JUN June 28, 2016

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1 June 28, 2016 JUN Arkansas Department of Environmental Quality Office of Land Resources Attn: Ms. Lynda Perry 5301 Northshore Drive North Little Rock, AR SUBJECT: Proposed Consent Administrative Order Upper Southwest Arkansas Regional Solid Waste Management District Class 1 and Class 4 Waste Disposal Areas Solid Waste Permit Number 0265-S1-R1 and 0265-S4, AFIN Dear Ms. Perry, The Upper Southwest Arkansas Regional Solid Waste Management District (USARSWMD) received your letter dated June 8, 2016 regarding our response to the proposed Consent Administrative Order for the Class 1 and Class 4 landfills. The letter identified two remaining compliance items of concern. One item is related to the alternate repair method submitted by the USARSWMD to address leachate leaks on the Class 1 landfill and the other item concerns the overfill of the Class 4 landfill. As requested in your letter, the enclosed workplan was prepared to address the alternate repair method. The workplan contains the items identified in your letter to address the deficiencies noted. In regard to the overfill of the Class 4 landfill, the Arkansas Department of Environmental Quality (ADEQ) was notified by on April 18, 2016 that the overfill removal had been completed and verified with a field survey of the area. In addition, an as-built survey of the overfill area was submitted to the ADEQ on June 24, correspondence with the ADEQ regarding the overfill is enclosed with this letter. ;s. :r. p."' The USARSWMD appreciates the cooperation and assistance of the ADEQ on this mattd{ If you have any questions or if you need additional information, please contact Max Tackett with the USARSWMD. The Honorable Kevin Smith USARSWMD Board Chairman

2 Upper Southwest Arkansas Regional Solid Waste Management District Page2 Enclosures cc: Max Tackett (USARSWMD Executive Director) Lance Powell, P.E. (Civil Engineering Associates, LLC)

3 2114 East Matthews Avenue Jonesboro, Arkansas Fax June 24, 2016 Arkansas Department of Environmental Quality Office of Land Resources Attn: Mr. Masoud Arjmandi 5301 Northshore Drive North Little Rock, AR SUBJECT: Overfill Correction Upper Southwest Arkansas Regional Solid Waste Management District Class 4 Waste Disposal Area Solid Waste Permit Number 0265-S4, AFIN Dear Mr. Arjmandi, As indicated in correspondence dated February 5, 2016 to the Arkansas Department of Environmental Quality (ADEQ), there was a small area within the corrected overfill area on the Upper Southwest Arkansas Regional Solid Waste Management District (USARSWMD) Class 4 landfill that was below the permitted final grades but above the intermediate cover grades. As approved by the ADEQ, USARSWMD personnel excavated four test pits in the area and verified that the material above the intermediate cover grades was all soil at two of the four locations. The other two locations had a small amount of waste above the intermediate cover grades so USARSWMD personnel re-graded the area to allow enough space for the required two feet of final cover. The ADEQ was notified by correspondence dated April 18, 2016 that a surveyor had verified that the area had been re-graded to bring it below the intermediate cover grades. As such, CEA is providing the enclosed survey to document completion of the overfill correction. On behalf of the USARSWMD, CEA appreciates the cooperation and assistance of the ADEQ on this matter. Please contact me if you have any questions or if you need additional information. Sincerely, CIVIL ENGINEERING ASSOCIATES, LLC _:cs:; Lance Powell, P.E. Project Engineer cc: Max Tackett (USARSWMD) Jeff Barfield (USARSWMD) CONWAY JONESBORO POPLAR BLUFF

4 * NSAS REGIONAL ENT DISTRICT Prepared By: CIVIL ENGINEERING ASSOCIATES, LLC 2114 East Matthews Avenue Jonesboro, Arkansas (870) Fax: (870) Cllll EIGINHIIIG ASSOCIAlU,llC

