July 7, Jason Barnes, Facilities and ESH Manager Facilities and ESH manager Baxter Healthcare Corporation Mountain Home, AR 72653

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July 7, 2015 Jason Barnes, Facilities and ESH Manager Facilities and ESH manager Baxter Healthcare Corporation Mountain Home, AR 72653 RE: Baxter Healthcare-Mt. Home Inspection (Baxter Co) AFIN: 03-00002 NPDES Permit No.: ARR154730 Dear Mr. Barnes: On June 16, 2015, I performed a Construction Stormwater Inspection of the above-referenced project in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. A copy of the inspection report is enclosed for your records. I received your written documentation addressing the violations noted during the inspection. No further response is required. However, please review all comments associated with the noted violations. If I can be of any assistance, please contact me at wallace@adeq.state.ar.us or (870) 424-3322 extension 3. Sincerely, Cody Wallace District 10 Field Inspector Water Division Page 1 of 8

FACILITY INFORMATION NAME: Baxter Healthcare-Mt. Home LOCATION: 1900 Hwy 201 North CITY: Mountain Home, AR 72653 RESPONSIBLE OFFICIAL NAME: / TITLE Jason Barnes / Facilities and ESH manager COMPANY: Baxter Healthcare Corporation MAILING ADDRESS: 1900 Hwy 201 North CITY, STATE, ZIP: Mountain Home AR 72653 PHONE & EXT: / FAX: 870-424-5200 / EMAIL: CONTACTED DURING INSPECTION: *** WATER DIVISION INSPECTION REPORT AFIN: 03-00002 PERMIT #: ARR154730 DATE: 6/16/2015 COUNTY: 03 Baxter PDS #: 085058 MEDIA: WN GPS LAT: 36.35756 LONG: -92.38740 LOCATION: General Area FACILITY TYPE: 2 - Industrial FACILITY EVALUATION RATING: N INSPECTION INFORMATION INSPECTOR ID#: 109962 S - State DATE(S): ENTRY TIME: EXIT TIME: 6/16/2015 10:00 11:35 FAYETTEVILLE SHALE RELATED: N INSPECTION TYPE: Construction Stormwater PERMIT EFFECTIVE DATE: 2/26/2015 PERMIT EXPIRATION DATE: 10/31/2016 FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/EMAIL/ETC.: Jason Barnes/Facilities and ESH manager (Baxter Healthcare)/870-424-5200 Will Gregory/Owner-Operator (Gregory Company)/870-404-7377 Kurt Parnell/Project Lead (Baxter Healthcare)/870-421- 0176 AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) ** PERMIT ** FLOW MEASUREMENT ** STORMWATER ** RECORDS/REPORTS ** LABORATORY ** FACILITY SITE REVIEW ** OPERATION & MAINTENANCE ** EFFLUENT/RECEIVING WATER ** SELF-MONITORING PROGRAM ** SAMPLING ** SLUDGE HANDLING/DISPOSAL ** PRETREATMENT M OTHER: Construction Stormwater SUMMARY OF FINDINGS 1.) Notice of Coverage (NOC) was not posted near the main entrance of the site to be made visible to the public. This is a violation of Part II, Section A.2.D of the general permit. Mr. Jason Barnes has submitted written documentation via email addressing this violation. No further response is required for this violation. 2.) Silt fence on the south-side of the construction project needs proper installation and maintenance in areas. This is a violation of Part II, Section B.17.A of the general permit. Observations included improper trenching of fence, gaps where two sections of fence meet, undercutting, and soil buildup potentially causing the fence to collapse. Mr. Jason Barnes has submitted written documentation via email addressing this violation. No further response is required for this violation. GENERAL COMMENTS Project construction was initiated in Spring 2015. On Tuesday June 16, 2015 I met with the above-referenced participants to perform a Construction Stormwater Inspection. Investigation discoveries were stated to Mr. Jason Barnes and Will Gregory during the inspection. Mr. Jason Barnes and Will Gregory affirmed that these findings would be corrected the day they were noted. Mr. Jason Barnes followed up with me via email and telephone on June 16, 2015 that corrective actions for the findings have been completed. INSPECTOR S SIGNATURE: Cody Wallace DATE: 6/19/2015 SUPERVISOR S SIGNATURE: Kerri McCabe DATE: 6/26/2015 Inspection Report Page 2 of 8

