March 28, Peggy Matherne, Plant Manager Albemarle Corporation 2226 P.O. Box 729 Magnolia, AR

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1 March 28, 2016 Peggy Matherne, Plant Manager Albemarle Corporation 2226 P.O. Box 729 Magnolia, AR RE: Albemarle Corporation Inspection (Columbia Co) AFIN: State Permit No.: 2189-WR-7 Dear Mrs. Matherne: On March 18 and 21, 2016, I performed a Reconnaissance Inspection of the above-referenced permit for the West Plant disposal pipeline in response to a reported spill 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 April 11, If I can be of any assistance, please contact me at youngm@adeq.state.ar.us or (501) Sincerely, Michael D. Young District 8 Field Inspector Water Division Page 1 of 7

2 Inspection Report: Albemarle Corporation, AFIN: , Permit #: 2189-WR-7 FACILITY INFORMATION NAME: Albemarle Corporation LOCATION: ROW on private land of Colombia 34 CITY: Magnolia, AR RESPONSIBLE OFFICIAL NAME: / TITLE Peggy Matherne / Plant Manager COMPANY: Albemarle Corporation MAILING ADDRESS: 2226 P.O. Box 729 CITY, STATE, ZIP: Magnolia AR PHONE & EXT: / FAX: / WATER DIVISION INSPECTION REPORT AFIN: PERMIT #: 2189-WR-7 DATE: 3/18/2016 COUNTY: 14 Columbia PDS #: MEDIA: WS GPS LAT: LONG: LOCATION: General Area FACILITY TYPE: 2 - Industrial FACILITY EVALUATION RATING: N INSPECTION INFORMATION INSPECTOR ID#: S - State DATE(S): ENTRY TIME: EXIT TIME: 3/18/ :11 10:58 3/21/ :00 11:25 FAYETTEVILLE SHALE RELATED: N INSPECTION TYPE: Reconnaissance PERMIT EFFECTIVE DATE: 1/1/2014 PERMIT EXPIRATION DATE: 12/31/2018 FAYETTEVILLE SHALE VIOLATIONS: N INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/ /ETC.: Steven Stamps/ CONTACTED DURING INSPECTION: No AREA EVALUATIONS (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated) S PERMIT N FLOW MEASUREMENT N STORMWATER N RECORDS/REPORTS N LABORATORY N FACILITY SITE REVIEW U OPERATION & MAINTENANCE N EFFLUENT/RECEIVING WATER S SELF-MONITORING PROGRAM N SAMPLING N SLUDGE HANDLING/DISPOSAL N PRETREATMENT ** OTHER: SUMMARY OF FINDINGS 1.) An unknown event caused a leak in a 10 transite line that caused a release of tail brine and crude oil sludge to the environment. This is a violation of permit condition Part 1. (6.). All paperwork with crude oil sludge removal and disposal needs to be submitted as a response to this violation. GENERAL COMMENTS I received a brine spill report via at 08:44 from Steve Card with Albemarle. The spill report indicated that there was 200 bbl. of tail brine released into the environment during a rain event. I responded to the location at approximately 10:11 and was met by Steven Stamps with Albemarle. Mr. Stamps led me to the area of the pipeline leak. The leak occurred from a collar that joined two sections of transite piping together. There was a large cavity present when I arrived (see Photo 1) with crude oil sludge immediately surrounding the area (see Photos 1 and 3). Mr. Stamps stated that the pipe used to carry the brine have residual crude oil sludge that was released with the tail brine. The area impacted was a pipeline right-ofway and extended ~400 linear feet (see Figure 1). The free tail brine then entered a heavily wooded area. I walked through the wooded area and did not see any channels or streams that would have been impacted by the release. There was some indication that rainwater/tail brine was still present in the wooded area (see Photo 4). I did not observe crude oil sludge in the wooded area. I instructed Mr. Stamps that the remediation of crude oil sludge would require soil removal and the proper disposal including any testing that would generate paperwork that needed to be retained and submitted with a response to the No-Discharge inspection performed on permit 2189-WR-7. Upon leaving, no remediation of crude oil sludge had started. On March 21, 2016 I returned to the location and observed a backhoe removing soil and placing it in a dump truck (see Photos 5-6). I instructed Mr. Stamps to again keep all paperwork with the remediation of the oil sludge and submit it with the response to the 2189-WR-7 inspection. Inspection Report Page 2 of 7

