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Home My WebLink AboutDSHW-2025-0003271 1Division of Waste Management and Radiation Control Solid Waste Management Program Mailing Address Office Location Phone (801) 536-0200 P.O. Box 144880 195 North 1950 West Fax (801) 536-0222 Salt Lake City, Utah 84114-488 Salt Lake City, Utah 84116 www.deq.utah.gov APPLICATION FOR A TEMPORARY PERMIT TO OPERATE AN EXPLORATION AND PRODUCTION WASTE FACILITY In 2019, the Utah Legislature made changes to the Solid and Hazardous Waste Act, Utah Code § 19-6- 101 et seq., which required jurisdiction over the disposal of Oil and Gas Exploration and Production Waste move from the Department of Natural Resources’ Division of Oil, Gas, and Mining (DOGM) to the Department of Environmental Quality’s Division of Waste Management and Radiation Control (DWMRC). In preparation for this regulatory shift, DWMRC has proposed a temporary permitting mechanism for existing Exploration and Production (E&P) facilities as defined in the proposed Utah Admin. Code R315- 301-2(22)(a). The proposed rules state that the Director of DWMRC may issue a temporary permit for the purposes of facilitating the owner’s or operator’s good faith transition from regulation under Utah Admin. Code R649-9 to regulation under Utah Admin. Code R315-321 or R315-322. Applications for temporary permits must be received by the Director of DWMRC no less than 30 days before October 1, 2024. The temporary permits will expire one year from the effective date, which is the date the financial assurance mechanism held by DOGM is transferred to DWMRC. To complete a temporary permit application to operate an E&P facility, an owner or operator of an existing E&P facility must: 1. Register the company in DWMRC’s Community Portal and complete facility information within the Community Portal. 2. Complete the attached Exploration and Production Waste Facility Temporary Permit Application Form. 3. Provide DWMRC with the following required documentation, to the extent it has not already been provided to DWMRC or is not already in DWMRC’s possession: a. Facility map with each landfarm cell, landfill cell, and surface impoundment labeled; b. Copy of Division of Oil, Gas, and Mining Permit; c. Copy of Division of Oil, Gas, and Mining Permit Approval/Issuance Letter; and d. Copy of Division of Oil, Gas, and Mining Bonding (financial assurance). 4. Submit the Application Form and required documentation to DWMRC through the Community Portal Miscellaneous Document Submission. 5. Within 120 days of DWMRC’s issuance of a temporary permit, the financial assurance mechanism held by DOGM must be transferred to DWMRC. If the Director issues a temporary permit, it shall not become effective until the financial assurance mechanism held by DOGM is transferred to DWMRC. An effective temporary permit is required to operate an E&P Facility under DWMRC’s jurisdiction. 2 Exploration and Production Waste Facility Temporary Permit Application Form I. Facility Name and Location Name of Facility Danish Flats Facility Address (Street or Directions to Facility) CR181 County Grand City. Cisco Zip Code 84540 Telephone 970-683-8153 Township T20 S Range R24 E Section 08 Quarter Section SW Quarter/Quarter Section SW Main Gate Latitude: 39° 4'35.92"N Longitude: 109°17'31.81" II. Existing E&P Facilities ☐ Open Landfarm Cell(s) x Evaporation Pond(s) Number of Open Landfarm Cells: Number of Evaporation Ponds: 14 III. Facilities to be Permitted by DWMRC ☐ Landfill Cell(s) ☐ Surface Impoundment(s) Number of Landfill Cells: Number of Surface Impoundments: III. Facility Owner(s) Information Legal Name of Facility Owner Jon Goza Mailing Address 1540 P Road City Loma State CO Zip Code 81524 Telephone 970-683-8153 IV. Facility Operator(s) Information Legal Name of Facility Operator Danish Flats Waste Solutions Mailing Address 1540 P Road City Loma State CO Zip Code 81524 Telephone 970-683-8153 V. Property Owner(s) Information Is the property leased? No Name of Property Owner Jon Goza Mailing Address 1540 P Road City Loma State CO Zip Code 81524 Telephone 970-683-8153 VI. Designated Contact Information Facility Owner Designated Contact (if different than above) Title 3 Mailing Address City. State Zip Code Telephone Email Address Alternative Telephone (cell phone or other) Facility Operator Designated Contact (if different than above) Title Mailing Address City State Zip Code Telephone Email Address Alternative Telephone (cell phone or other) Property Owner Contact (if different than above) Title Mailing Address City State Zip Code Telephone Email Address Alternative Telephone (cell phone or other) VII. Waste Types to be Disposed of (check all that apply) VIII. Facility Area x Exploration and Production wastes that are exempt from hazardous waste rules (R315-260-4(b)(5)). ☐ Very Small Quantity Generator hazardous waste Facility Area: 640 acres Disposal Area: 87 acres IX. Application Documents Indicate documents attached to this application (all are required): x Facility Map with each landfarm cell, landfill cell, and surface impoundment labeled x Copy of Division of Oil, Gas, and Mining Permit x Copy of Division of Oil, Gas, and Mining Approval/Issuance Letter x Copy of Division of Oil, Gas, and Mining Bonding (Financial Assurance) 1:12,00008001,600 2,400400Feet Copyright, 2024± Danish Flats Temporary PermitDanish Flats Disposal FacilityCisco, UTProject Number: 1931-001 Site Location Map Attachment1 Legend Surface Empoundments Site boundary Facility Enterance APPENDIX A - FIGURE 5 Site Plan/Evaporation Ponds/Containment 2 & 5 Oilfield Water Logistics Danish Flats SWD 39.076627 / -109.291579 Grand County, Utah Map not to scale LEGEND Property Boundary Tertiary Berm Phase II Evaporation Ponds 9-14 Phase I Evaporation Ponds 1-8 Un-named Intermittent Creek Entrance Reclaimed Settlement Pond Tank Battery Office / Shop 1 2 4 11 10 14 12 9 3 5 7 8 6 13 Phase II Evap. Ponds, Precipitation Only Containment Needed Containment 5 Phase I Evap. Ponds Containment 2 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 RECEIVED: Feb. 09, 2021 $WWDFKPHQW$ $FMM $FMM $FMMOBNFTBEEFECZ 5FUSB5FDI Sundry Number: 108522 Facility Number: 242 State of Utah DEPARTMENT OF NATURAL RESOURCES GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor MICHAEL R. STYLER Executive Director Division of Oil, Gas and Mining JOHN R. BAZA Division Director Permit to Operate ******************** Facility Name:Danish Flats Facility Type: Commercial Waste Disposal Facility Location: Section 8, Township 20S, Range 24E County:Grand Approval Date:April 15, 2019 1. Issued to: Owl Swd Operating, LLC (84195) 2. Authority: Pursuant to Utah Code Ann. §§ 40-6-1 et seq., and Utah Admin. Code §§ R649-9 et seq., the Utah Division of Oil, Gas and Mining (“Division”) issues this Permit to operate an E and P waste disposal facility. 3. Duration: This Permit shall expire five years from the Approval Date. The Division may revoke, suspend, or impose additional operating conditions or limitations on a disposal facility permit at any time, for good cause, after notice to the operator. The Division may suspend a waste disposal permit or impose additional conditions or limitations in an emergency to forestall an imminent threat to fresh water, public health, or safety of the environment. Suspension of a disposal facility permit may be for a fixed period of time or until the operator remedies the violation or potential violation. If the Division suspends a disposal facility permit, the disposal facility shall not accept E and P waste during the suspension period. 4. General: 4.1 Effect on Prior Permits. This Permit supersedes any existing E and P waste disposal permit previously obtained for the Facility and provides the terms that govern operations at this Facility. 4.2 Incorporation of Application. The Division issues this Permit in response to OWL’s “Permit Renewal Application” dated 6/28/2018 and received by the Division on 6/28/2018, (“Application”). The Facility shall operate in accordance with the best management practices described in the Application. 4.3 Compliance with Applicable Laws. The Facility shall comply with Utah Code Ann. §§ 40-6- 1 et seq. and Utah Administrative Code §§ R649-9 et seq.. 5. Reporting and Recordkeeping Requirements: 1594 West North Temple, Suite 1210, PO Box 145801, Salt Lake City, UT 84114-5801 telephone (801) 538-5340 x facsimile (801) 359-3940 x TTY (801) 538-7458 x www.ogm.utah.gov Sundry Number: 95372 RECEIVED: Apr. 15, 2019 The Facility shall comply with the reporting and recordkeeping requirements in Utah Admin. Code § R649-9-11. 6. Modifications: This Permit only applies to the Facility as it is described in the Application. Any additions to the Facility or modifications of the waste treatment processes described in the Application are not allowed and require a permit modification. 7. Enforcement: The issuance of this permit does not supersede local ordinances, county planning and zoning requirements, or other permits required to conduct business at the Facility. A copy of this approval should be kept at the Danish Flats field office, and field personnel shall be aware of the Conditions of Approval. 8. Approval: Therefore, having met all the technical permit requirements of Utah Admin. Code §§ R649-9 et seq., final approval to operate the Facility in accordance with this Permit is hereby granted. 9. Contact Information: The following are Division of Oil, Gas and Mining contacts and their telephone numbers: Dayne Doucet, Permit Manager: 801-538-5303 Bart Kettle, Operations Manager: 435-820-0862 Ammon McDonald, Environmental Scientist: 801-538-5337 Approved By: ________________________ By: Dayne Doucet Title: Permit Manager Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o=DNR, ou=DOGM, email=daynedoucet@utah.gov, c=US Date: 2019.04.15 09:01:23 -06'00' Sundry Number: 95372 RECEIVED: Apr. 15, 2019 Conditions of Approval: 1. Evaporation Facilities 1.1 A minimum of 2 feet of freeboard shall be maintained in the pit(s) at all times, and that a method of obviously displaying the freeboard shall be devised and implemented. Utah Admin. Code § R649-9-4.6.4. 1.2 Pit(s) are to be maintained such that hydrocarbons will not collect on the surface. Hydrocarbon accumulations, other than de minimis quantities, shall be removed within 24 hours. Utah Admin. Code § R649-9-4.6.4. 1.3 Spraying water to accelerate evaporation should be closely monitored. Overspray outside the lined pit area is considered a violation. Utah Admin. Code § R649-9-4.9.2. 1.4 The leak detection system must be checked weekly. Any leak must be reported to the Division immediately, and corrective measures must be taken as directed by the Division. 1.5 The compacted secondary containment berms at the Facility shall be inspected quarterly and after a major rainstorm or windstorm to ensure integrity Utah Admin. Code § R649-9-11.3.2. 1.6 Evaporation ponds are permitted to accept produced water. 1.7 Phase I ponds 1-8 are permitted to accept RCRA exempt E&P fluids. 1.8 Equipment, tanks, and liners must be visually inspected at least monthly. 1.9 Ground water monitoring shall be conducted at monitoring wells quarterly. FAILURE TO COMPLY WITH THE ABOVE LISTED CONDITIONS OF APPROVAL MAY RESULT IN CLOSURE OF THE FACILITY. Sundry Number: 95372 RECEIVED: Apr. 15, 2019 Oilfield Water Logistics OWL Danish Flats SWD Commercial Wastewater Disposal Facility Utah Division of Oil, Gas & Mining Five Year E&P Waste Disposal Facility Permit Renewal Prepared For Oilfield Water Logistics 8210 Preston Rd., Suite 520 Dallas, TX 75225 Prepared By CASE Associates speters@case-associates.com JUNE 2018 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics I TABLE OF CONTENTS A. DETAILED SITE DESCRIPTION ....................................................................................... 1 1. FACILITY DESCRIPTION ...................................................................................................... 1 2. PROCESS DESCRIPTION ..................................................................................................... 1 B. CONTAMINATION ASSESSMENT ................................................................................... 2 1. DESCRIPTION OF EXISTING CONTAMINATION ........................................................................ 2 2. PROPOSED MONITORING & PREVENTATIVE PRACTICES ........................................................ 4 C. EQUIPMENT ASSESSMENT ............................................................................................ 5 1. DESCRIPTION AND ASSESSMENT OF EQUIPMENT .................................................................. 5 D. PRACTICES ASSESSMENT ............................................................................................. 7 1. MANAGEMENT PRACTICES & CONTAMINATION MITIGATION ................................................... 7 E. MONITORING PROGRAM ................................................................................................ 8 F. ESTIMATING CLOSURE COSTS & BONDING EVALUATION ...................................... 10 1. PERMITTING & CURRENT BONDING ................................................................................... 