The URL can be used to link to this page

Home My WebLink AboutDSHW-2024-009352BRENNAN BOTTOM DISPOSAL - GLEN BENCH FACILITY DISPOSAL: 27545 S COYOTE WASH RD- VERNAL OFFICE: 4091 W 3000S – ROOSEVELT UT 84066 Rev 20240924 Temporary Permit Application for Brennan Bottom Disposal, llc BBD Glen Bench 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 170 Acres occupying NW/4 and NW/4 of NW/4 of SW/4 of Section 9 T 9S, R 22E, SLB&M Uintah County, Utah 1 of 19 Utah Solid Waste Program Temporary Permit Application for Brennan Bottom Disposal llc Exploration & Production Waste Disposal Glen Bench Facility 27545 South Coyote Wash Rd, Vernal, Utah Rev 20240924 TABLE OF CONTENTS A.Introduction and Narrative B.Solid Waste Temporary Permit Application Form C.Attachments 1. Facility Map 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 19 Utah Solid Waste Program Temporary Permit Application for Brennan Bottom Disposal llc Exploration & Production Waste Disposal Glen Bench Facility 27545 South Coyote 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 Glen Bench 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 27.7 miles south, southeast of Vernal, Utah and 2-miles east of the White River. The address of the Facility is: 27545 South Coyote Wash Rd Vernal, Utah 84078-8524 3 of 19 Utah Solid Waste Program Temporary Permit Application for Brennan Bottom Disposal llc Exploration & Production Waste Disposal Glen Bench Facility 27545 South Coyote Wash Rd, Vernal, Utah Rev 20240924 B. Solid Waste Temporary Permit Application Form 4 of 19 1 Division of Waste Management and Radiation Control Solid Waste Management Program Mailing Address Office Location Phone (801) 536-0200 P.O. Box 144880 195 North 1950 West Fax (801) 536-0222 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 19 2 Exploration and Production Waste Facility Temporary Permit Application Form I.Facility Name and Location Name of Facility Brennan Bottom Disposal Glen Bench Facility Facility Address (Street or Directions to Facility) 27545 South Coyote Wash Rd County Uintah City. Mountain Fuel Bridge (As listed by Uintah County Assessor) Zip Code 84078-8524 Telephone 435-722-9997 Township 9S, SLB&M Range 22E, SLB&M Section 9 Quarter Section NW & SW Quarter/Quarter Section NW-all & NW of SW Main Gate Latitude: N40.056628° Longitude: W109.445612° II.Existing E&P Facilities ☐Open Landfarm Cell(s) ☒Evaporation Pond(s) Number of Open Landfarm Cells: 0 Number of Evaporation Ponds: 3 III.Facilities to be Permitted by DWMRC409 ☐Landfill Cell(s) ☒Surface Impoundment(s) Number of Landfill Cells:0 Number of Surface Impoundments: 3 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 19 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 cjnebeker@yahoo.com Alternative Telephone (cell phone or other) (435) 823-1144 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: 170.0 acres Disposal Area: 33.0 acres total Comprised of 32.2 Acre Evap Pond area & 0.8 Acre Operating Space 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 19 Utah Solid Waste Program Temporary Permit Application for Brennan Bottom Disposal llc Exploration & Production Waste Disposal Glen Bench Facility 27545 South Coyote Wash Rd, Vernal, Utah Rev 20240925 C Attachments 8 of 19 Utah Solid Waste Program Temporary Permit Application for Brennan Bottom Disposal llc Exploration & Production Waste Disposal Glen Bench Facility 27545 South Coyote 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 9 of 19 UINTAH COUNTY, UTAH 0 092424 KJS INITIAL ISSUE REV DATE BY DESCRIPTION SCALE: 1" = 400 FT LOCATION PROJECT TITLE BRENNAN BOTTOM GLEN BENCH DISPOSAL NO.civil o structural o wastewater o engineering K K & E, llc BINDING EDGE S-001 LOCATION - SOLID WASTE TEMPORARY PERMIT 3 APRIL 2020 PHOTOGRAPHY 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 EERNOTES 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 19 Utah Solid Waste Program Temporary Permit Application for Brennan Bottom Disposal llc Exploration & Production Waste Disposal Glen Bench Facility 27545 South Coyote Wash Rd, Vernal, Utah Rev 20240925 ATTACHMENT 2-a DOGM PERMIT 11 of 19 1594 West North Temple, Suite 1210 PO Box 145801 Salt Lake City, UT 84114-5801 Telephone (801) 538-5340 www.ogm.utah.gov State of Utah SPENCER J. COX Governor DEIDRE M. HENDERSON Lieutenant Governor Permit to Operate ******************** Facility Name:Glen Bench Facility Type: Commercial Waste Disposal Facility Location: Section 9, Township 9S, Range 22E County:Uintah Approval Date:June 7, 2022 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 