May 28, Justin Haynes, Owner Southland Septic Services, Inc Highway 67 Malvern, Arkansas RE: Complaint investigation

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1 May 28, 2009 Justin Haynes, Owner Southland Septic Services, Inc Highway 67 Malvern, Arkansas RE: Complaint investigation AFIN: Permit No.: 4471-WR-2 Dear Mr. Haynes: On May 21, 2009, I performed a routine compliance inspection of the waste treatment and disposal facility in response to a citizen s complaint. The complaint alleged that foul odors were coming from the Hot Springs facility off of Amity Road. This inspection was performed in accordance with the provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated thereunder. This inspection revealed the following. 1. An apparent oil/water separator with a leach field disposal system has been installed without any prior approval from this department. All along this leach field there are areas where the waste is flowing to the top of the ground and flowing downhill and placed in manner that would likely cause pollution to the waters of the state. The separator was not part of the approved permit based off of the permit application, and is not part of the waste management plan for this site. 2. There is a slow leak in the valve of the holding tank is allowing waste to accumulate atop the ground in the immediate area in a manner that would likely cause pollution to the waters of the state. The aforementioned are violations of the following items in your permit. Item 1 of your state permit 4471-WR-2 which states in part that waste shall not be discharged from this operation to the waters of the State or onto the land in any manner that may result in runoff to the waters of the State. Item 2 of your state permit 4471-WR-2 which states that the waste disposal system shall be constructed, operated, and maintained in accordance with the Waste Management Plan (WMP) approved by the ADEQ. Item 3 of your state permit 4471-WR-2 which states in part that the disposal system shall be maintained in good operating condition at all times. Item 4 of your state permit 4471-WR-2 which states in part that bypassing the disposal system is prohibited and may result in the revocation of this permit and/or other appropriate enforcement action by the Department. Item 8 of your state permit 4471-WR-2 which states in part that this permit is issued in reliance upon the statements and representations made in the application and the WMP. Item 17 of your state permit 4471-WR-2 which states grease-trap waste shall be applied evenly over the application area by subsoil injection to a minimum of six inches.

2 Justin Haynes, Southland Septic Services 10/23/08 Page 2 Item 22 of your state permit 4471-WR-2 which states the permittee shall take all necessary measures to reduce obnoxious and offensive odors. Equipment shall be properly operated and maintained to prevent spillage, leakage or discharges. Item 24 of your state permit 4471-WR-2 which states the permittee shall give 120 days prior notice to the Director of any changes planned in the grease-trap waste disposal practice. Statement of Basis, Item 2-General Requirements of your state 4471-WR-2 which states in part that Waste spills, discharges, etc., shall be reported immediately to the Department and promptly corrected. The above items require your immediate attention. Please submit a written response to these findings to Cindy Garner, Water Division Enforcement Branch Manager. This response should be mailed to the address below. This response should contain documentation describing the course of action taken to correct each item noted. This corrective action should be completed as soon as possible, and the written response with all necessary documentations (i.e. pictures) is due by June 10, For additional information you may contact the enforcement section by telephone at or by fax at If I can be of any assistance, please contact me at Sincerely, Jim McSwain District 7 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch No Discharge Industrial Report Page 2

3 ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY NO DISCHARGE INDUSTRIAL PERMIT INSPECTION FORM AFIN: Log No.: Permit No.: 4471-WR-2 Inspection Date: 5/21/09 Media: Water Inspector: Jim McSwain Compliance Status: IN / OUT 1A. Name of Facility: Southland Septic Services Address: At the end of Orbit Road, off of Amity, Road just south of Hot Springs. County: Hot Spring 2A. Name of On-Site Representative: N/A 3A. Name of Responsible Official: Justin Haynes Address: Highway 67, Malvern, AR Telephone: A. Parent Company: N/A Address: Telephone: 5A. Description of Process (including type of industry, materials produced, and major byproducts): Subsurface injection of grease-trap waste. 6A. Any complaints registered against this permitted facility? Yes No If yes, give date and description of complaint: Numerous, see permit file 7A. Are there any additions, modifications, or corrections to the facility since the last inspection? Yes No If yes, explain: An oil/water heated separator has been added to the Glen Rose site. The Hot Springs site has added a modified activated sludge plant (modified to be a Separator). The discharge from this appears to be to a leach field near the old land application site. No Discharge Industrial Report Page 3

