DSHW-2018-004341 - 0901a0688081dade

DSHW-20181-004341 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. [phone]
www.deq.utah.gov Printed on 100% recycled paper
State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director
June 13, 2018 Russell Sorensen
Disposal Facilities Manager R.N. Industries (RNI) P. O. Box 1168 Vernal, Utah 84078
RE: Permit Application RNI Bluebell Class IIIb Exploration and Production Waste Landfill (Bluebell Landfill) Dear Mr. Sorensen:
The Division of Waste Management and Radiation Control has completed a preliminary review of the March 2018 permit application for the Bluebell Class IIIb Exploration and Production Waste Landfill. Review comments are enclosed. Please provide your response to these comments and an undated permit application
at your earliest convenience. The Division will complete its review upon receipt of the information. If you have any questions, please call Doug Taylor at [phone]. Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control STA/DWT/kl
c: Jordan Mathis, Health Officer, Tri-County Health Department
Darrin Brown, Environmental Health Director, Tri-County Health Department Nathan Hall, P.E., District Engineer Chance Massey, President, RNI Jon Peaden, ES, GEOSTRATA
Enclosure: Comments on Blue Bell Class IIIb Exploration and Production Waste Landfill Application

Division of Waste Management and Radiation Control
Comments on Blue Bell Class IIIb Exploration and Production Waste Landfill Application 1. Please provide a new title page for the permit application showing the facility name and owner’s name in the title rather than the consultant’s name, such as:

R N Industries Bluebell Class IIIb Oil and Gas
Exploration and Production Waste Landfill Permit Application

March 27, 2018 2. Part II, 1.1 - Facility General Description, third paragraph. The prevailing wind direction is actually Plate A-4, not A-3. Please correct.

3. Part II, 1.3. – Waste Types. Please provide the anticipated daily volume of waste. 4. Part II, 1.4 - Facility Hours. Please provide language describing the procedures to be followed to ensure that the Bluebell Landfill accepts only exploration and production waste passing the paint
filter test, if the facility is open 365 days, 24 hours a day.
5. Part II – 1.8, Historical Preservation Survey. The letter from the State Historical Preservation Officer (SHPO) mentioned is missing from Appendix G. Please provide a 2018 letter.
Part II, - 3.0, Operational Plan. Please provide engineered stamped plans for Ponds 6 and 7,
from the original build available in the Division of Oil, Gas and Mining files, showing the clay layer and the 60 ml liner. The application should contain a discussion demonstrating that the integrity of the liners in each of these ponds over their life time of the landfill will remain intact to ensure that no leaks have gone unnoticed. The schematic drawings in Appendix B show a 3:1
slope along the shoulder of the pond. It seems this is more like a 4:1 or larger slope. This slope
should be verified in the application Part II, 3.2.3, Waste Disposal. A description should be provided in this section regarding the placement of two to three feet of waste material onto the liner before driving on it with heavy
equipment. A one-foot layer is not sufficient to prevent damage to the liner. A two to three foot
protective layer must be placed on the liner before any waste is disposed. 6. Part III, 1.4 – Wet Lands, Plate A-3. These wetlands should be highlighted on the map to show that they are not within the Bluebell Landfill property. Please add language to Section 1.4 to
clarify that wet lands are not part of the landfill property.
7. Appendix J, not Appendix G, contains the letters to property owners within 1000 feet of the Bluebell Landfill. Please correct. A list of these property owners with their addresses should be included in the application as well.

8. Plate A-7 mentioned in Part III, 1.5 – Land Use Compatibility. This plate does not show
anything discussed in this section. Please provide a list showing the distances for each of the items discussed in this section from the Bluebell Landfill, as well as a map to demonstrate these distances.
9. Part III, 2.2.5 – Ground Water. In the third paragraph, Plate A-7 and A-8 are the cross sections
not Plate A-4. Please correct. 10. Part III, 3.35 - General Training Plan. Please provide a new cover page for the RNI Bluebell Landfill instead of the cover page for the RNI Wonsit Landfill.

11. Appendix A should contain a typical construction diagram of private or public wells found within the area. Please provide a table or list of these wells. 12. Part III, 4.3 Post Closure Contacts. Please provide an address for the contact person at the
facility.
13. Part III, 5.0 Financial Assurance. Please specify the financial mechanism and an amount as if a third party were to provide this service as required by R315-309-2-3 of the Utah Administrative Code for both closure and post-closure care. These costs will be verified by the Division.

14. For Appendix H, Plate H-1, please provide: a) Contractor mobilization/demobilization costs. b) Construction surveying costs (only as-built surveying addressed). c) Topsoil costs (alternatively, verification that on-site soils meet requirements).
d) Storm drainage control costs (run-on, run-off).
e) CQA report costs. 15. For Appendix H, Plate H-2, please provide: a) Security fencing and gates costs.
b) Storm drainage control maintenance costs.
c) Monitoring system maintenance costs. d) Leachate collection system maintenance costs.