DSHW-2024-007926

Wade Hess <[e-mail]>
Cell 7 E&P Landfill Permit Additions
18 messages
Wade Hess <[e-mail]>Tue, Jul 16, 2024 at 5:28 PM
To: Todd Bro <[e-mail]>, Bret Reynolds <[e-mail]>
Todd and Bret,
The Attorney General's Office has reviewed the draft permit, attachments, and application documents, and have brought some additional items to our attention. As
inclusions to your permit application, please submit the following to the Division:
1. A description of Cell #7. Inclusion of the precise length, width, distance from facility perimeter, and (if available) acreage, would be appropriate.
2. A revision of the Final Cover Design. The cover should consist of two feet of soil (with the top six inches being topsoil) OR meet the requirements for the
Alternative Cover Design. The application expresses the intention of an alternative design, but there is no demonstration made to justify the alternative
design. A mathematical model showing that the expected performance of the alternative design meets the performance of the required design must be
included in the application for approval of the alternative design OR the application should be revised to state that two feet of soil will be used as the cover.
3. A revision of Closure/Post-Closure Costs and Financial Assurance, if needed. Currently, the Financial Assurance section of your permit application states
that cost estimates are based on in-house personnel performing closure and post-closure care. R315-309-2(3) states that financial assurance cost
estimates shall be based on a third party performing closure and post-closure care. Additionally, if the final cover design is revised, the associated closure
costs will likely change. Costs and financial assurance should be revised accordingly.
These items can be submitted by emailing them to [e-mail].
I've attached a document with comments and highlights regarding the application submission. Please reach out with comments or questions.
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.
Attornery General Office Comments, EEI Cell 7 E&P Permit.pdf
1597K
Todd Bro <[e-mail]>Wed, Jul 17, 2024 at 4:10 PM
To: Wade Hess <[e-mail]>
A survey of cell #7 has been scheduled. Will that satisfy? I will get back to you on #2 and #3.

todd
[Quoted text hidden]
Wade Hess <[e-mail]>Thu, Jul 18, 2024 at 11:48 AM
To: Todd Bro <[e-mail]>
Hey Todd,
We'll add the survey to the permit later, but for now, approximations of the cell boundaries are needed. The application describes the cells collectively, but does not
describe Cell 7 specifically. I did some quick mapping on Google Earth and here's what I came up with. You can add the description below into the permit
application, or come up with something similar (Everything from the application has to be submitted by the owner/operator, so that's why I can't just add it in
myself).
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
8/21/24, 12:38 PM State of Utah Mail - Cell 7 E&P Landfill Permit Additions
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-1017583536772845800&simpl=msg-a:r-6401310406290…1/10
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
Thanks,
Wade
[Quoted text hidden]
Todd Bro <[e-mail]>Fri, Jul 19, 2024 at 5:16 PM
To: Bret Reynolds <[e-mail]>
Cc: Wade Hess <[e-mail]>
Bret,

.2 Yes, eliminate the alternative. I will contact the dirt contractor who will provide an estimate for 2 additional feet
of soil. Feel free to do the same.
.3 The original financial assurance estimate was based on a 3rd party’s number which EEI could provide. I will go
back to the same contractor for an estimate to provide 2 additional feet of soil.

Wade, is the new soil cap requirement 6” of top soil plus 18” of local soil? No clay required?

Todd bro, owner
EEI
801/599/7213

From: Bret Reynolds <[e-mail]>
Sent: Wednesday, July 17, 2024 6:40 PM
To: Todd Bro <[e-mail]>
Subject: RE: Cell 7 E&P Landfill Permit Additions

Todd
Okay let me know what I need to do.

Stay safe and have a great day, you deserve it!

Bret Reynolds, PE
CIVCO Engineering, Inc.
Office: 435-789-5448
Cell: 435-790-5624

From: Todd Bro <[e-mail]>
Sent: Wednesday, July 17, 2024 4:06 PM
To: Bret Reynolds <[e-mail]>
Subject: RE: Cell 7 E&P Landfill Permit Additions

8/21/24, 12:38 PM State of Utah Mail - Cell 7 E&P Landfill Permit Additions
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-1017583536772845800&simpl=msg-a:r-6401310406290…2/10
Bret,

I have a survey scheduled for cell #7
I’ll think about #2 and #3.

todd

From: Bret Reynolds <[e-mail]>
Sent: Wednesday, July 17, 2024 11:00 AM
To: Todd Bro <[e-mail]>
Cc: Camille Ericksen <[e-mail]>
Subject: RE: Cell 7 E&P Landfill Permit Additions

