Please refer to the Summary of Findings section of the attached inspection report and provide a written response for each violation that was noted.

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1 January 29, 2014 Homer Reeves, Water Superintendent City of McCrory WWTP P.O. Box 897 McCrory, AR RE: Compliance Inspection, City of McCrory Wastewater Treatment Plant AFIN: , Permit No.: AR Dear Mr. Reeves: On January 14, 2014, I performed a routine compliance evaluation inspection and sanitary sewer overflow inspection of the above referenced facility. These inspections were conducted in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. A copy of the inspection report is enclosed for your records. Please refer to the Summary of Findings section of the attached inspection report and provide a written response for each violation that was noted. This response should be mailed to the attention of the Water Division Inspection Branch at the address at the bottom of this letter or e- mailed 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 February 14, If I can be of any assistance, please contact me at greenway@adeq.state.ar.us or Sincerely, Michael Greenway District 3 Field Inspector Water Division Page 1 of 5

2 Inspection Report: City of McCrory WWTP, AFIN: , Permit #: AR WATER DIVISION INSPECTION REPORT AFIN: PERMIT #: AR COUNTY: 74 Woodruff PDS #: MEDIA: WN GPS LOCATION: LAT: LONG: Outfall / General Area / Entrance / Sample Point FACILITY INFORMATION INSPECTION INFORMATION NAME: City of McCrory WWTP DATE(S): 1/14/2014 1/14/2014 LOCATION: 500 Angelo Dr. ENTRY TIME: 11:45 13:30 EXIT TIME: 12:10 15:15 CITY: McCrory, AR INSPECTION TYPE: Compliance Evaluation RESPONSIBLE OFFICIAL INSPECTOR ID#: S - State CONTACTED DURING INSPECTION: Yes FACILITY TYPE: 1 - Municipal NAME: Homer Reeves PERMIT EFFECTIVE DATE: 12/1/2009 TITLE: Water Superintendent PERMIT EXPIRATION DATE: 11/30/2014 COMPANY: City of McCrory FACILITY EVALUATION RATING: 1 - Unsatisfactory MAILING P.O. Box 897 FAYETTEVILLE SHALE RELATED: N ADDRESS: FAYETTEVILLE SHALE VIOLATIONS: N CITY, STATE, ZIP: McCrory, AR INSPECTION PARTICIPANTS PHONE & EXT: NAME/TITLE/PHONE/FAX/ /ETC.: Matt Hunter / Operator / Homer Reeves / Water Supt. / FAX: N/A OTHER: N/A AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) S PERMIT U FLOW MEASUREMENT ** STORMWATER U RECORDS/REPORTS S LABORATORY U FACILITY SITE REVIEW U OPERATION & MAINTENANCE S EFFLUENT/RECEIVING WATER U SELF-MONITORING PROGRAM S SAMPLING ** SLUDGE HANDLING/DISPOSAL ** PRETREATMENT ** OTHER: SUMMARY OF FINDINGS This compliance inspection revealed the following: 1. There was excessive vegetation on the levees of the lagoon (Refer to photos 1-3). This violates Part III, Section B, Item 1.a of the Permit. 2. Removed wastes from the barscreen area were not properly disposed of (Refer to photo 4). This violates Part III, Section B, Item 6 of the Permit. 3. The device used for flow measurement was not adequate (Refer to photo 5). The device was also not installed at least 3 times the expected head upstream of the weir, and the measurements were not readable. This violates Part III, Section C, Item 2 of the Permit. 4. A time was not recorded with flow measurements. This violates Part III, Section C, Item 8 of the Permit. The Sanitary Sewer Overflow (SSO) inspection revealed the following: 1.Improper operation and maintenance. This violates Part III, Section B, Item 1.a of the Permit. The following items were noted a) The cover to the wet well was not secured with a lock at the Sewer Pond Station. b) There was excessive grease and solids in the wet well of the Sewer Pond station. c) There was no alarm system at the Sewer Pond Station. GENERAL COMMENTS A letter will be sent to the cognizant official. Refer to the January 14, 2014 SSO inspection report for additional information. INSPECTOR S SIGNATURE: Michael Greenway DATE: SUPERVISOR S SIGNATURE: Jason Bolenbaugh DATE: 1/29/2014 Inspection Report Page 2 of 5

3 Inspection Report: City of McCrory WWTP, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: City of McCrory WWTP Photographer: Michael Greenway Date: 01/14/2014 Time: 11:47 Witness: None Photo #: 1 Description: View of excessive vegetation on the east levee of the lagoon. Photographer: Michael Greenway Date: 01/14/2014 Time: 11:48 Witness: None Photo #: 2 Description: View of excessive vegetation on the southeast levees of the lagoon. Inspection Report Page 3 of 5

4 Inspection Report: City of McCrory WWTP, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: City of McCrory WWTP Photographer: Michael Greenway Date: 01/14/2014 Time: 11:48 Witness: None Photo #: 3 Description: View of excessive vegetation on the southeast levees of the lagoon. Also note the gap in the levee near the center of photo. Photographer: Michael Greenway Date: 01/14/2014 Time: 11:55 Witness: None Photo #: 4 Description: View of removed bar screen waste, which was not adequately contained. Note the wastes on the ground. Inspection Report Page 4 of 5

5 Inspection Report: City of McCrory WWTP, AFIN: , Permit #: AR Water Division Photographic Evidence Sheet Location: City of McCrory WWTP Photographer: Michael Greenway Date: 01/14/2014 Time: 11:59 Witness: None Photo #: 5 View of the chlorine contact chamber and flow measurement device (green level Description: placed vertically). The measurements on the level were not readable, it was too close to the weir, and it restricted flow in front of the weir. Photographer: Michael Greenway Date: 01/14/2014 Time: 14:19 Witness: None Photo #: 6 Description: View of facility records. A time was not recorded with flow measurements. Inspection Report Page 5 of 5

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12 February 27, 2014 Homer Reeves, Water Superintendent City of McCrory WWTP P.O. Box 897 McCrory, AR RE: Inspection Response, City of McCrory Wastewater Treatment Plant AFIN: , Permit No.: AR Dear Mr. Reeves: I have reviewed your response pertaining to my January 14, 2014 inspection of the above referenced wastewater treatment facility. Upon review, the information provided does not sufficiently address the violations referenced in my inspection report. The following items require your immediate attention: 1. The response was not signed by a cognizant official. 2. The response did not specify a date for the completion of woody vegetation removal from the levees and the installation of an alarm system at the sewer pond station. 3. The response did not document that grease and solids were removed from the wet well at the sewer pond station. 4. The new staff gauge should be installed at a distance of 3-4 times the expected head height upstream of the weir for flow measurements. You will need to submit additional photos showing that the new staff gauge has been properly installed. Please provide the ADEQ Water Division Inspection Branch with documentation for the above items no later than March 12, Thank you for your attention to this matter. Should you have any questions, feel free to contact me at or by at greenway@adeq.state.ar.us. Sincerely, Michael Greenway District 3 Field Inspector Water Division

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16 March 27, 2014 Homer Reeves, Water Superintendent City of McCrory WWTP P.O. Box 897 McCrory, AR RE: Inspection Response, City of McCrory Wastewater Treatment Plant AFIN: , Permit No.: AR Dear Mr. Reeves: I have reviewed the responses pertaining to my January 14, 2014 inspection of the above referenced facility. The information provided sufficiently addresses the violations referenced in my inspection report. At this time the Department has no further comment concerning this particular inspection. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. 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 ext. 15, or by at greenway@adeq.state.ar.us. Sincerely, Michael B. Greenway District 3 Field Inspector Water Division