DSHW-2024-009351

BRENNAN BOTTOM DISPOSAL – 12-MILE WASH FACILITY
DISPOSAL: 3999 W 12250 SOUTH 12-MILE WASH RD- VERNAL
OFFICE: 4091 W 3000S – ROOSEVELT UT 84066
Rev 20240925
Temporary Permit Application
for
Brennan Bottom Disposal, llc
12-Mile Wash E&P Waste Disposal Facility
Presented To:
State of Utah
Department of Environmental Quality
Division of Waste Management & Radiation Control
Solid Waste Program
Prepared by:
KK&E, llc
9706 Buttonwood Dr
Sandy, UT 84092
September 25, 2024
Property Location:
Approximately 200 Acres occupying
NE/4, SE/4 & SW/4 OF SE/4 OF Section 24
T 6S, R 20E, SLB&M
and
SE/4 & SW/4 of SW/4 Section 19
T 6S, R 21E, SLB&M
Uintah County, Utah
1 of 20
Utah Solid Waste Program Temporary Permit Application
for
Brennan Bottom Disposal llc Exploration & Production Waste Disposal
12-Mile Wash Facility
3999 W 12250 South 12-Mile Wash Rd, Vernal, Utah
Rev 20240924
TABLE OF CONTENTS
A.Introduction and Narrative
B.Solid Waste Temporary Permit Application Form
C.Attachments
1. Facility Maps with each landfarm cell, landfill cell, and surface impoundment
labeled
2. Oil Gas & Mining Documents
a. Permit
b. Approval/Issuance Letter
c. Bonding (Financial Assurance)
2 of 20
Utah Solid Waste Program Temporary Permit Application
for
Brennan Bottom Disposal llc Exploration & Production Waste Disposal
12-Mile Wash Facility
3999 W 12250 South 12-Mile Wash Rd, Vernal, Utah
Rev 20240924
A.Introduction and Narrative
Brennan Bottom Disposal, llc (BBD) submits this Exploration and Production (E&P) Waste
Disposal Temporary Permit Application (Application) for its 12-Mile Wash Exploration &
Production Waste Facility (Facility) in accordance with the requirements of Utah
Administrative Code, Rules R315-301-2(22)(a).
The Facility receives and separates components of produced water, natural gas liquids
(NGL), other Exploration and Production (E&P) wastes and other wastes as may be
permitted.
The Facility is located in Uintah County about 12.5 miles south, southwest of Vernal, Utah
and 0.8-miles northwest of the White River. The address to the Facility is:
3999 W 12250 12-Mile Wash Rd
Vernal, Utah 84078-8524
3 of 20
Utah Solid Waste Program Temporary Permit Application
for
Brennan Bottom Disposal llc Exploration & Production Waste Disposal
12-Mile Wash Facility
3999 W 12250 South 12-Mile Wash Rd, Vernal, Utah
Rev 20240924
B. Solid Waste Temporary Permit Application Form
4 of 20
1
Division of Waste Management and
Radiation Control
Solid Waste Management Program
Mailing Address Office Location Phone [phone]
P.O. Box 144880 195 North 1950 West Fax [phone]
Salt Lake City, Utah 84114-488 Salt Lake City, Utah 84116 www.deq.utah.gov
APPLICATION FOR A TEMPORARY PERMIT TO OPERATE AN
EXPLORATION AND PRODUCTION WASTE FACILITY
In 2019, the Utah Legislature made changes to the Solid and Hazardous Waste Act, Utah Code § 19-6-
101 et seq., which required jurisdiction over the disposal of Oil and Gas Exploration and Production
Waste move from the Department of Natural Resources’ Division of Oil, Gas, and Mining (DOGM) to the
Department of Environmental Quality’s Division of Waste Management and Radiation Control (DWMRC).
In preparation for this regulatory shift, DWMRC has proposed a temporary permitting mechanism for
existing Exploration and Production (E&P) facilities as defined in the proposed Utah Admin. Code R315-
301-2(22)(a).
The proposed rules state that the Director of DWMRC may issue a temporary permit for the purposes of
facilitating the owner’s or operator’s good faith transition from regulation under Utah Admin. Code R649-9
to regulation under Utah Admin. Code R315-321 or R315-322. Applications for temporary permits must
be received by the Director of DWMRC no less than 30 days before October 1, 2024. The temporary
permits will expire one year from the effective date, which is the date the financial assurance mechanism
held by DOGM is transferred to DWMRC.
To complete a temporary permit application to operate an E&P facility, an owner or operator of an existing
E&P facility must:
1. Register the company in DWMRC’s Community Portal and complete facility information within the
Community Portal.
2. Complete the attached Exploration and Production Waste Facility Temporary Permit Application
Form.
3. Provide DWMRC with the following required documentation, to the extent it has not already been
provided to DWMRC or is not already in DWMRC’s possession:
a. Facility map with each landfarm cell, landfill cell, and surface impoundment labeled;
b. Copy of Division of Oil, Gas, and Mining Permit;
c. Copy of Division of Oil, Gas, and Mining Permit Approval/Issuance Letter; and
d. Copy of Division of Oil, Gas, and Mining Bonding (financial assurance).
4. Submit the Application Form and required documentation to DWMRC through the Community
Portal Miscellaneous Document Submission.
5. Within 120 days of DWMRC’s issuance of a temporary permit, the financial assurance
mechanism held by DOGM must be transferred to DWMRC. If the Director issues a temporary
permit, it shall not become effective until the financial assurance mechanism held by DOGM is
transferred to DWMRC. An effective temporary permit is required to operate an E&P Facility
under DWMRC’s jurisdiction.
5 of 20
2
Exploration and Production Waste Facility Temporary Permit Application Form
I.Facility Name and Location
Name of Facility
Brennan Bottom Disposal 12-Mile Facility
Facility Address (Street or Directions to Facility)
3999 W 12250 South 12-Mile Wash Rd
County
Uintah
City.
Vernal
Zip Code
84078-8524
Telephone
435-722-9997
Township
6S, SLB&M
Range
20 E & 21E, SLB&M
Section
24 in R 20E &19 in R12 E
Quarter Section
SE of 24 & SW
of 19
Quarter/Quarter
Section
SE in 24 SW & SE in
19
Main Gate Latitude: N40.280134° Longitude: W109.599104°
II.Existing E&P Facilities
☐Open Landfarm Cell(s)
☒Evaporation Pond(s)
Number of Open Landfarm Cells: 0
Number of Evaporation Ponds: 7
III.Facilities to be Permitted by DWMRC
☒Landfill Cell(s)
☒Surface Impoundment(s)
Number of Landfill Cells:2
Number of Surface Impoundments:7
III.Facility Owner(s) Information
Legal Name of Facility Owner
Brennan Bottom Disposal, LLC
Mailing Address
4091 W 3000 South
City
Roosevelt
State
Utah
Zip Code
84066
Telephone
435-722-9997
IV.Facility Operator(s) Information
Legal Name of Facility Operator
C.J. Nebeker
Mailing Address
4091 W 3000 South
City
Roosevelt
State
Utah
Zip Code
84066
Telephone
435-722-9997
V.Property Owner(s) Information
Is the property leased? No
Name of Property Owner
Brennan Bottom Disposal, LLC
Mailing Address
4091 W 3000 South
City
Roosevelt
State
Utah
Zip Code
84066
Telephone
435-722-9997
6 of 20
3
VI.Designated Contact Information
Facility Owner Designated Contact (if different than
above)
C.J. Nebeker
Title
Manager
Mailing Address
4091 W 3000 South
City.
Roosevelt
State
Utah
Zip Code
84066
Telephone
435-722-9997
Email Address
[e-mail]
Alternative Telephone (cell phone or other)
[phone]
Facility Operator Designated Contact (if different than
above)
Title
Mailing Address
City State Zip Code Telephone
Email Address Alternative Telephone (cell phone or other)
Property Owner Contact (if different than above) Title
Mailing Address
City State Zip Code Telephone
Email Address Alternative Telephone (cell phone or other)
VII.Waste Types to be Disposed of (check all that
apply) VIII.Facility Area
☒Exploration and Production wastes that are exempt from
hazardous waste rules (R315-260-4(b)(5)).
☐Very Small Quantity Generator hazardous waste
Facility Area:
199.86 acres
Disposal Area: 39.00 acres total
7.25 Acre Landfill, 22.99 Acre Evap Pond, 3.25 Acre Operating
Space, 4.50 Acre Closed Landfarm not included in total area
IX.Application Documents
Indicate documents attached to this application (all are required):
☒Facility Map with each landfarm cell, landfill cell, and surface impoundment labeled
☒Copy of Division of Oil, Gas, and Mining Permit
☒Copy of Division of Oil, Gas, and Mining Approval/Issuance Letter
☒Copy of Division of Oil, Gas, and Mining Bonding (Financial Assurance)
7 of 20
Utah Solid Waste Program Temporary Permit Application
for
Brennan Bottom Disposal llc Exploration & Production Waste Disposal
12-Mile Wash Facility
3999 W 12250 South 12-Mile Wash Rd, Vernal, Utah
Rev 20240925
C Attachments
8 of 20
Utah Solid Waste Program Temporary Permit Application
for
Brennan Bottom Disposal llc Exploration & Production Waste Disposal
12-Mile Wash Facility
3999 W 12250 South 12-Mile Wash Rd, Vernal, Utah
Rev 20240925
ATTACHMENT 1
Facility Map with each landfarm cell, landfill cell, and surface impoundment labeled.
No. Drawing Sheet Title
1 S-001 1 of 1
Location - Solid Waste Temporary
Permit
2 G-001 1 of 1 Site - Solid Waste Temporary Permit
9 of 20
24
WE
L
L

R
D
43
0
4
7
3
7
5
6
3
1
2
-
M
I
L
E

W
A
S
H

R
D
2
2
4
0
WE
L
L

R
D
W
E
L
L

R
D
WELL

R
D
R
2
0
E
R
2
1
E
T 6S
WEL
L
/
T
A
N
K

P
A
D
0 300 600 900 1200 1500 FT
SEC 30SEC 25
19
PL
PL
PLPL
P
L
PL
LA
N
D
F
A
R
M
LANDFILL
CELL 1
LANDFILL
CELL 2
POND 3
POND 5 POND 6
POND 4
POND 2
PO
N
D

7
PO
N
D

8
N
OFFLOAD
AREA
NW/SW/4 NE/SW/4 NW/SE/4
SW/SE/4
12-MILE FACILITY
P
L
PL
UINTAH COUNTY
PARCEL 070160002
UINTAH COUNTY
PARCEL 070230002
SEC 19SEC 24
BI
N
D
I
N
G

E
D
G
E
UINTAH COUNTY, UTAH
0 KJS
REV DATE BY
DESCRIPTION
LOCATION
PROJECT
TITLE NO.
S-001
09/23/24 BRENNAN BOTTOM DISPOSAL 12-MILE FACILITY
LOCATION - SOLID WASTE TEMPORARY PERMIT
SCALE: 1" = 600 FT
civil o structural o wastewater o engineering
K K & E, llcINITIAL ISSUE
No. 273867-2203
KERRY JORDAN
SPIROFF
S
TATE OF U T A H
PROFESSIO N A L S T RUCTURAL E
N
G
I
N
EER
NOTES
1. DRAWING IS SUBMITTED TO DWMRC WITH
THE BRENNAN BOTTOM APPLICATION FOR
TEMPORARY E&P WASTE PERMIT.
2. COLOR MARKUP AS REQUESTED BY DWMRC
10 of 20
BI
N
D
I
N
G

