June 11, Ms. Kata Savic Mill Pond Village #1 Preakness Drive Hot Springs, AR Mill Pond Village Inspection (Garland Co) Dear Ms.

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June 11, 2015 Ms. Kata Savic Mill Pond Village #1 Preakness Drive Hot Springs, AR 71913 RE: Mill Pond Village Inspection (Garland Co) AFIN: 26-00208 NPDES Permit No.: AR0041319 Dear Ms. Savick: On May 28, 2015, I performed a Compliance Evaluation 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. A copy of the inspection report is enclosed for your records. Please refer to the Summary of Findings section of the attached inspection report and provide a written response for each violation that was noted. This response should be mailed to the attention of the Water Division Inspection Branch at the address at the bottom of this letter or e- mailed to Water-Inspection-Report@adeq.state.ar.us. 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 documentation (i.e., photos) is due by June 25, 2015. If I can be of any assistance, please contact me at harmont@adeq.state.ar.us or (479) 968-7339 ext. 14. Sincerely, Travis Harmon District 5 Field Inspector Water Division Page 1 of 10

Inspection Report: Mill Pond Village WWTP, AFIN: 26-00208, Permit #: AR0041319 FACILITY INFORMATION NAME: Mill Pond Village WWTP LOCATION: #1 Preakness Drive CITY: Hot Springs, AR 71913 RESPONSIBLE OFFICIAL NAME: / TITLE Kata Savick / Owner COMPANY: Mill Pond Village MAILING ADDRESS: #1 Preakness Dr CITY, STATE, ZIP: Hot Springs AR 71913 PHONE & EXT: / FAX: 501-525-3959 / EMAIL: WATER DIVISION INSPECTION REPORT AFIN: 26-00208 PERMIT #: AR0041319 DATE: 5/28/2015 COUNTY: 26 Garland PDS #: 084597 MEDIA: WN GPS LAT: 34.391826 LONG: -93.115356 LOCATION: General Area FACILITY TYPE: 2 - Industrial FACILITY EVALUATION RATING: 2 - Marginal INSPECTION INFORMATION INSPECTOR ID#: 34689 S - State DATE(S): ENTRY TIME: EXIT TIME: 5/28/2015 10:15 12:00 FAYETTEVILLE SHALE RELATED: N INSPECTION TYPE: Compliance Evaluation PERMIT EFFECTIVE DATE: 1/1/2014 PERMIT EXPIRATION DATE: 12/31/2018 FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/EMAIL/ETC.: Kata Savick (Owner) 501-525-3959 Gordon Yates (Operator) via telephone 501-276-2314. CONTACTED DURING INSPECTION: Yes AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) S PERMIT N FLOW MEASUREMENT N STORMWATER S RECORDS/REPORTS S LABORATORY S FACILITY SITE REVIEW M OPERATION & MAINTENANCE S EFFLUENT/RECEIVING WATER S SELF-MONITORING PROGRAM N SAMPLING N SLUDGE HANDLING/DISPOSAL N PRETREATMENT N OTHER: SUMMARY OF FINDINGS The following items were in violation of Part III.B.1.A of the permit, which requires all systems of treatment be properly operated and maintained: 1. Floating solids have accumulated in the clarifier of the package plant and need removal (see Photo #1). 2. The influent irrigation pipe to the filter beds is detached and needs to be repaired (see Photo #2). 3. Influent is pooling/puddling on the filter bed media surface. Solids and vegetation should be removed to ensure proper drainage through the filter media (see Photos #2 3). 4. A second filter bed is not in operation and needs repaired (see Photo #4). Also, note that solids and vegetation should be removed to ensure proper drainage through the filter media. 5. Chlorine tablets were not visible in the contact chamber at the time of inspection (see Photo #5). You should consider installing a structure to keeps tablets in place and ensure contact with all effluent. GENERAL COMMENTS INSPECTOR S SIGNATURE: Travis Harmon DATE: 6/9/2015 SUPERVISOR S SIGNATURE: Kerri McCabe DATE: 6/10/2015 Inspection Report Page 2 of 10

