DSHW-2024-007928

Wade Hess <[e-mail]>
RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill
for Oil and Gas Exploration
25 messages
Todd Bro <[e-mail]>Thu, Jan 18, 2024 at 7:05 AM
To: Brent Gaschler <[e-mail]>, Brian Speer <[e-mail]>, Wade Hess <[e-mail]>
Cc: Keith Hohensee <[e-mail]>, Bret Reynolds <[e-mail]>
The below increase to the LLC is untenable and not according to the operating plan
originally suggested by WMRC legal council [name escapes me at the moment].
Can we discuss this issue next week by phone? Please set up a conference call
and I will round up Bret Reynolds and Keith Hohensee for the call.

Thanks in advance,

Todd Bro, owner
801/599/7213

From: Brent Gaschler <[e-mail]>
Sent: Wednesday, January 17, 2024 4:26 PM
To: Todd Bro <[e-mail]>
Subject: Environmental Energy Innovaons LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploraon

Hi Mr. Bro.

I've been sent the attached cost estimate. This message is just a reminder that to obtain the permit for the Class IIIb
Landfill, Environmental Energy Innovations LLC will need to amend Letter of Credit #1433 with West Bank from the
existing $303,500 to $3,692,000 ($3,320,000 closure and $372,000 post closure).

Please let me know if you have any questions or concerns.

Thank you.

--
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:17884373036501658…1/19
Brent Gaschler, P.E.
Environmental Engineer | Planning and Technical Support
Section
Phone: [phone]
Email: [e-mail]
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Statements made in this email do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control. If you desire a statement of the Division Director's position,
please submit a written request to the Director, including copies of documents relevant to your request.

Wade Hess <[e-mail]>Thu, Jan 18, 2024 at 10:35 AM
To: Todd Bro <[e-mail]>
Cc: Brent Gaschler <[e-mail]>, Brian Speer <[e-mail]>, Keith Hohensee
<[e-mail]>, Bret Reynolds <[e-mail]>
I have invited you all to a call on Tuesday, Jan 23 at 11:00 am. You can either join by phone or with Google Meet. Please
let me know if that doesn't work for any of you.
Thanks!
Wade
[Quoted text hidden]
--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
[Quoted text hidden]
Todd Bro <[e-mail]>Sat, Jan 20, 2024 at 6:42 AM
To: Wade Hess <[e-mail]>
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:17884373036501658…2/19
Cc: Brent Gaschler <[e-mail]>, Brian Speer <[e-mail]>, Keith Hohensee
<[e-mail]>, Bret Reynolds <[e-mail]>
Wade,
I will use the phone for the meeting.

todd
[Quoted text hidden]
Brent Gaschler <[e-mail]>Mon, Aug 12, 2024 at 4:03 PM
To: Wade Hess <[e-mail]>
Hi Wade. I don't think they are. but I must ask just in case. Are these folks eligible for a time extension for financial
assurance like those applying for an Exploration and Production Waste Facility Temporary Permit would be? Or, are there
closure and post-closure requirements according to Class IIIb "R315-304-5 - Industrial Landfill Requirements"? If the
latter, have they submitted to you a closure and post-closure plan, upon which to base their cost estimate, do you know?
---------- Forwarded message ---------
From: Keith Hohensee <[e-mail]>
Date: Mon, Aug 12, 2024 at 3:40 PM
Subject: FW: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
To: Brent Gaschler <[e-mail]>
Brent:

Good aernoon. Hope your week is starng out well. I am following up on the process of EEI being issued the land
fill permit as addressed in the email string below. Please find aached an esmate from a third party for closure costs
of cell seven at EEI’s facility. As shown, the new esmate to put two feet of clay/dirt/soil on the ten acres is
$1,020,000. I believe you have a formula or some other method to calculate other post closure costs. Starng with
the $1,020,000 please let me know what the leer of credit amount needs to be for EEI to comply with the financial
assurance requirement of the applied for land fill permit. Just let me know if you have any quesons or if there is
anything else you need. I appreciate all of your me and assistance. Thank you.