Todd
Item 1) Do you want me to take on item 1 based on aerial from google or do you want to define the limits? Below is my take on Cell 7 and the perimeter.
Item 2) I would suggest eliminating the alternative. Not sure what mathematical model they would want and probably beyond my understanding and capabilities.
Item 3) this appears to be mainly in your court. Let me know if you need me to revise anything.
8/21/24, 12:38 PM State of Utah Mail - Cell 7 E&P Landfill Permit Additions
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-1017583536772845800&simpl=msg-a:r-6401310406290…3/10
Thanks for all you do. Have a great day, you deserve it.

Bret Reynolds, PE
CIVCO Engineering, Inc.
Mobile: [phone]
Office: 435-789-5448
1256 W 400 N
Suite 1
PO Box 1758
Vernal Utah 84078

8/21/24, 12:38 PM State of Utah Mail - Cell 7 E&P Landfill Permit Additions
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-1017583536772845800&simpl=msg-a:r-6401310406290…4/10
From: Wade Hess <[e-mail]>
Sent: Tuesday, July 16, 2024 5:28 PM
To: Todd Bro <[e-mail]>; Bret Reynolds <[e-mail]>
Subject: Cell 7 E&P Landfill Permit Additions

Todd and Bret,

The Attorney General's Office has reviewed the draft permit, attachments, and application documents, and have brought some additional items to our attention. As
inclusions to your permit application, please submit the following to the Division:
1. A description of Cell #7. Inclusion of the precise length, width, distance from facility perimeter, and (if available) acreage, would be appropriate.
2. A revision of the Final Cover Design. The cover should consist of two feet of soil (with the top six inches being topsoil) OR meet the requirements for the
Alternative Cover Design. The application expresses the intention of an alternative design, but there is no demonstration made to justify the alternative
design. A mathematical model showing that the expected performance of the alternative design meets the performance of the required design must be
included in the application for approval of the alternative design OR the application should be revised to state that two feet of soil will be used as the cover.
3. A revision of Closure/Post-Closure Costs and Financial Assurance, if needed. Currently, the Financial Assurance section of your permit application states that
cost estimates are based on in-house personnel performing closure and post-closure care. R315-309-2(3) states that financial assurance cost estimates shall
be based on a third party performing closure and post-closure care. Additionally, if the final cover design is revised, the associated closure costs will likely
change. Costs and financial assurance should be revised accordingly.
These items can be submitted by emailing them to [e-mail].

I've attached a document with comments and highlights regarding the application submission. Please reach out with comments or questions.
Thank you,

Wade

--
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 22, 2024 at 11:25 AM
To: Wade Hess <[e-mail]>, Bret Reynolds <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>
Wade,

Item #2 requires some guidance from WMRC.
1. What are the requirements of the alternative cover design?
2. Is this a new regulation requiring the additional soil [from 12” to 24”]?
Item #3 can be accomplished once we further understand item #2.

8/21/24, 12:38 PM State of Utah Mail - Cell 7 E&P Landfill Permit Additions
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-1017583536772845800&simpl=msg-a:r-6401310406290…5/10
todd

From: Wade Hess <[e-mail]>
Sent: Tuesday, July 16, 2024 6:28 PM
To: Todd Bro <[e-mail]>; Bret Reynolds <[e-mail]>
Subject: Cell 7 E&P Landfill Permit Addions

