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1 STATE OF ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 8001 NATIONAL DRIVE, P.O. BOX 8913 LITTLE ROCK, ARKANSAS PHONEo (501) FAXo (501) AFIN No Permit No WR-2 Effective Date Expiration Date A-1 Vacuum Services 4710 Genoa Road Texarkana, Arkansas This permit is your authority to construct, operate, and maintain the waste disposal system in Section 13, Township 15 South, Range 27 West, in Miller County as set forth in your application received August 2, This pennit is issued subject to provisions of the Arkansas Water and Air Pollution Control Act (A.C.A. Sec et seq.) and the following conditions: 1. This pennit is for the beneficial land-application of grease-trap waste and carwash solids. Waste shall not be discharged from this operation to the waters of the State or onto the land in any manner that may result in runoff to the waters of the State. 2. The waste disposal system shall be operated and maintained in accordance with the Waste Management Plan (WMP) as approved by the Department of Environmental Quality. 3. The system shall be serviced by qualified personnel and maintained in good operating condition at all times. 4. Bypassing of the system is prohibited and may result in the revocation of this permit and/or other appropriate enforcement action by the Department. 5. There shall be no increase in the volume or strength of the waste being treated by the system except within design limits covered in the WMP approved by the Department. 6. This pennit may be revoked or modified at any time, if in the opinion of the Department, it is necessary to prevent or abate pollution of any waters of the State. 7. Nothing herein contained shall be construed as releasing the pennittee from any liability for damage to persons or property by reason of the installation, maintenance or operation of the system. 8. This pennit is issued in reliance upon the statements and representations made in the application and the WMP. The Department has no responsibility for the adequacy or proper functioning of the system. 9. Any violations to this permit must be reported to the Department immediately. PLEASE NOTE ADDITIONAL CONDITIONS ON THE ATIACHED SHEETS. By: Martin Maner, P.E. Chief, Water Division Date

2 General Requirements ADDITIONAL CONDITIONS STORAGE & LAND-APPLICATION OF GREASE-TRAP WASTE AND LAND-APPLICATION OF CARW ASH SOLIDS FOR A-1 VACUUM SERVICES PERMIT NO WR-2; AFIN NO !0. Only wastes which are not classified as a hazardous waste under state or federal regulations may be land applied as fertilizer or soil conditioner. 11. Plant Available Nitrogen (PAN) shall not be applied at a rate exceeding the annual nitrogen uptake of the crop. At no time shall the nitrogen application rate (PAN/acre-year) be allowed to exceed the site specific rate approved by the Department. 12. Waste shall not be land-applied to slopes with a gradient greater than 15%, or to soils that are saturated, frozen or covered with snow, or during precipitation or when precipitation is imminent. 13. In the event that a waste cannot be land-applied, grease-trap waste shall be disposed by a method approved by the Director. 14. During land-application operation the wastes shall be evenly distributed over the land-application area. 15. Waste shall not be applied to slopes with a gradient greater than 15%; or to soils that are saturated, frozen or covered with snow, and during rain or when precipitation is imminent. 16. Waste shall not be spread within 50 feet of rock outcrops and property lines;!00 feet of wetlands, lakes, ponds, springs and streams, and sinkholes; 200 feet of drinking water wells; 300 feet of occupied buildings, water supplies or extraordinary resource body of water. 17. The permittee shall not cause any underground drinking water source to exceed the limitations expressed in federal regulations 40 CFR 257 Appendix I. 18. The permittee shall not cause or contribute to the taking of life or the destruction or adverse modification of the critical habitat of any endangered or threatened species of plant, fish or wildlife. 19. The permittee shall take all necessary measures to reduce obnoxious and offensive odors. Equipment shall be properly maintained and operated to prevent spillage, leakage or discharges. 20. Disposal of the waste in a flood plain shall not restrict the flow of the base flood, reduce the temporary storage capacity of the flood plain, or result in a washout of solid waste, so as to pose a hazard to human life, wildlife or land and water uses. 21. The permittee shall give 120 days prior notice to the Director of any change planned in the waste disposal practices.

