Quarterly Inspection; AFIN ; Permit Number 0254-S1-R4.

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Virginia Wheeler
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1 Document ID November 15, 2013 Robert Hendrix Craighead SWDA P.O. Box Jonesboro, AR RE: Quarterly Inspection; AFIN ; Permit Number 0254-S1-R4. Dear Mr. Hendrix, On November 8, 2013, 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 (501) Sincerely, Lori Burke, ADEQ Inspector Solid Waste Management Division Attachment

2 Arkansas Department of Environmental Quality Solid Waste Management Division Class 1 Landfill Inspection Site Name Legacy Landfill County Craighead AFIN Facility Address Hwy 1 south of Jonesboro Phone Number Permit Number 0254-S1-R4 Permittee Address Craighead SWDA, P.O. Box 16777, Jonesboro AR Address angela@ccswda.com PDS # Date 11/8/2013 Entry Time 6:20 AM Exit Time 11:30 AM X Depicts Violation Regulation 22 Operational Standards Category 1 R Repeat Violation Regulation Item Description Comments 411(l) Adequate employee facilities X R 421(a)(b) Record keeping meets requirements specified by regulations 417 Access requirements 411(j) Adequate provisions for backup equipment 421(d) Waste receipt records, ticket system maintained 411(k) Telephone system & written emergency response plan on site 423(b) Annual compliance inspection by registered professional engineer 422 Facility implements operating plan and narrative 421(f) Leachate disposal/recirculation records 421(g),701 Special waste disposal and procedures records Depicts Violation Repeat Violation Category 2 Regulation Item Description Comments R 411(a) Operations in accordance with permit documents See Category 2 Comments page 417(c) Adequate all weather operational roads 411(c) Smallest practical area, unloading supervised, single working face 411(e) Salvage operations meet approved conditions 411(f)(1) Scavenging of waste prohibited 411(p) Proper wet weather repairs 411(b) Operations by licensed on-site personnel at all times 411(d) Waste spread and compacted as unloaded 411(g) Litter control provisions maintained 414(a) Disease vectors controlled

3 Regulation Item Description R (h) )(1) 418(a) )(b) Surface Water Controls Contouring prevents surface water flowing into or through waste Run-on/off control system present and adequate R 411(h) )(2) Surface water control prevents off-site sediment accumulation R 411(i);427(f) 415 Adequate maintenance of intermediate/final cover vegetation Gas monitoring program X 411(o) 426 Leachate leaks or evidence of leachate seepage Survey controls X Leachate collection system Liquid Restrictions X Depicts Violation R (Repeat Violation) R Regulation 412 Implementation of hazardous/unauthorized waste exclusion plan 413(a) )(b) R 413(c) Satisfactory intermediate cover 416(b),411(f)(4) Open burning prohibited 419 Cause discharge/leachate discharge leaving landfill 411(f)(3),419(a)(4) Satisfactory daily/alternative cover Depositing waste in standing water prohibited 411(o) Erosion or other cover defects resulting in exposed refuse 309(c) Overfill/Off lined area Item Description Category 2 (continu Category 3 See Category 2 comments page See Category 2 comments page See Category 2 comments page See Category 2 comments page See Category 2 comments page See Category 3 comments page See Category 3 comments page Regulation 22 - Records 421(a)(8), 1203(k) 423(b) Date of last groundwater monitoring report Date of last engineering report 1/24/2013 3/30/ Liner construction in progresss Yes/No NO Notice of liner construction Yes/No Yes Third party CQA on-site during construction 412(a) Date of last random inspectionn for unauthorized waste 11/6/2013 Total # for month , 421(e) 421(g),412(a)(2),701 Date of last quarterly methanee monitoring Date of last special waste received 9/19/ /7/2013 Detection level Disposal location 415(a) Cell 4, Unit 6 Explosive gas records current? 421(d) Previous quarter waste received Tons Class 1-17,354.15Ton Class 4-10,100.86Ton 427(c) Surface water DMR records current? Yes/No Yes Fayetteville Shale Related Yes/No No Fayetteville Shale Violation Yes/No No Violation ued) Comments Comments Yes/No Yes/No Yes Yes Operator Name & Number Robert Hendrix Signature of Inspector with Tobin Baker Exit Interview Conducted with Angela Sparks / Robert Hendrix Method On site Date 11/8/2013 Time 11:00 Class 1Form 7/1/ /2012 For ADEQ Use Only