Sincerely,

Keith Hohensee
ITL/EEI
515-963-8386 ext. 104
[Quoted text hidden]
--
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:17884373036501658…3/19
Brent Gaschler, P.E.
Environmental Engineer | Used Oil and Outreach Section
Phone: [phone]
Email: [e-mail]
wasteandradiation.utah.gov
[Quoted text hidden]
EEI Excavations Services estimate 080224.jpg
69K
Wade Hess <[e-mail]>Mon, Aug 12, 2024 at 4:34 PM
To: Brent Gaschler <[e-mail]>
Hi Brent,
It's the latter! They're acquiring an Oil and Gas Exploration and Production Landfill Permit, which is essentially a Class IIIb
Permit. This is for Cell 7 of their property only. They've applied for the permit to take place of the Waste Pile approval
made on August 8,2024 (they had $300,000 in financial assurance for that one, if I remember correctly). As part of the
E&P Cell 7 permitting process, they've recently sent us updates to the closure/post-closure plan. I've attached those
below.
Ensuring that the financial assurance mechanism covers the cost of closure and post-closure is their final requirement
needed to get the permit, so once you give the okay/have the right documents, please let me know so I can move it
forward!
Thanks!
Wade
[Quoted text hidden]
--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
[Quoted text hidden]
EEI Cell 7 E&P Closure Cost (8-12-24).pdf
235K
Brent Gaschler <[e-mail]>Tue, Aug 13, 2024 at 10:05 AM
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:17884373036501658…4/19
To: Wade Hess <[e-mail]>
Is it likely, do you think, that we're changing regulations on IIIb landfills to require liners? And if you know offhand, are we
requiring groundwater monitoring wells for post-closure monitoring on IIIb landfills? How about any leachate collection
devices (or does cap impermeability negate the need)? Seems their cost estimate is missing a lot.
[Quoted text hidden]
Brent Gaschler <[e-mail]>Tue, Aug 13, 2024 at 12:07 PM
To: Keith Hohensee <[e-mail]>
Cc: Wade Hess <[e-mail]>
HI Keith.
The Excavation Services invoice for Cell 7 closure work ($1,020,000) seems reasonable, as does the corresponding
Civco closure costs of $1,055,000 (received a copy from Wade Hess). Missing from the descriptions, however, are things
like: contractor mobilization, construction surveying, storm drains, drainage ditches, etc.
Where I see the problem being is in the Civco post-closure cost estimate (attached). It should include similar tasks and
unit costs to the attached "Example Post-Closure Cost Estimate." This is from another E&P Waste IIIb Landfill and was
received in 2019. Note the "inspections and reports," "groundwater monitoring," and "cap maintenance" pay items. I
would expect to see similar descriptions and dollar amounts in any revised Environmental Energy Innovations LLC cost
estimate.
When you get your finalized cost estimate together you're going to need to formally submit it to the Division for approval.
The email for official submission is: [e-mail] The Solid Waste Manager will then make the call on the
acceptance or rejections of this document.
Thanks.

On Mon, Aug 12, 2024 at 3:40 PM Keith Hohensee <[e-mail]> wrote:
Brent:

Good aernoon. Hope your week is starng out well. I am following up on the process of EEI being issued the land
fill permit as addressed in the email string below. Please find aached an esmate from a third party for closure
costs of cell seven at EEI’s facility. As shown, the new esmate to put two feet of clay/dirt/soil on the ten acres is
$1,020,000. I believe you have a formula or some other method to calculate other post closure costs. Starng with
the $1,020,000 please let me know what the leer of credit amount needs to be for EEI to comply with the financial
assurance requirement of the applied for land fill permit. Just let me know if you have any quesons or if there is
anything else you need. I appreciate all of your me and assistance. Thank you.

Sincerely,

Keith Hohensee
ITL/EEI
515-963-8386 ext. 104

8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:17884373036501658…5/19
From: Todd Bro <[e-mail]>
Sent: Thursday, January 18, 2024 8:05 AM
To: Brent Gaschler <[e-mail]>; Brian Speer <[e-mail]>; Wade Hess
<[e-mail]>
Cc: Keith Hohensee <[e-mail]>; Bret Reynolds <bretreynolds@
civcoengineering.com>
[Quoted text hidden]
[Quoted text hidden]
--
Brent Gaschler, P.E.
Environmental Engineer | Used Oil and Outreach Section
Phone: [phone]
Email: [e-mail]
wasteandradiation.utah.gov
[Quoted text hidden]
2 attachments
Civco Cost Estimate, EEI Cell 7 E&P Closure Cost (8-12-24).pdf
235K
Example Post-Closure Cost Estimate.pdf
160K
Brent Gaschler <[e-mail]>Tue, Aug 13, 2024 at 12:14 PM
To: Keith Hohensee <[e-mail]>
Cc: Wade Hess <[e-mail]>
Perhaps I misspoke about officially submitting just the cost estimate. You'll have to ask Wade Hess how the Solid Waste
group handles this. You may need to submit the revised cost estimate within the permit application.
[Quoted text hidden]
Keith Hohensee <[e-mail]>Tue, Aug 13, 2024 at 12:22 PM
To: Brent Gaschler <[e-mail]>
Cc: Wade Hess <[e-mail]>
Brent and Wade:

Good aernoon. Thanks for the informaon. I will forward this to Bret at Civco and Todd at EEI for their review and
then have the documents updated. Wade, please let me know the correct procedure when these items are ready to
be submied. Thanks again to both of you for the assistance.
[Quoted text hidden]
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8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:17884373036501658…6/19
[Quoted text hidden]
[Quoted text hidden]
Brent Gaschler, P.E.
Environmental Engineer | Planning and Technical Support
Section
Phone: [phone]
Email: [e-mail]
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.

--
Brent Gaschler, P.E.
Environmental Engineer | Used Oil and Outreach Section
Phone: [phone]
Email: [e-mail]
wasteandradiation.utah.gov
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:17884373036501658…7/19
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.

--
Brent Gaschler, P.E.
Environmental Engineer | Used Oil and Outreach Section
Phone: [phone]
Email: [e-mail]
wasteandradiation.utah.gov
[Quoted text hidden]
Keith Hohensee <[e-mail]>Tue, Aug 13, 2024 at 1:26 PM
To: Brent Gaschler <[e-mail]>
Cc: Wade Hess <[e-mail]>
Brent:

Good aernoon. Bret sent me an email in regards to the post closure esmate. He indicated the only difference he
noced was in regards to ground water monitoring. Bret further stated that there is no ground water so no
monitoring would be required. It was also his understanding the report had been accepted as submied so let me
know if any of the verbiage needs to be changed. I did email Wade to confirm how everything should be submied
and will proceed accordingly once I have that informaon. Thanks again for your help.

Sincerely,

Keith Hohensee
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:17884373036501658…8/19
ITL/EEI

From: Brent Gaschler <[e-mail]>
Sent: Tuesday, August 13, 2024 1:14 PM
To: Keith Hohensee <[e-mail]>
Cc: Wade Hess <[e-mail]>
[Quoted text hidden]

[Quoted text hidden]
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[Quoted text hidden]
Brent Gaschler, P.E.
Environmental Engineer | Planning and Technical Support
Section
Phone: [phone]
Email: [e-mail]
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.

8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:17884373036501658…9/19
--
Brent Gaschler, P.E.
Environmental Engineer | Used Oil and Outreach Section
Phone: [phone]
Email: [e-mail]
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.

--
Brent Gaschler, P.E.
Environmental Engineer | Used Oil and Outreach Section
Phone: [phone]
Email: [e-mail]
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:1788437303650165…10/19
[Quoted text hidden]
Brent Gaschler <[e-mail]>Tue, Aug 13, 2024 at 1:53 PM
To: Keith Hohensee <[e-mail]>
Cc: Wade Hess <[e-mail]>
Regarding the post-closure estimate, $25 per hour is an unrealistic hourly rate for the professionals performing the
inspections and reports for the 30-year period. If I recall, the regulations require using RS Means to obtain realistic wages
and per diems. And, if there is no proximate groundwater, then maybe, the groundwater monitoring section may be
omitted. The Solid Waste group can confirm this.
[Quoted text hidden]
--
Brent Gaschler, P.E.
Environmental Engineer | Used Oil and Outreach Section
Phone: [phone]
Email: [e-mail]
wasteandradiation.utah.gov
[Quoted text hidden]
Todd Bro <[e-mail]>Tue, Aug 13, 2024 at 3:22 PM
To: Keith Hohensee <[e-mail]>, Bret Reynolds <[e-mail]>
Cc: Wade Hess <[e-mail]>
1. Bump the hourly rate by $5.00/hour.
2. The Solid Waste group has volumes of proof that there is no ground water under
EEI down to 50 ft. The ground water monitoring section should be eliminated.
Wade, do you agree and can you get Brent to drop it?
3. Bret, your closure document states 18” of clay and 6” of top soil. I think the
requirement is 18” of silt, soil, or clay. Would you research?

todd

From: Keith Hohensee <[e-mail]>
Sent: Tuesday, August 13, 2024 12:59 PM
To: 'Bret Reynolds' <[e-mail]>; Todd Bro <[e-mail]>
Subject: FW: FW: Environmental Energy Innovaons LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas
Exploraon

Bret and Todd:

8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:1788437303650165…11/19
Good aernoon. Please see below Mr. Gaschler ’s response on the items that need to addressed. Please adjust the
hourly rate as you deem appropriate and probably should have verbiage that indicates there is no proximate ground
water so everyone knows this was not overlooked. Thanks for the help.
[Quoted text hidden]
Bret Reynolds <[e-mail]>Wed, Aug 14, 2024 at 8:08 AM
To: Todd Bro <[e-mail]>, Keith Hohensee <[e-mail]>
Cc: Wade Hess <[e-mail]>
Will revise per all discussion
Sent from my boost Samsung Galaxy A15 5G
Get Outlook for Android
From: Todd Bro <[e-mail]>
Sent: Tuesday, August 13, 2024 3:22:41 PM
To: Keith Hohensee <[e-mail]>; Bret Reynolds <[e-mail]>
Cc: Wade Hess <[e-mail]>
Subject: RE: FW: Environmental Energy Innovaons LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas
Exploraon

[Quoted text hidden]
Wade Hess <[e-mail]>Wed, Aug 14, 2024 at 9:23 AM
To: Brent Gaschler <[e-mail]>
Liners will not be required. As for closure cover, they'll either need to close using the Standard or Alternative Final
Alternative Cover Design outlined in R315-303-3(4). No groundwater monitoring or leachate collection devices will be
required. Requirements are fairly bare-bones!
[Quoted text hidden]
Wade Hess <[e-mail]>Wed, Aug 14, 2024 at 9:36 AM
To: Todd Bro <[e-mail]>
Cc: Keith Hohensee <[e-mail]>, Bret Reynolds <[e-mail]>
Hey Everyone,
Groundwater monitoring will not be required, and may be omitted from the closure costs.
The requirement for the 18'' layer (UAC R315-303-3(4)(a)(i)) is "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;" Soils with this permeability are typically fine
sands, silts, clays, or mixture of these soil types.
Please email the final costs to [e-mail].
Thanks,
Wade
[Quoted text hidden]
--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:1788437303650165…12/19
wasteandradiation.utah.gov
[Quoted text hidden]
Bret Reynolds <[e-mail]>Wed, Aug 14, 2024 at 9:54 AM
To: Wade Hess <[e-mail]>, "[e-mail]" <[e-mail]>
Cc: Keith Hohensee <[e-mail]>, Todd Bro <[e-mail]>
Wade and Brent
The Post Closure Cost has been updated with new rates and a note indicating ground water testing not being done.
The verbiage in the closure cost section for the first layer material has been clarified.

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: Wade Hess <[e-mail]>
Sent: Wednesday, August 14, 2024 9:37 AM
To: Todd Bro <[e-mail]>
[Quoted text hidden]
[Quoted text hidden]
Closure Cost (8-14-24).pdf
236K
Keith Hohensee <[e-mail]>Wed, Aug 14, 2024 at 11:48 AM
To: "[e-mail]" <[e-mail]>
Cc: Bret Reynolds <[e-mail]>, Todd Bro <[e-mail]>, Wade Hess
<[e-mail]>
Division of Waste Management and Radiaon Control:

Good aernoon. Please find aached the closure and post-closure costs for the Environmental Energy Innovaons
LLC (EEI) permit applicaon. Just let me know if there are any quesons or if anything else is needed. Thank you.

Sincerely,

8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:1788437303650165…13/19
Keith Hohensee
ITL/EEI
515-963-8386 ext. 104

From: Wade Hess <[e-mail]>
Sent: Wednesday, August 14, 2024 10:37 AM
To: Todd Bro <[e-mail]>
Cc: Keith Hohensee <[e-mail]>; Bret Reynolds <[e-mail]>
Subject: Re: FW: Environmental Energy Innovaons LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas
Exploraon

Hey Everyone,
[Quoted text hidden]