E
D
G
E
G-001
SCALE: 1" = 200 FT LOCATION
PROJECT
TITLE NO.
A
REV DATE BY DESCRIPTION
09/23/24
civil o structural o wastewater o engineering
NOTES
1. DRAWING IS SUBMITTED TO DWMRC WITH
THE BRENNAN BOTTOM APPLICATION FOR
TEMPORARY E&P WASTE PERMIT.
2. COLOR MARKUP AS REQUESTED BY DWMRC
KJS INITIAL ISSUE
UINTAH COUNTY, UTAH
BRENNAN BOTTOM DISPOSAL 12-MILE FACILITY
SITE - SOLID WASTE TEMPORARY PERMIT
No. 273867-2203
KERRY JORDAN
SPIROFF
S
TATE OF U T A H
PROFESSIO N A L S T RUCTURAL E
N
G
I
N
EER
11 of 20
Utah Solid Waste Program Temporary Permit Application
for
Brennan Bottom Disposal llc Exploration & Production Waste Disposal
12-Mile Wash Facility
3999 W 12250 South 12-Mile Wash Rd, Vernal, Utah
Rev 20240925
ATTACHMENT 2-a
DOGM PERMIT
12 of 20
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
State of Utah
DEPARTMENT OF NATURAL RESOURCES
1594 West North Temple, Suite 1210, PO Box 145801, Salt Lake City, UT 84114-5801
telephone [phone] facsimile [phone] TTY [phone] www.ogm.utah.gov
BRIAN C. STEED
Executive Director
Division of Oil, Gas and Mining
JOHN R. BAZA
Division Director
Permit to Operate
********************
Facility Name:12 Mile Wash
Facility Type: Commercial Waste Disposal Facility
Location: Section 19, Township 6S, Range 21E
County: Uintah
Approval Date: August 26, 2020
1.Issued to:
Brennan Bottom Disposal (82470)
2.Authority:
Pursuant to Utah Code Ann. §§ 40-6-1 et seq., and Utah Admin. Code §§ R649-9 et seq., the
Utah Division of Oil, Gas and Mining (“Division”) issues this Permit to operate an E and P waste
disposal facility.
3.Duration:
This Permit shall expire five years from the Approval Date. The Division may revoke, suspend,
or impose additional operating conditions or limitations on a disposal facility permit at any time,
for good cause, after notice to the operator. The Division may suspend a waste disposal permit or
impose additional conditions or limitations in an emergency to forestall an imminent threat to
fresh water, public health, or safety of the environment. Suspension of a disposal facility permit
may be for a fixed period of time or until the operator remedies the violation or potential
violation. If the Division suspends a disposal facility permit, the disposal facility shall not accept
E and P waste during the suspension period.
4.General:
4.1 Effect on Prior Permits. This Permit supersedes any existing E and P waste disposal permit
previously obtained for the Facility and provides the terms that govern operations at this
Facility.
4.2 Incorporation of Application. The Division issues this Permit in response to BBD’s “Permit
Renewal Application” dated 8/14/2020 and received by the Division on 8/19/2020,
(“Application”). The Facility shall operate in accordance with the best management practices
described in the Application.
4.3 Compliance with Applicable Laws. The Facility shall comply with Utah Code Ann. §§ 40-6-
1 et seq. and Utah Administrative Code §§ R649-9 et seq..
5. Reporting and Recordkeeping Requirements:
JOHN R BAZA
13 of 20
The Facility shall comply with the reporting and recordkeeping requirements in Utah Admin.
Code § R649-9-11.
6. Modifications:
This Permit only applies to the Facility as it is described in the Application. Any additions to the
Facility or modifications of the waste treatment processes described in the Application are not
allowed and require a permit modification.
7. Enforcement:
The issuance of this permit does not supersede local ordinances, county planning and zoning
requirements, or other permits required to conduct business at the Facility. A copy of this
approval should be kept at the 12 Mile Wash field office, and field personnel shall be aware of
the Conditions of Approval.
8. Approval:
Therefore, having met all the technical permit requirements of Utah Admin. Code §§ R649-9 et
seq., final approval to operate the Facility in accordance with this Permit is hereby granted.
9. Contact Information:
The following are Division of Oil, Gas and Mining contacts and their telephone numbers:
Dayne Doucet, Oil and Gas Permitting Manager: 801-538-5303
Bart Kettle, Interim Deputy Director: 435-820-0862
Ammon McDonald, Environmental Scientist: 801-538-5337
Approved By:
________________________
By: Dayne Doucet
Title: Oil and Gas Permitting Manager
pp y
_______________________________________
D D
14 of 20
Conditions of Approval:
1.Evaporation Facilities
1.1 A minimum of 2 feet of freeboard shall be maintained in the pit(s) at all times, and that a
method of obviously displaying the freeboard shall be devised and implemented. Utah
Admin. Code § R649-9-4.6.4.
1.2 Pit(s) are to be maintained such that hydrocarbons will not collect on the surface.
Hydrocarbon accumulations, other than de minimis quantities, shall be removed within 24
hours. Utah Admin. Code § R649-9-4.6.4.
1.3 Spraying water to accelerate evaporation should be closely monitored. Overspray outside the
lined pit area is a violation. Utah Admin. Code § R649-9-4.9.2.
1.4 The leak detection system must be checked weekly. Any leak must be reported to the
Division immediately, and corrective measures must be taken as directed by the Division.
1.5 The compacted secondary containment berms at the Facility shall be inspected quarterly and
after a major rainstorm or windstorm to ensure integrity. Utah Admin. Code § R649-9-
11.3.2.
1.6 Evaporation ponds are permitted to accept produced water.
2.Landfarms
2.1 This facility is not permitted to accept new material to the existing landfarm.
2.2 Pooling of liquids in the landfarm is prohibited.
2.3 Soils shall be turned regularly, a minimum of once a month.
2.4 Continual progress shall be made with reclaiming the existing landfarm as outlined in the
submitted land farm remediation plan (with the modification that the remediation continues
until the entire volume in the land farm is reclaimed).
FAILURE TO COMPLY WITH THE ABOVE LISTED CONDITIONS OF
APPROVAL MAY RESULT IN CLOSURE OF THE FACILITY.
15 of 20
Compliance Review Completed:
No outstanding compliance
Active violation/compliance matter
Signature:
Comments
Disposal Facility ermit Renewal Check is
Name of Operator:
Name of
Brennan Bottoms Disposal
12 Mile Wash
SE SE S19 T6S R21E
08/14/20
KK&E, llc Digitally signed by Dayne Doucet
Date: 2020.06.19 14:34:20 -06'00'
06/13/18 BTK 08/21/20 DD
06/13/18 BTK 06/19/20 DD
06/20/18 BW 06/13/18 BW $ 1,286,000
Incomplete application received 05/14/2018
Digitally signed by Dayne K Doucet
Date: 2020.08.26 10:26:40 -06'00'
01/27/20 ASM Requires removal info for Glen Bench #2-BTK 7/26/2018
Diagram incorrectly labeled- BTK 7/26/2018
06/24/20 ASM Brine water spills not allowed to landfarm-BTK 7/26/2018
History of leak detection demonstrating no spills require
if referenced -BTK 7/26/2018
Landfarm remediation plan submitted -ASM 6/2/2020
01/27/20 ASM
06/24/20 ASM Landfarm samples provided ASM 8-21-2018. Landfarm
and Pond #1 hydrocarbons issued NOV 6/27/2018 with
no resolution- BTK 07/26/2018
16 of 20
Contouring or Regrading
Seedi
Notes:
Comments
01/27/20 ASM Lacks detail of what tasks are preformed daily weekly-
BTK 07/26/2018
Cost for Post Closure Monitoring not provided- BTK 7/26
06/20/18 BW $337,520. Are there other cost beyond what was listed in
the provided estimate?
06/20/18 BW $375,540. estimated
06/20/18 BW $473,000 Earthwork
$30,000 Seeding /Post closure cost estimate $30,00006/20/18 BW
3/26/2019 Estimation Closure Costs recommended $1,286,000.00 Unless there are items I am unaware of like heavy metals or such?
Items requiring modifications BTK 07/26/2018
-Corrected-Application contains information for both 12 Mile Wash and Glen Bench facilities: these are separate facilities which require separate renewal applications(6/20/2018-New
application provided)
-Diagram labeled incorrectly
-Description of spills taken to landfarm
-Landfarm sample results provided in renewal application
-Detailed description of daily/weekly monitoring task completed
-Cost estimate of Post Closure Monitoring
-Cost estimate depicting expense to deal with solids in evaporation pits along with more detailed description of cost estimate for Remediation Costs
17 of 20
Utah Solid Waste Program Temporary Permit Application
for
Brennan Bottom Disposal llc Exploration & Production Waste Disposal
12-Mile Wash Facility
3999 W 12250 South 12-Mile Wash Rd, Vernal, Utah
Rev 20240925
ATTACHMENT 2-c
DOGM Bonding (Financial Assurance)
DOGM database contains the following listing for the 12-Mile Wash Facility.
Guarantor: Zions Bank NA (10197)
Bond Number Bond Type Bond Status Bond Purpose Bond Instrument
5791694093 Individual Active Facility Bond
Certificate of
Deposit
Facility Name Operator Name Facility Type Facility Status Bonding Amount
12-Mile Wash
Brennan Bottom
Disposal
Waste
Facility/Commercial Active $1,286,000
Facility bonding amounts are also referenced in attached DOGM permitting documents.
20 of 20
 STATE OF UTAH Waste Disposal Permit
 DEPARTMENT OF NATURAL RESOURCES AMENDED REPORT 
 DIVISION OF OIL, GAS AND MINING Original Filing Date: 5/14/2018
WASTE DISPOSAL PERMIT
  1. Name of Operator
  Brennan Bottom Disposal
  2. Utah Account Number
  100280.0
  3. Address of Operator                   City            State      Zip
  4091 West 3000 South  Roosevelt  UT  84066  
  4. Phone Number
   435-722-6724
  5. Name of 3rd Party Contractor
  KK&E, llc
  6. Facility Name
  12 Mile Wash
  7. Address of Contractor                   City            State      Zip
  9706 Buttonwood Dr   Sandy   UT  84092  
  7. Phone Number

  9. Additional Comments
August 26, 2020
Sundry Number: 88084
RECEIVED: May. 14, 2018

BRENNAN BOTTOM DISPOSAL
DISPOSAL: 3999 W 12250 S TWELVE MILE RD - VERNAL
OFFICE: 4092 W 3000S – ROOSEVELT UT 84066
Rev 20200814 KK&E

Permit Renewal Application
for
Brennan Bottom Disposal, llc

BBD E&P Waste Disposal Facility
Five Year Permit Renewal
Presented To:
State of Utah
Division of Oil, Gas and Mining
Department of Natural Resources
Prepared by:
KK&E, llc
9706 Buttonwood Dr
Sandy, UT 84092
on
August 14, 2020
Property Location:
Approximately 80 Acres occupying
SE/4 & SW/4 of SW/4 Section 19
T 6S, R 21E, SLB&M
Uintah County, Utah

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 1 Page of 12 KK&E

TABLE OF CONTENTS
A. Introduction and Narrative
B. Site Description and Assessment and Closure and Post Closure Cost Estimate
1. Commercial Status
2. Description and Assessment of Existing Facility Components and Conditions
a. Site Description
b. Site Contamination Evaluation
c. Site and Equipment Assessment
d. Practices Assessment
e. Monitoring Program
3. Closure Cost and Bonding Evaluation
a. Contamination Evaluation
b. Remediation of E&P Waste Contamination
c. Site Closure Evaluation Scope of Work
d. Infrastructure Removal Scope of Work
e. Seeding and Revegetation Scope of Work
f. Initial Closure Monitoring Report
g. Post Closure Monitoring Scope of Work
4. Observations and Recommendations
C. Contact Information
1. Operator and Facility Manager
2. Engineer
3. Sampling/Testing Supervisor
4. Headworks Engineer
D. Attachments
1. Attachment 1 – Maps and drawings
2. Attachment 2 – Third Party Closure Cost Estimate

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 2 Page of 12 KK&E
A. Introduction and Narrative
Brennan Bottom Disposal, llc (BBD) submits this Exploration and Production (E&P) Waste Disposal
Permit Renewal Application (Application) for the subject facility (Facility) in accordance with the
requirements of Utah Administrative Code, Rules R649-9-8.2, R649-9-8.2.1 and R649-9-8.5.1. This
Application includes an assessment of site reclamation requirements and closure cost estimates
compiled by KK&E a third-party contractor.
BBD understands that permit renewals may be approved for a five-year period depending on the
results of Utah Division of Oil Gas & Mining (DOGM) review of the Application and historic Facility
compliance performance.
The Facility receives and separates components of produced water, natural gas liquids (NGL), other
Exploration and Production (E&P) wastes and other wastes as may be permitted.
The Facility is located about 12.5 miles south southeast of Vernal, Utah and 0.8-miles northwest of
the Green River. The address to the Facility is:
3999 West 12250 South Twelve Mile Rd
Vernal, Utah 84078-8524

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 3 Page of 12 KK&E
B. Commercial Designation, Site Description and Assessment, and Closure and Post
Closure Cost Estimate
The following narrative addresses requirements established for permit renewal of the titled facility as
described in in Utah Division of Oil, Gas and Mining guidance document, Five Year E&P Waste
Disposal Facility Permit Renewals, (re: Utah Oil & Gas Conservation General Rules R649-9-8.5.1
Bonding of Disposal Facilities), dated August 2017.
1. Commercial Status
BBD is defined by DOGM statute and rule as a commercial operation.
2. Description and Assessment of Existing Conditions and Waste Handling Process
a. Site Description.
i. Location
The BBD Exploration & Production (E&P) Waste Disposal is located on two 40-acre parcels
approximately 12.3 miles south southwest of Vernal, UT, at 399 W 12250 S Twelve Mile
Wash Road and situate in SE/4 & SW/4 of SW/4 Section 19 T 6S, R 21E, SLB&M.
ii. Geology, Drainage and Vegetation of 12 Mile Wash and the BBD Site
- 12-Mile Wash
As a geologic feature, it is an ephemeral drainage without known springs, seeps or
surface watercourses or impoundments. Rain and snow melt drain through this normally
dry wash to its confluence with the Green River, located approximately one (1) mile
down drainage to the southeast.
Its surficial geology is a combination of mixed alluvium, colluvium and lacustrine deposits
from the Brennan Basin member of Duchesne River formation.
The lacustrine surficial geology is Brennan Basin member of the Duchesne River
formation. It consists of light- to medium-red, light-reddish-brown, and yellowish-gray,
fine to medium-grained lithic sandstone and siltstone with minor amounts of mudstone
and conglomerate. It contains well-developed paleosols. The exposed basal part of the
Brennan Basin Member intertongues with the underlying Uinta Formation and is as much
as 60 m thick. The contact is placed at the base of a resistant reddish-brown sandstone
bed that lies on the uppermost variegated mudstone bed of the Uinta Formation. The
Brennan Basin Member, however, lies unconformably on beds of the Green River
Formation near Squaw Ridge
The surrounding land is composed of flats, plateaus and ridge tops overlooking broad
drainage bottoms bordered by low hills. Vegetation is sagebrush, greasewood and other
dry climate native and invasive species.
- BBD Site
To a large extent, major Facility improvements occupy the Wash flood plain. Soils are
mixed alluvium and colluvium, consisting of unconsolidated mud, silt, sand, and gravel.

