2. The facility had fresh asphalt and resin/glue dumped behind some trailers on the back side of the property.

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1 May 17, 2004 Ms. Lisa Owens Tank Trailer of Arkansas 182 Union 293 El Dorado, AR Compliant Investigation Dear Ms. Owens: On May 17, 2004, I performed a complaint investigation of your facility in response to a complaint which alleged that you were dumping waste on the ground behind the facility from a tank wash operation. This investigation was performed under provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated thereunder. This investigation revealed the following: 1. The facility had an area of oil stained soil behind the shop from spilled buckets of oil, from spills from a vat and from spills from a large tank (which had no containment wall.) This soil must be remediated to less than 100 ppm of Total Parts Hydrocarbon (TPH). 2. The facility had fresh asphalt and resin/glue dumped behind some trailers on the back side of the property. The aforementioned items require your immediate attention. Please submit a written response to these findings to the State Permit Branch of this Department when the items have been corrected. 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 is due by June 17, If you have any questions concerning this inspection, please feel free to contact me at (870) Sincerely, John W. Lamb District Field Inspector Water Division cc: State Permits Branch

2 FOR OFFICE USE ONLY: AIR HW RST SW WATER MINING ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY P. O. BOX 8913, LITTLE ROCK, AR COMPLAINT REPORT LOG#: CSN#: PERMIT#: DATE RECEIVED: COMPLAINANT NAME: Robert Benson ADDRESS:P.O. Box 275 El Dorado, AR COUNTY: Union COMPLAINT AGAINST: Tank Trailer of Arkansas ADDRESS:182 Union 293, El Dorado, AR PHONE: FAX: PHONE: FAX: PERSON RECEIVING REPORT: Chris Voss DATE: SUPERVISOR REFERRAL: DATE: INSPECTOR REFERRED: John Lamb DATE: MEDIA SUPERVISOR REFERRAL: DATE: PHONE REFERRAL CONTACT: DATE: RECEIVING INSPECTOR: DATE: DESCRIPTION (IN DETAIL) Tank Trailer of Ark has been cleaning out tankers and dumping the material out behind the building. They have been covering up waste that has been dumped with dirt and buried other waste. Trees have died behind the building. Facility is owned by Lisa Owens LOCATION (IN DETAIL) 182 Union 293 PREVIOUS COMPLAINT? G YES NO DATES: DISCHARGE TO STREAM? G YES NO NAME OF STREAM: HOW COMPLAINT WAS RECEIVED: G PHONE G LETTER VERBAL G FAX G Page 1

3 FOLLOW UP ON COMPLAINT COMPLAINT #: CSN #: INSPECTOR: John Lamb DATE: ACTION TAKEN: PHOTOS TAKEN: yes On 17 May 2004, Chris Voss, Solid Waste Inspector and I visited Tank Trailer of Arkansas located at the above address. According to an employee onsite, there was no one in the office to talk with. We explained the complaint to the shop employee and he told us to look anywhere we wanted to. We walked the entire cleared property of the facility and found much of the facility to be in an old abandoned oil field area. It appeared that the facility had in the past filled much of the low oil field area with fill dirt and debris such as bricks and block. We found several springs leaching out of the ground on the back side of the property. The water had a large amount of iron and associated algae in it. There was nothing in visual appearance of the water to indicate toxic chemicals were present. Several insects were seen in and around the water in the springs. We did see some dead trees, some appeared to have died from being over filled with dirt and others appeared to have died from standing in water from the leaching water. I did observe some oil globs of fresh asphalt along with what appeared to be some resin/glue globs behind some old semi trailers which appeared to have been dumped there to dry. Also, the area directly behind the shop building had numerous fresh oil stains, several five gallons buckets of oily material, a large vat of oil and a reclamation tank with no containment. According to the shop employee that tank is used when they steam out a tanker and the wastewater is placed in the tank and disposed of by some company out of Little Rock. This area was of the biggest concern with the large amount of oil stains present. Also, beside the shop was a large tanker with a hose going inside the building and the hose was coming out of the building again leaking what appeared to be fresh water. According the shop employee that tanker holds fresh water which is pumped into a clean tanker for hyrdostatic testing and then pumped back into the tanker outside to be used again. FURTHER ACTION TAKEN/TO BE TAKEN: Letter to be sent to Ms. Lisa Owens to clean up the oil soaked soil and asphalt spills around site. INSPECTOR SIGNATURE: John W. Lamb DATE: HOURS WORKED: Page 2