5 Upper Southwest Arkansas Regional Solid Waste Management District Class 1 Landfill Leachate Seep Repair Workplan This document constitutes a workplan for addressing persistent leachate seeps on the slopes of the Upper Southwest Arkansas Regional Solid Waste Management District (USARSWMD) Class 1 Landfill. Persistent leachate seeps at the facility will be repaired as shown in the enclosed Figure 1. The enclosed Figure 2 shows the locations for the leachate seep repairs, the length and depth of each excavation trench, and the bottom of each trench in relation to the top of the landfill bottom liner. Prior to performing any excavation for a leachate seep repair, the elevations of the landfill surface and the landfill bottom liner system in the area of the repair will be determined. A maximum depth for the leachate seep repair trench can be determined from this information to ensure that the bottom liner does not become damaged by over excavating the trench. Another provision in place to ensure that the landfill bottom liner is not damaged is the observation provided by the USARSWMD Landfill Manager as each trench is excavated. The landfill bottom liner system has a two foot thick granular leachate drainage layer that is above the geosynthetic liner that would be encountered before the bottom liner would be damaged. By observing the excavation of each trench, the Landfill Manager can alert the equipment operator if this layer is encountered so that the trench is not excavated any deeper. In the event that the landfill bottom liner system was damaged during the excavation of a leachate seep repair trench, the USARSWMD will immediately implement the following procedures for repairing the damaged liner. Excavate out enough waste material from the damaged area to determine the extents of the damage and to safely make the repair to the damaged liner. Install diversion materials to ensure that leachate does not pass through the damaged geosynthetic liner. Mobilize a qualified geosynthetic installer as soon as possible to repair the damaged liner. Contract with a third party consultant to provide construction quality assurance of the liner repair. Submit a Construction Quality Assurance Certification Report, prepared by the consultant, to the Arkansas Department of Environmental Quality documenting the repair. An as-built drawing will be maintained in the facility permanent operating record documenting the location of all leachate seep repairs made using this method. The as-built drawing will also include the length and depth of each repair. June 2016

6 Upper Southwest Arkansas Regional Solid Waste Management District Class 1 Landfill Leachate Seep Repair Workplan FIGURES June 2016

7 *EXCAVATE TRENCH EACH SIDE OF LEACHATE SEEP AS DETERt.iiNED NECESSARY IN THE FIELD LEACHATE LEAK BACKFILL WITH CLAY 3' DEEP OVERLAP HOPE LINER t.iaterial 5'-1 0' BACKFILL WITH SAND 3' FROt.i SURFACE HOPE LINER t.iaterial GEOTEXTILE EXCAVATE TRENCH AS DEEP AS TRACK-HOE WILL REACH OR TO LEACHATE DRAINAGE LAYER BACKFILL WITH WASHED ROCK 4' DEEP CIVIL ENGINEERING ASSOCIATES LtC LEACHATE SEEP REPAIR DETAIL Scale N.T.S. Job No. SW11-01 Date F'EIRUMY' 2011 Sheet F1GUK 1

