DSHW-2024-004135

1

Law Office of Kenneth J. Melrose
310 Gardengate Lane
Lompoc, California 93436
Tel. [phone]
[e-mail]

October 20, 2023

Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
PO Box 144880
Salt Lake City, Utah 84114-4880

cc: Wade Hess
[e-mail]

Sent via Certified Mail and E-Mail

Re: Utah Department of Waste Management and Radiation Control Issuance of
Temporary Waste Storage Permit to Environmental Energy Innovations, LLC

Mr. Hansen,

I represent Integrated Water Management, LLC (“IWM”). It has come to IWM’s
attention that on August 8, 2023, DWMRC issued an approval letter for a temporary storage
permit for Environmental Energy Innovations, LLC (“EEI”). [Attached hereto as Exh. “A”.]
Unfortunately, the temporary storage permit application presented by EEI suffers from a number
of fatal deficiencies, and should never have been approved. IWM calls each of these deficiencies
into question, as detailed below, and hereby requests immediate revocation by DWMRC of the
non-conforming permit. In addition to the below, IWM has contracted with Wasatch
Environmental to audit the EEI temporary permit application for additional non-compliance with
state, local and federal rules and regulations, which will be forthcoming.

1. EEI’s permit application does not indicate the site has a Standard Design liner,
nor has the Director given approval for an Equivalent or Alternative liner.

The approval letter is contingent upon EEI’s compliance with, among other regulations,
R315-314-(2)(2)(a-c), requiring that the waste pile have a conforming liner in place. It is clear
from the permit application that EEI does not have a “Standard Design” liner. It is also clear,
there has been no separate approval by the Director for an “Equivalent” or “Alternative” Design
pursuant to R315-303-3(b) or (c). Additionally, if EEI is relying on either an Equivalent or
Alternative Designs, it must demonstrate comprehensive soil testing to indicate whether the site
is suitable for either, which, again, is absent on the face of the application. Thus, EEI’s waste pile
2
has no conforming liner, nor approved Equivalent or Alternative design, and its temporary
permit approval must be revoked.

2. EEI’s permit application fails to affirm the contents of the waste pile and
whether the waste pile located at the site is greater than 10,000 cubic yards.

As DWMRC knows, R315-314-2(2)(c) requires that any waste pile greater than 10,000
cubic yard shall have either a ground water monitoring system that complies with R315-308, or,
a leachate detection, collection and treatment system. Here, the application, and issued permit,
fail to address definitively whether or not EEI’s waste pile is larger or smaller than the 10,000
cubic yard threshold, which should have mandated denial in the first place, and requires
revocation of the permit. In fact, the application also has failed to characterize the waste in the
pile—DWMRC has no information whatsoever about whether any of the material presently
stored at the site is or is not exempt. As a result, without further testing, the application should
have been denied on its face.

3. EEI’s permit application has failed to adequately characterize the groundwater
at the site.

R315-302-1(e) prohibits any new waste storage facility from being located over an
aquifer, or IB-classed groundwater. EEI’s application does include a groundwater analysis,
however, the samples are limited only to fifty feet. The analysis fails to affirm that the site is not
located at an aquifer, and given that there is no complying liner, the groundwater studies must be
performed to at least 100 feet to rule out the possibility of contaminating any aquifer. In many
cases, DOGM, DWMRC’s predecessor, required applicants to have testing boreholes down to
200 feet to rule out the possibility of aquifer and groundwater contamination. Given that such
studies and affirmations are missing from the application, those deficiencies alone should have
mandated denial. Given that, IWM requests revocation of the permit on this basis alone.

4. Conclusion

In summation, this temporary permit should never have been issued based on the
application presented. Its numerous deficiencies more than mandate immediate revocation of the
permit. IWM hereby formally requests such immediate revocation, which, if not done by
DWMRC by Friday, November 3, 2023, IWM will have no choice but to seek administrative
review and other legal recourse.

Sincerely,
/s/ Kenneth J. Melrose
Kenneth J. Melrose
Attorney for Integrated Water Management, LLC

Exh. “A”

DSHW-2023-206061 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. 711
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director

August 8, 2023

Todd Bro
Environmental Energy Innovations, LLC
P.O. Box 1758
Vernal, UT 84078

RE: Plan of Operations Approval for Cell #7 Waste Pile – Environmental Energy Innovations, LLC
SW349

Dear Mr. Bro:

The Division of Waste Management and Radiation Control (Division) has completed its review of the
submitted Plan of Operations (DSHW-2023-207301) for Cell #7 Waste Pile located in Section 18,
Township 4 South, Range 2 West in Duchesne County in Pleasant Valley, Utah. The plan is hereby
approved.

This approval is contingent on complying with the following conditions and requirements:

1. The facility shall be operated in accordance with the Plan of Operations submitted to the
Division. In addition, the facility shall be operated in compliance with all applicable
requirements of Utah Administrative Code (UAC) R315-302 and R315-314. Any changes to
operations at the facility or the Plan of Operations must be approved prior to implementation.

2. A daily operating record must be maintained for each day of operation in accordance with
UAC R315-302-2 and shall include a description for weight or volume of each incoming load,
and a description of material accepted and processed.

3. Surrounding berms, and any other run-on or run-off prevention system, shall be maintained to
divert the maximum flow from a 25-year storm event.

4. Solid waste disposal fees must be paid by the 15th day of the month following the end of each
quarter in accordance with Utah Code 19-6-119(7).
(Over)

5. An annual report must be submitted in accordance with UAC R315-302-2(4). This annual report
must be submitted to the Director of the Division by March 1st annually for the preceding
calendar year.

