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

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Janel Greene
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1 Document ID April 4, 2014 Robert Hendrix Craighead SWDA P.O. Box Jonesboro, AR RE: Quarterly Inspection; AFIN ; Permit Number 0254-S1-R4. Dear Mr. Hendrix, On March 18, 2014, 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 3/18/2014 Entry Time 6:00 AM Exit Time 11:55 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 411(a) Operations in accordance with permit documents 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) Leachate leaks or evidence of leachate seepage Survey controls Leachate collection system Liquid Restrictions X Depicts Violation R (Repeat Violation) Regulation (a) )(b) Item Description Implementation of hazardous/unauthorized waste exclusion plan Satisfactory daily/alternative cover R 413(c) 416(b),411(f)(4) Satisfactory intermediate cover Open burning prohibited X (f)(3),419(a)(4) Cause discharge/leachate discharge leaving landfill Depositing waste in standing water prohibited X 411(o) 309(c) Erosion or other cover defects resulting in exposed refuse Overfill/Off lined area 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 3 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 12/23/ /30/ Liner construction in progresss Yes/No NO Notice of liner construction Yes/No Yes Third party CQA on-site during construction 412(a) 415, 421(e) Date of last random inspectionn for unauthorized waste Date of last quarterly methanee monitoring 3/14/2014 3/10/2014 Total # for month Detection level 20 0 LEL 415(a) Explosive gas records current? 421(g),412(a)(2), (d) 427(c) Date of last special waste received Previous quarter waste received Surface water DMR records current? 3/17/2014 Yes/No Disposal location Tons Yes Cell 4, Unit 6 Class 1-9, Ton Class 4-10, Ton 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 Exit Interview Conducted with Angela Sparks Method On site Date 3/18/2014 with Tobin Baker Time 11:50 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 Category 2 Comments Permit Number 0254-S1-R4 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: The facility does not have any surface water controls in place as described in (d) and the limited use of the hay bales on the corners does not control the erosion on all slopes of the landfill. No BMP s were in place other than the limited hay bales which has resulted in erosion as noted in category 3. BMP ss violation has been noted since the 1 st quarter See Photos 1-2 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: Due to lack of surface water controls, the surface water control ditch on the southwest corner of Cell 4 Unit 3 was filledd with sediment which allowed for off-site sediment accumulation. The storm water system is not controlling water and sediment as designed. The facility is not following their operating plan/narrative ADEQ doc # section 1.9 additional surface waterr controls. Due to sediment build up in the ditch, water and sediment have flowed across the road. See photos 3-6 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 west slope of Cell 3 and Cell 4 Unit 3 below the 320 elevation bench-road lacked vegetative cover and there were no other slope stabilizers in place. The south slope of Cell 4 Unit 1 and 2,, and east slope of Cell 3 below the 320 elevation bench-road, lacked vegetative cover and there were no other slope stabilizers in place. The facility is not following f their operating plan/narrative ADEQ doc # section 1.9 additional surface water controls. This vegetative cover or stabilization is required on interim/final slopes that will not receive waste for more than one growing season. This lack of vegetation/stabilization of slopes violation has been noted since the 1st quarter See photos 7-12 Reg (o) General Operating Requirements (Leachate Leaks or e vidence 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: Several leachate leaks were observed throughout the landfill. Leachate leaks were observed on the west slope of Cell 2 below active working face, on the northeast corner and north slope of Cell 3 above active working face, near the top of the west slope of Cell 4 Unit 3 around the 320 road, and on the south slope of Cell 4 Unit 1 and 2 along the 360 road of the landfill. See Photos Date 3/ /18/2014 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 Permit Number 0254-S1-R4 Category 3 Comments 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, the west slope of Cell 3 and Cell 4 Unit 3 below the 320 elevation bench-road and on the south slope of Cell 4 Unit 1 and 3 of the landfill do not havee 12 inches of required intermediate cover. Due to the lack of intermediate cover, large amounts of waste were exposed on the surface and in the stormwater ditches. See photos Reg Surface Water Requirements (Cause discharge/leachate discharge leaving landfill) (a) General Requirements - As provided in 40 CFR all Class 1 landfills shall not: (5) Allow the discharge of leachate from the landfilll unit unless the discharge is permitted under the NPDES system. Comment: Leachate was observed discharging from the lined landfill unit at the base of the west slope of Cell 4 Unit 3 and from the base of the northeast corner of Cell 3 into the storm water ditch (another unit). Leachate was also being pumped from the active cell (Cell 2) to the storm water ditch. The leachate was noted discharging from one landfill unit and entering another landfill unit. See photos Reg General Operating Requirements(Erosion or other cover defects resulting in exposed refuse) (o) Cover Maintenance - The owner or operator shall be responsible for maintaining the cover system integrity and shall promptly r epair erosion, washout, tracking, or other defects that result in exposed refuse in either daily or intermediate cover, 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 coverr system shall also be promptly repaired. Comment: Erosion cuts with exposed waste were observed on the west slope of Cell 2 by the active working face and on the west slope of Cell 4 Unit 3. Erosion cuts with exposed waste weree also observed on the south slope of Cell 4 Unit 1 and on the south slope of Cell 4 Unit 3. There were also erosion cuts with exposed waste on the north side of Cell 3. The erosion cuts exposed large amounts of waste. See photos Date 3/ 18/2014 Signature of Inspector Page 4 with Tobin Baker Category 3 Comments Page7/1/2012 For ADEQ Use Only