April 30, Dear Mr. Ungerank:

Transcription

1 219 Brown Lane Bryant, AR (501) (501) fax April 30, 2013 Mr. Colby Ungerank Engineer No Discharge Permits, Water Division Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR RE: Southland Septic Service (Southland), Inc. May 1, 2013 Land Application Bi-Annual Report Reporting Period July 2012 through December 2012 Permit No WR-2, CAO LIS GBMc No Dear Mr. Ungerank: This letter is being submitted by GBM c & Associates on behalf of Southland in compliance with Condition 26. (4.) of Arkansas Department of Environmental Quality s (ADEQ) State Permit 4471-WR-2, and CAO LIS Condition 26. (4.) of State Permit 4471-WR-2 and CAO LIS requires the submittal of bi-annual reports concerning the land application of grease trap waste. This report covers July 2012 through December Background Permit No WR-2 authorizes Southland to land apply grease trap waste that is generated by food preparation establishments, primarily fast food restaurants on their land application site (150 acre site located in Glen Rose, Hot Spring County, Section 30, Township 3 South, Range 16 West). This report covers Southland s only active site (Glen Rose Site). Land application activities occurred on the Glen Rose Site during the months of July through December 2012.

2 Mr. Colby Ungerank April 30, 2013 Page 2 Grease Trap Waste and Soil Analyses Copies of all grease trap waste and soil analyses performed during December 2012 are included in Appendices A and B in this report. The test methods are identified in these data sheets. Table 1 presents data from soil samples collected from the Glen Rose Site on December 4, The concentrations reported in Table 1 are analytical results from composite samples as recommended by the Cooperative Extension Service (FSA M). Appendix C provides an excerpt for this document. Results that were reported less than the detection limit, a value of ½ the detection limit was used in calculations when necessary. Table 1. Glen Rose Land Application Site Soil Analysis, December 4, Glen Rose Site Parameter (Dry Weight) Arsenic, mg/kg <5.0 Cadmium, mg/kg <0.4 Chromium mg/kg 8.4 Copper, mg/kg 3.0 Lead, mg/kg 4.6 Mercury, mg/kg <0.1 Magnesium, mg/kg 300 Molybdenum, mg/kg <0.8 Nickel, mg/kg 2.7 NO2 + NO3 as N, mg/kg <0.6 Phosphorus, mg/kg 44 Potassium, mg/kg 330 Selenium, mg/kg <7.0 Zinc, mg/kg 7.2 CEC, meq/100g 3.2 Conductivity (µmho/cm) 30 ph (su) 4.4 Total Solids (%) 6.8

3 Mr. Colby Ungerank April 30, 2013 Page 3 Table 2 presents representative grease trap waste data analysis collected on December 4, Results that were reported less than the detection limit, a value of ½ the detection limit was used in calculations when necessary. Table 2. Grease Trap Waste Analyses, December 4, Parameter Grease Trap Waste (Dry Weight) Arsenic, mg/kg <5.0 Cadmium, mg/kg <0.4 Chromium mg/kg 13.0 Copper, mg/kg 93 Lead, mg/kg <4.0 Mercury, mg/kg <0.1 Molybdenum, mg/kg 2.4 Nickel, mg/kg 5.8 Zinc, mg/kg 110 Selenium, mg/kg <7.0 TKN, mg/kg Phosphorus, mg/kg 2100 Potassium, mg/kg 880 NO2 + NO3 - N, mg/kg <8 Ammonia-N, mg/kg 3300 % Oil & Grease 61 % Total Solids 6.8 % Volatile Solids 98.0 ph (su) 4.3 BOD5, mg/kg 12000

