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HomeMy WebLinkAboutDSHW-2024-009388State 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:Sand Pass Ranch Facility Type: Commercial Waste Disposal Facility Location: Section 9, Township 4S, Range 1W County:Duchesne Approval Date:December 17, 2018 1. Issued to: Western Water Solutions LLC 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 Western Water’s “Permit Renewal Application” dated 10/1/2018 and received by the Division on 10/1/2018, (“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 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 Sand Pass Ranch 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: 2018.12.21 13:25:27 -07'00' 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 New front end shall be installed and operational by 12/31/2019. 1.8 Existing skim ponds shall be reclaimed by 12/31/2019. 2. Landfarms 2.1 E and P waste accepted by the landfarm shall be sufficiently free of liquid content to pass a 60-mesh liquid paint filter test (i.e., no produced water or drilling mud). 2.2 Pooling of liquids in the landfarm is prohibited. 2.3 Within 72 hours after receipt of E and P waste, the operator shall prepare materials for remediation. 2.4 Soils shall be turned regularly, a minimum of once a month. 2.5 Additional materials shall not be added until the soil concentrations of the current lift meet the Division’s salinity and hydrocarbon cleanup standards. 2.6 Existing landfarm materials shall meet Division’s cleanup standards by 7/1/2020. FAILURE TO COMPLY WITH THE ABOVE LISTED CONDITIONS OF APPROVAL MAY RESULT IN CLOSURE OF THE FACILITY. &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 Western Water Solutions Sand Pass Ranch Sections 9 & 10, Township 4 south, Range 1 west 05/30/18 GeoStrata ✔ Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o, ou, email=daynedoucet@utah.gov, c=US Date: 2018.12.14 15:39:36 -07'00' 10/10/18 DKD 12/14/18 DKD 10/10/18 DKD 12/14/18 DKD 10/10/18 BTW 11/07/18 BTW $ 724,900 Operator's currently held bond is $724,923 Active compliance matter is being addressed as a COA of the new permit - DKD Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o=DNR, ou=DOGM, email=daynedoucet@utah.gov, c=US Date: 2020.04.01 16:53:43 -06'00'✔ 06/11/18 ASM Pond numbers are incorrect(?) 06/11/18 ASM Fixing known leaks(?) Cost Estimate for OWS clean up not included 06/15 BTK 06/11/18 ASM 11/01/18 ASM Leak detection sumps will be checked weekly. Lab samples for landfarm materials missing 6/15 BTK /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 11/01/18 ASM Leak detection sumps will be checked weekly. 06/15/18 BTW 06/15/18 BTW Fence remains - shared with neighbor, identifies boundary. 06/15/18 BTW 06/15/18 BTW Landfarm materials unlikely to meet abandonment levels, require additional bonding calculations for removal or remediation base on the volume of materials present and require current material be remediation prior to acceptance of additional materials. Need profile of current materials in the landfarm. 6/15 BTK No plan submitted for steel tanks replacing OWS system. OWS leaks, discontinue use until source of leak addressed No clean-up or remediation estimate provided for contamination at the OWS. The estimate includes the towers applied for. BTW. GARY R. HERBERT Division Director Richard Powell, 12/17/2018 NOTICE OF VIOLATION UTAH OIL AND GAS CONSERVATION ACT N Compliance Deadline: Description of Violation(s): Rule Reference(s): Rule R649-9-5. Landfarms Well(s) or Facility in Violation listed on next page www.ogm.ulah.gov Oil, GAi a "ININA .. Required Actions: Immediately stop applying additional waste material to the land farm until all landfarm contents meet Division cleanup standards as outlined in the Cleanup Level Selection Guidance Document. The Division must be notified prior to conducting soil sampling to allow Division personnel to witness. *Fines may be levied up to $10,000.00 per day for every well in violation given the authority provided under U.C.A 40-6-11, part4 This notice shall remain in effect until it is modified, terminated, or vacated by a written notice of an authorized representative of the director of the Division of Oil, Gas and Mining. Failure to comply with this notice will result in the Division pursuing further actions against said operator. Further actions may include initiation of agency actions to order full cost bonding and plugging and abandonment of wells and requests for bond forfeiture and civil penalties. Compliance Deadline: cc: Compliance File Well/ Facility File Dayne Doucet, Permit Manager Bart Kettle, Operations Manager John Rogers, Associate Director List of Well(s) or Facility in Violation: Well or Faciity Name Western Water Solutions, Sand Pass Western Water Solutions Richard Powell Dig11a11y signid by R!Chard Powell DN: cr,=,Richard Powell, O"'UDOGM. ov=DNR, email .. richardpow�l@ut1h gov, c=US Dale: 201 B 07 23 16 32 52 -0600' Environmental Scientist Josh Payne, Compliance Manager API # Date of Inspection 7/23/2018 Page 2 of 2 (435)790-6145 1010212017 version Jean Sweet <jsweet@utah.gov> Re: E&P Waste Facility Quarterly Reports OVERDUE 1 message LeGrand Woolstenhulme <legrandw@gmail.com>Tue, Mar 2, 2021 at 2:40 PM To: Jean Sweet <jsweet@utah.gov> Cc: LeGrand Woolstenhulme <legrand@westernwatersolutions.com>, reese@westernwatersolutions.com Hi Jean - I'm no longer involved with WWS and EWS. Best contact now is jason@ecovap.com or Scott snelson@ecovap.com. I did forward your email. LeGrand On Tue, Mar 2, 2021, 2:22 PM Jean Sweet <jsweet@utah.gov> wrote: Hello LeGrand and Reese, We have not received the quarterly reports for the Eastern Water Solutions facility for 4th Qtr 2019 and all quarters 2020. We have not received the quarterly reports for the Western Water Solutions Sand Pass Ranch facility for 4th Qtr 2019 and all quarters 2020. These reports are OVERDUE and need to be submitted via email to jsweet@utah.gov. Failure to submit these quarterly reports may result in the Division pursuing further action against Eastern Water Solutions and Western Water Solutions. Regards, Jean -- Jean Sweet Executive Secretar y Utah Division of Oil, Gas and Mining 801-538-5329 jsweet@utah.gov www.oilgas.ogm.utah.gov 5/13/2021 State of Utah Mail - Fwd: E&P Waste Facility Quarterly Reports OVERDUE https://mail.google.com/mail/u/0?ik=ad25b7bcd0&view=pt&search=all&permthid=thread-f%3A1693222482558730474%7Cmsg-f%3A1693222482558…1/3 Jean Sweet <jsweet@utah.gov> Fwd: E&P Waste Facility Quarterly Reports OVERDUE 1 message Kristen Lamb <klamb@ecovap.com>Wed, Mar 3, 2021 at 7:46 AM To: Jean Sweet <jsweet@utah.gov> Jean, Good Morning! Jason forwarded this to me. As I recall, I think you and I connected about records a couple of years ago i. An attempt to update the system so that hopefully everything would come to me and nothing would be missed but it looks like it didn’t populate everywhere. 1) Legrand has been gone from the company for over three years. His name and email address needs to be deleted from your system completely. 2) After the fire in 2019 at WWS we were no longer able to take water at that location and didn’t reopen to take water until Feb 2020 when we tested the functionality of the new system. Sadly we had to shut right back down due to COVID and have been closed at both sites ever since. Anyway, that’s neither here nor there at this point other than when we shut back down Reese (the second recipient of the emails you have on file) also stepped away to focus on his other business opportunities. Can you help me? Can you update the system anywhere you have email information that contains Legrand and replace it to reflect my name and email address instead? Klamb@ecovap.com. (Ecovap is the parent company to both EWS and WWS). This update on your end will allow all corespondents to come this direction and I can assign the work to the then steward at the sites once in operation again. Also, if you could forward me the necessary forms for each of those quarters for each of the two sites then I’ll get them filled out and sent back to you ASAP so the account reporting can be brought current. There will be a lot of zeros for the time period we’ve been closed but I want to make sure we don’t miss anything that may have come in at any point prior to closures. Also, if you have a set of state required guidelines that would let me know what gets reported and when for sites like these then I can create a reporting calendar in our system to help make sure nothing gets missed in the future as a secondary reminder. 5/13/2021 State of Utah Mail - Fwd: E&P Waste Facility Quarterly Reports OVERDUE https://mail.google.com/mail/u/0?ik=ad25b7bcd0&view=pt&search=all&permthid=thread-f%3A1693222482558730474%7Cmsg-f%3A1693222482558…2/3 Thanks for your help! Let me know if there is anything else you see that we’ve missed. Kristen Lamb COO ECOVAP, Inc. 801-960-3238 NOTICE: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. Begin forwarded message: From: Jason Mendenhall <jason@ecovap.com> Date: March 2, 2021 at 4:59:30 PM MST To: Kristen Lamb <klamb@ecovap.com> Subject: Fwd: E&P Waste Facility Quarterly Reports OVERDUE Didn’t we file these? Also - we need to get the email changed. Thanks, Jason M. 702.234.4605 On March 2, 2021 at 2:36:35 PM, LeGrand Woolstenhulme (legrandw@gmail.com) wrote: ---------- Forwarded message --------- From: Jean Sweet <jsweet@utah.gov> Date: Tue, Mar 2, 2021, 2:22 PM Subject: E&P Waste Facility Quarterly Reports OVERDUE To: LeGrand Woolstenhulme <legrand@ westernwatersolutions.com>, <reese@westernwatersolutions.com> Hello LeGrand and Reese, 5/13/2021 State of Utah Mail - Fwd: E&P Waste Facility Quarterly Reports OVERDUE https://mail.google.com/mail/u/0?ik=ad25b7bcd0&view=pt&search=all&permthid=thread-f%3A1693222482558730474%7Cmsg-f%3A1693222482558…3/3 We have not received the quarterly reports for the Eastern Water Solutions facility for 4th Qtr 2019 and all quarters 2020. We have not received the quarterly reports for the Western Water Solutions Sand Pass Ranch facility for 4th Qtr 2019 and all quarters 2020. These reports are OVERDUE and need to be submitted via email to jsweet@utah.gov. Failure to submit these quarterly reports may result in the Division pursuing further action against Eastern Water Solutions and Western Water Solutions. Regards, Jean -- Jean Sweet Executive Secretar y Utah Division of Oil, Gas and Mining 801-538-5329 jsweet@utah.gov www.oilgas.ogm.utah.gov State of Utah SPENCER J. COX Governor DEIDRE M. HENDERSON Lieutenant Governor Department of Natural Resources Division of Oil, Gas and Mining BRIAN C. STEED Executive Director J OHN R BAZA Division Director 1594 West North Temple, Suite 1210 PO Box 145801 Salt Lake City, UT 84114-5801 Telephone (801) 538-5340 www.ogm.utah.gov Kristen Lamb Western Water Solutions LLC 3214 N University Avenue,Suite 133 Provo,Utah 84604 klamb@ecovap.com 7/20/2022 7/20/2022 7020 1810 0000 3915 2762 7/29/2022 Evaporation Pond 1 has been leaking since January 2022. Crews have attempted to find and repair the leaks but have been unsuccessful. The pond dike is covered with oil and much of the pond surface has been covered with floating hydrocarbons during this time period. Crews have also attempted to remove the hydrocarbons from the pond surface also without success. A verbal agreement/timeline to have all hydrocarbons removed and all leaks repaired by the end of June 2022 has passed without success. Class I Rule R649-9-4. Evaporation Facilities Rule R649-9. Waste Management and Disposal Well or API #Date of Inspection Stop adding water to pond 1 immediately. Remove water from pond 1 leak detection - this may require draining pond 1. Remove hydrocarbons from pond 1. Removal of hydrocarbons and water as needed to stop leaking should be completed within 5 days. 7/29/2022 Environmental Scientist (435) 790-6145 cc:Compliance File Well / Facility File Bart Kettle, Deputy Director Josh Payne, Compliance Mgr Ammon McDonald, Operations Mgr Dayne Doucet, Permit Mgr Trevor Gruwell, AG office Sand Pass Ranch 309 7/13/2022 Richard Powell Digitally signed by Richard Powell Date: 2022.07.20 14:44:37 -06'00' Western Water Solutions LLC 02/09/2022 Jean Sweet <jsweet@utah.gov> Re: Western Water Solutions/Sand Pass Ranch 1 message Kristen Lamb <klamb@ecovap.com>Fri, Sep 2, 2022 at 12:08 PM To: Jean Sweet <jsweet@utah.gov> Cc: Richard Powell <richardpowell@utah.gov>, "Payne, Joshua" <joshuapayne@utah.gov>, "McDonald, Ammon" <ammonmcdonald@utah.gov> Jean, Just wanted to keep you in the loop. We got the oil off the pond and leaks have been repaired. Richard stopped by yesterday to check it out and has given us approval to bring the water up on the pond while viewing leak detections along the way as a double check as it goes. Kristen Lamb COO ECOVAP, Inc. 801-960-3238 NOTICE: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. On Jul 26, 2022, at 3:04 PM, Jean Sweet <jsweet@utah.gov> wrote: Hi Kristen, Please contact Richard Powell - 435-790-6145 regarding this NOV. He is the inspector over DOGM facilities and is the one that does the site visits. Richard issued the NOV and can discuss this with you. Please leave a message if necessary as he is in the field. Or you can try Ammon McDonald, Field Operations Manager at 801-538-5337. The penalty goes into effect if the NOV goes unresolved. Again, contact Richard to discuss what needs to be done to resolve this NOV. Regards, Jean On Tue, Jul 26, 2022 at 11:27 AM Kristen Lamb <klamb@ecovap.com> wrote: Jean, Draining an entire pond will take longer than the 5 day time frame you’ve given in the Notice of Violation. We hired and drained the pond down below the leaks several weeks ago. The leak I’ve referred to in my quarterly report are the leaks we’ve been finding as we’ve moved the water back up the liner. We have been actively in the repair process. Do you have time for a call? Can you help me understand what needs to occur so we aren’t getting daily fines? Kristen Lamb COO ECOVAP, Inc. 801-960-3238 NOTICE: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. On Jul 20, 2022, at 3:54 PM, Jean Sweet <jsweet@utah.gov> wrote: This is notification that a Notice of Violation is issued to Western Water Solutions/Sand Pass Ranch. See attached and respond accordingly. Division of Oil, Gas and Mining contact for this is Richard Powell at 435-790-6145. -- Jean Sweet Executive Secretar y Utah Division of Oil, Gas and Mining 801-538-5329 jsweet@utah.gov www.oilgas.ogm.utah.gov <20220720 Western Water Solutions NOV.pdf> -- STATE OF UTAH Waste Disposal Permit DEPARTMENT OF NATURAL RESOURCES AMENDED REPORT  DIVISION OF OIL, GAS AND MINING Original Filing Date: 10/10/2018 WASTE DISPOSAL PERMIT 1. Name of Operator WESTERN WATER SOLUTIONS LLC 2. Utah Account Number 102430.0   3. Address of Operator                   City            State      Zip 2230 N UNIVERSITY PKWY STE 2F  PROVO   UT  84604 4. Phone Number 801-787-1789 5. Name of 3rd Party Contractor GeoStrata Engineering & Geo-Sciences 6. Facility Name Sand Pass Ranch   7. Address of Contractor                   City            State      Zip 14425 South Center Point Way  Bluffdale  UT  84055 7. Phone Number 9. Additional Comments December 21, 2018 Sundry Number: 91114 RECEIVED: Oct. 10, 2018 2230 N University Drive, Provo, UT 84604 Rev 20180515 western water solutions Permit Renewal Application for Western Water Solutions Sand Pass Ranch E&P Waste Disposal Facility Five Year Permit Renewal Presented To: State of Utah Division of Oil, Gas and Mining Department of Natural Resources Prepared by: GeoStrata Engineering & Geo-Sciences 14425 South Center Point Way Bluffdale, UT 84055 on October 1, 2018 Property Location: 318 Acres in Section 09 and Section 10, Township 4 S, Range 1 W, Uintah Basin Special Meridian Duchesne County, Utah Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 1 Page of 8 TABLE OF CONTENTS A.Introduction and Narrative B.Site Description and Assessment and Closure and Post Closure Cost Estimate 1. Description and Assessment of Existing Conditions a. Site Description b. Contamination Evaluation c. Equipment Assessment d. Practices Assessment e. Monitoring Program 2. Closure Cost and Bonding Evaluation a. Contamination Evaluation b. Remediation of E&P Waste Contamination c. Site Closure Evaluation Scope of Work d. Infrastructure Removal Scope of Work e. Seeding and Revegetation Scope of Work f. Initial Closure Monitoring Report g. Post Closure Monitoring Scope of Work 3. Observations and Recommendations C.Attachments 1. Attachment 1 – Maps and drawings 2. Attachment 2 – Third Party Closure Cost Estimate 3. Attachment 3 – Response to Sept 10, 2018 Letter from DOGM Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 2 Page of 8 A. Introduction and Narrative WWS submits this Exploration and Production (E&P) Waste Disposal Permit Renewal Application (Application) for the subject facility (Facility) in accordance with the requirements of Utah Administrative Code, Rules R649-9-8.2, R649-9-8.2.1 and R649-9- 8.5.1. This Application includes an assessment of site reclamation requirements and closure cost estimates compiled by a responsible third-party contractor. WWS understands that permit renewals may be approved for a five-year period depending on the results of DOGM’s review and consideration of the Application and historic Facility compliance performance. The Facility receives and treats produced water, natural gas liquids (NGL), other Exploration and Production (E&P) wastes, and other wastes as may be permitted. Although the address assigned by Duchesne County is “Myton” the Facility is located about 6.5 miles southeast of Myton and is outside of the Myton City limits. The address to the Facility is: 200 W 10000 S, Myton, UT 84052 Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 3 Page of 8 B. Site Description and Assessment, Closure and Post Closure Cost Estimate and Bond Evaluation The following narrative addresses requirements established for permit renewal of the titled facility as described in in Utah Division of Oil, Gas and Mining guidance document, Five Year E&P Waste Disposal Facility Permit Renewals, (re: Utah Oil & Gas Conservation General Rules R649-9-8.5.1 Bonding of Disposal Facilities), dated August 2017. 1. Description and Assessment of Existing Conditions a. Site Description: The Western Water Solutions (WWS) Sand Pass Ranch Exploration & Production(E&P) Waste Disposal is located on approximately 318 Acres in Sections 9 and10, Township 4 S, Range 1 W, UBSM. Duchesne County, Utah. See DISPOSAL site map in Attachment 1. The current site has of one (1) fixed building and six (6) mobile/temporary buildings; an off-loading area; one (1) open concrete oil/water separation vault (OWS); two (2) centrifuges; thirteen (13) API-12 above-ground storage tanks; six (6) operational evaporation ponds; two (2) skim Ponds; and one (1) 5.8-acre Landfarm. The operational evaporation ponds are nominally 4.7, 4.6, 4.6, 3.0, 3.2 and 3.5 acres, west to east, respectively. Liquid E&P Waste is discharged into the treatment system from trucks into the in-ground OWS. It is then directed into a Skimming Pond and a series of above-ground tanks where oil, water and solids are gravity separated. The gravity separated oil, water and solids are run through one (1) of two (2) centrifuges. Waters are discharged to the evaporation ponds and the recovered oil is stored in another set of above ground storage tanks. Solids are de-watered and transported to the on-site Landfarm. See Process Flow Diagram in Attachment 1. Tank Bottoms waste, OWS solids and similar slurries are de-watered and conditioned for Landfarm treatment using gravity and centrifuge separators. E &P Contaminated Soils are accepted to be treated in the Landfarm if material meet the paint filter test for moisture content. Two Stormwater Detention basins have been designed to hold runoff generated by a 25- year, 24-hour storm until the runoff can be sampled and lab-tested. Depending on lab results the water will be either released to the local drainage; held to evaporate in place; diverted to evaporation ponds; or disposed by some combination of the three methods. b. Contamination Evaluation There is no existing Groundwater Monitoring System at the facility. However, each pond has an independent leak detection system. There are currently no known leaks in any of the evaporation pond liners. The evaporation pond leak detection system continues to be dry. The OWS is known to leak and is scheduled to be removed and replaced with a system of above-ground steel tanks during this calendar year. There is no known or observable surface soil contamination on this site. Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 4 Page of 8 Vadose zone soil is known to be contaminated in the vicinity of the OWS. It is believed that the shallow bedrock underlying this site is a low permeability aquiclude. There are no known records of incomplete spill clean-up. Process containment berms, sumps and similar enclosures are free from pooled oil and contaminated oil accumulation. c. Equipment Assessment Major construction and equipment operated at this facility has been observed by Engineer. Any tests performed to assess equipment condition were cursory in nature. A review of equipment repair and maintenance records provided by Owner form the basis of the Engineer’s opinion of service life expectancy. Service life expectancy is based upon the assumption that appropriate, regular maintenance and equipment repair has been and will continue to be performed. It is the Engineer’s opinion that all major equipment and infrastructure construction at this facility is in expected condition for its age. Future assessment of life expectancy can be based on age. More particularly: i. Site roadways appear to be constructed and maintained with appropriate wearing surface, drainage and turning radii for expected traffic. ii. Road and site drainage appear to have adequate overflow control to prevent excessive erosion. iii. Earthen structures appear to be free of excessive erosion. iv. Observable portions of piping and HDPE liners are not excessively worn or weathered. v. Observable pump seals do not leak. vi. Process heaters appear to be relatively new and automatically fire and shut off as would be expected. vii. Exposed surfaces of tanks and piping are corrosion free except for mill scale and light, tightly adhering rust. No pitting was observed. viii. Buildings - Office building is a space-conditioned, single-wide trailer equipped with wash water supply and wastewater drainage. External siding, roofing and interior floors and walls were determined be in satisfactory condition based on cursory visual inspection. - Shop building is a 2,400 ft 2, pre-engineered metal building on a concrete mat foundation located southeast of the office building. It is not space- conditioned. It houses three 150-bbl mixing tanks, two centrifuges, several feed, metering and transfer pumps and a solids holding bin. Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 5 Page of 8 d. Practices Assessment Engineer has reviewed Owner provided operating procedures and has observed those procedures in practice. Owner and Engineer offer the following practice changes to improve efficiency and environmental protections. i. Water Disposal and Solids Disposal Operation Assessment Controls for the process described in B.1.a., above and shown on the Process Flow Diagram in Attachment 1, have, for the most part not been automated. Only minor portions of equipment and controls are automated. Most automation is intrinsic to individual pieces of equipment. - Operators appear to be very familiar with the overall plant process and perform process Quality Control for a large percentage of their time. Throughout their working hours operators sample process liquids for anomalies. Whenever process liquids or machinery operation appears abnormal operators will intervene in one of two ways. Most often the operator will make equipment and process adjustments for which the operator has been trained and given authority to perform. Process and equipment adjustments which appear to be needed, but which operator has not been authorized to perform, are immediately brought to the attention of other operating staff and plant management for resolution. - Equipment temperatures, pressures, flowrates and the like are constantly monitored by operating staff and management. Although some process monitoring parameters are observed via remote displays, most instrument monitoring and all sampling is locally observed/performed. For the past three years major pumping and aeration equipment has not been put in service. - Leak detection equipment is monitored weekly. - It is the Engineer’s opinion that: No additional process monitoring automation is warranted for any reason at this Disposal unless it is returned to regular, continuous use or operation. Periodic leak detection monitoring should be decreased (i.e. allow a longer time between subsequent observations) to monthly time periods. Process sampling should continue to be performed when the facility is in active use. Manually and local process monitoring are appropriate because this operation is not big enough to warrant remote and/or automated process sampling. The biggest process variable is the type of waste brought to the Facility. It is the Engineer’s opinion there is no commercially available, off- the-shelf (COTS) equipment to classify incoming waste. There is no Reasonably Available Control Technology (RACT) or even Best Available Control Technology (BACT) that is economically viable for WWE to implement. The methods that remain (client waste certification, periodic waste testing by Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 6 Page of 8 client, waste evaluation by experienced staff and similar) are best available for the operation and should continue to be used. ii. Landfarm Operation Assessment - The existing landfarm can accept frac sands, filtered tank bottom sludges, and other acceptable E&P solid wastes that pass a paint filter test and contain hydrocarbons. This landfarm is a soil remediation process that reduces petroleum contaminated soil (PCS) concentrations through biodegradation. - Contaminated soils will be periodically turned over using common farming or similar equipment to aerate landfarmed soils. Soils will be worked in a traditional fashion by maintaining aeration and moisture that supports naturally occurring aerobic and/or augmented micro-organisms (archaea and bacteria). These micro-organisms remediate the soils by consuming E&P waste in the contaminated soil. Landfarm waste bulk density, texture and porosity may be controlled by addition of straw, sawdust, pearlite and similar conditioning material. Clean, low salinity water will be applied as needed to keep the soils moist enough to support micro-organism growth. - Runoff water from the landfarm area is detained in the southwest corner of the landfarm. Excess stormwater is drawn of as necessary and treated with incoming E&P waste. - Visual and olfactory screening will be used to monitor the landfarming process. Before material is removed from the landfarm, samples are taken, and lab tested to ensure the treatment process is completed. No changes to the proposed treatment process, per se, are needed to comply with regulation. This facility is planning major equipment and process changes within approximately 12 months. Although it is not reasonable to speculate about the effects of those changes, it is reasonable to expect that the facility process will be more efficient and less prone to operating faults and inadvertent discharge of E&P waste. e. Monitoring Program Soil and water sampling and testing, visual equipment inspection, pressure tests, sampling and analysis of material collected by leak detection systems and waste mass balance calculations used at this facility are described below. Additional or re- configured monitoring practices which could reasonably and economically improve detection of inadvertent waste release are also described below. i. Water Sampling and testing is performed on all liquid taken from leak detection sumps. ii. Leak Detection Monitoring of designated leak detection sumps is performed regularly. Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 7 Page of 8 iii. Soil sampling of the landfarm to evaluate conditions required to facilitate microbial activity and effectiveness of landfarm remediation process 2. Closure Cost and Bonding Evaluation Bond cost components referenced in this section have been determined by applying unit costs to quantity take-off from drawings and documents provided by Owner and cursory field inspections and surveys by the Engineer. a. Contamination Evaluation There is no evidence of soil or surface water contamination at this facility. Since the existing OWS is known to leak the closure cost estimate includes over excavation of the soil surrounding and beneath this vault. These soils and any other soil found to be contaminated with E&P waste will be remediated in the onsite landfarm during the landfarm closure. b. Remediation of E&P Waste Contamination Any soils that are found to be contaminated will be remediated as part of the landfarm remediation and closure. c. Site Closure Evaluation Scope of Work Upon closure potential soil contamination will be identified with a PID survey. Groundwater quality and surface water will be sampled and lab-tested. Hazardous substances stored or used on site will be inventoried. Costs for this evaluation are included in calculated closure costs. d. Infrastructure Removal Scope of Work The cost to remove all site infrastructure and equipment, as may be reasonable and necessary, to return site to a condition similar to its use and appearance before being used as an E&P Waste Disposal is included in reclamation cost estimate. No costs are included to reclaim and/or improve the site to conditions better than those occurring before its use as and E&P Disposal or markedly better than exist on adjacent property. Grading and contouring the site to the exact site geometry before site was used as an E&P Disposal has not been used as a reclamation criterion. As a general rule, infrastructure removal closure cost estimates include: i.Removal all tanks, security fence, buildings, liner materials, piping and concrete structures which do not add value to the site are included in the Infrastructure Removal portion of closure costs. ii.Pond liner and certain piping that do not harbor or contain E&P Waste and which will have at least two feet of soil cover will be abandoned in place. iii.Earthwork and grading to restore site to a serviceable condition similar to, and in keeping with surrounding land use and drainage. Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 8 Page of 8 e. Seeding and Revegetation Scope of Work Seeding/revegetation cost is based drag harrowing and hydroseeding is included in the closure cost estimate. Seed mixture and application rate determined by Great Basin Company of Ephraim, Utah are included in this component of closure cost estimate. f. Initial Closure Monitoring Report This report will describe: i.Estimated closure PID survey results and nature and amount of sampling and lab testing required. ii.Groundwater and surface water required to be sampled lab-tested. iii.Inventory of hazardous substances removed from site. iv.Completed site grading, revegetation and erosion control. g. Post Closure Monitoring Scope of Work Post closure monitoring and care cost includes annual: i. Annual erosion control and surface water management. ii. Installation of four to eight groundwater monitoring wells. iii. Sampling and testing of groundwater. iv. Sampling and testing of site and Landfarm soil and surface water as described in the initial closure report. v. Tilling of landfarm soils on a monthly basis for one year. vi. Written report describing the condition of the reclaimed site and work performed to monitor and maintain reclaimed site. 3. Observations and Recommendations Included in Articles 1. d. and 1. f, above. Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 C. Attachments Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 ATTACHMENT 1 MAPS and DRAWINGS Site & Vicinity PFD Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Oil Processing Tan ks Pond 1 Pond 3Pond 2 Landfarm Pond 6Pond 5Pond 4Bank PondVault Pump Pond Uncovered Tank 0 500 1,000 1,500 2,000250Feet1:8,000 ± Permit RenewalWestern Water SolutionsDuchesne County, UtahProject Number: 705-014 WWS Facility Current Layout Figure1 All L ocations are App roximate Legend Skim Pon dLandfarmOil Processing TankEvapration P ondUncovered Ta nk Vault Property Boundary Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Produced Water Copyright GeoStrata, 2018 Permit Renewal Western Water Solutions Project Number: 705-014 Legend Water Oil Solids Vault Oil/Water/solids Separator Skim Pond Evaporation Ponds Imported Solids Figure 2 Imported Solids Disposed in Landfarm Process Flow Diagram Crude Oil Transported off site Cleaned Oil Storage Tank Liquid Tank Bottoms/Oil Sludge Oil Surge Tank Centrifuge Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for Sand Pass Ranch Exploration & Production Waste Disposal 200 W 10000 S, Myton, UT 84052 Rev 20180515 ATTACHMENT 2 CLOSURE COST ESTIMATE Bev summary & GeoStrata Backup Calcs Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Western Water Solutions Date: 9/28/2018 Facility: Sand Pass Ranch E&P Disposal Total Permit Acreage 78.2 Acres Total Acreage to be reclaimed 28.3 Acres Contamination Remediation Cost Estimates 53,066.53$ 2 Removal of Infrastructure Costs Estimates 54,560.81$ 3 Earthwork and Grading Cost Estimates 390,496.02$ 4 Revegetation Cost Estimates 35,667.48$ 5 Final Closure & Post Closure Cost Estimates 60,354.40$ 6 Total Cost Estimate 594,145.24$ (Increase above total cost estimate by 14% if indirect costs are not included) 83,180.33$ Total Reclamation Cost Required 677,325.58$ Bond Posted 668,750.00$ 7 Difference Between Cost Estimate and Bond (8,575.58)$ Direct and Indirect Costs Five Year E&P Waste Disposal Facility Bond Calculation Summary Form Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Item - 78.2 Acres 1 Percentages 7%01 21 55.50 0200 With an additional 2% of unforseeable events 3%01 31 00 Adjusted to reflect a percentage, also referenced ACEC and ASCE for rates 1% 01 41 26.50 0100 0%01 51 00 Not applicable for the scope and scale of a project like this 3%01 71 00 Adjusted to reflect a percentage, also referenced ACEC and ASCE for rates Total: 14% 2 Unit Quantity Unit Price Extended Cost bbl 8660 1.66$14,396.89$02 65 10.30 0320 (modifed for scale) bbl 8,660 0.75$6,483.39$ 31 23 23.20 4096 adjusted to cy for hauling (with $.65 / bbl cost for disposal facility to accept waste) 0 0 -$ Above costs include the removal (by vac truck) and disposal of 10% of tank volume 309 160.00$No Cost Contaminated Soil will be transproted to and treated in their own Landfarm 0 0 -$ Positive Samples 19 Varies 32,186.25$MWH Standard 0 0 -$ Total: 53,066.53$ 3 Unit Quantity Unit Price Extended Cost Cubic Yard 6,400 Varies 2,496.00$02 41 16.13 0500 Each 9 Varies No Cost (net of salvage) 02 65 10.30 1213 Each 4 200.00$No Cost (net of salvage) 02 65 10.30 1213 Linear Foot 1,000 Varies -$ Leak Detection Pipe will be ground up with liner shredding Varies 1 10,546.80$ 10,546.80$02 41 16.17 0280, 22 05 05.10 2162 Includes Haul & Dump Cubic Yard 21 75.00$2,315.77$31 23 16.32 0020 Cubic Yard 7,104 1.40$17,226.02$02 41 16.17 2440 and 2620 Linear Foot -Varies -$ 02 41 13.60 1600 Fencing on site is for boundary indentification. Shared with neighboring owners Cubic Yard 728 0.70$510.13$31 23 23.20 4104 Ton 1,074 20.00$21,466.10$Duchesne/ Wasatch Bluebench Landfill Tonnage Rates Total: 54,560.81$ 4 Unit Quantity Unit Price Extended Cost cubic yard 206,298 1.76$381,246.02$31 23 16.46 5020 cubic yard -2.83$-$31 23 16.46 5040 cubic yard -1.53$-$31 23 16.46 5000 square foot 185,000 0.05$9,250.00$31 22 13.20 0280 (modifed for scale) Total: 390,496.02$ 5 Unit Quantity Unit Price Extended Cost MSF 1,232 28.94 35,667.48$ 32 92 19.14 5800 (modified with specific seeding costs of Granite Seed in Lehi, UT) Total: 35,667.48$ 6 Unit Quantity Unit Price Extended Cost Linear Foot 120 45.00$ 5,400.00$ 33 11 13.10 0100 Year 1 450.00$4,500.00$GeoStrata estimates based off of inhouse estimates Year 10 98.00$980.00$GeoStrata estimates based off of inhouse estimates Year 10 600.00$6,000.00$GeoStrata estimates based off of inhouse estimates Month 9 1,000.00$9,000.00$GeoStrata estimates based off of inhouse estimates month 12 1,531.20$18,374.40$32 91 13.23 6100 Tilling Topsoil (cost for 12 tillings) Year 1 Varies 2,100.00$GeoStrata estimates based off of inhouse estimates Year 8 1,200.00$9,600.00$GeoStrata estimates based off of inhouse estimates Year 2 2,200.00$4,400.00$GeoStrata estimates based off of inhouse estimates Total: 60,354.40$ 7 Type ID Number Posted Amount 1 7 668,750.00$ Total: 668,750.00$ Self Attenuating PID Closure Soil Sampling Post Remediation Monitoring Descripiton Removal of Contaminated Liquid Disposal of Contaminated Liquid (Haul and Dump) Pump & Treat Removal & Disposal of Contaminated Soil Western Water Solutions Sand Pass Ranch E&P Disposal Site Assessment, Closure & Post Closure Cost Estimate & Re-statement of Existing Bonds in Suport of DOGM Bonding Evaluation Site Area Contamination Remediation Cost Estimates DOGM Line Item Descripiton Contingencies Price and Payments Procedures Administrative Requirements Quality Requirements Temporary Facilities and Controls Executions of Closeout Requirements Indirect Costs Removal of Infrastructure Costs Estimates Descripiton Buildings - Structure Demolition Shred Liner Evap Tower Demo (Concrete and Piping removal) Sand & Gravel to be Moved Tanks (No Cost - net of salvage) Gensets Buried Piping Demolition Concrete Pads and Vault Fencing Earthwork and Grading Cost Estimates Descripiton Common Earth to be Dozed Clay to be Moved Hauling Dumping Rough Grading - Disturbed Areas Revegetation Cost Estimates Descripiton Listed Reclamation Water Quality Meter Rental Lab Analysis Grounds Maintenance Monitoring Well Abandonment Annual Report Final Post Closure Report Bond Posted Bond Descripiton & Date Hydro Seeding of Indian Rice Grass Final Closure & Post Closure Cost Estimates Descripiton Well Inspection & Sampling Landfarm Tilling Monitoring Well Installation Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 2230 N University Drive, Provo, UT 84604 Rev 10/1/2018 western water solutions ATTACHMENT 3 •Response to Letter Dated Sept 10, 2018 •WWS ECOVAP Dike Tower Configuration •Engineered Design of New Headworks •Future Landfill Location •Copy of Letter from DOGM Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 2230 N University Drive, Provo, UT 84604 Rev 20180515 western water solutions Dayne Doucet Permit Manager DOGM State of Utah DNR In response to your September 10, 2018 letter addressed to Kristen Lamb, CEO ECOVAP, Inc. Design and description of the new tower installation. The ECOVAP tower configuration and design is included at the end of this response. The new evaporation towers will be located between the two southeast evaporation ponds and will run the length of the ponds and the width of the existing separation berm. The footprint will have the approximate dimensions of 15ft x 350 ft. Installation will involve the assembly of individual HDPE blocks using mallets and specially designed fasteners. Once installed, produced water will be pumped directly from the adjacent evaporation pond to the base of the new evaporation tower. Water will then be pumped to the top of the tower using internal piping operating under hydro-mechanical properties. Water will then trickle down a series of HDPE blocks designed to assist in and accelerate the evaporation of the produced water. Professionally engineered design and timeframe for installing the new headworks Engineered designs are included in the attachments following this response. The time required to install the headworks will be approximately 12 months. Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 2230 N University Drive, Provo, UT 84604 Rev 20180515 western water solutions Future Landfill WWS has already begun the process of permitting an onsite landfill at their Sand Pass Facility. Preliminary location scouting, groundwater studies, and an ecological survey have all been completed. The estimated time for permit completion and construction is 12 months. A map of the preliminary cell design is included at the end of this document. Plans and timeframe to address the sludge pond problems Oil will continue to be skimmed from both sludge ponds and after being sufficiently cleaned will be stored in onsite sales tanks. Residual water will be routed into the evaporation ponds and any solids will be placed in the landfarm or future landfill based on the quality and level of contamination. After ponds have been emptied and cleaned, site reclamation will begin. The entire process will be completed in 12 months. Similar to the ponds, the existing vault will be emptied of oil, water, and solids. The inside of the cleaned vault will be relined and incorporated into the new front end design for surge capacity. Plans and timeframe to address the landfarm contamination Landfarm material will be washed using a fresh water source to clean the contaminated soil. Periodic sampling will take place in order to confirm the efficacy of the cleanup efforts for the landfarm material. The expected time of completion for the cleanup process is 12 months. If at the end of 12 months there are still significant level of contaminants in the landfarm soil, it will be removed and placed into the future onsite landfill. Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 12' 7.5" x 26' 4.5" long x 18' tall (gen 1) 2,655 panels (1 section) 12' 7.5" wide x 254' 7.5" long x 18' tall (gen 1) 22,653 panels (12 sections) © 2018 ECOVAP – CONFIDENTIAL – INTERNAL USE ONLY WWS ECOVAP Dike Tower Configuration (1 Section) Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Solids 0.23 Water 3187 Mass Balance Truck bbls 130 Capacity 2956 42%Oil buildup 0.12 3490 99.7% off load, mins 15 Water 3182 Capacity 850 106% 364 gpm Solid 4.64 Flow bbls/min 8.7 Oil 97.0 Solids Flow gpm 364 Solids 4.1 Dilution 0.23 Solids 0.05 0.0022 acre‐ft/year Day bbls 2625 Wtr Cut 402 156.2 water Water Water 3187 149.9 acre‐ft/year Loads 20.2 Oil 73.5 23.50 oil 3162 Oil 0.01 0.0003 acre‐ft/year 10.44 Water HC ppm 1.94 800 Limit ppm 4.18 Solids  Pond 90% Solids %Solids 0.19 oil 0.12 Day bbls 875 364 gpm 40% Slurry Water 0.46 Water 24.8 Loads 6.7 Efficiency 80%bbls/wkday 229 Flow gpm 364 Solids 0.46 Pond Shifts/day 0.62 Water 0.53 bbls/8hr 109.4 One Cycle Capacity 91 gpm Oil 97.0 Capacity 20 gpm Solids 1.59 hrs/load (8hrday) 1.19 Pond Solid Effcy 70%Water 3172 flow 4.10 gpm Oil 104.2 Solids 14 Oil quality 90.00%Bsw wtr cut 25%Bs&w 2% Farm Liquid cut 30%Oil 97.0 Capacity 500 82%Oil in wtr 0.5%Sales Vol 106.31 Water 172 Solids 0.23 Solids Oil 3% Oil 29.1 Water 9.7 Solids Moisture 5% Tot vol 215.0 Solids 8.24 Oil Loss 0.8% slurry 6%Oil 0.25 104.7 Solids 9.604 water 0.41 Waste Flowback Tank btms Receiving Bin Water 16.0 0.356% Capacity 300.00 28%Underflow Bin Oil 8.00 Capacity 100 16% 4 504.0 67 Water 574.0 55.7%slurry 40%Capacity 400 35%batches 0.71 1.8 15.8 87.5 Oil 105.0 10.2%btu/hr 500000 Water 25.7 18.3% farm 169.8 5.3 21 Solids 196.0 19.0%BS&W 25.3%Oil 105.0 74.7% Cycles 5 1 3 Dilution 156.2 15.1%Cycle hrs 3.17 Solids 9.8 7.0% Solids 189.0 176.4 Solids Water 7.9 90% Cut Oil ‐0.1 Oil ppm (590)30,000 Limit ppm Moisture 4% Wtr Effcy 30%dirt mix 0% Water 3.4 Oil 0.48 41% Oil Effcy 10% Capacity 480 residual 0.0458 Western Water Solution Separation Process Flow Model V3.3 Coarse Separation Chemical TreatingConcentration Dewatering/SolidsRemovalUnloading Classifcation Screening Disposition Production Water Tank Bottom, Flow Back  No Washouts Pond Land FarmModeling 1. Enter Flow stream characteristics 2. Enter Equipment volumes 3. Enter unit operating parameters Vac  Truck Floc  Add Vac  Truck Polymer  Oil  Pump Water  solids  pump Dump Off, Hydrovac Fine Separation Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 !U !U !U Down Gradient Well Down Gradient Well Background Monitoring Well Cell 4 Cell 2 Cell 1 Cell 3Staging Area 0 480 960 1,440 1,920240Feet 1:7,000 ± Landfill PermitWestern Water SolutionsDuchesne County, UtahProject Number: 705-009 Proposed Landfill Location Plate1 Legend !U Proposed Monitoring Well Proposed Access Road 10 ft Contour Proposed Landfill Location Property Boundary Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018 Area To Be Reclaimed Area To Be Reclaimed Area To Be Reclaimed 48 0 M u d T a n k So l i d s M a n i f o l d Manifold Manifold Wa t e r Pu m p Po n d Pu m p So l i d s Pu m p Di s t r i b u t i o n Ma n i f o l d Cy c l o n e Sk i d Manifold Manifold Manifold Cone Bottom Tank Cone Bottom Tank Cone Bottom Tank Cone Bottom Tank Cone Bottom Tank Cone Bottom Tank Standard Tank Standard Tank Standard Tank Gunbarrel Tank Backflush Filter Pot Screen 48 0 M u d T a n k 48 0 M u d T a n k 30 0 M u d T a n k 30 0 M u d T a n k Dewater Bin (Turbo Bin) St a i r s Sheltered PipingSump Sump Off Load Lane Off Load Lane Off Load Lane Receiving Tank Receiving Tank Sales Tank Sales Tank Centrifuge Operations DUCHESNE COUNTY, UTAHDUCHESNE COUNTY, UTAH Sand Pass Front End Design WESTERN WATER SOLUTIONS, LLC NOA REV DATE BY DESCRIPTION 10-25-18 BER INIITAL SYSTEM LAYOUT 1804-10 SH 1 OF 2 W E S T E R N W A T E R S O L U T I O N S FOR CLIENT REVIEW NOT FOR CONSTRUCTION Sundry Number: 91114 RECEIVED: Oct. 10, 2018 48 0 M u d T a n k So l i d s M a n i f o l d Manifold Manifold Wa t e r Pu m p Po n d Pu m p So l i d s Pu m p Di s t r i b u t i o n Ma n i f o l d Cy c l o n e Sk i d Manifold Manifold Manifold Cone Bottom Tank Cone Bottom Tank Cone Bottom Tank Cone Bottom Tank Cone Bottom Tank Cone Bottom Tank Standard Tank Standard Tank Standard Tank Receiving Tank Receiving Tank Sales Tank Gunbarrel Tank Backflush Filter Pot Screen 48 0 M u d T a n k 48 0 M u d T a n k 30 0 M u d T a n k 30 0 M u d T a n k Sales Tank Dewater Bin (Turbo Bin) 155' 50' 2' 6' 12' 16'Sheltered Piping 2' 10' 8" Mountable Curb 8" C.I.P. Concrete Slab Sump Sump Stairs DUCHESNE COUNTY, UTAHDUCHESNE COUNTY, UTAH Sand Pass Front Design WESTERN WATER SOLUTIONS, LLC NOA REV DATE BY DESCRIPTION 04-10-18 KJS INIITAL SYSTEM LAYOUT 1804-10 SH 2 OF 2 W E S T E R N W A T E R S O L U T I O N S FOR CLIENT REVIEW NOT FOR CONSTRUCTION Sundry Number: 91114 RECEIVED: Oct. 10, 2018 Western Water Solutions Date: 9/28/2018 Facility: Sand Pass Ranch E&P Disposal Total Permit Acreage 78.2 Acres Total Acreage to be reclaimed 28.3 Acres Contamination Remediation Cost Estimates 53,066.53$ 2 Removal of Infrastructure Costs Estimates 54,560.81$ 3 Earthwork and Grading Cost Estimates 390,496.02$ 4 Revegetation Cost Estimates 35,667.48$ 5 Final Closure & Post Closure Cost Estimates 60,354.40$ 6 Total Cost Estimate 594,145.24$ (Increase above total cost estimate by 14% if indirect costs are not included) 83,180.33$ Total Reclamation Cost Required 677,325.58$ Bond Posted 668,750.00$ 7 Difference Between Cost Estimate and Bond (8,575.58)$ Direct and Indirect Costs Five Year E&P Waste Disposal Facility Bond Calculation Summary Form Sundry Number: 91114 File: Detailed Site Description RECEIVED: Oct. 10, 2018