Temp - DSHW-2025-001543

DSHW-2023-004424 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

February 21, 2025

Rob Hartman, Environmental Manager
US Magnesium LLC
238 North 2200 West
Salt Lake City, UT 84116

RE: Draft Permit for Review – US Magnesium LLC Class IIIb Landfill
SW223

Dear Mr. Hartman:

The Division of Waste Management and Radiation Control (Division) has completed its review of your
permit application to operate the US Magnesium LLC Class IIIb Landfill to dispose of on-site industrial
waste.

A draft permit has been prepared and is enclosed with this letter. Please review the draft permit and
provide any comments to the Division. Following your review and approval, the Division will initiate
the required 45-day public comment period for the draft permit.

If you have any questions, please call Beatriz Ávila 385-515-0723.

Sincerely,

Brian Speer, Solid Waste Program Manager
Division of Waste Management and Radiation Control

(Over)

BS/BA/wa

Enclosures: Draft US Magnesium Class IIIb Landfill Permit (DSHW-2023-004409)
Attachment #1 – Design and Construction (DSHW-2023-004420)
Attachment #2 – Plan of Operation (DSHW-2023-004421)
Attachment #3 – Inspection Forms (DSHW-2023-004412)
Attachment #4 – Closure & Post-Closure Plans (DSHW-2023-004433)

c: Grant Sunada, Health Officer, Tooele County Health Department
Taylor Palmer, Environmental Health Director, Tooele County Health Department
Annette Maxwell, U.S. EPA, Region 8
Rob Hartman, Environmental Manager, US Magnesium LLC (Email and Hard Copy)

Page 1 of 14

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
SOLID WASTE LANDFILL PERMIT
US Magnesium Class IIIb Landfill

Pursuant to the Utah Solid and Hazardous Waste Act, Title 19, Chapter 6, Part 1 (the Act) of the
Utah Code and Utah Administrative Code R315-301 et seq. (the Rules) adopted thereunder, this
Permit is issued to:

US Magnesium LLC as owner and operator (the Permittee),

of the US Magnesium Class IIIb Landfill located in the East one-half of the East one-half of
Section 10, Township 2 North, Range 8 West, Salt Lake Base and Meridian, Tooele County,
Utah as shown in the Permit Application that was determined complete on January 26, 2022
(DSHW-2021-024922).

The Permittee is subject to the requirements of the Rules and the requirements set forth herein.

All references to the Rules are to regulations that are in effect on the date that this Permit
becomes effective.

This Permit shall become effective .
Closure Cost Revision Date: .
This Permit shall expire at midnight .
Signed this day of , 2025.

Douglas J. Hansen, Director
Division of Waste Management and Radiation Control

Page 2 of 14

FACILITY OWNER/OPERATOR INFORMATION

LANDFILL NAME:

US Magnesium Class IIIb Landfill
OWNER NAME:

US Magnesium LLC
OWNER ADDRESS:

238 North 2200 West
Salt Lake City, UT 84116

OWNER PHONE NO.:

801-532-1522
OPERATOR NAME: Same as Owner

OPERATOR ADDRESS:

Same as Owner

OPERATOR PHONE NO.:

Same as Owner

TYPE OF PERMIT:

Class IIIb Landfill

PERMIT NUMBER:

Application No. A-132397 until permit issuance
LOCATION:

Landfill site is located in the East one-half of the
East one-half of Section 10, Township 2 North,
Range 8 West, Salt Lake Base and Meridian, Tooele
County, Utah, Lat. 40º 54’ 49.5" North,
Long. 112º 44' 1.5" West.

12819 N Rowley Rd.
Skull Valley, UT 84029

PERMIT HISTORY

This is the first permit for this facility.

Page 3 of 14

RECITALS

A. The term “Permit” as used in this document is defined in Utah Admin. Code
R315-301-2(59). “Director” as used throughout this Permit refers to the Director of the
Division of Waste Management and Radiation Control (Division).

B. The Division determined the Permit Application (DSHW-2021-025123) for the US
Magnesium Class IIIb Landfill was complete on January 26, 2022
(DSHW-2021-024922). On February 12, 2024, a US Magnesium LLC representative
emailed clarifications on the boundaries of the facility and the presence of a designated
asbestos disposal location. This email has been included in Attachment #1. On
October 17, 2024, a US Magnesium LLC representative submitted updates to information
about waste load inspections and training that are included in Attachment #2, and closure
and post-closure cost updates that are included in Attachment #4.

C. This Permit consists of the signature page, Facility Owner/Operator Information section,
General Permit Conditions, Specific Permit Conditions, and four attachments.

D. The “facility” as described in this Permit consists of a Class IIIb Landfill cell for
industrial and general waste from the US Magnesium facility. The facility has a footprint
of 33.4 acres.

E. The facility’s landfill cell currently has an estimated volume of 830,000 cubic yards of
waste with 28.5 acres of working area. The proposed total capacity of the landfill cell is
estimated at 2,570,000 cubic yards with 32 acres of working area.

GENERAL PERMIT CONDITIONS

1. CONTROLLING TERMS
Where differences in wording exist between this Permit and the attachments of this
Permit, the wording of this Permit supersedes that of the attachments.

2. COMPLAINCE NO DEFENSE
Compliance with this Permit does not constitute a defense to actions brought under any
other local, state, or federal laws. This Permit does not exempt the Permittee from
obtaining any other local, state, or federal permits or approvals required for the facility’s
operation.

3. EFFECT OF PERMIT
The issuance of this Permit does not convey any property rights, in either real or personal
property, or any exclusive privileges. Nor does this Permit authorize any injury to private
property or any invasion of personal rights, nor any infringement of local, state, or federal
laws or regulations, including zoning ordinances.

Page 4 of 14

4. SEVERABILITY
The provisions of this Permit are severable. If any provision of this Permit is held invalid
for any reason, the remaining provisions shall remain in full force and effect. If the
application of any provision of this Permit to any circumstance is held invalid, its
application to other circumstances shall not be affected.

5. INCORPORATION OF RECITALS
The aforementioned recitals are expressly incorporated into and made part of this Permit.

6. INCORPORATION OF ATTACHMENTS
Attachments to this Permit are incorporated by reference into and made part of this
Permit, as are documents incorporated by reference into the attachments. All
representations made in the attachments of this Permit are enforceable under Utah
Admin. Code R315-301-5(2).

By this Permit, the Permittee is subject to the following conditions.

Page 5 of 14

SPECIFIC PERMIT CONDITIONS
I. GENERAL COMPLIANCE RESPONSIBILITIES
I.A. General Operation
I.A.1. The Permittee shall operate the landfill in accordance with all applicable requirements
of Utah Admin. Code R315-304, that are in effect as of the date of this Permit unless
otherwise noted in this Permit. Any permit noncompliance or noncompliance with any
applicable portions of the Act or the Rules constitutes a violation of this Permit or
applicable statute or rule and is grounds for appropriate enforcement action, Permit
revocation, modification, termination, or denial of a Permit renewal application.
I.B. Acceptable Waste
I.B.1. This Permit is for disposal of nonhazardous industrial solid waste, as defined in Utah
Admin. Code R315-301-2(38), generated by US Magnesium; and
I.B.2. The Permittee is authorized to receive for disposal regulated asbestos-containing
material in compliance with Utah Admin. Code R315-315-2 and this Permit.
I.C. Prohibited Waste
I.C.1. Any prohibited waste received and accepted for disposal at the facility shall constitute a
violation of this Permit, the Act and the Rules.
I.C.2. Prohibited waste includes, but is not limited to:
I.C.2.a Hazardous waste as defined by Utah Admin. Code R315-261;
I.C.2.b PCBs as defined by Utah Admin. Code R315-301-2(57), except PCBs specified by
Utah Admin. Code R315-315-7(2)(a) and (c);
I.C.2.c Household waste as defined by Utah Admin. Code R315-301-2(36);
I.C.2.d Municipal solid waste as defined by Utah Admin. Code R315-301-2(50);
I.C.2.e Special waste as defined by Utah Admin. Code R315-301-2(76), except as specified in
this Permit;
I.C.2.f Commercial solid waste as defined by Utah Admin. Code R315-301-2(15); and
I.C.2.g Containers larger than household size (five gallons) holding any liquid,
non-containerized material containing free liquids or any waste containing free liquids
in containers larger than five gallons.
I.D. Inspections and Inspection Access
I.D.1. The Permittee shall allow the Director or an authorized representative, or
representatives from the Tooele County Health Department, with or without prior
notice, to enter at reasonable times to:

Page 6 of 14

I.D.1.a Inspect the facility or other premises, practices, or operations regulated or required
under the terms and conditions of this Permit or the Rules;
I.D.1.b Have access to and make copies of any records required to be kept under the terms and
conditions of this Permit or the Rules;
I.D.1.c Inspect any loads of waste, treatment facilities or processes, pollution management
facilities or processes, or control facilities or processes required under this Permit or
regulated under the Rules; and
I.D.1.d Use photographic equipment, video camera, electronic recording device, or any other
reasonable means to record information during an inspection.
I.E. Noncompliance
I.E.1. If monitoring, inspection, or testing indicates that any condition of this Permit or any
applicable requirement of the Act or the Rules may be or is being violated, the
Permittee shall promptly make corrections to the operation or other activities to bring
the facility into compliance with the Act, the Rules, and this Permit.
I.E.2. In the event of noncompliance with any condition of this Permit or violation of an
applicable Rule, the Permittee shall promptly take any action reasonably necessary to
correct the noncompliance or violation and mitigate any risk to the human health or the
environment. Actions may include, but are not limited to, the Permittee eliminating the
activity causing the noncompliance or violation and containment of any waste or
contamination using barriers or access restrictions, placing warning signs at the facility,
or permanently closing all or certain areas of the facility.
I.E.3. The Permittee shall:
I.E.3.a Document the noncompliance or violation in the daily operating record, on the day the
noncompliance occurred or the day it was discovered;
I.E.3.b Notify the Director by telephone within 24 hours, or the next business day following
documentation of the noncompliance or violation; and
I.E.3.c Give written notice of the noncompliance or violation and measures taken to protect
human health and the environment to the Director within seven days of documenting
the noncompliance or violation.
I.E.4. Within 30 days after the documentation of the noncompliance or violation, the
Permittee shall submit to the Director a written report describing the nature and extent
of the noncompliance or violation and the remedial measures taken or to be taken to
protect human health and the environment and to eliminate the noncompliance or
violation. Upon receipt and review of the assessment report, the Director may order the
Permittee to perform appropriate remedial measures such as development of a site
remediation plan for approval by the Director.
I.E.5. In an enforcement action, the Permittee may not claim as a defense that it would have
been necessary to halt or reduce the permitted activity in order to maintain compliance
with the Rules and this Permit.

Page 7 of 14

I.F. Revocation
I.F.1. This Permit is subject to revocation if the Permittee fails to comply with any condition
of this Permit. The Director will notify the Permittee in writing prior to any proposed
revocation action and such action shall be subject to all applicable procedures
established under Utah Admin. Code R315-124-5 and the Utah Administrative
Procedures Act, Utah Code Section 63G-4-101 et seq.
II. DESIGN AND CONSTRUCTION
II.A. Design and Construction
II.A.1. The landfill shall be constructed according to the design outlined in Attachment #1 and
in the area designated in Attachment #1, including landfill cells, fences, gates, and
berms.
II.A.2. If groundwater is encountered during excavation of the landfill, the Permittee shall
notify the Director immediately, implement a contingency plan, and develop and
submit an alternative construction design for approval.
II.A.3. No later than 90 days after construction, the Permittee shall:
II.A.3.a Notify the Director of completion of construction of any engineered structure or
feature, excluding buildings, and including but not limited to any landfill cell, sub-cell,
landfill liner, monitoring system, control or collection system, waste treatment unit, or
final cover; and
II.A.3.b Submit construction documents, including as-built documents for each construction
event, to the Director for review.
II.A.4. No waste shall be accepted into an engineered structure or feature until the Director has
reviewed the as-built documents and has provided approval for the acceptance of waste.
II.B. Run-On and Run-Off Control
II.B.1. The Permittee shall ensure that drainage as presented in Attachment #1 is maintained,
or shall construct drainage channels and diversions to meet the requirements of Utah
Admin. Code R315-303-3(1)(c) and (d).
II.B.1.a The Permittee shall prevent run-on from entering the active area of the facility; and
run-off control systems shall contain, and collect and treat, if necessary, run-off from
the active area of the facility.
III. LANDFILL OPERATION
III.A. Operations Plan
III.A.1. At all times, the Permittee shall keep the Plan of Operation included in Attachment #2
on site at the facility or at the location designated in Section III.H of this Permit. The
Permittee shall operate the landfill in accordance with the Plan of Operation. If

Page 8 of 14

necessary, the Permittee may modify the Plan of Operation following the procedures of
Utah Admin. Code R315-311-2(1) upon approval from the Director. The Permittee
shall note any modification to the Plan of Operation in the daily operating record.
III.B. Security
III.B.1. The Permittee shall operate the facility so that unauthorized entry to the facility is
restricted. The Permittee shall:
III.B.1.a Lock all facility gates and other access routes while the facility is closed;
III.B.1.b Have at least one person employed by the Permittee at the landfill while the facility is
open; and
III.B.1.c Construct and maintain all fencing and any other access controls as required by Utah
Admin. Code R315-303-3(8) to prevent access by the public and large animals.
III.C. Training
III.C.1. The Permittee shall provide training for on-site personnel in landfill operation,
including but not limited to waste load inspection, hazardous waste identification, and
personal safety and protection, and relevant documentation and notification
requirements.
III.D. Burning of Waste
III.D.1. Intentional burning of solid waste is prohibited and is a violation of Utah Admin. Code
R315-303-4(2)(b).
III.D.2. The Permittee shall take reasonable steps to prevent the ignition of accidental fires,
maintain adequate fire protection to control any fires that may occur at the facility, and
extinguish all accidental fires that ignite despite these steps as soon as reasonably
possible.
III.E. Cover
III.E.1. The Permittee shall cover the waste as necessary to prevent fires and to control vectors,
blowing litter, odor, scavenging, and fugitive dust. The Permittee shall cover wastes
that are capable of attracting or providing food for vectors, materials that may become
windblown litter, or fine materials that may become fugitive dust with a minimum of
six inches of earthen cover at the end of each working day on which the facility
receives waste.
III.E.2. The Permittee shall use a minimum of six inches of earthen cover no less than once
each month for all waste received at the landfill. This cover shall consist of soil; no
alternative may be used, unless the material and operation meet the requirements of
Utah Admin. Code R315-303-4(4)(b)-(e).
III.E.3. The Permittee shall record in the daily operating record and the operator shall certify, at
the end of each day of operation when soil or an alternative cover is placed, the amount
and type of cover placed, and the area receiving cover.

Page 9 of 14

III.E.4. Cover requirements for dead animals are found in Section III.L of this Permit.
III.F. Waste Inspections
III.F.1. The Permittee shall visually inspect incoming waste loads to verify that no wastes other
than those allowed by this Permit are disposed in the landfill. The Permittee shall
conduct a complete waste inspection at a minimum frequency of 1% of incoming loads
but no less than one complete inspection per day. The Permittee shall select the loads
to be inspected on a random basis.
III.F.2. The Permittee shall inspect all loads suspected or known to have one or more
containers capable of holding more than five gallons of liquid to ensure that each
container is empty.
III.F.3. The Permittee shall inspect all loads that the Permittee suspects may contain a waste
not allowed for disposal at the landfill.
III.F.4. The Permittee shall conduct random inspections as follows:
III.F.4.a The Permittee shall conduct the random waste inspection at the working face, or an
area designated by the Permittee;
III.F.4.b The Permittee shall require the loads subjected to inspection be unloaded at the
designated area;
III.F.4.c The Permittee shall use equipment or hand tools to spread loads for inspection;
III.F.4.d Personnel trained in hazardous waste recognition and recognition of other unacceptable
waste shall conduct a visual inspection of the waste;
III.F.4.e The personnel conducting the inspection shall record the results of the inspection on a
waste inspection form as found in Attachment #3. The Permittee shall place the form
in the daily operating record at the end of the operating day; and
III.F.4.f The Permittee or the waste transporter shall properly dispose of any waste that is not
acceptable at the facility at an approved disposal site for the waste type and handle the
waste according to the rules covering the waste type.
III.G. Self Inspections
III.G.1. The Permittee shall inspect the facility to prevent malfunctions and deterioration,
operator errors, and discharges that may cause or lead to the release of wastes or
contaminated materials to the environment or create a threat to human health or the
environment.
III.G.2. The Permittee shall complete these inspections no less than quarterly and shall include
the following areas: Waste placement, cover; fences and access controls; roads;
run-on/run-off controls; final and intermediate cover; litter controls; and records.
III.G.3. The Permittee shall place a record of the inspections in the daily operating record on
the day of the inspection. The Permittee shall correct the problems identified in the

Page 10 of 14

inspections in a timely manner and document the corrective actions in the daily
operating record.
III.H. Recordkeeping
III.H.1. The Permittee shall maintain and keep on file in the main office a daily operating
record and other general records of landfill operation as required by Utah Admin. Code
R315-302-2(3). The landfill operator, or other designated personnel, shall date and
sign the daily operating record at the end of each operating day. Each record kept by
the Permittee shall contain the signature of the appropriate operator or personnel and
the date signed. The daily operating record shall consist of the following two types of
documents:
III.H.1.a Records related to the daily landfill operation and periodic events, including:
The number of loads of waste and the weights or estimates of weights or volumes
of waste received each day of operation and recorded at the end of each operating
day;
Major deviations from the approved Plan of Operation, recorded at the end of the
operating day the deviation occurred;
Results of monitoring required by this Permit recorded in the daily operating
record on the day of the event or the day the information is received; and
Records of all inspections conducted by the Permittee, results of the inspections,
and, if necessary, corrective actions taken shall be recorded in the daily operating
record on the day of the event.
III.H.1.b Records of a general nature, including:
A copy of this Permit, including all attachments;
Results of inspections conducted by representatives of the Director and of
representatives of the local health department, when forwarded to the Permittee;
Closure and Post-closure care plans; and
Records of employee training.
III.I. Reporting
III.I.1. The Permittee shall prepare and submit to the Director an Annual Report as required by
Utah Admin. Code R315-302-2(4), using the Division’s Community Portal.
III.J. Roads
III.J.1. The Permittee shall improve and maintain all access roads at the facility that are used
for transporting waste to the disposal area to assure safe and reliable all-weather access
to and from the disposal area.