10 2. BONDING FOR THE PERMIT RENEWAL PROCESS ................................................................ 11 3. SEEDING & REVEGETATION .............................................................................................. 12 LIST OF TABLES TABLE 1. 1 EQUIPMENT INVENTORY .............................................................................................. 5 TABLE 1. 2 FACILITY TANK PARAMETERS ....................................................................................... 5 TABLE 1. 3 CURRENT BONDING SYNOPSIS ................................................................................... 10 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics II FIGURES APPENDIX A ........................................................................................................................... 13 Figure 1 General Location Map Figure 2 Vicinity Map Figure 3 Land Title Survey Figure 4 Tank Battery & Headworks As Build Figure 5 Facility Retention Berms Figure 6 Site Acreage for Reclamation Evaluation Figure 7 Current Facility Map with Annotations ATTACHMENTS ATTACHMENT A .................................................................................................................... 14 Separation Pond Closure Certification Letter ATTACHMENT B .................................................................................................................... 15 KRW Consulting, Inc. Design & Operations Plan Excerpts ATTACHMENT C .................................................................................................................... 16 Ground Engineering Consultants, Inc. Geotechnical Report ATTACHMENT D .................................................................................................................... 17 Utah DEQ, DWQ Groundwater Discharge Permit, UGW 190002 ATTACHMENT E .................................................................................................................... 18 Email Correspondence with Dan Hall, UDWQ Regarding Bonding ATTACHMENT F ..................................................................................................................... 19 Cost Estimate for Closure & Post-Closure ATTACHMENT G .................................................................................................................... 20 NRCS Seeding Recommendations ATTACHMENT H .................................................................................................................... 21 Section R649-9-13 Variance Request – Removal of Phase II Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 1 Five Year E&P Waste Disposal Facility Renewal OWL Danish Flats SWD A. DETAILED SITE DESCRIPTION 1. Facility Description OWL Danish Flats SWD (Danish Flats) is located at County Road 181, Cisco, Utah 84540, in Grand County (Appendix A – Figure 1 & Figure 2). The facility is in Township 20 South, Range 24 East, Section 8, approximately 2.5 miles north of Interstate 70, Exit 214 (Appendix A – Figure 3). The section is owned by Oilfield Water Logistics. Danish Flats accepts exploration and production (E&P) exempt wastewater from oil and gas producers for disposal by evaporation in lined evaporation ponds. The Standard Industrial Classification code for the facility is 1389. UTM coordinates are 648,198 m Easting, 4,327,028 m Northing, UTM Zone 12. The facility has been in operation since 2008. In August 2015, Oilfield Water Logistics (OWL) provided specifications to the Utah Division of Oil, Gas & Mining (DOGM) for closure of six concrete separation vaults and the facilities original separation pond which was used for solids removal and secondary phase separation. To close and reclaim the separation pond, sediment was mixed with fresh soil obtained from two excavated cells adjacent to the separation pond, and the pond was backfilled and compacted. On March 29, 2017 DOGM provided the signed ‘Separation Pond Closure Certification Letter’ outlining approval that the sludge pond contents had been stabilized and mitigated (Attachment B). 2. Process Description Shippers of third-party E&P produced water offload from tanker trucks at one of four offloading bays located on a cement apron near the new tank battery area. A process diagram for the tank battery is shown in Appendix A – Figure 4. The tank battery is designed with lined secondary containment to comply with spill prevention control and countermeasure requirements. Produced water is pumped to a Desanding Tank designed to capture suspended solids and consolidate them in one vessel where they are removed for offsite disposal at a facility approved to accept E&P solid wastes. Produced water gravity flows from the Desanding Tank to four Surge Tanks. The Surge Tanks provide primary oil/water phase separation for the produced water and condensate. Any sediment or solids which may have settled in the Surge Tanks are manually Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 2 pumped to a Slop Oil Tank for offsite disposal at a facility approved to accept E&P solid waste. Separated water then flows to two Gun Barrel tanks for secondary phase separation. Condensate and recovered oil from the Desanding, Surge, and Gun Barrel tanks is pumped to the Oil Tanks as additional saleable product for refining. Five propane-fired generators are used to power the facility. The dual-fuel generators also are designed to operate using natural gas, which is available intermittently at the site. One 70- kilowatt (kW) generator powers the facility office. Four 125-kW generators are used on demand and less than full time to offload trucks and power pumps in the tank battery during its operation. Seven dual-fuel natural gas/propane-fired process tank heaters are located one each at the Slop Oil Tank, Gun Barrel tanks, and Oil Tanks. The entrance to the facility is accessed from CR 181 (also referred to as Cottonwood Wash) and Agate Oil Field Road, public roads under the jurisdiction of Grand County. Trucks enter the offloading area at the tank battery directly from the county road. The drive through offloading area is stabilized with road base material and a concrete apron. Following primary and secondary phase separation, water flows to lined evaporation ponds. Phase I evaporation ponds consist of eight approximately 5-acre ponds 1 through 8. Phase II evaporation ponds consist of an additional six approximately 5-acre ponds 9 through 14 for increased disposal capacity for E&P produced water. The ponds are shown on Appendix A - Figure 7. The Phase I ponds have a working level of approximately 8 feet, considering a maximum freeboard of 2 feet, and a surface area of approximately 1,780,100 square feet. The Phase II ponds have a working level of approximately 18 feet, considering a maximum freeboard of 2 feet, and a surface area of approximately 1,365,497 square feet. The ponds were permitted to accept E&P produced water by DOGM; the Utah Department of Environmental Quality, Division of Water Quality, and Grand County. B. CONTAMINATION ASSESSMENT 1. Description of Existing Contamination OWL Danish Flats SWD does not pose a contamination threat to the surrounding environment. In support of that statement the application will reference three main factors. First, the geology and hydrology of the site. Next is the characteristics of the waste being managed at the facility, and finally, the engineering design of the liner system. Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 3 I. Geology & Hydrology An initial subsurface exploration was performed by KRW Consulting, Inc. (KRW) in June 2007. Excerpts from the Design and Operations Plan submitted to DOGM are included in Attachment C. As seen from the highlighted portion of Section 2.d, the facility was constructed in an area where the Mancos shale is reported to be up to 1,200 feet thick. KRW reported that groundwater was not observed during test hole activities at the site and that “The Mancos shale is considered a confining unit that forms a thick barrier to vertical and lateral groundwater flow.” A geotechnical report was completed for the subject property by Ground Engineering Consultants, Inc. (Ground) in January 2008, which is included in Attachment D of this report. Ground reportedly completed 35 test holes to depths ranging from approximately five (5) to ten (10) feet below ground surface (bgs). Ground reported that sandy, lean clay was observed beneath surface materials to depths ranging from approximately five (5) to ten (10) feet bgs. This soils exploration was in addition to borings completed in June 2004. Those earlier borings extended as deep as approximately 44 feet bgs. Ground reported that occasionally weathered claystone was observed beneath the sandy, lean clay layer at the bottom of the test holes, which terminated above the Mancos shale. The Mancos shale is reported to be up to 1,200 feet thick. Ground reported that groundwater was not observed during test-hole activities at the site. The facility is engineered with emergency overflow and storm water retention berms (i.e., secondary containment) outlined in Appendix A – Figure 5. In the unlikely event of an over flow or berm failure of the above portion of a pond berm, waters are diverted to the secondary containment areas. Which include for Phase I a containment area with retention volume of 10- acre feet and a secondary containment berm surrounds Phase II with a retention volume of approximately 15-acre feet. The facility has decreased elevation to the southwest where potential discharge would sheet flow and run to an un-named intermittent creek. The un-named intermittent creek is located approximately 500 feet south of the southern evaporation ponds. Due to the distance, the tertiary containment berm, and nature of the closest water body any potential spills would be remediated before reaching the closest water way. II. Waste Management Solid Waste: The facility does not accumulate a large volume of solids. As noted earlier the separation pond, the source of the largest volume of accumulated solids, was reclaimed in March 2017. In August 2015, OWL provided specifications to DOGM for construction of a new tank battery at Danish Flats. The tank battery is designed to enhance phased oil and water separation while increasing solids removal for improved condensate recovery and downstream evaporation pond water quality. Tank battery construction was completed in March 2016 with construction Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 4 certification provided to DOGM on April 7, 2016. The solids are now contained within a sealed process as they are transferred to a Slop Oil tank in preparation for off-site disposal before they have an opportunity of discharging to the ponds. Hydrocarbon Recovery: As noted the new tank battery system enhances hydrocarbon recovery. This results in reduced to insignificant discharges of hydrocarbons to the evaporation ponds. III. Liner System Design The facilities ponds have been constructed with a composite liner system consisting of a minimum 6-inch clay underliner with a permeability of 1 x 10-5 cm/sec overlain with a synthetic primary liner consisting of 60-mil high density polyethylene (HDPE) flexible membrane liner (FML). The soils at the site are of low permeability and are not expected to transmit liquids even if a leak occurs in the HDPE liner. The ponds are slightly sloped at a minimum of 0.4% with a gravel/pipe trench leak detection system at the low end of each pond. A riser access pipe allows sump water detection measurements and samples to be collected if any leakage is detected in the sump. OWL have been proactive in implementing technology to assist in reducing any risk of environmental contamination at the facility. Over the previous 24-36 months the facility has undergone extensive remodeling which has included the reclamation of the separation pond and installation of a modern and progressive tank battery and offloading system. Those initiatives are considered methods for preventing the risk of contamination at the site. 2. Proposed Monitoring & Preventative Practices As per R649-9-12 a written closure and post-closure plan will be prepared and submitted to DOGM, for approval, at least 60 days prior to cessation of operations of the facility. Post-closure maintenance will be performed, as needed, based on routine inspections and sampling of the site by the owner's representative, which may include: • Ponding; • Dying or dead vegetation; • Proper drainage; • Erosion of channels; • Condition of drainage structures; and • Sampling and noting condition of groundwater monitoring wells. Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 5 But, as a generalization, inspections of the site shall be conducted at a minimum annual basis. The exception is that groundwater will be sampled and tested quarterly. The groundwater testing results, and any deficiencies encountered during the inspections shall be recorded and a memo will be drafted, then necessary repairs shall be made. The inspection and sampling shall begin after the closure construction and re-vegetation, and will continue after site closure for a minimum of 5 years, at which time DOGM will be notified. At that time, DOGM will determine, if the post-closure period should be extended or if it can cease. C. EQUIPMENT ASSESSMENT 1. Description and Assessment of Equipment I. General Facility Inventory Table 1.1 Equipment Inventory Source Description Rating/Capacity Desanding Tank (1) 500 bbl Surge Tanks (4) 1,000 bbl Gun Barrel Tanks (2) 500 bbl Oil Tanks (4) 400 bbl Slop Oil Tank (1) 400 bbl Propane Generator (1) 70 KW Propane Generator (4) 125 KW Natural Gas/Propane Tank Heaters (7) 0.5 MMBtu/hr Phase 1 Ponds (8) 310,000 bbl Phase 2 Ponds (6) 600,000 bbl Diesel Tank 1,000 gallons Gasoline Tank 500 gallons II. Facility Aboveground Storage Tanks Table 1.2 Facility Tank Parameters Tank ID Tank Description Tank Size (bbl) Tank Size (gal) Estimated Oil in Mixture Tank Shell Height (ft) Tank Shell Diameter (ft) Tank Contents T-1 Surge 1,000 42,000 2 30 15.6 Produced Water T-2 Surge 1,000 42,000 2 30 15.6 Produced Water T-3 Surge 1,000 42,000 2 30 15.6 Produced Water T-4 Surge 1,000 42,000 2 30 15.6 Produced Water T-5 Oil 400 16,800 95 20 12 Condensate/Oil T-6 Oil 400 16,800 95 20 12 Condensate/Oil T-7 Oil 400 16,800 95 20 12 Condensate/Oil Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 6 T-8 Oil 400 16,800 95 20 12 Condensate/Oil T-9 Gun Barrel 500 21,000 2 25 12 Produced Water T-10 Gun Barrel 500 21,000 2 25 12 Produced Water T-11 Slop Oil 400 16,800 80 20 13.6 Condensate/Oil/Solids T-12 De-Sanding 500 21,000 2 35 10 Produced Water T-13 Diesel 24 1,000 NA 12 4 Diesel T-14 Gasoline 12 500 NA 6 4 Gasoline The service life of the tanks varies pending the manufacturing material and maintenance schedule. The steel tanks, namely the 2 x Gun Barrel and 4 x Oil tanks, are subject to a 10-year integrity evaluation as per 40 CFR 112.20 and 112.21. Inspections of the tanks are governed by the facilities Spill Prevention, Control and Countermeasure Plan. It obligates the facility to conduct monthly inspections on the valves, thief hatches, plumbing and piping of the tank battery, and, to also examine the tanks for leaks. If a tank pinhole is identified then repairs will be organized through an independent contractor. The remaining tanks are manufactured from fiberglass which is a product known for its durability and longevity, but also, ease of maintenance and repair. The tanks are documented as having superior service life of 30 years’ maintenance free, even when managing liquids of a corrosive nature. III. Evaporation Ponds Phase 1: Eight (8) x 600 ft x 400 ft x 10 ft Phase II: Six (6) x 600 ft x 400 ft x 20 ft Water resulting from the separation process is routed to lined evaporation ponds. Phase I evaporation ponds consist of eight 5-acre ponds (1 through 8), each with a working level of approximately 8 feet and maximum freeboard of 2 feet. Phase II evaporation ponds consist of an additional six 5-acre ponds (9 through 14), each with a working level of approximately 18 feet and maximum freeboard of 2 feet. The average annual evaporation rate for the area, according to the Western Regional Climate Center near Moab, Utah, is 66.6 inches per year. The HDPE liner is acknowledged as having a minimum service life of twenty (20) to thirty (30) plus years and is well suited for its purpose as it is UV resistant and chemical resistant. The integrity of the HDPE liner is visually inspected on a weekly basis and the results recorded on the appropriate inspection log. The pond floors slope toward a sump that is fitted with a monitoring pipe. The leak detection system for each pond is inspected and data recorded on a weekly basis. Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 7 IV. Generators Generators on site are fueled using propane. The dual-fuel generators also are designed to operate using natural gas, which is available intermittently at the site. There are four 125-kW generators and one 70-kW generator. The 70-kW generator operates continuously. The 125-kW generators operate as needed during produced water offloading operations. Both come with a guarantee of extended service life form the manufacturer. V. Tank Heaters Tank heaters will be operated for the four Oil tanks, the two Gun Barrel tanks, and the Slop Oil tank. The seven 0.5-MMBtu/hr tank heaters are dual fuel and can use natural gas or propane. D. PRACTICES ASSESSMENT 1. Management Practices & Contamination Mitigation In the previous few years Danish Flats has introduced modern technology which has assisted in eliminating manual practices, manual handling and risk of produced water and hydrocarbon spills. The introduction of industrial automation at the site has provided the following primary benefits: I. Automated Produced Water Off-Loading Incoming delivery drivers can only activate the off-loading pumps by entering a unique driver ID code in to the automation system (kiosk). The automation system obtains a photograph of the driver and a scan of the water ticket to ensure correctness with the ID code and product being delivered. Once the system is satisfied the correct procedures have been followed the driver is able to return to their truck, manually connect the hose and start the off-load pumps. This protects the facility from unauthorized unloading and ensures electronic tracking of all incoming water to the site. II. Automated Tank Battery Management The industrial automation system monitors all fluids in the tank battery through high-precision sensors which pass on real time updates and emergency alerts to the nominated subscribers. The benefits include: • Eliminating manual tank gauging • Wed-based data tracking • Flow and pressure readings to monitor pumps, flow lines, and vessels. Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 8 • Real-time updates to desktop and mobile devices to assist in immediate response • Reduces or eliminates spills When combining the tank battery automation with the newly installed OSHA and State approved corrugated iron secondary containment the site has implemented practices which should provide reassurance regarding the mitigation of contamination. The secondary containment has also been underlain with a 40-mil HDPE liner, with the joins welded and pipe intrusions sprayed with an epoxy resin, to deliver a water tight structure. The design of the site today is meeting the highest of technological and environmental standards. E. MONITORING PROGRAM 1. Leak Detection System & HDPE Liner The evaporations ponds are designed with a leak detection system to assist in monitoring potential integrity failures of the HDPE liner. The leak detection system is inspected and data recorded on a weekly basis. A summary of the weekly inspections is reported to the State on a quarterly term. If necessary, sump pumps are available on site to evacuate the sumps. As per the ‘Final Approval to Operate’, issued by DOGM for each pond, if a leak is identified then DOGM will be notified immediately and corrective action initiated. The HDPE liner is also subject to a visual weekly inspection and recorded on the LDS inspection document. 2. Tank Battery & Off-Loading System Visual inspections of the tanks, piping, valves, thief hatches, connections, pumps and secondary containment is conducted during routine shifts. A formal recorded inspection is completed each month and filed with the facility records. 3. Separation Pond Reclamation Monitoring The three (3) cells created during remediation of the separation pond have entered the post closure period. “Keep Off” signs have been posted in an effort to keep vehicular and foot traffic off the closed cells. The monitoring wells are checked quarterly and if apparent groundwater is observed in the wells in quantities sufficient for sampling, groundwater samples are collected for chemical analyses. Those samples will be analyzed for TEPH, TVPH, EC, SAR and ESP. Monitoring of the cells is conducted and documented, at a minimum, on a quarterly basis. Monitoring shall focus on erosion of the cover, condition of the gravel layer, and evenness of grades and plant growth. Cover repairs and maintenance as well as the results of groundwater well monitoring shall be documented in an annual report to be submitted to DOGM. The Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 9 monitoring shall begin after the closure construction and re-vegetation, and will continue during the post-closure period for a minimum of five (5) years, at which time the DOGM will be notified. At that time, the DOGM will determine if the post-closure period should be extended or if it can cease. 4. Groundwater Monitoring Presently the groundwater monitoring associated with the site is the quarterly monitoring linked with the post-closure requirements of the separation pond. Due to the geology and hydrology of the site and no record of contamination in 10 years of operations, no further groundwater monitoring is recommended. 5. Air Emissions As per the Utah Division of Air Quality Approval Order the facility is required to track emissions through a rolling 12-month emissions inventory. This includes the requirement of obtaining monthly samples of the wastewater being discharged from the tank battery to the evaporation ponds. 6. E&P Exempt Wastewater All E&P exempt wastewater is accounted for from sales tickets and electronic tracking through the industrial automation system. The volumes are reported to DOGM each quarter. 7. Hydrocarbons Sales All hydrocarbons transported off the facility is accounted for from sales tickets. The volumes are reported to DOGM each quarter. 8. Industrial Automation Provides accurate data as to the volumes and levels of fluids or solids in the tank battery. The automation system has the ability to disseminate live updates outlining the behavior of the system managing the liquids and solids at the site. Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 10 F. ESTIMATING CLOSURE COSTS & BONDING EVALUATION 1. Permitting & Current Bonding Presently the facility is bonded through DOGM. A unique situation exists where the Phase II ponds, numbers nine (9) to fourteen (14), are dual permitted to potentially accept two different waste streams. Under the DOGM permit the ponds are approved to receive E&P produced water. But Phase II also operates under the Utah Department of Environmental Quality, Division of Water Quality (UDWQ), Groundwater Discharge Permit, UGW190002, permitted to receive non-hazardous low and high salinity fluids (Attachment E). A condition of the UDWQ permit is that the storage and evaporation of petroleum E&P wastes is limited to Phase I evaporation ponds under the jurisdiction of DOGM. The facility has complied with this condition since issuance of the UDWQ permit on October 09, 2014. DOGM have requested that the 2018 permit renewal process eliminate the situation where the Phase II ponds are dual permitted. OWL have determined its preference to move forward and remove the Phase II ponds from DOGM bonding. Advice was obtained from UDWQ Manager, Dan Hall P.G., who advised via email the Utah DEQ/DWQ does not have bonding authority. Further the position of the UDWQ is that this part of the facility, referencing Phase II, does not allow for the acceptance of oil and gas waste and therefore does not fall under the DOGM’s jurisdiction (Attachment F). This application will therefore endeavor to outline a bonding scope for the facility excluding Phase II which will default to the UDWQ authority. A variance request, under R649-9-13, has been submitted with the application to formalize the modification (Attachment H). The facility has been constructed in phases since 2007. Oilfield Water Logistics assumed all liabilities regarding the bonds commencing October 20, 2014. A breakdown of the current bonding status, where DOGM have been named as the ‘Obligee,’ is outlined below: Table 1.3 Current Bonding Synopsis POND # DATE BONDED BOND # AMOUNT Separation Pond & Concrete Vaults Reclaimed March 29, 2017 Pond One (1) 12/13/2012 SUR0020547 $170,000.00 Pond Two (2) 12/13/2012 SUR0020546 $170,000.00 Pond Three (3) 12/13/2012 SUR0020545 $149,130.00 Pond Four (4) 12/13/2012 SUR0020544 $149,130.00 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 11 2. Bonding for the Permit Renewal Process As previously outlined OWL Danish Flats SWD is located in section 8. When breaking the section to a quarter-quarter section and overlaying it to an aerial view of the facility a conservative calculation assumes that approximately 300 of the 640 acres has been disturbed (Appendix A – Figure 6). Relevant to this permit renewal application is the soil disturbance to Phase I. The bonded acreage includes the Phase I ponds, the tank battery, site office and offloading bays, soil stockpiles, internal facility roads, storm water channels, containment walls, the perimeter fence and the previously reclaimed separation pond. In total the soil disturbance to Phase I is approximately 155 acres. Bonding estimates have been calculated through reliance on RS Means as well as current proposals from contractors. The ‘Notes’ section of the ‘Cost Estimate for Closure & Post-Closure (Attachment H) provides a comment which outlines the source referenced to arrive at the bonding estimate for that particular line item. The line item estimates include labor and equipment unless otherwise stated. In respect to contamination. The bonding estimate has considered soil samples in two (2) separate locations at the base of each pond to assess for potential contamination. Those soil samples will be analyzed for TEPH, TVPH, EC, SAR and ESP. Pond Five (5) 12/13/2012 SUR0020543 $149,130.00 Pond Six (6) 11/06/2012 SUR0020536 $149,130.00 Pond Seven (7) 11/06/2012 SUR0020536 $149,130.00 Pond Eight (8) 11/06/2012 SUR0020536 $149,130.00 Pond Nine (9) 11/06/2012 SUR0020535 $233,130.00 Pond Ten (10) 11/06/2012 SUR0020534 $233,130.00 Pond Eleven (11) 11/06/2012 SUR0020533 $233,130.00 Pond Twelve (12) 12/13/2012 SUR0020548 $233,130.00 Pond Thirteen (13) 12/13/2012 SUR0020549 $233,130.00 Pond Fourteen (14) 11/06/2012 SUR0020550 $233,130.00 TOTAL $2,633,560.00 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 12 3. Seeding & Revegetation The facility recently reclaimed the separation pond. Expert opinion was obtained from Shane Green, the Natural Resources Conservation Service Utah State Rangeland Specialist (NRCS) regarding the seeding and revegetation requirements. The recommendations were provided in a letter to Oilfield Water Logistics dated May 09, 2016 (Attachment I). Oilfield Water Logistics will duplicate the recommendations provided by the NRCS for the seeding and revegetation of Phase I. Those recommendations include advice on seed mix, soil preparation, method of application, rates of application, time of seeding and watering requirements. Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewals OWL Danish Flats SWD Oilfield Water Logistics 13 APPENDIX A FIGURES Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Not to Scale Project Site Appendix A - Figure 1 General Location Map OWL Danish Flats SWD Grand County, Utah Grand Junction Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Undeveloped Area Undeveloped Area Undeveloped Area Undeveloped Area Undeveloped Area Appendix A - Figure 2 Vicinty MapOWL Danish Flats SWD Grand County, Utah Scale = 1 : 24 000 Project Site Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 7'6" 12' X 20' Oil Tank 12' X 20' Oil Tank 13'6" X 20' Slop Oil Tank 12' X 25' Gun Barrel Tank 12' X 25' Gun Barrel Tank 74' Danish Flats As Build Created for: Oilfield Water LogisticsCreated: 3/24/2016 Danish Flats ***NOTHING TO SCALE*** Aerial View Road 68.5' 50' 38' Ma i n B u i l d i n g Light PoleElectric Box Cement Pad (See Figure #2) 2' 10' X 35' De-Sanding Tank 15'6" X 30' Surge Tank Manifold Housing 15'6" X 30' Surge Tank 15'6" X 30' Surge Tank 15'6" X 30' Surge Tank 12' X 20' Oil Tank 12' X 20' Oil Tank Pump Shed 7'10" 6'11" 24'4" 22'10" 3'3" 5'9" 5'4" Electric Line Underground Load Lines 128' 2'10"2'6" 2'10"2'6" 7'7"8' 40' 6" 84'6" 7'7"8' 24'10" 21'8" 2'6" 8' 5' 9'9" 12'3" 3'5" 20'3" 12'3" 9' 5' 5'11" 7' 7'9" 10' 4' 4' 5'11" 5'10"6' 6' 6'6' 12'11"12'11" 14'14'8" 56' 4' 12'11' Supply Gas Line Electric Riser Supply Gas Riser 88' Underground Supply Gas (Only 6" Deep to Containment) Key Cement Pad (See Figure #1) Water Line Risers Into De-Sanding Tank Water Line Riser Doors (1 Regular, 1 Garage) Cement Pad (Above Ground) Generators Generators LPG Tanks LPG Tanks Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 APPENDIX A - FIGURE 5 Site Plan/Evaporation Ponds/Containment 2 & 5 Oilfield Water Logistics Danish Flats SWD 39.076627 / -109.291579 Grand County, Utah Map not to scale LEGEND Property Boundary Tertiary Berm Phase II Evaporation Ponds 9-14 Phase I Evaporation Ponds 1-8 Un-named Intermittent Creek Entrance Reclaimed Settlement Pond Tank Battery Office / Shop 1 2 4 11 10 14 12 9 3 5 7 8 6 13 Phase II Evap. Ponds, Precipitation Only Containment Needed Containment 5 Phase I Evap. Ponds Containment 2 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 OWL DANISH FLATS SWD SECTION 8 640 acres QUARTER -QUARTER SECTIONS 40 acres Acreage for Reclamation Phase I: 155 acres Phase II: 145 acres JUNE 23, 2018 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Danish Flat Rd CR 1 8 1 Agate O i lfie l d R o a d Phase 1 Evaporation Ponds Phase 2 Evaporation Ponds Tank Battery Area 0 400 800 Feet ³ \\ E C S S 1 3 4 F S 0 1 \ B O U - P R O J E C T S \ B L D 0 1 \ 7 4 5 5 0 0 1 _ O I L F I E L D W A T E R L O G I S T I C S \ D A N I S H F L A T S \ G I S \ O W L _ F A C I L I T Y _ L O C _ M A P . M X D www.tetratech.com Project No.: Date: Designed By: OWL DANISH FLATS SWD 7 FACILITY MAP Figure No. 117-7455001 OCT 04, 2016 ES 4900 Pearl E. Cir., Suite 300W Boulder, Colorado 80301 PHONE: (720) 406-9110Service Layer Credits: Google Earth Cisco, UT Facility Location §¨¦I-70 OWL Danish Flats SWD T20S R24ET20S R23E Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewals OWL Danish Flats SWD Oilfield Water Logistics 14 ATTACHMENT A SEPARATION POND CLOSURE CERTIFICATION LETTER Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor State of Utah DEPARTMENT OF NATURAL RESOURCES 1594 West North Temple, Suite 1210, PO Box 145801, Salt Lake City, UT 84114-5801 telephone (801) 538-5340 • facsimile (801) 359-3940 • TTY (801) 538-7458 • www.ogm.utah.gov MICHAEL R. STYLER Executive Director Division of Oil, Gas and Mining JOHN R. BAZA Division Director March 29, 2017 Oilfield Water Logistics Johnstown, Regional Office P.O. Box 670 Windsor, CO 80550 ATTN: Seth Peters SUBJECT: Re: OWL Danish Flats SWD: Sludge Pond Closure Certification letter dated February1, 2017 Dear Mr. Peters: The Utah Division of Oil, Gas and Mining (Division) has received a Certification Letter with corresponding attachments, a letter to Grand County Recorder’s Office, Himes Drilling Company Inc daily drilling reports for monitoring wells and seed tags. These documents have been accepted and placed into the facility file. Through performing site visits during Sludge Pit closure and a review of provided documentation, the Division concludes OWL has achieved objectives set forth in the August 14, 2015 Closure Plan, March 31, 2016 Request to Amend Sludge Pond Closure Plan, and June 10, 2016 Tetra Tech Technical Memorandum. As observed and reviewed, the implemented Sludge Pond Closure actions are expected to mitigate risk materials would have posed to human health, safety and the environment. Therefore, the Division has determined Sludge Pond contents are stabilized and mitigated. If you have questions feel free to contact me at (435) 820-0862. Sincerely, Bart Kettle Environmental Scientist bk/dj/js cc: Dan Jarvis, Operations Manager Brad Hill, Permitting Manger Ammon McDonald, Environmental Scientist Facility File Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewals OWL Danish Flats SWD Oilfield Water Logistics 15 ATTACHMENT B KRW CONSULTING, INC. DESIGN & OPERATIONS PLAN EXCERPTS Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 1011007.3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 1011007.3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 1011007.3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 1011007.3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 1011007.3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 1011007.3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 1011007.3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 1011007.3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 1011007.3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewals OWL Danish Flats SWD Oilfield Water Logistics 17 ATTACHMENT D UTAH DEQ, DWQ GROUNDWATER DISCHARGE PERMIT, UGW190002 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Si SI State of Utah GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor Department of Environmental Quality Amanda Smith Executive Director DIVISION OF WATER QUALITY Walter L. Baker, P.E. Director ument Date 10/9/2014 OCT 0 9 2014 DWQ-2014-013399 Justin Spaeth Danish Flats Environmental Services 4775 Larimer Parkway, Suite 200 Johnstown, CO 80534 Dear Mr. Spaeth: Subject: Issuance of Utah Ground Water Discharge Permit for the Danish Flats Environmental Services Phase 2 Evaporation Ponds The 30-day public comment period closed on October 6, 2014 for draft Ground Water Discharge Permit UGW190002. No public comments from the public were received during the comment period. The Ground Water Discharge Permit and Statement of Basis are enclosed. An invoice is also enclosed for the legislative mandated fee of $2,250 for 25 hours of staff time preparing the permits. Therefore, please remit $2,250 within 30 days from receipt to: Attn: Stacy Carroll Department of Environmental Quality Division of Water Quality P.O.Box 144870 Salt Lake City, UT 84114-4870 Please be sure to include the invoice number with your remittance. We value your feedback to help us improve the permitting process to better meet your needs. Please go to http://www. waterqual it v.Utah, go v/ and take a few minutes to complete our customer feedback form (Give Feedback on the left side of the web page). 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144870 • Salt Lake City, UT 84114-4870 Telephone (801) 536-4300 *Fax (801) 536-4301 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 If you have any questions or comments about the permit, please contact Ed Hickey at ehickev@utah.gov or (801) 536-4357. Sincerely, Leah Ann Lamb Assistant Director LAL:DJH:EPH:mc Enclosures: 1. UGW190002 Permit (DWQ-2014-013187 2. UGW190002 Statement of Basis (DWQ-2014-0131 3. Invoice DWQ-2014-013186 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144870 • Salt Lake City, UT 84114-4870 Telephone (801) 536-4300 • Fax (801) 536-4301 • T.D.D. (801) 536-4414 www.cieq.utah.gov Printed on 100% recycled paper Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 STATEMENT OF BASIS GROUND WATER DISCHARGE PERMIT UGW190002 Danish Flats Environmental Services Evaporation Ponds Grand County, Utah October 2014 Purpose Danish Flats Environmental Services has constructed lined evaporation ponds to contain and evaporate fresh and saline fluids obtained from a variety of ground water and surface water sources. This Ground Water Discharge Permit will require best available technology and compliance monitoring for 6 evaporation ponds. The facility is located in the Danish Flats area 2.5 miles north of 1-70 interchange Exit 212, approximately 43 miles west of the Utah-Colorado border, in Section 8, Township 20 South, Range 24 East, in Grand County, Utah. The property is privately owned. The Danish Flats area is a desert landscape that gradually slopes to the southeast. Site Geology and Hydrogeology Geology The Danish Flats area is part of the Greater Cisco area and is located in the Mancos Shale lowlands where weathered Mancos Shale is exposed at the surface over most of the area. Based on site boring logs from a geotechnical investigation, the site-specific geology consists of 15 to 40 feet of silty clay derived from and underlain by the Mancos Shale Formation. The Mancos Shale Formation is a marine deposit consisting of gray, thin-bedded, fissile shale ranging from 3,500 feet thick in western Grand County to 4,000 feet thick near the Utah-Colorado border (BLM, 2003). Soils associated with the Mancos Shale are alkaline and may have high concentrations of selenium. As a result, surface water in ephemeral washes is likely to have high salinity, high turbidity, considerable hardness, and elevated levels of sulfate and selenium. The Mancos Shale is between 900 and 1,000 feet thick in the Danish Flats area. Hydrogeology Shallow ground water in the Greater Cisco area is limited to alluvial deposits along ephemeral washes and drainages. There are no major watercourses on or near the project site. Ground water was not encountered in any of the Danish Flats site soil borings. Therefore, the first ground water that would be encountered would be in discontinuous sandstone channel lenses within the Mancos Shale. The Mancos Shale overall does not yield ground water and forms an effective aquitard that inhibits ground water migration. Ground water that comes in contact with the Mancos Shale typically contains very high total dissolved solids concentrations due the high content of sulfate. Potential aquifers below the Mancos Shale are discontinuous stream channel sandstones of the Dakota, Cedar Mountain, and Morrison formations. However, these sandstones are the hydrocarbon reservoirs for oil and gas production in the Greater Cisco area and any ground water contained in them would most likely be saline. This is supported by the hydrostatic gradient in Dakota and Morrison hydrocarbon reservoirs in and the presence of saline water in the Morrison Formation near Cisco. A search of the Utah Division of Water Rights data base indicates no water wells have been drilled within a 5-mile radius of the project site. 1 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Ground Water Quality Ground Water Classification As indicated by the site geology and hydrogeology above, the presence of at least 900 feet of Mancos Shale coupled with the absence or poor quality of shallow ground water beneath the site indicate a very low risk and low vulnerability to ground water quality. The site is assigned Class IV Protection Levels based on the lack of a shallow aquifer and the characteristics of the Mancos Shale. Class IV Protection Levels In accordance with UAC R317-6-4.7, Class IV ground water protection levels are established to protect human health and the environment. Best Available Technology (BAT) The composite liner system consists of a 6-inch clay underliner with a permeability of IxlO"5 cm/sec overlain by a 60-mil HDPE primary synthetic liner. Although the permeability of the clay underliner is an order of magnitude greater than the DWQ municipal lagoon clay liner specification, the primary liner is a 60-mil HDPE instead of the typical 40-mil HDPE synthetic liner. In addition to the safety factor provided by the 60-mil primary liner, a leak detection system has been installed. The ponds are slightly sloped at a minimum of 0.4% with a gravel/pipe trench leak detection system at the low end of each pond under the clay and FML liners. A riser access pipe from the trench is used for leak detection sump inspection. A perimeter berm was also constructed to prevent any surface water from entering or leaving the Phase 2 complex. BAT Performance Monitoring Source Water Monitoring Non-hazardous low and high salinity fluids will be placed into the ponds and evaporated. Regular pond water sample collection is not a condition of this permit. However, the operator will obtain laboratory analyses of any proposed discharge water of unknown character prior to placement into the ponds. Excepting dissolved metals in water, hazardous or radioactive waste materials cannot be discharged into the Phase 2 ponds without a permit amendment, as these wastes are subject to other DEQ disposal regulations. Storage and evaporation of petroleum E&P wastes is limited to Phase 1 evaporation ponds under the jurisdiction of DOGM. Best Available Technology Monitoring BAT monitoring will include minimum vertical freeboard, leak detection sump monitoring, and maximum allowable head monitoring. These performance standards are based on the precedence of previous ground water discharge permits and Action Leakage Rates For Leak Detection Systems (EPA, January 1992). Minimum Vertical Freeboard A minimum of 36 inches of vertical freeboard shall be maintained to ensure total containment of untreated mine water and filter backwash. Leak Detection Sump Monitoring Monitoring of the sumps w ill be conducted on a monthly basis throughout the term of the permit. Detection of any sump fluids will be recorded and reported. 2 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Maximum Allowable Head Any fluids collected in the leak detection sump will be pumped back to the evaporation pond so that the water level in the leak detection sump is always less than one foot. In the event that the leak detection system has flows or heads that exceed the BAT performance standards of the permit, a BAT failure exists and the permittee will be required to regain BAT by a number of solutions including identifying and repairing the liner leak. Potential Impacts to Ground Water Potential impacts to ground water have been minimized by employing best available technology for the Evaporation Ponds. The Division of Water Quality will provide periodic onsite inspections during construction and operation of the facilities described above. The BAT performance monitoring plan, which the permittee is required to be submitted to the Director, will ensure that the facility is operated in accordance with design specifications and will also ensure that any indications of facility problems will be detected early and resolved. Compliance Schedule Items BAT Performance Monitoring Plan The Permittee shall submit a BAT monitoring plan to the Director and secure approval of the plan. The plan will include all procedures and methods sufficient to ensure compliance with the BAT performance standards of Part I.D.3 of the permit, including minimum vertical freeboard of the ponds, maximum allowable leakage rate and maximum allowable head for the Evaporation Pond leak detection system. The approved document will become an enforceable Appendix C to this permit. Reference Cited: R.D. Hettinger and Mark A. Kirschbaum, 2003, Stratigraphy of the Upper Cretaceous Mancos Shale (Upper Part) and Mesaverde Group in the Southern Part of the Uinta and Piceance Basins, Utah and Colorado, Chapter 12 of U.S. Geological Survey Digital Data Series DDS-69-B http://pubs.usgs.gov/dds/dds-069/dds-069-b/REPORTS/Chapter_12.pdf 3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 F STATE OF UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER QUALITY WATER QUALITY BOARD P.O. BOX 144870 SALT LAKE CITY, UTAH 84114-4870 Ground Water Discharge Permit Permit No. UGW190002 In compliance with the provisions of the Utah Water Quality Act, Title 19, Chapter 5, Utah Code Annotated 1953, as amended, the Act, hereafter referred to as the Permittee, is granted a Ground Water Discharge Permit for a fluids disposal facility for evaporation of wastewater in Grand County, Utah. The evaporation pond facility is located at Latitude 39° 04' 36.44" North, Longitude 109° 17* 28.69" West on the following tracts of land (Salt Lake Base and Meridian): This permit is based on representation made by the Permittee and other information contained in the administrative record. It is the responsibility of the Permittee to read and understand all provisions of this permit. The facility shall be constructed and operated in accordance with conditions set forth in the permit and the Utah Administrative Rules for Ground Water Quality Protection (UAC R317-6). Danish Flats Environmental Services 4775 Larimer Parkway, Suite 200 Johnstown, CO 80534 in Section 8, Township 20 South, Range 24 East in Grand County, Utah Leah Ann Lamb Acting Director Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 TABLE OF CONTENTS TABLE OF CONTENTS ii PART I SPECIFIC CONDITIONS 1 A. Ground Water Classification 1 B. Background Ground Water Quality 1 C. Ground Water Protection Levels 1 D. Best Available Technology (BAT) Standard 1 F. Non-Compliance Status 3 G. Reporting Requirements 4 H. Compliance Schedule 4 PART II MONITORING, RECORDING AND REPORTING REQUIREMENTS 6 A. Representative Sampling 6 B. Analytical Procedures 6 C. Penalties for Tampering 6 D. Reporting of Monitoring Results 6 E. Compliance Schedules 6 F. Additional Monitoring by the Permittee 6 G. Records Contents 6 H. Retention of Records 6 I. Twenty-four Hour Notice of Noncompliance Reporting 7 J. Other Noncompliance Reporting 7 K. Inspection and Entry 7 PART III COMPLIANCE RESPONSIBILITIES 8 A. Duty to Comply 8 B. Penalties for Violations of Permit Conditions 8 C. Need to Halt or Reduce Activity not a Defense 8 D. Duty to Mitigate 8 E. Proper Operation and Maintenance 8 PART IV GENERAL REQUIREMENTS 9 A. Planned Changes 9 B. Anticipated Noncompliance 9 C. Permit Actions 9 D. Duty to Reapply 9 E. Duty to Provide Information 9 F. Other Information 9 G. Signatory Requirements 9 H. Penalties for Falsification of Reports 10 I. Availability of Reports 10 J. Property Rights 10 K. Severability 11 L. Transfers 11 M. State Laws 11 N. Reopener Provision 11 ii Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Parti Permit No. UGW 190002 PART I SPECIFIC CONDITIONS A. GROUND WATER CLASSIFICATION Based on information submitted in the permit application, ground water at the Danish Flats Environmental Services evaporation pond site is defined as Class IV Saline Ground Water. B. BACKGROUND GROUND WATER QUALITY There are no shallow, continuous, permeable aquifers in the Mancos Shale underlying the site. The presence of at least 900 feet of Mancos Shale, coupled with the absence or poor quality of shallow ground water beneath the site, indicate a very low vulnerability and low risk to ground water quality. C. GROUND WATER PROTECTION LEVELS The site is assigned Class IV Protection Levels based on the lack of a shallow aquifer and the characteristics of the Mancos Shale. In accordance with UAC R317-6-4.7, Class IV ground water protection levels are established to protect human health and the environment. D. BEST AVAILABLE TECHNOLOGY (BAT) STANDARD 1. Authorized Construction - The Danish Flats Environmental Services site is designed and operated as a non-discharging facility. Six ponds constructed during Phase 2 are authorized by this permit. Each pond is approximately 5.5 acres in size (600ft x 400 ft). Ancillary features permitted by rule: six concrete acceptance pits and one sludge pond. 2. Design and Construction - The composite liner system for each pond consists of a 6-inch clay underliner, a 60-mil HDPE primary synthetic liner, and leak detection sump. Approved construction elements include: a. Subgrade Preparation - the subgrade has been scarified and recompacted to 95% on the Standard Proctor Scale (ASTM D698) prior to clay placement. b. Clay underliner - the clay underliner is 6 inches thick and has a compacted permeability of lxl 0"5 cm/sec. c. 60-mil HDPE Primary Liner - a 60-mil high density polyethylene liner is installed immediately above the clay subliner in accordance with the construction quality assurance/quality control manual approved by the Construction Permit. d. Leak Detection Sump - The pond bases are slightly sloped at a minimum of 0.4% and a gravel filled leak detection sump is constructed beneath the lowest section of each evaporation pond under the primary HDPE liners and clay underliner. A riser access pipe allows sump water detection measurements and samples to be collected if any leakage is detected in the sump. 1 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Parti Permit No. UGW 190002 h. Perimeter Berm - a secondary containment berm was constructed above surrounding grade along the low end of the Phase 2 ponds (southeast side) to contain the catastrophic failure of one pond volume (20 acre- feet). 3. BAT Performance Monitoring - Best available technology monitoring will include minimum vertical freeboard, maximum allowable leakage rate, and maximum allowable head monitoring. These performance standards are based on the precedence of previous ground water discharge permits and Action Leakage Rates for Leak Detection Systems (EPA, January 1992). a. Minimum Vertical Freeboard - a minimum of 36 inches of vertical freeboard shall be maintained to ensure total containment of the evaporation/surge pond and peripheral ditches. b. Maximum Allowable Leakage Rate - the maximum allowable leakage rate through the primary HDPE liner of an evaporation pond is 200 gallons per acre per day. The allowable leakage rate per pond is shown in Table 1. Table 1: Allowable Construction Phase 2 ,eakage Rate (ALR) Approximate Liner area (acres) per pond 5^5 Allowable Leakage Rate per pond (gallons per day) uoo Any fluids collected in the leak detection sump will be removed and placed back into the pond. c. Maximum Allowable head in any pond sump is 1.0 foot. 4. Spill Containment - The permittee shall maintain all pipelines, delivery pads, storage tanks, and pond facilities with a spill containment system that shall: a. Prevent any spills or leakage from any contact with the ground surface or ground water. b. Convey all spills or leakage to an evaporation pond. Any spill that does come into contact with the ground surface or ground water that causes pollution or has the potential to cause pollution to waters of the state shall be reported in accordance with Part 11.1. 5. Monitoring Well Construction - Monitoring wells are not a permit compliance requirement as there is no shallow groundwater underlying the site. 2 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Parti Permit No. UGW 190002 E. Compliance Monitoring Requirements Non-hazardous low and high salinity fluids will be placed into the ponds and evaporated. Regular pond water sample collection is not a condition of this permit. However, the operator will obtain laboratory analyses of any proposed discharge water of unknown character prior to placement into the ponds. Excepting dissolved metals in water, hazardous or radioactive waste materials cannot be discharged into the Phase 2 ponds without a permit amendment, as these wastes are subject to other Utah Department of Environmental Quality (DEQ) disposal regulations. Storage and evaporation of petroleum E&P wastes is limited to Phase 1 evaporation ponds under the jurisdiction of the Utah Division of Oil, Gas, and Mining (DOGM). 1. Weekly Leak Detection Monitoring a. Fluid Measurement - the leak detection sump will be monitored weekly for the presence of fluids. b. Sampling if Fluids Present - if fluids are detected in the leak detection sump, the permittee will either collect samples or measure conductivity to determine the source of fluid. F. NON-COMPLIANCE STATUS 1. Probable Out-of-Compliance Status - The permittee shall evaluate results of each leak detection sampling event to determine any exceedence of the Allowable Leakage Rate found in Table 1 above. Upon determination that an allowable leakage rate has been exceeded at any leak detection sump, the permittee shall: a. Pump fluids from the sump and determine the leakage rate from the pond. 2. Out-of-Compliance Based Upon Failure To Maintain Best Available Technology a. Out of Compliance Status shall be defined as follows: 1) Exceeding the allowable leakage rate (ALR) for a consecutive period of 30 days. b. Notification and Accelerated Monitoring - In the event that BAT monitoring indicates a violation of any of the construction or performance standards outlined in Part I.D of this permit, the permittee shall submit to the Director both verbal and written notification and description of the violation in accordance with Part 11.1 of this permit. 1) Increase leak detection monitoring frequency of the non-compliant pond/sump until the facility is brought into compliance as determined by the Director. c. Source Assessment Study Plan - within 30 days after the written notice to the Director required in Part I.F.2.b above, the permittee shall submit an assessment study plan and compliance schedule for: 3 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Parti Permit No. UGW 190002 1) Assessment of the source or cause of the leakage, and determination of steps necessary to correct the source. 2) Assessment of the extent of any potential dispersion in the underlying soil. 3) Evaluation of potential remedial actions to restore the pond to compliance. G. REPORTING REQUIREMENTS 1. Leak Detection Sump Monitoring - monitoring required in Part I.E.2 above shall be reported according to the schedule in Table 2 below, unless modified by the Director: Table 2: Compliance Monitoring Report Schedule Quarter Report Due Date 1st (January, February, March) April 30th 2nd (April, May, June) July 31st 3rd (July, August, September) October 31st 4th (October, November, December) January 31st 2. Leak Detection Sump Monitoring- reporting will include: a. Presence or absence of fluid in the leak detection sumps. b. Volume of fluid in a leak detection sump, if present. c. Depth of fluid in a leak detection sump, if present. c. Results of sampling and analysis of fluid collected for compliance or leak assessment purposes. d. The disposition of any fluids in a leak detection sump. e. The volume of fluid remove from the leak detection sumps. 3. Electronic Filing Requirements - In addition to submittal of the hard copy data, above, the permittee will electronically submit the required ground water monitoring data in the electronic format specified by the Director. The data may be submitted by e-mail, compact disc, or other approved transmittal mechanism. H. COMPLIANCE SCHEDULE 1. Submit a Leak Detection Manual for Phase 2 Ponds that describes the physical features, operation, monitoring, and maintenance of the ponds and leak detection system. This manual is due within 90 days after permit issuance. 2. Final Closure Plan. In the event that the permittee decides to discontinue its operations at the facility the permittee shall notify the Director of such a decision 4 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Part I Permit No. UGW 190002 3. Duty to Reapply. 180 days prior to permit expiration, an application for the ground water discharge permit renewal is due. The application notice will include an updated operational plan describing the proposed operational and closure activities expected to occur in the next five-year term of the permit. 5 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Part II Permit No. UGW 190002 PART II A B. C. D E. F. G MONITORING, RECORDING AND REPORTING REQUIREMENTS REPRESENTATIVE SAMPLING Samples taken in compliance with the monitoring requirements established under Part I shall be representative of the monitored activity. ANALYTICAL PROCEDURES Water sample analysis must be conducted according to test procedures specified under UAC R317-6-6.3.L, unless other test procedures have been specified in this permit. PENALTIES FOR TAMPERING The Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than six months per violation, or by both. REPORTING OF MONITORING RESULTS Monitoring results obtained during each reporting period specified in the permit, shall be submitted to the Director, Utah Division of Water Quality at the following address no later than the 15th day of the month following the completed reporting period: Attention: Ground Water Protection Section Department of Environmental Quality Division of Water Quality P.O. Box 144870 Salt Lake City, Utah 841 14-4870 COMPLIANCE SCHEDULES Reports of compliance or noncompliance with, or any progress reports on interim and final requirements contained in any Compliance Schedule of this permit shall be submitted no later than 14 days following each schedule date. ADDITIONAL MONITORING BY THE PERMITTEE If the permittee monitors any pollutant more frequently than required by this permit, using approved test procedures as specified in this permit, the results of this monitoring shall be included in the calculation and reporting of the data submitted. Such increased frequency shall also be indicated. RECORDS CONTENTS Records of monitoring information shall include: 1. The date, exact place, and time of sampling or measurements: 2. The individual(s) who performed the sampling or measurements; 3. The date(s) and time(s) analyses were performed; 4. The individual(s) who performed the analyses; 5. The analytical techniques or methods used; and, 6. The results of such analyses. RETENTION OF RECORDS The permittee shall retain records of all monitoring information, including all calibration and maintenance records and copies of all reports required by this permit, and records of all data used to complete the application for this permit, for a period of at least three years 6 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Part II Permit No. UGW 190002 from the date of the sample, measurement, report or application. This period may be extended by request of the Director at any time. I. TWENTY-FOUR HOUR NOTICE OF NONCOMPLIANCE REPORTING 1. The permittee shall verbally report any noncompliance which may endanger public health or the environment as soon as possible, but no later than 24 hours from the time the permittee first became aware of the circumstances. The report shall be made to the Utah Department of Environmental Quality 24 hour number, (801) 536-4123, or to the Division of Water Quality, Ground Water Protection Section at (801) 536-4300, during normal business hours (Monday through Friday 8:00 am - 5:00 pm Mountain Time). 2. A written submission shall also be provided to the Director within five days of the time that the permittee becomes aware of the circumstances. The written submission shall contain: a. A description of the noncompliance and its cause; b. The period of noncompliance, including exact dates and times; c. The estimated time noncompliance is expected to continue if it has not been corrected; and, d. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance. 3. Reports shall be submitted to the addresses in Part II.D, Reporting of Monitoring Results. J. OTHER NONCOMPLIANCE REPORTING Instances of noncompliance not required to be reported within 24 hours, shall be reported at the time that monitoring reports for Part II.D are submitted. K. INSPECTION AND ENTRY The permittee shall allow the Director, or an authorized representative, upon the presentation of credentials and other documents as may be required by law, to: 1. Enter upon the permittee's premises where a regulated facility or activity is located or conducted, or where records must be kept under the conditions of the permit; 2. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit; 3. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this permit; and, 4. Sample or monitor at reasonable times, for the purpose of assuring permit compliance or as otherwise authorized by the Act, any substances or parameters at any location. 7 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Part III Permit No. UGW 190002 PART III COMPLIANCE RESPONSIBILITIES A. DUTY TO COMPLY The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The permittee shall give advance notice to the Director of any planned changes in the pemiitted facility or activity which may result in noncompliance with permit requirements. B. PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS The Act provides that any person who violates a permit condition implementing provisions of the Act is subject to a civil penalty not to exceed $10,000 per day of such violation. Any person who willfully or negligently violates permit conditions is subject to a fine not exceeding $25,000 per day of violation. Any person convicted under Section 19-5-115(2) of the Act a second time shall be punished by a fine not exceeding $50,000 per day. Nothing in this permit shall be construed to relieve the permittee of the civil or criminal penalties for noncompliance. C. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. D. DUTY TO MITIGATE The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment. E. PROPER OPERATION AND MAINTENANCE The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. 8 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Part IV Permit No. UGW 190002 PART IV GENERAL REQUIREMENTS A. PLANNED CHANGES The permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions to the permitted facility. Notice is required when the alteration or addition could significantly change the nature of the facility or increase the quantity of pollutants discharged. B. ANTICIPATED NONCOMPLIANCE The permittee shall give advance notice of any planned changes in the permitted facility or activity which may result in noncompliance with permit requirements. C. PERMIT ACTIONS This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes or anticipated noncompliance, does not stay any permit condition. D. DUTY TO REAPPLY If the permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the permittee must apply for and obtain a permit renewal or extension. The application should be submitted at least 180 days before the expiration date of this permit. E. DUTY TO PROVIDE INFORMATION The permittee shall furnish to the Director, within a reasonable time, any information which the Director may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. The permittee shall also furnish to the Director, upon request, copies of records required to be kept by this permit. F. OTHER INFORMATION When the permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted incorrect information in a permit application or any report to the Director, it shall promptly submit such facts or information. G. SIGNATORY REQUIREMENTS All applications, reports or information submitted to the Director shall be signed and certified. 1. All permit applications shall be signed as follows: a. For a corporation: by a responsible corporate officer; b. For a partnership or sole proprietorship: by a general partner or the proprietor, respectively. c. For a municipality, State, Federal, or other public agency: by either a principal executive officer or ranking elected official. 9 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Part IV Permit No. UGW 190002 2. All reports required by the permit and other information requested by the Director shall be signed by a person described above or by a duly authorized representative of that person. A person is a duly authorized representative only if: a. The authorization is made in writing by a person described above and submitted to the Director, and, b. The authorization specified either an individual or a position having responsibility for the overall operation of the regulated facility or activity, such as the position of plant manager, operator of a well or a well field, superintendent, position of equivalent responsibility, or an individual or position having overall responsibility for environmental matters for the company. (A duly authorized representative may thus be either a named individual or any individual occupying a named position.) 3. Changes to Authorization. If an authorization under Part IV.G.2 is no longer accurate because a different individual or position has responsibility for the overall operation of the facility, a new authorization satisfying the requirements of Part IV.G.2 must be submitted to the Director prior to or together with any reports, information, or applications to be signed by an authorized representative. 4. Certification. Any person signing a document under this section shall make the following certification: "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." H. PENALTIES FOR FALSIFICATION OF REPORTS The Act provides that any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this permit, including monitoring reports or reports of compliance or noncompliance shall, upon conviction be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than six months per violation, or by both. I. AVAILABILITY OF REPORTS Except for data determined to be confidential by the permittee, all reports prepared in accordance with the terms of this permit shall be available for public inspection at the offices of the Director. As required by the Act, permit applications, permits, effluent data, and ground water quality data shall not be considered confidential. J. PROPERTY RIGHTS The issuance of this permit does not convey any property rights of any sort, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of federal, state or local laws or regulations. 10 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Part IV Permit No. UGW 190002 K. SEVERABILITY The provisions of this permit are severable, and if any provision of this permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not be affected thereby. L. TRANSFERS This permit may be automatically transferred to a new permittee if: 1. The current permittee notifies the Director at least 30 days in advance of the proposed transfer date; 2. The notice includes a written agreement between the existing and new permittee containing a specific date for transfer of permit responsibility, coverage, and liability between them; and, 3. The Director does not notify the existing permittee and the proposed new permittee of his or her intent to modify, or revoke and reissue the permit. If this notice is not received, the transfer is effective on the date specified in the agreement mentioned in paragraph 2 above. M. STATE LAWS Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, penalties established pursuant to any applicable state law or regulation under authority preserved by Section 19-5-117 of the Act. N. REOPENER PROVISION This permit may be reopened and modified (following proper administrative procedures) to include the appropriate limitations and compliance schedule, if necessary, if one or more of the following events occurs: 1. If new ground water standards are adopted by the Board, the permit may be reopened and modified to extend the terms of the permit or to include pollutants covered by new standards. The permittee may apply for a variance under the conditions outlined in R317-6-6.4.D. 2. If alternative compliance mechanisms are required. 3. If monitoring data reveal the wastewater quality is different from that authorized by this permit. 11 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewals OWL Danish Flats SWD Oilfield Water Logistics 19 \ ATTACHMENT F COST ESTIMATE FOR CLOSURE & POST-CLOSURE Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 6/27/2018 OILFIELD WATER LOGISTICS 1 of 3 SITE NAME: OWL Danish Flats SWD - Evaporation Ponds 1-8 (Phase I Only) Plus Site Infrastructure SITE ADDRESS: County Road 181, Cisco, UT 84540 (Exit 214) Unit Quantity Subtotals 12 6,000 2,000 30.2 30.2 1 $ 89,527.01 1 $ 67,187.01 16 2,276,696 $ 3,760.00 12 3,413,424 $ 2,820.00 $ 160,474.02 1,948,800 $ 97,440.00 1,526,400 $ 76,320.00 $ 97,440.00 697 1,500 12 697 697 $ 45,597.87 1 60 $ 3,977.00 Item A.2.3 Subtotal Phase II: UDEQ-DWQ Remove Tanks and Treatment Equipment ls $ 31,592.00 $ 31,592.00 2018 quote from BCR. Includes transport, cleaning and disposal fees for 12 tanks. Phase I for Bonding $ 1,268.54 If Contaminated - Dispose of soil in approx. 9,408-ft2 pad @ 2 feet cy $ 46.07 $ 32,110.79 2018 Cubic yard cost for disposal at ECDC, Carbon County, UT Phase I Total Mobilization ls $ 625.00 $ 625.00 Mob from Grand Junction. 4. Monitoring Wells A.4.1 - Closure of Monitoring Wells Close 2 wells ft $ 7.85 $ 3,352.00 Existing wells. A.3.1 - Receiving & Treatment Tanks - 4 x Receiving Tanks (1,000-bbl), 1 x Flow Splitter (500-bbl), 2 x Gun Barrel Tanks (500-bbl), 1 x Slop Tank (400-bbl), 4 x Oil Tanks (400- bbl) Soil removal Restore area by tanks (est. 2 feet thick)cy $ 1.82 $ 1,268.54 Grading & Backfill. 3. Tanks and Piping Remove / place piping and blocks within pond bottom lf $ 5.50 $ 8,250.00 Estimated for manifold piping. A.3.2 - Piping Test soil sam $ 225.00 $ 2,700.00 Lab and collection cost. A.3.3 - Soil Under Tanks If Contaminated - Remove soil in approx. 9,408-ft2 pad @ 2 feet cy $ 1.82 Phase I for Bonding Phase I Total Lab and collection cost estimate. Natural evaporation for 5 years. Item A.1.5 Subtotal Phase II: UDEQ-DWQ Item A.2.2 Subtotal Phase I for Bonding A.2.1 - Settlement Pond x One (1) (Reclaimed) A.2.2 - Evaporation Ponds x Eight (8) (Phase I: Ponds 1-8 - 600 x 400 x 10) Reclaimed on March 29, 2017. Cut and fold 60ml geomembrane liner in ponds sf $ 0.05 Phase I Total 2. Geomembrane Liner A.1.5 - Evaporation Ponds x Six (6) (Phase II: Ponds 9-14 - 600 x 400 x 20) Test sediment $ 235.00 $ 2,820.00 Evaporate water at 100% (working level of 18')bbl $ - $ - If Contaminated - Dispose of Sediment cy $ 46.07 $ 1,389.01 Item A.1.4 Subtotal 2018 Cubic yard cost for disposal at ECDC, Carbon County, UT Evaporate water at 100% (working level of 8')bbl $ - $ - Natural evaporation for 5 years. Phase I for Bonding A.1.3 - Settlement Pond x One (1) (Reclaimed) Reclaimed on March 29, 2017. Test sediment sam $ 235.00 $ 3,760.00 Lab and collection cost estimate. A.1.4 - Evaporation Ponds x Eight (8) (Phase I: Ponds 1-8 - 600 x 400 x 10) Item A.1.1 Subtotal bbl $ 25.00 $ 50,000.00 From Integrated Water Management and assumes no sale value. If Contaminated - Remove sediment (est. 6" thick)cy $ 40.00 $ 1,206.00 Remove and pump sediment from tanks. Cost Estimate for Closure & Post-Closure Version: 06/27/2018 Item Unit Unit Cost Item Cost Notes A. DEWATERING AND REMOVING OF STRUCTURES 1. Remove Water and Sediment (stabilize in place, if not contaminated) Test sediment sam $ 235.00 $ 2,820.00 Lab cost plus 1/2 hour. Transfer water to ponds for evaporation bbl Phase I Item A.1 Subtotal $ 0.42 $ 2,520.00 Pump from tanks to ponds. A.1.1 - Receiving & Treatment Tanks - 4 x Receiving Tanks (1,000-bbl), 1 x Flow Splitter (500-bbl), 2 x Gun Barrel Tanks (500-bbl), 1 x Slop Tank (400-bbl), 4 x Oil Tanks (400- bbl) Transport and Dispose of Slop Oil and Condensate Phase I Item A.2 Subtotal Phase I Item A.3 Subtotal Phase I Item A.4. Subtotal A.1.2 - Site Office Office demolishing. Tear down of all tin, metai, interior, concrete, and the capping of all utility lines. Includes trucking and disposal of all debris. ls $ 33,000.00 $ 33,000.00 Quote from Two in the Loop, Grand Junction, CO. Item A.1.2 Subtotal Phase I for Bonding A.2.3 - Evaporation Ponds x Six (6) (Phase II: Ponds 9-14 - 600 x 400 x 20) Cut and fold 60ml geomembrane liner in ponds sf $ 0.05 $ 76,320.00 Labor for cutting and folding liner in- place. $ 97,440.00 Labor for cutting and folding liner in- place. sam Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 6/27/2018 OILFIELD WATER LOGISTICS 2 of 3 SITE NAME: OWL Danish Flats SWD - Evaporation Ponds 1-8 (Phase I Only) Plus Site Infrastructure SITE ADDRESS: County Road 181, Cisco, UT 84540 (Exit 214) Unit Quantity Subtotals Cost Estimate for Closure & Post-Closure Version: 06/27/2018 Item Unit Unit Cost Item Cost Notes $ 307,488.89 1 625,784 6,751,800 $ 1,449,628.88 1 821,334 6,316,200 $ 1,788,105.88 $ 1,449,628.88 155.0 $ 275,974.40 145.0 $ 258,169.60 $ 275,974.40 $ 1,725,603.28 0 $ - A to C CONSTRUCTION COST SUBTOTAL $ 2,033,092.17 5 40 1 $ 26,000.00 4 40 1 $ 23,500.00 $ 26,000.00 $ 26,000.00 $ 2,059,092.17 $ 2,265,001.39 day $ 2,500.00 $ 10,000.00 Estimated. * Surveying (as-built final)hrs $ 200.00 $ 8,000.00 Estimated. Seeding, topsoil and hydro-mulch ac $ 1,780.48 Item B.2.2 Subtotal Phase II: UDEQ-DWQ Phase I Bonding Item B.1.2 Subtotal Phase II: UDEQ-DWQ $ 258,169.60 2. Re-Vegetation: Includes Tank Battery, Office, Ponds, Road & Berms Seeding, topsoil and hydro-mulch ac $ 1,780.48 Item B.2.1 Subtotal Phase I for Bonding B.2.2 - Phase II: Re-Vegetation (seeding & topsoil) - Pond Area & Road/Berms $ 275,974.40 RS Means & Bids. B.2.1 - Phase 1: Re-Vegetation (seeding & topsoil) - Pond Area & Road/Berms cy $ 1.82 $ 1,494,827.88 RS Means & Bids. Final Grading and Surface sf $ 0.04 $ 252,648.00 RS Means & Bids. Final Grading and Surface sf $ 0.04 $ 270,072.00 RS Means & Bids. A. REMOVAL/DISPOSAL SUBTOTAL B.1.1 - Phase I: Includes tank area, off loading system, 8 ponds with dikes and road. Phase I for Bonding CLOSURE COST ESTIMATE TOTAL (A - E) A - E COST D. ENGINEERING MANAGEMENT SUBTOTAL E. CLOSURE COST CONTINGENCIES * CONTINGENCY (10%) $ 205,909.22 10% * Surveying (as-built final)hrs $ 200.00 $ 8,000.00 Estimated. Phase I Bonding * Cert. Report Closure (letter)LS $ 5,500.00 $ 5,500.00 Estimated. Item D.1.1 Subtotal Phase I for Bonding D.1.2 - Phase II - Engineering * Construction Inspection/Oversight (not full time) * Cert. Report Closure (letter)LS $ 5,500.00 $ 5,500.00 Estimated. Item D.1.2 Subtotal Phase II for Bonding D. ENGINEERING MANAGEMENT * Construction Inspection/Oversight (not full time)day $ 2,500.00 $ 12,500.00 Estimated. 1. Engineering D.1.1 - Phase I - Engineering C. MISCELLANEOUS 1. Miscellaneous Inventory C.1.1 - Miscellaneous A - C COST (PHASE I ONLY) Miscellaneous $ - $ - C. MISCELLANEOUS SUBTOTAL Phase I RS Means & Bids. B. RESTORATION SUBTOTAL Mobilization ls $ 40,630.00 $ 40,630.00 RS Means. Excavate and place soil on-site cy $ 1.82 $ 1,138,926.88 RS Means & Bids. Item B.1.1 Subtotal Phase I for Bonding B.1.2 - Phase II: Includes 6 ponds with dikes Mobilization ls $ 40,630.00 $ 40,630.00 RS Means. Excavate and place soil on-site B. RESTORATION 1. Place Fill & Grade Phase I Item B.1 Subtotal Phase I Item B.2 Subtotal Phase I Item D.1 Subtotal Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 6/27/2018 OILFIELD WATER LOGISTICS 3 of 3 SITE NAME: OWL Danish Flats SWD - Evaporation Ponds 1-8 (Phase I Only) Plus Site Infrastructure SITE ADDRESS: County Road 181, Cisco, UT 84540 (Exit 214) Unit Quantity Subtotals Cost Estimate for Closure & Post-Closure Version: 06/27/2018 Item Unit Unit Cost Item Cost Notes 10 $ 248,764.55 $ 2,513,765.94 COSTS ARE IN 2018 DOLLARS:As of June 27, 2018 PRIOR APPROVED AMOUNT: PHASE I BONDING INCREASE & RIDER AMOUNT: DECREASE & RIDER AMOUNT: SITE NAME: OWL Danish Flats SWD SITE ADDRESS: County Road 181, Cisco, UT 84540 (Exit 214) REVISED: Revised 06/27/2018 2 16 110 1 2 2 2 3 8 3 2 $ 3,631.70 9 $ 18,000.00 $ 21,631.70 $ 3,244.76 $ 24,876.46 TOTAL ESTIMATED ITEM F. TOTAL Principal Engineer Project Manager Project Professional II Draftsman Clerical 2,513,765.94$ ITEM F. SUBTOTAL 15% CONTINGENCY Hour Hour Hour Hour Item Subtotal Acre $ 351.00 $ 840.00 $ 225.00 $ 104.00 $ 117.00 $ 105.00 $ 75.00 $ 52.00 Item Subtotal $ 18,000.00 2 monitoring wells, annual. F.1.1 - Groundwater Sampling & Site Review Includes mob/demob Method 8015 TPH-D, TPH-G, chlorides, total dissolved solids (TDS), and sulfates. Project Manager Sampling Technician Mileage Per Diem Sampling Supplies Groundwater Analyses Mile Day $ 149.50 $ 234.00 $ 1,024.00 Each Each $ 117.00 $ 64.00 $ 0.57 F.1.2 - Annual Report Hour Hour $ 12.00 $ 2,000.00 F.1.3 - POST-CLOSURE MAINTENANCE Repair Erosion and Vegetation Assumes 3% of total area of 300 acres per year $ 62.70 $ 160.00 $ 24.00 $ 299.00 $ 160.00 $ 154.00 Hour $ 308.00 Phase I A - F COST F. POST-CLOSURE MONITORING & MAINTENANCE 1. Monitoring & Reporting 2,633,560.00$ 119,794.06$ CLOSURE COST ESTIMATE TOTAL (A - F) YR $ 24,876.46 $ 248,764.55 5 YEARS PLUS 5 YEARS FOR 2 WELLS F. POST-CLOSURE MONITORING & MAINTENANCE Maintenance COSTS IN 2018 USD Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewals OWL Danish Flats SWD Oilfield Water Logistics 20 ATTACHMENT G NRCS SEEDING RECOMMENDATIONS Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Natural Resources Conservation Service 125 South State St., Room 4010, Salt Lake City, UT 84138 Voice 801 524-4550 Fax 801 524 4403 An Equal Opportunity Provider and Employer May 9, 2016 Seth Peters Safety Manager OWL SWD Operating, LLC Johnstown, Regional Office PO Box 670 Windsor, CO 80550 (970)775-8100 Mr. Peters, The seeding specification for the OWL Danish Flats SWD Sludge Pond Closure Plan is attached. Also attached are two supporting documents, the soil report and the ecological site description. From our phone conversation, I understand that soil from onsite will be used to cap an area of approximately 10 acres to a depth of 2 feet: one foot of compacted clay and one foot of topsoil, stockpiled from previous excavations at the site. The soil (Mack Loam) contains the following layers: A1 - 0 to 3 inches: loam B2t - 3 to 11 inches: clay loam B3tca - 11 to 16 inches: silt loam C1ca,C2 - 16 to 33 inches: fine sandy loam C3 - 33 to 60 inches: silt loam Presumably, the topsoil (consisting of loam and clay loam) was stockpiled separately, and the lower one foot of the cap will be a mixture of the remaining lower layers. It is questionable whether there will be sufficient clay content to create an impermeable compacted layer from this material. Leaving the material uncompacted will aid in plant persistence and growth. The species recommended in the seeding specification were chosen from a list of plants that are able to grow in 5-8 inches of precipitation, with a soil pH range of 7.9-8.4, are readily available on the commercial market, are useful for alleviating erosion by wind or water, and have a high to moderate seedling vigor. The ecological site description (Desert Loam (shadscale)) was used to further select plants that are native and suited for this specific location. In addition, the nonnative plants Siberian wheatgrass and forage kochia were added to the list for their ability to establish and grow in the severe climate conditions at the site. Specific recommendations for seeding these species are on the specification sheet. In addition to the seeding, I am offering the following alternatives for you to consider to improve the odds of plant establishment and persistence on the challenging site. Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Natural Resources Conservation Service 125 South State St., Room 4010, Salt Lake City, UT 84138 Voice 801 524-4550 Fax 801 524 4403 An Equal Opportunity Provider and Employer • Straw mulch, crimped into the soil with a disc or coulter (not offset), to provide shade and wind protection to the seedlings. The straws crimped into the soil will help any precipitation that falls infiltrate the soil, and will also help prevent wind erosion during establishment. This would be applied following the seeding. • Continuity modifiers placed at intervals across the site would help create micro environments conducive to seedling establishment, and prevent wind erosion. These can be thought of as small windbreaks. They could be made from many different materials such as straw bales or hardware cloth, and their spacing would typically be 6 to 10 times their height. • Temporary sprinkler irrigation to ensure seeds will germinate and establish could be applied. There are companies that rent irrigation equipment. A water source at the site would be a necessary requirement if this alternative is chosen. Once the plants advance their growth beyond the critical seedling stage with root systems that reach deep into the soil, the species recommended will be able to persist without irrigation after one or two growing seasons. • Containerized 4-wing saltbush plants are available from conservation nurseries. Planting seedlings directly, with the aid of water supplying aids such as DriWater, may increase the establishment of this shrub that will ultimately be important for protecting the site from wind erosion. Spacing of the plants would be on a grid with about 25 feet between plants. I hope you find this recommendation useful. Shane Green NRCS Utah State Rangeland Specialist 435-901-1124 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Name: Date: MLRA Purpose(s): Total PLS Date: Depth: D34 Ecological Site: Desert Loam (Shadscale) If Yes, Who with & When: VavilovII 10 Tract:Field:Slope: 0-4%Elevation:4625 Location: Mack Loam Acres: Planned by:S. Green Erosion Potential: High Wildlife: Stabilize areas with existing or expected high rates of soil erosion Livestock: Grazing should be in accordance with Prescribed Grazing (528) specifications. Weeds, insects, and/or diseases should be controlled through mowing, burning, flash grazing, or pesticides as needed to maintain a healthy stand. Where stands are damaged by drought, insects, or other uncontrollable events, the stand should be replanted, overseeded, or spot planted. Thin stands may only need grazing deferment during the growing season rather than replanting. Monitor seedling establishment for 3 years. Re-seed after 2 years in the case of a failure. Equipment: Rangeland Drill Notes: The recommendations shown above are for most of the seeds in the mix. The Indian ricegrass should be planted in a separate operation to a 2 inch depth. The Forage Kochia should be planted seperately via broadcast followed by a drag. 106Lbs of No.1 rice hulls needd to make 2 bushel per acre volume 10.57 Operation and Maintenance of Seeding After Establishment 20 4 Management During Plant Establishment 191 1.95 0.39 5.85 59 *Total Rate to be Seeded:19.11 Kochia, Forage Critical Area Planting (342) SPECIFICATION SHEET Oilfield Water Logisitcs c/o Seth Peters May 9, 2016 Precip: 8-May 7.80 2 78 29 0.20 Sec 8, T20s R24e near Cisco Soil(s): Method: Drill Wheatgrass, Siberian Immigrant A sludge pit will be capped with one foot of subsoil and one foot of topsoil stockpiled from previous excavations on site. Implements such as a cultipacker will be used to create a firm seedbed (a footprint should sink in less than 1/2 inch) Seed (lbs)Species VarietyOct 15 - Feb 25 Winterfat Saltbush, Fourwing Seedbed Preparation: Planting Information Squirreltail, bottlebrush0-1/8 inch DWR Consultation: 12 inchesSpacing: Ricegrass, Indian 2.93 PLS Rate (lbs/ac) USDA - NRCS - UTAH May 2016 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewals OWL Danish Flats SWD Oilfield Water Logistics 21 ATTACHMENT H SECTION R649-9-13 VARIANCE REQUEST – TRANSFER OF PHASE II Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 &ŽƌŝǀŝƐŝŽŶhƐĞKŶůǇ Compliance Review Completed: No outstanding compliance Active violation/compliance matter Signature: Comments &ŝǀĞzĞĂƌΘWtĂƐƚĞDisposal Facility Wermit Renewal Checkůisƚ WĞƌŵŝƚZĞŶĞǁĂůƉƉůŝĐĂƚŝŽŶ^ƵďŵŝƐƐŝŽŶ ^ƵďŵŝƚĂŶĂƐƐĞƐƐŵĞŶƚŽĨƐŝƚĞƌĞĐůĂŵĂƚŝŽŶƌĞƋƵŝƌĞŵĞŶƚƐĨƌŽŵĂĐĞƌƚŝĨŝĞĚ ƚŚŝƌĚƉĂƌƚǇĐŽŶƚƌĂĐƚŽƌZϲϰϵͲϵͲϴ͘Ϯ ^ƵďŵŝƚĐůŽƐƵƌĞĐŽƐƚĞƐƚŝŵĂƚĞƐĨƌŽŵĂĐĞƌƚŝĨŝĞĚƚŚŝƌĚƉĂƌƚǇĐŽŶƚƌĂĐƚŽƌ ZϲϰϵͲϵͲϴ͘Ϯ WƌŽǀŝĚĞďŽŶĚĂŵŽƵŶƚĂƉƉƌŽǀĞĚďǇƚŚĞŝǀŝƐŝŽŶZϲϰϵͲϵͲϴ ĞƚĂŝůĞĚ^ŝƚĞĞƐĐƌŝƉƚŝŽŶ &ƵŶĐƚŝŽŶŽĨƚŚĞǁĂƐƚĞĚŝƐƉŽƐĂůĨĂĐŝůŝƚǇ ƵƌƌĞŶƚĨĂĐŝůŝƚǇŵĂƉ ^ŝƚĞĚĞƐĐƌŝƉƚŝŽŶƐĂŶŶŽƚĂƚĞĚǁŝƚŚĨĂĐŝůŝƚǇŝŶĨƌĂƐƚƌƵĐƚƵƌĞĂŶĚĂƐƐŽĐŝĂƚĞĚĨƵŶĐƚŝŽŶ ŽŶƚĂŵŝŶĂƚŝŽŶƐƐĞƐƐŵĞŶƚ ĞƐĐƌŝƉƚŝŽŶŽĨĞǆŝƐƚŝŶŐĐŽŶƚĂŵŝŶĂƚŝŽŶǁŝƚŚƐĂŵƉůĞƌĞƐƵůƚƐ WƌŽƉŽƐĞĚŵŽŶŝƚŽƌŝŶŐͬƌĞŵĞĚŝĂƚŝŽŶ WƌŽƉŽƐĞĚƉƌĂĐƚŝĐĞƐƚŽƉƌĞǀĞŶƚĨƵƌƚŚĞƌĐŽŶƚĂŵŝŶĂƚŝŽŶ ƋƵŝƉŵĞŶƚƐƐĞƐƐŵĞŶƚ ĞƐĐƌŝƉƚŝŽŶĂŶĚĂƐƐĞƐƐŵĞŶƚŽĨĞƋƵŝƉŵĞŶƚůŽĐĂƚĞĚĂƚƚŚĞĨĂĐŝůŝƚǇ ĞƐĐƌŝďĞŝŶĚĞƚĂŝůƐĞƌǀŝĐĞůŝĨĞĨŽƌĞƋƵŝƉŵĞŶƚƵƐĞĚŝŶĨĂĐŝůŝƚǇŽƉĞƌĂƚŝŽŶƐĞƐĐƌŝƉƚŝŽŶŽĨƚĞƐƚŝŶŐ ĐŽŵƉůĞƚĞĚĨŽƌĞƋƵŝƉŵĞŶƚ;ƚĂŶŬƐ͕ƉŝƉŝŶŐ͕ůŝŶĞƌƐ͕ůĞĂŬĚĞƚĞĐƚŝŽŶĞƋƵŝƉŵĞŶƚ͕ĞǀĂƉŽƌĂƚŝŽŶĨĂŶƐͿ WƌĂĐƚŝĐĞƐƐƐĞƐƐŵĞŶƚ ƐƐĞƐƐŵĞŶƚŽĨŵĂŶĂŐĞŵĞŶƚƉƌĂĐƚŝĐĞƐƵƚŝůŝǌĞĚƚŽŽƉĞƌĂƚĞƚŚĞĨĂĐŝůŝƚǇ/ĚĞŶƚŝĨǇĂůƚĞƌŶĂƚŝǀĞ ƉƌĂĐƚŝĐĞƐǁŚŝĐŚĐŽƵůĚŝŵƉƌŽǀĞŽƉĞƌĂƚŝŽŶƐŽƌƌĞĚƵĐĞƉƌŽďĂďŝůŝƚǇŽĨĨƵƚƵƌĞĐŽŶƚĂŵŝŶĂƚŝŽŶ Name of &ĂĐŝůŝƚǇOperator: Name of &ĂĐŝůŝƚǇ͗ >ŽĐĂƚŝŽŶ͗ ĂƚĞ͗ WƌĞƉĂƌĞƌ͗ ĂƚĞ /ŶŝƚŝĂůƐ ĂƚĞ/ŶŝƚŝĂůƐ ZĞĐĞŝǀĞĚ ZĞǀŝĞǁĞĚ ZĞǀŝĞǁŽŵƉůĞƚĞĚ͗ƉƉůŝĐĂƚŝŽŶ^ƚĂƚƵƐ͗ WWZKs &ŽƌŝǀŝƐŝŽŶhƐĞKŶůǇĞůŽǁdŚŝƐ>ŝŶĞ OWL SWD Operating, LLC dba Oilfield Water Logistics OWL Danish Flats SWD County Road 181, Cisco, UT 84540 (Exit 214). T. 20 S, R. 24 E, Sec 8 06/27/18 CASE Associates, LLC ✔ Bart Kettle Digitally signed by Bart Kettle Date: 2018.12.28 17:43:24 -07'00' 06/28/18 BTK 12/28/18 BTK 06/28/18 BTK 12/28/18 BTK 06/28/18 BW 04/02/19 BW $ 2,200,000 Phase I DOGM. Phase II DEQ per permit renewal info- BTK 04/02/2019 DOGM Received renewed full cost bond amount of $2,633,560.BW Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o=DNR, ou=DOGM, email=daynedoucet@utah.gov, c=US Date: 2019.04.15 08:58:54 -06'00'✔ 12/28/18 BTK Description of process included. Engineer drawing provided. 12/28/18 BTK Reference barrier of Mancos shale, no ground water. Remediation of sludge pond 12/28/18 BTK Monthly Inspections. Service life 15-30 years for equipment and liners 12/28/18 BTK Automated system recently installed. Sundry Number: 95372 RECEIVED: Apr. 15, 2019 /ŶĨƌĂƐƚƌƵĐƚƵƌĞZĞŵŽǀĂůŽƐƚƐ Contouring or RegradingŽƐƚƐ SeediŶŐŽƐƚƐ Notes: ŽŶƚĂŵŝŶĂƚŝŽŶŽƐƚƐ ƐƚŝŵĂƚŝŶŐůŽƐƵƌĞŽƐƚĂŶĚŽŶĚŝŶŐǀĂůƵĂƚŝŽŶ ZĞŵŽǀĂůͬZĞŵĞĚŝĂƚŝŽŶ ^ĂŵƉůŝŶŐ WŽƐƚĐůŽƐƵƌĞŵŽŶŝƚŽƌŝŶŐ ǆƉĞŶƐĞƐƚŽƌĞŵŽǀĞĂůůŝŶĨƌĂƐƚƌƵĐƚƵƌĞĂŶĚĞƋƵŝƉŵĞŶƚ WƌŽũĞĐƚĞǆƉĞŶƐĞƚŽĐŽŶƚŽƵƌƐŝƚĞďĂĐŬƚŽŽƌŝŐŝŶĂůŐƌĂĚĞ sŽůƵŵĞƐŽĨŵĂƚĞƌŝĂů ƋƵŝƉŵĞŶƚĐŽƐƚƐ >ĂďŽƌĐŽƐƚƐ DĞƚŚŽĚŽĨƌĞƐĞĞĚŝŶŐ ^ƉĞĐŝĞƐƵƐĞĚĨŽƌƌĞǀĞŐĞƚĂƚŝŽŶ ĂƚĞ/ŶŝƚŝĂůƐ ZĞĐĞŝǀĞĚ Comments DŽŶŝƚŽƌŝŶŐWƌŽŐƌĂŵ ĞƚĂŝůĞĚĚĞƐĐƌŝƉƚŝŽŶŽĨŵŽŶŝƚŽƌŝŶŐƉƌŽŐƌĂŵƐŝŶƵƐĞŽƌďĞŝŶŐƉƌŽƉŽƐĞĚ;ǀŝƐƵĂůŝŶƐƉĞĐƚŝŽŶƐŽĨ ĞƋƵŝƉŵĞŶƚ͕ƉƌĞƐƐƵƌĞƚĞƐƚƐ͕ůĞĂŬĚĞƚĞĐƚŝŽŶƐǇƐƚĞŵƐ͕ǁĂƐƚĞĂĐĐŽƵŶƚĂďŝůŝƚǇ͕ĂƵƚŽŵĂƚĞĚƐǇƐƚĞŵƐ͕ ƉƌŽƉŽƐĞĚƉƌĂĐƚŝĐĞƐǁŚŝĐŚĐĂŶƌĞĚƵĐĞƚŚĞƌŝƐŬŽĨĨƵƚƵƌĞĐŽŶƚĂŵŝŶĂƚŝŽŶͿ 12/28/18 BTK Weekly leak detection monitoring. Weekly liner monitoring. Monthly tank monitoring. Reclamation area monitored quarterly. Quarterly ground water monitoring 04/02/19 BW 04/02/19 BW 04/02/19 BW 04/02/19 BW 04/02/2019 Phase I Ponds #1-8 DOGM administration/bonding. Phase II Ponds #9-14 UWDQ administration. Supporting info: Attachment F. Bond Estimate-Operator is choosing UDWQ administration for Phase II Ponds #9-14 Attachment H-Operator submitted Variance Request to transfer Phase II Ponds #9-14 UWDQ Attachment E-An e-mail Correspondence with UDWQ Dan Hall Attachment D UDWQ Ground Water Discharge Permit 10/9/2014 UDWQ Letter- Conversion Evaporation Pond use Utah Division of Water Quality oversight 07/1/2014 Bond for Phase I is set at $2,200,000.00. The operator has submitted full cost bonding for the facility at $2,633,560. BW COA's -Visual inspection of Equipment, tanks and liners on a monthly basis. Quarterly ground water monitoring conducted for at monitoring wells. -Phase I Ponds #1-8 are permitted to accept RCRA E&P exempt fluids. Sundry Number: 95372 RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 10 F. ESTIMATING CLOSURE COSTS & BONDING EVALUATION 1. Permitting & Current Bonding Presently the facility is bonded through DOGM. A unique situation exists where the Phase II ponds, numbers nine (9) to fourteen (14), are dual permitted to potentially accept two different waste streams. Under the DOGM permit the ponds are approved to receive E&P produced water. But Phase II also operates under the Utah Department of Environmental Quality, Division of Water Quality (UDWQ), Groundwater Discharge Permit, UGW190002, permitted to receive non-hazardous low and high salinity fluids (Attachment E). A condition of the UDWQ permit is that the storage and evaporation of petroleum E&P wastes is limited to Phase I evaporation ponds under the jurisdiction of DOGM. The facility has complied with this condition since issuance of the UDWQ permit on October 09, 2014. DOGM have requested that the 2018 permit renewal process eliminate the situation where the Phase II ponds are dual permitted. OWL have determined its preference to move forward and remove the Phase II ponds from DOGM bonding. Advice was obtained from UDWQ Manager, Dan Hall P.G., who advised via email the Utah DEQ/DWQ does not have bonding authority. Further the position of the UDWQ is that this part of the facility, referencing Phase II, does not allow for the acceptance of oil and gas waste and therefore does not fall under the DOGM’s jurisdiction (Attachment F). This application will therefore endeavor to outline a bonding scope for the facility excluding Phase II which will default to the UDWQ authority. A variance request, under R649-9-13, has been submitted with the application to formalize the modification (Attachment H). The facility has been constructed in phases since 2007. Oilfield Water Logistics assumed all liabilities regarding the bonds commencing October 20, 2014. A breakdown of the current bonding status, where DOGM have been named as the ‘Obligee,’ is outlined below: Table 1.3 Current Bonding Synopsis POND # DATE BONDED BOND # AMOUNT Separation Pond & Concrete Vaults Reclaimed March 29, 2017 Pond One (1) 12/13/2012 SUR0020547 $170,000.00 Pond Two (2) 12/13/2012 SUR0020546 $170,000.00 Pond Three (3) 12/13/2012 SUR0020545 $149,130.00 Pond Four (4) 12/13/2012 SUR0020544 $149,130.00 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Five Year E&P Waste Disposal Facility Permit Renewal OWL Danish Flats SWD Oilfield Water Logistics 11 2. Bonding for the Permit Renewal Process As previously outlined OWL Danish Flats SWD is located in section 8. When breaking the section to a quarter-quarter section and overlaying it to an aerial view of the facility a conservative calculation assumes that approximately 300 of the 640 acres has been disturbed (Appendix A – Figure 6). Relevant to this permit renewal application is the soil disturbance to Phase I. The bonded acreage includes the Phase I ponds, the tank battery, site office and offloading bays, soil stockpiles, internal facility roads, storm water channels, containment walls, the perimeter fence and the previously reclaimed separation pond. In total the soil disturbance to Phase I is approximately 155 acres. Bonding estimates have been calculated through reliance on RS Means as well as current proposals from contractors. The ‘Notes’ section of the ‘Cost Estimate for Closure & Post-Closure (Attachment H) provides a comment which outlines the source referenced to arrive at the bonding estimate for that particular line item. The line item estimates include labor and equipment unless otherwise stated. In respect to contamination. The bonding estimate has considered soil samples in two (2) separate locations at the base of each pond to assess for potential contamination. Those soil samples will be analyzed for TEPH, TVPH, EC, SAR and ESP. Pond Five (5) 12/13/2012 SUR0020543 $149,130.00 Pond Six (6) 11/06/2012 SUR0020536 $149,130.00 Pond Seven (7) 11/06/2012 SUR0020536 $149,130.00 Pond Eight (8) 11/06/2012 SUR0020536 $149,130.00 Pond Nine (9) 11/06/2012 SUR0020535 $233,130.00 Pond Ten (10) 11/06/2012 SUR0020534 $233,130.00 Pond Eleven (11) 11/06/2012 SUR0020533 $233,130.00 Pond Twelve (12) 12/13/2012 SUR0020548 $233,130.00 Pond Thirteen (13) 12/13/2012 SUR0020549 $233,130.00 Pond Fourteen (14) 11/06/2012 SUR0020550 $233,130.00 TOTAL $2,633,560.00 Sundry Number: 95372 File: Detailed Site Description RECEIVED: Apr. 15, 2019 1594 West North Temple, Suite 1210 • PO Box 145801 • Salt Lake City, UT 84114-5801 • Telephone (801) 538-5340 • www.ogm.utah.gov State of Utah SPENCER J. COX Governor DEIDRE M. HENDERSON Lieutenant Governor October 12, 2023 via email: eliteprotectivecoatings@gmail.com Jon Goza Danish Flats Waste Disposal, LLC 881 Baxter Drive South Jordan, UT 84095 SUBJECT: Danish Flats Waste Disposal, LLC Recognition as Operator of the Danish Flats Surface Facility Dear Mr. Goza, On September 11, 2023, the Division of Oil, Gas, and Mining (Division) transferred the Danish Flats surface facility from OWL SWD Operating, LLC to Danish Flats Waste Disposal, LLC. Danish Flats Waste Disposal, LLC has provided a full-cost bond to the Division for the Danish Flats surface facility; therefore, effective September 11, 2023, Danish Flats Waste Disposal, LLC may operate the facility as permitted. If you have any questions, please contact Rachel Medina at (385) 249-0126 or rachelmedina@utah.gov. Sincerely, Rachel Medina Bonding Technician Department of Natural Resources Division of Oil, Gas and Mining JOEL FERRY Executive Director JOHN R. BAZA Division Director