DSHW-2024-007576

Wade Hess <[e-mail]>
Permit Attachment Changes
8 messages
Wade Hess <[e-mail]>Thu, Jun 20, 2024 at 11:54 AM
To: Todd Bro <[e-mail]>, Bret Reynolds <[e-mail]>
Hi Todd and Bret,
We've changed some of the language in your permit attachments, but we need to make sure that you approve of those
changes. We've altered the language to more clearly state that the permit will be for Cell #7 only, that the area will be
called an Oil and Gas E&P Waste Landfill (instead of IIIb), and to more accurately define the acceptable waste for Cell #7.
If you're okay with the highlighted text/alterations throughout the attached document, please reply to this email stating that
you acknowledge and approve of the changes. If not, feel free to call/email me to talk through any issues you might have.
Thanks,
Wade
--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Statements made in this email do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control. If you desire a statement of the Division Director's position,
please submit a written request to the Director, including copies of documents relevant to your request.
Permit Attachments, changes highlighted.pdf
7545K
Todd Bro <[e-mail]>Fri, Jun 21, 2024 at 8:38 AM
To: Wade Hess <[e-mail]>
Wade,

I will read your attachments shortly.
To bring you up to date on our DOGM closure we submitted our lab sample analysis
to them earlier this week and are waiting for their response. We believe they will
accept cells #3,4,5,6,9,10,11,12.
7/31/24, 1:50 PM State of Utah Mail - Permit Attachment Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r5240236422111705574&simpl=msg-a:r-557689974944472…1/7
The remaining cells will be as follows:
#8 and #1 will join #7 and will be bonded accordingly under WMRC jurisdiction.
#2 has 8400 ppm DRO so we will continue harvesting 1 ft. of mix soil and test again.

todd

From: Wade Hess <[e-mail]>
Sent: Thursday, June 20, 2024 10:54 AM
To: Todd Bro <[e-mail]>; Bret Reynolds <[e-mail]>
Subject: Permit Aachment Changes

Hi Todd and Bret,

We've changed some of the language in your permit attachments, but we need to make sure that you approve of those
changes. We've altered the language to more clearly state that the permit will be for Cell #7 only, that the area will be
called an Oil and Gas E&P Waste Landfill (instead of IIIb), and to more accurately define the acceptable waste for Cell #7.

If you're okay with the highlighted text/alterations throughout the attached document, please reply to this email stating that
you acknowledge and approve of the changes. If not, feel free to call/email me to talk through any issues you might have.

Thanks,
Wade

--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
7/31/24, 1:50 PM State of Utah Mail - Permit Attachment Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r5240236422111705574&simpl=msg-a:r-557689974944472…2/7
[Quoted text hidden]
Wade Hess <[e-mail]>Fri, Jun 21, 2024 at 10:06 AM
To: Todd Bro <[e-mail]>
Oh, wow! That's a huge reduction in your footprint! Happy to hear you're working some things out with DOGM. Appreciate
the update!
Wade
[Quoted text hidden]
--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
[Quoted text hidden]
Todd Bro <[e-mail]>Mon, Jun 24, 2024 at 2:28 PM
To: Wade Hess <[e-mail]>
Cc: Bret Reynolds <[e-mail]>
Wade,

The changes you highlighted are acceptable to me.
We will also have to include changes to reference the addition of cell #8 and #1 to
the permit.

Let me know if you require anything else.

todd

From: Wade Hess <[e-mail]>
Sent: Thursday, June 20, 2024 10:54 AM
To: Todd Bro <[e-mail]>; Bret Reynolds <[e-mail]>
Subject: Permit Aachment Changes

Hi Todd and Bret,
[Quoted text hidden]
7/31/24, 1:50 PM State of Utah Mail - Permit Attachment Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r5240236422111705574&simpl=msg-a:r-557689974944472…3/7
Todd Bro <[e-mail]>Mon, Jul 1, 2024 at 3:58 PM
To: Wade Hess <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>
Wade,

I acknowledge and approve of the highlighted changes.