3 22. Any additional land-application sites must have a waste management plan approved by the Department before it can be used. This normally requires a permit modification. 23. If the permittee wishes to continue the activities regulated by this permit after its expiration date, the permittee must apply and obtain a new permit. The complete application must be submitted to the Department at least 120 days before the expiration date of the permit. The Director may grant permission to submit an application less than 120 days in advance but not later than the permit expiration date. 24. The permit conditions will continue in effect past its expiration date pending issuance of a new permit, provided that: a. The permittee has timely submitted a complete application as described in Condition 23 above, and b. The Director, through no fault of the permittee, does not issue a new permit prior to the expiration date of the previous permit. Grease-trap Waste Storage and Land-application Requirements 25. Ceiling Concentration of Pollutants: If any one of the pollutant concentrations in the grease-trap waste exceeds the concentrations below, the grease-trap waste cannot be land applied. (All units are expressed in mg/kg, unless otherwise specified.) TABLE I Ceiling Concentration of Elements in mg/kg Arsenic Cadmium Chromium Copper Lead Mercury Nickel Selenium Zinc Cumulative Pollutant Loadings Grease-trap waste applied to land shall not exceed the total amounts of cumulative element loadings listed in the table below. If background soil element concentrations exceed the loadings listed below, land application of waste is prohibited. TABLE2 Cumulative Loadings of Elements in kg!ha (lbs/acre) Arsenic Cadmium Chromium Copper Lead (37) (35) (2700) (1350) (270)

4 Mercury Nickel Selenium Zinc (15) (378) (90) (2520) 27. The storage tank area and its surroundings must be maintained perfectly clean and in top sanitary conditions at all times. 28. Land-application of grease-trap waste shall be done by subsoil injection to a minimum depth of six (6) inches, or by applying the waste on a furrow cut having a minimum depth of eight (6) inches. The area shall be immediately disked to incorporate the applied material to the soil. 29. Materials accumulated in the storage tank or the storage tank dike shall be removed to maintain the tanks volume and the dike's design volume. Materials collected in the berm shall be only disposed by methods approved by the Department 30. The land application of grease-trap waste is limited to no more than 20,000 Ibs. of Oil and Grease per acre per year or 30,000 gallons per acre per year, whichever is the least. The permittee is responsible for maintaining the proper ph of the soil for vegetation growth. The soil ph shall not be less than 5.7. Carwash Solids Land-application and Storage Requirements 31. The permittee must take a representative sample of carwash solids for every fifteen (15) cubic yards collected or fraction thereof. 32. The permittee must determine the TPH concentration in the solids prior to land-application. If the concentration is greater than 2,000, other methods approved by the Department shall be used for disposal. 33. The solids must be stored in a designated-covered area to avert contamination of runoff water. The solids must be stock piled under a roof, or covered with a suitable waterproofing material properly secured over the waste. 34. Land-application of of carwash solids can only be performed once per year on the same tract of land. Monitoring and Reporting Requirements Grease Trap Waste 35. The permittee shall be responsible for a grease-trap waste analysis and reporting program which includes the following: (a) Grease-trap Waste Analysis Annual grab samples of the grease-trap waste from each facility under this permit shall be analyzed for the following parameters. Concentrations must be in mg/kg, except as otherwise specified. %Volatile Solids % Total Solids Total Kjeldahl Nitrogen Nitrate +Nitrite Nitrogen