Todd and Bret,
[Quoted text hidden]
Wade Hess <[e-mail]>Tue, Jul 23, 2024 at 12:43 PM
To: Todd Bro <[e-mail]>
Cc: Bret Reynolds <[e-mail]>, "Cahoon, Brad R." <[e-mail]>
Hey Todd,
Apologies for the lack of specificity on the required final cover. The Class VII Facility requirements must be met for the E&P Waste Landfill Permit in Cell #7. This
means that the Standard Design found in R315-303-3(5)(a) or the Alternative Design in R315-303-3(5)(c) must be met in the permit application.
The Standard Design requires two layers, one layer between the final lift and the topsoil to minimize infiltration (18 inches of compacted soil with a permeability of
1x 10-5 or less, typically made up of silty sand, silt, or clay) and a layer on top to minimize erosion (6 inches of soil capable of sustaining vegetative growth,
typically topsoil) that is seeded.
An Alternative Design (typically clay or HDPE) may be approved if it achieves equivalent reduction in infiltration as the clay layer mentioned above and equivalent
protection from wind and water erosion as the topsoil layer mentioned above. To acquire approval of an Alternative Design, the expected performance of the
Alternative Design must be demonstrated with the use of a mathematical model. Inputs for the modeling must include climatic conditions at the facility site as well
as soil types that make up the final cover. The model should be run to show the expected performance of the cover at normal precipitation for the period of time
before stability will be reached, as well as expected performance for the five wettest years on-site or at the nearest weather station. If, using the model, the
proposed Alternative Design using clay performs as well as the Standard Design, or the proposed Alternative Design using HDPE shows an infiltration rate of no
greater than 3 millimeters of water per year, then the Alternative Design may be approved.
So, to answer your question, the final cover should be made up of 18 inches of soil with a permeability of 1 x 10-5 and 6 inches of topsoil. Which makes the total
cover 24'' thick.
Rule references are below.
Thanks,
Wade
R315-321-4. Exploration and Production Waste Facility Requirements.
...
(3) Standards for Design.
…
(d) The owner or operator of a Class VII Facility shall meet the closure requirements of Subsection R315-303-3(5).
R315-303-3(5)
(5) Closure. At closure, an owner or operator of a Class I, II, IIIa, IVa, or VII Landfill Facility shall use one of the following designs for the final cover for each
associated landfill cell.
(a) Standard Design. The standard design of the final cover for landfill cells within the facility shall consist of two layers:
(i) a layer to minimize infiltration, consisting of at least 18 inches of compacted soil, or equivalent, with a permeability of 1 x 10-5 cm/sec or less, or equivalent, shall
be placed upon the final lifts;
(A) in no case shall the cover of the final lifts be more permeable than the bottom liner system or natural subsoils present in the unit; and
(B) the grade of surface slopes shall not be less than 2%, nor the grade of side slopes more than 33%, except where construction integrity and the integrity of
erosion control can be demonstrated at steeper slopes; and
(ii) a layer to minimize erosion, consisting of:
(A) at least six 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; or
(B) other suitable material, approved by the Director.
(b) Requirements for any Earthen Final Cover at a Landfill cell.
(i) Markers or other benchmarks shall be installed in any final earthen cover to indicate the thickness of the final cover. These markers shall be observed during
each quarterly inspection and the earthen cover shall be raised to the appropriate thickness as necessary.
(ii) Erosion channels deeper than 10% of the total cover thickness shall be repaired as soon as possible following their discovery.
(c) Alternative Final Cover Design. The Director may approve an alternative final cover design, on a site specific basis, if it can be documented that:
(i) the alternative final cover achieves an equivalent reduction in infiltration as achieved by the standard design in Subsection R315-303-3(5)(a)(i); and
(ii) the alternative final cover provides equivalent protection from wind and water erosion as achieved by the standard design in Subsection R315-303-3(5)(a)(ii).
(d) The expected performance of an alternative final cover design shall be documented by the use of an appropriate mathematical model.
(i) The input for the modeling shall include the climatic conditions at the specific [landfill]facility site and the soil types that will make up the final cover.
(ii) The model shall:
(A) be run to show the expected performance of the final cover at normal precipitation for a period of time until stability has been reached; and
(B) shall be run to show the expected performance of the final cover during the five wettest years on record at the site or the nearest weather station.
(e) The Director shall use the following criteria as part of the basis for determining if an alternative final cover will be approved:
(i) If the landfill cell has a liner design that does not use a synthetic material such as HDPE, the model will compare the infiltration through the standard cover as
required in Subsection R315-303-3(5)(a) and shall show that the alternative cover performs as well as the standard cover; or
(ii) If the landfill cell has a liner composed in part of a synthetic material such as HDPE, the model must show an infiltration rate of no greater that 3 millimeters of
water per year during any year of the model run.
(f) If a landfill cell has been constructed using an approved alternative landfill cell design, the Director may require, on a site-specific basis, the landfill cell closure
design to be more stringent than the standard design specified in Subsection R315-303-3(5)(a) to protect human health or the environment.
(g) In no case shall any modification be made to the final cover, as placed and approved at closure by the Director, unless that modification:
8/21/24, 12:38 PM State of Utah Mail - Cell 7 E&P Landfill Permit Additions
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-1017583536772845800&simpl=msg-a:r-6401310406290…6/10
(i) is a necessary repair of the approved final cover;
(ii) maintains or improves the effectiveness of the final cover; and
(iii) is approved by the Director.
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Bret Reynolds <[e-mail]>Mon, Jul 29, 2024 at 9:08 AM
To: Wade Hess <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>, Todd Bro <[e-mail]>
Wade

Attached is a Mathematical Analysis of the Alternative Cover Design that was specified in the original application for your review and acceptance. As shown in the
calculations, the alternative cover design surpasses the standard design.

