DSHW-2024-004417

January XX, 2024
Jay Lowder, Public Services Director
Ogden City Corporation
133 W 29th Street
Ogden, UT 84404
RE:Moulding& Sons LandfillRequirements
Dear Mr. Lowder:
Over the last several months, the Division of Waste Management and Radiation Control (Division) has been in contact with you regarding the Moulding and Sons Construction “Moulding &
Sons Landfill” (the Landfill), located at what was formerly known as 910 W 21st Street, Ogden, Utah (the Property). The city of Ogden has assisted the Division by providing records
and clarification to document the city’s ownership of 4 of the 6 parcels of the Property. As you know, the other two parcels are owned by the city of West Haven.
The Division does not have records to document whether the Landfill was closed in accordance with the closure requirements found in Utah Administrative Code (UAC)R315-302-3(4) and has
asked Moulding and Sons Construction to provide those records. In addition, once a facility has closed the owner or operator of a solid waste disposal facility is required to undertake
the following post-closure requirements:
Submit proof that the location of the disposal site has been recorded with the county recorder as part of the record of title as required by UAC R315-302-2(6);
Apply for and obtain a post-closure care permit as required by UAC R315-310-10;
Maintain and update financial assurance as required by UAC R315-311-1(5);
Provide post-closure activities for continued facility maintenance and monitoring of gases, land, and water 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 as required by UAC R315-302-3(5); and
Comply with all other applicable requirements of UAC R315-301 through R315-320 until the Director authorizes the owner or operator to discontinue post-closure maintenance and monitoring
according to UAC R315-302-3(7)(c).
As the operator of the Landfill, Moulding and Sonsis responsible for ensuring that the requirements listed above are met. These responsibilities may also be transferred according to
UAC R315-310-11, but no transfer has occurred.
As the owner of property that the Landfill occupies, the city of Ogden will be required to be named as a permittee, even if post-closure care activities are provided by another party.
The Division has attempted to convene a meeting with Moulding and Sons Construction, Ogden, and West Haven to discuss the requirements, but has been unsuccessful at bringing all three
parties together. Between themselves, Moulding and Sons, Ogden, and West Haven shouldmake arrangementsto fulfill the above requirements.
Because theLandfill has not been in operation for so long, the Division requests your attention to the requirements, and requests that within 30 days you provide the Division with the
following:
Agreements made between Moulding and Sons, Ogden, and West Haven for conducting post-closure care;
A schedule with estimated dates for completing items #1, #2, and #3 above;
Who will be the post-closure care operator(s) that the Division will communicate with during the post-closure care period; and
Who will be the contributor(s) on the financial assurance obligation for the post-closure care period.
The Division has provided a similar letter to Moudling and Sons Construction, and West Haven. The Division is happy to meet in person, by phone, or by virtual meeting, to address questions
that you may have about the requirements and provide assistance with the application process through the Community Portal.
Please contact Alex Milne at [e-mail] or at 801-599-4672 with any questions that you may have.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/AM/???
c:Brian Cowan, Health Officer, Weber-Morgan Health Department
Michela Harris, Deputy Director, Weber-Morgan Health Department
Scott Braeden, Environmental Health Director, Weber-Morgan Health DepartmentAmy Hugie, City Attorney, West Haven City, [e-mail] Moulding, President, Moulding and Sons
Construction,(Email) [e-mail]