4 Mr. Colby Ungerank April 30, 2013 Page 4 Application Dates and Locations During the 2 nd half of 2012, Southland applied grease trap waste to the Glen Rose Site from July 25 through December 21, The land application of grease trap waste was carried out in accordance with the Site Management Plan updated December, Table 3 provides specific application dates and volumes. A detailed application log is provided in Appendix D. Table 3. Application Months and Volumes, July 2012 through December Application Month Monthly Volume (Gallons) July 8,500 August 4,500 September 11,250 October 2,250 November 6,750 December 4,500 Generating Facilities Grease trap waste is generated from kitchens of food preparation establishments. Southland collected grease trap waste during the 2 nd half of 2012 from restaurants, schools, gas-stations, churches, resorts, and child-care facilities. Volume of Grease Trap Waste Applied The total volume of grease trap waste applied to the Glen Rose Site was 37,750 gallons. This total applied over 12 acres equals 3,146 gallons per acre. Based on the total number of gallons of grease trap waste applied (37,750) and using 7.0 lbs per gallon, calculations rendered approximately 132 wet tons of grease trap waste was land applied to the Glen Rose Site. Based on a consistency of 6.8% dry solids content, a total 8.98 dry tons of grease trap waste was land applied during the months of June through December. Using the total land area used for land application (12 acres), it was calculated that 0.75 dry tons/acre or 1,497 lbs/acre of grease trap waste was land applied during the 2 nd half of 2012.

5 Mr. Colby Ungerank April 30, 2013 Page 5 Method of Disposal/Identity of Hauler Southland collected and hauled all grease trap waste during this period using 3,000 and 4,000 gallon vacuum trucks. The grease trap waste was collected directly from the generating facility and hauled to the Glen Rose Site for land application activities or temporarily stored (as needed) in a 4,400 gallon portable storage tank. The method of land application was sub-surface injection using a Terragator type injection machine. Detailed pictures of this machine can be found in the Site Management Plan updated December, Type of Crop Grown Approximately 60% Biologic (Clover), 20% natural vegetation, 10% Bermuda grass, & 10% fescue was grown on the land application site. PAN Application Rates Analyses of grease trap waste applied during the 2 nd half of 2012 indicate the level of Plant Available Nitrogen (PAN) to be lbs per dry ton of grease trap waste applied. Based on this number and the total quantities of grease trap waste applied, the total nitrogen loading to the site was lbs PAN, total, or lbs PAN per acre. This rate value (18.07 lbs PAN/acre) for the site is well below the expected uptake for clover, natural vegetation, Bermuda, and fescue, which averages approximately 200 lbs PAN/acre, based on Table 4-11 of the Process Design Manual for Land Treatment of Municipal Wastewater, USEPA, October 1981 and previous correspondence with Mr. Keith Brown at ADEQ. Total Metals Applied to Date Table 4 provides a calculated estimate of cumulative loading for heavy metals at the Glen Rose Site at the beginning of the reporting period, for the second half of 2012, and the total cumulative loading through December Also shown is the cumulative metal loading allowed by Permit No WR-2.

6 Mr. Colby Ungerank April 30, 2013 Page 6 Table 4. Glen Rose Site Loading of Heavy Metals through December 2012 Metal Cumulative Loading Through June 2012 (lbs/acre) Applied 2nd half 2012 (lbs/acre) Cumulative Loading Through December 2012 (lbs/acre) Cumulative Loading Allowed (lbs/acre) Arsenic Cadmium Chromium Copper Lead Mercury Molybdenum Nickel Selenium Zinc Note: where values were less than detection, ½ the detection limit was used for calculations If you have any additional questions or comments, please contact Justin Haynes (Southland) at (501) or Kyle Hathcote (GBM c & Associates) at (501) Sincerely, GBM c & Associates Kyle Hathcote Senior Scientist cc: Justin Haynes, Southland

7 Appendix A Soils Data

8 December 12, 2012 Control No Page 1 of 6 Southland Septic Service, Inc. ATTN: Mr. Justin Haynes HWY 67 Malvern, AR This report contains the analytical results and supporting information for the sample submitted on December 4, Attached please find a copy of the Chain of Custody and/or other documents received. Note that any remaining sample will be discarded two weeks from the original report date unless other arrangements are made. This report is intended for the sole use of the client listed above. Assessment of the data requires access to the entire document. This report has been reviewed by the Laboratory Director or a qualified designee. Steve Bradford Deputy Laboratory Director This document has been distributed to the following: PDF cc: Southland Septic Service, Inc. ATTN: Mr. Justin Haynes sludgemuncher@gmail.com GBMc & Associates, Inc. ATTN: Mr. Kyle Hathcote khathcote@gbmcassoc.com 8600 Kanis Road Little Rock, AR Phone FAX