6. The length of time that solid waste may be stored the pile shall not exceed 1 year unless the
Director provides approval according to UAC R315-314-2(3).

7. This approval does not grant exemption from complying with applicable Duchesne County,
Tri-County Health Department, or any other local, regional, or federal requirements.

The facility may be periodically inspected by representatives of the Division and the Tri-County Health
Department to determine compliance with the approved Plan of Operations and the applicable
requirements of UAC R315-302 and R315-314.

If you have any questions, please contact Wade Hess by email at [e-mail] or by phone at
385-454-5877.

Sincerely,

Douglas J. Hansen, Director
Division of Waste Management and Radiation Control

DJH/WH/wa

Enclosure: Plan of Operation (DSHW-2023-207301)

c: Kirk Benge, Health Officer, Tri-County Health Department
Darrin Brown, LEHS, Environmental Health Director, Tri-County Health Department
Nathan Hall, District Engineer, UDEQ
Bart Kettle, Deputy Director, UDOGM (Email)
Todd Bro, Owner, Environmental Energy Innovations, LLC (Email and Hard Copy)
CIVCO Engineering, Inc.
Civil Engineering Consultants
PO Box 1758 * 1256 W 400 S, Suite 1
Vernal, Utah 84078

Phone [phone] * Fax [phone]
Email: [e-mail]

ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH

Plan of Operation

Description of Property
The property is 140 +/- acres and is operated for the purpose of disposal of E & P RCRA exempt solid
waste. 130 acres of the site are considered active with 10 acres providing parking, office space and
loading/unloading area. The property is fenced, bermed, and divided into 12 cells, each approximately
10 acres in size. See attached facility layout drawing.
The loading area includes a concrete pad and lined holding ponds that function in separating liquid from
solids arriving on hydro excavators. There are 3 - 400 bbl insulated hot water tanks for dust control and
the occasional cleaning of equipment and concrete surfaces, see attached solid separator drawing for
details.

There is a small office trailer. Small tools are stored in a con-ex located on site. Equipment used on the
site includes Front End Loaders (2), Dump Trucks (2), Backhoe (1), Farm Tractor (1), and miscellaneous
discs, rippers, tillers.

Surface Water
The Bridgeland Quadrangle map shows an intermittent stream located approximately 950 feet
southwest and 528 feet northwest of the project. These stream beds consist of desert shrub vegetation.
There is an irrigation canal 4,488 feet northwest of the project. The streams and canal are at a lower
elevation than the project. See attached water and contour map.

Storm Water
Annual precipitation for the project area is below 10 inches per year. See attached precipitation map.

1.0 OPERATIONS PLAN
1.1 SCHEDULE OF CONSTRUCTION
The 140 =/- acre property has been operated as a bio-remediation land farm since 2011. The
proposed facility is sectioned into 12 10 acre =/- cells plus a 10 acre area for operations, parking,
office, and water tank battery. A 2-to-8-foot berm will surround each cell with slopes no steeper
than 33% to prevent storm water from entering or leaving each cell. Berms are constructed from
existing site soils excavated from the property. A detail of the EEI Facility berm is attached in the
solid separator drawing.

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To the south, adjacent to the facility will be a waste staging area where waste delivered to the site
will be inspected and treated, if necessary, prior to disposal. Waste that requires treatment will be
processed in a waste concrete holding area designed to protect ground water from possible waste
contamination. Drawing details of the waste staging area are attached see the solid separator
drawing.
At the start of operations, EEI anticipates approximately 70 cubic yards of E & P waste will be
transported to the proposed facility per day. EEI is considering using several different products and
processes to stabilize the waste. Some of the products that may be used for mixing and stabilizing
the waste include but are not limited to sawdust, native soils, lime, potash, or remediated soils from
any of the 11 cells currently not in use receiving waste. EEI may also process the waste to remove
liquids by drying the waste in the concrete storage area. Waste acceptance procedures and quality
control of waste being disposed in the facility are outlined in sections 1.2.1 and 1.2.2 of this report.
Each of the 10-acre cells will be filled to closure capacity one cell at a time.
Once the final process is defined adjustments to the design life of the facility will be made. At this
point the life duration of the facility is defined assuming that half of the waste arriving at the facility
will be mixed with remediated soil and the remaining waste will be processed using other
equipment [mixing, drying] and then placed directly into one of the facilities cells. Waste that will
be mixed with additional material will need to reach a moisture content that is workable. In order
to obtain an estimate for the mixing ratio, a preliminary waste assessment was conducted using
samples of anticipated types of waste and remediated soils that will be disposed of in the EEI facility
under this permit application. During this assessment it was determined that the mixing of
remediated soils with waste when needed will be done at a ratio of approximately 1.5:1
respectively, in order to reach a waste moisture content that will be suitable to be spread on the
site. In other words, for every 1 Cu. Yd. of waste there will be approximately 0.5 Cu. Yds. of
remediated soils added to reach a moisture content that is workable.
Based on waste mixing assumptions described above and assuming waste will be accepted 6 days
per week with a 10% growth rate over the life of the facility up to 50,000 cubic yard per year, the
projected life of the facility is approximately 85 years. However, the projected life may increase or
decrease based on the type of processing and/or mixing methods utilized. A copy of the
spreadsheet used to calculate this estimated life is included in the closure plan. All assumptions
presented in the previous paragraphs were used in the spreadsheet calculations.
1.2. DESCRIPTION OF WASTE HANDLING PROCEEDURES
The following sections describe the general procedures that will be followed under this permit
application for accepting, disposing, recording, and excluding waste at EEI.
1.2.1 General Procedures
All waste will be hauled to EEI using commercial or independently owned trucks. All trucks will enter
at the main gate and check in with the EEI facility office. Every truck load of waste will be inspected
for liquids and inappropriate waste prior to disposal. Waste that appears to be stable, free of liquids,
will be directed to the appropriate cell for placement. Waste that is unstable, has excessive liquid

