Revised 10/21/2014

December 2, 2015 Ms. Tammy Leeman EHS Compliance Manager MARCK Industries, Inc. P.O. Box 912 Cassville, MO 65625 RE: Quarterly Inspection; AFIN 72-00871 Permit Number 0009-SWRF Dear Ms. Leeman: On November 30, 2015, I conducted a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Regulation 22, and the above-referenced permit. A copy of the inspection report is enclosed for your records. 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 to my attention at the address listed below within thirty (30) days from the date hereof. Failure to submit the written response shall be construed as an admission of any allegations. Any items noted that are neglected and/or persistent may warrant formal enforcement action. If I can be of any further assistance, feel free to contact me at 479-424-0333 or sparrow@adeq.state.ar.us. Sincerely,

Justin Sparrow ADEQ Inspector Solid Waste Management Division Attachment

Document ID 087970

Site Name MARCK Industries, Inc. County Washington AFIN 72-00871

Facility Address 500 West Van Asche Drive Fayetteville, AR 72704

Phone Number 479-872-9098 Permit Number 0009-SWRF

Permittee Address P.O. Box 912 Cassville, MO 65625

E-Mail Address PDS # 087970

Date 11-30-15 Entry Time 1230 Exit Time 1300

Regulation 22 – Operational Standards Category 1

Regulation Item Description Comments 904(n) Periodic reports prepared and filed with ADEQ No annual report has been filed by this facility since 3-19-12.

904(g) Recovery of Solid Waste

904(o) Adequate employee facilities

904(i) Adequate information sign posted at all access points

905 Meets design requirements

907 Maintain recordkeeping requirements

Category 2

Regulation Item Description Comments x 904(p) Operations in accordance with permit documents No approved operating plan on site at the time of this inspection.

905(b) Adequate unloading and loading areas

904(k) Adequate facility maintenance

904(m) Adequate fire protection equipment available at all times

x 904(h) Adequate supervision of facility Facility does not have licensed operator on site as required.

904(e) Adequate storage space for incoming solid waste

904(j) Control of litter, insects, odors, and vectors

Category 3

Regulation Item Description Comments 904(a) Facility accepts only allowable types of waste

904(d) Processing areas adequate

904(f) External storage of solid waste

904 (l) Adequate drainage to sanitary sewers

904(b) Ultimate disposal of waste

Arkansas Department of Environmental Quality

Solid Waste Management Division Transfer Station and Solid Waste Recovery Facility Inspection

Regulation 22 - Records 904(n) Date of annual report Site Conditions Wet

904(p)(10) Maintains contingency plan yes Weather Conditions 1 907(c ) Last quarter’s report waste received

Operator Name & Number

None

Signature of Inspector

Exit Interview Conducted with Bobby Noland Method On Site Date 11-30-15 Time 1230

TS/SWRF Form 7/1/2012 (Revised and Implemented 10-21-14) For ADEQ Use Only

Permit Number 0009-SWRFPhotos 1 & 2

11/30/2015

11/30/2015

M K' RECYCliNG

JAN 0 5 2016

December 31, 2015 ~~\fJ//SWMD Mr. Justin Sparrow ADEQ Inspector, Solid Waste Management Division Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR 72118-5317

RE: Response to Quarterly Inspection; AFIN 72-00871

Dear Mr. Sparrow;

Permit # 0009-SWRF

This letter is the formal written response to the allegations noted on the quarterly inspection report for the above-mentioned solid waste permit.

Regulation 904(n)- No annual report has been filed by this facility since 3-19-12. Marek Industries has only operated this facility since 8-1-2015. We are currently in the process

of closing 4th quarter and will have the total tons collected and processed for this facility for the 3rd and 4th quarters of2015 by the end of January, 2016. Those totals will be sent to ADEQ at that time.

Regulation 904(p)- No approved operating plan on site at the time of this inspection: Marek Industries does have an operating plan for this facility and the permit. It is now posted at

the site and a copy is attached for your records.

Regulation 904(h)- Facility does not have a licensed operator on site as required: Marek Industries has two employees who are certified apprentices with a third scheduled to begin

the certification process in March, 2016. This will assure there is someone at the apprentice level at the facility full time. The apprentices are in the process of moving to the journeyman level in the coming months. We also have an employee who is in the process of having his credentials with the State of Missouri Department of Natural Resources acknowledged by ADEQ, potentially giving us someone with a masters certification by the end of first quarter, 2016.

A hard copy of this letter along with a copy of the operating plan and your report, have been mailed to ADEQ.

Please let me know if you have questions or need additional information from me.

Sincerely,

T~ LeewLart~

Tammy Leeman EHS Compliance Coordinator Marek Industries, Inc.