Thanks for all you do. Have a great day, you deserve it.

Bret Reynolds, PE
CIVCO Engineering, Inc.
Mobile: [phone]
Office: 435-789-5448
1256 W 400 N
Suite 1
PO Box 1758
Vernal Utah 84078

[Quoted text hidden]
Closure Plan Alternative Design.pdf
284K
Wade Hess <[e-mail]>Tue, Jul 30, 2024 at 10:42 AM
To: Bret Reynolds <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>, Todd Bro <[e-mail]>
Hey Bret,
The document attached to your previous email is only one page. A mathematical model is mentioned, but not included. I think perhaps the document was somehow
cut short? If you could resend it, that would be appreciated.
Thank you,
Wade
[Quoted text hidden]
Bret Reynolds <[e-mail]>Tue, Jul 30, 2024 at 11:17 AM
To: Wade Hess <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>, Todd Bro <[e-mail]>
Wade
Sorry about that. This one with the second page is the one that was supposed to be sent.
[Quoted text hidden]
Closure Plan Alternative Design.pdf
341K
Wade Hess <[e-mail]>Wed, Jul 31, 2024 at 5:58 PM
To: Bret Reynolds <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>, Todd Bro <[e-mail]>
Bret,
The proposed mathematical model does not include climatic conditions at the site, the expected performance of the cover at normal precipitation, or the expected
performance during the five wettest years on record. The EPA's Hydrologic Evaluation of Landfill Performance (HELP) Model is the most widely used model that
8/21/24, 12:38 PM State of Utah Mail - Cell 7 E&P Landfill Permit Additions
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-1017583536772845800&simpl=msg-a:r-6401310406290…7/10
can account for each of those things. Perhaps run EEI's information through that model for the Standard Design, the proposed Alternative Design during normal
precipitation, and the proposed Alternative Design for the five wettest years on record to make the case required by our rules.
If the modeling is not completed with the required inputs, or if the alternative design proves insufficient, then the Standard Design will be required. If EEI choses the
Standard Design, the closure section of the permit application and associated costs will need to be altered to account for the additional 12 inches of soil in the
infiltration layer.
Thanks,
Wade
R315-303-3. Standards for Design.
...
(5) Closure. At closure, an owner or operator of a Class I, II, IIIa, IVa, or VII Landfill Facility shall use one of the following designs for the final cover for each
associated landfill cell.
...
(c) Alternative Final Cover Design. The Director may approve an alternative final cover design, on a site specific basis, if it can be documented that:
(i) the alternative final cover achieves an equivalent reduction in infiltration as achieved by the standard design in Subsection R315-303-3(5)(a)(i); and
(ii) the alternative final cover provides equivalent protection from wind and water erosion as achieved by the standard design in Subsection R315-303-3(5)(a)(ii).
(d) The expected performance of an alternative final cover design shall be documented by the use of an appropriate mathematical model.
(i) The input for the modeling shall include the climatic conditions at the specific [landfill]facility site and the soil types that will make up the final cover.
(ii) The model shall:
(A) be run to show the expected performance of the final cover at normal precipitation for a period of time until stability has been reached; and
(B) shall be run to show the expected performance of the final cover during the five wettest years on record at the site or the nearest weather station.
(e) The Director shall use the following criteria as part of the basis for determining if an alternative final cover will be approved:
(i) If the landfill cell has a liner design that does not use a synthetic material such as HDPE, the model will compare the infiltration through the standard cover as
required in Subsection R315-303-3(5)(a) and shall show that the alternative cover performs as well as the standard cover; or
[Quoted text hidden]
Bret Reynolds <[e-mail]>Thu, Aug 1, 2024 at 8:10 AM
To: Wade Hess <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>, Todd Bro <[e-mail]>
Wade.
As stated, the final cover material meets the standard. Therefore, why is a model required to show that the standard is acceptable? The only
change requested is in the lower layer.
Sent from my boost Samsung Galaxy A15 5G
Get Outlook for Android
From: Wade Hess <[e-mail]>
Sent: Wednesday, July 31, 2024 5:58:43 PM
[Quoted text hidden]

