April 2, Jay Bartley JT s Washout Facility, LLC PO Box 1308, Greenbrier, AR 72058

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1 April 2, 2013 Jay Bartley JT s Washout Facility, LLC tj.bartley@yahoo.com PO Box 1308, Greenbrier, AR RE: FACILITY: JT s Washout Facility, LLC PERMIT: 4982-WR-3 AFIN: COUNTY: Faulkner Mr. Bartley: On March 22, 2013, District 5 Inspector Amy Beck and I performed an inspection of the No Discharge permit for the above washout and waste storage facility in accordance with the provisions of the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. The following violations were observed: 1) There was a crack in Pit #1, multiple holes in the liner of the secondary containment surrounding the washout pits, and a visible sheen/oily film on the north side of the washout (See Photos 1 through 5). These are violations of Part I, Special Condition 3 of the permit. 2) The three (3) feet lined emergency containment berm specified in the Waste Management Plan (WMP) revised May 15, 2012 has been removed from around the 7 onsite storage tanks (10 permitted). Open barrels were stored without caps and the site generally had poor housekeeping (See Photos 6 through 9). These are violations of Part I, Special Condition 2 and Part II, Standard Condition 10.a of the permit. 3) Modifications have not been submitted to ADEQ for review and approval, including: a. A new solidification process, consisting of 9 large storage containers filled with E&P solids and fluids and a chemical additive, referred to as concrete water by the owner, was recently added to the site. The containers were installed on an incline without containment and several containers had water levels that were less than 24 inches from the top (See Photos 10 & 11). b. A chemical tote identified as slurry by the owner, which when added to the washout water produces a type of static charge that separates out the solids, was installed outside of containment on the north side of the washout pit (See Photo 12). These are violations of Part II, Standard Condition 18 of the permit. The above items require your immediate attention. Please submit a written response to these findings to Water Division Inspection Branch. The response should be mailed to the address below, or ed 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 documentations (including photos) is due by April 16, 2013.

2 JT s Washout Facility, LLC April 2, 2013 Page 2 Please find additional information pertaining to the above violations in the Comments section of this report. If I can be of any further assistance, please contact me at x17 or via at digiacomo@adeq.state.ar.us Sincerely, Stephen DiGiacomo Oil & Gas Field Inspector Water Division (479) x17 digiacomo@adeq.state.ar.us cc: Water Division Permits Branch Dale Guyse, Regulatory Compliance Manager ESCI, dale@escied.net

3 ADEQ Water Industrial No Discharge AFIN: Permit #: 4984-WR-2 ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY NO DISCHARGE INDUSTRIAL PERMIT INSPECTION FORM AFIN: Log No.: Permit No.: 4982-WR-3 Inspection Date: 3/22/2013 Media: WATER Inspector: Stephen DiGiacomo Compliance Status: IN / OUT 1A. Name of Facility: JT s Washout Facility, LLC Address: 7195 Heber Springs Rd., Quitman, AR ( ) County: Faulkner 2A. Name of On-Site Representative: Jay Bartley & Dale Guyse 3A. Name of Responsible Official: Jay Bartley Address: 367 Adkisson Rd., Mt. Vernon, AR Telephone: (501) A. Parent Company: JT s Washout Facility, LLC Address: PO Box 1308, Greenbrier, AR Telephone: (501) A. Description of Process (including type of industry, materials produced, and major by-products): The washout facility receives trucks hauling Exploration and Production waste from operations in the Fayetteville Shale Play into a cascading system of settling pits, separates and mixes the solids with lime for transport to a landfill, and has begun a new solidification process using multiple open topped containers and a chemical additive that the owner called concrete water. The facility is also used as a staging area for Jay Bartley Oil Field Services LLC. 6A. Any complaints registered against this permitted facility? Yes No If yes, give date and description of complaint: 2/2/2012 concern about O&G waste contaminating stormwater runoff, addressed by Kerri McCabe on February 9, A. Are there any additions, modifications, or corrections to the facility since the last inspection? Yes No If yes, explain: A new solidification process using open containers and a chemical additive, which the owner called concrete water. The containers are filled with water and solids from the washout and allowed to sit until the remainder of the water hardens into a solid that can be disposed of at a landfill. A shop has been constructed to service trucks. Staging areas have expanded into the field for storage of open bins used at Oil & Gas facilities WR-3 No Discharge Industrial Report Page 3

4 1B. Furnish a simplified flow diagram of the treatment system and include main components, flow sequence through plant, and calculated or estimated flows. Offices Parking and Staging Washout Staging 2B. Nearest Stream: ~1100 from intermittent tributary of Mortar Creek 3B. Does wastewater from this facility cause adverse effect on the waters of the State? Yes No If yes, describe: 4B. Are operating records kept as required by permit? Yes No N/A 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/A 7B. Does the sampling program meet the requirements of the permit? Yes No N/A If no, explain: Not required by the permit 8B. What laboratory does the facility use? N/A Address: Telephone: 1C. Do laboratory procedures and records meet the requirements of the permit? Yes No N/A If no, explain: N/A 2C. Is contaminated runoff a problem? Yes No N/A

