 4 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch Laura Mushinski, Director of Environmental Quality with Allen Canning

2 ADEQ Water Industrial No Discharge AFIN: Permit #: 3484-WR-2 ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY NO DISCHARGE INDUSTRIAL PERMIT INSPECTION FORM AFIN: Log No.: N/A Permit No.: 3484-WR-2 Inspection Date: April 21, 2011 Media: Water Inspector: Jeff Tyler Compliance Status: IN / OUT 1A. Name of Facility: Allen Canning Company-Van Buren Plant Address: 700 South 12 Street-Van Buren County: Crawford 2A. Name of On-Site Representative: Josh Crittenden- Env. Engineer ( ) 3A. Name of Responsible Official: Roderick Allen Address: P.O. Box 250 Siloam Springs Telephone: A. Parent Company: N/A Address: N/A Telephone: N/A 5A. Description of Process (including type of industry, materials produced, and major byproducts): Vegetable processing plant which cans various products including potatoes, spinach, mustard greens, green beans and other seasonal products. 6A. Any complaints registered against this permitted facility? Yes No If yes, give date and description of complaint: No complaints in A. Are there any additions, modifications, or corrections to the facility since the last inspection? Yes No If yes, explain: Excessive solids located in lagoon are being addressed. No Discharge Industrial Report Page 2

3 ADEQ Water Industrial No Discharge AFIN: Permit #: 3484-WR-2 1B. Furnish a simplified flow diagram of the treatment system and include main components, flow sequence through plant, and calculated or estimated flows. Plant Wastewater Pump Station Settling basin Separation Channels Anaerobic Lagoon Second Lagoon Spray Irrigation 2B. Nearest Stream: Flat Rock Creek to Hollis Lake to Arkansas River 3B. Does wastewater from this facility cause adverse effect on the waters of the State: Yes No If yes, describe: Line break has allowed waste water to enter waters of the State. 4B. Are operating records kept as required by permit? Yes No N/E If no, explain: 5B. Are maintenance records kept as required by permit? Yes No N/A If no, explain: 6B. Are Samples routinely taken? Yes No N/E 7B. Does the sampling program meet the requirements of the permit? Yes No N/E If no, explain: 8B. What laboratory does the facility use? Data Testing Address: 3434 Country Club-Fort Smith Telephone: No Discharge Industrial Report Page 3

4 ADEQ Water Industrial No Discharge AFIN: Permit #: 3484-WR-2 1C. Do laboratory procedures and records meet the requirements of the permit? Yes No N/A If no, explain: 2C. Is contaminated runoff a problem? Yes No N/A If yes, explain: Runoff from the line break entered the waters of the State. 3C. Is sludge disposal required? Yes No N/A If yes, describe (including final destination): Problems with excessive solids in lagoon are being addressed. 4C. Is the treatment system being properly operated and maintained as required by permit? Yes No N/A If no, explain See summary of findings/comments SUMMARY OF FINDINGS/COMMENTS Allen Canning reported a break in their force main line from the plant to the lagoon on Site visit on revealed that an unpermitted discharge of processed waste water occurred west of Highway 59, on Port Road. Waste water pooled in the pasture and migrated north to an unnamed tributary of Hollis Lake. A small pit was excavated down slope of the line break to contain the leaking water, this wastewater was vacuumed and then transported to the lagoon. A temporary berm was also constructed in the small tributary in an attempt to restrict the flow of the wastewater from migrating further downstream. Allen Canning collected field samples of the tributary at the confluence of the inflow of wastewater and at a location upstream from that point. Lab results will be provided for these samples with the detailed summary of the incident by Allen Canning. Inspector Signature: Jeff Tyler Date of Report: May 9, 2011 Signature of Reviewer: Date of Review: May 10, 2011 No Discharge Industrial Report Page 4

5 ADEQ Water Industrial No Discharge AFIN: Permit #: 3484-WR-2 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Allen Canning line break located on Port Road in Crawford County. Photographer: Jeff Tyler Witness: N/A Photo # 1 Of 4 Date: Time: 1006 Description: Line break which allowed for the unpermitted discharge to occur. Photographer: Jeff Tyler Witness: N/A Photo # 2 Of 4 Date: Time: 1008 Description: Processed waste water in pasture migrating to tributary. No Discharge Industrial Report Page 5

6 ADEQ Water Industrial No Discharge AFIN: Permit #: 3484-WR-2 Water Division No Discharge Industrial Photographic Evidence Sheet Location: Allen Canning line break located on Port Road in Crawford County Photographer: Jeff Tyler Witness: N/A Photo # 3 Of 4 Date: Time: 1020 Description: Excavated pit acting as containment for the leaking wastewater. Photographer: Jeff Tyler Witness: N/A Photo # 4 Of 4 Date: Time: 1046 Description: Berm constructed in the small tributary to restrict the wastewater from flowing further downstream. No Discharge Industrial Report Page 6