SECTION I: SITE POSTING AND SITE INFORMATION SITE NAME: Baxter Healthcare Expansion Proj. TOTAL ACREAGE: 75 ACREAGE DISTURBED: 5.50 LATITUDE: 36.35756 LONGITUDE: -92.38740 STARTING DATE February 26, 2015 1. Is site is posted with Notice of Coverage (NOC)? (Part II, A.2.D) Y N NA NE 2. Is posting at construction entrance and visible to the public? (Part II, A.2.D) Y N NA NE 3. If project is linear, is posting at area actively under construction? (Part I, B.8.C) Y N NA NE 4. If project is part of larger common plan of development, what is development name and permit number? Development Name: Development Permit No: SECTION II: STORM WATER POLLUTION PREVENTION PLAN EVALUATION AND IMPLEMENTATION A. Is the SWPPP being maintained on site from 08:00 am to 5:00 pm? (Part II, A.2.A) B. Is the SWPPP properly signed as required by Part II, A.2.A of the permit? C. Is the SWPPP being updated as required by Part II, A.3 of the permit? D. Site map in SWPPP (Part II, A.4.F) 1) Pre-construction topographic view (Part II, A.4.F.1); 2) Direction of stormwater flow (i.e., use arrows to show which direction stormwater will flow) and approximate slopes anticipated after major grading activities (Part II, A.4.F.2); 3) Delineate on the site map areas of soil disturbance and areas that will not be disturbed under the coverage of this permit (Part II, A.4.F.3) 4) Location of major structural and nonstructural controls identified in the plan (Part II, A.4.F.4) 5) Location of main construction entrance and exit (Part II, A.4.F.5) 6) Location where stabilization practices are expected to occur (Part II, A.4.F.6) 7) Locations of off-site materials, waste, borrow area, or equipment storage area (Part II, A.4.F.7) Y N NA NE 8) Location of areas used for concrete wash-out (Part II, A.4.F.8) 9) Location of all surface water bodies (including wetlands) (Part II, A.4.F.9) 10) Locations where stormwater is discharged to a surface water and/or municipal separate storm sewer system if applicable (Part II, A.4.F.10) 11) Locations where stormwater is discharged off-site (should be continuously updated) (Part II, A.4.F.11) 12) Areas where final stabilization has been accomplished and no further construction phase permit requirements apply (Part II, A.4.F.12) E. Stormwater Controls Y N NA NE Y N NA NE 1) Are all controls installed as described in the SWPPP? (Part II, A.4.G) 2) Silt fences properly installed and maintained? (Part II, B.17.A) Y N NA NE 3) Check dams and velocity dissipation devices properly installed and maintained? (Part II, B.17.A) 4) Sedimentation basins and sediment traps properly installed and maintained (sediment removed when 50% capacity)? (Part II, B.17.A) and (Part II, A.4.G.1.e) Y N NA NE 5) Has sediment that has gotten offsite been removed? (Part II, A.4.G.1.d) Y N NA NE 6) Is construction site entrance sufficiently stabilized to prevent off site tracking? (Part II, A.4.H.2) 7) Are stabilization methods described in SWPPP being implemented in a timely manner? (Part II, A.4.G.2) Inspection Report Page 3 of 8