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content, will be placed on the concrete pad for further processing. The concrete pad is designed to
separate liquids from solid waste. The liquids drain off into lined holding ponds. Liquids are then
collected and loaded into a vacuum truck and sprayed onto a dry cell.
After the solid waste has been separated from the liquid waste and mixed with other solid materials,
the solid waste will be removed from the concrete pad and then placed in the appropriate cell using
heavy equipment or a conveyor system. All waste will then be placed in a uniform layer in the
current working cell.
1.2.2 Waste Shipment Records
The EEI facility operation manager will maintain and store waste shipment records as part of the
daily record of disposal activity. Each truck load of inbound waste will have a load ticket completed
by the truck driver and verified by the EEI facility operating staff. An example of the load ticket is
included below. See Figure 1.
Figure 1

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1.2.3 Waste Disposal
Waste deposited in one 10-acre cell will be placed in 1 ft. thick lifts and compacted to reach a firm
and unyielding surface to maximize facility capacity. EEI will distribute inbound waste to the same
10-acre cell until the capacity of that cell has been reached. Closure of the cell will occur at that
time and EEI will direct new waste material to one of the remaining eleven cells.
1.2.4 Plans For Excluding Waste
Non-hazardous industrial waste including E&P waste and RCRA exempt waste will be accepted at
the EEI facility as allowed as directed by DWMRC. To ensure that waste meets this requirement, all
potential waste generators disposing of waste at EEI proposed facility must first complete a waste
profile assessment to determine the acceptability of the waste according to this permit application.
Representative samples of each type of waste will be provided to EEI by all generators for testing.
Generators will provide a waste characterization form certifying that it meets the requirements of
disposal from all sources. Generators will be required to inform EEI when composition changes and
then resubmit a waste characterization form with samples.
1.3. WASTE FACILITY INSPECTION AND MONITORING
EEI personnel will inspect the proposed facility to avoid operator error and discharges which may
cause or lead to the release of wastes to the environment or to a threat to human health. Facility
inspections will be conducted weekly.
1.3.1 Fugitive Dust Control
As part of the daily operations of the proposed facility, fugitive dust will be monitored, and controls
will be put in place as deemed necessary by the Operations Manager. These sources of dust will be
controlled by watering and proper placement of waste in the facility. EEI staff will be trained in
monitoring opacity and checking the facility for dust control issues. When opacity of the dust
exceeds 20%, watering controls will be affected on the facility haul roads, waste cells, and common
areas.
1.3.2 Plan For Litter Control
EEI does not anticipate accepting waste materials that will cause a wind-blown litter problem. EEI
will complete a daily inspection of the facility and the surrounding area to identify a potential litter
problem. EEI does not anticipate waste that would be considered a disease vector.
1.3.3 Contingency Plan for Fire or Explosion
In the event of a fire or explosion the EEI manager will contact local emergency authorities to
initiate emergency response. A list of the local responders is provided, see Figure 2.

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1.3.4 Alternative Waste Handling Plan
In the event of a facility closure due to an emergency or repairs, EEI will make arrangements to have
the waste re-directed to other DWMRC landfills in Duchesne County or the Duchesne County Landfill
located at 20550 W and 2000 S.
1.3.5 General Training Plan
EEI currently has a training program to educate employees on handling waste and operating existing
equipment at the EEI waste facility as required in R315-302-2[2]. This training program consists of;
New hire safety training is completed by our on-staff safety professional. This classroom course
includes safety training provided by OSHA.
The EEI general manager will complete on the job training in the first week of employment to
include;
-facility safety policy
-emergency procedures and equipment
-fire prevention and control
-spill prevention and control
-personal protection equipment
-waste loading and unloading procedures
- chemical hazards
-threat of exposure
-H2S exposure threat and H2S monitor usage
E&P Waste Handling Training
The EEI operations manager will instruct all employees on proper handling of E&P waste based on
current government regulations:
-overview of E&P waste production and disposal
-identification of E&P waste types
-review of regulations
-prohibited waste
-proper handling and disposal of each waste type

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-proper recordkeeping of accepted waste
EEI Facility Operations Specific Training
All employees will receive specific training. Including hands-on training from the general manager,
to include;
-overview of the facility design
-waste identification and characterization
-documentation of accepted waste
-facility hazard and safety
-on-site waste loading, transportation, and unloading
-waste sampling
-waste inspection, processing, and testing
-recordkeeping
Facility inspection and general maintenance
-emergency procedures and contingency plan
-spill prevention and containment
All personnel working at EEI will be required to participate in the following;
-weekly tailgate safety meetings
-semiannual review of the permit
-annual refresher training of the above-mentioned training program
1.4. RECORD KEEPING
The general manager will maintain and store on site records of facility activities as required by R315-
302-2-[3].
1.4.1 Daily Permanent Record
The general manager will record the following data daily and maintain the data in a permanent file;
-waste shipment records as described in section 1.2.2
-estimated weight in tons and volume in cu. yds. of E&P waste received per day