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 4 Page of 12 KK&E

iii. Overview of Facility Operations
The current site has one fixed building, an off-loading area, one open, concrete, in-ground
receiving headworks tank set, 17-each, API-12 above-ground storage tanks which are in
service, eight operational evaporation ponds, one 3.7-acre Landfarm and one E&P Waste
Landfill. The E&P Waste Landfill is regulated by Utah Department of Environmental Quality,
Division of Waste Management and Radiation Control, Solid Waste Program Management.
Although the BBD Landfill is co-located at the Facility, it is not regulated by DOGM.
iv. Current Site Configuration, Components Equipment and Process Compared to Previous Permit
BBD seeks to:
- Change the secondary stage of its oil, water and solids separation operations from a
heated, coagulation-based process to an enhanced gravity process using a
centrifuges,
- Cease operating and reclaim its existing Landfarm at such time as the backlog of
untreated material in the Landfarm is significantly reduced and
- Maintain the eight (8) produced water evaporation ponds and the primary gravity
separation process for oil, inter-phase, water and solids.
Existing fixed and mobile buildings, off-loading area, open, concrete, in-ground receiving
headworks tank, propane tanks and all API tanks will remain.
v. Evaporation Ponds
The eight operational evaporation ponds are nominally 3.0, 3.9, 3.5, 1.9, 3.5, 3.0, 3.6 and
3.6 acres. Each has a primary 60-mil HDOE liner and a secondary compacted soil liner
having a lab permeability not greater than 10-7 cm/sec.
Leak detection piping is located on top of the secondary liner and discharges to designation
leak detection observation wells.
vi. Landfarm
The 3.7-acre Landfarm was permitted by DOGM and constructed to meet DOGM standards.
As such, it rests on unlined native soil.
Landfarm soils are periodically lab tested to determine how to maintain the amount of
moisture, nutrients and available free oxygen to support the population of Colony Forming
Units of bacteria recommended by USEPA for this operation. These bacteria clean
contaminated soil by fixing and transforming Volatile Organic Compounds (VOC’s) into water,
carbon dioxide and organic nitrogen compounds.
Logs of landfarm activity, soil sampling and lab reports are maintained and reported in
accordance with DOGM regulations.
Laboratory analysis is performed for (a) BTEX concentrations (Benzene; Toluene;
Ethylbenzene; Xylene; Naphthalene); (b) Total Petroleum Hydrocarbons, in the Gasoline,
Diesel and Oil/Grease ranges (TPH-GRO; TPH-DRO; TPH-ORO) and (c) soil salinity.
Soil meeting DOGM cleanliness standards is moved from the landfarm to the landfill or other
on-site locations. Treated soil moved from the landfarm, but not placed in the landfill will be
stockpiled in a designated location.
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 5 Page of 12 KK&E
vii. Heating Fuel Tanks
Propane heating fuel is stored in one 500-gallon and three 1,500-gallon propane tanks. All
tanks are free-standing and oriented with long axes oriented parallel to the long axes of
adjacent buildings or storage tank batteries.
viii. Oil Wells Owned and Operated by Others
Two operating, commercial oil wells owned by others are located inside of the site
boundaries. No other oil or injection wells are co-located on this site.
ix. Waste Handling Process
Liquid E&P Waste is discharged into the on-site process system from transport trucks. There
are no buried or above-ground pipelines delivering liquid E&P waste to this site.
Water having relatively low solids content and little economically recoverable oil is routed
through the Headworks tank set.
Water having high solids content and/or a relatively economically recoverable oil content is
transferred by truck to a set of API-12, heated and un-heated gravity separation tanks.
One, open, steel above ground 150 bbl mixing tank is used to incorporate certain
conditioning reagents before being fed to Tank No. 5 and/or Tank No. 6. The contents of
Tank No. 5 and No. 6 are fed to a single Flottweg Z4E Tricanter centrifuge separator by a
Moyno progressive cavity screw pump.
Solids from gravity and enhanced gravity separation are stored in holding tanks before being
landfarmed.
Water from gravity and enhanced-gravity separation is routed to the primary receiving cell in
the Headworks tank. Water which either never contained phase separable hydrocarbons or
from which phase separable hydrocarbons have been effectively removed is routed to the
evaporation pond system.
Oil from gravity and enhanced-gravity separation is ultimately transferred to on-site oil sales
holding tanks.
Tank Bottoms waste and similar slurries having excess free liquid are not allowed to be
transferred to the Landfarm. Before placement in the Landfarm all such slurries are required
to pass the EPA 9095B Paint Filter Test.
Drilling Mud and Contaminated Soil meeting the paint filter test threshold for free liquid are
accepted by BBD and either remediated in the Landfarm or disposed in the Landfill.
Other permitted E&P waste is also taken to the 4.5-acre landfill which is not permitted or
regulated by DOGM.
One, 1-acre Stormwater Detention basin is located in the center of the eastern quarter of the
site. It has been designed to hold runoff generated by a 25-year, 24-hour storm until the
runoff can be sampled and lab-tested. Depending on lab results the water will be either
released to the local drainage, held to evaporate in place, diverted to evaporation ponds or
disposed by some combination of the three aforementioned methods.

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 6 Page of 12 KK&E

b. Site Contamination Evaluation
i. Site Contamination No. 1 (NOV-1)
One DOGM Notice Of Violation dated 12/12/2019 described unredmediated waste placed on
roads, dikes and berms throughout the facility.
NOV-1 has been successfully remediated. Remediation consisted of removal of all
inappropriately placed unredmediated waste. Where unredmediated waste was incorporated
into earthen structures it has been replaced with clean, appropriately screened, graded and
compacted soil and gravel.
A complete description of the resolution of NOV-1 has been transmitted to and accepted by
DOGM’s Enforcement Manager.
ii. Site Contamination No. 2 (NOV-2)
A second DOGM Notice Of Violation also dated 12/12/2019 described visible hydrocarbons on
the surface of evaporation pond 1 and water in the leak detection of the concrete unloading
vault.
NOV-2 has been successfully remediated. Remediation consisted of excavation and removal
of soil around and immediately to the north of the concrete Headworks Tank to expose and
repair or replace damaged secondary liner, leak detection piping, leak observation well and
the 10-inch Headworks discharge pipe.
The discharge pipe and leak detection sump were replaced in their entirety.
A complete description of the resolution of NOV-2 has been transmitted to and accepted by
DOGM’s Enforcement Manager.
iii. Other Site Contamination
There is no known or observable hydrocarbon contamination on this site.
No process-induced vadose zone soil contamination is known to exist at the Facility. The is
no or unconfined aquifer at this site.
There are no known records of incomplete spill clean-up.
Process containment berms, sumps and similar enclosures are free from pooled crude oil or
crude oil contaminated solids.
c. Site and Equipment Assessment
Major equipment operated at this facility has been examined by Engineer. Engineer’s opinion of
equipment service life expectations is included in this article. All tests were cursory in nature. A
review of equipment repair and evaluation records provided by Owner forms the basis of the
Engineer’s opinion of service life expectancy. All evaluations made were based upon the
assumption that regular maintenance and equipment repair has been and will continue to be
performed.
More particularly:
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 7 Page of 12 KK&E
i. Site roadways are constructed and maintained with appropriate wearing surface, drainage
and turning radii for expected traffic.
ii. Roadway and site drainage channels show no signs of overflow or excessive erosion.
iii. Earthen structures are free of excessive erosion.
iv. Observable portions of piping and HDPE liners are not excessively worn or weathered. One
3.0-acre and on 2.9-acre evaporation pond are currently empty.
v. Pump seals do not leak and drips are installed where necessary for bearing water discharge.
vi. Process heaters appear to be operational and automatically fire and shut off as expected.
vii. Exposed surfaces of steel tanks and piping are corrosion free with the exception of mill scale
and light, tightly adhering rust. No pitting indicative of concentrated corrosion cells was
observed.
viii. Buildings
- Office building is a space-conditioned, single-wide trailer. There is no piped wash water,
potable water or sanitary system on-site. External siding, roofing and interior floors and
walls were determined be in satisfactory condition based on cursory visual inspection.
- Equipment process building is a 30 by 30-foot, pre-engineered metal building on a
concrete mat foundation located immediately south of API tanks No. 5 and No. 6.
Building is not space-conditioned. This building houses the Flottweg Tricanter and
associated equipment.
- There is no vapor extraction system on the site.
- There are two hand tool and consumable storage buildings on the site. Both are stick-
built structure and neither is constructed for human occupancy.
ix. Observable manual and motor-operated valves show signs of recent operation suggesting
they perform satisfactorily for throttling and shut-off.
x. Landfarm operation shows no sign of excess water or oil present in the mix. Landfarm soil
sampling and lab testing are performed at least monthly. Care is being taken to accurately
collect five-point composite samples from the cardinal corners and center of the Landfarm
area that are representative of the landfarm waste being remediated.
d. Practices Assessment
Engineer has reviewed Owner provided operating procedures and has observed those
procedures in practice. Owner and Engineer offer the following practice changes to improve
efficiency and environmental protections.
i. Oil Cleaning, Water Disposal and Solids Disposal Operation Assessment
Controls for the process described in B., 1., a., Waste Handling Process, above and shown on
the Process Flow Diagram in Attachment 1, are all manually operated. There is no site wide
analog, discrete or distributed control system.
- Operators appear to be familiar with the overall plant process. Operators sample process
liquids for anomalies. Whenever process liquids or machinery operation appears
abnormal operators will intervene in one of two ways.
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 8 Page of 12 KK&E
Most often the operator will make equipment and process adjustments for which the
operator has been trained and given authority to perform.
Process and equipment adjustments which appear to be needed, but which operator has
not been authorized to perform, are immediately brought to the attention of other
operating staff and plant management for resolution.
- Centrifuge and heated tank temperatures, pressures, flowrates and the like are
monitored by operating staff. All monitoring and all sampling is locally
observed/performed/recorded.
- Leak detection equipment is monitored weekly.
- It is the Engineer’s opinion that:
ii. Some additional process monitoring automation would increase overall plant efficiency and
lessen the probability that accidental waste discharge would occur.
iii. Weekly leak detection monitoring is appropriate and should be maintained.
The biggest process variable is the type of waste brought to the Facility. It is the Engineer’s
opinion there is no commercially available, cost effective, off- the-shelf (COTS) equipment to
classify incoming waste. There is no Reasonably Available Control Technology (RACT) or
even Best Available Control Technology (BACT) that is economically viable for BBD to
implement. The methods that remain (client waste certification, periodic waste testing by
client, waste evaluation by experienced staff and similar) are best available for the BBD
operation and should continue to be used.
iv. Landfarm Operation Assessment
- The existing landfarm accepts E&P solid wastes that pass a paint filter test and contain
hydrocarbons. This "Landfarm" is a wind-row, soil remediation process that reduces
petroleum contaminated soil (PCS) concentrations through biodegradation.
- Contaminated soils are periodically turned over using common farming or similar
equipment to aerate landfarmed soils. This practice supports naturally occurring aerobic
and/or augmented micro-organisms (archaea and bacteria) consuming E&P waste in the
contaminated soil.
Landfarm waste bulk density, texture and porosity are controlled by addition of straw,
sawdust, farm manure and similar conditioning material.
Clean, low salinity water is applied as needed to keep the soils moist enough to support
micro-organism growth.
- Runoff water is detained in the southeast corner of the landfarm. Excess stormwater is
drawn off as necessary and added to incoming liquid E&P waste.
- Lab testing is used in addition to visual and olfactory screening to monitor the
landfarming process. Before material is removed from the landfarm, samples are taken
and lab tested to ensure the treatment process is completed.
- Engineer has determined that this treatment process and associated lab test results are
being correctly applied. No changes to this treatment process are needed to comply with
regulation or improve the process.

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 9 Page of 12 KK&E

e. Monitoring Program
i. Soil and Water Complex
Soil and water sampling and testing, visual equipment inspection, pressure tests, sampling and
analysis of material collected by leak detection systems used at this facility are described below.
- Sampling and testing for spill and/or leak clean-up is performed to verify that all needed
clean-up is complete.
- Sampling of landfarm soil is performed to evaluate process efficiency, completeness of
hydrocarbon removal and salinity thresholds before removal of treated soil.
- Water Sampling and testing is performed on all liquid taken from leak detection sumps.
- Leak Detection Monitoring of designated leak detection sumps is performed weekly.
- Additional or re-configured monitoring practices which could reasonably and
economically improve operational efficacy and detection of inadvertent waste release
are described below.
ii. Equipment Monitoring
Mechanical and electrical equipment efficiency and safety could be enhanced by performing
the following.
- Quarterly survey of valve packing and gaskets for excessive wear and leaks.
- Annual evaluation of mechanical and hydraulic operating efficiency of pumps, mixers and
centrifuge. Such an evaluation would include verifying that equipment is matched to
system operating pressures and temperatures.
- Annual calibration of pressure release/vacuum relief valves and thief hatch springs and
weights.
- Annual cursory check of process and stoichiometry and mass balance to rule out leaks
and verify process efficiency.
- One-time evaluation of each pump and blower to verify that the correct type of
equipment has been chosen for the operating condition. For example, verifying that the
most appropriate equipment types and ratings have been selected.
- Quarterly readings to determine that individual large motor and plant-wide power factor
correction is within reasonable ranges to reduce electric power consumption and
demand.
- To enhance early detection of inadvertent waste release and more accurately determine
leak sources BBD is considering:
o Annual low-pressure testing of buried pipe.
o Perform five-year electrical liner leak testing per ASTM D7007.
iii. Electric Power System
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 10 Page of 12 KK&E
- No transient or harmonics monitoring/hardening is required because there are no
variable frequency drives or phase shifting equipment in use.
3. Closure Cost and Bonding Evaluation
Bond cost components referenced in this section have been determined by applying unit costs to a
quantity take-off from drawings and documents provided by Owner and cursory field inspections and
surveys by the Engineer.
a. Contamination Evaluation
All documented contaminated soil at BBD has been removed and sequestered in the Landfarm or
Landfill. No other soil contamination is known or has been observed at BBD.
Geotechnical exploration borings advanced to over 50 feet below ground surface did not
encounter water, consolidated soil or rock. Geologic maps do not indicate the presence of near
surface groundwater and there are no nearby well boring logs showing the presence of
groundwater. For the purposes of this Application it is assumed there is no groundwater in the
unconfined strata underlying BBD.
b. Remediation of E&P Waste Contamination
With the exception of the controlled and on-going landfarm operations none is required because
all known contamination outside of the Landfarm has been removed.
c. Site Closure Evaluation Scope of Work
Upon closure the existence and extent soil contamination will be identified with a PID survey.
Groundwater quality and surface water will be sampled lab-tested. Hazardous substances stored
or used on site will be inventoried. Costs for this evaluation are included in calculated closure
costs in Appendix 2.
d. Infrastructure Removal Scope of Work
The cost to remove all site infrastructure and equipment as may be reasonable and necessary to
return site to a condition similar to its use and appearance before being used as an E&P Waste
Disposal is included in reclamation cost estimate.
No costs are included to reclaim and/or improve the site to conditions better than those occurring
before its use as and E&P Disposal or markedly better than exist on adjacent property. Grading
and contouring the site to the exact site geometry before site was used as an E&P Disposal has
not been used as a reclamation criterion.
Infrastructure removal closure cost estimates include:
i. Removal all tanks, fences, buildings, liner materials, piping and concrete structures which do
not add value to the site are included in the Infrastructure Removal portion of closure costs.
ii. Earthwork and grading to restore site to a serviceable condition similar to, and in keeping
with surrounding land use and drainage.