Todd bro, owner

From: Wade Hess <[e-mail]>
Sent: Thursday, June 20, 2024 10:54 AM
To: Todd Bro <[e-mail]>; Bret Reynolds <[e-mail]>
Subject: Permit Aachment Changes

Hi Todd and Bret,

We've changed some of the language in your permit attachments, but we need to make sure that you approve of those
changes. We've altered the language to more clearly state that the permit will be for Cell #7 only, that the area will be
called an Oil and Gas E&P Waste Landfill (instead of IIIb), and to more accurately define the acceptable waste for Cell #7.

If you're okay with the highlighted text/alterations throughout the attached document, please reply to this email stating that
you acknowledge and approve of the changes. If not, feel free to call/email me to talk through any issues you might have.

Thanks,
Wade

--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
7/31/24, 1:50 PM State of Utah Mail - Permit Attachment Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r5240236422111705574&simpl=msg-a:r-557689974944472…4/7
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
[Quoted text hidden]

Todd Bro <[e-mail]>Tue, Jul 2, 2024 at 1:27 PM
To: Wade Hess <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>
Wade,

I withdraw my approval below until I can discuss the issues with my advisors.

Todd bro

From: Todd Bro
Sent: Monday, July 01, 2024 2:59 PM
To: 'Wade Hess' <[e-mail]>
Cc: 'Cahoon, Brad R.' <[e-mail]>
Subject: RE: Permit Aachment Changes

Wade,

I acknowledge and approve of the highlighted changes.

Todd bro, owner

From: Wade Hess <[e-mail]>
Sent: Thursday, June 20, 2024 10:54 AM
7/31/24, 1:50 PM State of Utah Mail - Permit Attachment Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r5240236422111705574&simpl=msg-a:r-557689974944472…5/7
To: Todd Bro <[e-mail]>; Bret Reynolds <[e-mail]>
Subject: Permit Aachment Changes

Hi Todd and Bret,

We've changed some of the language in your permit attachments, but we need to make sure that you approve of those
changes. We've altered the language to more clearly state that the permit will be for Cell #7 only, that the area will be
called an Oil and Gas E&P Waste Landfill (instead of IIIb), and to more accurately define the acceptable waste for Cell #7.

If you're okay with the highlighted text/alterations throughout the attached document, please reply to this email stating that
you acknowledge and approve of the changes. If not, feel free to call/email me to talk through any issues you might have.

Thanks,
Wade

--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Statements made in this email do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control. If you desire a statement of the Division Director's position,
please submit a written request to the Director, including copies of documents relevant to your request.

Wade Hess <[e-mail]>Tue, Jul 2, 2024 at 1:45 PM
To: Todd Bro <[e-mail]>
7/31/24, 1:50 PM State of Utah Mail - Permit Attachment Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r5240236422111705574&simpl=msg-a:r-557689974944472…6/7
Cc: "Cahoon, Brad R." <[e-mail]>
Noted. Please let me know what is decided.
Thanks,
Wade
[Quoted text hidden]
--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
[Quoted text hidden]
Todd Bro <[e-mail]>Mon, Jul 8, 2024 at 2:46 PM
To: Wade Hess <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>
Wade,

I acknowledge and approve of the changes made to the EEI permit application as
represented by the 2 email chains previously discussed.