4 Arkansas Department of Environmental Quality Solid Waste Management Division Complaint/Illegal Dump Investigation Landowner/ Violator: Location/ Address: GPS Location: Lisa Owens Tank Trailer of Arkansas 182 Union 293 El Dorado, AR County: Page 1 of 2 Union Valid X Confirmed Complaint Violator Type Of Waste: Haz. Waste X Invalid Complaint Unconfirmed Violator Complainant: Robert Benson Date of Complaint: 5/14/04 Address: P. O. Box 275 El Dorado, AR Person Received Report: Chris Voss Phone: (870) Complaint forwarded to: John Lamb Section 1 Size of Waste Mass Pts Points Total Length >640 yd³ 5 0 Width 320 yd³ to 640 yd³ = 16 roll offs 5 0 Height 160 yd³ to 320 yd³ = 8 roll offs yd³ to 160 yd³ = 4 roll offs 3 0 Total 40 yd³ to 80 yd³ = 2 roll offs 2 0 Approx. Cyd 40 yd³ or < = 1 roll off 1 0 Total 0 Comments: No disposal of Solid Waste found. Section 2 Contents of Waste Mass Pts Points Total Household Waste 5 0 Hazardous items {i.e. paint thinner, cleaning chemicals, oil cans, herbicides, medical waste, asbestos} 5 0 White Waste {i.e. Refrigerators and appliances - May Contain Freon} 3 0 Construction/Demolition Waste 3 0 Tires: Approximate Number of Trucks. Passenger:. other:. 3 0 Abandoned Vehicles /Auto Parts. May contain gasoline, oil, antifreeze or other automotive fluids 2 0 Other Bulky Waste {i.e. TV s, Furniture, Mattresses, etc.} 2 0 Yard Waste 1 0 Dead Animals 4 0 Other 0 TOTAL 0 Comments: Illegal Dump Form 1997/ Rev. Jan FOR ADEQ USE ONLY Inspector Signature:

5 Section 3 Site Assessment Pts Points Total Air Pollution Open Burning 5 0 Air Pollution Evidence of Open Burning 4 0 Air Pollution Strong; Foul Order Present 3 0 Water Pollution Waste in or near standing or flowing water 5 0 Water Pollution High probability of leachate (run-off) into ground/surface water 5 0 Public Health Risk Assessment Vectors sighted 5 0 Public Health Risk Assessment Evidence of Vectors {i.e. rats, flies, mosquitoes, snakes, scavengers} 4 0 Public Health Risk Assessment Public Nuisance {i.e. feces and/or eggs and/or tunnels} 3 0 Site Usage Assessment Site attended or maintained for a fee 5 0 Site Usage Assessment History of previous complaints 5 0 Site Usage Assessment Active, attractive nuisance; evidence of recent dumping 5 0 Site Usage Assessment Dumping resumed at cleaned up or closed site 4 0 Site Usage Assessment Old Site; no evidence of recent dumping; overgrown 2 0 TOTAL for Section 3 0 TOTAL for Section 1 & 2 0 Entry Time: Comments: Exit Time: Total Hours: Date: (F9) TOTAL POINTS 0 Section 4 Violations Solid Waste Management Act (a)(2) To construct, install, alter, modify, use or operate any solid waste processing or disposal facility or disposal site without a permit from the department (a)(3) To dispose of solid wastes at any disposal site or facility other than a disposal site or for which a permit has been issued by the department (a)(3) Individual s household disposal that creates a public or private nuisance or a hazard to health and/or violates a city ordinance or other law and/or involves the open dumping of garbage (a)(4) To dump, deposit, throw, or in any manner leave or abandon any solid wastes upon property owned by another person without the written permission of the owner or upon public property (a)(5) To sort, collect, transport, process, or dispose of solid waste contrary to the rules, regulations or orders of the department, or create or likely to create a public nuisance or public health hazard or to cause or likely to cause water or air pollution (Ark. Water and Air Pollution Control Act et seq) (a)(5)(b) A rebuttal presumption when one (1) or more items of solid waste bear the name to indicate that the person committed the unlawful act of disposal Waste Tire Regulations #14 9, Prohibitions: Tires disposed unless part of a permitted processing/collection facility Caused or permitted the open burning of tires Air Pollution Control Code (a)(1)(2)(3) 5)(a) No person shall cause or permit the open burning of refuse, garbage, trade wastes or other waste material, or shall conduct a salvage operation by open burning Litter Act Comments: Dispose of litter upon any public or private property or into any body of water Vehicle is not covered to prevent the contents from departing from vehicle Illegal Dump Form 1997/ Rev. Jan FOR ADEQ USE ONLY Inspector Signature:

6 Complaint Investigation and Illegal Dump Form Attachment Location: 182 Union 293, El Dorado, AR County: Union Inspector: Chris Voss Date: 5/27/04 COMMENTS: On May 14, 2004, I was asked by K. O. Mogensen to sit in with a Robert Benson who wanted to make a complaint on Lee Trucking of El Dorado. He seemed very concerned about some tank cleaning practices used by Mr. Lee and stated that he would go to court or to the media to get them stopped. Mr. Benson was very specific about locations that hazardous waste had been dumped on both Lee Trucking and at Tank Trailer of Arkansas properties, owned by Lisa Owens. On May 17, 2004, Water Inspector John Lamb and I visited both sites. Mr. Benson had informed me that the area used for dumping at the trucking yard had been covered. John and I looked at the site and then went over to Tank Trailer of Arkansas, after observing no visual violations on Lee Trucking's Yard. No Solid Waste violations were observed and the rest of this complaint was turned over to Inspector Lamb. FURTHER ACTION TAKEN/TO BE TAKEN: Inspector Signature Date 5/27/04 Hours 3 ADEQ dump form att. 9/99

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