November 26, The Honorable Ron Daniell Clark County Judge Courthouse Square 401 Clay Street Arkadelphia, AR 71923

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Hugh Hampton
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1 Document ID November 26, 2014 The Honorable Ron Daniell Clark County Judge Courthouse Square 401 Clay Street Arkadelphia, AR RE: Quarterly Inspection; AFIN ; Permit Number 0044-S4 Dear Judge Daniell: On November 20, 2014, Matthew Greenwood (District 7 Inspector) and I conducted a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Regulation 22, and the above-referenced permit. A copy of the inspection report is enclosed for your records. Please refer to the attached inspection report to note the specific allegations. A written response for the noted allegations, describing the corrective action taken or to be taken, must be submitted to my attention at the address listed below within thirty (30) days from the date hereof. Failure to submit the written response shall be construed as an admission of any allegations. Any items noted that are neglected and/or persistent may warrant formal enforcement action. If I can be of any further assistance, feel free to contact me at or burke@adeq.state.ar.us. Sincerely, Lori Burke ADEQ Inspector Solid Waste Management Division Attachment Revised

2 Arkansas Department of Environmental Quality Solid Waste Management Division Class 4 Landfill Inspection Site Name Clark Co. Class 4 County Clark AFIN Facility Address Hwy 51 North of Joan Phone Number Permit Number 0044-S4 Permittee Address Courthouse Square Arkadelphia, AR Address ron@clarkcountyarkansas.com PDS # Date 11/20/2014 Entry Time 10:30 Exit Time 11:32 Regulation 22 Operational Standards Category 1 Regulation Item Description Comments 607(l) Adequate employee facilities 617(a)(b) Record keeping meets requirements specified by regulations 613 Access requirements 607(j) 617(c) 607(k) 619(a) Adequate provisions for backup equipment Waste receipt records, ticket system maintained Telephone system & written emergency response plan on site Annual compliance inspection by registered professional engineer 618 Facility implements operating plan and narrative 701 Special waste disposal and procedures records Category 2 Regulation Item Description Comments 607(a) Operations in accordance with permit documents 613(c) 607(c)(d) 607(e) 607(f)(1) Adequate all weather operational roads Smallest practical area, single working face Salvage operations meet approved conditions Scavenging of waste prohibited 613 (c) Proper wet weather repairs 607(b) 607(d) 607(g) 610(a) Operations by licensed on-site personnel at all times Waste spread and compacted as unloaded Litter control provisions maintained Disease vectors controlled 611 Gas monitoring program 622 Survey controls

3 Category 2 (continued) Regulation Item Description Comments 623 Surface water controls 607(h)(1) 614(a) 607(h)(2) 607(h)(i)(o) Contouring prevents surface water flowing into or through waste Run-on/off control system present and adequate Surface water control prevents off-site sediment accumulation Adequate maintenance of intermediate/final cover vegetation X 607(o) Leachate leaks or evidence of leachate seepage A leachate leak was documented at the bottom western toe of the current working face. See Photos Liquid restrictions Category 3 Regulation Item Description Comments 608 Implementation of hazardous waste exclusion plan 609(a) 609(b) 612(b),607(f)(4) Satisfactory weekly or more frequent cover Satisfactory immediate cover Open burning prohibited X 615 Cause discharge/leachate discharge leaving landfill Several leachate leaks were noted in the inactive Class IV area flowing off the side slope into the storm water ditch on the southwestern slope and into the pine trees near the sedimentation pond. These leachate leaks were a cause discharge since they were leaving one landfill unit and entering two other units. See Photos (f)(3),615(a)(4) Depositing waste in standing water prohibited X 607(o) Erosion or other cover defects resulting in exposed refuse There was erosion occurring with exposed waste in the inactive area on the southwestern slope next to access road. See Photos 1-7 X 309(c ) Overfill/off lined area According to AEIR submitted 4/11/2014 an overfill condition was noted. The facility has not submitted the overfill management plan in writing which is required 7 days of learning of excess fill. Regulation 22 - Records 617(a)(4), 621(e) Date of last groundwater monitoring report n/a Site Conditions Cloudy 619 Date of last engineering report 4/11/2014 Weather Conditions Dry 617(a)(4) Liner construction in progress Yes/No Notice of liner construction Yes/No Third part CQA on-site during construction Yes/No 608 Date of last random inspection for unauthorized waste Total # for month 611 Date of last quarterly methane monitoring N/A Detection level 611 Explosive gas records current? Yes/No 701 Date of last special waste received N/A Disposal location 617(c ) Previous quarter waste received Tons 623 Surface water DMR records current Yes/No Unknown Operator Name & Number Joe Riley Signature of Inspector Exit Interview Conducted with Joe Riley Method On-site Date 11/20/2014 Time 11:00 Class 4 Form 7/1/2012 (Revised and Implemented 10/21/2014) For ADEQ Use Only