Todd bro, owner
EEI
[Quoted text hidden]
7/31/24, 1:50 PM State of Utah Mail - Permit Attachment Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r5240236422111705574&simpl=msg-a:r-557689974944472…7/7
Wade Hess <[e-mail]>
Additional Permit Attachment Language Changes
4 messages
Wade Hess <[e-mail]>Mon, Jul 1, 2024 at 10:19 AM
To: Todd Bro <[e-mail]>, Bret Reynolds <[e-mail]>
Hi Todd,
As discussed during our phone call today, I've made a few additional changes to the permit language. One change
removed the term "RCRA-exempt" from the Description of Property section. Additionally, the acceptable wastes described
in the Description of Waste and Plans for Excluding Waste sections now read "Solid wastes from oil and gas field
exploration and production (E and P) and nonhazardous solid waste generated incidental to oil and gas E and P and
related operations will be accepted at the EEI facility as allowed and directed by DWMRC." This reflects the proposed rule
language.
The document highlighting all changes made from the submitted documentation is attached. If you approve of the
changes, please let us know by stating so in a response email.
Thank you!
Wade
--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Statements made in this email do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control. If you desire a statement of the Division Director's position,
please submit a written request to the Director, including copies of documents relevant to your request.
Permit Attachments, changes highlighted 2.pdf
7466K
Wade Hess <[e-mail]>Mon, Jul 1, 2024 at 4:05 PM
To: Todd Bro <[e-mail]>, Bret Reynolds <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>
Hey Todd,
I just got your email approving of highlighted changes, but it was sent as part of the previous email chain. If you could
respond to the changes on this chain, that would be helpful.
Thanks!
Wade
[Quoted text hidden]
7/31/24, 1:48 PM State of Utah Mail - Additional Permit Attachment Language Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-7100634198385322843&simpl=msg-a:r-34635170407357…1/4
Todd Bro <[e-mail]>Mon, Jul 1, 2024 at 5:20 PM
To: Wade Hess <[e-mail]>
Is the highlighted attachment I approved considered by you to be the final final
permit application?
I approve the below changes but prefer that we get to a final final…

todd

From: Wade Hess <[e-mail]>
Sent: Monday, July 01, 2024 3:05 PM
To: Todd Bro <[e-mail]>; Bret Reynolds <[e-mail]>
Cc: Cahoon, Brad R. <[e-mail]>
Subject: Re: Addional Permit Aachment Language Changes

Hey Todd,
I just got your email approving of highlighted changes, but it was sent as part of the previous email chain. If you could
respond to the changes on this chain, that would be helpful.

Thanks!

Wade

On Mon, Jul 1, 2024 at 10:19 AM Wade Hess <[e-mail]> wrote:
Hi Todd,

As discussed during our phone call today, I've made a few additional changes to the permit language. One change
removed the term "RCRA-exempt" from the Description of Property section. Additionally, the acceptable wastes
described in the Description of Waste and Plans for Excluding Waste sections now read "Solid wastes from oil and gas
field exploration and production (E and P) and nonhazardous solid waste generated incidental to oil and gas E and P
and related operations will be accepted at the EEI facility as allowed and directed by DWMRC." This reflects the
proposed rule language.

The document highlighting all changes made from the submitted documentation is attached. If you approve of the
changes, please let us know by stating so in a response email.

Thank you!
Wade
7/31/24, 1:48 PM State of Utah Mail - Additional Permit Attachment Language Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-7100634198385322843&simpl=msg-a:r-34635170407357…2/4
--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Statements made in this email do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control. If you desire a statement of the Division Director's position,
please submit a written request to the Director, including copies of documents relevant to your request.

--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
[Quoted text hidden]
7/31/24, 1:48 PM State of Utah Mail - Additional Permit Attachment Language Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-7100634198385322843&simpl=msg-a:r-34635170407357…3/4
Wade Hess <[e-mail]>Tue, Jul 2, 2024 at 8:59 AM
To: Todd Bro <[e-mail]>
Thanks, Todd! Both for the response and for your patience. This should be the final version.
Wade
[Quoted text hidden]
--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
[Quoted text hidden]
7/31/24, 1:48 PM State of Utah Mail - Additional Permit Attachment Language Changes
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-7100634198385322843&simpl=msg-a:r-34635170407357…4/4
Attachment 1:
Design and Construction
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 Class IIIb Landfill will be located in Cell #7.
The attached plats show the boundaries and legal descriptions of the property. The
attached warranty deeds provides the proof of ownership.
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 Property
The property is 140 +/- acres and is operated for the purpose of disposal of E & P 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. The
landfill cell will be located in Cell #7. 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) and Dump Trucks (2).
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.
1.1 SCHEDULE OF CONSTRUCTION {R315-302-2{2){a))
The 140 =/- acre property has been operated as a bio-remediation land farm since 2011. The
facility is sectioned into 12 10 acre =/- cells plus a 10 acre area for operations, parking, office,
and water tank battery. The proposed landfill will be located in Cell #7.
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.
Phone ( 435)789-5448 *Fax ( 435)789-4485
Email: [e-mail]
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.
At the start of operations, EEi anticipates approximately 70 cubic yards of E & P waste will be
transported to the s ite 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 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, starting with Cell #7.
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 a permitted landfill cell. 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.
Page 12
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.

