DSHW-2023-211281 - 0901a068812af525

DSHW-2023-211281 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. 711
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director

December 15, 2023

Tsuyoshi Okano, President
Contract Environmental Services, Inc.
925 South Broadway, Suite 251
Cortez, CO 81321

RE: Routine Inspection – Contract Environmental Services, Inc. Landfarm

Dear Mr. Okano:

On October 11, 2023, a representative of the Division of Waste Management and Radiation Control
(Division) performed an inspection of the Contract Environmental Services, Inc. Landfarm located
approximately one mile west of Hovenweep National Monument. The purpose of this inspection was to
discuss future facility plans and any concerns as regulatory oversight transfers from the Utah Department of
Natural Resources, Division of Oil, Gas, and Mining (DOGM) to the Utah Department of Environmental
Quality, Division of Waste Management and Radiation Control. The details of the inspection are
documented in the enclosed inspection report.

As discussed during the inspection, both DOGM and the Division are working to revise rules for the
management of oil and gas exploration waste disposal facilities. The rule revisions are expected to require
existing DOGM-permitted landfarms that wish to continue receiving waste, to obtain a landfill permit from
the Division. You may apply for a landfill permit at any time.

If you have any questions, please contact Wade Hess by email at [e-mail] or by phone at
385-454-5877.

Sincerely,

Brian Speer, Solid Waste Section Manager
Division of Waste Management and Radiation Control
(Over)

BS/WH/wa

Enclosure: Solid Waste Program Facility Inspection Report Checklist (DSHW-2023-211960)