5/27/2022 and received by the Division on 6/1/2022, (“Application”). The Facility shall operate in accordance with the best management practices described in the Application. Department of Natural Resources Division of Oil, Gas and Mining BRIAN C. STEED Executive Director JOHN R BAZA Division Director DEIDRE M. HENDERSON 12 of 19 1594 West North Temple, Suite 1210 PO Box 145801 Salt Lake City, UT 84114-5801 Telephone (801) 538-5340 www.ogm.utah.gov 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: 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 Glen Bench 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: 385-235-0952 Bart Kettle, Deputy Director: 435-820-0862 Ammon McDonald, Field Operations Manager: 801-538-5337 Approved By: ________________________ By: Dayne Doucet Title: Oil and Gas Permitting Manager 13 of 19 1594 West North Temple, Suite 1210 PO Box 145801 Salt Lake City, UT 84114-5801 Telephone (801) 538-5340 www.ogm.utah.gov 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. FAILURE TO COMPLY WITH THE ABOVE LISTED CONDITIONS OF APPROVAL MAY RESULT IN CLOSURE OF THE FACILITY. 14 of 19 15 of 19 16 of 19 Utah Solid Waste Program Temporary Permit Application for Brennan Bottom Disposal llc Exploration & Production Waste Disposal Glen Bench Facility 27545 South Coyote Wash Rd, Vernal, Utah Rev 20240925 ATTACHMENT 2-c DOGM Bonding (Financial Assurance) DOGM database contains the following listing for the Glen Bench Facility. Guarantor: Bond Safeguard Insurance Company (10118) Bond Number Bond Type Bond Status Bond Purpose Bond Instrument BSIC5044327 Individual Active Facility Bond Surety Bond Facility Name Operator Name Facility Type Facility Status Bonding Amount Glen Bench Brennan Bottom Disposal Waste Facility/Commercial Active $932,000 Facility bonding amounts are also referenced in attached DOGM permitting documents. 19 of 19 RECEIVED: Sep. 28, 2022 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: Glen Bench 2. NAME OF OPERATOR: Brennan Bottom Disposal 6. FACILITY NUMBER: 75 3. ADDRESS OF OPERATOR: 4091 West 3000 South , Roosevelt, UT, 84066 7. PHONE NUMBER: 435-722-6724 4. LOCATION OF FACILITY Qtr/Qtr:NWNW Section: 9 Township: 9S Range: 22E 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: 10/17/2022 PREVIOUSLY APPROVED SUNDRY 117152 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 Add HDPE Liner to existing tank 12. DESCRIBE PROPOSED OR COMPLETED OPERATIONS. Clearly show all pertinent details including dates, depths, volumes, etc. This submittal requests modifications to the DOGM Approved Operating Permit dated June 7, 2022. Changes are made to both the equipment and process approved for the existing permit. Background- The existing 5,000-barrel concrete Headworks tank was constructed without a secondary liner so it does not meet current DOGM rules requiring Exploration and Production waste tanks to have primary and secondary containment. Adding an HDPE primary liner and leak detection sumps allows the existing concrete tank to be used for oil/water/solids decanting and separation. Equipment Change- This Permit Modification requests DOGM approval to line the Headworks tank and add leak detection sumps to the interior of the Headworks Tank. Process Change- The HDPE-lined Headworks tank will supplement the decanting process currently provided by two-600 barrel frac tanks. NAME (PLEASE PRINT) Kerry Spiroff PHONE NUMBER 801-712-8677 TITLE PE, SE SIGNATURE N/A DATE 9/28/2022 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 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: Glen Bench 2. NAME OF OPERATOR: Brennan Bottom Disposal 6. FACILITY NUMBER: 75 3. ADDRESS OF OPERATOR: 4091 West 3000 South , Roosevelt, UT, 84066 7. PHONE NUMBER: 435-722-6724 4. LOCATION OF FACILITY Qtr/Qtr:NWNW Section: 9 Township: 9S Range: 22E 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: 10/17/2022 PREVIOUSLY APPROVED SUNDRY 117152 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 Add HDPE Liner to existing tank 12. DESCRIBE PROPOSED OR COMPLETED OPERATIONS. Clearly show all pertinent details including dates, depths, volumes, etc. This submittal requests modifications to the DOGM Approved Operating Permit dated June 7, 2022. Changes are made to both the equipment and process approved for the existing permit. Background- The existing 5,000-barrel concrete Headworks tank was constructed without a secondary liner so it does not meet current DOGM rules requiring Exploration and Production waste tanks to have primary and secondary