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 11 Page of 12 KK&E
e. Seeding and Revegetation Scope of Work
Seeding/revegetation cost is based drag harrowing and hydroseeding is included in the closure
cost estimate. Seed mixture and application rate determined by Great Basin Company of
Ephraim, Utah are included in this component of closure cost estimate.
f. Initial Closure Monitoring Report
This report will describe:
i. Closure PID survey results and required sampling and lab testing.
ii. Groundwater and surface water required to be sampled lab-tested.
iii. Inventory of hazardous substances removed from site.
iv. Description of site grading, revegetation and erosion control installed.
g. Post Closure Monitoring Scope of Work
Post closure monitoring and care cost includes annual:
i. Erosion control and surface water management.
ii. No groundwater sampling has been included because the is no unconfined aquifer underlying
this site.
iii. Sampling and testing of site and Landfarm soil and any surface water as described in the
initial closure report.
iv. Written report describing the condition of the reclaimed site and work performed to monitor
and maintain reclaimed site.
4. Observations and Recommendations are Included in Article 1.d, above.
C. Contact Information
1. Operator and Facility Manager
C.J. Nebeker
Brennan Bottom Disposal, LLC
4091 West 3000 South, Roosevelt, UT 84066
435-823-1144
E-mail: [e-mail]
2. Engineer
Kerry J. Spiroff, P.E. (UT 273867-2203)
KK & E, llc
9706 Buttonwood Drive, Sandy, UT 84092
(O) 801-712-8677, (F) 801-943-8145
E-mail: [e-mail]

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 12 Page of 12 KK&E
3. Sampling/Testing Supervisor
Kenneth L. Walter, PG
Walter Environmental Group, LLC
P.O. Box 3967
Grand Junction, CO 81502
(O) 970-255-8017; (F) 970-255-8018; Cell 970-250-2470
E-mail: [e-mail]
4. Headworks Engineer
David Fox, PE
Fox Engineering Solutions
P.O. Box 413
Fruita, CO 81521
970-250-5505
E-mail: [e-mail]

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 KK&E

D Attachments

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 KK&E

ATTACHMENT 1
DRAWINGS
S-001 Site & Parcels
S-002 Site Topography
G-001 Site Layout
G-002 Offload
G-003 Headworks Tank
G-004 Tank Batteries
G-005 Centrifuge Building
G-006 Landfarm
M-001 Centrifuge Plan
M-002 Centrifuge West Elevation
M-003 Centrifuge North Elevation
M-004 Centrifuge Section
PFD-001 Process Flow Diagram

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
(9 0 w (9
0 z ca
I I I I I I
I I I I I I
I I I
I I I
I I I I I I I I I I I I -----+------+------------�-------+-------�------
-----
I I
I I
I I
I I
I I
I I 4------+--
-----+-----
1 I I I
I I
I I
I I
w w T 6S I I I
___ o�------�-------------�------
0:: o:: I I
I I
SEC25
NW/SW/4 I I
I NE/SW/4 NW/SE/4 I
I I
BRENNAN BOTifOM DISPOSAL I I
POND 1
POND3
SEC30
\ POND2
r-
0 z 0 0...
CX)
0 z 0 0...
- - - -1- - - - - - -
0 I 300 I 60 900 1200 1500 FT I I I I
t---t----+-+-------------_J SCALE: 1" = 600 FT LOCATION UINTAH COUNTY, UTAH
A
REV
071720 KJS
DATE BY
5-YEAR PERMIT RENEWAL
DESCRIPTION
PROJECT
KK&E BRENNAN BOTTOM DISPOSAL
TITLE CIVIL, PROCESS & STRUCTURAL ENGR SITE AND PARCELS
5-001
NO.
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
12" 0 PVC NEW
GROU
WELL
NDWATER OBSERVATION
NEW
DETE
WELL
WITH SLIP-ON CAP
<
12"0 PVC LEAK J
CTION OBSERVATION
WITH SLIP-ON CAP
12" 0 PVC LEAK NEW
DETE
WELL
CTION OBSERVATION
NEW
GROU
WELL
WITH SLIP-ON CAP
<
12"0PVC
·� NDWATER OBSERV� WITH SLIP-ON CAP
NEW 10" 0 PVC LINE
TO EVAP POND NO. 2 ffl
Cl < 0
LL LL 0
I
FLOW
DECANTING
CELL4
SC/\L:::: 3/16" -1'-0"
08/14/20 KJS PERMIT RENEWAL
--
le\ " "'
DECANTING
CELL3
FLOW
PLAN
le\ " "' " -l:J
DECANTING
CELL 1
I I
�
DECANTING
CELL2
f'ROcEC-LCCA TON
II ILL
0
"' "
l:J
SOLIDS &
INTERPHASE
HOLDING
CELL
10 20
UINTAH COUNTY, UT
BRENNAN BOTTOM DISPOSAL
HEADWORKS TANK
30
G-003
'iEVISION
A
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
LEAK DETECTION
MONITORING WEL� -----o
-ELEV4730
-ELEV4728
.•. . ... .. �
� ..
..o:
-ELEV4726 ··:.-� �··
i-------1-+----20 FT -----i i------+-+----20 FT -----i ··i-------1-+----20 FT -------i---------20 FT -----i -� . .,,.
-ELEV4724
-ELEV4722
-ELEV4720
LEAK DETECTION
MONITORING WEL�
-ELEV 4730
?10"0 HEADWORKS DISCHARGES
-ELEV 4728
-ELEV 4726
-ELEV 4724
-ELEV 4722
-ELEV 4720
08/14/20 KJS PERMIT RENEWAL
REV DATE BY DESCRIPTION
D
. . .... ·. : .. ·.�.·.· ... ·:: '(:. •• • •
•
• .. • ... • • :"· • •• • � ••
•
•
• •
•
•
•••• •' • .... •
.: •
••• ••
•• : • • • .: .. • • ; : • \.. ... l4' • " • • .. • • •' • • • • • • • • • '4 •, .. .. • • •' :,,. • • • • • • • • • • • • • 4 .. .. •• •
. : .:.. ••• .� ·• • .,it·· .. ....... �· ••• ·: ..... • .• ..... • .• ••.•• :.,, ···�· •. • .. • •.•• , :· ,' :· •• • ... • ...... •••• .:·: :,,, •. :�· :· •••• ,·.
0
SECTION A-A
SCALE: 1/8" = 1'-0"
TOP OF CONC ELEV 4731.9
BOTTOM OF TANK
CELL ELEV 4724
LEAK DETECTION WELL DETAIL
SCALE: 5/8" = 1 '-0"
-­
T"""
T""" -·
LOCATION
..
.
4
4.
10
0
20 I
5
SCALE: AS NOTED UINTAH COUNTY, UTAH
PROJECT KK&E CIVIL, PROCESS & STRUCTURAL ENGR
BRENNAN BOTTOMS DISPOSAL
TITLE HEADWORKS TANK
.... :
30
G-004
NO.
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
UJ
z
w
<( u.. w 0 ...J u5<( I-Z:::> �o 00 z I-I-wu.. CJ 0 <(
C') u.. w 0 u5 I-:::> 0
T
j-1 co
COVERED DUMPSTER
15 CY±
3-0 DOOR
,__----------19'-4" -----------!-----�-'-------"-''----__, I "-
2" ¢ SCHED 40 STEEL _/ I
8'-6"±
! "
4" ¢ SCHED 40 STEEL
WATER WASTE / TRANSFER PUMP
r.±--�= 2" ¢ WATER LINE 2" ¢ SCHED 40 STEEL
\ 2" ¢ OIL LINE
\_ OIL TRANSFER PUMP
�l���-------==::i-----------r-�--------c::=====:
3'-6,=-e:FTOHD OROPNGJ3'0"L10FTOHD00ROPNG� - -
A 071720 KJS BRENNAN REVIEW REV DATE BY DESCRIPTION
1 30 FT N MINAL f-------------+---0 UT SIDE FACET OUTSIDE FACE
SCALE: 1/4" = l'-0" LOCATION
PROJECT
KK&E TITLE CIVIL, PROCESS & STRUCTURAL ENGR
'------_EXIST. INSU.itATED API 12.._ __ ______,
...
TANK & PR1ESS TANK #5
I
EXIST._JNSU TED A_PI,_,1=2�_ TANK & PRO ESS TANK #6
4"
UINTAH COUNTY, UTAH
CENTRIFUGE BUILDING
PLAN
G-005
NO.
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
w
(9 n w
(9 z
0
A
REV
071720
DATE
I
WEST ELEVATION
SCALE: 1/4" = l'-0"
KJS BRENNAN REVIEW
BY DESCRIPTION
�
11-----11
=
LOCATION
PROJECT
KK&E TITLE CIVIL, PROCESS & STRUCTURAL ENGR
I
INSULAT 1 D API 12 TANK & iROCESS
TAr6
I
UINTAH COUNTY, UTAH
CENTRIFUGE BUILDING
WEST ELEVATION
G-006
NO.
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
(90w
(9
0zen
A
REV
071720
DATE
KJS
BY
U) '
:?
f
,J
BRENNAN REVIEW
DESCRIPTION
�,�;
I
1 s
f ,� J
I I
SECTION 1
SCALE: 1/4" = l'-0"
I I 14"±
CUT OPNG FOR CONV81'0R � H
,---,--'""�\-/�---�
j-1 '\l � / -----N ( //\ j
�-/,�\ >���RAGAL
NEW
FIXED LEAF
3-0 DOOR
EXISTING
ACTIVE LEAF
3-0 DOORI
NEW DOOR DETAIL
NEW DOUBLE DOOR
1· I I I ii __ �-�-
0 �I // �-� �v �l'\LI I 1 \
��-----L-1 ,"' '\ ---
LOCATION UINTAH COUNTY, UTAH
PROJECT
KK&E CENTRIFUGE BUILDING
TITLE CIVIL, PROCESS & STRUCTURAL ENGR NORTH ELEVATION
G-007
NO.
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
w 0 n w
0 z -0 L.
A 071720 KJS
REV DATE BY
.....J CD CD
_J co co
11
0 0 --------r----'--------'---------'------�--...:......:...--g-...;....;...-----r-----'--------�
�
BRENNAN REVIEW
DESCRIPTION
2" ¢
CENTRIFUGE
FEED -----------
MOYNO
CENTRIFUGE
FEED
PUMP
SCALE: 3/8" = 1'-0"
l-o::: z $ UJ UJ
= !::: ::::) N.....,.....J 3: tl:: UJ
N
� I
I
TS 6X6X 3/8
9-INCH±
SCREW
CONVEYOR
SOLIDS
DISCHARGE
CHUTE
;
Cf)
TS 6X6X3/8
I 5 FT SQ. I-----15 BBL WATER-�-'---­HOLDING TANK
SECTION 1
KK&E
5 FT SQ. I15 BBL OIL -------I HOLDING TANK
CIVIL, PROCESS & STRUCTURAL ENGR
LOCATION
PROJECT
TITLE
� 3 FT± CLEAR ___j Cl 0...JIll c::: UJ
0 (.) - <(c::: u. UJ
UJ
UINTAH COUNTY, UTAH
CENTRIFUGE BUILDING
SECTION
G-008
NO.
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018

Utah Division of Oil Gas & Mining Permit Renewal Application
for
BBD llc Exploration & Production Waste Disposal
3999 W 12250 S Twelve Mile Rd, Vernal, Utah

Rev 20200814 KK&E

ATTACHMENT 2
CLOSURE COST ESTIMATE
DOGM Closure Summary Form
Supporting Calculations

Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
Brennan Bottom Disposal, llc Date: 8/16/2020
Facility: 12-Mile Wash
Number of Acres to be Reclaimed 55.7 Acres 0
Contamination Remediation Cost Estimates 77,781$ 2
Removal of Infrastructure Costs Estimates 33,076$ 3
Earthwork and Grading Cost Estimates 600,142$ 4
Revegetation Cost Estimates 98,353$ 5
Final Closure & Post Closure Cost Estimates 48,715$ 6
Total Cost Estimate 858,066$
(Increase above total cost estimate by 14% if indirect costs are not included) 120,129$
Total Reclamation Cost Required 978,196$
Bond Posted 1,296,000$ 7
Difference Between Cost Estimate and Bond Excess Bond 317,804$
Direct and Indirect Costs
Five Year E&P Waste Disposal Facility Bond Calculation Summary Form
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
RECLAMATION BOND
CALCULATION SUMMARY
DOGM Line
Item
0
Percentages Reference (RS Means Unless Noted Otherwise)
7%
01 21 55.50 0200 With an additional 2% of unforseeable
events
3%
01 31 00 Adjusted to reflect a percentage, also referenced
ACEC and ASCE for rates
1%01 41 26.50 0100
0%
01 51 00 Not applicable for the scope and scale of a project
like this
3%
01 71 00 Adjusted to reflect a percentage, also referenced
ACEC and ASCE for rates
Total: 14%
1
Reference (RS Means Unless Noted Otherwise)
77.8 AC
22.0 AC
55.7 AC
2
Quantity Unit Price Extended Cost Reference (RS Means Unless Noted Otherwise)
10,298 GAL 1.66$ 17,128$ 02 65 10.30 0130 (modifed for scale)
10,298 BBL 0.86$ 8,900$
31 23 23.20 4096 adjusted to cy for hauling (with $.65 / bbl
cost for disposal facility to accept waste)
0 EA -$ -$
Above costs include the removal (by vac truck) and disposal
of 10% of tank volume
0 EA -$ -$
0 EA -$ -$
4 EA 13,741$ 51,753$ MWH Standard
0-$ -$
Total: 77,781$
Site Assessment, Closure & Post Closure Cost Estimate & Re-statement of Existing Bonds
Line Item Description
Contamination Remediation Cost Estimates
Indirect Costs
Description
Contingencies Price and Payments Procedures
Administrative Requirements
Quality Requirements
Temporary Facilities and Controls
Execution of Closeout Requirements
Site Area
Reclaimed Area
PID Closure Soil Sampling Positives
add text
Description
Descripiton
Total Site Area
Undisturbed Area
Total Disturbed Area
Removal of Contaminated Liquid (1-inch in Pond
Bottom)
Disposal of Contaminated Liquid (Haul and Dump)
Vapor Extraction
Pump & Treat
Managed Self Attenuating Contamination
REV: 08172020 Page 1 of 3 KK,llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
RECLAMATION BOND
CALCULATION SUMMARY
3
Quantity Unit Price Extended Cost Reference (RS Means Unless Noted Otherwise)
2,700 CY Varies 972$ 02 41 19.20 0020 (includes 20 Mile Haul)
18 EA Varies No Cost (net of salvage)
02 65 10.30 1253
4 EA 200.00$ No Cost (net of salvage)02 65 10.30 1253
8,350 LF Varies -$ Removal Included with Hauling Cost , below
297 CY Varies 3,557$ 31 23 16.42 1550 modified to add truck loading
500. SF 1.09$ 545$ 02 41 16.17 0440
9,000 LF Varies 20,340$ No cost net of salvage
429 CY 1.85$ 796$ -$
153 T 45.00$ 6,865$ -$
Total: 33,076$
4
Quantity Unit Price Extended Cost Reference (RS Means Unless Noted Otherwise)
244,765 CY 1.76$ 430,786$ 31 23 16.46 5020
0 CY 2.83$ -$ 31 23 16.46 5040
0 CY 1.53$ -$ 31 23 16.46 5000
1,247,925. SF 0.05$ 169,356$ 31 22 13.20 0280 (modifed for scale)
Total: 600,142$
5
Quantity Unit Price Extended Cost Reference (RS Means Unless Noted Otherwise)
3,387 MSF 28.94 98,353$ 32 92 19.14 5800*
Total: 98,353$
6
Quantity Unit Price Extended Cost Reference (RS Means Unless Noted Otherwise)
1 YR 550.00$ 5,500$ MWH estimates based on inhouse estimates
10 YR 120.00$ 1,200$ MWH estimates based on inhouse estimates
10 YR 750.00$ 7,500$ MWH estimates based on inhouse estimates
9 Mo 1,000.00$ 9,000$ 32 91 13.23 Structural Soil Mixing
12 Mo 534.60$ 6,415$ 32 91 13.23 6000 Tilling 6" Cost for 12 tillings
1 YR Varies 2,100$ MWH estimates based on inhouse estimates
8 YR 1,500.00$ 12,000$ MWH estimates based on inhouse estimates
2 YR 2,500.00$ 5,000$ MWH estimates based on inhouse estimates
Total: 48,715$
Removal of Infrastructure Costs Estimates
Earthwork and Grading Cost Estimates
Revegetation Cost Estimates
Final Closure & Post Closure Cost Estimates
Descripiton
Buildings
Tanks (No cost - net of salvage)
Gensets (No cost - net of salvage)
Buried Piping
HDPE Liner Removal
Concrete Pads
Fencing
Hauling
Landfill Fees
Descripiton
Common Earth to be Dozed
Clay Liner to be Moved
Sand & Gravel to be Moved
Rough Grading
Descripiton
Hydro Seeding of Native Grass
Descripiton
Well Inspection & Sampling
Water Quality Meter Rental
Initial and Final Post Closure Report
Lab Analysis
Grounds Maintenance
Landfarm
Monitoring Well Abandonment
Annual Report
REV: 08172020 Page 2 of 3 KK,llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
RECLAMATION BOND
CALCULATION SUMMARY
7
Posted Amount Reference (RS Means Unless Noted Otherwise)
1,296,000$ BBD Records
Total: 1,296,000$
ID No. & Listed Reclamation
Bond Posted
Bond Descripiton & Date
REV: 08172020 Page 3 of 3 KK,llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAM BOTTOM DISPOSAL
INDIRECT COST ALLOCATION
Percentage Reference (RS Means Unless Noted Otherwise)
7% 01 21 00
01 21 55.50 0200 With an additional 2% of unforseeable events
Percentage Reference (RS Means Unless Noted Otherwise)
3% 01 31 00
01 31 00 Adjusted to reflect a percentage, also referenced ACEC and ASCE for rates
Percentage Reference (RS Means Unless Noted Otherwise)
1% 01 41 00
01 41 26.50 0100
Percentage Reference (RS Means Unless Noted Otherwise)
0% 01 51 00
01 51 00 Not applicable for the scope and scale of a project like this
Percentage Reference (RS Means Unless Noted Otherwise)
3% 01 71 00
01 71 00 Adjusted to reflect a percentage, also referenced ACEC and ASCE for rates
Total Indirect Cost: 14%
INDIRECTION COST EVALUATION
5. Examination and Preparation
3. Permits
Item
4. Temp Utilites
Item
Item
Administrative Requirements
Quality Requirements
Temporary Facilities and Controls
Execution of Closeout Requirements
Contingencies Price and Payments Procedures
Item
1. Economic Conditions (Unfavorable)
Item
2. Project Management and Coordination
REV: 08172020 Page 1 of 1 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
CONTAMINATION AND REMEDIATION
Location Quantity Unit Unit Price Cost Reference (RS Means Unless Noted Otherwise)
Pond 1 1,226 BBL Bbl 1.66$ 2,038$ 02 65 10.30 Line 0130 (modifed for scale)
Pond 2 1,124 BBL Bbl 1.66$ 1,870$
Pond 3 1,448 BBL Bbl 1.66$ 2,408$
Pond 4 687 BBL BBl 1.66$ 1,142$
Pond 5 1,305 BBL Bbl 1.66$ 2,171$
Pond 6 1,194 BBL Bbl 1.66$ 1,986$
Pond 7 1,526 BBL Bbl 1.66$ 2,539$
Pond 8 1,653 BBL Bbl 1.66$ 2,748$
Tanks 136 BBL Bbl 1.66$ 226$
Total 10,298 BBL 1.66$ 17,128$
Location Quantity Unit Unit Price Cost Reference (RS Means Unless Noted Otherwise)
Pond 1 1,226 bbl 0.86$ 1,059$ 31 23 23.20 4104
Pond 2 1,124 bbl 0.86$ 972$
Pond 3 1,448 bbl 0.86$ 1,251$
Pond 4 687 bbl 0.86$ 593$
Pond 5 1,305 bbl 0.86$ 1,128$
Pond 6 1,194 bbl 0.86$ 1,032$
Pond 7 1,526 bbl 0.86$ 1,319$
Pond 8 1,653 bbl 0.86$ 1,428$
Tanks 136 bbl 0.86$ 118$
Total 10,298 0.86$ 8,900$
CONTAMINATION ASSESSMENT & REMEDIATION COST
Removal of Contaminated Liquid (1-inch in Pond Bottom)
Disposal of Contaminated Liquid (Haul and Dump)
REV: 08172020 Page 1 of 2 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
CONTAMINATION AND REMEDIATION
Location Quantity Unit Unit Price Cost Reference (RS Means Unless Noted Otherwise)
None 0 SET 2,700.00$ -$
Location Quantity Unit Unit Price Cost Reference (RS Means Unless Noted Otherwise)
No Equipment 0 EA 0.10$ -$
Location Quantity Unit Unit Price Cost Reference (RS Means Unless Noted Otherwise)
0 lump sum -$
Location Quantity Unit Unit Price Cost Reference (RS Means Unless Noted Otherwise)
4 Positives Positive Samples Varies 51,753$
Vapor Extraction
Pump & Treat
Managed Self Attenuating Contamination
PID Closure Soil Sampling
REV: 08172020 Page 2 of 2 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
INFRASTUCTURE REMOVAL
Material Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
Steel 2,700 CF* $0.36 / CF* 972$ 02 41 19.20 0020 (includes 20 Mile Haul)
Masonry 0 CF* $0.39 / CF* -$
Concrete 0 CF* $0.51 / CF* -$
Wood 0 CF* $0.39 / CF* -$
Total: 2,700 CF* 972$ * Cubic Feet of Walls & Roof
Type Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
Upright 17 LF 880$ 14,960$ 02 65 10.30 1253
Flat 0 LF 880$ -$
Cenrifuge 1 LF 825$ 825$
Oil Take Away 0 LF 825$ -$
Total: 18 LF 15,785.00$
Type Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
Welders / Generators - 200$ -$
Size Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
4" 8,050 LF 0.26$ -$
-$
Total:8,050 LF -$
Removal Included with Hauling Cost , below
Buildings
Tanks (No cost - net of salvage)
Gensets (No cost - net of salvage)
Leak Detection Piping Removal
REV: 08172020 Page 1 of 4 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
INFRASTUCTURE REMOVAL
Size Quantity Reference (RS Means Unless Noted Otherwise)
4"-6" 300 LF
10" 0 LF
300 LF
Location Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
Pond 1 36 CY 2.51$ 91$ 31 23 16.42 1550 modified to add truck loading
Pond 2 34 CY 2.51$ 86$
Pond 3 41 CY 2.51$ 103$
Pond 4 23 CY 2.51$ 57$
Pond 5 38 CY 2.51$ 96$
Pond 6 36 CY 2.51$ 89$
Pond 7 43 CY 2.51$ 108$
Pond 8 46 CY 2.51$ 115$
Loading Cost 2,813$
Total:297 CY CY 4.28$ 3,557$
Size Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
6" 500 SF 1.09$ 545$ 02 41 16.17 0440
6" REBAR Reinforced 0 SF 0.98$ -$
Total:500 SF 545$
Removal Included with Hauling Cost , below
Transfer Piping on Ground Surface or with Shallow Bury
HDPE Liner Removal
Concrete Pads