3 INSPECTOR S SIGNATURE: Michael D. Young DATE: 3/22/2016 SUPERVISOR S SIGNATURE: Kerri McCabe DATE: 3/25/2016 Page 3 of 7

4 Inspection Report: Albemarle Corporation, AFIN: , Permit #: 2189-WR-7 Water Division Photographic Evidence Sheet Location: Albemarle ROW for 2189-WR-7 on private property off Colombia 34 Photographer: Michael Young Date: 3/18/2016 Time: 10:19 Witness: Steven Stamps Photo #: 1 Description: Location where 10 transite line leaked and released tail brine and crude oil sludge. Photographer: Michael Young Date: 03/18/2016 Time: 10:22 Witness: Steven Stamps Photo #: 2 Description: Extent of tail brine release. Inspection Report Page 4 of 7

5 Inspection Report: Albemarle Corporation, AFIN: , Permit #: 2189-WR-7 Water Division Photographic Evidence Sheet Location: Albemarle ROW for 2189-WR-7 on private property off Colombia 34 Photographer: Michael Young Date: 03/18/2016 Time: 10:28 Witness: Photo #: 3 Description: Crude oil sludge from release of 2189-WR-7 no discharge pipeline. Photographer: Michael Young Date: 03/18/2016 Time: 10:26 Witness: Photo #: 4 Description: Wooded area with tail brine residuals still on surface. Inspection Report Page 5 of 7

6 Inspection Report: Albemarle Corporation, AFIN: , Permit #: 2189-WR-7 Water Division Photographic Evidence Sheet Location: Albemarle ROW for 2189-WR-7 on private property off Colombia 34 Photographer: Michael Young Date: 03/21/2016 Time: 11:00 Witness: Steven Stamps Photo #: 5 Description: Area that has been remediated for crude oil sludge removal. Photographer: Michael Young Date: 03/21/2016 Time: 11:00 Witness: Steven Stamps Photo #: 6 Description: Area that has been remediated for crude oil sludge removal. Inspection Report Page 6 of 7

7 Inspection Report: Albemarle Corporation, AFIN: , Permit #: 2189-WR-7 Figure 1. Overview of path of tail brine from 2189-WR-7 pipeline. Inspection Report Page 7 of 7

8 From: To: Cc: Subject: Date: Attachments: Young, Michael McConnell, Melissa McCabe, Kerri FW: Albemarle Corporation Inspection Report Follow-up (Columbia Co) WID Tuesday, April 05, :19:20 AM Spill Remediation Report - BIW#29 March 2016.pdf Melissa, Please attach the spill remediation report to WID Thank you! Michael Young District 8 Inspector El Dorado Field Office ADEQ Water Division Cell Phone: youngm@adeq.state.ar.us -----Original Message----From: McCabe, Kerri Sent: Monday, April 04, :39 PM To: Young, Michael Subject: FW: Albemarle Corporation Inspection Report Follow-up (Columbia Co) Michael, FYI. Please forward to Melissa with the WID so she can attach it. Thank you. Kerri McCabe Inspector Supervisor ADEQ Water Division Field Services Branch (office) From: steve.card@albemarle.com [steve.card@albemarle.com] Sent: Monday, April 04, :03 PM To: McCabe, Kerri Cc: Stephen.Stamps@albemarle.com; Peggy.Matherne@Albemarle.com; gary.looney@aogc.state.ar.us; Randall.Whitmore@martinmlp.com Subject: Albemarle Corporation Inspection Report Follow-up (Columbia Co) Attached below is the spill follow-up report as requested:

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26 April 28, 2016 Peggy Matherne, Plant Manager Albemarle Corporation P.O. Box 729 Magnolia, AR RE: Response to Albemarle Inspection (Columbia Co) AFIN: State Permit No.: 2189-WR-7 Dear Ms. Matherne: I have reviewed the response pertaining to my March 18 and 21, 2016 inspection of the South Plant Brine Disposal 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 (501) or you may me at youngm@adeq.state.ar.us. Sincerely, Michael Young District 8 Field Inspector Water Division