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-estimated weight in tons and volume in cu. yds. of E&P waste requiring treatment prior to
disposal in the facility
-the estimated weight in tons and volume in cu. yds. of material added to treat the waste and
the total weight and volume of treated waste
-number of trucks delivering
-type of E&P waste received
-deviations from the DWMRC approved operations plan
-staff training records
1.4.2 Other Records
The general manager will also include the following data in a permanent record;
-closure and post closure care plans and activities
-cost estimates and financial assurance documentation
-inspections as mentioned in section 1.3 will be recorded and records maintained

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CIVCO Engineering, Inc.
Civil Engineering Consultants
PO Box 1758 * 1256 W 400 S, Suite 1
Vernal, Utah 84078

ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH

Description of Waste

Non-hazardous industrial waste including solid wastes from oil field exploration and production (E
and P) and volatile organic compounds (VOC) related to automotive and industrial operations
related to oil field work and RCRA exempt waste will be accepted at the EEI facility as allowed as
directed by DWMRC. To ensure that waste meets this requirement, all potential waste generators
disposing of waste at EEI proposed facility must first complete a waste profile assessment to
determine the acceptability of the waste according to this permit application.

Phone [phone] * Fax [phone]
Email: [e-mail]
CIVCO Engineering, Inc.
Civil Engineering Consultants
PO Box 1758 * 1256 W 400 S, Suite 1
Vernal, Utah 84078

Phone [phone] * Fax [phone]
Email: [e-mail]

ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH
CLOSURE COSTS
The EEI facility is planned to close in 12 single operations when the waste reaches the final design grade
for each cell. The closure costs for the EEI facility are based on the cost of constructing the final cover.
The final cover construction includes the placement and grading of the 6-inch clay cover, 6-inch topsoil
layer and seeding of topsoil. The cost for the closure tasks is estimated at $275,000. Detailed financial
assurance costs are presented below in table 1. This is the cost of just one cell.

Closure Cost for 1 EEI Facility Cell
Task Description Total Cost Details
Closure Cost Letter of Notification of Closure $2,000 Letter to DWMRC and County
Cover and Topsoil Material $240,000
Seeding/Mulching $8,000
Contingency $25,000
Total Cost $275,000
Table 1 Closure Costs
POST CLOSURE CARE COSTS
Post closure care of inactive sections of the EEI facility will consist of maintaining the integrity of the final
and vegetative covers. Any areas subject to erosion will be corrected and appropriate measures will be
implemented to identify and eliminate the run-on source. No active or technical devices are proposed
for at the EEI facility. Best management practices will be implemented to minimize infiltration and
assure the integrity of the run-on/run-off system. An evaluation of the system will be made during the
quarterly inspections and corrective measures if any will be implemented. All run-on and run-off from
events smaller than the 25-year storm will be controlled through drainage design.
Post closure care costs are estimated by the cost of maintaining the previously described activities for a
30-year period. The estimated cost of the post closure care tasks is approximately $28,500. A detailed
financial assurance cost estimate is provided below in table 2.

Post Cost for 1 EEI Facility Cell
Task Description Unit Cost No. Units in Cell Unit Type Total Cost Total
Units 8
Total Cost
8 years Details
Inspections Quarterly 1st 2 years;
Semiannually for 6 years $25 4 hours $100 20 $500
Report Quarterly 1st 2 years;
Semiannually for 6 years $25 2 hours $50 20 $500
Subtotal for 8
years $1,000
Maintenance Replacing topsoil 1 $24,000 Assumes 10% will need to be replaced
Reseeding 1 $1,000 Assumes 10% will need to be replaced
Subtotal for 8
years $25,000
Contingency $2,500
Total Post
Closure Cost
$28,500

Table 2 Post Closure Care Costs

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FINAL FACILITY CLOSURE CARE COSTS

Upon closure of the entire facility, the parking area, office spaces, and loading and unloading facilities will be
removed and the area graded to provide a natural looking surface. The cost of doing this work is estimated
at $20,000.

CIVCO Engineering, Inc.
Civil Engineering Consultants
PO Box 1758 * 1256 W 400 S, Suite 1
Vernal, Utah 84078

Phone [phone] * Fax [phone]
Email: [e-mail]

ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH

CLOSURE DESIGN PLAN

Introduction
At the end of the life of the Environmental Energy Innovations, LLC (EEI) facility it will be closed
according to R315-302. The following is a brief plan for closure of the facility and each cell and is
subject to amendment if conditions and circumstances justify an amendment.

Closure Procedures

The following procedures will be followed:
1. Notify the Executive Secretary of intent to close 60 days prior receipt of final material.
2. Commence closure procedures within 30 days of receipt of final material. Closure
activities will be completed within 180 days of commencement of closure activities.
3. Within 90 days of completion of closure activities, submit a copy of the closure
plan and certificate that closure has been performed per the closure plan. These
must be stamped and signed by a State of Utah Licensed Professional Engineer.

Closure Schedule
It is anticipated that the proposed EEI facility will be closed, one 10-acre cell at a time, including the
final grading of the waste material and the placement of the final cover. Sixty days prior to the
expected final receipt of waste, EEI will notify the division of their intent to begin closure operations.
EEI will begin the closure operations after the final receipt of waste is obtained. It is anticipated that
each closure operation will take place over an anticipated duration of 90 to 120 days. During this
period, the EEI facility cell will be graded, covered, and surveyed. As-built plans will be generated for
reference for the final inspection by the division.