Inspection Report: Mill Pond Village WWTP, AFIN: 26-00208, Permit #: AR0041319 SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS S M U NA NE DETAILS: 1. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: Y N NA NE 2. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: Y N NA NE 3. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: Y N NA NE 4. ALL DISCHARGES ARE PERMITTED: Y N NA NE SECTION B: RECORDKEEPING AND REPORTING EVALUATION RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT DETAILS: S M U NA NE 1. ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON DMRS: Y N NA NE 2. SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE: S M U NA NE a. DATES AND TIME(S) OF SAMPLING: Y N NA NE b. EXACT LOCATION(S) OF SAMPLING: Y N NA NE c. NAME OF INDIVIDUAL PERFORMING SAMPLING: Y N NA NE d. ANALYTICAL METHODS AND TECHNIQUES: Y N NA NE e. RESULTS OF CALIBRATIONS: Y N NA NE f. RESULTS OF ANALYSES: Y N NA NE g. DATES AND TIMES OF ANALYSES: Y N NA NE h. NAME OF PERSON(S) PERFORMING ANALYSES: Y N NA NE 3. LABORATORY EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS ADEQUATE: S M U NA NE 4. PLANT RECORDS INCLUDE SCHEDULES, DATES OF EQUIPMENT MAINTENANCE AND REPAIR: S M U NA NE 5. EFFLUENT LOADINGS CALCULATED USING DAILY EFFLUENT FLOW AND DAILY ANALYTICAL DATA: Y N NA NE SECTION C: OPERATIONS AND MAINTENANCE TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED S M U NA NE DETAILS: Floating solids need removed from clarifier (package plant), filter bed PVC line detached and needs repair. Pooled water on filter media surface; vegetation established on filter media surface. Second filter bed is not in service and section of pipe is buried in solids. No chlorine tablets visible in contact chamber. 1. TREATMENT UNITS PROPERLY OPERATED: S M U NA NE 2. TREATMENT UNITS PROPERLY MAINTAINED: Please see above. S M U NA NE 3. STANDBY POWER OR OTHER EQUIVALENT PROVIDED: S M U NA NE 4. ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE: S M U NA NE 5. ALL NEEDED TREATMENT UNITS IN SERVICE: S M U NA NE 6. ADEQUATE NUMBER OF QUALIFIED OPERATORS PROVIDED: S M U NA NE 7. SPARE PARTS AND SUPPLIES INVENTORY MAINTAINED: S M U NA NE 8. OPERATION AND MAINTENANCE MANUAL AVAILABLE: Y N NA NE 9. STANDARD OPERATING PROCEDURES AND SCHEDULES ESTABLISHED: Y N NA NE 10. PROCEDURES FOR EMERGENCY TREATMENT CONTROL ESTABLISHED: Y N NA NE 11. HAVE BYPASSES/OVERFLOWS OCCURRED AT THE PLANT OR IN THE COLLECTION SYSTEM IN THE LAST YEAR: Y N NA NE 12. IF SO, HAS THE REGULATORY AGENCY BEEN NOTIFIED: Y N NA NE 13. HAS CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL BYPASSES/OVERFLOWS: Y N NA NE 14. HAVE ANY HYDRAULIC OVERLOADS OCCURRED AT THE TREATMENT PLANT: Y N NA NE 15. IF SO, DID PERMIT VIOLATIONS OCCUR AS A RESULT: Y N NA NE Inspection Report Page 3 of 10