Page 11 of 14

III.K. Litter Control
III.K.1. The Permittee shall minimize litter resulting from operations of the landfill. In addition
to the litter control plans required by Utah Admin. Code R315-302-2(2)(h) and found in
Attachment #2, the Permittee shall implement the following procedures when high
wind conditions are present:
III.K.1.a Reduce the size of the tipping face;
III.K.1.b Reduce the number of vehicles allowed to discharge at the tipping face at one time;
III.K.1.c Orient vehicles to reduce wind effects on unloading and waste compaction;
III.K.1.d Reconfigure tipping face to reduce wind effect;
III.K.1.e Use portable and permanent wind fencing as needed; and
III.K.1.f Should high winds present a situation where the windblown litter cannot be controlled,
the Permittee shall cease operations of the landfill until the winds diminish.
III.L. Disposal of Special Wastes
III.L.1. The Permittee may dispose of dead animals in the landfill working face and shall cover
them with other solid waste or earthen cover by the end of the operating day on which
the carcasses are received. Alternatively, the Permittee may dispose of dead animals in
a special trench or pit prepared for the acceptance of dead animals. If a special trench
is used, the Permittee shall completely cover dead animals placed in the trench with a
minimum of six inches of earthen cover by the end of the operating day the dead
animals are received.
III.L.2. The Permittee shall handle and dispose of asbestos waste in accordance with Utah
Admin. Code R315-315-2.
III.L.2.a The Permittee shall handle and dispose of asbestos waste in accordance with Utah
Admin. Code R315-315-2. Dispose of all asbestos waste in the dedicated asbestos
disposal location, as demonstrated by Attachment #1.
III.M. Groundwater Monitoring
III.M.1. The groundwater monitoring requirement for the US Magnesium Class IIIb Landfill
has been waived in accordance with Utah Admin. Code R315-304-5(4)(c). Any
contamination of groundwater resulting from operation of the landfill shall result in the
revocation of this waiver.

Page 12 of 14

IV. CLOSURE REQUIREMENTS
IV.A. Closure
IV.A.1. Final cover of the landfill shall be as shown in Attachment #4. Pursuant to Utah
Admin. Code R315-304-5(2)(b), the final cover shall meet, at a minimum, the standard
design for closure as specified in Utah Admin. Code R315-305-5(5)(b).
IV.A.2. Upon completion of closure activities, the Permittee shall submit to the Director, for
approval, all documents demonstrating closure activities and a certification from the
owner or operator that the landfill has been closed in accordance with the approved
Closure Plan.
IV.B. Title Recording
IV.B.1. The Permittee shall meet the requirements of Utah Admin. Code R315-302-2(6) by
recording a notice with the Tooele County Recorder as part of the record of title that the
property has been used as a landfill. The notice shall include waste disposal locations
and types of waste disposed. The Permittee shall provide the Director with the notice
as recorded.
IV.C. Post-Closure Care
IV.C.1. Upon approval from the Director that the facility has been closed in accordance with
the approved Closure Plan, the Permittee shall apply for a Post-Closure Care Permit in
accordance with Utah Admin. Code R315-310-10.
IV.C.2. The Permittee shall perform post-closure care at the closed facility in accordance with
the Post-Closure Care Plan contained in Attachment #4 until a Post-Closure Care
Permit is issued by the Director. Post-closure care shall continue until all waste
disposal cells at the facility have stabilized and the Director makes a finding under Utah
Admin. Code R315-302-3(7)(c).
IV.D. Financial Assurance
IV.D.1. The Permittee shall keep in effect and active the currently approved mechanism that
meets the requirements of Utah Admin. Code R315-309 and is approved by the
Director to cover the costs of closure and post-closure care at the facility. The
Permittee shall adequately fund and maintain the financial assurance mechanism to
provide for the cost of closure at any stage or phase or anytime during the life of the
facility or life of this Permit, whichever is shorter. The Permittee shall keep the
approved financial assurance mechanism in effect and active until closure and
post-closure care activities are completed and the Director has released the facility from
all post-closure care requirements.
IV.E. Financial Assurance Annual Update
IV.E.1. The Permittee shall update the financial assurance annually to adjust for inflation or
facility modification that would affect closure or post-closure costs, as required by Utah

Page 13 of 14

Admin. Code R315-309-2(2). The Permittee shall provide this update to the Director
as part of the Annual Report.
IV.F. Closure Cost and Post-Closure Cost Revision
IV.F.1. The Permittee shall submit a complete revision of the closure and post-closure cost
estimates by the Closure Cost Revision Date listed on the signature page of this Permit
and any time the facility is expanded, any time a new cell is constructed, or any time a
cell is expanded.
V. ADMINISTRATIVE REQUIREMENTS
V.A. Permit Modification
V.A.1. Modifications to this Permit may be made by the Permittee or by the Director in
accordance with the procedures specified in Utah Admin. Code R315-311-2. The
Permittee may initiate a modification by submitting a written request to the Director.
The Director may initiate a modification by giving written notice to the Permittee.
V.B. Permit Transfer
V.B.1. This Permit may be transferred to a new Permittee or new Permittees by complying
with the permit transfer provisions specified in Utah Admin. Code R315-310-11.
V.C. Expansion
V.C.1. This Permit is for the operation of a Class IIIb Landfill according to the Design and
Construction specified in Attachment #1 and the Plan of Operation described and
explained in Attachment #2. The Permittee shall submit plans and specifications to the
Director for any lateral expansion of the facility’s current landfill cell as further
described in Attachment #1, or lateral expansion including a new landfill cell or
disposal area within the facility’s property boundaries. The Permittee shall receive
approval of the plans and specifications from the Director prior to expanding the
facility.
V.C.2. Any expansion of the facility beyond the facility’s property boundaries as further
described in Attachment #1 shall require the Permittee to submit a new permit
application in accordance with the requirements of Utah Admin. Code R315-310.
V.C.3. Any addition to the list of acceptable waste in Section I.B. of this Permit shall require a
permit modification in accordance with Utah Admin. Code R315-311.
V.D. Permit Renewal
V.D.1. If the Permittee desires to continue operating this facility after the expiration date of
this Permit, the Permittee shall submit an application for permit renewal at least six
months prior to the expiration date, as shown on the signature page of this Permit. If
the Permittee timely submits a permit renewal application and the permit renewal is not