Design of Final Cover for each 10 Acre Cell
The final cover will consist of two soil layers. The lower layer will consist of a compacted clay soil liner
which will be overlain by an upper layer of soil that will be seeded with native grasses. The construction
of the lower layer portion of the final cover will be an Alternative Design that will achieve equivalent
requirements as the Standard Design as prescribed in R315-303-3(4)(c)(i). The upper layer will follow
the Standard Design requirements as explained in R315-303- 3(4)(a)(ii). Cover soils will be constructed
from existing site soils. All testing and calculations are based on samples of the native soils at the site.
In the alternative final cover design the waste will be covered with a minimum of six inches of clay that

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will have a permeability of at most 1 x 10 -6 cm/sec. The Utah regulation R315-303- 3(4)(c)(i) requires
that the alternative final cover of a soil liner must achieve an equivalent reduction in infiltration as
achieved by the standard design. Standard design calls for at least 18 inches of compacted soil, or
equivalent, with a permeability of 1 x 10 -5 cm/sec or less, or equivalent. The proposed soils used for
the final cover are far less permeable than this requirement. The proposed lower layer will use 6
inches of clay soils that have a permeability of no greater than 1 x 10 -7 cm/s
In addition, R315-303-3(4)(a)(ii) also requires that a second layer of soil is to be used for reducing
erosion consisting of at least 6 inches of soil capable of sustaining vegetative growth placed over the
compacted soil cover and seeded with grass, other shallow rooted vegetation, or other native
vegetation. In our proposed design follows the standard design requirements in that the compacted
clay liner soils will be covered with a second soil layer that will be a minimum of six inches of soil as
prescribed in R315-303-3(4)(a)(ii). This soil layer will be capable of sustaining vegetative growth and
will be seeded with native shallow root vegetation or native vegetation to minimize erosion of the
final cover. These soils may be tested for organic content, permeability and cohesion prior to use as
final cover soil.
The final cover for each cell will be graded to no steeper than a 3:1 slope around the outer perimeter
of the EEI facility cell. The top elevation of each EEI facility cell will be rectangular and will have a slope
of no less than 2%. To control the run-off of storm water and minimize erosion of the final cover
material, it is intended that the final cover soils be seeded with native grasses and use other erosion
controls as needed. The final cover may be reseeded as needed during the post closure phase of the
EEI facility. The final cover plan of each cell is attached.

Capacity of EEI Facility
Based on the assumption of half the waste being mixed with additional material, the estimated capacity
of the (1) EEI facility cell up to the final cover is approximately 343,000 cubic yards of waste plus
mixing material. This calculation also accounts for an estimated dry density of 135 lb./cu-ft for the
mixing material. In total, the EEI facility will store approximately 4,117,000 cubic yards of waste
plus mixing material after all 12 cells are built. An additional 2,058,500 cubic yards of waste can
be accommodated by filling in between the completed cells and building upward after the first
12 cells are filled in.

A table with the projected life at 10 percent growth rate, capped at 50,000 cubic yards of waste plus
mixing material per year, for the EEI facility is provided in Table 1 below. The growth rate is defined as
the number of trucks delivered to the site on an average daily basis. With an increase in the growth rate,
the life of the EEI facility will be reduced.

It will take eight years for the first cell to be completed, and then seven years for each cell thereafter
to be completed. This process will take 85 years to fill in 12 cells. The EEI facility can have its life
expectancy extended 50 years by filling in between these completed cells with waste after the initial
12 are built, as well as building additional cells on top.

Page | 3

Cell

Growth
Waste Delivered
to Site per Day
(cuyd)
Onsite Material
Mixed with Waste
(cuyd)
Total Material to be Spread on Site (cuyd)
Year
Cell
Volume
(cuyd)
Day
(cuyd)
Week
(cuyd)
Year
(cuyd)
Cumulative
(cuyd)
0.1 70.00 35.00 105.00 630.00 33000 33000 1
0.1 77.00 38.50 115.50 693.00 36000 69000 2
0.1 84.70 42.35 127.05 762.30 40000 109000 3
0.1 93.17 46.59 139.76 838.53 44000 153000 4
0.1 102.49 51.24 153.73 922.38 48000 201000 5
0.1 112.74 56.37 169.10 1014.62 50000 251000 6
124.01 62.00 186.01 1116.08 50000 301000 7
#1 136.41 68.21 204.62 1227.69 50000 351000 8 343000
150.05 75.03 225.08 1350.46 50000 401000 9
165.06 82.53 247.58 1485.51 50000 451000 10
181.56 90.78 272.34 1634.06 50000 501000 11
199.72 99.86 299.58 1797.46 50000 551000 12
219.69 109.84 329.53 1977.21 50000 601000 13
241.66 120.83 362.49 2174.93 50000 651000 14
#2 265.82 132.91 398.74 2392.42 50000 701000 15 686000

Table 1: EEI Facility Growth Rate

Final Inspection
After the completion of the final cover, the final inspection of each EEI facility cell will be
conducted by officials from DWMRC. EEI will notify the division of the anticipated date of
completion and plan for scheduling the inspection.