5 ADEQ Water Industrial No Discharge AFIN: Permit #: 4984-WR-2 If yes, explain: Evidence of overflow from the washout pits into the lined secondary containment berm; large holes in the lined secondary containment berm; solids from the washout built up on the ground around the mud bulking bins; E&P wastewater in the concrete water solidification process was 24 from the top of several bins. 3C. Is sludge disposal required? Yes No N/A If yes, describe (including final destination): County landfill 4C. Is the treatment system being properly operated and maintained as required by permit? Yes No N/A If no, explain The pit is overflowing into the lined secondary containment berm, which has large holes in it; solids from the washout are built up on the ground around the mud bulking bins; the concrete water solidification process has not been submitted to ADEQ for review and approval SUMMARY OF FINDINGS/COMMENTS Onsite personnel were courteous and provided a tour of the facility. The permit was onsite as was the Waste Management Plan. PDS # Inspector Signature: Stephen DiGiacomo Date of Report: April 1, 2013 Signature of Reviewer: Kerri McCabe Date of Report: April 1, WR-3 No Discharge Industrial Report Page 5

6 Water Division Photographic Evidence Sheet Location: JT s Washout Facility, LLC ( ) Photographer: Stephen DiGiacomo Witness: Photo # 1 Of 12 Date: Time: Description: Site Identification (2009 State of Arkansas Imagery 1 Resolution). Refer to 1B for detailed flow chart for updated facility layout. Photo # 2 Of 12 Date: Time: 1330 Description: Washout pit

7 ADEQ Water Industrial No Discharge AFIN: Permit #: 4984-WR-2 Location: JT s Washout Facility, LLC (south side of washout pit) Photo # 3 Of 12 Date: Time: 1349 Description: Crack in Pit #1; evidence of overflow and solids accumulation on exterior pit walls; liner tacked with wood strips coming away from pit wall Photo # 4 Of 12 Date: Time: 1349 Description: Multiple holes in the liner around the washout; soil visible underneath 4982-WR-3 No Discharge Industrial Report Page 7

8 Location: JT s Washout Facility, LLC (south lot) Photo # 5 Of 12 Date: Time: 1357 Description: Visible sheen and oily film in stormwater flow on the north side of the washout pit. Photo # 6 Of 12 Date: Time: 1402 Description: The 3 lined emergency containment berm has been removed from around storage tanks

9 ADEQ Water Industrial No Discharge AFIN: Permit #: 4984-WR-2 Location: JT s Washout Facility, LLC (south lot) Photo # 7 Of 12 Date: Time: 1418 Description: Full barrels without caps Photo # 8 Of 12 Date: Time: 1419 Description: Chemical Identification; some barrels were empty 4982-WR-3 No Discharge Industrial Report Page 9

10 Location: JT s Washout Facility, LLC (south lot) Photo # 9 Of 12 Date: Time: 1414 Description: E&P residue inside storage containers in the staging area Photo # 10 Of 12 Date: Time: 1357 Description: concrete water solidification process 1 of 9 containers of E&P wastewater and solids

11 ADEQ Water Industrial No Discharge AFIN: Permit #: 4984-WR-2 Location: JT s Washout Facility, LLC (south lot) Photo # 11 Of 12 Date: Time: 1358 Description: concrete water solidification containers were stored on an incline without secondary containment; water level was approximately24 from the top of this bin and several others. Photo # 12 Of 12 Date: Time: 1331 Description: Slurry used in the washout pits to statically separate solids from wastewater 4982-WR-3 No Discharge Industrial Report Page 11

12 Oil & Gas Violation Summary Sheet No Violations Noted Placing Waste Permitting Issues Spills & Leaks Turbidity, etc. (Regulation #2 Violations) Stormwater &/or Erosion Issues Notification/Reporting Violations Unpermitted Discharges Record Keeping/Paperwork Violations Trash/Unauthorized Fluids in Pits Improper Closure of Pit Insufficient Freeboard Poor Pit Construction Other (Describe): Multiple violations (spills/leaks, permitting issues, and proper operation & maintenance)

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14 May 29, 2013 Jay Bartley JT s Washout Facility, LLC PO Box 1308, Greenbrier, AR RE: FACILITY: JT s Washout Facility, LLC PERMIT: 4982-WR-3 AFIN: COUNTY: Faulkner Mr. Bartley: I have reviewed the response pertaining to my March 22, 2013 inspection of the above facility. The information provided sufficiently addresses the violation 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 I can be of any further assistance, please feel free to contact me at or via at digiacomo@adeq.state.ar.us. Thank you for your time, Stephen DiGiacomo Oil & Gas Field Inspector Water Division digiacomo@adeq.state.ar.us