[Quoted text hidden]
Wade Hess <[e-mail]>Thu, Aug 1, 2024 at 11:53 AM
To: Bret Reynolds <[e-mail]>
Cc: "Cahoon, Brad R." <[e-mail]>, Todd Bro <[e-mail]>
Bret,
You must show that infiltration through the alternative design is equivalent to that of the standard design. The math that you supplied accounts for soil permeability
only. Soil depth, soil type, and climatic conditions (precipitation, humidity, etc.) must also be included in modeling to predict infiltration rates. The proposed 6 inch
clay layer meets the permeability standard, but showing that that layer meets an equivalent reduction in infiltration as the standard design can be determined only
through comparing the infiltration of the standard design model with the infiltration of the alternative design model.
UAC R315-303-3(5)(a)(i) states that, for the Standard Design, the layer of cover for minimizing infiltration must consist of at least 18 inches of compacted soil, or
something equivalent to soil, and that the soil must have a permeability of 1 x 10-5 cm/sec or less. So, even if the permeability of the soil is less than 1x10-5
cm/sec, it still must be at least 18 inches thick. The only way to get around that is through proving that the infiltration will be equivalent (for both normal precipitation
until stability has been reach and for the five wettest years on record).
Thanks,
Wade
[Quoted text hidden]
Todd Bro <[e-mail]>Fri, Aug 2, 2024 at 3:32 PM
To: Wade Hess <[e-mail]>, Brian Speer <[e-mail]>
Cc: Bret Reynolds <[e-mail]>, "Cahoon, Brad R." <[e-mail]>
Wade,

1.We think our best path forward concerning UAC R315-303-3[5][a][i] is to commit temporarily to the standard
closure cap of 24” and provide the appropriate bonding.
8/21/24, 12:38 PM State of Utah Mail - Cell 7 E&P Landfill Permit Additions
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-1017583536772845800&simpl=msg-a:r-6401310406290…8/10
After that’s complete we will go to work on modelling according to the requirements of the alternative closure
plan.
Will WMRC approve a change from the standard closure to the alternative in the future if our alternative plan
meets the regulation?
2.Concerning modelling; we have approached Jeremy with Snowshoe Engineering to help us decide this issue.
He wants to discuss modelling and the EPA’s Hydrologic Evaluation of Landfill Performance Model with WRMC
before we take steps toward meeting the requirements of the alternative plan.
Can we meet with WMRC to discuss this?
3.Is the requirement for top 6” of the soil cap top soil?
Does top soil include any surface soil in the adjoining area?

Please get back to me on the meeting [#2 above] and available dates.

