September 22, Lexi Grisham, President Grisham Farm Products 7364 Newkirk Rd. Mountain Grove, MO RE: Grisham Farm Products Hoxie, AR

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September 22, 2008 Lexi Grisham, President 7364 Newkirk Rd. Mountain Grove, MO 65711 RE: Hoxie, AR AFIN: 38-XXXXX NPDES Permit No.: No-Permit Dear Mr. Grisham: On September 17, 2008, I performed a compliance inspection of the above referenced facility in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. This inspection was conducted in response to a complaint alleging exposed materials stored outside and revealed the following violations: 1. Operation of a facility discharging storm water associated with industrial activities without an NPDES Industrial Storm Water permit as required by 40 CFR 122.26(b)(14) Subpart (i) (xi). The facility handles and stores food waste from local manufactures to be used in the production of swine and poultry feed. 2. Placing or causing to be placed any waste where it is likely to cause pollution to the Waters of the State; this is a violation of the Arkansas Water and Air Pollution Control Act 8-4-217.(a)(2). At the time of the inspection, there were multiple piles of partially burned waste that had not been removed from the site following a fire on August 18, 2008. The above items require your immediate attention. Please submit a written response to these findings to the Water Division Enforcement Branch of this Department at the following address: Water Division Enforcement Branch Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR 72118-5317

«Cognizant_Official», «Facility_Name» September 22, 2008 Page 2 This response should contain detailed documentation describing the course of action taken to correct the items noted. This corrective action should be completed as soon as possible, and the written response is due by October 16, 2008. For additional information you may contact the Enforcement Branch by telephone at 501-682-0639 or by fax at 501-682-0910. If I can be of any assistance, please contact me at walker@adeq.state.ar.us or 870-935-7221 ext.-12. Sincerely, Brent L. Walker District 3 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch NPDES Report Page 2

Form Approved OMB No. 2040-0003 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C. 20460 NPDES Compliance Inspection Report Section A: National Data System Coding Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N 2 5 3 N O - P E R M I T 11 12 0 8 0 9 1 7 17 18 W 19 S 20 2 Remarks Inspection Work Days Facility Evaluation Rating BI QA -------------------------------Reserved------------------------------ 67 69 70 N 71 N 72 N 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) SE of Hwy. 67B and Towne St. Hoxie, AR Entry Time/Date 1155 9/17/2008 Exit Time/Date 1210 9/17/2008 Permit Effective Date N/A Permit Expiration Date N/A Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Lexi Grisham/President/417-746-4834 Cell-417-259-3131 7364 Newkirk Rd. Mountain Grove, MO 65711 Yes Contacted No Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) U Permit N Flow Measurement N Operations & Maintenance N Sampling N Records/Reports N Self-Monitoring Program N Sludge Handling/Disposal U Pollution Prevention N Facility Site Review N Compliance Schedules N Pretreatment N Multimedia N Effluent/Receiving Waters N Laboratory U Storm Water N Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) The following violations were noted: 1. Operation of a facility discharging storm water associated with industrial activities without an NPDES Industrial Storm Water permit as required by 40 CFR 122.26(b)(14) Subpart (i) (xi). The facility handles and stores food waste from local manufactures to be used in the production of swine and poultry feed. 2. Placing or causing to be placed any waste where it is likely to cause pollution to the Waters of the State; this is a violation of the Arkansas Water and Air Pollution Control Act 8-4-217.(a)(2). At the time of the inspection, there were multiple piles of partially burned waste that had not been removed from the site following a fire on August 18, 2008. Name(s) and Signature(s) of Inspector(s) Brent L. Walker Agency/Office/Telephone/Fax AR Dept. of Environmental Quality-Jonesboro (870) 935-7221 ext. 12/(870) 935-4715 (Fax) Date September 22, 2008 Signature of Reviewer Agency/Office/Phone and Fax Numbers Date NPDES Report Page 3

NPDES Report Page 4

Location: Photo # Water Division NPDES Photographic Evidence Sheet 1 Of 4 Date: 9/17/2008 Time: 1157 Piles of partially burned food waste. Photo # 2 Of 4 Date: 9/17/2008 Time: 1157 Piles of partially burned food waste. NPDES Report Page 5

Location: Photo # Water Division NPDES Photographic Evidence Sheet 3 Of 4 Date: 9/17/2008 Time: 1158 Piles of partially burned food waste. Photo # 4 Of 4 Date: 9/17/2008 Time: 1202 Storage and loading area. NPDES Report Page 6