E&P Waste Cell
Attachment 2:
Operations Plan
CIVCO Engineering, Inc.
Civil Engineering Consultants
PO Box 1758 *1256 W 400 S, Suite 1
Vernal, Utah 84078
Phone ( 435)789-5448 *Fax ( 435)789-4485
Email: [e-mail]
ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH
1.0 Plan of Operation {R315-302-2(2))
1.1 DESCRIPTION OF WASTE
Solid wastes from oil and gas field exploration and production (E and P) and nonhazardous solid
waste generated incidental to oil and gas E and P and related operations will be accepted at the EEI
facility as allowed and 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.
Waste manifests and records detailing any waste profile assessment will be kept on-site.
1.2. DESCRIPTION OF WASTE HANDLING PROCEEDURES {R315-302-2{2)(b))
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
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. When capacity has been
reached, closure of the cell will occur and EEi will submit an application for a major permit
modification to aquire approval to open new cells.
1.3. WASTE FACILITY INSPECTION AND MONITORING (R315-302-2{2)(c)}{R315-302-2{5}{a))
EEi personnel will inspect the proposed facility to avoid operator error and discharges which may
cause or lead to the release of waste to the environment or cause threat to human health. Facility
inspections will be conducted weekly.
1.3.1 Contingency Plan for Fire or Explosion {R315-302-2{2}{d))
In the event of a fire or explosion the EEi manager will contact local emergency authorities to
initiate an emergency response. A list of the local responders is provided, see Figure 2.
1.3.2 Corrective Action for Ground Water Contamination (R315-302-2{2}{e))
No ground water was encountered while doing the bore holes for soil analysis on the site to a depth
of 50 feet so it is highly unlikely that ground water will be contaminated. Under previous permit
requirements ground water monitoring was not required because of the depth of boring without
encountering ground water and the clay layer encountered.
1.3.3 Contingency Plan for Other Releases {R315-302-2{2){f))
EEi's run off/ run on prevention system amounts to 3' to 7' earth berms constructed around each of
the 12 approx. 10-acre cells. The property falls south to north with 3 berms running east to west
every 10 acres. The berms provide maximum protection against run off/ run on. They have been in
place since 2011 and have not failed in that time. The containment system will be routinely
inspected, and corrective action taken if there are any defects in the system. In the event of a
breach of the system, berms will be immediately constructed around the breached area and the
ground in the area will be tested and if found to be contaminated, the soil will be dug up and
brought into the facility and new uncontaminated soil will be hauled in to replace the soil excavated.
1.3.4 Fugitive Dust Control {R315-302-2{2)(g))
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.
Page 14
1.3.5 Plan For Litter Control {R315-302-2{2}(h}}
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.
1.3.6 Maintenance of Installed Equipment Procedure {R315-302-2{2}(i}}
The only installed equipment is the concrete pad where waste is initially unloaded, the holding tank
headworks, and the holding tanks that water is collected in, each of which are currently
permitted by the Division of Oil, Gas, and Mining. Per the employee policy and safety manual,
these items are routinely inspected and if any issues are found corrective action is taken to fix the
issues.
1.3. 7 Plans For Excluding Waste{R315-302-2{2}(j}}
Solid wastes from oil and gas field exploration and production (E and P) and nonhazardous solid
waste generated incidental to oil and gas E and P and related operations will be accepted at the
EEI facility as allowed and 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.
1.3.8 Procedures for Controlling disease Vectors {R315-302-2{2)(k}}
See the employee policy and safety manual.
1.3.9 Alternative Waste Handling Plan {R315-302-2{2)(/JJ
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 Wand 2000 S.
1.3.10 Closure and Post Closure Plan {R315-302-2{2}(m}}
See Closure Plan document.
1.3.11 Cost Estimated and Financial Assurance {R315-302-2{2)(n}}
See Financial Assurance and Closure Cost document.
Page 15
-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
-waste profile assessments and nonhazardous waste manifests provided by haulers.
Page 18
R315-302-2 [2) [bl Addressing high liquid wastes or WET [2 below].
Two different processes must occur upon waste delivery at EEi.
