DSHW-2024-008685

10/10/2024
Douglas Hansen, Director
Division of Waste Management and Radiation Control
R.E. In response to item III of your October 7, 2024 letter requesting closure and post closure information for
Environmental Energy Innovations LLC Land spreading [SW349] AKC cell #6.
Utah R315-302-3
1[a] Financial Assurance – EEI was not required to provide financial assurance by WMRC when this permit was granted in
2013. However, the entire facility, 140 acres, which includes cell #6 is covered by an LOC required by OGM. In addition,
the closure work has been completed [see appendix A]. Post closure care will be limited to harvesting mixing soil from
cell #6 to be used to dry and firm inbound waste on cell #7, cell #7 landfill @EEI. For these reasons no additional
financial assurance is required.
1[b] minimize threats – Cell #6 has been excavated and bio-remediated to meet closure standards endorsed by OGM
[see appendix A]. All threats to human health and the environment have been removed [see photo].
[3][a] Closure Plan - As stated above, mixing soil will be harvested off cell #6 which would eliminate the need for
grading, seeding, landscaping, contouring, or screening.
[3][b][c] Plan of closure on file - Because the excavation and bio-remediation of cell #6 is complete [see Appendix A] we
see no reason to maintain a file.
[4][a][b][c] Closure Procedures - The closure plan has been implemented and completed. We will forward the required
professional engineer’s registered stamp.
[6][a] Post closure Plan and Amendment - No ground water was detected down to 50 ft. according to 3rd party boring
results. The waste imported to the property does not generate leachate [see July 11,2024 email to Director Hansen,
opinion provided by Dr. Sheril Burton, Blackrock Consulting]. Planned use of the property is to provide mixing soil for
the landfill as explained above.
[6][b] Post closure file - EEI will maintain a monthly inspection schedule of cell #6 until the director determines that the
property has stabilized.
[7][a][b][c] - There is no evidence of settlement, gas production, or leachate generation on the property. All waste
material has been removed along with approximately 12 “ of soil. The property can be considered stabilized.

Please contact me if the above is not sufficient to meet the requirements of a closure and post closure plan for cell #6.

Todd Bro, owner
EEI