Page 14 of 14

complete by the expiration date, this Permit shall continue in force until the permit
renewal is completed or the renewal application is denied.
VI. ATTACHMENTS
Attachment #1 – Design and Construction
Attachment #2 – Plan of Operation
Attachment #3 – Inspection Forms
Attachment #4 – Closure & Post-Closure Plans
US Magnesium Permit
Attachment #1 - Design and Construction
Class IIlb Landfill Permit Application US Magnesium LLC
Rowley. Utah Plant
5.0 FACILITY TECHNICAL INFORMATION
Tetra Tech retained Cook Surveying and Associates to perform a topographic survey during November 2021 to
support development of a current topographic map of the landfill area. The survey has been used to develop the
following drawings for this landfill permit application:
Drawing 1 Existing Conditions Plan
Drawing 2 Final Waste Extent & Grade Plan
Drawing 3 Final Cover Plan
Drawing 4 Stormwater Management Plan
The aerial photograph included as background for the drawings was obtained by US Magnesium during
September 2021 through high resolution satellite imagery.
The drawings are included with this permit application at the end of this supplemental information under a cover
sheet labeled "Drawings." The drawing were developed to present the preliminary landfill design, extrapolate
material quantities for current waste volume and remaining landfill capacity, present the approach for landfill
closure, and estimate the costs for landfill closure as presented in this permit application.
5 1 TOPOGRAPHIC MAP
A topographic map of the current landfill is included as Drawing 1 — Existing Conditions Plan. This plan is drawn
to scale with one-foot contour intervals. This drawing shows the current landfill features and surrounding
operations. The drawing presents the current extent of waste.
5.2 ENGINEERING REPORT - PLANS, SPECIFICATIONS, AND CALCULATIONS
Drawings 2, 3 and 4 present the preliminary design for operation and closure of the landfill. This section describes
the operational aspects of the design and Section 6 presents the closure plan.
Waste materials will continue to be hauled by trucks to the landfill for placement in piles or windrows on the top
surface of the landfill. The trucks access the landfill from dirt roads that enter from the west and drive to the active
operational area of the landfill for waste placement. It is anticipated that over the life of the landfill, the locations
for access and haul roads will be modified to allow placement of materials in the areas needed to fill the remaining
landfill capacity.
The waste piles and windrows are graded using front-end loaders that push materials toward the tipping faces on
the east, north and south sides of the landfill. The wastes are generally graded in horizontal lifts measuring 1 to 2
feet thick prior to placement of weekly cover described in Section 5. The placement and buildup of waste will
continue until the waste grades shown on the Drawing 2 are achieved and the site is ready for closure. The final
waste grade slopes will measure three horizontal to one vertical on the side slopes (3H:1V), which are considered
stable for the types of industrial wastes placed at the landfill. The plateau top of the landfill will have slopes of
approximately 5% to promote stormwater runoff and preclude ponding.
As previously stated, the site receives little precipitation (i.e., approximately 9 inches per year), and the
precipitation that is received primarily infiltrates into the waste within the landfill area. The area surrounding the
landfill is generally flat, so there is little potential for run-on of stormwater onto the landfill which is elevated above
the surrounding ground surface. In the event that the site receives sufficient precipitation to generate run-off from
the landfill, the existing contours direct water toward and around the base of the landfill and toward the waste
pond to the east, which is a suitable discharge point for runoff from the landfill.
lc TETRA TECH December 16, 2021
Class IIlb Landfill Perrnit Application US Magnesium LLC
Rowley. Utah Plant
AutoCAD Civil3D was used by Tetra Tech to quantify the existing and final areal footprints for the landfill, the
existing volume of waste, the remaining landfill capacity, and material quantities for landfill closure. The results
from this evaluation are presented in various sections of this supplement information for the permit application.
'Ft TETRA TECH 10 December 16. 2021
3/7/24, 4:15 PM Fwd: US Magnesium Landfill Permit Questions [e-mail] -State of Utah Mail
From: Jeffrey Mensinger <[e-mail]> Date: Mon, Feb 12, 2024 at 2:07 PM Subject: RE: US Magnesium Landfill Permit Questions To: Bryan Woolf <[e-mail]!.> Cc: Brian Speer <l,,§[e-mail]!.>
Bryan:
Sorry it has taken me a little time to get back to you but here are USM's responses:
1) The total actual acreage of the landfill/facility (footprint, which includes the slope to the north of the landfill) is 33.4 acres. The total working area of the landfill will be 32 acres.
The difference is based on waste not being able to be placed on the north slope of the landfill, which accounts for the extra 1.4 acres. As to why the form has 33 acres as opposed to
33.4, it appears that the form would not allow decimal place to be used when they used PDF forms initially. So the total acreage of the landfill/facility is 33.4 and the working/disposal
area is 32.
2) There is a dedicated area in the landfill that is specifically for asbestos, not an actual separate cell. The one drawing (C-001) shows this area. Procedures as to how asbestos is
placed into the landfill are in Section Ill of the SOP in Appendix A.
Please let me know if there are any further questions. If necessary, I can upload a copy of this email to the portal. Let me know how you want to proceed.
Thanks,
Jeff
Jeffrey L. Mensinger Environmental Manager US Magnesium LLC 12819 N Skull Valley Road Rowley, UT 84029 0: 801.433.4086 C: 801.657.8671 [e-mail]

Drawings
EXISTING CONDITIONS
PLAN 4750 W. 2100 SHIP SP. 400 SeIt Lake USG 84120 PHONE: [phone]
US MAGNESIUM LLC
USMUONETI2C2BASUIBL404OFILL
12/2/2021 4S7 712 - STTS367FSI PROJECTS \ T-AUS MAGNESIUM LLCMS-8713005 - CIASSULS USI413FILL KRAIG APPPT-GAGISHEETFILESVAPP 1_EXISTING GONISTIONSOWG
174/ 21 41/119 TTSMESS11191202ECTS, CLASS LOH LAMP, PERMIT APP107,0,2192HEETFLES11,19P 231NAL WASTE EXTENT AND ORPOING PLAN,OWN
0
US MAGNESIUM LLC
usOaoNeNOAocLnSsl4n LANDFILL TETRA TECH
FINAL WASTE EXTENT GRADE PLAN 9990.19,29999,11.99.09
4290 W. 2100 SNAl SW 900 sax Lake City, .1120 PHONE: 901-222,2100
0 6
TETRA TECH
erawtetraleckcom
US MAGNESIUM LLC
US MAMMA. GLASS BM IA/MILL
FINAL COVER PLAN
1=111:92111:32:21:2 11M
4750104 2100 Sa. SW 400 MI Lake GIA. Utah 24120 PHONE. [phone]
12/2/2021 42 PM -11T403615.4110JEGMOMS MAGNESILAR LLG1117-104000S - GLASS MB LANOWLL PERIAT AP AGADMISEMISMAP SyDIAL COVER PLAN/DWG
P POSED rrr I rift CHAN L
2805ST1U LL
°TEXTILE FABRIC EXISITNOORAVNO III lOOOSONU00005EOÁTO
STORMWATER CAPTURE CHANNEL TYPICAL SECTION
EXISTING CONTOUR (MAKS°
EXISDNG CONTOUR (MINOR)
- - 2021 SURVEY BOUNDARY EXISTING LANDFILL EXTENTS pROPOSEEICRANNEL CONTOUR FNAJOIN) - PROPOSED CHANNEL CONTOUR (MINOR)
- - PROPOSED CHANNEL EXTENTS
- 000- PROPOSED COVEN CONTOUR 112A3.) PROPOSED COVER CONTOUR (MINOR)
rr APRCAN