7 Bolenbaugh, Jason From: Tyler, Jeffery Sent: Tuesday, June 07, :56 AM To: Bolenbaugh, Jason Subject: FW: Allens line break April 21, 2011 Attachments: ADEQ response letter-5_22_2011 Model (1).pdf I think this is what you are looking for. Sorry for my delayed response I was out on sick leave yesterday. Jeff Tyler District 4 Field Inspector ADEQ - Water Division From: Joshua Crittenden [mailto:jcrittenden@allens.com] Sent: Friday, May 20, :55 PM To: Garner, Cindy Cc: Tyler, Jeffery; Neel Sathi; Laura Mushinski; Earl Wells Subject: Allens line break April 21, 2011 Attached is a copy of the response letter to ADEQ. Please let me know if you have any problems viewing this . Joshua Crittenden Engineering and Environmental Dept. Allens, Inc. Tel , ext. 453 Cell jcrittenden@allens.com 1

8 May 20, 2011 Cindy Garner Water Division Enforcement Branch Manager ADEQ 5301 Northshore Drive North Little Rock, AR RE: Force Main Line Break on April 21, 2011 Allens, Inc Van Buren Facility Permit No WR-2 Dear Ms. Garner: The purpose of this letter is to follow- up on the verbal notification to the Arkansas Department of Environmental Quality (ADEQ) regarding an accidental spill from the Allens, Inc. (Allens) facility in Van Buren on April 21, As reported to ADEQ, Allens experienced a break in the wastewater line that runs from processing plant to the wastewater lagoons and irrigation fields. The following describes the events that took place on April 21, 2011: On April 21, 2011, at approximately 1:28 am Allens plant employees noticed a slight discharge pressure drop (100 psi to 80 psi) in gauges at the facility s wastewater pump house. Historically, the pressure drops to 20 psi whenever there is a line break. The plant manager was notified and plant personnel were sent to investigate possible line break. During the course of inspection, at and around the irrigation fields, no evidence of a line break was found. At approximately 2:03 am, the plant was shut down until further investigations could be made in the daylight. Allens corporate personnel were contacted by the Van Buren plant employees of the line break and its approximate location around 6:30 am. Location was determined to be near the Five Rivers Distribution and Van Buren Wastewater facility entrances. After initial location of line break was found, Harris Construction was contacted and repair work was started at approximately 7:00 am and was finished around 3:00 pm. Due to the location of line break, Allens personnel were unable to estimate the amount of wastewater that was leaked from the line break. See Drawing 1 for site location. Two samples were taken around the impacted area at 8:00 am and 8:15 am. Samples were sent to Data Testing to be analyzed. Specific parameters for the lab samples were BOD5, Allens, Inc. PO Box E. Main Street Siloam Springs, AR 72761

9 TSS, Total Nitrogen, ph, and Chlorides. See attachments for analytical data from Data Testing. See Below. Around 8:22 am Allens made contact with the ADEQ by phoning Jeff Tyler. Mr. Tyler ran field tests on-site for ph and DO. There was a mix-up with the samples collected during the clean-up. Samples were collected with Jeff Tyler, placed in a refrigerator initially, then transferred to a cooler, and the cooler was filled with ice. Lawrence Dangas recalls bringing the samples in the cooler to Data Testing in Fort Smith. During preparation of this letter, Allens contacted Data Testing to get the results and Data Testing indicated they had no record of these samples at the lab. Allens cannot locate their copy of the chain-of-custody either. So, although it was Allens intention to have sample results from the spill, this mix-up means that results cannot be provided. Allens will improve their procedures for chain-of-custodies for samples so that the documentation about sample collection and delivery to the lab will be available in any future events. If the lab finds the samples at a later date, Allens will forward the results to ADEQ. If you have any questions or concerns, please feel free to contact me by phone at (479) or by at jcrittenden@allens.com. Sincerely, Allens, Inc. Joshua Crittenden, EIT Engineer cc: Earl Wells, Allens Van Buren Neelakandan Sathiyakumar, Allens Laura Mushinski, Allens Jeff Tyler, ADEQ Allens, Inc. PO Box E. Main Street Siloam Springs, AR 72761

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11 June 13, 2011 Mr. Josh Crittenden Allens, Inc. P.O. Box 250 Siloam Springs, AR RE: AFIN: , NPDES Permit No.: 3484-WR-2 Response to Inspection # Dear Mr. Crittenden: The Department has received your secondary response to the April 21, 2011 inspection of your facility by our District Field Inspector, Jeff Tyler. Your letter appears to satisfy the discrepancies identified during the visit. The Department expects the corrective actions taken will be maintained to ensure consistent compliance with the requirements of the permit. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. The Department will keep the inspection and response on file. If future violations occur that require enforcement action, the Department will consider the inspection and response as required by the Pollution Control and Ecology Commission Regulation No. 7, Civil Penalties. This regulation requires the Department to consider the past history of your site and how expeditiously the violations were addressed in determining any civil penalty that may be necessary for any future violations. If we need further information concerning this matter, we will contact you. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at or you may me at Sincerely, Jason Bolenbaugh Enforcement Analyst Water Division Enforcement Branch