POST CLOSURE CARE

Immediately after the completion of construction for the final cover of a EEI facility cell, the post
closure care plan will be implemented. As required in R315-302-3(5) the post closure care activities will
take place for 30 years or as long as the Director determines is necessary for the facility or unit to
become stabilized and to protect human health and the environment. A licensed engineer with the
state of Utah will direct the post-closure care of the facility and will provide EEI with recommendations
to properly maintain the EEI facility and prevent any release of harmful substances. The engineer will
also provide the division with documentation if he determines that the site is safe to reduce or
discontinue site monitoring prior to the end of the 30-year period.
During the post closure period the following activities will take place:
Site Monitoring: EEI personnel will be on site weekly to monitor activities at the proposed EEI facility
and restrict access to the facility. Access to the proposed EEI facility will be restricted with fencing and
locked gates at the roadway entrance. Signs will be posted advising of the potential dangers
associated with the EEI facility. Only authorized personnel of EEI will have access to the site.
On a quarterly basis the EEI facility cover will be inspected to check for rutting and depressions that
could result in rapid erosion. If rutting or depressions in the cover are identified, they will be repaired
by grading and seeding the surface. Slopes of the final cover will also be inspected and maintained. EEI

Page | 4

will ensure that a 2% slope will be maintained on the top of the cover and a 3:1 slope will be
maintained around the perimeter of the EEI facility.
Run-off water from the final cover will be directed into the existing drainages to the north and west of
the EEI facility. EEI will on a Quarterly basis inspect the run-off collection system and ensure that they
are properly diverting water into the existing storm water drainages. Repairs will be made as needed.

Surface and Ground Water Monitoring: No samples of surface waters will be collected because there
are no observed streams, springs, or other surface waters at the site of the proposed EEI facility.
Ground water will not be sampled as the test holes taken did not encounter groundwater.

Record of Title, Land Use, Zoning
The Duchesne County Recorder will be notified during the closure period of the completion of the
disposal site. The county recorder will be provided with documentation and plats of the location of the
disposal site. Notification of the closure, and location of the EEI facility will also be sent to the county
recorder and zoning changes will be made if necessary. Documentation of the history of the EEI facility
permanently appended to the title of record and land use restrictions will be put in place.

Post Closure Contacts
The point of contact during the post closure care period for this facility is Todd Bro. His contact
information is provided below:
Todd Bro
P.O. Box 1389 Roosevelt Utah 84066
Telephone: [phone]

CIVCO Engineering, Inc.
Civil Engineering Consultants
PO Box 1758 * 1256 W 400 S, Suite 1
Vernal, Utah 84078

ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH

FINANCIAL ASSURANCES
FINANCIAL ASSURANCE
This section of the permit describes compliance with Subsection R315-309, Financial Assurance of
the Administrative Rules for Solid Waste Permitting and Management. Cost estimates consider the
most expensive option during the period and are based on in-house personnel performing closure
and post closure care.
The EEI team complies with financial assurance test requirements for private entities based on
putting cash into a Trust Fund sufficient to meet WMRC’s financial assurance requirements.

Phone [phone] * Fax [phone]
Email: [e-mail]
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CIVCO Engineering, Inc.
Telephone: [phone] Fax: [phone]
1256 W. 400 S. STE. 1, P.O. Box 1758, Vernal, Utah 84078 ####
FINAL COVER PLAN
ENVIRONMENTAL ENERGY INNOVATIONS
####
####
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Located in the NE 1/4 of Section 18, T4S, R2W,
U.S.B.&M.
DUCHESNE COUNTY, UTAH
SITE LAYOUT
ENVIRONMENTAL
ENERGY INNOVATIONS
CIVCO Engineering, Inc.
Civil Engineering Consultants
PO Box 1758 * 1256 W 400 S, Suite 1
Vernal, Utah 84078
Phone [phone] * Fax [phone]
Email: [e-mail]
ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH
Legal Description
The project is located in Pleasant Valley, approximately 3 miles South of US 40, in Section 18,
Township 4 South, Range 2 West. The attached plats show the boundaries and legal
descriptions of the property. The attached warranty deeds provides the proof of ownership.
Sec. 18 Sec. 17
T4S, R2W, U.S.B.&M.
Remainder
Fence Line
16.0'
8.
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25.2'
17.9'
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Located in the NE 1/4 of Section 18,
T4S, R2W, U.S.B.&M.
DUCHESNE COUNTY, UTAH
LOCATION MAP
ENVIRONMENTAL
ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH
PROJECT INFORMATION
Owner/Operator: Environmental Energy Innovations
Engineer:
P.O. Box 1389
Roosevelt, Utah 84066
801-599-7213
CIVCO Engineering, Inc.
1256 W. 400 S. Suite 1
Vernal, Utah 84078
435-789-5448
Farm and Home Tide
Inc.#8573
Tax Id No.
Mail Tax Notice to Grantee at;
POBox 1389
Roosevelt.Utah 84066
QUIT CLAIM DEED
Limited Liability Company
ENVIRONMENTAL ENERGY INNOVATIONS,
LLC,A UTAH LIMITED LIABILITY COMPANY,
Grantor(s)
with its principal office at Roosevelt,Utah 84066
hereby QUIT-CLAIM To:
Recorder's Use Only
Znt AA'dGBl flk A639 Pq £5
Date:a3-FEB-e01S 9:35:00011
Fee:$14.0tj Check
Filed Bys CBM
CAROLYNE MftDSEN,Recorder
DUCHESNE COUNTY CORPORATION
For:FflRii &HOME TITLE
ENVIRONMENTAL ENERGY INNOVATIONS,LLC,a Nevada Limited Liability
Company,
Grantee(s)
of Roosevelt,Utah 84066
For the sum of-—TEN and other good and valuable consideration
the following described tract of land in DUCHESNE County.State of Utah:
DOLLARS,
See Exhibit "A"attached hereto.
The members or designated agents who sign this deed hereby certify that this deed and the
transfer represented thereby is the free ana voluntary act and deed of the limited liability
company,by authority of statute,its articles or organization or its operating agreement,for the
uses and purposes therein mentioned,and on oath state that they are authorized to execute this
instrument.
In witness whereof,the grantor has caused its name to be hereunto affixed by its members or
designated agents this /7 day of February,2012.
Environmental Energy Innovations,LLC,a
Utah Limited Liability Company
Marie L.Murray,Manager
STATE OF UTAH }
ss.
COUNTY OF DUCHESNE }
On the !'Day of February A.D.2012,Personally appeared before me Mark L.
Murray ,known to me to be member(s)or designated agent(s)of the limited liability company
that executed this instrument and acknowledged to the same to be the^ree and voluntary act and
deed of the limited liability company,by authority of statute,its articles of organization or its
operating agreement,for the uses and purposes therein mentioned,and on oath stated that he is
authorized to execute this instrument and in fact executed this instrument on behalf of the limited
liability company.
Residing in:PO^cs
My commission expires:
CX
1 \
Notary Public
WALTBURDETTE
NOTARY PUBLIC •STATE of UTAH
COMMISSION NO.577399
COMM.EXP.01/28/2013
tnt 44£Gai 6k A063S Pg
Exhibit "A"
TOWNSHIP 4 SOUTH,RANGE 2 WEST,UINTAH SPECIAL BASE AND MERIDIAN
SECTION 18:The Southwest Quarter of the Northeast Quarter;The South half of the Northwest
Quarter of the Northeast Quarter.
ALSO:
Beginning at the center Quarter corner of Section 18,Township 4 South,Range 2 West,Uintah
Special Base and Meridian;thence South 0°43'29"East 421.75 feet;thence North 76°14'41"East
1354.43 feet;thence North 0o42'14"West 127.68 feet;thence South 88°46'52 West 1319.63 feet
to the point of beginning.
CIVCO Engineering, Inc.
Civil Engineering Consultants
PO Box 1758 * 1256 W 400 S, Suite 1
Vernal, Utah 84078