WMRC EEI Closure Cost (8-14-24).pdf
236K
Brent Gaschler <[e-mail]>Thu, Aug 15, 2024 at 7:05 AM
To: Wade Hess <[e-mail]>
Sad to hear you're leaving Wade. I wish you well. Hope our paths cross again.
About EEI - If the existing letter of credit is $303,500 (and if that was for the waste pile permit on the same Cell 7), and if
the new closure and post-closure sum is $1,086,740, then they'll have to increase the existing letter of credit by
$783,240.
I'll leave it to you and Brian Speer to approve the application and associated cost estimate, and let the applicant know
about the needed letter of credit amendment.
~Brent Gaschler
[Quoted text hidden]
Wade Hess <[e-mail]>Thu, Aug 15, 2024 at 9:48 AM
To: Brent Gaschler <[e-mail]>
Thanks, Brent! Wouldn't mind ending back at DEQ some day!
Those numbers are correct...I'll reach out to them about the letter of credit amendment.
[Quoted text hidden]
Wade Hess <[e-mail]>Thu, Aug 15, 2024 at 10:06 AM
To: Keith Hohensee <[e-mail]>, Todd Bro <[e-mail]>
Cc: Bret Reynolds <[e-mail]>
Hi All,
The Closure and Post-closure estimates look good. I'll be sure to add them to the permit attachments.
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:1788437303650165…14/19
The existing letter of credit for the Cell 7 Waste Pile is $303,500, and the new closure and post-closure sum is
$1,086,740. Therefore, the existing letter of credit must increase by $783,240.
Once we receive proof of a financial assurance mechanism that covers closure/post-closure, we should be good to go on
the permit. As per usual, send the proof to [e-mail].
Thank you,
Wade
[Quoted text hidden]
Keith Hohensee <[e-mail]>Thu, Aug 15, 2024 at 12:18 PM
To: Wade Hess <[e-mail]>, Todd Bro <[e-mail]>
Cc: Bret Reynolds <[e-mail]>
Wade:

Good aernoon. That all sounds good and thanks for the informaon. I have contacted our bank and they will start
working on revising the amount of the leer of credit. I will keep you posted as to the status. Thanks again for your
me and assistance.

Sincerely,

Keith Hohensee
ITL/EEI
[Quoted text hidden]
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Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:1788437303650165…15/19

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Statements made in this email do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control. If you desire a statement of the Division Director's position,
please submit a written request to the Director, including copies of documents relevant to your request.

--
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
[Quoted text hidden]
Keith Hohensee <[e-mail]>Mon, Aug 19, 2024 at 3:01 PM
To: Wade Hess <[e-mail]>, "[e-mail]" <[e-mail]>
Cc: Bret Reynolds <[e-mail]>, Todd Bro <[e-mail]>
Wade:

Good aernoon. Please find aached the new standby leer of credit with an effecve date of 08/20/24 in the
amount of $1,090,000. I am including the [e-mail] on this email as instructed. Please confirm
where the original standby leer of credit should be sent to confirm is sending it to the correct address. I assume it is
the same as the exisng leer of credit and simply wanted to verify that. Just let me know if you have any quesons
or need anything else. Thanks for your me and assistance.

Sincerely,

8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:1788437303650165…16/19
Keith Hohensee
ITL/EEI

From: Wade Hess <[e-mail]>
Sent: Thursday, August 15, 2024 11:06 AM
To: Keith Hohensee <[e-mail]>; Todd Bro <[e-mail]>
[Quoted text hidden]

[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
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.

--
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:1788437303650165…17/19
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
[Quoted text hidden]
EEI WMRC SLOC 082024.pdf
635K
Keith Hohensee <[e-mail]>Tue, Aug 20, 2024 at 5:04 PM
To: Wade Hess <[e-mail]>
Wade:

Good aernoon. Hope your week is going well. I was just following up to confirm the address the original standby
leer of credit should be mailed to. Our bank is inquiring so please let me know when you get a chance. Thanks for
your help and have a great rest of the day.
[Quoted text hidden]
Wade Hess <[e-mail]>Wed, Aug 21, 2024 at 8:45 AM
To: Keith Hohensee <[e-mail]>
Hi Keith,
The Address is:
Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
Thanks!
Wade
[Quoted text hidden]
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8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:1788437303650165…18/19
Wade Hess
Environmental Scientist | Solid Waste
Division of Waste Management and Radiation Control
Cell: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
[Quoted text hidden]
Keith Hohensee <[e-mail]>Wed, Aug 21, 2024 at 8:50 AM
To: Wade Hess <[e-mail]>
Wade:

Good morning. Excellent and thanks for confirming the address. I assume the process of issuing the permit is moving
forward as I believe the financial assurance was the last remaining item. I appreciate the assistance and have a great
rest of the day.

Sincerely,

Keith Hohensee
ITL/EEI
[Quoted text hidden]
8/21/24, 12:58 PM State of Utah Mail - RE: Environmental Energy Innovations LLC - Waste Pile Permit to Class IIIb Landfill for Oil and Gas Exploration
https://mail.google.com/mail/u/0/?ik=7a8f3b10ce&view=pt&search=all&permthid=thread-f:1788437303650165830&simpl=msg-f:1788437303650165…19/19
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 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