Document ID 099030...Alana Wallace Solid Waste Inspector Office of Land Resources Attachment cc: Tammie J. Hynum, Sr. Operations Manager, Office of Land Resources Document ID 099030

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS 72118-5317

TELEPHONE 501-682-0744 / FAX 501-682-0880 / www.adeq.state.ar.us

September 8, 2017 Mr. Alan Spangler City of Fort Smith 5900 Commerce Road Fort Smith, AR 72916 RE: Quarterly Inspection conducted on August 22, 2017 AFIN 66-00226 Permit Number 0267-S1-R1 Dear Mr. Spangler: The Arkansas Department of Environmental Quality Office of Land Resources (ADEQ) conducted a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Act (Arkansas Code, Annotated, § 8-6-201 et seq.), of 1971, as amended, the Arkansas Pollution Control & Ecology Commission Regulation 22 (Solid Waste Management), and the above-referenced permit. The inspection identified conditions at your facility which the ADEQ alleges constitute violations of APC&EC Regulation No. 22. A copy of the inspection report is attached. 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 within thirty (30) calendar days from the date of this letter to the attention of Alana Wallace. Failure to submit the written response shall be construed as an admission of any allegations. Any items noted that are neglected or persistent may warrant formal enforcement action. If I can be of any further assistance, please do not hesitate to contact me at (479) 424-0333 ext. 206 or [email protected]. Sincerely,

Alana Wallace Solid Waste Inspector Office of Land Resources Attachment cc: Tammie J. Hynum, Sr. Operations Manager, Office of Land Resources

Document ID 099030

mailto:[email protected]

Site Name City of Fort Smith County Sebastian AFIN 66-00226 Facility Address 5900 Commerce Drive, Fort Smith Phone Number 479-784-2351 Permit Number 0267-S1-R1 Permittee Address 5900 Commerce Drive, Fort Smith, AR 72901 E-Mail Address PDS # 099030 Date 8/22/2017 Entry Time 0840 Exit Time 1030

Regulation 22 – Operational Standards Category 1 Regulation Item Description Comments 411(l) Adequate employee facilities

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

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

Arkansas Department of Environmental Quality

Office of Land Resources - Solid Waste Management Class 1 Landfill Inspection

Category 2 (continued) Regulation Item Description Comments

427 Surface Water Controls

411(h)(1) Contouring prevents surface water flowing into or through waste

418(a)(b) Run-on/off control system present and adequate

411(h)(2) Surface water control prevents off-site sediment accumulation

411(i);427(f) Adequate maintenance of intermediate/final cover vegetation

415 Gas monitoring program

X 411(o) Leachate leaks or evidence of leachate seepage Leachate seep noted on western slope of Area 2. See photos 13-14.

426 Survey controls

X 429 Leachate collection system Leachate pumps reading at 24.2 and 28.4 with no alarms. See photos 16-18.

420 Liquid Restrictions

Category 3

Regulation Item Description Comments 412 Implementation of hazardous/unauthorized waste exclusion plan

413(a)(b) Satisfactory daily/alternative cover

413(c) Satisfactory intermediate cover

416(b),411(f)(4) Open burning prohibited

419 Cause discharge/leachate discharge leaving landfill

411(f)(3),419(a)(4) Depositing waste in standing water prohibited

X 411(o) Erosion or other cover defects resulting in exposed refuse Erosion and cover defects noted on southern and western perimeter of Area 1. See photos 6, 8, 9, 10.

309(c) Overfill/Off lined area

Regulation 22 - Records 421(a)(8), 1203(k) Date of last groundwater monitoring report 5/24/2017 Site Conditions Dry

423(b) Date of last engineering report 3/27/2017 Weather Conditions Sunny, hot 428 Liner construction in progress Yes/No No Notice of liner construction Yes/No NA Third party CQA on-site during construction Yes/No NA

412(a) Date of last random inspection for unauthorized waste 8/22/2017 Total # for month 38 415, 421(e) Date of last quarterly methane monitoring 7/11/2017 Detection level 0.0, 14.0 415(a) Explosive gas records current? Yes/No Yes

421(g),412(a)(2),701 Date of last special waste received 7/17/2017 Disposal location 35.298500, -94.358333 Tank Sludge 421(d) Previous quarter waste received 61,798 Tons 427(c) Surface water DMR records current? Yes/No Yes

Fayetteville Shale Related Yes/No No Out of Compliance with Fayetteville Shale Yes/No No

Operator Name & Number

Alan Spangler - 002694

Signature of Inspector

Exit Interview Conducted with Alan Spangler Method Phone Date 8/22/2017 Time 1030 Class 1Form 7/1/2012 (Revised and Implemented 10/21/2014) For ADEQ Use Only

Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet

Revised 3/1/2017 Inspector Signature:

Location Fort Smith Class 1 Permit 0267-S1-R1 AFIN 66-00226

Photographer Alana Wallace Witness None

Photo # 1 Of 18 Date 8/22/2017 Time 0902 Description View of active Area 2; facing north.



