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DSHW-2024-006707
Attachment 1: Design and Construction 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: civco@civcoengineering.com 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. Cell #7 is a trapezoid-shaped cell located along the southern border of the facility property. The northern border of the cell is nearly parallel to the southern border of the facility. The distance from the northern border to the southern border of the cell ranges from 250 to 290 yards. The eastern border of the cell is 240 yards west of the eastern border of the property. The western border of the cell is 440 yards east of the western border of the property. The distance between the eastern and western borders is 255 yards. Cell 7 Perimeter distances: North side, 275 yards; East side, 247 yards; South side, 290; West side, 288 yards Cell 7 Acreage: 13.9 acres Cell 7 Corner latitudes, longitudes: Northwest 40°08'14'' N 110°08'50''W; Northeast 40°08'17'' N 110°08'40''W; Southeast 40°08'10'' N 110°08'40''W; Southwest 40°08'05'' N 110°08'50''W *All distances, sizes, and locations are approximate 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 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 and cell description. 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: civco@civcoengineering.com 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, Run-on/Run-off Controls 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 and prevent water from entering site, as shown in the attached calculation. 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 o w ( c f s ) 1 0 Inflow Area=9.237 ac Peak Elev=5,454.73' Storage=0.168 af 1.38 cfs 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: civco@civcoengineering.com 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 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 class lllb permit. All employees are required to be familiar with those permit requirements. PLANS FOR EXCLUDING WASTE NOT PERMITTED UNDER E&P LANDFILL 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 (435)789-5448 * Fax (435)789-4485 Email: civco@civcoengineering.com 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 meeting the requirements of R315-303-3(5). The first layer will consist of at least 18 inches of compacted soil, or equivalent, with a permeability of 1 x 10-5 cm/sec or less, or equivalent with surface slopes grades not less than 2% and the side slopes grades not more than 33%. The second layer will consist of at least six inches of soil capable of sustaining vegetative growth and seeded with grass, other shallow rooted vegetation, or other native vegetation. Page | 2 Markers or other benchmarks shall be installed in any final earthen cover to indicate the thickness of the final cover. 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. 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 Page | 3 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. Markers or other benchmarks installed as part of the closure plan will be observed during each quarterly inspection and the earthen cover shall be raised to the appropriate thickness as necessary. Erosion channels deeper than 10% of the total cover thickness shall be repaired as soon as possible following their discovery. 