8 / w B DD EE SURVEY NOTES: ICSURVEY PERFORMED BY ACE AERIAL, LLC ON JANUARY 30, THE GRID SYSTEM SHOWN WAS ESTABUSHED 1N AND IS INTENDED TO COMPLY WITH SECTION OF ARKANSAS REGULATION 22. 8M2 / \ /"--\ / \ \\ "<lp \ \ 'l-\ LEACHATEPlJM\... STATION \ \ (" AINPlJM 'b UNDERDR STATION.....,,., /,--:;.;;#(}'"<- //".;-rfl-" /::/ // >/'d \\ -. -'>'""'" \\. /7//::://,;p \ \ //..//. / \ -/ / ) ///// ///ii \..\.....,.Ci to(o.'-s \\ '\ \\ \ \ \ tf 00.p& '<?'o(o..,._s<;;. 616,.c<;;.\..\..'2. PERMITIED CLASS LANDFILL AREA 814 \..\..'3 \.Ci -o(o.l'-s<;;. o>-o '<? ss'?.!.,._cc 0-b. <'- \.Ci '<?-o(o.f>-s..._ \ \..\..':> '2-.Ci 'o(o..,._s 1.2,.,.... / 'b. 52., '2-'G<;;.\..\.. '<?'o(o.'-s<;;. _,.-f0\..\..'2. J";ACHATESE.. /?'o(\1>-# c:teseep.. // // N0.3. // -::-.::::::---- /. "0'.:> /,...- y EACHATESEEP/./// LEACHATE RISER RE/ // ANOHEAD::.v;/< //_:>/-.AI oo - // \..\..\ '2-.Ci '<?'o(o.t-.s 0 -.da;:::/ \ @<:l9 -v/ ' >/,/ =: #------c:$o - --c--./---/..,.,,i'j'-0',0' _;p:!'rp' '<.\. ////. -:// STATION INPUMP \f'\1'-i'(;.. f>-'2>\ sio.,._i,o <c s<;;.o''tj.<;; / i' BMNO THE COORDINATE MARKERS BEGIN WITH THE ORIGIN AT THE SOUTHWEST CORNER. 4. PERMANENT BENCHMARKS HAVE BEEN ESTABUSHED ATTHE SITE AS SHOWN ON THE DRAWtNG. THE COORDINATE INFORMATIOIN FOR THE BENCHMARKS IS PROVIDED IN THE TABLE BELOW. 5. MARKERS HAVE BEEN tnstalled AT THE SITE WITH EITHER A LETTER OR NUMBER DESIONATlON AS SHOWN ON THE DRAWING. AS SHOWN, THE MARKERS CAN BE CORRECTED TO THE STATE PLANE COORDINATE SYSTEM. BENCHMARK TABLE NORTHING EASTING ELEVATION TORM WATER DISCHARGE UMPSTATION NO LEACHATE SE P REPAIR SUMMARY TABLE LENGTH(FT) OEPTH(FT) BOTTOM UNERELEVATION 70 so so so NOTES: SO SO -...!Is i..... &1... I -- I= m:::ru a.o ; = ol= a 1- ::) 0 w 1- Ci) SIWATERDITCH PHASE 1-CELL 1 ACTIVE CELL PHASE 1-CELL 2 ACTIVE CELL PHASE 1-CELL 3 ACTIVE CELL PHASE 1-CELL 4 ACTIVE CELL PHASE 2-CELL 1 ACTIVE CELL PHASE 2-CELL 2 ACTIVE CELL PHASE 2-CELL 3 ACTIVE CELL PHASE 2-CELL 4 ACTIVE CELL... IlL_ CIIICIIIII--._... IlL_... IlL_ - I...,.. = too sw-01 0&/25/U lllll FlOUR 2

9 ( N) 10 ( N) 9 ( N) oo /AND FILL OFFICES cc? _-----::---- f.nd PERMITIED WA&FE-l'fRE / PROCES$1NG-FA'Ch;;t-TY / I /1 I , THE TOPOGRAPHY SHOWN WITHIN THE APPROXIMATE LIMITS OF THE CORRECTED OVERFLL MANAGEMENT AREA IS AS SURVEYED BY BUTLER & ASSOCIA.TES ON APRl.15, TEST PIT LOCATIONS ( N) 4 SITE ENTRANCE ( N) 3 AbiLITY SOAL c \ BMNO BENCHMARK TABLE NORTliiNG EASTING ELEVATION ila.*! =!i= I = 1M CD = = I = I I i!!!!!=.. :1:: " :5 fa:::iu === ( N) 2 ( N) A B C D E F G H I J ( E) ( E) ( E) ( E) ( E) ( E) ( E) ( E) ( E) ( E) (7! BM1 0 lti 0:: 0:: UJ <l: > 1-0 z 0 UJ UJ ::E 1- UJ () (!) UJ <l: 0:: z 0:: <l: 0 ::E ()... IlL_ llllleiiii !il_... IlL_... 1 = SO' SW n: _.,, 01/24/1& f'lgure 1

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