April 5, 2010 Arkansas Resources Management PO BOX 17877€¦ · PO BOX 17877 North Little Rock, AR 72117 RE: AFIN: 73-01055 Permit No.: 5040-WR-1 Dear Mr. Lackie: On April 2, 2010,

April 5, 2010 Jackie Lackie Arkansas Resources Management PO BOX 17877 North Little Rock, AR 72117 RE: AFIN: 73-01055 Permit No.: 5040-WR-1 Dear Mr. Lackie: On April 2, 2010, Inspector Dennis Benson, Permit Engineer Stuart Bradford and I, performed a routine compliance inspection of the waste treatment and disposal facility, and observed the facility sampling procedures. This inspection was performed in accordance with the provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated thereunder. Though no permit violations were found at this time, the following items were noted:

1. A small bubble under the liner was noted on the east end of the receiving pond. This bubble may disperse when more fluids are placed in this pond.

2. A written Sampling Protocol should be developed for your facility.

3. Low areas in the application fields should be filled and brought to grade.

4. A thicker vegetative cover is needed in a few areas for better stabilization.

5. Another equal sized holding pond was constructed north of the two permitted holding ponds.

6. The permitted oil removal equipment was not observed at the site at the time of this

inspection. The above items require your immediate attention. Please submit a written response to these findings to Cindy Garner, Water Division Enforcement Branch Manager. 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 with all necessary documentations (i.e. photos) is due by April 18, 2010. If I can be of any assistance, please contact me at (501)-682-0659. Sincerely,

Eric M. Fleming Inspection Branch Manager Water Division cc: Water Division Enforcement Branch

Water Division Permits Branch

ADEQ Water Industrial No Discharge AFIN: 73-01055 Permit #: 5040-WR-1

No Discharge Industrial Report Page 2

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

NO DISCHARGE INDUSTRIAL PERMIT INSPECTION FORM

AFIN: 73-01055 Log No.:

Permit No.: 5040-WR-1 Inspection Date: 4/2/10

Media: Water Inspector: E. Fleming

Compliance Status: ■ IN / OUT

1A. Name of Facility: Arkansas Resources Management, Searcy Landfarm

Address: West of HWY 367, and just south of Searcy County: White 2A. Name of On-Site Representative: Jay Carmen, Operations Manager 3A. Name of Responsible Official: Jackie Lackie,

Address: PO BOX 17877, North Little Rock, AR 72117 Telephone: (501) 375-6611

4A. Parent Company: N/A Address: Telephone:

Description of Process (including type of industry, materials produced, and major by- 5A. products):

Storage and land application of water-based drilling fluids.

6A. Any complaints registered against this permitted facility? Yes ■No If yes, give date and description of complaint: 7A. Are there any additions, modifications, or corrections to the facility since the last

inspection? First inspection Yes ■No If yes, explain:



1B. Furnish a simplified flow diagram of the treatment system and include main components,

flow sequence through plant, and calculated or estimated flows. Application fields Holding Ponds Receiving Pond 2B. Nearest Stream: Bayou Des Arc 3B. Does wastewater from this facility cause adverse effect on the waters of the State:

Yes ■No If yes, describe:

4B. Are operating records kept as required by permit? ■ Yes No N/A If no, explain:

5B. Are maintenance records kept as required by permit? Yes No ■N/A If no, explain: Not reviewed

6B. Are Samples routinely taken? ■ Yes No N/A 7B. Does the sampling program meet the requirements of the permit?

■ Yes No N/A If no, explain: 8B. What laboratory does the facility use? Arkansas Analytical

Address: 11701 Interstate 30 # 115 Little Rock, AR 72209-7076 Telephone: 501) 455-3233



1C. Do laboratory procedures and records meet the requirements of the permit?

Yes No ■N/A If no, explain:

2C. Is contaminated runoff a problem? Yes ■No N/A If yes, explain:

3C. Is sludge disposal required? Yes ■No N/A If yes, describe (including final destination): 4C. Is the treatment system being properly operated and maintained as required by permit?

■ Yes No N/A If no, explain

SUMMARY OF FINDINGS/COMMENTS 1. A small bubble under the liner was noted on the east end of the receiving pond. This bubble may disperse when more fluids are placed in this pond. 2. A written Sampling Protocol should be developed for your facility. 3. Low areas in the application fields should be filled and brought to grade. 4. A thicker vegetative cover is needed in a few areas for better stabilization. 5. Another equal sized holding pond was constructed north of the two permitted holding ponds. 6. The permitted oil removal equipment was not observed at the site at the time of this inspection. Inspector Signature: Date of Report: 4/5/10 Signature of Reviewer: Date of Review:





Water Division No Discharge Industrial Photographic Evidence Sheet Location: ARM – Searcy Landfarm Photographer: EMF Witness: DMB Photo # 1 Of 4 Date: 4/2/10 Time: 0937 Description: Small bubble under the liner in the receiving pond.

Photographer: EMF Witness: DMB Photo # 2 Of 4 Date: 4/2/10 Time: 0952 Description: Holding pond #3. Unstabilized, poorly vegetated levee.



Water Division No Discharge Industrial Photographic Evidence Sheet Location: ARM – Searcy Landfarm Photographer: EMF Witness: DMB Photo # 3 Of 4 Date: 4/2/10 Time: 0957 Description: Photo showing the staff gauge in Holding Pond #2

Photographer: EMF Witness: DMB Photo # 4 Of 4 Date: 4/2/10 Time: 1042 Description: Low, wet area observed in area #24.

August 23, 2010 Jackie Lackie Arkansas Resource Management PO Box 17877 North Little Rock, AR 72117 RE: State Permit No.: 5040-WR-1 AFIN: 73-01055 Failure to Respond Dear Mr. Lackie: On April 2, 2010 Eric Fleming, Inspection Branch Manager, Water Division performed a routine compliance inspection of your facility. Mr. Fleming sent you a letter dated April 5, 2010 (copy enclosed) informing you of the results of the inspection and requesting a written response by April 18, 2010. As of the date of this letter, the response has not been received. Please submit the required response to the inspection to the Department by September 7, 2010. Please be advised that a continuing lack of cooperation in this matter will result in formal enforcement action in this matter. Such action would include but would not be limited to the assessment of monetary penalties. 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 [email protected]. Sincerely,

Sam Sawyer Enforcement Coordinator Water Division Enforcement Section

September 20, 2010 Jackie Lackie Arkansas Resource Management P.O. Box 17877 North Little Rock, AR 72117 RE: Permit No.: 5040-WR-1 AFIN: 73-01055 Response to Inspection Dear Mr. Lackie: The Department has received your response to the August 19, 2010 routine compliance inspection of your facility by our District Field Inspector, Dennis Benson. 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 [email protected]. Sincerely,

Sam Sawyer Enforcement Coordinator Water Division Enforcement Branch

Documents

April 5, 2010 Arkansas Resources Management PO BOX 17877€¦ · PO BOX 17877 North Little Rock, AR 72117 RE: AFIN: 73-01055 Permit No.: 5040-WR-1 Dear Mr. Lackie: On April 2, 2010,