c: Grant Sunada, Health Director, San Juan Public Health Department
Ronnie Nieves, Environmental Health Director, San Juan Public Health Department
Russell Seeley, District Engineer, UDEQ
Orlan Wallace, Oil and Gas Permitting Manager, DOGM, UDNR (Email)
Site Information
Finalized Yes
Facility Name San Juan County Non Facility Specific Inspections
Facility_ID 372
Facility Name San Juan County Non Facility Specific Inspections
Street Address Contract Environmental, West of Hovenweep National Monument
City Aneth
ZIP Code 84510
County San Juan
Inspection Date 10-11-2023
Type of Visit Routine Oversite
Is the Visit Announced?Yes
40.704012, -111.881418
Weather Conditions 70°, sunny
Inspection Goal To discuss Oil and Gas Exploration and Production waste rules and
facility’s future plans.
Facility Contact Tsuyoshi Okano, Owner
Participants Wade Hess, DWMRC
Tsuyoshi Okano, Owner
Follow Up Inspection Needed?N/A
Recommended Follow Up Date
Depart Office Date 10-11-2023
Depart Office time 08:00 PM (-6 GMT)
Return to Office Date 10-12-2023
Return to Office time 06:00 PM (-6 GMT)
1. Pre-Inspection Review
1.1 Permit Review N/A
Comment This facility is not currently permitted by DWMRC.
1.2 Annual Report Review N/A
Comment This facility is not currently permitted by DWMRC.
1.3 Previous Inspection Review N/A
Comment There is not a previous inspection to review.
1.4 Facility Contacts Confirmed Yes
Date Submitted: 11-03-2023 10:38 AM
Submitted By: [e-mail]
Solid Waste Program Facility Inspection Report Checklist
Page 1 of 8
Comment Confirmed.
1.5 Facility Contacted (If an
announced inspection)
Yes
Comment Called Tsuyoshi Okano 10/5/23
1.6 Local Health Contacted Yes
Comment Emailed Ronnie Nieves, San Juan County HD, 10/5/23
1.7 Other N/A
Comment N/A
2. Facility / Operational Controls (1-Good, 5-Poor)
2.1 Litter NA
2.2 Roads 1
2.3 Gate House Operations 1
2.4 Vectors NA
2.5 Communications
2.6 Recycling Area NA
2.7 Fugitive Dust Control 1
2.8 Waste Inspection Area NA
2.9 Scavenging Control 1
2.10 Open Burning NA
2.11 Fences, Gates, Locks,
Access Control
1
2.12 Working Face NA
2.13 Daily - Soil NA
2.14 Daily - Alternative NA
2.15 Leachate Collection System NA
2.16 Other NA
Comment (Required)No issues. Operational controls are sufficient.
3. Signs Required / Properly Posted
3.1 Operating Days / Hours Yes
3.2 Directions & Procedures Yes
3.3 Emergency Numbers Yes
3.4 List of Unacceptable Materials Yes
3.5 Other Yes
Comment (Required)Signs are posted.
Date Submitted: 11-03-2023 10:38 AM
Submitted By: [e-mail]
Solid Waste Program Facility Inspection Report Checklist
Page 2 of 8
4. Operator / Representative / Employees
4.1 On-site While Open Yes
4.2 Training Yes
4.3 Other Yes
Comment (Required)Employees trained and on site.
5. Monitoring
5.1 Methane N/A
5.2 Random Inspections Yes
5.3 Leachate N/A
5.4 Ground Water N/A
5.5 Other N/A
Comment (Required)Each load is inspected. No other monitoring is required.
6. Drainage / Erosion
6.1 Water Run-on Yes
6.2 Water Run-off Yes
6.3 Other Yes
Comment (Required)Controls in place.
7. Proper Storage / Isolation / Disposal
7.1 Special Waste Yes
7.2 Batteries N/A
7.3 Hazardous Waste N/A
7.4 Infectious Waste N/A
7.6 Dead Animals N/A
7.7 Asbestos N/A
7.8 Bulky Waste N/A
7.9 Contaminated Soil Yes
7.10 Ash N/A
7.11 Sludge N/A
7.12 Other N/A
Comment (Required)Special waste handled correctly.
8. Cover
8.1 Intermediate N/A
Date Submitted: 11-03-2023 10:38 AM
Submitted By: [e-mail]
Solid Waste Program Facility Inspection Report Checklist
Page 3 of 8
8.2 Final N/A
8.3 Vegetation N/A
8.4 Other N/A
Comment (Required)Cover is not applied.
9. Inspection Records
9.1 Random Inspection Report N/A
9.2 Gas Monitoring System N/A
9.3 Surface Drainage Control N/A
9.4 Daily Records Yes
9.5 Weight or Volumes Yes
9.6 Intermediate Cover N/A
9.7 Final Cover N/A
9.8 Self Inspection (Quarterly
Reports)
Yes
9.9 Deviation From Plans N/A
9.10 Permit, Permit Application,
and Rules Available
Yes
9.11 Other N/A
Comment (Required)Records are kept.
10. Monitoring / Sampling / Analysis Records
10.1 Explosive Gas Monitoring N/A
10.2 Leachate Sampling &
Treatment
N/A
10.3 Ground Water Sampling
Results
N/A
10.4 Other N/A
Comment (Required) Monitoring at this facility is not required.
11. Special Waste Records
11.1 Lab Analysis Results N/A
11.2 Manifests Yes
11.3 Treatment Certification Yes
11.4 Paint Filter Test Results Yes
11.5 Onsite Treatment
Documentation
Yes
11.6 Other N/A
Date Submitted: 11-03-2023 10:38 AM
Submitted By: [e-mail]
Solid Waste Program Facility Inspection Report Checklist
Page 4 of 8
Comment (Required)Special waste records kept.
12. Waste Tires
12.1 Acceptance procedures for
Waste Tires
N/A
12.2 Waste Tire Pile Segregated N/A
12.3 Estimated Quanitity of Waste
Tires
No
Number of Tires
12.4 Waste Tire Fund Training N/A
Comment (Required)Waste tires are not accepted.
13 Other Items
13.1 Notice of Inspections Form
Completed and Signed
N/A
13.2 N/A
13.3 N/A
13.4 N/A
Comment (Required)N/A
14. Special Permit Requirements
14.1 N/A
14.2 N/A
14.3 N/A
Comment (Required)N/A
General Comments
Comments Facility and operational controls are satisfactory. Discussed the future of the
facility as regulatory control moves from DOGM to DWMRC. Discussed the
option of beginning to landfill instead of landfarm.
DWMRC Inspector Signature
DWMRC Inspector Name Wade Hess
Date/Time 10-11-2023
Photos
Date Submitted: 11-03-2023 10:38 AM
Submitted By: [e-mail]
Solid Waste Program Facility Inspection Report Checklist
Page 5 of 8
Attach Photos
Landfarm cell.
Road.
Signage at entrance.
Date Submitted: 11-03-2023 10:38 AM
Submitted By: [e-mail]
Solid Waste Program Facility Inspection Report Checklist
Page 6 of 8
Entrance gate.
Landfarm cell.
Facility plan.
Date Submitted: 11-03-2023 10:38 AM
Submitted By: [e-mail]
Solid Waste Program Facility Inspection Report Checklist
Page 7 of 8
Form Locations
Date Submitted: 11-03-2023 10:38 AM
Submitted By: [e-mail]
Solid Waste Program Facility Inspection Report Checklist
Page 8 of 8