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 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. Page | 4 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: 801-599-7213 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: civco@civcoengineering.com ENVIRONMENT ENERGY INNOVATIONS PLEASANT VALLEY, UTAH CLOSURE COSTS The EEI facility is planned to close each cell as the waste reaches the final design grade. The closure cost for the EEI facility is based on the cost of the placement and grading of 18 inches of compacted soil, or equivalent, with a permeability of 1x10-5 cm/sec or less, or equivalent placed upon the final lifts and a 6-inch topsoil layer and seeding of topsoil. Closure cost estimates were obtained from an independent contractor. Upon closure of all cells the parking area, office spaces, and loading and unloading facilities will be removed and the area graded, topsoil layer added and seeding of topsoil to provide a natural looking surface. The cost of doing this work is estimated at $20,000. The closure cost of cell 7 is $1,055,000 as shown in Table 1. Closure Cost for Cell 7 Task Description Total Cost Details Closure Cost Per Cell Letter of Notification of Closure $2,000 Letter to DWMRC and County Cover and Topsoil Material $1,020,000 Seeding/Mulching $8,000 Contingency $25,000 Total Cost Per Cell $1,055,000 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 $31,000 for cell 7 as shown in Table 2. Post Cost for EEI Facility Page | 2 Task Description Unit Cost Hours per year Unit Type Years Total Units Total Cost 28 years Details Inspections Quarterly 1st 2 years; $ 30 4 hours 2 8 $240 Semiannually for 28 years $ 30 2 hours 28 56 $1,680 Ground Water Testing Not required as investigations have revealed there is no ground water present near the site Report Quarterly 1st 2 years; $30 4 hours 2 8 $240 Semiannually for 28 years $30 2 hours 28 56 $1,680 Subtotal for 30 years $3,840 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 30 years $28,840 Contingency $ 2,900 ( 10%) Post Closure Cost cell 7 $31,740 Table 2 Post Closure Care Costs 2 . 0 0 % 2.0 0 % 2 . 0 0 % 3. 0 : 1 3. 0 : 1 10.0:1 2.0 0 % 3.0:1 3.0:1 1 0 . 0 0 % 1 : 3 . 0 0 1:3 . 0 0 2. 0 0 % 2. 0 0 % CIVCO Engineering, Inc. Telephone: (435) 789-5448 Fax: (435) 789-4485 1256 W. 400 S. STE. 1, P.O. Box 1758, Vernal, Utah 84078 #### FINAL COVER PLAN ENVIRONMENTAL ENERGY INNOVATIONS #### #### VO L U M E : 34 3 , 0 6 8 C U Y D S . SU R F A C E A R E A : B O T T O M - 8 . 5 A C R E S T O P - 3 . 7 A C R E S AC C E S S R O A D AC C E S S R O A D BE R M WA S T E P I L E BE R M 6" C L A Y S O I L 6" T O P S O I L WA S T E P I L E PL A N V I E W CR O S S S E C T I O N W I T H A C C E S S R O A D Attachment 4: Facility Maps Sec. 18 Sec. 17 T4S, R2W, U.S.B.&M. Remainder Fence Line 16.0' 8. 6 ' 25.2' 17.9' CI V C O E n g i n e e r i n g , I n c . Te l e p h o n e : ( 4 3 5 ) 7 8 9 - 5 4 4 8 F a x : ( 4 3 5 ) 7 8 9 - 4 4 8 5 12 5 6 W . 4 0 0 S . S T E . 1 , P . O . B o x 1 7 5 8 , V e r n a l , U t a h 8 4 0 7 8 ## # # LO C A T I O N M A P EN V I R O N M E N T A L E N E R G Y I N N O V A T I O N S ## # # ## # # 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 CI V C O E n g i n e e r i n g , I n c . Te l e p h o n e : ( 4 3 5 ) 7 8 9 - 5 4 4 8 F a x : ( 4 3 5 ) 7 8 9 - 4 4 8 5 12 5 6 W . 4 0 0 S . S T E . 1 , P . O . B o x 1 7 5 8 , V e r n a l , U t a h 8 4 0 7 8 ## # # WA T E R M A P EN V I R O N M E N T A L E N E R G Y I N N O V A T I O N S ## # # ## # # PROJECT AREA 0.1 MILES 0.85 MILES 0.18 MILES INTERMEDIATE STREAM CI V C O E n g i n e e r i n g , I n c . Te l e p h o n e : ( 4 3 5 ) 7 8 9 - 5 4 4 8 F a x : ( 4 3 5 ) 7 8 9 - 4 4 8 5 12 5 6 W . 4 0 0 S . S T E . 1 , P . O . B o x 1 7 5 8 , V e r n a l , U t a h 8 4 0 7 8 ## # # Co n t o u r s ## # # ## # # EN V I R O N M E N T A L E N E R G Y I N N O V A T I O N S PROJECT CI V C O E n g i n e e r i n g , I n c . Te l e p h o n e : ( 4 3 5 ) 7 8 9 - 5 4 4 8 F a x : ( 4 3 5 ) 7 8 9 - 4 4 8 5 12 5 6 W . 4 0 0 S . S T E . 1 , P . O . B o x 1 7 5 8 , V e r n a l , U t a h 8 4 0 7 8 ## # # PR E C I P I T A T I O N D A T A EN V I R O N M E N T A L E N E R G Y I N N O V A T I O N S ## # # ## # # PROJECT LOCATION