My regards,

Todd bro, owner
801/599/7213
[Quoted text hidden]
Wade Hess <[e-mail]>Mon, Aug 5, 2024 at 9:01 AM
To: Todd Bro <[e-mail]>
Cc: Bret Reynolds <[e-mail]>, Brian Speer <[e-mail]>, "Cahoon, Brad R." <[e-mail]>
Hey Todd,
1. Yes, that plan works. I think it's a good way to move forward. We can approve the 24'' cover/appropriate bonding to secure an initial permit, and then can change
it to an alternative cover through a major permit modification. A permit modification is similar to an initial permit issuance in that you will send us all the information
that you want changed, we'll alter the permit accordingly, there will be a public comment period, and then the permit will be officially modified.
So, for this initial permit, we'll need you to submit: 1) a new closure plan with the cover layer depth specifications altered; 2) alterations of the associated closure
costs; and 3) proof that your financial assurance mechanism covers the increased closure costs.
2. I'll get back to you on meeting times this afternoon. Brian just got back from vacation and currently has a full schedule, but we'll figure that out and be in touch.
3. The requirement for the top 6'' layer of cover is "soil capable of sustaining vegetative growth." This is typically native soil from somewhere nearby (or the property
itself) that can facilitate native vegetative growth.
Thanks,
Wade
[Quoted text hidden]
Bret Reynolds <[e-mail]>Thu, Aug 8, 2024 at 2:49 PM
To: Wade Hess <[e-mail]>, Todd Bro <[e-mail]>
Cc: Brian Speer <[e-mail]>, "Cahoon, Brad R." <[e-mail]>
Wade
The closure plan has been revised to go with the standard cover. The alternative cover was eliminated.
The facility legal description has been revised to reflect the boundaries of cell 7.
[Quoted text hidden]
2 attachments
Closure Plan (8-6-24).pdf
275K
Facility Legal Description (8-6-24).pdf
184K
Wade Hess <[e-mail]>Thu, Aug 8, 2024 at 5:25 PM
To: Bret Reynolds <[e-mail]>, Todd Bro <[e-mail]>
8/21/24, 12:38 PM State of Utah Mail - Cell 7 E&P Landfill Permit Additions
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-1017583536772845800&simpl=msg-a:r-6401310406290…9/10
Cc: Brian Speer <[e-mail]>, "Cahoon, Brad R." <[e-mail]>
Great, thanks! Everything looks good concerning those changes.
Now that there is an increase in soil amount used for closure, the Financial Assurances, Closure Costs, and (possibly) Post Closure Car Costs sections of the
document need updating.
Currently, the Financial Assurances Section states that the closure/post-closure costs are based on in-house personnel doing the work, but they must be based on
a third party performing the work.
The Closure and Post-Closure Costs sections should include adjustments to any costs associated with changing the depth of the cover layer and having a third
party perform closure/post-closure work.
Remember, this permit is for a landfill for Cell #7 only, so the permit sections can reflect that. Once the costs are adjusted, the financial assurance mechanism must
be updated to cover the costs of Cell #7 closure and post-closure.
Please send the following once you acquire them:
1. Update to Financial Assurance, Closure Costs, and Post Closure Costs sections of the permit application.
2. Proof that Financial Assurance mechanism will cover the updated costs.
Let me know if you have any questions!
Thanks,
Wade
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Bret Reynolds <[e-mail]>Fri, Aug 9, 2024 at 9:55 AM
To: Wade Hess <[e-mail]>, Todd Bro <[e-mail]>
Cc: Brian Speer <[e-mail]>, "Cahoon, Brad R." <[e-mail]>
Wade
Todd is obtaining a third party cost estimate for the closure then we can update those sections.
[Quoted text hidden]
Bret Reynolds <[e-mail]>Mon, Aug 12, 2024 at 1:54 PM
To: Wade Hess <[e-mail]>
Cc: Brian Speer <[e-mail]>, "Cahoon, Brad R." <[e-mail]>, Todd Bro <[e-mail]>
Wade
I have updated the closure cost based on the new cover concept. It has been updated to only reflect the cost for Cell 7. The post closure cost was revised to only
show the cost for Cell 7.
[Quoted text hidden]
Closure Cost (8-12-24).pdf
235K
8/21/24, 12:38 PM State of Utah Mail - Cell 7 E&P Landfill Permit Additions
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-a:r-1017583536772845800&simpl=msg-a:r-640131040629…10/10
Attorney General Office Comments
EEI Draft Permit
7/16/2024
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
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]
site includes Front End Loaders (2) and Dump Trucks (2).
Add Cell #7 description here (i.e. dimensions, distance from property line).
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 Testing and calculations should be included in application.
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.
Lower layer must be 18 inches thick, unless demonstration of equivalency is made.
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]
Must be based on third party performing closure.
This does not meet cover requirements. See cover requirements at end of document.
Likely needs revision
if work is not being
performed in-house,
and because of the
final cover changes.
Likely needs revision if work is not being performed
in-house, and because of the final cover changes.
Final Cover Current Rule
R315-304-5. Industrial Landfill Requirements.
...
(2)Each Class III Landfill shall meet the applicable general requirements for closure and post-closure care of
Subsections R315-302-2(6); R315-302-3(2); (3); (4)(a), and (b); (5); (6)(a)(iv) through (vi), (6)(b), and (c); and (7)(a) as
determined by the Director.
...
(b)Each Class IIIb Landfill shall meet the closure requirements of Subsection R315-305-5(5)(b).
R315-305-5. Requirements for Operation.
…
(5) The owner or operator of a Class IV or VI Landfill shall meet the applicable general requirements of closure and
post-closure care of Section R315-302-3 as determined by the Director.
...
(b) The owner or operator of a Class IVb or VI Landfill shall close the facility by:
(i) leveling the waste to the extent practicable;
(ii)covering the waste with a minimum of two feet of soil, including six inches of topsoil;
(iii) contouring the cover as specified in Subsection R315-303-3(4)(a)(i)(B); and
R315-303-3(4)(a)(i)(B)
(B)the grade of surface slopes shall not be less than 2%, nor the grade of side slopes more than 33%,
except where construction integrity and the integrity of erosion control can be demonstrated at steeper
slopes; and
(iv) seeding the cover with grass, other shallow rooted vegetation, or other native vegetation or covering in
another manner approved by the Director to minimize erosion.
(v) The Director may approve an alternative final cover design for a Class IVb or VI Landfill if it is documented that
the alternative final cover provides equivalent protection from infiltration and erosion as the cover specified in
Subsection R315-305-5(5)(b).
Alternative Cover Requirements for Current Rule
To receive Director approval for an alternative final cover design, it must be documented that the alternative final cover provides
equivalent protection from infiltration and erosion as the cover specified in R315-305-5(5)(b). The documentation must include
an appropriate mathematical model that details the expected performance of the alternative cover design. Details concerning the
mathematical model are found in R315-303-3(4)(d).
R315-303-3(4)(d).
(d)The expected performance of an alternative final cover design shall be documented by the use of an appropriate
mathematical model.