Photo # 2 Of 18 Date 8/22/2017 Time 0902 Description View of active Area 2; facing northeast.





Photo # 3 Of 18 Date 8/22/2017 Time 0903 Description Overview of working face; facing southeast.



Photo # 4 Of 18 Date 8/22/2017 Time 0905 Description Close up of working face; facing east.





Photo # 5 Of 18 Date 8/22/2017 Time 0909 Description South side of working face; facing north.



Photo # 6 Of 18 Date 8/22/2017 Time 0914 Description Erosion on southern perimeter of Area 1; facing east.





Photo # 7 Of 18 Date 8/22/2017 Time 0917 Description Permanent litter fences in Area 1; facing west.



Photo # 8 Of 18 Date 8/22/2017 Time 0918 Description Protruding waste and erosion on southwest corner of Area 1; facing west.





Photo # 9 Of 18 Date 8/22/2017 Time 0920 Description Standing water on west perimeter of Area 1; facing north.



Photo # 10 Of 18 Date 8/22/2017 Time 0921 Description Protruding waste on west side of Area 1; facing east.





Photo # 11 Of 18 Date 8/22/2017 Time 0924 Description Methane bubbling through puddle on west side of Area 2.



Photo # 12 Of 18 Date 8/22/2017 Time 0925 Description View of gas well near puddle; facing south.





Photo # 13 Of 18 Date 8/22/2017 Time 0927 Description Leachate seepage western slope of Area 2; facing west.



Photo # 14 Of 18 Date 8/22/2017 Time 0929 Description Alternate view of leachate.





Photo # 15 Of 18 Date 8/22/2017 Time 0933 Description Gas well installation in Area 2; facing east.



Photo # 16 Of 18 Date 8/22/2017 Time 0946 Description Leachate pump; 35.300087°, -94.361072°. Reading at 24.2





Photo # 17 Of 18 Date 8/22/2017 Time 0947 Description Leachate pump; 35.300538°, -94.360115°



Photo # 18 Of 18 Date 8/22/2017 Time 0947 Description Close up of pump; reading at 28.4.

September 14, 2017

Mrs. Alana Wallace Arkansas Department of Environmental Quality Office of Land Resources 5301 Northshore Drive North Little Rock, AR 72118-5317

SEP 1 8 2017

DOC 10#: 1 '2. 5'11 TO: ttkS Ell-fl L "-Mfz

RE: Quarterly Inspection, Document ID 099030 Fort Smith Landfill Permit #0267-S1-Rl

Dear Mrs. Wallace:

In response to the August 22, 2017 Quarterly Inspection the Fort Smith Landfill proposes the following remedy to the allegations noted:

• Category 2 Regulation 411 ( o) Leachate Seep: The Fort Smith Landfill will be excavating the leachate seep to investigate what is causing the leak. The area will be repacked with clay and top soil. This task will be completed within the next thirty (30) days.

• Category 2 Regulation 429 Leachate Collection System: The high level alarms for these pumps are set at 34 inches and 46 inches. The elevations for these set levels are on file at the facility. Each number displayed is not the actual head pressure on the liner. Each number represents a certain elevation per sea level. As the transducer for the sump pump sets lower than the bottom liner. Diagrams and calculations are on file at the facility and available for inspection.

• Category 3 Regulation 411 ( o) Erosion or cover defects: The erosion and cover defects were mostly caused by the 6.43 inches of rain received from 08/01 till your arrival on 08/22. The areas noted will be repaired by personnel and intermediate cover will be applied. Downshoot area noted will be completed within the next thirty (30) days.

If you should have any other questions or concerns feel free to contact me any time.

Thank you,

7/:~~~~i~ Landfill Manager City of Fort Smith

ADEQ A R K A N S A S Department of Environmental Quality

September 8, 2017

Mr. Alan Spangler City of Fort Smith 5900 Commerce Road Fort Smith, AR 72916

RE: Quarterly Inspection conducted on August 22, 2017 AFIN 66-00226 Permit Number 0267-S 1-R1

Dear Mr. Spangler:

Document ID 099030

The Arkansas Department of Environmental Quality Office of Land Resources (ADEQ) conducted a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Act (Arkansas Code, Annotated, § 8-6-201 et seq.), of 1971 , as amended, the Arkansas Pollution Control & Ecology Commission Regulation 22 (Solid Waste Management), and the above-referenced permit. The inspection identified conditions at your facility which the ADEQ alleges constitute violations of APC&EC Regulation No. 22. A copy of the inspection report is attached.

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 within thirty (30) calendar days from the date of this letter to the attention of Alana Wallace. Failure to submit the written response shall be construed as an admission of any allegations. Any items noted that are neglected or persistent may warrant formal enforcement action.

If I can be of any further assistance, please do not hesitate to contact me at (479) 424-0333 ext. 206 or [email protected].