5 Total Phosphorus Total Potassium Arsenic Cadmium Copper Lead Nickel BODS % Oil & Grease Ammonia Nitrogen Selenium Mercury Chromium Zinc ph (SU) (b) Soils Analysis Each land application site shall be soil tested prior to Spring of each year for the following parameters: Nitrate +Nitrite Nitrogen Phosphorus Magnesium ph (SU) Copper Lead Arsenic Mercury Potassium Salt Content (micro-mhos/em) Cation Exchange Capacity (me/! OOg) Cadmium Zinc Nickel Chromium Selenium (c) Reporting Carwash Solids (i) Annual reports shall be sent to the Department and to the owner of the land receiving grease-trap waste prior to May 1, which must include the following: Waste and soil analyses conducted under Sections (a) and (b) above (including a statement that the analyses were performed in accordance with EPA Document SW-846, "Test Methods for Evaluation of Solid Waste"' or other procedures approved by the Director), sources or generating facilities of waste, application dates and locations, quantities of waste applied (gallons/acre/year and lbs/acre/year), methods of disposal, identity of hauler, and type(s) of crops grown, amounts of nitrogen applied, total elements added that year (lbs/acre), total elements applied to date as per Table 2 (lbs/acre), and copies of soil analyses for each site. (ii)the permittee shall also maintain current copies of the above records for Department personnel review at the facility. 36. The total petroleum hydrocarbons (TPH) analytical determinations must conform to the U.S. Environmental Protection Agency Method No The carwash solids may be land-applied if the TPH is equal or less than 100 mg/kg. Should the TPH concentration in the solids exceeds I 00 mglkg but is less than 2,000 mglkg, the following methods may be used for reducing the TPH concentration of the waste prior to land application. (Formulas and sample calculations for the cases shown below may be found in the Department's "Guidelines for the Land Application of Carwash Solids.")

6 (a) (a) (a) The solids must be thoroughly mixed with the land-application TPH-free soils at a minimum depth of six (6) inches that will result in a TPH concentration of 100 or less in the mixed soils. Import sufficient amounts oftph-free off-site soils to reduce the TPH concentration to 100 mg/kg or less. Annual Reports shall be submitted to the Department no later than May I of each year. The report shall contain the following information. (i) (ii) TPH concentration in mg/kg in the stored solids Location and total area (sq. ft.) utilized in the!and-application operations (iii) For carwash solids with TPH concentrations greater than 100 mg/kg, the permittee must record the size of the tract of land disturbed to accommodate the landapplication operation, or the amount of imported soils utilized to reduce the TPH concentrations (iv) The permittee must maintain complete and current records of the operational activities of the facility. All events must be accurately recorded showing solids removal dates from the carwash, location and amount of solids stockpiled, laboratory analytical results, amounts and location of the land-application efforts, etc.

7 STATEMENT OF BASIS THIS IS A STATE WATER PERMIT FOR A NO-DISCHARGE OPERA TIONUNDERPERMITNUMBER 4602-WR-2 AND AFIN NUMBER WASTE SHALL NOT BE DISCHARGED FROM THIS FACILITY TO THE WATERS OF THE STATE OR ONTO LAND IN ANY MANNER THAT MAY RESULT IN RUNOFF TO THE WATERS OF THE STATE. ISSUING OFFICE AND DATE: Arkansas Department of Environmental Quality Water Division, State Permit Branch 8001 National Drive Post Office Box 8913 Little Rock, Arkansas ADEQ EVALUATING ENGINEER: APPLICANT: A-1 Vacuum Services 4710 Genoa Road Texarkana, Arkansas October I, 2004 Henry C. lnsua CONSULTANT: Oswald Engineering, Inc South Louisiana Street Little Rock, Arkansas FACILITYINFORMATION: Facility Type: Beneficial land-application of grease trap waste and carwash on sixty acres of land. SIC Code: 4953 NAICS Code: Waste Storage/Treatment Component(s): 12,000-gallon tank for the storage of grease-trap waste. Washwater Source: N/A Stream Segment: lb Nearest Stream: McKinney Bayou Nearest Communitv: Texarkana Countv: Miller Section: 13 Township: 15 South Range: 27 West Latitude: 33' 27' 20" Longitude: 93 51' 10" Road Location Description: On Miller County Road No. 21, North of Highway 82 and approximately 0.8 miles from Highway 296 Additional Site Information: The permittee owns approximately 60 acres ofland where the wastes are land-applied at the location shown above.