Or00T SCR

A C-004

US Magnesium Permit
Attachment #2 - Plan of Operation
Class IIlb Landfill Permit Application US Magnesium LLC
Rowley, Utah Plant
4.1 ON-SITE WASTE HANDLING
The landfill operates 24 hours a day, 7 days a week. The on-site waste is transported to the landfill by dumpster,
dump truck, heavy equipment, or by other appropriate methods. Waste shall be disposed of according to US
Magnesium's Maintaining Landfill SOP (US Magnesium, 2021), included in Appendix A. Each time waste is
disposed of at the landfill, the truck driver will keep a log recording the area the waste was sourced from and the
general composition of waste types. An example waste management and disposal form is provided in Appendix
B.
4.2 INSPECTIONS AND MONITORING
Pe-R.93.
Once per month the landfill will be inspected by the Environmental Manager and/or assigned representative. The
person conducting the inspection will record observations and areas for corrective action (if needed). An example
inspection form is provided in Appendix B.
4.3 CONTINGENCY PLAN
qd,RWIR IM
Potential fires and explosion hazards at the landfill are adequately controlled because of the relatively low percent
of organic materials in the landfill waste that could ignite, burn, or decompose, leading to the formation of gases
such as methane. However, to minimize health and environmental hazards in the event of a fire or explosion, a
contingency plan is outlined herein.
In the event of a fire or explosion, the area will be evacuated, and US Magnesium's fire brigade and
Environmental Manager will be notified. If inappropriate material is discovered in the landfill, the Environmental
Manager will be notified, and the area will be evacuated as appropriate. The hazardous materials team will attain
control and cleanup if necessary and the Environmental Manager will notify the appropriate regulatory agencies
as warranted. Responses to a fire or explosion will be in accordance with US Magnesium's Emergency Response
Plan (US Magnesium, current revision February 2021).
4.4 FUGITIVE DUST PLAN
Dust control is important due to wind dispersion, landfill traffic, and the types of waste disposed of at the landfill.
The primary means used to control dust at the landfill is the utilization of water trucks to periodically apply water
using a water truck on roads, the landfill surface and other dust prone areas. Secondly, heavy materials, such as
bricks and dirt, are part of the typical daily waste disposed and are used for daily cover to help control fugitive
dust. The active landfill face will be covered weekly with a minimum of six inches of gypsum tailings (calcium
sulfate, calcium chloride, and coarse limestone). Inclusion of calcium chloride helps to control fugitive dust due it's
hygroscopic nature.
4.5 LITTER CONTROL AND COLLECTION
While heavy waste and the weekly gypsum cover reduce or eliminate the potential for wind-blown litter, some
wind-blown litter can be carried from the landfill. The predominant wind direction is from the west and southwest,
which would carry litter toward the waste pond to the east. Litter recovery from the pond is not possible; however,
the presence of the pond precludes further transport of the litter to off-site areas. Occasionally, blue poly drums
that are placed in the landfill will blow and/or roll to the east toe of the landfill and toward the waste pond. The
Environmental Manager will include inspection for wind-blown litter and debris as part of the monthly landfill
inspection, and to the extent practical, litter, debris and drums will be picked up by the grounds crew for
placement of materials back into the landfill.
TETRA TECH December 16, 2021
Class IIlb Landfill Permit Application US Magnesium LLC
Rowley, Utah Plant
4.6 PROHIBITED HAZARDOUS OR PCB CONTAINING WASTES
This landfill is for non-hazardous waste generated solely through on-site sources. US Magnesium controls the
waste deposited in the landfill, and in accordance with Class IIlb regulations, US Magnesium will assure that no
hazardous or PCB containing wastes are disposed of at this site.
4.7 DISEASE VECTORS
The waste disposed at this landfill is primarily from industrial operations, although some lunchroom and office
wastes are placed at the landfill. Therefore, minimal food waste is placed in the landfill that would attract rodents,
birds or other vectors that can harbor disease. Continued waste type restrictions will be enforced, including
exclusion of liquid wastes, tires, and other materials which may carry disease or lead to the propagation of
disease vectors. The waste type restrictions, along with cover being applied weekly, will minimize the potential for
vectors. Historically, there have not been significant problems with disease vectors at the landfill.
The plant site receives very little precipitation, and the rain that falls on the landfill rapidly infiltrates into the porous
waste materials. In addition, the active surface of the waste pile is maintained with a minimum slope of 2% to
preclude ponding in low spots that might attract birds or vectors.
4.8 ALTERNATIVE WASTE HANDLING
Since the landfill receives waste solely from US Magnesium, the company will assure that only the appropriate
wastes are deposited at the landfill. If the landfill is unable to receive the waste, the waste will either be held on
site until it can be properly accepted at the landfill or US Magnesium will arrange for transportation to an
appropriate off-site facility.
4.9 TRAINING PROGRAM
US Magnesium provides initial and periodic refresher training related to landfill operation for personnel involved in
waste management and disposal at the landfill. The training programs includes the following topics:
• Check Out Procedure — Grounds Equipment (Standard Operating Procedure 123-02)
• Maintaining Landfill (Standard Operating Procedure 123-15) that includes the following topics:
O Recognizing hazards and situations that lead to problems
O Acceptable types of waste
O Inspecting loads for wastes that cannot be accepted at the landfill
O Proper disposal practices
o Cover requirements and procedures
o Special procedures for handling, placing and covering asbestos waste
In addition to landfill operation training, employees also receive monthly health and safety training, covering a
variety of safety topics throughout the year in accordance with US Magnesium's Health and Safety Program.
4.10 RECYCLING PROGRAMS
US Magnesium maintains a recycling program for select materials to preclude their disposal at the landfill and/or
to recover their value; the current materials being recycled are as follows: printer cartridges, lead-acid batteries
and scrap metal.
4.11 ADDITIONAL S1TE-SPECIFIC INFORMATION
There is no other site-specific information pertaining to the Plan of Operation.
TETRA TECH December 16. 2021
A-2: Maintaining Landfill SOP
STANDARD OPERATING PROCEDURE
Title Maintaining Landfill
Procedure No. 123-15 Revision Date (See QualTrax for Current Revision History) Effective Date 5/1/06
Area Grounds Prepared K. Palmer Page 1 of 3
I. OBJECTIVE
To provide safe operating procedure for maintaining landfill to County and State
specifications.
II. SAFETY PRECAUTIONS AND EQUH'MENT
A. Standard Safety Equipment
Hard hat Safety boots Safety glasses Chlorine Monitor-
Long sleeves Respirator Long pants Gloves
B. Additional Precautions
Tip over hazard, Sharp drop off, Uneven surfaces, Soft shoulders, High winds,
Obscured vision, Blind spots, Low lighting in area.
Equipment traffic/ Pedestrian traffic
Slip, trip, falls
Equipment tire damage
Pinch points
Material creating caverns under equipment
C. Potential Hazards
Hazardous materials/ Unknown materials, and contents
Oversized parts and materials, Awkward materials, Glama lines, Casting lines
Fire hazard/ Hot materials, Methane fumes
Equipment damage, Material rolling into ladder, Material rolling over bucket
D. Reference JSA's/Enerey Isolation Procedures
A. JSA's:
B. EIP's:
C. SOP-123-02 Equipment Checkout
III. REQUIRED EQUIPMENT OR SUPPLIES NEEDED
Front End Loader Dump Truck Haul truck
IV. PROCEDURE
1. Checkout equipment.
a. Complete checkout sheets on all equipment used.
Revision #: 19 Document ID: 3836 Document approved by area supervisor on 5/17/2021 9:52:41 AM. Pnntouts of this document may be out of date and should be considered uncontrolled. To accomplish work, the on-line document should be used.
SOP: 123-15_Maintaining Landfill
Page 2 of 4
b. ALWAYS use 3-point rule when mounting or dismounting equipment.
c. ALWAYS check brakes before approaching landfill face.
2. Picking up waste loads
a. Inspect waste loads to make sure improper waste is not being picked up for
disposal at the landfill. Improper waste includes hazardous waste, wastes
containing free liquids, PCB-regulated wastes, batteries, fluorescent lights,
etc. Contact Area Foremen if improper or suspicious waste material is
present.
b. At each pick-up location note in the truck logbook the pick-up location and
the total cubic yards.
3. Prior to Dumping off edge
a. Prior to backing to landfill face operators SHALL exit cabs using 3 point
contact and inspect face for caverns at minimal once per shift, more as
necessary pending on material being dumped.
b. Operators SHALL NOT back over prior loads of debris.
c. Operators SHALL dump on level ground.
d. ALWAYS STAY A SAFE DISTANCE FROM FACE OF LANDFILL.
e. Ground might be soft and give away under the weight of the Loader/ Haul
truck. Uneven ground could also cause Loader/ Haul truck to tip over.
f. Operators SHALL pull away from dumped load prior to lowering bed
4. Pushing off dumping area.
a. Prior to pushing off landfill operator SHALL exit cab using 3 point contact
and inspect the face for caverns at a minimal once per shift, more as necessary
pending on material being pushed
b. Push off all material at least ONCE PER DAY, more if necessary.
c. To prevent tire damage be aware of sharp objects. Do not drive over materials
d. ALWAYS be aware of other equipment traffic in area.
e. ALWAYS STAY A SAFE DISTANCE FROM FACE OF LANDFILL.
Ground might be soft and give way under the weight of the Loader/ Haul
truck. Uneven ground could cause Loader/ Haul truck to tip over.
f. Face should NEVER exceed 100 feet wide.
g. ALWAYS make sure area below dump is clear before pushing anything off.
h. Haul fines on dumping area to maintain smooth level dumping surface.
i. NEVER dump hot materials in Landfill
j. NEVER push off ferrous chloride sump cleanout residue or asbestos
containing materials without approval from Foreman.
5. Covering face with fill material.
a. Haul at least 10 LOADS PER WEEK of fill on face, more if necessary.
b. ALWAYS STAY A SAFE DISTANCE FROM FACE OF LANDFILL.
Ground might be soft and give way under the weight of the Loader/ Haul truck.
Uneven ground could cause Loader/ Haul truck to tip over
Revision #: 19 Document ID: 3836 Document appmved by area supervisor on 5/17/2021 9:52:41 AM. Prmtouts of this document may be out of date and should be considered uncontrolled. To accomplish work, the on-line document should be used.
SOP: 123-15_Maintaining Landfill
Page 3 of 4
c. NEVER leave cab of truck while dumping material.
d. ALWAYS be aware of equipment traffic in area.
e. At least ONCE PER MONTH cover entire face with fill material
6. Completing task:
a. Leave small berm along edge of face to prevent other employees from driving
off.
b. Check bottom of landfill for any debris or wind-blown litter that has migrated
outside dump area.
c. ALWAYS verify equipment is shutdown, and no stored energy in moving
components, Ground bucket, Set park brake, Place wheel chalks prior to
removing lodged materials from equipment moving components/ Under
carriage
d. Check Loader tires for damage.
e. Check for any hot spots
f. Enter results of inspections in landfill logbook.
g. Report any problems or concerns to Area Foreman.
III. PROCEDURE — ASBESTOS WASTE

1. Receiving a load of asbestos waste at the landfill.
a. Check for sign on truck that says asbestos waste is present.
b. Check to see that the waste has been properly wetted or otherwise treated
to prevent asbestos from crumbling or becoming airborne. Proper wetting
is normally indicated by the presence of moisture within the waste
packaging/container.
c. Check to see that the waste has been properly containerized or wrapped
and that the container has a warning label stating that the container holds
asbestos waste.
d. Contact Environmental Manager to report that asbestos waste has arrived
at landfill and tell him whether there are any problems or concerns.
e. Verify that the quantity of waste is accurately indicated on the waste
shipment record and, if there are no discrepancies, sign the shipment
record.