containment. Adding an HDPE primary liner and leak detection sumps allows the existing concrete tank to be used for oil/water/solids decanting and separation. Equipment Change- This Permit Modification requests DOGM approval to line the Headworks tank and add leak detection sumps to the interior of the Headworks Tank. Process Change- The HDPE-lined Headworks tank will supplement the decanting process currently provided by two-600 barrel frac tanks. NAME (PLEASE PRINT) Kerry Spiroff PHONE NUMBER 801-712-8677 TITLE PE, SE SIGNATURE N/A DATE 9/28/2022 Please Review Attached Conditions December 01, 2022 Sundry Number: 119373 Facility Number: 75 RECEIVED: Dec. 01, 2022 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 75 LLDPE material; pipe boots needed for the three equalization valves and four internal leak detection sumps, stainless battens to accommodate equalization valve pipe boots, add 200 ml geo-composite drain material covering the bottom of each headworks cell, pipe boot material will need to be changed to go along with the LLDPE liner material. Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM DISPOSAL - GLEN BENCH FACILITY DISPOSAL: 27545 S COYOTE WASH RD- VERNAL OFFICE: 4092 W 3000S – ROOSEVELT UT 84066 Rev 20220915 Exploration and Production Waste Disposal Facility Request to Modify Existing Permit (Dated: June 07,2022) For Operating Existing Offload Area, Decanting Tanks and Evaporation Pond No. 1 for Brennan Bottom Disposal, llc Glen Bench E&P Waste Disposal Facility Permit Modification Presented To: State of Utah Department of Natural Resources Division of Oil, Gas and Mining Oil and Gas Program Prepared by: KK&E, llc 9706 Buttonwood Dr Sandy, UT 84092 Revision 2 September 25, 2022 Property Location: Approximately 16.5 Acres situate in N/2 of NW/4 of Section 9 T 9S, R 22E, SLB&M Uintah County, Utah Page 001 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 1 | Page of 16 Note: This document requests modifications to the DOGM Approved Operating Permit (Approved Permit), dated June 7, 2022. This Operating Permit Modification Request (Request) is formatted the same as Approved Permit. Those portions of the Approved Permit for which changes are sought are underlined. TABLE OF CONTENTS A.Introduction and Narrative -P-3 B.Site Description and Assessment and Closure and Post Closure Cost Estimate -P-4 1.Commercial Status -P-4 2.Description and Assessment of Facility Components and Conditions -P-4 a.Site Description -P-4 b.Previous Disposal Configurations Proposed and Permitted for the Parcel -P-7 c.Site Contamination Evaluation -P-8 d.Previous Waste Disposal Design Configurations Proposed and/or permitted on the Parcel –P-10 e.Status of Facility after February 2021 -P-11 f.Assessment of Proposed Site Operations and Equipment -P-11 g.Proposed Monitoring Program -P-12 3.Closure Cost and Bonding Evaluation -P-13 a.Contamination Evaluation -P-13 b.Remediation of E&P Waste Contamination -P-14 c.Site Closure Evaluation Scope of Work -P-15 d.Infrastructure Removal Scope of Work -P-15 e.Seeding and Revegetation Scope of Work -P-15 f.Initial Closure Monitoring Report –P-16 g.Post Closure Monitoring Scope of Work -P-16 4.Observations and Recommendations -P-16 C.Contact Information -P-16 1.Operator and Facility Manager -P-16 2. Engineer -P-16 3. Sampling/Testing Supervisor -P-16 Page 002 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 2 | Page of 16 D.Attachments 1.Attachment 1 – Maps and drawings 2.Attachment 2 – Third Party Closure Cost Estimate 3.Attachment 3 – Terms of February 17, 2021 Facility Deactivation THIS ATTACHMENT IS UNCHANGED FROM PREVIOUSLY APPROVED PERMIT 4.Attachment 4 – Site Sensitivity Level Evaluation THIS ATTACHMENT IS UNCHANGED FROM PREVIOUSLY APPROVED PERMIT 5.Attachment 5 – Offload Area Soil Sampling and Analysis THIS ATTACHMENT IS UNCHANGED FROM PREVIOUSLY APPROVED PERMIT 6.Attachment 6 – Certification of Substantial Completion THIS ATTACHMENT IS UNCHANGED FROM PREVIOUSLY APPROVED PERMIT Page 003 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 3 | Page of 16 A. Introduction and Description of Intent Brennan Bottom Disposal, llc (BBD) submits this Request for its Glen Bench E&P Waste Disposal Facility (Facility) in accordance with the requirements of Utah Administrative Code (UAC), Title R649, Rule 9, Waste Management and Disposal. This Application includes an assessment of site reclamation requirements and closure cost estimates compiled by KK&E, llc, a third-party contractor. BBD submits this Request to change the process and equipment