REV: 08172020 Page 2 of 4 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
INFRASTUCTURE REMOVAL
Type Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
1/0 & Smaller 0 MLF 15.65$ -$
250 MCM 0 MLF 19.95$ -$
Total:0 MLF -$
Size Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
Barbed Wire 9,000 LF 2.26$ 20,340$ No cost net of salvage
5' Chain Link 2.18$ -$ 02 41 13.60 0600
Total:9,000 LF 20,340$
Item Volume Unit Cost Reference (RS Means Unless Noted Otherwise)
HDPE Liner 297 CY $1.85 /T/Trip 550$ 31 23 23.20 4104 Modified for Proximity to Uintah LF
Concrete 50 CY $1.85 /T/Trip 93$ 31 23 23.20 4104 Modified for Proximity to Uintah LF
Rubble 0 CY $1.85 /T/Trip -$
Dry Wall 0 CY $1.85 /T/Trip -$
Scrap Metal 56 CY $1.85 /T/Trip 103$
Scrap Wood 0 CY $1.85 /T/Trip -$
4" PVC 27 CY $1.85 /T/Trip 50$
6" PVC 0 CY $1.85 /T/Trip -$
10" PVC 0 CY $1.85 /T/Trip -$
Total:429 CY $1.85 /T/Trip**796$ ** 90 Mi-RT
Hauling
Major Electrical Panels, Conduit, Conductor & Grounding
Fencing
REV: 08172020 Page 3 of 4 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
INFRASTUCTURE REMOVAL
Item Unit Weight
Total Weight
(ton)Tipping Fee Cost
Reference (RS Means Unless Noted Otherwise)
HDPE Liner 0.3 lb/sf 144.21 $45 /T $ 6,490 Uintah County Landfill
Concrete 4,050 lb/CY - $45 /T -$
Rubble 1,400 lb/CY - $45 /T -$
Dry Wall 500 lb/CY - $45 /T -$
Scrap Metal 1,000 lb/CY - $45 /T -$
Scrap Wood 300 lb/CY - $45 /T -$
4" PVC 2.0 lb/LF 8.35 $45 /T 376$
6" PVC 3.6 lb/LF - $45 /T -$
10" PVC 7.9 lb/LF - $45 /T -$
Total:152.56 6,865$
Landfill Fees
REV: 08172020 Page 4 of 4 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM BOSPOSAL
EARTHWORK AND GRADING
Location Quantity Unit Unit Price Cost Reference (RS Means Unless Noted Otherwise)
Pond 1 23,900 CY 1.76$ 42,065$ 31 23 16.46 5020
Pond 2 22,303 CY 1.76$ 39,253$
Pond 3 27,509 CY 1.76$ 48,416$
Pond 4 14,309 CY 1.76$ 25,184$
Pond 5 25,376 CY 1.76$ 44,662$
Pond 6 23,385 CY 1.76$ 41,157$
Pond 7 29,006 CY 1.76$ 51,051$
Pond 8 30,976 CY 1.76$ 54,518$
Landfarm 48,000 CY 1.76$ 84,480$
Total 244,765 CY 430,786$
Location Quantity Unit Unit Price Cost Reference (RS Means Unless Noted Otherwise)
Landfarm 0 CY 2.83$ -$ 31 23 16.46 5040
Landfill 0 CY 2.83$ -$
Total 0 -$
Location Quantity Unit Unit Price Cost Reference
Landfarm 0 CY 1.53$ -$ 31 23 16.46 5000
Landfill 0
CY 1.53$ -$
Total 0 -$
Common Earth to be Dozed
Clay Liner to be Moved
Sand & Gravel to be Moved
REV: 08172020 Page 1 of 2 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM BOSPOSAL
EARTHWORK AND GRADING
Location Quantity Unit Unit Price Cost Reference
Pond 1 132,500 SF 0.05$ 6,625$ 31 22 13.20 0280 (modifed for scale)
Pond 2 124,950 SF 0.05$ 6,248$
Pond 3 150,000 SF 0.05$ 7,500$
Pond 4 82,500 SF 0.05$ 4,125$
Pond 5 140,400 SF 0.05$ 7,020$
Pond 6 130,000 SF 0.05$ 6,500$
Pond 7 158,175 SF 0.05$ 7,909$
Pond 8 167,400 SF 0.05$ 8,370$
Landfarm 162,000 SF 0.05$ 8,100$
Other Disturbed Site 2,139,195 SF 0.05$ 106,960$
Total 1,247,925 0.05$ 169,356$
Rough Grading
REV: 08172020 Page 2 of 2 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
REVEGITATION
Location Quantity Unit Price Cost
Reference (RS Means Unless Noted Otherwise)
Pond 1 133 MSF 28.94$ 3,835$ 32 92 19.14 5800*
Pond 2 125 MSF 28.94$ 3,616$
Pond 3 150 MSF 28.94$ 4,341$
Pond 4 83 MSF 28.94$ 2,388$
Pond 5 140 MSF 28.94$ 4,063$
Pond 6 130 MSF 28.94$ 3,762$
Pond 7 158 MSF 28.94$ 4,578$
Pond 8 167 MSF 29.94$ 5,012$
Landfarm 162 MSF 29.94$ 4,850$
Other Disutbed Area 2,139 MSF 28.94$ 61,908$
Total 3,387 MSF 28.94$ 98,353$
*Note:
Hydro Seeding of Native Grass
Rate modified with specific seeding costs from Granite Seed in Lehi, UT
REV: 08172020 Page 1 of 1 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
CLOSURE POST CLOSRE COSTS
Location Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
10 YR $550 /YR 5,500$ ACEC & NSPE Local Rates
Total: 5,500$
Meter Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
10 YR $120 /YR 1,200$ Enviro Equipment, Inc
Total: 1,200$
Labs Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
10 YR $750 /YR 7,500$ America West Analytical Lab
Total: 7,500$
Annual Maintenance Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
9 EA $1,000 /EA 9,000$ 32 91 13.23 Structural Soil Mixing
Total: 9,000$
Location Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
162 MSF $3.30 /MSF 6,415$ 32 91 13.23 6000 Tilling 6" Cost for 12 tillings
Total: 6,415$
Well Inspection & Sampling
Water Quality Meter Rental
Lab Analysis
Grounds Maintenance
Landfarm Tilling
REV: 08172020 Page 1 of 2 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
BRENNAN BOTTOM DISPOSAL
CLOSURE POST CLOSRE COSTS
Monitoring Wells Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
Driller 1 EA $1,200 /EA 1,200$ Boart Longyear
Driller Oversight 1 EA $900 /EA 900$ ACEC & NSPE Local Rates
Total: 2,100$
Location Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
8 EA 1,500$ 12,000$ ACEC & NSPE Local Rates
Total: 12,000$
Location Quantity Unit Price Cost Reference (RS Means Unless Noted Otherwise)
2 EA 2,500$ 5,000$ ACEC & NSPE Local Rates
Total: 5,000$
Total Closure & Post Closure 48,715$
Initial and Final Post Closure Report
Monitoring Well Abandonment
Annual Report
REV: 08172020 Page 2 of 2 KK, llc
Sundry Number: 88084 File: Detailed Site Description
RECEIVED: May. 14, 2018
&ŽƌŝǀŝƐŝŽŶhƐĞKŶůLJ
Compliance Review Completed:
No outstanding compliance
Active violation/compliance matter
Signature:
Comments
&ŝǀĞzĞĂƌΘWtĂƐƚĞDisposal Facility Wermit Renewal Checkůisƚ
WĞƌŵŝƚZĞŶĞǁĂůƉƉůŝĐĂƚŝŽŶ^ƵďŵŝƐƐŝŽŶ
^ƵďŵŝƚĂŶĂƐƐĞƐƐŵĞŶƚŽĨƐŝƚĞƌĞĐůĂŵĂƚŝŽŶƌĞƋƵŝƌĞŵĞŶƚƐĨƌŽŵĂĐĞƌƚŝĨŝĞĚ
ƚŚŝƌĚƉĂƌƚLJĐŽŶƚƌĂĐƚŽƌZϲϰϵͲϵͲϴ͘Ϯ
^ƵďŵŝƚĐůŽƐƵƌĞĐŽƐƚĞƐƚŝŵĂƚĞƐĨƌŽŵĂĐĞƌƚŝĨŝĞĚƚŚŝƌĚƉĂƌƚLJĐŽŶƚƌĂĐƚŽƌ
ZϲϰϵͲϵͲϴ͘Ϯ
WƌŽǀŝĚĞďŽŶĚĂŵŽƵŶƚĂƉƉƌŽǀĞĚďLJƚŚĞŝǀŝƐŝŽŶZϲϰϵͲϵͲϴ
ĞƚĂŝůĞĚ^ŝƚĞĞƐĐƌŝƉƚŝŽŶ
&ƵŶĐƚŝŽŶŽĨƚŚĞǁĂƐƚĞĚŝƐƉŽƐĂůĨĂĐŝůŝƚLJ
ƵƌƌĞŶƚĨĂĐŝůŝƚLJŵĂƉ
^ŝƚĞĚĞƐĐƌŝƉƚŝŽŶƐĂŶŶŽƚĂƚĞĚǁŝƚŚĨĂĐŝůŝƚLJŝŶĨƌĂƐƚƌƵĐƚƵƌĞĂŶĚĂƐƐŽĐŝĂƚĞĚĨƵŶĐƚŝŽŶ
ŽŶƚĂŵŝŶĂƚŝŽŶƐƐĞƐƐŵĞŶƚ
ĞƐĐƌŝƉƚŝŽŶŽĨĞdžŝƐƚŝŶŐĐŽŶƚĂŵŝŶĂƚŝŽŶǁŝƚŚƐĂŵƉůĞƌĞƐƵůƚƐ
WƌŽƉŽƐĞĚŵŽŶŝƚŽƌŝŶŐͬƌĞŵĞĚŝĂƚŝŽŶ
WƌŽƉŽƐĞĚƉƌĂĐƚŝĐĞƐƚŽƉƌĞǀĞŶƚĨƵƌƚŚĞƌĐŽŶƚĂŵŝŶĂƚŝŽŶ
ƋƵŝƉŵĞŶƚƐƐĞƐƐŵĞŶƚ
ĞƐĐƌŝƉƚŝŽŶĂŶĚĂƐƐĞƐƐŵĞŶƚŽĨĞƋƵŝƉŵĞŶƚůŽĐĂƚĞĚĂƚƚŚĞĨĂĐŝůŝƚLJ
ĞƐĐƌŝďĞŝŶĚĞƚĂŝůƐĞƌǀŝĐĞůŝĨĞĨŽƌĞƋƵŝƉŵĞŶƚƵƐĞĚŝŶĨĂĐŝůŝƚLJŽƉĞƌĂƚŝŽŶƐĞƐĐƌŝƉƚŝŽŶŽĨƚĞƐƚŝŶŐ
ĐŽŵƉůĞƚĞĚĨŽƌĞƋƵŝƉŵĞŶƚ;ƚĂŶŬƐ͕ƉŝƉŝŶŐ͕ůŝŶĞƌƐ͕ůĞĂŬĚĞƚĞĐƚŝŽŶĞƋƵŝƉŵĞŶƚ͕ĞǀĂƉŽƌĂƚŝŽŶĨĂŶƐͿ
WƌĂĐƚŝĐĞƐƐƐĞƐƐŵĞŶƚ
ƐƐĞƐƐŵĞŶƚŽĨŵĂŶĂŐĞŵĞŶƚƉƌĂĐƚŝĐĞƐƵƚŝůŝnjĞĚƚŽŽƉĞƌĂƚĞƚŚĞĨĂĐŝůŝƚLJ/ĚĞŶƚŝĨLJĂůƚĞƌŶĂƚŝǀĞ
ƉƌĂĐƚŝĐĞƐǁŚŝĐŚĐŽƵůĚŝŵƉƌŽǀĞŽƉĞƌĂƚŝŽŶƐŽƌƌĞĚƵĐĞƉƌŽďĂďŝůŝƚLJŽĨĨƵƚƵƌĞĐŽŶƚĂŵŝŶĂƚŝŽŶ
Name of &ĂĐŝůŝƚLJOperator:
Name of &ĂĐŝůŝƚLJ͗
>ŽĐĂƚŝŽŶ͗
ĂƚĞ͗
WƌĞƉĂƌĞƌ͗
ĂƚĞ /ŶŝƚŝĂůƐ ĂƚĞ/ŶŝƚŝĂůƐ
ZĞĐĞŝǀĞĚ ZĞǀŝĞǁĞĚ
ZĞǀŝĞǁŽŵƉůĞƚĞĚ͗ƉƉůŝĐĂƚŝŽŶ^ƚĂƚƵƐ͗ WWZKs
&ŽƌŝǀŝƐŝŽŶhƐĞKŶůLJĞůŽǁdŚŝƐ>ŝŶĞ
Brennan Bottoms Disposal
12 Mile Wash
SE SE S19 T6S R21E
08/14/20
KK&E, llc
✔
1FSNJU
.BOBHFS
Digitally signed by Dayne Doucet
Date: 2020.06.19 14:34:20 -06'00'
06/13/18 BTK 08/21/20 DD
06/13/18 BTK 06/19/20 DD
06/20/18 BW 06/13/18 BW $ 1,286,000
Incomplete application received 05/14/2018
Digitally signed by Dayne K Doucet
Date: 2020.08.26 10:26:40 -06'00'✔
01/27/20 ASM Requires removal info for Glen Bench #2-BTK 7/26/2018
Diagram incorrectly labeled- BTK 7/26/2018
06/24/20 ASM Brine water spills not allowed to landfarm-BTK 7/26/2018
History of leak detection demonstrating no spills require
if referenced -BTK 7/26/2018
Landfarm remediation plan submitted -ASM 6/2/2020
01/27/20 ASM
06/24/20 ASM Landfarm samples provided ASM 8-21-2018. Landfarm
and Pond #1 hydrocarbons issued NOV 6/27/2018 with
no resolution- BTK 07/26/2018
Sundry Number: 88084
RECEIVED: May. 14, 2018
/ŶĨƌĂƐƚƌƵĐƚƵƌĞZĞŵŽǀĂůŽƐƚƐ
Contouring or RegradingŽƐƚƐ
SeediŶŐŽƐƚƐ
Notes:
ŽŶƚĂŵŝŶĂƚŝŽŶŽƐƚƐ
ƐƚŝŵĂƚŝŶŐůŽƐƵƌĞŽƐƚĂŶĚŽŶĚŝŶŐǀĂůƵĂƚŝŽŶ
ZĞŵŽǀĂůͬZĞŵĞĚŝĂƚŝŽŶ
^ĂŵƉůŝŶŐ
WŽƐƚĐůŽƐƵƌĞŵŽŶŝƚŽƌŝŶŐ
džƉĞŶƐĞƐƚŽƌĞŵŽǀĞĂůůŝŶĨƌĂƐƚƌƵĐƚƵƌĞĂŶĚĞƋƵŝƉŵĞŶƚ
WƌŽũĞĐƚĞdžƉĞŶƐĞƚŽĐŽŶƚŽƵƌƐŝƚĞďĂĐŬƚŽŽƌŝŐŝŶĂůŐƌĂĚĞ
sŽůƵŵĞƐŽĨŵĂƚĞƌŝĂů
ƋƵŝƉŵĞŶƚĐŽƐƚƐ
>ĂďŽƌĐŽƐƚƐ
DĞƚŚŽĚŽĨƌĞƐĞĞĚŝŶŐ
^ƉĞĐŝĞƐƵƐĞĚĨŽƌƌĞǀĞŐĞƚĂƚŝŽŶ
ĂƚĞ/ŶŝƚŝĂůƐ
ZĞĐĞŝǀĞĚ
Comments
DŽŶŝƚŽƌŝŶŐWƌŽŐƌĂŵ
ĞƚĂŝůĞĚĚĞƐĐƌŝƉƚŝŽŶŽĨŵŽŶŝƚŽƌŝŶŐƉƌŽŐƌĂŵƐŝŶƵƐĞŽƌďĞŝŶŐ
ƉƌŽƉŽƐĞĚ;ǀŝƐƵĂůŝŶƐƉĞĐƚŝŽŶƐŽĨ
ĞƋƵŝƉŵĞŶƚ͕ƉƌĞƐƐƵƌĞƚĞƐƚƐ͕ůĞĂŬĚĞƚĞĐƚŝŽŶƐLJƐƚĞŵƐ͕ǁĂƐƚĞĂĐĐŽƵŶƚĂďŝůŝƚLJ͕ĂƵƚŽŵĂƚĞĚƐLJƐƚĞŵƐ͕
ƉƌŽƉŽƐĞĚƉƌĂĐƚŝĐĞƐǁŚŝĐŚĐĂŶƌĞĚƵĐĞƚŚĞƌŝƐŬŽĨĨƵƚƵƌĞĐŽŶƚĂŵŝŶĂƚŝŽŶͿ
01/27/20 ASM
Lacks detail of what tasks are preformed daily weekly-
BTK 07/26/2018
Cost for Post Closure Monitoring not provided- BTK 7/26
06/20/18 BW $337,520. Are there other cost beyond what was listed in
the provided estimate?
06/20/18 BW $375,540. estimated
06/20/18 BW $473,000 Earthwork
$30,000 Seeding /Post closure cost estimate $30,00006/20/18 BW
3/26/2019 Estimation Closure Costs recommended $1,286,000.00 Unless there are items I am unaware of like heavy metals or such?
Items requiring modifications BTK 07/26/2018
-Corrected-Application contains information for both 12 Mile Wash and Glen Bench facilities: these are separate facilities which require separate renewal applications(6/20/2018-New
application provided)
-Diagram labeled incorrectly
-Description of spills taken to landfarm
-Landfarm sample results provided in renewal application
-Detailed description of daily/weekly monitoring task completed
-Cost estimate of Post Closure Monitoring
-Cost estimate depicting expense to deal with solids in evaporation pits along with more detailed description of cost estimate for Remediation Costs
Sundry Number: 88084
RECEIVED: May. 14, 2018
The Facility shall comply with the reporting and recordkeeping requirements in Utah Admin.
Code § R649-9-11.
6. Modifications:
This Permit only applies to the Facility as it is described in the Application. Any additions to the
Facility or modifications of the waste treatment processes described in the Application are not
allowed and require a permit modification.