2. Placing and covering the asbestos waste in the landfill.
a. Place the asbestos waste in a separate, previously designated area within
the landfill while trying to prevent any significant damage to the asbestos
waste container/wrapping. For particularly large asbestos waste articles,
arrange the waste in an organized manner in order to minimize the amount
of landfill area that is used for asbestos disposal.
b. Cover the asbestos waste with a minimum of 6 inches of fill within 18
hours of placing the waste in the landfill. Try to avoid damaging the
asbestos waste containers/wrapping when covering the waste.

Revision #: 19 Document ID: 3836 Document approved by area supervisor on 5/17/2021 9:52:41 AM.
Printouts of this document may be out of date and should be considered uncontrolled. To accomplish work, the on-line document should be used.
SOP: 123-15_Maintaining Landfill
Page 4 of 4
c. If a container is damaged or becomes damaged during placement
IMMEDIATELY cover the waste with a minimum of 6 inches of fill
d. NEVER compact the waste until there is a minimum of 6 inches of fill.
3. Completing the task.
a. Perform all other completion activities specified in the General
Procedures, section IV.5.
b. If there are any problems or concerns the Area Foreman should also
contact the Environmental Manager for any questions regarding the best
way to respond.
Revision #: 19 Document ID: 3836 Document approved by area supervisor on 5/17/2021 9:52:41 AM. Printouts of this document may be out of date and should be considered uncontrolled. To accomplish work, the on-hne document should be used.
US Magnesium LLC
238 North 2200 West - Salt Lake City, UT 84116-2921
801/532-2043 - 800/262-9624 - FACSIMILE 801/534-1407
October 17, 2024
Via Submittal to [e-mail]
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
Subject: USM Response to DWMRC Request for Information dated August 19, 2024 regarding
USM Permit Application SW223
Dear Mr. Hansen:
US Magnesium (USM) has reviewed the above-referenced Division of Waste Management and Radiation
Control (DWMRC) request for information (RFI) and provides the following updated operational
information and responses to the RFI. As DWMRC is aware, USM only disposes of waste generated on-
site in its on-site landfill, so there is no scale-house for receiving and inspecting loads of waste as is the
case for wastes delivered to commercial landfills (e.g., Wasatch Regional Landfill).
During the period leading up to USM’s December 16, 2021 Complete Permit Application for the Existing
Class III(b) Landfill, USM’s magnesium production operation was the primary volumetric source of
waste to the on-site landfill. In September 2022, USM idled its magnesium production process which
resulted in a significant decrease in waste volume and frequency of hauling bins/loads to the on-site
landfill. USM currently has no specific timeframe to resume magnesium production. Thus, the responses
below reflect USM’s current limited operations.
Request for Information:
1.Please provide details and descriptions of the waste inspections that will be conducted.
USM Response: As DWMRC observed in its RFI, the plan of operation within the application
states that waste loads are inspected at each pick up location to make sure improper waste is not
being disposed of at the landfill. Refer to Landfill Operation Form B-1 Example Landfill Daily
Log.
a)inspection frequency and inspection of loads suspected of containing prohibited hazardous
waste or prohibited waste containing PCBs;
DSHW-2024-008768
October 17, 2024 Updates to waste inspections and training identified below.
Response to DWMRC RFI
October 17, 2024
Page 2 of 3
USM Response: During USM’s primary magnesium production, bins (“luggers”), front-end-
loader (FEL) loads and end-dump loads were typically moved to the landfill twice per week.
Given the currently limited operations, loads may be taken to the on-site landfill once every two or
three weeks. USM will inspect loads of waste based on the frequency of loads to the on-site
landfill. Thus, the frequency of inspections will be at least one load per each hauling of loads to
the on-site landfill.
b)inspection in a designated area or at a designated point in the disposal process;
USM Response: USM personnel have and will continue to inspect the loads at the point of pickup
within the USM plant whether that is a bin, FEL or end-dump loads. The points of pick-up are at
the office buildings (bins), warehouses (bins, FEL or end-dump loads of broken pallets / packaging
materials), and casthouse bulk waste area (FEL or end-dump loads).
c)a training program for the facility employees in identification of prohibited hazardous waste
and prohibited waste containing PCBs; and
USM Response: USM has and will train its personnel for hauling waste to the on-site landfill. The
training will include the acceptable and prohibited wastes as specified in Section 2.5 of the
application and on the Landfill Operation Form B-1 Example Landfill Daily Log and load
inspection example form drafted in response to item 2 below.
d)maintaining written records of inspections, signed by the inspector.
USM Response: The load inspection example form drafted in response to item 2 below will be
printed, filled out by the operator, initialed by the operator, and scanned to electronic record.
2.Please provide the Division with a waste inspection form that provides space to record what is
being inspected, results of the inspection, and a place for the individual conducting the waste
inspection to sign and date the form.
USM Response: A load inspection example form is attached to this RFI.
3.Please update the closure and post-closure care costs to include the 2023 annual inflation factor
of 1.037.
USM Response: USM has updated the closure and post-closure cost estimate by applying the
2023-2024 Utah DEQ interest rate (3.7%) referenced in the RFI. The closure and post-closure unit
costs have been multiplied by the inflation factor/multiplier for 2023, 1.037, such that the estimated
quantity times unit cost line item totals reflect the stated interest (“inflation”) rate. However, USM
has re-evaluated the contingency on direct closure capital cost and decreased that contingency to
10% to eliminate disproportionate inflation of the contingency line item. USM’s October 2024
updated closure and post closure cost estimate is attached.
4.Please update the financial assurance bond so that it is sufficiently funded to cover the adjusted
closure and post-closure care costs with the 2023 annual inflation factor included.
Response to DWMRC RFI
October 17, 2024
Page 3 of 3

USM Response: As described in response to item 3, USM recalculated the closure and post-closure
cost estimate and the total is now $1,983,491 which is less than USM’s current closure and post-
closure bond amount of $2,018,041.40.

Contact me should you have questions regarding this information.

Signed,
Rob J Hartman, P.G.
Environmental Manager
US Magnesium LLC
[e-mail]
M: 208.241.8216