(i) The input for the modeling shall include the climatic conditions at the specific facility site and the soil types that will
make up the final cover.
(ii) The model shall:
(A) be run to show the expected performance of the final cover at normal precipitation for a period of time until
stability has been reached; and
(B) shall be run to show the expected performance of the final cover during the five wettest years on record at the site
or the nearest weather station.
(e) The Director shall use the following criteria as part of the basis for determining if an alternative final cover will be
approved:
(i) If the landfill cell has a liner design that does not use a synthetic material such as HDPE, the model will compare the
infiltration through the standard cover as required in Subsection R315-303-3(5)(a) and shall show that the alternative
cover performs as well as the standard cover; or
(ii) If the landfill cell has a liner composed in part of a synthetic material such as HDPE, the model [must]shall show an
infiltration rate of no greater that 3 millimeters of water per year during any year of the model run.
(f) If a landfill cell has been constructed using an approved alternative landfill cell design, the Director may require, on
a site-specific basis, the landfill cell closure design to be more stringent than the standard design specified in
Subsection R315-303-3(5)(a) to protect human health or the environment.
(g) In no case shall any modification be made to the final cover, as placed and approved at closure by the Director,
unless that modification:
(i) is a necessary repair of the approved final cover;
(ii) maintains or improves the effectiveness of the final cover; and
(iii) is approved by the Director.
Cover Requirements, Future Rule
R315-321-4. Exploration and Production Waste Facility Requirements.
…
(d)The owner or operator of a Class VII Facility shall meet the closure requirements of Subsection R315-303-3(5).
R315-303-3(5)
(5) Closure. At closure, an owner or operator of a Class I, II, IIIa, IVa, or VII Landfill Facility shall use one of the
following designs for the final cover for each associated landfill cell.
(a) Standard Design. The standard design of the final cover for landfill cells within the facility shall consist of two
layers:
(i) a layer to minimize infiltration, consisting of at least 18 inches of compacted soil, or equivalent, with a permeability
of 1 x 10-5 cm/sec or less, or equivalent, shall be placed upon the final lifts;
(A) in no case shall the cover of the final lifts be more permeable than the bottom liner system or natural subsoils
present in the unit; and
(B) the grade of surface slopes shall not be less than 2%, nor the grade of side slopes more than 33%, except where
construction integrity and the integrity of erosion control can be demonstrated at steeper slopes; and
(ii) a layer to minimize erosion, consisting of:
(A) at least six 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; or
(B) other suitable material, approved by the Director.
(b) Requirements for any Earthen Final Cover at a Landfill cell.
(i) Markers or other benchmarks shall be installed in any final earthen cover to indicate the thickness of the final cover.
These markers shall be observed during each quarterly inspection and the earthen cover shall be raised to the
appropriate thickness as necessary.
(ii) Erosion channels deeper than 10% of the total cover thickness shall be repaired as soon as possible following their
discovery.
(c) Alternative Final Cover Design. The [D]director may approve an alternative final cover design, on a site specific
basis, if it can be documented that:
(i) the alternative final cover achieves an equivalent reduction in infiltration as achieved by the standard design in
Subsection R315-303-3(5)(a)(i); and
(ii) the alternative final cover provides equivalent protection from wind and water erosion as achieved by the standard
design in Subsection R315-303-3(5)(a)(ii).
(d) The expected performance of an alternative final cover design shall be documented by the use of an appropriate
mathematical model.
(i) The input for the modeling shall include the climatic conditions at the specific [landfill]facility site and the soil types
that will make up the final cover.
(ii) The model shall:
(A) be run to show the expected performance of the final cover at normal precipitation for a period of time until
stability has been reached; and
(B) shall be run to show the expected performance of the final cover during the five wettest years on record at the site
or the nearest weather station.
(e) The Director shall use the following criteria as part of the basis for determining if an alternative final cover will be
approved:
(i) If the landfill cell has a liner design that does not use a synthetic material such as HDPE, the model will compare the
infiltration through the standard cover as required in Subsection R315-303-3(5)(a) and shall show that the alternative
cover performs as well as the standard cover; or
(ii) If the landfill cell has a liner composed in part of a synthetic material such as HDPE, the model [must]shall show an
infiltration rate of no greater that 3 millimeters of water per year during any year of the model run.
(f) If a landfill cell has been constructed using an approved alternative landfill cell design, the Director may require, on
a site-specific basis, the landfill cell closure design to be more stringent than the standard design specified in
Subsection R315-303-3(5)(a) to protect human health or the environment.
(g) In no case shall any modification be made to the final cover, as placed and approved at closure by the Director,
unless that modification:
(i) is a necessary repair of the approved final cover;
(ii) maintains or improves the effectiveness of the final cover; and
(iii) is approved by the Director.
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 PLAN ALTERNATIVE DESIGN
Introduction
Environment Energy Innovations proposed an Alternative Final Cover Design in accordance with
R315-303-3(5). The alternative design includes a minimum of six inches of clay that will have a
permeability of at most 1 x 10 -6 cm/sec along with a second layer cover layer of material with
a minimum of six inches of soil as prescribed in R315-303-3(4)(a)(ii).
The attached mathematical model shows that a minimum of 1.8 inches of soil satisfies the
requirements of 18 inches of soil meeting a permeability of 1x10-5 cm/sec. The proposed 6
inches of soil is 333% more effective that the standard therefore it satisfies the requirement of
achieving an equivalent reduction in infiltration as achieved by the standard design in
Subsection R315-303-3(5)(a)(i);
The Alternative Final Cover Design provides equivalent protection from wind and water erosion
as achieved by the standard design in Subsection R315-303-3(5)(a)(ii) in that the top layer of
the Alternative Final Cover Design matches the requirements of the standard design.
Bret Reynolds, SE
Mathamatical Model For Alternative Final Cover Design 1 cm = 0.3937 inches
1x10-5 =1.00E-05 =0.0000100 cm/sec =0.0000039 in/sec @ 18 inches 1,800,000 sec to permeate
1x10-6 =1.00E-06 =0.0000010 cm/sec =0.0000004 in/sec @ 1.8 inches 1,800,000 sec to permeate
Delta from Standard 0
1x10-6 =1.00E-06 =0.0000010 cm/sec =0.0000004 in/sec @ 6 inches 6,000,000 sec to permeate
Delta from Standard (4,200,000) 333%
Standard Design
Min. Alternative Design
Proposed Alternative
CIVCO Engineering, Inc.
Civil Engineering Consultants
PO Box 1758 * 1256 W 400 S, Suite 1
Vernal, Utah 84078