8 .. 2. GENERAL REQUIREMENTS The storage volume required for the waste generated at the facility is based on the amount grease-trap collections made by the operator. Solid material accumulated in the storage tank shall be removed and disposed according to methods approved by the Director. The storage area shall be maintained perfectly clean at all times. Any discharge from the waste storage system such as an overflow, a broken pipe, etc., immediately corrected and reported to the Department. 3. BASIS FOR PERMIT CONDITIONS The Arkansas Department of Environmental Quality has made a tentative determination to issue a permit for the no-discharge facility as described in the application and waste management plan. Permit requirements and conditions are based on regulations pursuant to the Arkansas Water and Air Pollution Control Act (Act 472 of 1949, as amended, Ark. Code Ann et. seq.). 4. SOURCES FOR DOCUMENT DEVELOPMENT A. Regulation No.2, Water Quality Standards for Surface Waters of the State of Arkansas, as amended. B. Regulation No. 8, Administrative Procedures, as amended. C. Regulation No. 9, Fee System for Environmental Permits, as amended. D. ACT 165 of 1993, Public Notice Requirements E. ACT 472 of 1949, as amended, Arkansas Water and Air Pollution Control Act 5. PUBLIC NOTICE A Draft Permit and draft public notice will be sent to the applicant and District Engineer ofthe Natural Resource Conservation Service or consulting engineer prior to publication of notice. The public notice describes the procedures for the formulation of final determinations and shall provide for a public comment period of 30 days. During this period, any interested persons may submit written comments on the Draft Permit and may request a public hearing to clarify issues involved in the permit decision. A request for a public hearing shall be in writing and shall state the nature of the issue(s) proposed to be raised in the hearing. For additional information, contact: Doug Szenher, Information Officer Arkansas Department of Environmental Quality 8001 National Drive P.O. Box 8913 Little Rock, Arkansas

9 , ARKANSAS Department of Environmental Quality CERTIFIED MAIL: RETURN RECEIPT REQUESTED October 22, 2004 Ricky Ray A-1 Vacuum Services Genoa Road Texarkana, Arkansas RE: AFIN No , Permit No WR-2 Dear Mr. Ray: Enclosed is your permit for the waste disposal system as set forth in your application. After considering the facts and requirements of the Arkansas Water and Air Pollution Control Act (A.C.A. Sec et seq.) and implementing regulations, the Department has determined that your permit renewal for the operation, and maintenance of a water pollution control system be issued and effective on the date specified in the permit, unless a Commission review has been properly requested under the provisions of Regulation No. 8, Administrative Procedures, as amended, within 30 days after service of this decision. All persons who have submitted written comments during the comment period, and all other persons entitled to do so, may request an adjudicative hearing and Commission review on whether the decision of the Director should be reversed or modified. Such a request shall be in the form and manner required by Regulation No. 8, as amended. In addition to the permit conditions contained herein, the permittee must comply with all other applicable State and Federal Regulations, including, but not limited to, Acts 1059, 1060, and 1061 of2003, and the regulations promulgated there-under by the Arkansas Soil & Water Conservation Commission. Please note that no changes may be introduced to the waste management plan without the written authorization from the Department. Should you have any questions please contact the State Permits Branch at ~IJ~e:erg f/1~~~ Martin Maner, P. E. Chief, Water Division Enclosures cc: Fred Oswald, Oswald Engineering, Inc. Ronald "Red" Smith, ADEQ District Field Inspector Henry C. Insua, ADEQ Engineer Permit files WATER DIVISION 8001 NATIONAL DRIVE / POST OFFICE BOX 8913 / LITTLE ROCK, ARKANSAS I TELEPHONE I FAX