cc (electronic):
Roger Francom, USM
Paula Chu, USM
DATE Lugger
Front End
Loader
Bucket
End Dump Office/
Lunchroom
Trash
Pipe
Wood/
Pallets
Plastic
Waste
Empty
Barrels Any Prohibited
Contents
Lugger, FEL, or End Dump
Bin, Front End Loader (FEL) bucket or End Dump Contents
Inspection (“X” if present)
B-3
US MAGNESIUM – ROWLEY, UTAH
EXAMPLE LANDFILL LOAD INSPECTION LOG
If prohibited
Content, Load
Rejected, enter Yes
if prohibited
contents
Inspector Initials
Item
No.Description Estimated
Quantity
Unit Cost (Labor
and
Unit Materials)
Unit Cost (Labor and
Unit Materials)Estimated Cost
1 Place Protective Cover (18-inches: obtain on-site fill, haul,
spread)81,000 CY $6.53 $529,181
2 Place topsoil (6-inches: obtain on site, haul, spread) 27,000 CY $6.53 $176,394
3 Dust control 3 Month $6,222 $18,666
4 Install stormwater drainages 3,300 SY $104 $342,210
5 Revegetation 36 AC $1,348 $48,532
DIRECT CAPITAL COST SUBTOTAL: $1,114,982
Final Engineering Design and Project Administration: $70,516
Construction Oversight: $70,516
Contingency (10% of Direct Capital Cost): $111,498
INDIRECT COST SUBTOTAL: $252,530
TOTAL CLOSURE COST: $1,367,513
Notes: 1. This cost estimate is expected to be within +/-20%.
2. Contigency reduced to 10% of Direct Capital Cost for October 2024 Updated Closure Cost Estimate.
3. Unit costs multiplied by DWMRC specified 1.037 inflation factor compared to 2023 cost estimate.
Landfill Closure
Table C-1
Landfill Closure Costs Estimate
US Magnesium
Tooele County, Utah
US Magnesium Landfill Closure and Post-Closure Cost Estimate Updated October 2024
Item No. Description
Estimated
Quantity
Unit Cost (Labor and
Unit Materials)
Unit Cost (Labor and Unit
Materials)Estimated Cost
Post Closure Care
1 Develop Institutional Controls 1 One-Time Cost $15,555 $15,555
2 Inspections 30 YR $6,533 $195,993
3 Maintenance 30 YR $13,481 $404,430
Post Closure Care Subtotal:$615,978
Notes: 1. This cost estimate is expected to be within +/-20%.
2. Unit costs multiplied by DWMRC specified 1.037 inflation factor compared to 2023 cost estimate.
Table C-2
Post Closure Care Cost Estimate
US Magnesium
Tooele County, Utah
USM Landfill Closure and Post-Closure Cost Estimate Updated October 2024
US Magnesium Permit Attachment
#3 - Inspection Forms
B-1
US MAGNESIUM — ROWLEY, UTAH
EXAMPLE LANDFILL DAILY LOG
DATE
Lugger, FEL, or End Dump
(Number of Loads/Day) Bin, Front End Loader (FEL) bucket or End Dump Contents ("X" if present, if Other describe)
Lugger FEL End
Dump
Office/
Lunchroom
Trash
Pipe Wood/
Pallets
Plastic
Waste
Empty
Barrels Other - Describe
-
B-2
US MAGNESWM — ROWLEY, UTAH
EXAMPLE LANDFILL MONTHLY INSPECTION FORM
Date lnspection/Monitoring Activity Condition Expected Acceptable
(Yes/No)
Unacceptable (insert
Action Needed) Comment/Action Needed
Access Road Condition and
Maintenance Accessible, no debris on road
Cover Current and Acceptable T op bench covered other than current working area
Slope Condition Covered, no excess head cuts
or rills
Toe of Slope Condition Minimal or no debris at toe of
slopes
Drainage Channels Condition Clear of excess debris
DATE Lugger
Front End
Loader
Bucket
End Dump Office/
Lunchroom
Trash
Pipe
Wood/
Pallets
Plastic
Waste
Empty
Barrels Any Prohibited
Contents
Lugger, FEL, or End Dump
Bin, Front End Loader (FEL) bucket or End Dump Contents
Inspection (“X” if present)
B-3
US MAGNESIUM – ROWLEY, UTAH
EXAMPLE LANDFILL LOAD INSPECTION LOG
If prohibited
Content, Load
Rejected, enter Yes
if prohibited
contents
Inspector Initials
US Magnesium Permit
Attachment #4 - Closure & Post-Closure Plans
Class IIIb Landfill Permit Application US Magnesium LLC Rowley, Utah Plant
11 June 22, 2023
6.0 CLOSURE PLAN
Final closure activities will be implemented upon complete filling of the remaining landfill capacity as shown on the
drawings. If plant operations permanently cease prior to achieving the final waste grades shown on Drawing 2,
the design elevations and grades will be modified to reflect the actual quantities of waste at the landfill to reflect
the smaller quantity of material to be contained therein. The purpose for closure of the landfill is to minimize the
need for maintenance, minimize the potential effects of the landfill on the surrounding environment, and prepare
the facility for the post-closure period.
CLOSURE SCHEDULE
The estimated remaining life of the landfill is 106 years, which would be the year 2128, assuming the same waste
disposal rates through this period. US Magnesium will implement a phased-closure approach as portions of the
landfill reach the final waste elevations and grades shown on Drawing 2. The closure procedures will be
integrated into the landfill operating practices to modify haul roads and other features to accommodate partial
closure as applicable. The interim closure process may include grading select landfill slopes to achieve the 3H:1V
grades, applying protective cover material over completed slopes, adding topsoil or growth media in select areas,
and seeding completed areas according to the cap design presented below. These activities will help to close
inactive areas of the landfill to the extent practicable. Once the landfill has reached capacity, the final cover will be
placed to provide a containment of all underlaying wastes.
FINAL COVER
The final cover design elevations, grades, and cover detail are presented on Drawing 3. The design is based on
applicable Class IIIb industrial landfill regulations cited in R315-304-5(2)(b), which cross references the final cover
design cited in R315-305-5(5)(b). The primary components consist of earth-base materials that can be obtained
from on-site borrow sources. Immediately overlying the waste grade surface will be an 18-inch-thick layer of
protective cover soil; this will be overlain by 6 inches of soil suitable to sustain a vegetated cover to protect
against stormwater erosion. The overall thickness of the cover will measure 24 inches thick, with side slopes at
3H:1V and the top plateau slopes at roughly 5% grade.
FINAL STORMWATER CONTROLS
Drawing 4 shows the anticipated stormwater flow patterns for precipitation falling on and around the perimeter of
the landfill following closure. Stormwater runoff will flow down the 3H:1V slopes and be collected in perimeter
drainage trenches consisting of V-shaped channels with a geotextile separator fabric and riprap 12- to 18-inches
thick as shown on the detail on Drawing 4. The channels will transmit stormwater around the perimeter toe of the
landfill to on the north and south sides until the channels discharge water to the east toward the existing waste
pond.
SITE CAPACITY
The total capacity of the US Magnesium Class IIIb Industrial Landfill is 2,570,000 CY (in volume), which is
estimated to be approximately 493,000 tons based on the company’s assessment of waste types and unit weights
of materials disposed. The evaluation of average waste material unit weights prepared previously by US
Magnesium is included in Appendix A.
FINAL INSPECTION
US Magnesium will notify the DWMRC of its intent to implement the closure plan in whole or in part, 60 days prior
to the projected final receipt of waste at the facility. The landfill will commence implementation of the closure plan
Class IIIb Landfill Permit Application US Magnesium LLC Rowley, Utah Plant
12 June 22, 2023
within 90 days following receipt of the final volume of waste, or when the final elevations are attained. Closure
activities will be completed within 365 days of their commencement.
A final inspection of the landfill site will be performed at the termination of the landfill closure. The final inspection
will determine if the landfill meets all the closure requirements outlined in the permit and closure plan. Inspection
requirements of the closure plan will include long-term operation of run-on and run-off controls (as appropriate),
maintenance of proper final grades and the cover system on the landfill to promote run-off, and control of access
at the site.
Within 90 days of completion of closure activities, US Magnesium will submit a certified document to the DWMRC,
indicating that the facility has been closed in accordance with the approved closure plan. This document will
include facility or closure plan sheets and record drawings.
Class IIIb Landfill Permit Application US Magnesium LLC Rowley, Utah Plant
13 June 22, 2023
7.0 POST-CLOSURE CARE
After closure, the landfill will periodically be inspected to identify wear of the cover materials as evidenced by
erosion, subsidence, water ponding, or other evidence of changes after closure. If during the inspections, the
cover appears to be damaged or eroded, and/or if run-on and run-off control systems are damaged, then these
issues will be repaired by US Magnesium or the retained caretaker. Post-closure care shall continue for 30 years
after closure, or as long as the DWMRC determines necessary for the landfill to become stabilized to protect
human health and the environment.
RECORD OF TITLE, LAND USE, AND ZONING RESTRICTION CHANGES
The current zoning for the plant area, including the landfill, is “Manufacturing General (M-G).” The zoning for this
area is not expected to change in the near- or long-term, so there will be no required changes to the land use or
zoning restrictions for the post-closure care period.
Within 60 days following certification of closure, US Magnesium will submit to the Tooele County Recorder a plat
and statement of fact concerning the location of the landfill. The Recorder will be instructed to include this
information as part of the record of title. US Magnesium will provide proof to the director that the record of title
has been filed.
MAINTENANCE ACTIVITIES
During landfill operation, as well as after closure, the cover and run-on and run-off systems will be periodically
inspected. Vegetation will be added to inhibit cover erosion. If damage to the cover, vegetation, and/or run-on and