7. Enforcement:
The issuance of this permit does not supersede local ordinances, county planning and zoning
requirements, or other permits required to conduct business at the Facility. A copy of this
approval should be kept at the 12 Mile Wash field office, and field personnel shall be aware of
the Conditions of Approval.
8. Approval:
Therefore, having met all the technical permit requirements of Utah Admin. Code §§ R649-9 et
seq., final approval to operate the Facility in accordance with this Permit is hereby granted.

9. Contact Information:
The following are Division of Oil, Gas and Mining contacts and their telephone numbers:
Dayne Doucet, Oil and Gas Permitting Manager: 801-538-5303
Bart Kettle, Interim Deputy Director: 435-820-0862
Ammon McDonald, Environmental Scientist: 801-538-5337

Approved By:
________________________
By: Dayne Doucet
Title: Oil and Gas Permitting Manager
pp y
_______________________________________
D D
Sundry Number: 88084
RECEIVED: May. 14, 2018

Conditions of Approval:

1. Evaporation Facilities

1.1 A minimum of 2 feet of freeboard shall be maintained in the pit(s) at all times, and that a
method of obviously displaying the freeboard shall be devised and implemented. Utah
Admin. Code § R649-9-4.6.4.

1.2 Pit(s) are to be maintained such that hydrocarbons will not collect on the surface.
Hydrocarbon accumulations, other than de minimis quantities, shall be removed within 24
hours. Utah Admin. Code § R649-9-4.6.4.

1.3 Spraying water to accelerate evaporation should be closely monitored. Overspray outside the
lined pit area is a violation. Utah Admin. Code § R649-9-4.9.2.

1.4 The leak detection system must be checked weekly. Any leak must be reported to the
Division immediately, and corrective measures must be taken as directed by the Division.

1.5 The compacted secondary containment berms at the Facility shall be inspected quarterly and
after a major rainstorm or windstorm to ensure integrity. Utah Admin. Code § R649-9-
11.3.2.

1.6 Evaporation ponds are permitted to accept produced water.

2. Landfarms

2.1 This facility is not permitted to accept new material to the existing landfarm.

2.2 Pooling of liquids in the landfarm is prohibited.

2.3 Soils shall be turned regularly, a minimum of once a month.

2.4 Continual progress shall be made with reclaiming the existing landfarm as outlined in the
submitted land farm remediation plan (with the modification that the remediation continues
until the entire volume in the land farm is reclaimed).

FAILURE TO COMPLY WITH THE ABOVE LISTED CONDITIONS OF
APPROVAL MAY RESULT IN CLOSURE OF THE FACILITY.
Sundry Number: 88084
RECEIVED: May. 14, 2018
Jean Sweet <[e-mail]>
Fwd: Brennan Bottom Disposals, LLC. Facilities Operations Update
1 message
Richard Powell <[e-mail]>Thu, Dec 17, 2020 at 5:02 PM
To: Jean Sweet <[e-mail]>
Cc: Bart Kettle <[e-mail]>
Jean,
This should be put in the file of both Brennan Bottom Disposal facilities.

Thanks,
Richard
---------- Forwarded message ---------
From: C.j. Nebeker <[e-mail]>
Date: Thu, Dec 17, 2020 at 4:22 PM
Subject: Brennan Bottom Disposals, LLC. Facilities Operations Update
To: Dayne Doucet <[e-mail]>, Richard Powell <[e-mail]>, Beverly Wiser
<[e-mail]>
--
Richard J Powell, LEHS
Utah Division of Oil, Gas & Mining
Vernal Field Office
318 North Vernal Avenue
Vernal, UT 84078
Phone: [phone]
[e-mail]
BBD Facilities Operations Update_1.PDF
765K
p
EVAP POND #2
SflND
EV*P P 96
BRB4NAN BOTTOM DISPOSAl.
12-MILE WASH FACIliTY
ExS
LNCFD.L #1 &
EVAP POND #1
oasm
EVAP POND #3
[
POND #4
i3kD. DII©4091 W. 3000 S. Roosevelt, UT 84066
December 17, 2020
Mr. Dayne Doucet, Oil & Gas Permitting Manager
Oil & Gas Section
Division of Oil, Gas & Mining (DOGM)
Utah Department of Natural Resources
1594 West North Temple, Suite 1210
Salt Lake City, UT 84114
VIA:Email and US Mail
RE:Facility Operating Update
12-Mile Wash Facility and Glen Bench Facility
Brennan Bottom Disposal. lic
Dear Dayne:
In her November 16, 2020 Email, Bev Wiser suggested that both Brennan Bottom Disposal (BBD) and DOGM
would benefit if BBD were to keep you updated about our operating intentions. The Email suggested that we
should give you additional information to describe which portions of the 12-Mile Wash and Glen Bench facilities
that will continue to operate under DOGM permits and which portions BBD either operates or desires to operate
under Waste Management and Radiation Control (WMRC) permits.
For the BBD 12-Mile Wash Facility
We will continue to operate the E&P Waste Receiving Area, Evaporation Ponds #1 through #8, and the Landfarm
as currently permitted by DOGM.
As far as we can predict we cannot see a big enough produced water market to profitably justify the operation all
eight evaporation ponds. Over the past year we have been considering how many of the ponds are needed for
produced water evaporation and how many could be used for other purposes. We will give you and Richard
Powell a timely notice when we decide how to change the 12-Mile Wash site to be used for operations other than
those now permitted by DOGM.
The Landfill will operate as currently permitted by WMRC. A permit modification application to extend the Landfill
to about 45 feet above the existing berms has been submitted to WMRC.
BRENNAN BOTTOM DISPOSAL
GLEN BENCH FACxLrrY
Mr. Dayne Doucet
December 17, 2020
Page 2
We will provide Financial Assurance in accordance with the current Reclamation Estimate approved by DOGM and
will keep an appropriate Financial Assurance instrument in place with DOGM until the 12-Mile Wash site is used
for purposes that don't require a DOGM permit.
For the BBD Glen Bench Facility
In the near term we will operate the E&P Waste Receiving Area and Evaporation Ponds #1 through #3 as
currently permitted by DOGM.
At Glen Bench we cannot see a big enough produced water market to justify all evaporation ponds. We have
been considering how this facility could be used for other purposes. We will give you and Richard Powell a timely
notice when we decide how to change the Glen Bench site to be used for operations other than those now
permitted by DOGM.
Our first operational change for Glen Bench will be to convert Pond #3 to a landfill. We started that process last
January when we submitted a Permit Application to WMRC to convert Pond 3 to a landfill. The conversion won't
be possible for at least another six months.
We will provide Financial Assurance in accordance with the Reclamation Estimate Update that you have
requested. We will keep an appropriate Financial Assurance instrument in place with DOGM until the Glen Bench
site is used for purposes that don't require a DOGM permit.
I understand that notifying you and others at DOGM of operational changes that we want to make for
facilities that you regulate will be beneficial to us both. Do not hesitate to contact me whenever you have
questions about BBD operations.
Sincer ly,
0 beker, Operations Manager
DOGM Richard Powell BBD: Don Demille KK&E: Kerry Spiroff
Richard Powell Jim Nebeker
Bev Wiser
RECEIVED: Jun. 04, 2021

STATE OF UTAH
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF OIL, GAS, AND MINING 
FORM 9
SUNDRY NOTICES AND REPORTS ON FACILITIES
1. TYPE OF FACILITY
  Waste Facility/Commercial 
5. FACILITY NAME:
 12 Mile Wash 
2. NAME OF OPERATOR:
 Brennan Bottom Disposal 
6. FACILITY NUMBER:
 76 
3. ADDRESS OF OPERATOR:
 4091 West 3000 South , Roosevelt, UT, 84066 
7. PHONE NUMBER:
 435-722-6724 
4. LOCATION OF FACILITY  
  Qtr/Qtr:SW Section: 19 Township: 6S Range: 21E Meridian: S 
COUNTY:
 UINTAH 
STATE:
 UTAH 
11.
CHECK APPROPRIATE BOXES TO INDICATE NATURE OF NOTICE, REPORT, OR OTHER DATA 
TYPE OF SUBMISSION TYPE OF ACTION
    NOTICE OF INTENT 
Approximate date work will start:

    SUBSEQUENT REPORT 
Date of Work Completion:
6/4/2021
    New Facility Construction   
    Repair of Facility   
    Facility Reclamation   
    Facility Status Report   
    Results of Sampling    
    Change to Previous Plans   
    E&P Waste Disposal Facility Permit   
    Other   
12. DESCRIBE PROPOSED OR COMPLETED OPERATIONS. Clearly show all pertinent details including dates, depths, volumes, etc.
 Landfarm Soil Test Results On April 7, 2021, Mr. Ken Walter, of Walter
Environmental, provided the attached report on soil testing and sampling on the 12 Mile
Wash Land Farm. Based on the the attached test results Brennan Bottom would like to
remove the top 2 feet of treated soil and move it to a designated stock pile area within
the 12 Mile Wash facility. The attachment is an abridged version of a 100 page
document. Please advise if you wish to receive the full 100 pages. Should you have any
questions, do not hesitate to contact CJ Nebeker, Kari Campbell (435-722-9997) or
Kerry Spiroff (cell: 801-712-8677).
NAME (PLEASE PRINT)  
 Kerry Spiroff  
PHONE NUMBER
801-712-8677 
TITLE
 PE, SE 
SIGNATURE
 N/A 
DATE
 6/4/2021 
Please Review Attached Conditions
June 24, 2021
Sundry Number: 110451 Facility Number: 76
RECEIVED: Jun. 24, 2021