9 December 12, 2012 Control No Page 2 of 6 Southland Septic Service, Inc HWY 67 Malvern, AR SAMPLE INFORMATION Project Description: One (1) soil sample(s) received on December 4, 2012 Receipt Details: A Chain of Custody was provided. The samples were delivered in one (1) ice chest. Each sample container was checked for proper labeling, including date and time sampled. Sample containers were reviewed for proper type, adequate volume, integrity, temperature, preservation, and holding times. Any exceptions are noted below: Sample Identification: Laboratory ID Client Sample ID Sampled Date/Time Notes Soil 12/4/12 10:00am 04-Dec Case Narrative: Analysis of soils/sludges are reported on a dry-weight basis unless otherwise specified. References: "Methods for Chemical Analysis of Water and Wastes", EPA/600/ (Mar 1983) with updates and supplements EPA/600/ (Jun 1991), EPA/600/R (Aug 1992) and EPA/600/R (Aug 1993). "Test Methods for Evaluating Solid Waste Physical/Chemical Methods (SW846)", Third Edition. "Standard Methods for the Examination of Water and Wastewaters", 21st edition. "American Society for Testing and Materials" (ASTM). "Association of Analytical Chemists" (AOAC) Kanis Road Little Rock, AR Phone FAX

10 December 12, 2012 Control No Page 3 of 6 Southland Septic Service, Inc HWY 67 Malvern, AR ANALYTICAL RESULTS AIC No Sample Identification: Soil 12/4/12 10:00am Analyte Result RL Units Qualifier ph 4.4 Units EPA 9045C Prep: 04-Dec by 93 Analyzed: 04-Dec by 93 Batch: W41865 Electrical Conductivity Mod. EPA 9050A Cation-Exchange Capacity Mod. EPA 9080 Total Solids SM 2540 G Arsenic Cadmium Chromium Copper Lead Magnesium Molybdenum Nickel Phosphorus Potassium Selenium Zinc Mercury EPA 7471B Nitrate + Nitrite as N EPA 9056A Prep: 04-Dec by 93 Prep: 04-Dec by 285 Prep: 05-Dec by 271 Prep: 05-Dec by umho/cm Analyzed: 04-Dec by 93 Batch: W meq/100g Analyzed: 10-Dec by 306 Batch: W % Analyzed: 06-Dec by 285 Batch: W41866 < 5 5 Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: < Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: < 7 7 Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: < Analyzed: 07-Dec by 271 Batch: S33597 < Analyzed: 05-Dec by 07 Batch: S Kanis Road Little Rock, AR Phone FAX

11 December 12, 2012 Control No Page 4 of 6 Southland Septic Service, Inc HWY 67 Malvern, AR DUPLICATE RESULTS Analyte AIC No. Result RPD RPD Limit Preparation Date Analysis Date Dil Qual Electrical Conductivity umho/cm 04Dec by 93 04Dec by 93 Batch: W41864 Duplicate 27 umho/cm Dec by 93 04Dec by 93 ph Units 04Dec by 93 04Dec by 93 Batch: W41865 Duplicate 4.4 Units Dec by 93 04Dec by 93 Total Solids % 04Dec by Dec by 285 Batch: W41866 Duplicate 6.9 % Dec by Dec by 285 Cation-Exchange Capacity meq/100g 10Dec by 306 Batch: W41929 Duplicate 3.2 meq/100g Dec by 306 LABORATORY CONTROL SAMPLE RESULTS Spike Analyte Amount % Limits RPD Limit Batch Preparation Date Analysis Date ph W Dec by 93 04Dec by 93 Electrical Conductivity 0.00 umho/cm W Dec by 93 04Dec by 93 Arsenic Dec by 270 Cadmium Dec by 270 Chromium Dec by 270 Copper Dec by 270 Lead Dec by 270 Magnesium Dec by 270 Molybdenum Dec by 270 Nickel Dec by 270 Phosphorus Dec by 270 Potassium Dec by 270 Selenium Dec by 270 Zinc Dec by 270 Mercury S Dec by Dec by 271 Nitrate + Nitrite as N S Dec by 07 05Dec by 07 Dil Qual 8600 Kanis Road Little Rock, AR Phone FAX