,A ,cK· RECYCliNG

OPERATING PLAN

The purpose of this operating plan is to detail how MARCK Industries, Inc. will meet or exceed the requirements in the Arkansas Department of Environmental Quality's (ADEQ) Regulation 22, which regulates the permitting of solid waste material recovery facilities. This plan will specify policies and procedures for the operation of the Recycling Facility located at 500 W. Van Asche; Fayetteville, AR. For additional information contact Tammy Leeman, EHS Manager; MARCK Industries, Inc.; PO Box 912; Cassville, MO; 65625. Phone (417) 847-5900 or cell (417) 385-8746.

Schedule of Operations

The Recycling Facility will accept material Monday through Friday from 7:00a.m. to 3:30 p.m. with occasional Saturday operations. The facility will initially have one shift of operation with the ability to expand to two shifts. The Recycling Facility will accept deliveries from third party vehicles.

Personnel Training and Responsibilities

Facility Supervisor:

This person will have or will be working towards earning a Class 1-C license as defined by ADEQ. This person will have a minimum of one year of experience working with refuse handling/collection equipment; the ability to comprehend and comply with established policies and regulations; and the ability to supervise and coordinate the work of assigned personnel. This person will perfonn supervisory work in the administration of the total operation.

Production Team Member:

This person will have or be working towards earning at a minimum a Class 1-A license as defined by ADEQ, if the position this person holds is required to have such a license as specified in the regulations. This person will have the ability to comprehend and comply with established policies and regulations; the ability to take directions and work independently; the ability and knowledge to inspect tools, equipment and the work area daily; the ability to coordinate and guide truck unloading and loading activities and ensure all facility tools and equipment are cleaned at the end of each day.

Record-Keeping Procedures and Requirements

Records will be kept both electronically and manually. The scales operated by MARCK Industries, Inc. will provide a weight for measurement. A manual tracking system using copies of information gathered by weighing each load is used for entry and compilation of data to ensure the records kept are accurate.

Control of Undesirable Wastes

Every load of recyclables will be inspected for undesirable waste that could either contaminate other recyclables or pose an unusual health hazard and risk to employees. An authorized facility employee will visually inspect each load before it is off-loaded. Undesirable wastes include the following: hazardous waste, radioactive materials, explosives and medical wastes. A storage area for undesirable wastes will be designated. Undesirable wastes will be returned to the generator when possible. Other unacceptable wastes will be stored until the material can be identified and disposed of properly. Records will be kept of quantities, types, date of receipt and removal, and destination of the unacceptable wastes.

Equipment

Various powered industrial equipment will be used to ensure all waste is properly loaded into the transport containers/trailers at the facility. Also, the processing equipment outlined in the design narrative will be utilized.

Site Access Control

The Recycling facility will accept deliveries from third party vehicles during normal hours of operation. At the end of each day of operation, all entrances to the facility will be closed and locked.

Safety Hazards and Safety Equipment

Fire is the greatest hazard that will exist at the facility. A strict NO SMOKING policy will be enforced for the facility and the surrounding grounds. Safety equipment that meets or exceeds the required code for this facility will be located throughout the building. The safety equipment at this facility includes: fire extinguishers, an eye wash station and personal protective equipment including but not limited to safety glasses, gloves and hi-viz clothing.

Fire-Fighting Procedures

Upon the discovery of fire of any size, immediate contact will be made to emergency 911. Facility personnel may then attack the fire per the MARCK Industries, Inc. fire-fighting policy with fire extinguishers located throughout the facility. In the event the fire becomes

more than incipient, all personnel will evacuate the building per the MARCK Industries, Inc. emergency evacuation plan.

Contingency Plan

Facility personnel will have training in waste approval to prevent delivery of unapproved waste. Due to the fact that no putrescible waste will be received at this location and only recyclables will be received, the opportunity to receive unapproved waste will be minimal. If unapproved waste should reach the facility, personnel will remove the unapproved waste and follow procedures outlined above in the ((Undesirable Waste" section.

A cleaning schedule will be followed to prevent odors, dust, vectors and other nuisance conditions from developing. The cleaning schedule includes but is not limited to the following: collection and containerization of all materials, mow and groom as required all areas which buffer the facility, clean and maintain all equipment used in the operation of the facility and police the surrounding grounds prior to securing the facility area.

Arkansas Department of Environmental Quality Solid Waste Management Division

Transfer Station and Solid Waste Recovery Facility Inspection

R~g\ll~tioii"2~,;,~:~~coids Site Conditions Weather Conditions

Operator Name & Number None Signature of Inspector ~· Exit Interview Conducted with I Bobby Noland Method On Site Date 11-30-15 1230

TS!SWRF Form 7/112012 (Revised and Implemented 10-21-14) For ADEQ Use Only