Inspection Report: Mill Pond Village WWTP, AFIN: 26-00208, Permit #: AR0041319 SECTION D: SAMPLING PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. SAMPLES TAKEN AT SITE(S) SPECIFIED IN PERMIT: Y N NA NE 2. LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES: Y N NA NE 3. FLOW PROPORTIONED SAMPLES OBTAINED WHEN REQUIRED BY PERMIT: Y N NA NE 4. SAMPLING AND ANALYSES COMPLETED ON PARAMETERS SPECIFIED IN PERMIT: Y N NA NE 5. SAMPLING AND ANALYSES PERFORMED AT FREQUENCY SPECIFIED IN PERMIT: Y N NA NE 6. SAMPLE COLLECTION PROCEDURES ADEQUATE: Y N NA NE a. SAMPLES REFRIGERATED DURING COMPOSITING: Y N NA NE b. PROPER PRESERVATION TECHNIQUES USED: Y N NA NE c. CONTAINERS AND SAMPLE HOLDING TIMES CONFORM TO 40 CFR 136: Y N NA NE 7. IF MONITORING IS PERFORMED MORE OFTEN THAN REQUIRED ARE RESULTS REPORTED ON THE DMR: Y N NA NE SECTION E: FLOW MEASUREMENT PERMITTEE FLOW MEASUREMENT MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: Operator uses bucket and time to measure flow. 1. PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: TYPE OF DEVICE: Y N NA NE 2. FLOW MEASURED AT EACH OUTFALL AS REQUIRED: Y N NA NE 3. SECONDARY INSTRUMENTS (TOTALIZERS, RECORDERS, ETC.) PROPERLY OPERATED AND MAINTAINED: Y N NA NE 4. CALIBRATION FREQUENCY ADEQUATE: Y N NA NE 5. RECORDS MAINTAINED OF CALIBRATION PROCEDURES: Y N NA NE 6. CALIBRATION CHECKS DONE TO ASSURE CONTINUED COMPLIANCE: Y N NA NE 7. FLOW ENTERING DEVICE WELL DISTRIBUTED ACROSS THE CHANNEL AND FREE OF TURBULENCE: Y N NA NE 8. FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGE OF FLOW RATES: Y N NA NE 9. HEAD MEASURED AT PROPER LOCATION: Y N NA NE SECTION F: LABORATORY PERMITTEE LABORATORY PROCEDURES MEET PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. EPA APPROVED ANALYTICAL PROCEDURES USED (40 CFR 136.3 FOR LIQUIDS, 503.8(B) FOR SLUDGES) : Y N NA NE 2. IF ALTERNATIVE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN OBTAINED: Y N NA NE 3. SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT: Y N NA NE 4. QUALITY CONTROL PROCEDURES ADEQUATE: Y N NA NE 5. DUPLICATE SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 6. SPIKED SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 7. COMMERCIAL LABORATORY USED: Y N NA NE a. LAB NAME: Sorrels Research, Inc. & Arkansas Analytical, Inc. b. LAB ADDRESS: 8010 National Dr, Little Rock, AR 72209 & 11701 I-30 Bldg. 1 Ste 115, Little Rock, AR 72209 c. PARAMETERS PERFORMED: CBOD5, TSS, NH3-N, FCB 8. BIOMONITORING PROCEDURES ADEQUATE: Y N NA NE a. PROPER ORGANISMS USED: Y N NA NE b. PROPER DILUTION SERIES FOLLOWED: Y N NA NE c. PROPER TEST METHODS AND DURATION: Y N NA NE d. RETESTS AND/OR TRE PERFORMED AS REQUIRED: Y N NA NE Inspection Report Page 4 of 10