4 1B. Furnish a simplified flow diagram of the treatment system and include main components, flow sequence through plant, and calculated or estimated flows. Old Storage Tank Containment dike Leak Treatment Unit Possible Leach Field line nts Wastewater is surfacing in these locations 2B. Nearest Stream: Unnamed Tributary approximately 150 feet away 3B. Does wastewater from this facility cause adverse effect on the waters of the State: Yes No N/A If yes, describe: Could not be determined at the time of this inspection 4B. Are operating records kept as required by permit? Yes No N/A If no, explain: Permittee was not at the application site at the time of inspection 5B. Are maintenance records kept as required by permit? Yes No N/A If no, explain: 6B. Are Samples routinely taken? Yes No N/A 7B. Does the sampling program meet the requirements of the permit? Yes No N/A If no, explain: 8B. What laboratory does the facility use? N/A Address: Telephone: No Discharge Industrial Report Page 4

5 1C. Do laboratory procedures and records meet the requirements of the permit? Yes No N/A If no, explain: 2C. Is contaminated runoff a problem? Yes No N/A If yes, explain: Exposed wastewater is subject to runoff from rainfall events. 3C. Is sludge disposal required? Yes No N/A If yes, describe (including final destination): Subsurface injection system 4C. Is the treatment system being properly operated and maintained as required by permit? Yes No N/A This system near the Hot Springs site is malfunctioning and is not If no, explain permitted. SUMMARY OF FINDINGS/COMMENTS Upon receiving this complaint, I went to the site. The gate on the site was unlocked, so I proceeded up to the application site. Upon pulling up near the holding tank, I could smell a a strong odor coming from behind a new metal building that was not there during my last inspection. I looked inside the building and saw what looked to be an old modified activated sludge plant that was being used a an oil/water separator. The discharge from this looked like it was being piped underground into a leach field (similar to a septic system). Looking around outside of the building in the direction where this line ran, there was wastewater surfacing along where the ground had been disturbed. From looking at this, the disturbed ground ran for approximately 150 feet. Along this area were several areas where wastewater was surfacing and flowing along the surface of the ground. At the time of this inspection, the surfacing wastewater had a constant flow where it ran across the old application site. This runoff would pose a threat to surface waters if there were a rainfall event. Inspector Signature: Date of Report: 5/21/09 Signature of Reviewer: Date of Review: 5/27/09 No Discharge Industrial Report Page 5

6 Water Division No Discharge Industrial Photographic Evidence Sheet Photo # 1 Of 12 Date: 5/21/09 Time: 1110 Description: Wastewater surfacing from a possible leach field Photo # 2 Of 12 Date: 5/21/09 Time: 1110 Description: Wastewater surfacing from a possible leach field No Discharge Industrial Report Page 6

7 Photo # 3 Of 12 Date: 5/21/09 Time: 1110 Description: Wastewater surfacing from a possible leach field Photo # 4 Of 12 Date: 5/21/09 Time: 1110 Description: Wastewater surfacing from a possible leach field No Discharge Industrial Report Page 7

8 Water Division No Discharge Industrial Photographic Evidence Sheet Photo # 5 Of 12 Date: 5/21/09 Time: 1110 Description: Exposed pipe. Possibly coming from the treatment unit. Photo # 6 Of 12 Date: 5/21/09 Time: 1111 Description: Waste treatment unit which appears to be discharging to a leach field No Discharge Industrial Report Page 8

9 Photo # 7 Of 12 Date: 5/21/09 Time: 1112 Description: Waste treatment unit which appears to be discharging to a leach field Photo # 8 Of 12 Date: 5/21/09 Time: 1112 Description: Discharge Point of the waste treatment unit No Discharge Industrial Report Page 9

10 Photo # 9 Of 12 Date: 5/21/09 Time: 1112 Description: Waste treatment unit which appears to be discharging to a leach field Photo # 10 Of 12 Date: 5/21/09 Time: 1114 Description: Wastewater surfacing from a possible leach field No Discharge Industrial Report Page 10

11 Photo # 11 Of 12 Date: 5/21/09 Time: 1115 Description: Runoff from wastewater surfacing from a possible leach field Photo # 12 Of 12 Date: 5/21/09 Time: 1116 Description: Runoff from wastewater surfacing from a possible leach field No Discharge Industrial Report Page 11