Phone [phone] * Fax [phone]
Email: [e-mail]

ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH

Ground Water Analysis
A subsurface investigation was performed on the project site. Below is the resulting analysis of
the well bore samples.

The attached map shows the locations of the drill holes. Each hole was bored to a depth of 50
feet.

Borehole # 1:
0’-10’: light buff colored sandy silt, colluvium.
10’-15’: tan clay.
15’-20’: sandy gravel.
25’-35’: light reddish brown clayey silt, Uinta Formation.
35’-52’: purplish brown silty clay, Uinta Formation.
*No water encountered in BH-1.

Borehole # 2:
0’-10’: light buff silty sand, colluvium.
10’-25’: pale greenish sandy gravel.
25’-35’: grayish sandstone.
35’-50’: greenish gray shale.
*No water encountered in BH-2. Bedrock at 25 feet.

Borehole # 3:
0’-10’: buff colored sandy silt, colluvium.
10’-15’: greenish brown sandy gravel w/ 1mm-3cm sized clasts.
15’-30’: light brown clayey/silty shale.
30’-50’: blue green clayey/silty shale.
*No water encountered in BH-3. Bedrock at 15 feet.

Borehole # 4:
0’-10’: light buff sandy silt, colluvium.
10’-25’: tan sandy gravel w/ 1mm-3cm clasts.
25’-30’: tan siltstone.
30’-40’: blue green silty shale.
40’-50’: blue green clay.
*No water encountered in BH-4. Bedrock at 25 feet.

Page | 2

Borehole # 5:
0’-10’: light buff silty gravel, colluvium.
10’-20’: tan sandy gravel.
20’-30’: grayish brown siltstone.
30’-40’: pale green silty shale.
40’-50’: blue green shale.
*No water encountered in BH-5. Bedrock at 25 feet.

Borehole # 6:
0’-10’: light buff colored silt, colluvium.
10’-20’: whitish tan sandy gravel.
20’-30’: blue green sandy silt.
30’-50’: purplish green shale.
*No water encountered in BH-6. Bedrock at 30 feet.

Borehole # 7:
0” – 8” Lt brn-buff silt and sand with some minor components of clay.
0’ – 10’ Clay with minor amounts of silt and sand.
10’ – 20’ Clay brn-gry.
20’ – 30’ Clay with minor amounts of sand.
30’ – 40’ Clay dk brn-drk gry.
40’ – 50’ Clay drk gry-drk brn with minor amounts of ls pebbles and rock shards.
*No water encountered in BH-7. .

Borehole # 8:
0” – 8” Lt brn-buff silt and sand with some minor components of clay.
0’ – 10’ Clay with minor amounts of buff silt and sand.
10’ – 20’ Clay brn-gry-drk brn.
20 ‘ – 30’ Clay with minor amounts of sand.
30’ – 40’ Clay dk brn-drk gry.
40’ – 50’ Clay drk gry-drk brn with a minor amount of blue shale, very limey.
*No water encountered in BH-8.

Borehole # 9:
0” – 8” Lt brn-buff silt and sand with some minor components of clay.
0’ – 10’ Clay lt brn-brn.
10’ – 20’ Clay brn-gry-drk brn with minor pebbles of drk gry shale.
20’ – 30’ Clay with minor amounts of sand, very fine.
30’ – 40’ Clay drk brn-drk gry.
40’ – 50’ Clay drk gry-drk brn.
*No water encountered in BH-9.