Sincerely,

(J)J,u~ Alana Wallace Solid Waste Inspector Office of Land Resources

Attachment

cc: Tammie J. Hynum, Sr. Operations Manager, Office of Land Resources

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

5301 NORTHSHORE DRIVE I NORTH UTILE ROCK I ARKANSAS 72118-5317

TELEPHONE 501-682-0744 I FAX 501-682-0880 I www.adeq.state.ar.us

ADEQ Arkansas Department of Environmental Quality Office of Land Resources- Solid Waste Management

Class 1 Landfill Inspection A R K A N S A S Department of Environmental Quality

Site Name Facility_ Address Permittee Address Date

Regulation 411(1)

421(a)(b)

417

4110)

42I(d)

41l(k)

423(b)

422

421(f)

42I(g),701

Regulation 411(a)

417(c)

411(c)

411(e)

41l(f)(l)

411(p)

411(b)

4II(d)

411(g)

414(a)

.

City of Fort Smith County Sebastian I AFIN 5900 Commerce Drive, Fort Smith Phone Number 4 79-784-2351 I Permit Number 5900 Commerce Drive, Fort Smith, AR 72901 E-Mail Address 8/22/2017 Entry Time 0840 I Exit Time

ll

Regulation 22- Operational Standards ' -'- .... - :::.

Category 1 Item Description Comments

Adequate employee facilities

Record keeping ineets requirements specified by regulations

Access requirements

Adequate provisions for backup equipment

Waste receipt records, ticket system maintained

Telephone system & written emergency response plan on site

Annual compliance inspection by registered professional engineer

Facility implements operating plan and narrative

Leachate disposal/recirculation records

Special waste disposal and procedures records

Category 2 Item Description Comments

Operations in accordance with permit documents

Adequate all weather operational roads

Smallest practical area, unloading supervised, single working face

Salvage operations meet approved conditions

Scavenging of waste prohibited

Proper wet weather repairs

Operations by licensed on-site personnel at all times

Waste spread and compacted as unloaded

Litter control provisions maintained

Disease vectors controlled

66-00226 0267-SI-RI PDS # I 099030 1030

l

I

I

Cate wry 2 (continued)

Regulation Item Descdption Comments 427 Surface Water Controls

411(h)(1) Contouring prevents surface water flowing into or through waste

418(a)(b) Run-on/off control system present and adequate

411(h)(2) Surface water control prevents off-site sediment accumulation

411(i);427(f) Adequate maintenance of intermediate/final cover vegetation

415 Gas monitoring program

X 41l(o) Leachate leaks or evidence of leachate seepage Leachate seep noted on western slope of Area 2. See photos 13-14.

426 Survey controls

X 429 Leachate collection system Leachate pumps reading at 24.2 and 28.4 with no alarms. See photos 16-18.

420 Liquid Restrictions

Category 3

Regulation Item Description Comments 412 Implementation of hazardous/unauthorized waste exclusion plan

413(a)(b) Satisfactory daily/alternative cover

413(c) Satisfactory intermediate cover

416(b ),411(1)(4) Open burning prohibited

419 Cause discharge/leachate discharge leaving landfill

411(1)(3),419(a)(4) Depositing waste in standing water prohibited

X 411(o) Erosion or other cover defects resulting in exposed refuse Erosion and cover defects noted on southern and western perimeter of Area I . See photos 6, 8, 9, I 0.

309(c) Overfill/Off lined area

Regulation 22- Records 42l(a)(8), 1203(k) Date of last groundwater monitoring report 5/24/2017 Site Conditions Dry

423(b) Date of last engineering report 3/27/2017 Weather Conditions Sunny, hot 428 Liner construction in progress 1 Yes/No 1 No Notice of liner construction I Yes/No I NA Third party CQA on-site during construction I Yes/No I NA

412(a) Date of last random inspection for unauthorized waste 8/22/2017 Total # for month 38 415, 42l(e) Date of last quarterly methane monitoring 7/ 11 /2017 Detection level o.o, 14.0 I 4t5(a> I Explosive gas records current? I Ves/No I Yes

421(g),412(a)(2),701 Date of last special waste received 7/17/2017 Disposal location 35.298500, -94.358333 Tank Sludge 42l(d) Previous quarter waste received 6 1,798 Tons 427(c) Surface water DMR records current? Yes/No j Yes

Fayetteville Shale Related Yes/No I No I Out of Compliance with Fayetteville Shale I Yes/No I No

Operator Name & Number Alan Spangler - 002694 Signature of Inspector auuWtu'"' Exit Interview Conducted with Alan Spangler I Method I Phone [ Date 8/22/2017 I Time I 1030

Class I Form 7/1/2012 (Re•·ised aud lmplemeuted 1012112014) For ADEQ Use Only

Documents

Document ID 099030...Alana Wallace Solid Waste Inspector Office of Land Resources Attachment cc: Tammie J. Hynum, Sr. Operations Manager, Office of Land Resources Document ID 099030