DSHW-2024-006191

Deq submit <[e-mail]>
Fwd: Draft Rules Comments and Questions
1 message
JaLynn Knudsen <[e-mail]>Mon, May 6, 2024 at 7:58 AM
To: Deq submit <[e-mail]>
SHW
---------- Forwarded message ---------
From: Spencer Merrell <[e-mail]>
Date: Friday, May 3, 2024 at 5:00:20 PM UTC-6
Subject: Draft Rules Comments and Questions
To: [e-mail] <[e-mail]>
Cc: Kendal Hacking <[e-mail]>
See Attached Document for the comments and questions for the new draft rules!

Spencer Merrell
DHI – Environmental Specialist
435.790.9925
dalboholdings.com

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DWMRC Draft Rule Questions.docx
17K
5/6/24, 1:04 PM State of Utah Mail - Fwd: Draft Rules Comments and Questions
https://mail.google.com/mail/b/AEoRXRR7iQeljWFqWDk5PQsnGV0n1MeTkhofqHSHCUMdDOupaVZD/u/0/?ik=adf9d5e615&view=pt&search=all&per…1/1
Draft Rules Comments and Questions:
Landfarms:
1.Will DWMRC allow landfarms to continue operating without a liner?
a.If so-What can and can’t go in the landfarm. Will there be any analytics or MDL”
minimum detection limits to stay under. Metals, Chlorides, Sulfates ETC.
b.If not- What can and can’t go in the landfarm
2.Will there be any regulatory on existing or new landfarms material depths?
3.WMRC has stated that landfarms can be reclaimed by covering them in soil or clay. Is
any post closure monitoring required in this process?
4.Is landfarm bonding the same for all companies based on what criteria?
5.Is any soil testing required of both the material in the landfarm and or the soil cap?
a.Would closure of a landfarm in this manner result in the release of any bonding
being held for a landfarm?
Landfills:
1.There needs to be a better definition of what landfills require a liner and what is the
definition of a landfill with no liner?
a.What is allowed in a landfill with a liner? ie E&P waste only or Oil and gas
industrial waste?
b.What is allowed in a landfill without a liner?
2.Is landfill bonding the same for all companies based on what criteria?
Skim Ponds:
3.Need definition on netting and size requirements of netting or be open to suggestions
from the operators.
4.Skim ponds by EPA air quality standards need to have a oil cap layer on them.
Ponds:
1.Free board requirements are 3’ I would keep that rule the same as DOGM and keep it at
2’ this is the case in many other states.
Additional questions:
Most existing disposal facilities were not constructed with dual HDPE liners and therefore would
not meet the liner spec outlined for surface impoundments but have been permitted with DOGM.
How does WMRC intend to manage facilities with ponds constructed in this manner?