12 December 12, 2012 Control No Page 5 of 6 Southland Septic Service, Inc HWY 67 Malvern, AR MATRIX SPIKE SAMPLE RESULTS Analyte Sample Spike Amount % Limits Batch Preparation Date Arsenic Relative Percent Difference: Cadmium Relative Percent Difference: Chromium Relative Percent Difference: Copper Relative Percent Difference: Lead Relative Percent Difference: Magnesium Relative Percent Difference: Molybdenum Relative Percent Difference: Nickel Relative Percent Difference: Phosphorus Relative Percent Difference: Potassium Relative Percent Difference: Selenium Relative Percent Difference: Zinc Relative Percent Difference: Mercury S Dec by S Dec by 271 Relative Percent Difference: S33597 Nitrate + Nitrite as N S33604 S Dec by 07 05Dec by 07 Relative Percent Difference: S33604 Analysis Date Dil 07Dec by Dec by Dec by 07 05Dec by 07 Qual 8600 Kanis Road Little Rock, AR Phone FAX

13 December 12, 2012 Control No Page 6 of 6 Southland Septic Service, Inc HWY 67 Malvern, AR LABORATORY BLANK RESULTS Analyte Result RL PQL QC Sample Preparation Date Analysis Date Qual Electrical Conductivity < 2 umho/cm 2 2 W Dec by 93 04Dec by 93 Cation-Exchange Capacity < 0.1 meq/100g W Dec by 306 Total Solids < 0.01 % W Dec by Dec by 285 Arsenic < Dec by 270 Cadmium < Dec by 270 Chromium < Dec by 270 Copper < Dec by 270 Lead < Dec by 270 Magnesium < Dec by 270 Molybdenum < Dec by 270 Nickel < Dec by 270 Phosphorus < Dec by 270 Potassium < Dec by 270 Selenium < Dec by 270 Zinc < Dec by 270 Mercury < S Dec by Dec by 271 Nitrate + Nitrite as N < S Dec by 07 05Dec by Kanis Road Little Rock, AR Phone FAX

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15 Appendix B Grease Trap Waste Data

16 December 12, 2012 Control No Page 1 of 6 Southland Septic Service, Inc. ATTN: Mr. Justin Haynes HWY 67 Malvern, AR This report contains the analytical results and supporting information for the sample submitted on December 4, Attached please find a copy of the Chain of Custody and/or other documents received. Note that any remaining sample will be discarded two weeks from the original report date unless other arrangements are made. This report is intended for the sole use of the client listed above. Assessment of the data requires access to the entire document. This report has been reviewed by the Laboratory Director or a qualified designee. Steve Bradford Deputy Laboratory Director This document has been distributed to the following: PDF cc: Southland Septic Service, Inc. ATTN: Mr. Justin Haynes sludgemuncher@gmail.com GBMc & Associates, Inc. ATTN: Mr. Kyle Hathcote khathcote@gbmcassoc.com 8600 Kanis Road Little Rock, AR Phone FAX

17 December 12, 2012 Control No Page 2 of 6 Southland Septic Service, Inc HWY 67 Malvern, AR SAMPLE INFORMATION Project Description: One (1) sludge sample(s) received on December 4, 2012 Receipt Details: A Chain of Custody was provided. The samples were delivered in one (1) ice chest. Each sample container was checked for proper labeling, including date and time sampled. Sample containers were reviewed for proper type, adequate volume, integrity, temperature, preservation, and holding times. Any exceptions are noted below: Sample Identification: Laboratory ID Client Sample ID Sampled Date/Time Notes GT Waste 2 12/4/12 10:06am 04-Dec Qualifiers: W Result is presented on a Wet Weight Basis X Spiking level is invalid due to the high concentration of analyte in the spiked sample Case Narrative: Analysis of soils/sludges are reported on a dry-weight basis unless otherwise specified. References: "Methods for Chemical Analysis of Water and Wastes", EPA/600/ (Mar 1983) with updates and supplements EPA/600/ (Jun 1991), EPA/600/R (Aug 1992) and EPA/600/R (Aug 1993). "Test Methods for Evaluating Solid Waste Physical/Chemical Methods (SW846)", Third Edition. "Standard Methods for the Examination of Water and Wastewaters", 21st edition. "American Society for Testing and Materials" (ASTM). "Association of Analytical Chemists" (AOAC) Kanis Road Little Rock, AR Phone FAX