4 Arkansas Department of Environmental l Quality Solid Waste Management Division Comments Page Site Name Legacy Landfill AFIN Permit Number 0254-S1-R4 Category 2 Comments Reg (a) General Operating Requirements (Operations in accordance with permit documents) Conformance with permit documents- All operations at the landfill shall be in accordance with the approved a plans and operating plans and narrative. Comments: The facility was not handling surface water and sediment in accordance with the approved plans. Surface water was being routed through the future cells and borrow areas. At A the time of the inspection water was being pumped from the approved sedimentation pond into an on-site ditch. Seee Photos 1-2 Reg Surface Water Controls (Surface Water Controls) (d) Erosion Control- The design shall also include berms, swales, benches, downchutes and other measures as appropriate on steep slopes to minimize erosion. In areas where flow quantity and velocity warrant, rip rap, gabions, revetments, or other protection shall be provided. Comments: There were no adequate BMP s maintained to minimize erosion on all slopes throughout the landfill. Additionally, exposed waste was noted in the erosion cuts and washouts. There T was waste noted in the storm water ditches. This erosion and BMP s violation has been noted since the 1 st quarter See Photos Reg General Operating Requirements ( Surface water control prevents off-site sediment accumulation) (h) (2) Install, construct, repair, and maintain controls to prevent offf site sediment accumulation at all landfill, soil stockpile, and borrow site areas. Temporary and permanent seeding, grading, diking, terracing, diversion ditches, silt fencing, silt traps, vegetation filter strips, mulching, erosion, control c blankets, and matting, gravel filter berms, check dams, riprap, sediment ponds, and other best management practices for the site shall be inn accordance with any stormwater permit issued for the site, shall s be described in the operating narrative, and shall be included in the permit plans as appropriate. Comments: The surface water control ditches on all sides of the landfill had a large amount of sediment accumulated and exposedd waste. See photos 7, Reg Surface Water Control (Final and Interim Slope Stabilization) (f) - The operating narrative shall describe seeding and soil stabilization methods on both interim and final slopes. Inn general, exposed slopes shall be seeded or stabilized if it is anticipated that these slopes will not be disturbed for more than one growing season. More frequent seeding or stabilization may be required too prevent erosion of the cover system. The narrative shall also describe vegetative maintenance procedures and shall provide that vegetation shall be maintained in such a manner that vigorous growth is achieved. Comments: At the time of inspection, the bottom 1/3 of all slopes lacked vegetative cover and has not received waste for more than one growing season; therefore the slopes should be stabilized to prevent erosion. This lack of vegetation violation has been noted since the 1st quarter See photos Date 11/8/2013 Signature of Inspector with Tobin Baker Page 3 Category 2 Comments Page7/1/2012 For ADEQ Use Only

5 Arkansas Department of Environmental l Quality Solid Waste Management Division Comments Page Site Name Legacy Landfill AFIN Category 2 Comments Permit Number 0254-S1-R4 Reg (o) General Operating Requirements (Leachate Leaks or evidence of leachate seepage ) Cover Material Requirements (a) Daily Cover- Cover Maintenance - The owner or operator shall be responsible for maintaining the cover system integrity and shall promptly repair erosion, washout, tracking, or other defects that result in exposed refuse in either daily or intermediate cover, c or exposure of the barrier system of the final cover. Areas of leachate seepage, or areas exhibiting evidence of leachate seepage such as staining and discoloration of the cover system shall also be promptly p repaired. Comments: A leachate leak was observed on the west slope of the landfill. See Photos Reg (a) Leachate Collection System Design And Construction (Leachate collection system ) System Requirements - Leachate collection systems shalll be designed and installed to facilitate dewatering of the waste mass and disposal area. The systems shall be designed to limit the maximum leachate head on the bottom liner at any point at any time to 30 cm (12 inches) or less. The system shall also be designed to facilitate maintenance. Comments: During the inspection, it was noted that the monitor for Celll 4 was reading and according to 2012 AEIR report this would indicate there are greater than 12 inches of head on the liner. A warning light was flashing on the leachate collection 20,000 gallon tank. Additionally, the monitor in that building for the new cell was reading and the light was flashing on it. During the inspection the facility had greater than 12 inches of head on the liner. See Photos 24-26, and 55 Date 11/8/2013 Signature of Inspector with Tobin Baker Page 4 Category 2 Comments Page7/1/2012 For ADEQ Use Only

6 Arkansas Department of Environmental l Quality Solid Waste Management Division Comments Page Site Name Legacy Landfill AFIN Permit Number 0254-S1-R4 Category 3 Comments Reg Cover Material Requirements (Satisfactory Daily/Alternative Cover)- (a) Daily Cover- Except as provided in paragraph (d) of this section, the owners or operators of all Class 1 Landfills must cover disposed solid waste with six (6) inches of earthen material at the end of each operating day, or at more frequent intervals if necessary, to control disease vectors, fires, odors, blowing litter, andd scavenging and to limit the generation of leachate. (b) Alternative Cover Materials - Alternative cover materials of an alternative thicknesss (other than at least six inches of earthen material) may be approved by the Director, r, either through individual requests or through generalized Department approval upon demonstration that the alternative material and thickness controls disease vectors, fires, odors, blowing litter, and scavenging without presenting a threat to human health and the environment. Comments: At the time of the inspection, the facility had not received any waste for that day. It was noted that the active working area had exposed waste that did not have 6 inches of required daily cover or alternative cover material from the previous day of operation. See Photos Reg Cover Material Requirements (Satisfactory intermediate cover) (c)interim Cover Material Requirements: A compacted layer of cover soil of sufficient quantity to ensure there is no exposed waste, but not less than twelve (12) inches in total thickness including the six inches of daily cover (or an approved alternate material), shall be applied upon surfacess that will not receivee an additional application of waste of final cover within 180 days. Comment: At the time of the inspection, there was not the 12 inches of required cover on the bottom 1/3 of landfill. Due to the lack of the required cover, the slopes had an a excessive amount of exposed waste. Waste was also noted in the surface water control ditches. See photos 33-36, Date 11/8/2013 Signature of Inspector Page 5 with Tobin Baker Category 3 Comments Page7/1/2012 For ADEQ Use Only