1. DRY Waste delivered in side dumps, dump trailers, and belly dumps is considered dry waste generally with a moisture content
ranging from 5% to 30% and anywhere in between. These inbound loads are dry enough not to leak out of the trailers used for
transport. To determine that the waste is nonhazardous, EEI requires a waste manifest or waste determination paperwork.
When waste reaches the facility, EEI personell first talk to the driver and aquire a waste determination, source location such as
a well lease number, pipeline name, tank battery, generator, and the generator's employee ordering the work. Then the
operator will physically inspect the waste looking for characteristics that support our decision to accept the load. Somewhere
around 99.9%of our inbound waste contains black wax crude oil or drill cuttings.
If satisfied the load is dumped onto the dry unloading area where our operator can test moisture content with a meter to
determine the soil mixing necessary to reduce the moisture content to below 20%. EEi uses soil only to stabilize or absorb
liquids. This calculation is based on the operator's best guess but is checked by the manager after the soil mixing [done by
front end loaders] is complete. Additional soil is often required to reach the 20% threshold and is excavated from any of the 11
other in- active EEi cells [currently cell # 10] When the manager is satisfied the waste material is loaded and delivered to cell
#7 for spreading and compacting. Compacting is done by the haul trucks EEi employees to deliver waste blended with mixing
soil to cell #7.
2.WET waste is delivered in super suckers or vacuum tanks and are estimated at 50% water.
Each super sucker's vacuum tank is 40 bbl - 60 bbl capacity with the allowable fill at 80% [protecting the scrubber]. Therefore,
each average load's water content depending on size of tank and accuracy of the driver is as follows:
Ave. total load on 60 bbl tanks = 50 bbl. [50 bbl X 80%] X 50% water =25 bbls of water
Ave. total load on 40 bbl tanks = 32 bbls l40 bbl X 80%J X 50% water = 16 bbls of water
The drivers write up the receiving tickets and guess at the bll totals, usually inflating the amount. EEi uses delivering drivers
estimate and compiles the totals daily on the attached spreadsheet [2].
Ave. daily estimated water delivered by super sucker and vacuum trailer, based on actual load counts from 9 /20 /23 -
l0/31/23 = 140 Bbl/day. See WMRC daily shipment record [2J ..
Super Suckers are also called hydro excavators and off er a technology that sucks up liquid mixtures of oil field waste including
tank bottom clean outs, pipeline clean outs, drilling rig clean outs, hydrocarbon spills, wet drill cuttings, etc. These loads require
an unloading site designed to separate water from solids and to confine the water in holding ponds until EEi can deliver it to cell
#7. EEi's unloading site is a concrete pad, with 2' sides, designed by engineers to utilize gravity to drain water off the solids
ENVIRONMENTAL ENERGY INNOVATIONS, LLC
E&P LANDFILL PERMIT APPLICATIONS REQUIREMENTS
5/31/2024
R315-303-3[1.1][a][iv]
The above regulation requires E&P Waste permit holders to submit a communication plan detailing how EEI will
inform waste generators of our high liquid waste acceptance criteria and associated potential increased costs.
1. Initial notifications will be emailed to each customer’s payables department with instructions to forward to
all supervisors responsible for high liquid waste disposal.
2.After the initial notifications we will email directly to all supervisors of waste generators and to all hydro-
excavator operators frequenting EEI.
3.EEI personnel interacts with delivering hydro-excavator operators on a daily basis, allowing for
communications required under R315-303-3[1.1][a][iv].
EEi EMPLOYEE POLICY AND SAFETY MANUEL
9/15/2023
FACILITY SAFETY POLICY
EEi policy requires all employees to learn and practice safety first procedures and to encourage their fellow
operators to practice the same. The following addresses those basic safe practices.
OVERVIEW OF WASTE PRODUCTION AND DISPOSAL- E&P waste is generated from virtually all oil and gas
production activity. Regulation of the disposal of that waste is based on numerous Utah regulations which
guide disposal facilities activities under the authority of the DEPARTMENT OF WASTE MANAGEMENT AND
RADIATION CONTROL located in SLC. EEi operates under a E&P Waste landfill permit approved by DWMRC.