18 December 12, 2012 Control No Page 3 of 6 Southland Septic Service, Inc HWY 67 Malvern, AR ANALYTICAL RESULTS AIC No Sample Identification: GT Waste 2 12/4/12 10:06am Analyte Result RL Units Qualifier ph 4.3 Units EPA 9045C Prep: 04-Dec by 306 Analyzed: 04-Dec by 306 Batch: W41860 Total Solids SM 2540 G Volatile Solids SM 2540 G Ammonia as N SM 4500-NH3 B,G Total Kjeldahl Nitrogen SM 4500-Norg D BOD 5-day SM 5210 B Arsenic Cadmium Chromium Copper Lead Molybdenum Nickel Phosphorus Potassium Selenium Zinc Mercury EPA 7471B Nitrate + Nitrite as N EPA 9056A Oil and Grease AR OG Prep: 04-Dec by 285 Prep: 04-Dec by 285 Prep: 06-Dec by 93 Prep: 06-Dec by 93 Prep: 06-Dec by 285 Prep: 05-Dec by 271 Prep: 05-Dec by % Analyzed: 06-Dec by 285 Batch: W % Analyzed: 06-Dec by 285 Batch: W Analyzed: 07-Dec by 93 Batch: W Analyzed: 11-Dec by 93 Batch: W Analyzed: 11-Dec by 285 Batch: W41888 < 5 5 Analyzed: 06-Dec by 270 Batch: < Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: < 4 4 Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: < 7 7 Analyzed: 06-Dec by 270 Batch: Analyzed: 06-Dec by 270 Batch: < Analyzed: 07-Dec by 271 Batch: S33597 < 8 8 Analyzed: 05-Dec by 07 Batch: S % Analyzed: 04-Dec by 295 Batch: B Kanis Road Little Rock, AR Phone FAX

19 December 12, 2012 Control No Page 4 of 6 Southland Septic Service, Inc HWY 67 Malvern, AR DUPLICATE RESULTS Analyte AIC No. Result RPD RPD Limit Preparation Date Analysis Date Dil Qual Oil and Grease % 04Dec by 295 W Batch: B8014 Duplicate 4.3 % Dec by 295 W ph Units 04Dec by Dec by 306 Batch: W41860 Duplicate 4.3 Units Dec by Dec by 306 Total Solids % 04Dec by Dec by 285 Batch: W41866 Duplicate 6.9 % Dec by Dec by 285 Volatile Solids % 04Dec by Dec by 285 Batch: W41866 Duplicate 94 % Dec by Dec by 285 BOD 5-day Dec by Dec by 285 Batch: W41888 Duplicate Dec by Dec by 285 LABORATORY CONTROL SAMPLE RESULTS Spike Analyte Amount % Limits RPD Limit Batch Preparation Date Analysis Date Dil ph W Dec by Dec by 306 Ammonia as N W Dec by 93 07Dec by 93 Total Kjeldahl Nitrogen W Dec by 93 11Dec by 93 BOD 5-day 200 mg/l W Dec by Dec by 285 Arsenic Dec by 270 Cadmium Dec by 270 Chromium Dec by 270 Copper Dec by 270 Lead Dec by 270 Molybdenum Dec by 270 Nickel Dec by 270 Phosphorus Dec by 270 Potassium Dec by 270 Selenium Dec by 270 Zinc Dec by 270 Mercury S Dec by Dec by 271 Nitrate + Nitrite as N S Dec by 07 05Dec by 07 Oil and Grease B8014 B Dec by Dec by 295 Qual 8600 Kanis Road Little Rock, AR Phone FAX