Page | 3

Borehole # 10:
0” – 8” Lt brn-buff silt and sand with some minor components of clay.
0’ – 10’ Clay lt brn-brn.
10’ – 20’ Clay brn-gry-drk brn with minor pebbles of drk gry shale.
20’ – 30’ Clay with minor amounts of sand, very fine.
30’ – 40’ Clay drk brn-drk gry.
40’ – 50’ Clay drk gry-drk brn, minor amount of very fine blue-drk gry shale.
*No water encountered in BH-10.

Borehole # 11:

BH 11 0” – 8” Cobble rock, sand and silt.
0’ - 10’ Clay lt brn-brn, with drk gry shale.
10’ – 20’ Clay brn-gry-drk brn with minor pebbles of drk gry shale.
20’ – 30’ Clay drk brn-drk gry.
30’ – 40’ Clay brn-buff, minor amount of silt.
40’ – 50’ Clay drk gry-drk brn.
*No water encountered in BH-11.

Borehole # 12:
0” – 8” Cobble rock, sand and silt.
0’ - 10’ Clay lt brn-brn, with drk gry shale.
10’ – 20’ Clay buff-drk brn.
20’ – 30’ Clay drk brn-drk gray.
30’ – 40’ Clay brn-buff, minor amounts of small pebbles of shale.
40’ – 50’ Clay drk gry-drk brn.
*No water encountered in BH-12.

The site is underlain by mostly clay materials to a minimum depth of fifty feet. No ground
water was encountered in the holes.
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CIVCO Engineering, Inc.
Telephone: [phone] Fax: [phone]
1256 W. 400 S. STE. 1, P.O. Box 1758, Vernal, Utah 84078 ####
SOIL MAP
ENVIRONMENTAL ENERGY INNOVATIONS
####
####
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CIVCO Engineering, Inc.
Telephone: [phone] Fax: [phone]
1256 W. 400 S. STE. 1, P.O. Box 1758, Vernal, Utah 84078 ####
FACILITY LAYOUT
ENVIRONMENTAL ENERGY INNOVATIONS
####
####
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Telephone: [phone] Fax: [phone]
1256 W. 400 S. STE. 1, P.O. Box 1758, Vernal, Utah 84078
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CIVCO Engineering, Inc.
Telephone: [phone] Fax: [phone]
1256 W. 400 S. STE. 1, P.O. Box 1758, Vernal, Utah 84078 ####
WATER MAP
ENVIRONMENTAL ENERGY INNOVATIONS
####
####
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CIVCO Engineering, Inc.
Telephone: [phone] Fax: [phone]
1256 W. 400 S. STE. 1, P.O. Box 1758, Vernal, Utah 84078 ####
Contours ####
####ENVIRONMENTAL ENERGY INNOVATIONS
PR
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CIVCO Engineering, Inc.
Telephone: [phone] Fax: [phone]
1256 W. 400 S. STE. 1, P.O. Box 1758, Vernal, Utah 84078 ####
PRECIPITATION DATA
ENVIRONMENTAL ENERGY INNOVATIONS
####
####
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CIVCO Engineering, Inc.
Civil Engineering Consultants
PO Box 1758 * 1256 W 400 S, Suite 1
Vernal, Utah 84078

ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH

Surface Water

The Bridgeland Quadrangle map shows an intermittent stream located approximately 950 feet
southwest and 528 feet northwest of the project. These stream beds consist of desert shrub
vegetation. There is an irrigation canal 4,488 feet northwest of the project. The streams and
canal are at a lower elevation than the project. See attached map.

Storm Water
Annual precipitation for the project area is below 10 inches per year. See attached map. A 25-
year 24-hour storm produces 1.61 inches of water with a peak of 1.38 cfs as shown in the
attached report. The berms around the cells are sufficient to contain the water on-site as
shown in the attached calculation.

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PROJECT AREA
0.1 MILES
0.85 MILES
0.18 MILES
INTERMEDIATE
STREAM
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PROJECT
LOCATION
Type II 24-hr Rainfall=1.61"Hydrocad
Printed 6/26/2023Prepared by {enter your company name here}
Page 1HydroCAD® 10.00-26 s/n 04652 © 2020 HydroCAD Software Solutions LLC
Summary for Pond 2P: (new Pond)
Inflow Area = 9.237 ac, 0.00% Impervious, Inflow Depth > 0.22"
Inflow = 1.38 cfs @ 12.33 hrs, Volume= 0.168 af
Outflow = 0.00 cfs @ 5.00 hrs, Volume= 0.000 af, Atten= 100%, Lag= 0.0 min
Routing by Stor-Ind method, Time Span= 5.00-20.00 hrs, dt= 0.05 hrs
Peak Elev= 5,454.73' @ 20.00 hrs Surf.Area= 0.000 ac Storage= 0.168 af
Plug-Flow detention time= (not calculated: initial storage exceeds outflow)
Center-of-Mass det. time= (not calculated: no outflow)
Volume Invert Avail.Storage Storage Description
#1 5,453.90' 0.815 af Custom Stage Data Listed below
Elevation Cum.Store
(feet) (acre-feet)
5,453.90 0.000
5,457.90 0.815
Pond 2P: (new Pond)
Inflow
Hydrograph
Time (hours)
201918171615141312111098765
Fl
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Inflow Area=9.237 ac
Peak Elev=5,454.73'
Storage=0.168 af
1.38 cfs