Inspection Report: Mill Pond Village WWTP, AFIN: 26-00208, Permit #: AR0041319 SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS BASED ON VISUAL OBSERVATIONS ONLY S M U NA NE DETAILS: Viewed at outfall pipe. OUTFALL #: OIL SHEEN GREASE TURBIDITY VISIBLE FOAM FLOATING SOLIDS COLOR OTHER 001 none none none none none clear -- SECTION H: SLUDGE DISPOSAL SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. SLUDGE MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY: S M U NA NE 2. SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503: S M U NA NE 3. FOR LAND APPLIED SLUDGE, TYPE OF LAND APPLIED TO: (E.G., FOREST, AGRICULTURAL, PUBLIC CONTACT SITE): SECTION I: SAMPLING INSPECTION PROCEDURES SAMPLE RESULTS WITHIN PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. SAMPLES OBTAINED THIS INSPECTION: Y N NA NE 2. TYPE OF SAMPLE: GRAB: COMPOSITE: METHOD: FREQUENCY: 3. SAMPLES PRESERVED: Y N NA NE 4. FLOW PROPORTIONED SAMPLES OBTAINED: Y N NA NE 5. SAMPLE OBTAINED FROM FACILITY'S SAMPLING DEVICE: Y N NA NE 6. SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE: Y N NA NE 7. SAMPLE SPLIT WITH PERMITTEE: Y N NA NE 8. CHAIN-OF-CUSTODY PROCEDURES EMPLOYED: Y N NA NE 9. SAMPLES COLLECTED IN ACCORDANCE WITH PERMIT: Y N NA NE SECTION J: STORM WATER POLLUTION PREVENTION PLAN STORM WATER MANAGEMENT MEETS PERMIT REQUIREMENTS S M U NA NE DETAILS: 1. SWPPP UPDATED AS NEEDED: DATE OF LAST UPDATE: Y N NA NE 2. SITE MAP INCLUDING ALL DISCHARGES AND SURFACE WATERS: Y N NA NE 3. POLLUTION PREVENTION TEAM IDENTIFIED: Y N NA NE 4. POLLUTION PREVENTION TEAM PROPERLY TRAINED: Y N NA NE 5. LIST OF POTENTIAL POLLUTANT SOURCES: Y N NA NE 6. LIST OF POTENTIAL SOURCES AND PAST SPILLS AND LEAKS: Y N NA NE 7. ALL NON-STORM WATER DISCHARGES ARE AUTHORIZED: Y N NA NE 8. LIST OF STRUCTURAL BMPS: Y N NA NE 9. LIST OF NON-STRUCTURAL BMPS: Y N NA NE 10. BMPS PROPERLY OPERATED AND MAINTAINED: Y N NA NE 11. INSPECTIONS CONDUCTED AS REQUIRED: Y N NA NE Inspection Report Page 5 of 10

Inspection Report: Mill Pond Village WWTP, AFIN: 26-00208, Permit #: AR0041319 DMR Calculation Check Reporting Period: From 15 1 1 To 15 3 31 Year Month Day Year Month Day Parameter Checked: CBOD5 Loading Concentration Mass Monthly Mo. Avg. - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l Reported Value: 0.826 33 33 Calculated Value: 0.8256 33 33 Permit Value: 1.9 10 15 If calculated value does not equal reported value, explain: Recorded flow of 0.00288 MGD (round to 0.003) x 8.34 lbs. x 33 mg/l = 0.8256 lb/day. Inspection Report Page 6 of 10

Inspection Report: Mill Pond Village WWTP, AFIN: 26-00208, Permit #: AR0041319 DMR Calculation Check Reporting Period: From 15 1 1 To 15 3 31 Year Month Day Year Month Day Parameter Checked: TSS Loading Concentration Mass Monthly Mo. Avg. - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l Reported Value: 0.726 29 29 Calculated Value: 0.7258 29 29 Permit Value: 2.9 15 22.5 If calculated value does not equal reported value, explain: Recorded flow of 0.00288 MGD (round to 0.003) x 8.34 lbs. x 29 mg/l = 0.8256 lb/day. Inspection Report Page 7 of 10

Inspection Report: Mill Pond Village WWTP, AFIN: 26-00208, Permit #: AR0041319 Water Division Photographic Evidence Sheet Location: Mill Pond Village WWTP Photographer: Travis Harmon Date: 5/28/15 Time: 1054 Witness: None Photo #: 1 Description: Floating solids need to be removed from clarifiers of package plant. Photographer: Travis Harmon Date: 5/28/15 Time: 1056 Witness: None Photo #: 2 Description: PVC (influent to filter bed) irrigation pipe is detached and needs repair so that influent is distributed more evenly across filter media surface. Also, note pooled water on filter media surface. Influent should drain more rapidly. Inspection Report Page 8 of 10

Inspection Report: Mill Pond Village WWTP, AFIN: 26-00208, Permit #: AR0041319 Water Division Photographic Evidence Sheet Location: Mill Pond Village WWTP Photographer: Travis Harmon Date: 5/28/15 Time: 1056 Witness: None Photo #: 3 Description: Pooled influent and vegetation on filter bed media surface. Same bed as viewed in Photo #2. Photographer: Travis Harmon Date: 5/28/15 Time: 1102 Witness: None Photo #: 4 Description: Second filter bed is not in operation and not maintained. Solids and vegetation on the media surface. Note section of irrigation pipe is buried in solids along filter bed wall (under the brush). Inspection Report Page 9 of 10

