DSHW-2025-001245

Statement of Basis
for the Cell #7 landfill@EEI
Class VII Landfill Permit

May __, 2025

1. INTRODUCTION

This Statement of Basis provides the rationale of the Director of the Division of Waste Management and
Radiation Control (Division) for issuing the Cell #7 landfill@EEI Class VII Landfill Permit. The Director's staff
conducted this evaluation to ensure compliance with the applicable solid waste rules. Nathan Nicolodemos wrote
this Statement of Basis.

2. FACILITY BACKGROUND

a. Facility Location and History

Cell #7 landfill@EEI (the Landfill) is located in Pleasant Valley, approximately 3 miles south of US
Highway 40. See Figure 1 for a map of the Landfill.

b. Regulatory History

Cell #7, identified in Figure 1, has historically operated as a "landfarm" according to the provisions and
approval from the Utah Division of Oil, Gas, and Mining. On June 8, 2023, an application for a landfill
permit for Cell #7 was submitted to the Division, and on August 8, 2023, the cell was approved for use as
a Waste Storage Pile (DSHW-2023-206061). Upon issuance, the new permit will allow for
Cell #7 landfill@EEI to operate according to regulations as a Class VII Landfill.

3. EVALUATION OF THE PERMIT APPLICATION

The initial permit application from Environmental Energy Innovations LLC was submitted on
June 8, 2023 (DSHW-2023-205083). Several updates and clarifications to the application were received
after the initial submission, and on October 7, 2024, the Division requested re-submittal to ensure that the
permit application record was complete (DSHW-2024-008380). On November 5, 2024, the Permittee
re-submitted its application (DSHW-2024-009053), and then on January 6, 2025, it submitted an
addendum to the permit application (DSHW-2025-000094) proposing an alternative design for the final
cover of the landfill cell. The November 5, 2024 submittal, and the January 6, 2025 addendum, comprise
the Permit Application. The Director determined that the permit application was complete on
January 7, 2025.

a. The Permittee proposed alternative final cover for the landfill cell, including:

i. A layer containing a minimum of six inches of clay that will have a permeability of at most
1 x 10-6 cm/sec. along with;
ii. A second cover layer of a minimum of six inches of soil, with surface slope grades not less than
2% and side slope grades not more than 33%. The second layer will consist of soil capable of
sustaining vegetative growth and be seeded with grass, other shallow rooted vegetation, or other
native vegetation.

The Permittee included a mathematical performance model with the alternate design proposition as
required by Utah Administrative Code R315-303-3(5)(d). The design and its associated model were
reviewed by Division staff and were determined to meet the requirements for Alternative Final Cover
Design as described by Utah Admin. Code R315-303-3(5).

4. JUSTIFICATION FOR ISSUING THE PERMIT

a. The Director's staff has evaluated the permit application as required by Section 19-6-108 of the Solid and
Hazardous Waste Act and Utah Admin. Code R315-301 through 322. The information provided in the
permit application satisfies the requirements. The permit was approved by the Permittee on
February 26, 2025 (DSHW-2025-001146) with no comments, and the permit received no comments
during a subsequent 45-day public comment period.

5. PUBLIC PARTICIPATION

a. As required by Utah Admin. Code R315-311-3, the Director provided an initial 45-day public comment
period from March 13, 2025, through April 28, 2025. No comments were received during this time.

6. DIRECTOR RESPONSE TO PUBLIC COMMENTS

a. No comments were received during the public comment period.

Figure 1
Cell #7 landfill@EEI