The Utah Division of Oil, Gas, and Mining
- State of Utah
- Department of Natural Resources
Electronic Permitting System - Sundry Notices
Sundry Conditions For Facility Number 76
No materials shall be removed from the landfarm until they met Division clean-up standards, and in this case, the
DRO constituents shall be below 2,000ppm.
Sundry Number: 110451 Facility Number: 76
RECEIVED: Jun. 04, 2021
P.O. Box 3967
Grand Junction, Colorado 81502
phone: [phone]
toll free: [phone]
fax: [phone]
April 7, 2021
Brennan Bottom Disposal, LLC
Attn.: Mr. CJ Nebeker
4091 West 300 South
Roosevelt, Utah 84066
Subject: Brennan Bottom #1 Land Farm Status Summary
12 Mile Wash Road
Uinta County, Utah
Gentlemen,
At your request, Walter Environmental & Engineering Group, Inc. (Walter) was retained by
Brennan Bottom Disposal, LLC to assist in the completion of environmental assessment tasks at the
above-referenced site south of Vernal, Utah (Facility). These tasks included the collection of soil
samples for laboratory testing from the land farm, and providing the professional opinions regarding
the subsequent laboratory results. The purpose of this letter is to summarize these activities and
opinions.
Background
The Facility’s existing land farm at 12 Mile Wash encompasses an estimated area of 380 x 480 ft.
Walter understands that the land farm has operated for approximately 11 years and is estimated to
average 10 feet in depth. The material in the land farm is believed to be oilfield-generated drilling
mud and soil. The amount of this material currently in place in the land farm is estimated to be
approximately 70,000 yards3. On October 1, 2018, the Facility reportedly stopped receiving material
into the land farm due to a lack of available capacity.
Since August 2018, Brennan Bottom Disposal, LLC has had five land-farmed soil characterization
efforts completed at the Facility. The primary focus of these sampling and testing efforts was to
determine whether the soil met the Utah Division of Oil, Gas and Mining (DOGM) Cleanup Levels
as identified in DOGM’s August 2017 Guidance Document. In addition, the April 30, 2020
sampling effort was performed to estimate the suitability of the existing land farm material for
remediation by land-farming methods. The suitability criteria are spelled out in the publication
“How To Evaluate Alternative Cleanup Technologies For Underground Storage Tank Sites, A Guide
For Corrective Action Plan Reviewers, Chapter V, Landfarming; EPA 510-B-17-003, October
1994.”
In addition, beginning in May, 2020 Brennan Bottom Disposal, LLC has initiated a remedial effort
that included the “working” and addition of amendments to the upper few feet of the land-farmed
soil. These efforts are summarized in the paragraphs that follow.
Sundry Number: 110451 Facility Number: 76
RECEIVED: Jun. 04, 2021
Page 2 of 5
P.O. Box 3967, Grand Junction, CO 81502
phone: [phone] fax: [phone]
August, 20 2018 Land-Farm Sampling
Snowshoe Engineering Company collected a total of 7 soil samples from 5 locations at the land farm
(August 21, 2018 Report, Attachment A). The samples were collected from depths ranging from 3
to 10 feet below the surface of the land farm. Table One summarizes the laboratory results, and
compares the concentrations to DOGM’s Cleanup Levels. Walter makes the reasonable assumption
that this facility meets the Level II Sensitivity Cleanup Ranking Criteria.
The “take-away” from the tabular presentation of the laboratory data are generally:
• shallower soils contain lower concentrations of light-end (BTEX) hydrocarbons than
the deeper samples,
• elevated concentrations of diesel-range organics (DRO) were present in all the
samples,
• salinity concentrations were at or above DOGM Cleanup Levels in all the samples.
April 8, 2020 Walter Land-Farm Sampling
From Walter’s April 14, 2020 report (Attachment B):
“Field Investigation
On April 8, 2020, Walter representative Ken Walter arrived at the Facility at approximately 9:00am,
mountain daylight savings time. Utah Department of Natural Resources (DNR), Division of Oil,
Gas, and Mining (DOGM) representative Richard Powell, and Brennan Bottom Disposal, LLC
consultant Kerry Spiroff were also in attendance to observe the field investigation. The goal of the
field investigation was to collect representative soil samples and submit them for laboratory analysis
in general conformance with DOGM’s August 2017 “Cleanup Level Selection Guidance Document
(Oil & Gas Conservation General Rules R649-3 Drilling and Operating Practices R649-9 Waste
Management and Disposal).”
The subsurface was accessed by a Facility-provided backhoe and operator. The land-farm sample
locations were specified to mirror those locations samples by Snowshoe Engineering Company from
their August 2018 effort (Attachment A). Sample depths for Walter’s field investigation were
specified by you to be 5 feet and 10 feet below ground surface. Walter’s location-naming
convention was designed to generally mirror the August 2018 effort. However, the 2018 TP-1
location is now named TP-1A, etc. The excavation and sampling effort began at approximately
9:30am, and terminated at approximately 11:30am. The test pits were subsequently backfilled the
same day.
Walter observed the soil in the excavations to be sandy clay and clayey sand. Observed were
interbedded layers of light-brown soil, and black hydrocarbon-affected (based on color and odor)
soil to the depth of the excavations.
Sundry Number: 110451 Facility Number: 76
RECEIVED: Jun. 04, 2021
Page 3 of 5
P.O. Box 3967, Grand Junction, CO 81502
phone: [phone] fax: [phone]
Investigation Results
The laboratory results (Table One) indicate that the land farm samples generally exceeded Utah
Cleanup Levels for:
Benzene
Toluene
Xylenes
Gasoline Range Organic Compounds
Diesel Range Organic Compounds
Although the salt concentrations exceeded the Cleanup Levels, the August 2017 DOGM document
states:
“If natural background soil characteristics show poorer quality than depicted by these limits,
or if higher levels can be demonstrated to be consistent with the intended land use, then
these limits can be exceeded.”
Walter reviewed the Natural Resources Conservation Services (NRCS) Custom Soils Report the
Facility (Attachment C). The predominant soil type in the vicinity of the land farm is illustrated to
be Hideout-Badland-Rock Outcrop Complex and Turzo Loam. The natural, background electrical
conductivity (EC) of these soils are reported by NRCS to be 4.0 to 20.0 mmho/cm. The land farm
samples laboratory results fall within this natural, background, range. The measured sodium
adsorption ratio (SAR) of 9 of the 10 land farm samples also fall within the expected natural
background range.
Based upon these results, Walter believes that “...natural background soil characteristics show poorer
quality than depicted by these limits...”
April 30, 2020 Walter Land Farm Sampling
Walter completed another round of land-farm soil on April 30, 2020. As discussed in the excerpt
below, the primary goal of this event was to estimate the shallow land-farm soil’s suitability for
remediation by land farming. Walter’s June 9, 2020 summary report (Attachment C) states:
“Investigation Goal
The primary goal of Walter’s investigation is to estimate the suitability of the existing land farm
material for remediation by land farming methods. The suitability criteria are spelled out in the
publication “How To Evaluate Alternative Cleanup Technologies For Underground Storage Tank
Sites, A Guide For Corrective Action Plan Reviewers, Chapter V, Landfarming; EPA 510-B-17-003,
October 1994.”
Sundry Number: 110451 Facility Number: 76
RECEIVED: Jun. 04, 2021
Page 4 of 5
P.O. Box 3967, Grand Junction, CO 81502
phone: [phone] fax: [phone]
“Summary
The primary goal of Walter’s investigation was to estimate the suitability of the existing land farm
material for remediation by land farming methods. The suitability criteria are spelled out in a 1994
EPA publication (referenced above). The investigation results are summarized:
Microbial Population Density - Favorable Land Farming Conditions
Soil pH - High, but Still Favorable
Moisture Content - Dryer than Recommended
Nutrient Concentrations - Nitrogen and Phosphorous Deficient
Soil Texture - More Clayey than Optimal
Volatility - Gasoline and Diesel-Range Components are Favorable
Chemical Structure - Gasoline and Diesel-Range Components are Favorable
Concentration And Toxicity - Not Favorable
Although some of the analyses summarized above indicate unfavorable site conditions, key
parameters suggest that hydrocarbon degradation is currently occurring in the shallow regime. The
favorable microbial population density results and the reduced gasoline-range concentrations (in the
shallow material) support this opinion. As such, Walter recommends the consideration of more
aggressive assessment, maintenance, or monitoring of the land farm be implemented to achieve the
site cleanup goals.”
Land-Farm Maintenance and Remediation
In response to Walter’s April 2020 investigations, Brennan Bottom Disposal, LLC initiated an
aggressive maintenance and remediation program beginning in late May 2020. The goals were to
enhance the natural hydrocarbon degradation processes by tilling and adding amendments to the
upper soil horizon. These tasks were recorded in the attached logs (Attachment D).
Subsequent Land-Farm Sampling
Two additional rounds of soil sampling and analysis have been conducted subsequent to the
initiation of the aggressive land-farm maintenance and remediation program:
August 7, 2020
January 28, 2021
Laboratory correspondence are provided as Attachment E and F, respectively. These laboratory data
are also summarized in Table One, attached. In general, the laboratory data suggest that the upper
~2 feet of land-farmed soil now meet the DOGM Cleanup Levels (Level II Sensitivity Cleanup
Ranking Criteria) for light-end (BTEX and GRO) petroleum hydrocarbons. Diesel and oil-range
hydrocarbons concentrations, and salinity parameters do not meet the DOGM Cleanup Levels.
These results are not unexpected as diesel and oil-range hydrocarbons, and salts are not as
conductive to remediation by land farming.
Sundry Number: 110451 Facility Number: 76
RECEIVED: Jun. 04, 2021
Page 5 of 5
P.O. Box 3967, Grand Junction, CO 81502
phone: [phone] fax: [phone]
However, as stated in Walter’s April 14, 2020 report (Attachment B):
“The natural, background electrical conductivity (EC) of these soils are reported by NRCS to be 4.0
to 20.0 mmho/cm. The land farm samples laboratory results fall within this natural, background,
range. The measured sodium adsorption ratio (SAR) of 9 of the 10 land farm samples also fall
within the expected natural background range.”
Proposed Next Actions
Walter understands that you have had conversations with DOGM representatives about reasonable
next actions. These conversations have suggested that rather than focusing on the continued
remediation of the upper ~2 feet of land-farmed soil, and likely realizing only modest progress, this
upper layer could be removed from the land farm, and stockpiled onsite. This would expose deeper
(more affected) soils, and subsequent remedial efforts would target this deeper layer. Walter agrees
that this approach would provide considerably more “bang for the buck” as more cleanup progress
is expected by working the deeper more-affected soils. Walter recommends that Brennan Bottom
Disposal, LLC identify a reasonable location and/or use for the upper ~2 feet of land farmed soil to
propose to the DOGM. Once the upper material is removed, Brennan Bottom Disposal, LLC should
continue working, adding amendments, and periodically testing the newly-exposed material.
Thank you for the opportunity to be of assistance. If you have any questions, please do not hesitate
to call.
Sincerely,
Walter Environmental & Engineering Group, Inc.
Kenneth L. Walter
B.A., M.S.
Professional Geologist, Colorado
ASTM Environmental Professional
Recognized Environmental Professional, No. 58, Colorado
Attachments
C:\TWG\Clients\Active\BrennanBottom\BB#1 TwelveMileWashRd\LandFarm\March2021StatusSummaryLetter\BB#1LandfarmStatusSumLetter-v040721-kw.wpd April 7, 2021 (8:26am)
Sundry Number: 110451 Facility Number: 76
RECEIVED: Jun. 04, 2021
Table One
Brennan Bottom #1 Landfarm - Soil-Sample Laboratory Results
Version: March 22, 2021
Ethyl-Total
Compound Benzene Toluene benzene Xylenes Naphthalene GRO DRO ORO EC ESP SAR
Cleanup Levels*0.9 25 23 142 51 1,000 2,000 7,000 4 15%12
Units ppm ppm ppm ppm ppm ppm ppm ppm mmho/cm percent ratio
Location Sample Date Location Depth (ft)
Landfarm 8/20/2018 TP-1 7 1.71 26.4 7.57 147 5.51 843 13,700 3,920 6.120 13 10.6
Landfarm 8/20/2018 TP-2 6.5 0.977 2.5 1.69 22.8 2.41 456 10,800 2,730 6.780 17 14.4
Landfarm 8/20/2018 TP-3 3 0.521 7.01 2.5 33.3 4.1 282 18,300 4,580 6.340 15 13.1
Landfarm 8/20/2018 TP-3 10 4.91 57.3 11.4 364 30 1,780 17,300 3,230 7.580 21 18.4
Landfarm 8/20/2018 TP-4 4 0.418 7.22 4.49 77.7 7.7 552 12,000 3,410 5.560 14 12.2
Landfarm 8/20/2018 TP-4 9.5 16.6 9.55 35.4 663 35.8 2,740 15,600 2,660 7.210 33 34.4
Landfarm 8/20/2018 TP-5 5.5 0.298 3.25 2.01 -4.77 374 13,600 2,980 3.990 14 12
Landfarm 4/8/2020 TP-1A 5 3.71 56.5 13.2 273 15.8 2,420 18,200 3,290 5.790 16 13.5
Landfarm 4/8/2020 TP-1A 10 2.87 44.4 11.5 211 16.4 1,740 17,300 3,240 8.690 14 11.6
Landfarm 4/8/2020 TP-2A 5 2.43 33.5 9.02 156 13.1 1,620 13,800 3,030 7.680 26 24.7
Landfarm 4/8/2020 TP-2A 10 2.94 39.2 12.8 205 11.7 1,590 14,300 3,330 5.750 25 23.0
Landfarm 4/8/2020 TP-3A 5 7.07 89.4 21.8 454 21.8 3,100 31,700 6,020 8.810 15 12.7
Landfarm 4/8/2020 TP-3A 10 5.33 60.5 18.8 376 25.4 2,630 23,800 3,880 9.120 16 13.9
Landfarm 4/8/2020 TP-4A 5 0.985 J 9.36 3.51 60.2 9.37 939 20,300 5,140 8.930 18 16.0
Landfarm 4/8/2020 TP-4A 10 10.0 155 38.5 763 33.5 4,580 20,000 3,340 5.040 31 30.7
Landfarm 4/8/2020 TP-5A 5 3.92 42.6 16.1 261 21.4 2,370 21,900 4,370 4.410 28 27.8
Landfarm 4/8/2020 TP-5A 10 16.6 151 42.8 702 29.9 4,290 28,400 5,420 7.050 29 28.2
Landfarm 4/30/2020 TP-1B 0-2 <0.569 6.22 2.81 26.3 2.55 464 40,500 9,750 5.690 20 17.8
Landfarm 4/30/2020 TP-2B 0-2 0.126 2.92 1.42 22.1 3.52 282 27,300 7,000 6.840 13 11.3
Landfarm 4/30/2020 TP-3B 0-2 3.03 39.5 8.86 115 9.18 1,190 24,900 5,770 6.790 18 15.3
Landfarm 4/30/2020 TP-4B 0-2 <0.0515 0.307 0.342 4.35 1.04 94.0 25,200 6,370 8.830 13 10.7
Landfarm 4/30/2020 TP-5B 0-2 0.921 16.0 5.24 65.7 5.47 825 23,800 6,110 7.140 14 11.8
Avg.571 28,340 7,000 7.06 15.6 13.4
Landfarm 8/7/2020 NW (TP-1)0.5-1.0 <0.0516 0.171 0.139 1.57 1.46 52.6 26,600 -10.700 16 14.0
Landfarm 8/7/2020 NE (TP-2)0.5-1.0 <0.0520 1.29 0.653 10.4 3.69 111.0 36,100 -11.800 17 14.6
Landfarm 8/7/2020 C (TP-3)0.5-1.0 <0.0517 0.605 0.401 6.39 2.79 93.4 31,600 -8.740 17 14.4
Landfarm 8/7/2020 SW (TP-4)0.5-1.0 <0.0517 <0.103 <0.103 0.539 0.857 48.2 25,100 -9.250 15 12.6
Landfarm 8/7/2020 SE (TP-5)0.5-1.0 <0.0519 0.798 0.421 7.54 2.70 84.1 34,800 -10.900 15 13.0
Avg.78 30,840 -10.28 16.0 13.7
Landfarm 1/28/2021 BB1-NW (TP-1)0.5-1.0 <0.0539 <0.108 <0.108 0.259 0.432 19.5 32,000 10,800 2.980 15 12.8
Landfarm 1/28/2021 BB1-NE (TP-2)0.5-1.0 <0.0559 <0.112 <0.112 0.334 0.679 19.9 31,500 10,600 6.610 15 13.0
Landfarm 1/28/2021 BB1-C (TP-3)0.5-1.0 <0.0559 <0.112 <0.112 0.324 0.704 20.0 21,200 6,470 7.690 14 12.1
Landfarm 1/28/2021 BB1-SW (TP-4)0.5-1.0 <0.0549 0.334 0.160 3.11 2.03 77.1 19,800 5,540 2.210 14 11.5
Landfarm 1/28/2021 BB1-SE (TP-5)0.5-1.0 <0.0596 0.184 <0.119 0.966 0.990 29.2 23,800 7,080 8.680 14 11.7
Avg.33 25,660 8,098 5.63 14.4 12.2
Notes:
Cleanup Levels * - Utah DOGM August 2017 Guidance
Bolded value exceeds DOGM Cleanup Level.
C:\TWG\Clients\Active\BrennanBottom\BB#1 TwelveMileWashRd\MasterLabSummaryTables\[SoilLabSummaryTables-022221-kw.xlsx]Landfarm-Monitoring
March 22, 2021 9:09:45 AM
Sundry Number: 110451 Facility Number: 76