Inspection Report: Mill Pond Village WWTP, AFIN: 26-00208, Permit #: AR0041319 Water Division Photographic Evidence Sheet Location: Mill Pond Village WWTP Photographer: Travis Harmon Date: 5/28/15 Time: 1117 Witness: None Photo #: 5 Description: I did not see any chlorine tablets inside the chlorine contact chamber at the timer of inspection. Inspection Report Page 10 of 10

From: To: Subject: Date: Harmon, Travis McConnell, Melissa FW: millpond village AFIN: 26-00208 NPDES: AR0041319 Wednesday, June 24, 2015 9:56:16 AM Melissa, Below is a compliance plan/extension for Mill Pond Village (ID 17248). Could you attach to the inspection in the tracker? The operator has scheduled repair of the filter beds during the 2 nd week of July. Mr. Yates works for Hot Springs but also operates the Mill Pond Village Treatment Plant. Thanks, Travis From: Gordon Yates [mailto:gyates@cityhs.net] Sent: Wednesday, June 24, 2015 9:45 AM To: Harmon, Travis Subject: millpond village AFIN: 26-00208 NPDES: AR0041319 Good Morning Mr. Harmon I spoke to you earlier today about corrective action to be taken on your inspection for Millpond Village And I anticipate it to be completed by 7/17/15. And I will send photos and email of completion of work On 7/20/15. Thank You Gordon Yates City of Hot Springs Utility Waste Water gyates@cityhs.net (501) 262-1125

From: To: Subject: Date: Harmon, Travis McConnell, Melissa FW: Mill pond Village AFIN: 26-00208 NPDES: AR0041319 violations corrections Monday, July 20, 2015 12:33:17 PM Melissa, Can you attach to ID 17248 when you get a chance. Inspection response for Mill Pond Village. Thanks, Travis From: Gordon Yates [mailto:gyates@cityhs.net] Sent: Monday, July 20, 2015 9:47 AM To: Harmon, Travis Subject: FW: Mill pond Village AFIN: 26-00208 NPDES: AR0041319 violations corrections Good Morning Mr. Harmon I have taken corrective action on the violations that were outlined in your inspection dated 5/28/15. 1. Floating solids were cleaned out and hosed I have a sprayer that I m going to leave on to help. 2. The influent pipe has been installed and is back on line, I generally keep a filter off line while The other one is drying. 3. The pooling problem I is caused by problems with the blower and operational problems, Mrs. Savick hired electrician to install a timer for the blower the quality of the effluent will improve. Also we wasted 1250 gallons sludge out of the plant by Arkansas septic. 4. Vegetation has been removed from filer to help drainage. 5. Chlorine is in the contact chamber and I am working on a structure to hold the chlorine tablets. I have attached photos, if there is anything else I need to do please let me know, I appreciate You bringing this to my attention Thank You Gordon Yates City of Hot Springs Utility Waste Water gyates@cityhs.net (501) 262-1125 From: yates59.gy [mailto:yates59.gy@gmail.com] Sent: Monday, July 20, 2015 8:55 AM To: Gordon Yates

Subject: Sent via the Samsung GALAXY S 5, an AT&T 4G LTE smartphone

August 6, 2015 Ms. Kata Savic Mill Pond Village #1 Preakness Drive Hot Springs, AR 71913 RE: Response to Inspection (Garland Co) AFIN: 26-00208 NPDES Permit No.: AR0041319 Dear Ms. Savick: I have reviewed the response pertaining to my May 28, 2015 inspection of the Mill Pond Village Waste Water Treatment System. The information provided sufficiently addresses the violations referenced in my inspection report. At this time, the Department has no further comment concerning this particular inspection. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. If we need further information concerning this matter, we will contact you. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at (479) 968-7339 ext. 14 or you may e-mail me at harmont@adeq.state.ar.us. Sincerely, Travis Harmon District 5 Field Inspector Water Division