January 5, 2010 Ronnie Wood, Manager Western Greene County Water District P.O. Box 44 Walcott, AR 72474 RE: Western Greene County Water District AFIN: N/A NPDES Permit No.: No-Permit Dear Mr. Wood: On November 20, 2009, I performed an inspection of the water treatment facility located on Woods Chapel Rd. ~0.15 Miles east of Hwy. 351 in Paragould, AR, 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 the facility was discharging without a permit and revealed the following violation: There was an apparent discharge of filter backwash from the potable water treatment facility. This is an unpermitted discharge in violation of the Arkansas Water and Air Pollution Control Act - A.C.A. §8-4-217 (b)(1). This facility may be eligible to seek coverage under the Arkansas NPDES General Permit (ARG640000) for Discharges from Water Treatment Plants. You should contact the NPDES Permits Section of this Department at 501-682-0623 to obtain proper permit coverage for this and any other facilities you operate. The above items require your immediate attention. Please submit a written response to these findings to Cindy Garner, Water Division Enforcement Branch Manager, of this Department. 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 is due by January 18, 2010. For additional information you may contact the Enforcement Branch by telephone at 501-682-0639 or by fax at 501-682-0910.

Ronnie Wood, Western Greene County Water District December 31, 2009 Page 2 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

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY NPDES Report Page 2 5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880

www.adeq.state.ar.us

ADEQ Water NPDES Inspection AFIN: N/A Permit #: No-Permit

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY NPDES Report Page 3 5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880

www.adeq.state.ar.us

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C. 20460

NPDES Compliance Inspection Report

Form Approved OMB No. 2040-0003

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 9 1 1 2 0 17 18 R 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

Entry Time/Date 1045 11/20/2009

Permit Effective Date N/A

Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Western Greene County Water District Woods Chapel Rd. ~0.15 Miles east of Hwy. 351 Paragould, AR Greene Co.

Exit Time/Date 1100 11/20/2009

Permit Expiration Date N/A

Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) None

Other Facility Data 35.980513 -90.616413

Contacted

Yes No

Name, Address of Responsible Official/Title/Phone and Fax Number Ronnie Wood/Manager/870-573-6969 Western Greene County Water District P.O. Box 44 Walcott, AR 72474

Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated)

N N N U Sampling Operations & Maintenance Flow Measurement Permit

N N N N Pollution Prevention Sludge Handling/Disposal Self-Monitoring Program Records/Reports

N N N N Facility Site Review Compliance Schedules Pretreatment Multimedia

N N N N Effluent/Receiving Waters Laboratory Storm Water Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) This inspection was conducted in response to a complaint and revealed an apparent discharge of filter backwash from the potable water treatment facility. This is an unpermitted discharge in violation of the Arkansas Water and Air Pollution Control Act - A.C.A. §8-4-217 (b)(1). This facility may be eligible to seek coverage under the Arkansas NPDES General Permit (ARG640000) for Discharges from Water Treatment Plants. A letter requiring a written response has been sent advising them of the violation and requiring them to obtain proper permit coverage.

Name(s) and Signature(s) of Inspector(s) Agency/Office/Telephone/Fax Date AR Dept. of Environmental Quality-Jonesboro (870) 935-7221 ext. 12/(870) 935-4715 (Fax) December 31, 2009 Brent L. Walker

Signature of Reviewer Agency/Office/Phone and Fax Numbers Date

ADEQ Water NPDES Inspection AFIN: N/A Permit #: No-Permit

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY NPDES Report Page 4 5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880

www.adeq.state.ar.us

Water Division NPDES Photographic Evidence Sheet

Location: Western Greene County Water District Photographer: Witness: Brent Walker None Photo # Of 1 4 Date: Time: 11/20/2009 1053 Description: Outfall from treatment facility.

Photographer: Witness: Brent Walker None Photo # Of Date: Time: 2 4 11/20/2009 1054 Description: Outfall from treatment facility to brushy area.

ADEQ Water NPDES Inspection AFIN: N/A Permit #: No-Permit

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY NPDES Report Page 5 5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880

www.adeq.state.ar.us

Water Division NPDES Photographic Evidence Sheet Location: Western Greene County Water District Photographer: Witness: Brent Walker None Photo # Of 3 4 Date: Time: 11/20/2009 1053 Description: Discharge from facility crossing under fence into brushy area.

Photographer: Witness: Brent Walker None Photo # Of Date: Time: 4 4 11/20/2009 1055 Description: Facility overview.

April 26, 2010 Ronnie Wood, Manager Western Greene County Water District P.O. Box 44 Walcott, AR 72474 RE: Response to Inspection Dear Mr. Wood: The Department has received your response to the November 20, 2009, inspection of your facility by our District Field Inspector, Brent Walker. Your letter appears to adequately address the discrepancies identified during the visit. The Department assumes the corrective actions taken will be maintained to ensure consistent compliance with the requirements of the permit. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. The Department will keep the inspection and response on file. If future violations occur that require enforcement action, the Department will consider the inspection and response as required by the Pollution Control and Ecology Commission Regulation No. 7, Civil Penalties. This regulation requires the Department to consider the past history of your site and how expeditiously the violations were addressed in determining any civil penalty that may be necessary for any future violations. 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 501-682-0649 or you may e-mail me at sawyer@adeq.state.ar.us. Sincerely,

Sam Sawyer Enforcement Coordinator Water Division / Enforcement Branch