F. Inspections Inspection Report: Baxter Healthcare-Mt. Home, AFIN: 03-00002, Permit #: ARR154730 1) Inspection Frequency in SWPPP Once every 7 days 14 days and after ½ inch rain event 1a) If inspection frequency is every 14 days, do they have a rain gauge onsite? (Part II, A.4.L.1.b) 1b) Is rain gauge properly installed? (nothing obstructing rain gauge) (Part II, B.17.A) 2) Are inspection records being maintained onsite? (Part II, A.4.L.3) 3) Are ADEQ inspection forms being used or do the forms contain the elements required by the permit? (Part II, A.4.L.2) 3a) Inspector Name and Title (Part II, A.4.L.2.a) 3b) Date of Inspection (Part II, A.4.L.2.b) 3c) Amount of Rainfall and Days Since Last Rain Event (only if inspection frequency is 14 days) (Part II, A.4.L.2.c) 3d) Approximate beginning and duration of the storm event (Part II, A.4.L.2.d) 3e) Description of any discharges during inspection (Part II, A.4.L.2.e) Y N NA NE 3f) Locations of discharges of sediment/other pollutants (Part II, A.4.L.2.f) Y N NA NE 3g) Locations of BMPs in need of maintenance or where maintenance was performed (Part II, A.4.L.2.g) 3h) If the BMPs are in working order and if maintenance is required (when scheduled and completed) (Part II, A.4.L.2.h) Y N NA NE Y N NA NE 3i) Locations that are in need of additional controls (Part II, A.4.L.2.i) Y N NA NE 3j) Location and Dates When Major Construction Activities Begin, Occur or Cease (Part II, A.4.L.2.j) 3k) Report Signature of Inspector (Part II, A.4.L.2.k) 4) Are inspections conducted in accordance with the requirements of the SWPPP? (Part II, A.4.L) 5) Are corrective actions being implemented within 3 business days? (Part II, A.4.M) Y N NA NE G. Stormwater management 1) Is solid waste being controlled as described in SWPPP? (Part II, A.4.H.1) 2) Are stabilized buffer zones being maintained? (25 feet from stream, 50 feet if 303 d, TMDL, ERW, ESW, or NSW) (Part II, A.4.G.2.b) 3) Have velocity dissipation devices been installed at discharge points, within concentrated flow areas serving two or more acres, and along drainage courses where required to prevent erosive flows? (Part II, A.4.G.3.b) 4) Has silt or sediment gotten off the construction site? A.C.A. 8-4-217(a)(2) Y N NA NE 5) Has silt and sediment been discharged to the waters of the State? A.C.A. 8-4-217(a)(2) Y N NA NE If yes, give the name of the stream or waterbody: 6) Is the washout of concrete being done at the designated location? (Part II, A.4.F.8) 7) Does the liquid waste from concrete washout reach the waters of the State? (Part II, A.4.H.5) Y N NA NE 8) Are fuel storage areas protected as described by SWPPP? (Part II, A.4.H.6) Y N NA NE 9) Have temporary erosion controls been removed from areas finally stabilized? (Part II, A.4.G) Y N NA NE 10) Are there any allowable non-stormwater discharges that have not been addressed in the SWPPP? (Part II, A.4.I) 11) Are there any process waters or non-stormwater discharges that are not allowed under the permit being discharged? A.C.A. 8-4-217(b)(1)(E) 12) Does the SWPPP include the required information about employee training (dates of training, records of training, etc.)? (Part II, A.4.N) Y N NA NE Y N NA NE Inspection Report Page 4 of 8

Water Division Photographic Evidence Sheet Location: Baxter Healthcare-Mt. Home Photographer: Cody Wallace Date: June 16, 2015 Time: 1057 Witness: Jason Barnes, Will Gregory, Kurt Parnell Photo #: 1 Description: Gap where two sections of fence meet on south-side of project. Photographer: Cody Wallace Date: June 16, 2015 Time: 1058 Witness: Jason Barnes, Will Gregory, Kurt Parnell Photo #: 2 Description: Fence leaning heavily. Soil piled against fence; potentially causing the fence to collapse on south-side of project. Inspection Report Page 5 of 8

Water Division Photographic Evidence Sheet Location: Baxter Healthcare-Mt. Home Photographer: Cody Wallace Date: June 16, 2015 Time: 1100 Witness: Jason Barnes, Will Gregory, Kurt Parnell Photo #: 3 Description: Example of area where silt fence is not properly trenched on south-side of project. Photographer: Cody Wallace Date: June 16, 2015 Time: 1101 Witness: Jason Barnes, Will Gregory, Kurt Parnell Photo #: 4 Description: Undercutting occurring below silt fence on south-side of project. Inspection Report Page 6 of 8

Water Division Photographic Evidence Sheet Location: Baxter Healthcare-Mt. Home Photographer: Cody Wallace Date: June 16, 2015 Time: 1107 Witness: Jason Barnes, Will Gregory, Kurt Parnell Photo #: 5 Description: View of concrete washout station facing north. Cody Wallace Baxter Healthcare-Mt. Photographer: Date: June 16, 2015 Time: Home Witness: Jason Barnes, Will Gregory, Kurt Parnell Photo #: 6 Description: View of detention basin facing north; basin work has not been finalized. Inspection Report Page 7 of 8

Figure 1. General area of the Baxter Healthcare Expansion Project (Google Earth, imagery date: May 4, 2014). Inspection Report Page 8 of 8