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

ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH
CLOSURE COSTS
The EEI facility is planned to close 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 an 18-inch clay cover, 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 No. Units per year
per cell
Unit Type Years Total
Units
Total Cost
28 years Details
Inspections
Quarterly 1st 2 years; $25 4 hours 2 8 $200
Semiannually for 28 years $25 2 hours 28 56 $1,400
Report

Quarterly 1st 2 years; $25 4 hours 2 8 $200

Semiannually for 28 years $25 2 hours 28 56 $1,400

Subtotal for 30
years $3,200

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 $28,200
Contingency $2,800 (10%)

Post Closure
Cost cell 7 $31,000

Table 2 Post Closure Care Costs

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 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: [phone]

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

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

ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH

Legal Description

The project is located in Pleasant Valley, approximately 3 miles South of US 40, in Section 18,
Township 4 South, Range 2 West. The attached plats show the boundaries and legal
descriptions of the property. The attached warranty deeds provides the proof of ownership.

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

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

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

ENVIRONMENT ENERGY INNOVATIONS
PLEASANT VALLEY, UTAH
CLOSURE COSTS
The EEI facility is planned to close 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 an 18-inch clay cover, 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 No. Units per year
per cell
Unit Type Years Total
Units
Total Cost
28 years Details
Inspections
Quarterly 1st 2 years; $25 4 hours 2 8 $200
Semiannually for 28 years $25 2 hours 28 56 $1,400
Report

Quarterly 1st 2 years; $25 4 hours 2 8 $200

Semiannually for 28 years $25 2 hours 28 56 $1,400

Subtotal for 30
years $3,200

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 $28,200
Contingency $2,800 (10%)

Post Closure
Cost cell 7 $31,000

Table 2 Post Closure Care Costs