run-off systems occurs, then these issues will be repaired by US Magnesium or the retained caretaker.
POST-CLOSURE CARE CONTACT INFORMATION
The name, address, and telephone number of the office to contact about the landfill during the post-closure care
period is listed below.
US Magnesium Environmental Manager
238 North 2200 West
Salt Lake City, Utah 84116-2921
801-532-2043
Item
No.Description Estimated
Quantity
Unit Cost (Labor
and
Unit Materials)
Unit Cost (Labor and
Unit Materials)Estimated Cost
1 Place Protective Cover (18-inches: obtain on-site fill, haul,
spread)81,000 CY $6.53 $529,181
2 Place topsoil (6-inches: obtain on site, haul, spread) 27,000 CY $6.53 $176,394
3 Dust control 3 Month $6,222 $18,666
4 Install stormwater drainages 3,300 SY $104 $342,210
5 Revegetation 36 AC $1,348 $48,532
DIRECT CAPITAL COST SUBTOTAL: $1,114,982
Final Engineering Design and Project Administration: $70,516
Construction Oversight: $70,516
Contingency (10% of Direct Capital Cost): $111,498
INDIRECT COST SUBTOTAL: $252,530
TOTAL CLOSURE COST: $1,367,513
Notes: 1. This cost estimate is expected to be within +/-20%.
2. Contigency reduced to 10% of Direct Capital Cost for October 2024 Updated Closure Cost Estimate.
3. Unit costs multiplied by DWMRC specified 1.037 inflation factor compared to 2023 cost estimate.
Landfill Closure
Table C-1
Landfill Closure Costs Estimate
US Magnesium
Tooele County, Utah
US Magnesium Landfill Closure and Post-Closure Cost Estimate Updated October 2024
Item No. Description
Estimated
Quantity
Unit Cost (Labor and
Unit Materials)
Unit Cost (Labor and Unit
Materials)Estimated Cost
Post Closure Care
1 Develop Institutional Controls 1 One-Time Cost $15,555 $15,555
2 Inspections 30 YR $6,533 $195,993
3 Maintenance 30 YR $13,481 $404,430
Post Closure Care Subtotal:$615,978
Notes: 1. This cost estimate is expected to be within +/-20%.
2. Unit costs multiplied by DWMRC specified 1.037 inflation factor for October 2024 Updated Post-Closure Cost Estimate.
3. Unit cost for Inspections includes an average of 4 inspections per year.
4. Unit cost for Maintenance represents an average annual cost reflecting lower and higher maintenance cost years.
Table C-2
Post Closure Care Cost Estimate
US Magnesium
Tooele County, Utah
USM Landfill Closure and Post-Closure Cost Estimate Updated October 2024
US Magnesium LLC
238 North 2200 West - Salt Lake City, UT 84116-2921
801/532-2043 - 800/262-9624 - FACSIMILE 801/534-1407
October 17, 2024
Via Submittal to [e-mail]
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
Subject: USM Response to DWMRC Request for Information dated August 19, 2024 regarding
USM Permit Application SW223
Dear Mr. Hansen:
US Magnesium (USM) has reviewed the above-referenced Division of Waste Management and Radiation
Control (DWMRC) request for information (RFI) and provides the following updated operational
information and responses to the RFI. As DWMRC is aware, USM only disposes of waste generated on-
site in its on-site landfill, so there is no scale-house for receiving and inspecting loads of waste as is the
case for wastes delivered to commercial landfills (e.g., Wasatch Regional Landfill).
During the period leading up to USM’s December 16, 2021 Complete Permit Application for the Existing
Class III(b) Landfill, USM’s magnesium production operation was the primary volumetric source of
waste to the on-site landfill. In September 2022, USM idled its magnesium production process which
resulted in a significant decrease in waste volume and frequency of hauling bins/loads to the on-site
landfill. USM currently has no specific timeframe to resume magnesium production. Thus, the responses
below reflect USM’s current limited operations.
Request for Information:
1.Please provide details and descriptions of the waste inspections that will be conducted.
USM Response: As DWMRC observed in its RFI, the plan of operation within the application
states that waste loads are inspected at each pick up location to make sure improper waste is not
being disposed of at the landfill. Refer to Landfill Operation Form B-1 Example Landfill Daily
Log.
a)inspection frequency and inspection of loads suspected of containing prohibited hazardous
waste or prohibited waste containing PCBs;
DSHW-2024-008768
October 17, 2024 Updates to closure and post-closure care costs identified below.
Response to DWMRC RFI
October 17, 2024
Page 2 of 3
USM Response: During USM’s primary magnesium production, bins (“luggers”), front-end-
loader (FEL) loads and end-dump loads were typically moved to the landfill twice per week.
Given the currently limited operations, loads may be taken to the on-site landfill once every two or
three weeks. USM will inspect loads of waste based on the frequency of loads to the on-site
landfill. Thus, the frequency of inspections will be at least one load per each hauling of loads to
the on-site landfill.
b)inspection in a designated area or at a designated point in the disposal process;
USM Response: USM personnel have and will continue to inspect the loads at the point of pickup
within the USM plant whether that is a bin, FEL or end-dump loads. The points of pick-up are at
the office buildings (bins), warehouses (bins, FEL or end-dump loads of broken pallets / packaging
materials), and casthouse bulk waste area (FEL or end-dump loads).
c)a training program for the facility employees in identification of prohibited hazardous waste
and prohibited waste containing PCBs; and
USM Response: USM has and will train its personnel for hauling waste to the on-site landfill. The
training will include the acceptable and prohibited wastes as specified in Section 2.5 of the
application and on the Landfill Operation Form B-1 Example Landfill Daily Log and load
inspection example form drafted in response to item 2 below.
d)maintaining written records of inspections, signed by the inspector.
USM Response: The load inspection example form drafted in response to item 2 below will be
printed, filled out by the operator, initialed by the operator, and scanned to electronic record.
2.Please provide the Division with a waste inspection form that provides space to record what is
being inspected, results of the inspection, and a place for the individual conducting the waste
inspection to sign and date the form.
USM Response: A load inspection example form is attached to this RFI.
3.Please update the closure and post-closure care costs to include the 2023 annual inflation factor
of 1.037.
USM Response: USM has updated the closure and post-closure cost estimate by applying the
2023-2024 Utah DEQ interest rate (3.7%) referenced in the RFI. The closure and post-closure unit
costs have been multiplied by the inflation factor/multiplier for 2023, 1.037, such that the estimated
quantity times unit cost line item totals reflect the stated interest (“inflation”) rate. However, USM
has re-evaluated the contingency on direct closure capital cost and decreased that contingency to
10% to eliminate disproportionate inflation of the contingency line item. USM’s October 2024
updated closure and post closure cost estimate is attached.
4.Please update the financial assurance bond so that it is sufficiently funded to cover the adjusted
closure and post-closure care costs with the 2023 annual inflation factor included.
Response to DWMRC RFI
October 17, 2024
Page 3 of 3
USM Response: As described in response to item 3, USM recalculated the closure and post-closure
cost estimate and the total is now $1,983,491 which is less than USM’s current closure and post-
closure bond amount of $2,018,041.40.
Contact me should you have questions regarding this information.
Signed,
Rob J Hartman, P.G.
Environmental Manager
US Magnesium LLC
[e-mail]
M: 208.241.8216
cc (electronic):
Roger Francom, USM
Paula Chu, USM
DATE Lugger
Front End
Loader
Bucket
End Dump Office/
Lunchroom
Trash
Pipe
Wood/
Pallets
Plastic
Waste
Empty
Barrels Any Prohibited
Contents
Lugger, FEL, or End Dump
Bin, Front End Loader (FEL) bucket or End Dump Contents
Inspection (“X” if present)
B-3
US MAGNESIUM – ROWLEY, UTAH
EXAMPLE LANDFILL LOAD INSPECTION LOG
If prohibited
Content, Load
Rejected, enter Yes
if prohibited
contents
Inspector Initials
Item
No.Description Estimated
Quantity
Unit Cost (Labor
and
Unit Materials)
Unit Cost (Labor and
Unit Materials)Estimated Cost
1 Place Protective Cover (18-inches: obtain on-site fill, haul,
spread)81,000 CY $6.53 $529,181
2 Place topsoil (6-inches: obtain on site, haul, spread) 27,000 CY $6.53 $176,394
3 Dust control 3 Month $6,222 $18,666
4 Install stormwater drainages 3,300 SY $104 $342,210
5 Revegetation 36 AC $1,348 $48,532
DIRECT CAPITAL COST SUBTOTAL: $1,114,982
Final Engineering Design and Project Administration: $70,516
Construction Oversight: $70,516
Contingency (10% of Direct Capital Cost): $111,498
INDIRECT COST SUBTOTAL: $252,530
TOTAL CLOSURE COST: $1,367,513
Notes: 1. This cost estimate is expected to be within +/-20%.
2. Contigency reduced to 10% of Direct Capital Cost for October 2024 Updated Closure Cost Estimate.
3. Unit costs multiplied by DWMRC specified 1.037 inflation factor compared to 2023 cost estimate.
Landfill Closure
Table C-1
Landfill Closure Costs Estimate
US Magnesium
Tooele County, Utah
US Magnesium Landfill Closure and Post-Closure Cost Estimate Updated October 2024
Item No. Description
Estimated
Quantity
Unit Cost (Labor and
Unit Materials)
Unit Cost (Labor and Unit
Materials)Estimated Cost
Post Closure Care
1 Develop Institutional Controls 1 One-Time Cost $15,555 $15,555
2 Inspections 30 YR $6,533 $195,993
3 Maintenance 30 YR $13,481 $404,430
Post Closure Care Subtotal:$615,978
Notes: 1. This cost estimate is expected to be within +/-20%.
2. Unit costs multiplied by DWMRC specified 1.037 inflation factor compared to 2023 cost estimate.
Table C-2
Post Closure Care Cost Estimate
US Magnesium
Tooele County, Utah
USM Landfill Closure and Post-Closure Cost Estimate Updated October 2024