FACILITY DESIGN - EEi is located on a clay base that acts like a rubber liner, discouraging water runoff or
seepage into any ground water reservoir. The property falls from south to north and is divided into 12 - ten
acre cells. Each cell is surrounded by earthen berms capable of holding rain water or snow melt in large
amounts resulting in the elimination of water runoff to surrounding properties. One 10 acre cell [#7) is used
for holding all inbound waste until that cell has reached maximum capacity. The other 11 cells provide the
mixing material necessary for blending with inbound waste.
EMERGENCY PROCEEDURES AND EQUIPMENT, HAZARDS ANO SAFETY
FIRE PREVENTION, SPILL PREVENTION, CONTROL AND CONTAINMENT
IN CASE OF FIRE
-drive all equipment away and up wind of the fire if possible.
-Determine if the fire is an oil or grease fire.
-Call Myton and Roosevelt fire departments to report the fire at our LAT LONG location. Report what is
burning, such as oil and/or grease.
-If the fire is near the tank farm or the office trailer you may employ the use of the fire extinguishers.
Training with the extinguishers will be provided. If the fire is on the land fill do not attempt to extinguish
the fire.
SPILL PREVENTION RULES
-Always unload super suckers and vacuum trailers on the concrete pad only, where any waste release can
be contained.
-Bring truck loads of dry mixing soil to aid in soaking up the spill.
1.Solid Waste liquid-Is always delivered for disposal in hydro-excavators, also called super suckers.
These loads are generally 40% to 60%% water carrying sludge, pigging water, tank cleanouts, etc.
2.Drill Cuttings -Includes spent drilling mud, chemicals, and dirt. Drill Cuttings are delivered in both
super suckers, side dumps, and dump trucks.
3.Contaminated Soil -soil mixed with spilled crude oil, sludge, cement, etc.
PROHIBITED WASTE, WASTE SAMPLING, PROCESSING AND TESTING For a list please see our permit.
There are several categories of waste which are prohibited from disposal at an E&P land fill. Among
them are hazardous waste, PCBs, household waste, municipal waste, and commercial waste. Prior to any
waste generator using our disposal services, they will provide a waste profile assessment certifying that
their waste meets the requirements of our permit. All employees are required to be familiar with those
permit requirements.
PLANS FOR EXCLUDING WASTE NOT PERMITTED UNDER CLASS 111b
EEi staff will not allow the unloading of prohibited waste as described above.
In the unlikely event that a waste generator disposes of prohibited waste at EEi the manager will effect
the following:
1.Quarantine the waste in a pile away from all other waste.
2.Take a photo and write a description of waste.
3.Secure the truck ticket and notify senior management.
4.Senior management will contact the waste generator to arrange for pickup.
PROPER HANDLING AND DISPOSAL OF EACH TYPE OF WASTE-
Solid Waste liquid-Super sucker and vacuum tank loads are directed to unload and wash out their
loads onto our concrete pad which is designed to separate water from solids. The water portion of
the load is gravity fed into holding ponds where it will be held pending distribution onto the landfill
via vacuum water truck. The solid portion of the load will dry on the concrete pad and be mixed with
mixing soil to reach a dry consistency capable of compaction. It will then be loaded and spread on
the land fill, ready for compaction. For a more detailed description of our wet waste process see
Drill Cuttings -Are delivered by both super sucker and side dumps with the super sucker loads being
handled as solid waste liquid above. Side dump loads are dumped and mixed with mixing soil and
spread on the land fill for compaction.
Contaminated Soil -Handled the same as drill cuttings in a dry condition.
PROPER RECORD KEEPING OF ACCEPTED WASTE -Please see excel spreadsheet. Due to dusty conditions
at the land fill we have experienced computer problems such that any computer records require
generation and storage at our corporate offices. EEi will make records available for inspection at any time
WMRC requires.
Attachment 3:
Closure and Post-Closure Care
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
Page | 2
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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Attachment 4:
Facility Maps
Sec. 18 Sec. 17
T4S, R2W, U.S.B.&M.
Remainder
Fence Line
16.0'
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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
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