RE: Quarterly Inspection: AFIN Permit Number 0230-S1-R1

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1 Document ID May 17, 2016 The Honorable Dennis Holland Ashley County Courthouse 205 E. Jefferson, Suite 14 Hamburg, AR RE: Quarterly Inspection: AFIN Permit Number 0230-S1-R1 Dear Judge Holland: On May 12, 2016, Heidi Love (Inspector Supervisor) and 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 eddy@adeq.state.ar.us. Sincerely, Gerry Eddy ADEQ Inspector Office of Land Resources Attachment cc: Tammie Hynum, Senior Manager, Office of Land Resources Regulated Waste Programs Revised

2 Arkansas Department of Environmental Quality Solid Waste Management Division Class 1 Landfill Inspection Site Name Ashley County Landfill County Ashley AFIN Facility Address County Rd. 438 West, Hamburg, AR Phone Number Permit Number 0230-S1-R1 Permittee Address 205 E Jefferson, Suite 14 Hamburg, AR Address PDS # Date 5/12/2016 Entry Time 1100 Exit Time 1158 Regulation 22 Operational Standards Category 1 411(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 2 411(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)

3 427 Surface Water Controls 411(h)(1) 418(a)(b) 411(h)(2) 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 X 411(i);427(f) Adequate maintenance of intermediate/final cover vegetation Noted willow trees growing on the south edge of Phase 4 and on north slope of Phase 1 (see photos 1&2). 415 Gas monitoring program 411(o) Leachate leaks or evidence of leachate seepage 426 Survey controls X 429 Leachate collection system The Phase 4 Cell leachate pump controller display indicated inches at the time of inspection. The operator stated the controller was scheduled for repair. This issue was noted on last inspection. 420 Liquid Restrictions Category Implementation of hazardous/unauthorized waste exclusion plan 413(a)(b) Satisfactory daily/alternative cover X 413(c) Satisfactory intermediate cover Noted inadequate intermediate cover on east side of Phase 4 Cell (see photos 3 thru 6). 416(b),411(f)(4) Open burning prohibited 419 Cause discharge/leachate discharge leaving landfill 411(f)(3),419(a)(4) 411(o) 309(c) Depositing waste in standing water prohibited Erosion or other cover defects resulting in exposed refuse Overfill/Off lined area Regulation 22 - Records 421(a)(8), 1203(k) Date of last groundwater monitoring report 9/29/2015 Site Conditions Dry 423(b) Date of last engineering report 3/31/2016 Weather Conditions Overcast 428 Liner construction in progress Yes/No No Notice of liner construction Yes/No N/A Third party CQA on-site during construction Yes/No N/A 412(a) Date of last random inspection for unauthorized waste 5/11/2016 Total # for month 14 (April 2016) 415, 421(e) Date of last quarterly methane monitoring 2/24/2016 Detection level GP 5 > (a) Explosive gas records current? Yes/No Yes 421(g),412(a)(2),701 Date of last special waste received N/A Disposal location N/A 421(d) Previous quarter waste received 3, Tons 1st Quarter (c) Surface water DMR records current? Yes/No Yes Fayetteville Shale Related Yes/No No Out of Compliance with Fayetteville Shale Yes/No N/A Operator Name & Number Lee Ware Christy Lynn Pack Michael Thompson Signature of Inspector With Heidi Love Exit Interview Conducted with Lee Ware Method On site Date 5/12/20106 Time 1155 Class 1Form 7/1/2012 (Revised and Implemented 10/21/2014) For ADEQ Use Only

4 Permit 0230-S1-R1 Photos 1 & 2

5 Permit 0230-S1-R1 Photos 3 & 4

6 Permit 0230-S1-R1 Photos 5 & 6

7 Permit 0230-S1-R1 Photos 7 & 8

8 ~- I!)~ 02dSY FVii?5 +$ Zt REC'O&CAN ant of En"l. ;"' -~'''"" '., ~ MAY Arkansas Department of Environmental Quality 3 { c PLIA ce l Solid Waste Management Division ;;.;.: ~.,; DOCJ'}~ 76~// Class 1 Landfill Inspection.,..,.~, TO: ;? ;::::;z_., SWMD --1 Site Name Ashley County Landfill Coui!!Y_ I Ashley AFIN Facility Address County Rd. 438 West, Hamburg, AR Phone Number I Permit Number 0230-SI-Rl Permittee Address 205 E Jefferson, Suite 14 Hamburg, AR Address PDS # I Date 5112/2016 Entry Time I 1100 Exit Time 1158 Regulation 22- Operational Standards Category (I) Adequate employee facilities 421(a)(b) Record keeping meets requirements specified by regulations 417 Access requirements 411U) Adequate provisions for backup equipment 421(d) 411(k) 423(b) 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 2 411(a) Operations in accordance with permit documents 417(c) 411(c) 411(e) 4ll(f)(l) 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)

9 427 Surface Water Controls 4ll(h)(1) 418(a)(b) 411(h)(2) 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 X 411(i);427(f) Adequate maintenance of intermediate/final cover vegetation Noted willow trees growi~\ \" the south edge of P{'\~ 4 and on north slope of Phase 1 (see photos I 1&2). ~r.:els \1\. ~ r..u:t-.a.h. 415 Gas monitoring program 4ll(o) Leachate leaks or evidence of leachate seepage 426 Survey controls X 429 Leachate collection system The Phase 4 Cell leachate pump controller display indicated inches at the time of inspection. The operator s,tated the controller was scheduled for repair. This iss ue was noted on last in spe411tion. 420 Liquid Restrictions t:,\t:c:nr OCU" To c..ht::.ck:. v:j/ \... ~"4 6Jt;cl,d- r _.,lr~ ~ UlSf>~ Category Implementation of hazardous/unauthorized waste exclusion plan 413(a)(b) Satisfactory daily/alternative cover X 413(c) Satisfactory intermediate cover Noted inadequate intermediate cov ~ r on east side of Phase 4 Cell (see photos 3 thru 6). 416(b),4ll(f)(4) Open burning prohibited tv\ LYe:.. l...-u\k,y V\C.O \VCXJ1 :X~~. 419 Cause discharge/leachate discharge leaving landfill 411(1)(3),4L9(a)(4) 411(o) 309(c) Depositing waste in standing water prohibited Erosion or other cover defects resulting in exposed refuse Overfill/Off lined area Regulation 22 - Records 421(a)(8), 1203(k) Date of last groundwater monitoring report 9/29/20 15 Site Conditions D l)l_ 423(b) Date of last engineering report 3/3 1/20 16 Weather Conditions Overcast 428 Liner construction in progress 1 Yes/No 1 No Notice of liner construction I Yes/No I N/A Third party CQA on-site during construction I Yes/No I N/A 412(a) Date of last random inspection for unauthorized waste 5/ Total # for month 14 (April 201 6) 415, 421(e) Date of last quarterly methane monitoring 2/24/20 16 Detection level GP 5 >100 I 415(a) I Explosive gas records current? I Yes/No I Yes 42l(g),412(a)(2),701 Date of last special waste received NIA Disposal location N/A 42l(d) Previous quarter waste received 3, Tons I st Quarter (c) Surface water DMR records current? Yes/No j Yes Fayetteville Shale Related Yes/No 1 No I Out of Compliance with Fayetteville Shale I Yes/No I N/A A~ 4 Lee Ware Operator Name & Number Christy Lynn Pack Michael Thompson Signature of Inspector With Heidi Love Exit Interview Conducted with Lee Ware I Method I On site I Date 5/ 12/20106 I Time I _i! I Class I Form 7/ (Revised ond Implemented ) For ADEQ Use Only