20 December 12, 2012 Control No Page 5 of 6 Southland Septic Service, Inc HWY 67 Malvern, AR MATRIX SPIKE SAMPLE RESULTS Analyte Sample Spike Amount % Limits Batch Preparation Date Ammonia as N W Dec by W Dec by 93 Relative Percent Difference: W41893 Total Kjeldahl Nitrogen W Dec by W Dec by 93 Relative Percent Difference: W41895 Arsenic Relative Percent Difference: Cadmium Relative Percent Difference: Chromium Relative Percent Difference: Copper Relative Percent Difference: Lead Relative Percent Difference: Molybdenum Relative Percent Difference: Nickel Relative Percent Difference: Phosphorus Relative Percent Difference: Potassium Relative Percent Difference: Selenium Relative Percent Difference: Zinc Relative Percent Difference: Mercury S33597 S Dec by Dec by 271 Relative Percent Difference: S33597 Nitrate + Nitrite as N S Dec by S Dec by 07 Relative Percent Difference: S33604 Analysis Date 07Dec by 93 07Dec by 93 11Dec by 93 11Dec by 93 07Dec by Dec by Dec by 07 05Dec by 07 Dil Qual X X 8600 Kanis Road Little Rock, AR Phone FAX

21 December 12, 2012 Control No Page 6 of 6 Southland Septic Service, Inc HWY 67 Malvern, AR LABORATORY BLANK RESULTS Analyte Result RL PQL QC Sample Preparation Date Analysis Date Qual Total Solids < 0.01 % W Dec by Dec by 285 Volatile Solids < 0.01 % W Dec by Dec by 285 Ammonia as N < W Dec by 93 07Dec by 93 Total Kjeldahl Nitrogen < W Dec by 93 11Dec by 93 BOD 5-day < W Dec by Dec by 285 Arsenic < Dec by 270 Cadmium < Dec by 270 Chromium < Dec by 270 Copper < Dec by 270 Lead < Dec by 270 Molybdenum < Dec by 270 Nickel < Dec by 270 Phosphorus < Dec by 270 Potassium < Dec by 270 Selenium < Dec by 270 Zinc < Dec by 270 Mercury < S Dec by Dec by 271 Nitrate + Nitrite as N < S Dec by 07 05Dec by 07 Oil and Grease < % B Dec by Kanis Road Little Rock, AR Phone FAX

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23 Appendix C ACES Soil Sampling Method

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26 Appendix D Application Log

27 Land Application Log July-December 2012 Date Material gallons ~lbs Use July Jul Grease trap waste 4,000 28,000 Land Applied 27-Jul Grease trap waste 2,250 15,750 Land Applied 30-Jul Grease trap waste 2,250 15,750 Land Applied August Aug Grease trap waste 2,250 15,750 Land Applied 24-Aug Grease trap waste 2,250 15,750 Land Applied September Sep Grease trap waste 4,500 31,500 Land Applied 11-Sep Grease trap waste 2,250 15,750 Land Applied 27-Sep Grease trap waste 4,500 31,500 Land Applied October Oct Grease trap waste 2,250 15,750 Land Applied November Nov Grease trap waste 4,500 31,500 Land Applied 17-Nov Grease trap waste 2,250 15,750 Land Applied December Dec Grease trap waste 2,250 15,750 Land Applied 21-Dec Grease trap waste 2,250 15,750 Land Applied Totals 37, ,250

28 From: To: Subject: Date: Attachments: Ungerank, Colby Deardoff, Amy FW: Southland Septic Service, Inc. Land Application Bi-Annual Report Tuesday, April 30, :00:07 PM 2nd half 2012 Biannual Report.pdf 2nd half 2012 Biannual Repot - Attachments.pdf Colby From: Kyle Hathcote [mailto:khathcote@gbmcassoc.com] Sent: Tuesday, April 30, :54 PM To: Ungerank, Colby Cc: Justin Haynes; Rachel Mechling Subject: Southland Septic Service, Inc. Land Application Bi-Annual Report Colby, Please find attached Southland Septic Service, Inc. s (Southland) Bi-annual report for the land application of grease trap waste. This report covers the reporting period July, 2012 December, 2012 as required by ADEQ Permit No WR-2, and CAO LIS Additionally, a hard copy will be hand delivered to ADEQ by the end of the day tomorrow. If you have any questions or need additional information, please let me know. Thank You, Kyle Kyle Hathcote Senior Scientist GBMc & Associates 219 Brown Lane Bryant, AR Office: Cell: