DSHW-2025-000925

February XX, 2025
Cory Condie, Landfill Manager
Sevier County
250 North Main Street
Richfield, UT 84701
RE:Request for Information – Permit Modification and Compost Permit Applications for the Sevier County Sage Flat Class I LandfillSW117
Dear Mr. Condie:
The Division of Waste Management and Radiation Control (Division) conducted a review of your permit modification application (DSHW-2025-000566)and your compost permit application (DSHW-2025-000567)
for the Sevier County Sage Flat Class I Landfill. The Applications were received by the Division on January 27, 2025. Upon initial review, the applicationsappear to be deficient and
the items in the enclosed document were not sufficiently addressed as required by Utah Administrative Code R315-301 through R315-320.
Please provide the requested information or otherwise respond to each of the items listed in the attached document within 30-days. After responses are received, the Division will continue
to review your permit modification and compost permit applications. If additional information is needed, the Division will contact you.
All information regarding this matter should be addressed to the Director at:
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
or by email at:[e-mail]
DO NOT submit any documents or information through email that are protected, confidential, proprietary, or for which you are claiming business confidentiality under Utah Code Section
63G-2-305. To better ensure records are protected, all such documents and information must be submitted using the mailing address above andin accordance with Utah Code Section 63G-2-309.
If you have any questions, please contactAlex Milne by email at [e-mail] by phone at
801-599-4672.
Sincerely,
Brian Speer, Solid Waste Manager
Division of Waste Management and Radiation Control
BS/AM
Enclosure:Sevier County Sage Flat Class I Landfill Outstanding Permit Application Requirements
c:Nathan Selin, Health Officer, Central Utah Public Health Department
Eric Larsen, Environmental Health Director, Central Utah Public Health Department
John Chartier, P.E., District Engineer, UDEQ
Scott Johnson, Sevier County Commissioner (Email)[e-mail]
Ralph Brown, Sevier County Commissioner (Email)[e-mail]
Greg Jensen, Sevier County Commissioner (Email)[e-mail]
Malcolm Nash, Economic Development Director, Sevier County (Email) [e-mail]
Cory Condie, Landfill Manager, Sevier County (Email)[e-mail]
Sevier County Sage Flat Class I Landfill PermitApplication Requirements
Permit Modification Application
Rule
Rule Content
Information Needed from Permittee
High Liquid Wastes Modification
R315-303-3(2)(a)
(2) High liquid wastes.
(a) The direct disposal of high liquid wastes in a landfill cells is prohibited unless the owner or operator implements appropriate measures described in a high liquid wastes management
plan approved by the Director and included in the plan of operation, that includes the following information:
…
(iv) a communication plan to inform customers of high liquid wastes acceptance criteria, and costs associated with the treatment of high liquid wastes at the facility.
Please provide your communication plan to inform customers of high liquid wastes acceptance criteria.
Please provide costs associated with treatment of high liquid wastes at the facility.The only costs presented in the application was the cost to construct the mixing pad. Examples of
the communication plan may include signage, instructions posted on the county’s website, etc.
R315-303-3(2)(b)(i)
(b) An owner or operator of a solid waste management facility that utilizes processes such as dewatering other stabilization or treatment techniques shall:
(i) install and maintain a containment system having a permeability of no more than 1 x 10-7 cm/sec, that is capable of maintaining integrity under the operation of heavy equipment for:

(A) all high liquid wastes unloading areas and structures;
(B) staging areas for high liquid wastes before dewatering, stabilization, or other treatment; and
(C) areas used for dewatering, stabilization, or other treatment.
Please provide information demonstrating the proposed containment system meets the requirements.
Additionally, please provide information about where unloading areas and structures and staging areas will be located.
The current maps only depict the area that will be used as a mix pit to solidify high liquid wastes.

R315-311-2(1)(d)
(1)(d) If the Director determines that major modifications to a permit or plan of operation are justified, a new operational plan incorporating the approved modifications shall be prepared.
Please provide information on the waste handling procedures for high liquid wastes. Section 2.4 of the permit application does not indicate if all incoming high liquid wastes goes straight
into the concrete mixing pad or if it is stored elsewhere.
Additionally, please provide information on how the facility plans to manage high liquid wastes that have been received, but the concrete mixing pad isn’t available for use due to lack
of staff, the concrete mixing pad is currently in use, the concrete mixing pad is full, etc.
Additional Dead Animal Cells
Permit Condition II.A.2
Prior to construction of any landfill cell, sub-cell, engineered control system, wastetreatment facility, leachate handling system, or final cover, the permittee shall submitconstruction
design drawings and a Construction Quality Control and ConstructionQuality Assurance (CQC/CQA) Plans to the Director for approval.
Approved designdrawings and CQC/CQA plans will be incorporated into the permit through
Modification. Buildings do not require approval. The Permittee shall construct anylandfill cell, sub-cell, cell liner, engineered control system, waste treatment facility,leachate handling
system, and final cover in accordance with the design drawings andCQC/CQA Plans submitted to and approved by the Director.
Please submit CQC/CQA plans for the proposed dead animal cells.
R315-311-2(1)(d)
(1)(d) If the Director determines that major modifications to a permit or plan of operation are justified, a new operational plan incorporating the approved modifications shall be prepared.
It is unclear how many dead animal cells are being proposed. Please specify how many dead animal cells the facility is proposing to construct.
Please provide updated facility maps detailing the locations and name of each proposed cell such as “future dead animal cell #1”.
Please provide meets and bounds that identify each cell. This may be in the form of length and width of each cell and the distance from a reasonably immoveable landmark, GPS coordinates
for corners, etc.
Alternative Daily Cover
R315-303-4(4)(c)(i)
(4)(c) The use of an approved alternative daily cover is subject to the following conditions:
(i) the alternative daily cover may not present a threat to human health or the environment.
Section 4.1 of the permit application does not specify how the proposed alternative daily cover will not present a threat to human health or the environment. Please include this information.
Additionally, please clarify in this section what material(s) will be used as alternative daily cover including which cells will receive it.
High liquid wastes cannot be used as alternative daily cover. Please update the verbiage of your application in such a way the material is not described as liquid. For example, please
use “solidified grease products”.
R315-303-4(4)(c)(iii)(A)
(4)(c)(iii) The facility owner or operator shall establish the schedule for use of the approved alternative cover based on the alternative cover’s performance in controlling vectors,
fires, odors, blowing, and scavenging. The schedule shall contain the following requirements:
(A) any schedule established by the facility owner or operator shall provide for the placing of six inches of soil cover at least once per week.
Section 4.1 of the permit application does not indicate that at least six inches of soil cover will be used at least once a week. The permit application only indicates six inches of
soil cover will be applied if the alternative cover results in increased disease vectors, odors, blowing litter, or scavenging activity. Please include the use of at least six inches
of soil cover at least once per week in your proposed schedule.
Compost Permit Application
R315-310-3. General Contents of a Permit Application for a New Facility or Facility Seeking Expansion
Rule
Rule Content
Information Needed from Permittee
R315-310-3(1)(b)
(1) Each permit application for a new facility or a facility seeking expansion shall contain the following:
…
(b) a general description of the facility accompanied by facility plans and drawings signed and sealed by a professional engineer in Utah…
The permit application contains several maps affiliated with the Sevier County Sage Flat Class I Landfill. Minimal maps were provided detailing the proposed compost facility, including
but not limited to which windrows will utilize animal mortalities and require longer composting durations, where materials used for composting will be stored, etc.
R315-310-3(1)(f)
(1) Each permit application for a new facility or a facility seeking expansion shall contain the following:
…
(f) the form used to record weights or volumes of wastes required by Utah Admin. Code R315-302-2(3)(a)(i).
The form provided in the permit application only applies to animal products for compost or animal products to be diverted to the dead animal pits. Section 1.3 of the permit application
states that the compost facility will accept yard and garden waste, clean woody construction material, grease trap waste, animal mortalities, and butcher residuals.
Please provide updated forms to be utilized by the compost facility to reflect the various wastes that will be accepted for composting.
R315-310-3(1)(g)
(1) Each permit application for a new facility or a facility seeking expansion shall contain the following:
…
(g) an inspection schedule and inspection log required by Utah Admin. Code R315-302-2(5)(a).
The permit application included a monitoring log that will demonstrate where and what the windrow temperatures are. However, an inspection log for the overall facility was not included.
Please provide an inspection log for the compost facility.
Please refer to the Facility Self-Inspection Program to get an understanding of the items that should be included in the inspection log at the bottom of the page at:

https://deq.utah.gov/waste-management-and-radiation-control/solid-waste-documents-solid-waste-program
R315-310-3(1)(h)
(1) Each permit application for a new facility or a facility seeking expansion shall contain the following:
…
(g) the closure and post-closure plans required by Utah Admin. Code R315-302-3.
Section 7.7 of the permit application details closure plans and closure costs. Post-closure plans and post-closure costs were not provided.
Please provide a post-closure care plan that meets the requirements of Utah Admin. Code R315-312-3(5) and identifies the post-closure care costs for the five year monitoring period.
R315-310-3(1)(l)
(1) Each permit application for a new facility or a facility seeking expansion shall contain the following:
…
(l) An application for a new facility that is owned or operated by a local government shall include financial information that discloses the costs of establishing and operating the facility,
including:
(i) land acquisition and leasing;
(ii) construction;
(iii) estimated annual operation;
(iv) equipment;
(v) ancillary structures;
(vi) roads;
(vii) transfer stations; and
(viii) other operations not contiguous to the proposed facility that are necessary to support the facility’s construction and operation.
Section 6.1 of the permit application includes startup costs and Section 6.2 of the permit application includes descriptions of operational costs including the use of a contractor for
the initial years of operation and a future purchase of a compost windrow turner at $90,000.
Please provide the financial information that discloses the costs of establishing and operating the facility.
R315-302-2. General Facility Requirements
R315-302-2(2)(b)
(2) … each plan of operation shall include:
…
(b) a description of on-site solid waste handling procedures during the active life of the facility.
Section 7.1 of the permit application provides minimalinformation regarding the waste handling procedures for waste that will be utilized for composting.
Please provide information detailing waste handling procedures for the compost facility including but not limitedto high liquid wastes and dead animals.
R315-302-2(2)(e)
(2) … each plan of operation shall include:
…
(e) corrective action programs to be initiated if groundwater is contaminated.
Please provide information that confirms the likelihood for groundwater contamination is nonexistent.
R315-312-3. Composting Requirements
R315-312-3(1)(a)
No new composting facility shall be located in the following areas:
…
wetlands, wastercourses, or floodplains.
According to the National Wetlands Inventory (NWI) map, a ephemeral stream impacts the proposed facility. The map provided in the application does not demonstrate this.
Please provide an updated wetlands map that focuses on the compost facility.
Additionally, the Division of Water Right’s Stream Alteration Program was contacted by DWMRC on January 29, 2025. It appears that the channel is ephemeral and lacks any significant riparian
vegetation and therefore does not meet the State Engineer's definition of a regulated natural stream. As such, no state stream alteration permit is required for alteration to this channel.

R315-312-3(3)(a)
(3) Each owner or operator of a composting facility, in addition to the operational plan required in Utah Admin. Code R315-312-2(1), shall develop, keep on file, and abide by a plan
that addresses:
…
(a) detailed plans and specifications for the entire composting facility including manufacturer’s performance data for equipment.
Please provide detailed plans and specifications for the entire composting facility. This can include any schedules of maintenance required for equipment, thermometer calibration, etc.
R315-312-3(3)(b)
(3) Each owner or operator of a composting facility, in addition to the operational plan required in Utah Admin. Code R315-312-2(1), shall develop, keep on file, and abide by a plan
that addresses:
…
(b) methods of measuring, grinding or shredding, mixing, and proportioning input materials.
Please provide information detailing the methods of measuring, grinding or shredding, mixing, and proportioning input materials.
R315-312-3(3)(d)
(3) Each owner or operator of a composting facility, in addition to the operational plan required in Utah Admin. Code R315-312-2(1), shall develop, keep on file, and abide by a plan
that addresses:

…
(d) a description of any additive material, including its origin, quantity, quality, and frequency of use.
Please provide information describing any additive material, including its origin, quantity, quality, and frequency of use.