approved to be used in the DOGM Operating Permit dated June 7, 2022. The Facility is intended to receive, separate and naturally evaporate the water content of produced water, natural gas liquids (NGL), other Exploration and Production (E&P) wastes and other wastes as may be permitted by Title 649. The Facility is in Uintah County about 27.7 miles south, southeast of Vernal, Utah and 2-miles east of the White River. Facility address is: 27545 South Coyote Wash Rd Vernal, Utah 84078-8524 Page 004 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 4 | Page of 16 B. Commercial Designation, Site Description and Assessment and Closure and Post Closure Cost Estimate The following narrative addresses statutory requirements for the Request as described in the 2017 DOGM guidance document, Five Year E&P Waste Disposal Facility Permit Renewals and Utah Administrative Code (UAC) and UAC Title R649, Rule 9. 1. Commercial Status BBD acknowledges that it intends to operate the Facility as a “Commercial Disposal Facility” as defined by UAC Title 649, Rule1. 2. Description and Assessment of Existing Conditions and Waste Handling Process a. Site Description. i. Location The Facility will occupy an approximately 16.5-acre portion of a 170-acre parcel (Parcel) owned in fee by BBD. The Facility is located in the northerly 10% of the Parcel. The Parcel itself occupies the NW/4 and NW/4 of NW/4 of SW/4 of Section 9, T 6S, R 22E, SLB&M, Uintah County, Utah. Its location is described in Article A, above, and shown on drawing no. S-001 in Attachment 1. ii. Facility Drainage, Geology and Vegetation - Facility is located in the Lower Coyote Wash Drainage Basin. Coyote Wash is an ephemeral drainage without known springs, seeps or other surface watercourses or impoundments. Rain and snow melt drain through this normally dry wash to its confluence with the White River, located approximately two miles down drainage to the west. - Surficial Geology is a combination weathered Unita Formation material and alluvial and eolian deposits therefrom. The unconsolidated layer consists of weathered Eocene Epoch, Uinta Formation, Member B in the north portion of the Parcel and mixed alluvium and eolian deposits from the more recent Holocene Epoch on the southern portion of the Parcel. This geology was created from Lake Uinta deposits that are nominally thousands of feet thick in the Uintah Basin. Soil in the proposed operating area is classified as “Badlands-Tipperary” by the US Department of Agriculture Natural Resources Conservation Service and is described as moderately sloping barren land dissected by many intermittent drainage channels. It is comprised of soft geologic materials of the Duchesne River, Mancos, and Uinta formations. Potential for runoff is very high and erosion is active. Uinta Formation Member B consists of light-gray, light-greenish-gray, light-brown, and light-purple mudstone and claystone with interbeds of greenish-gray, yellow, and brown Page 005 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 5 | Page of 16 fine-grained sandstone. It contains minor conglomerate and tuffaceous beds and forms nonresistant slopes and thin, but erosion-resistant B Horizon ledges. Alluvial and Eolian material is unconsolidated and consists of erosional and depositional mud, silt, and sand mixed with windblown sand and silt. These deposits are present in Coyote Wash and its intermittent tributary stream drainages. Member C of the Uinta Formation is exposed on the very southern portion of the Parcel and extends off-site of the Parcel. It consists of Horizon C, soft, light-gray, greenish- gray, white, grayish-purple, red, and pale-yellow shale, mudstone, claystone, and minor sandstone material in local tuffaceous interbeds. - Vegetation The surrounding land is composed of flats, plateaus and ridge tops overlooking narrow drainage bottoms. Vegetation is sagebrush, greasewood and other dry-climate native and invasive species. iii. Overview of Proposed Facility Operations The Facility has an off-loading area and one existing open, concrete, in-ground receiving headworks tank-set (Headworks). With this Request BBD proposes to install an HDPE liner inside of the existing Headworks as shown on drawings S-021, S-022, S-023, S-024 and S-025. The HDPE Liner will provide Primary Containment and the Headworks Tank will provide Secondary Containment. An HDPE-lined earthen Tank Battery and Containment has been constructed in accordance with the Approved Permit. This Tank Battery and Containment is shown on drawings S-008, S-010, S-011 (Sh 2 of 2), S-012 (Sh 2 of 2) and PFD-002. Of the three existing double-lined evaporation ponds only the most northeasterly pond is intended to be operated under this Request. That pond has been and will continue to be designated as Pond No. 1. iv. Site Configuration, Components, Equipment and Process The N/2 of the NW/4, Section 9, T 9S, R 22E comprise the northerly 80-acre portion of the Parcel. This 80-acre tract contains the off-loading area, Headworks Tank, Tank Battery and Containment and all three existing evaporation ponds. Excepting the Tank Battery and Containment, all of these improvements were included in previous DOGM E&P Waste Disposal Facility permits. The operating permit in effect as of January 1, 2021 was inactivated in February 2021 at BBD’s request. v. Evaporation Ponds Eight ponds have been planned and designed for construction at this site. To date, three evaporation ponds have been approved by DOGM and constructed. All existing evaporation ponds have leak detection piping positioned on top of their secondary liner. This piping discharges to designated leak detection observation wells. Page 006 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 6 | Page of 16 Table 1 – List of Existing and Planned Evaporation Ponds on the Parcel Pond Number Construction Status (see drawing S-006) Use Requested in this Application Area Enclosed at Pond Berm Crest Volume Below High Water Limit (Two Feet Below Pond Crest) 1. Construction Completed Produced Water to Freeboard Limit 11.9 Acres 1,096,000 BBL 2. Construction Completed None 8.3 Acres 766,000 BBL 3. Construction Completed None 12.5 Acres 1,073,000 BBL 4. Not Constructed None 5.1 Acres 501,000 BBL 5. Not Constructed None 7.7 Acres 872,000 BBL 6. Not Constructed None 5.7 Acres 618,000 BBL 7. Not Constructed None 6.8 Acres 777,000 BBL 8. Not Constructed None 5.5 Acres 593,000 BBL vi. Oil and Gas Wells Owned and Operated by Others Five operating, commercial oil wells owned and operated by others are located on the Parcel. No other production or injection wells are co-located on this site. vii. Proposed Waste Handling Process Liquid E&P Waste received at this Facility will be off-loaded from transport trucks into the HDPE Lined-Headworks, steel API 650 and/or API 12F tanks. There are no buried or above-ground pipelines delivering liquid E&P waste to this site. All wastes received at the Facility are liquids and will be routed through the HDPE Lined Headworks, and/or API 650 and/or API 12F receiving and decanting tanks. Both the Headworks and the API free-standing steel tanks are used to gravity-separate entrained and entrapped oil, water, and solids naturally present in Produced Water. Brine water separated from Produced Water will be routed to Evaporation Pond No. 1. Page 007 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 7 | Page of 16 Wastewater which either never contained phase separable hydrocarbons or from which phase separable hydrocarbons have been removed will be routed directly to Evaporation Pond No. 1. No liquids from Pond No. 1 will be transferred to existing Pond Nos. 2 or 3. One 1.4-acre Stormwater Detention basin is located on the proposed 16.5-acre Facility operating area. The location of this detention basin is shown and labelled on drawings S-002 and S-005. This basin has been previously designed by others to detain storm water runoff generated by a 25-year, 24-hour storm until the runoff can be sampled and lab-tested. Depending on lab test results, the detained water will be either released to a local drainage, held to evaporate in place, diverted to evaporation pond No. 1 or disposed by some combination of the three aforementioned methods. viii Wastes Received Wastes to be received at the facility will be limited to those E&P Waste types identified in UAC Title 649 as appropriate for acceptance in this type of waste disposal facility and which are, in general, suitable for gravity and enhanced gravity separation of constituents. b. Site Contamination Evaluation i. No extra regulatory contamination of the Facility site is documented or known to have occurred by BBD or regulators having jurisdiction for this Facility. ii. Test pits and exploratory drill holes made in 2007 did not encounter ground water. Driller reports show nominal test hole depths of 50 feet Below Ground Surface. Those reports provide only a description of the material encountered in the drill holes. No geologic interpretation of the drill hole material data has been found. Data from two drill holes for Water Right No. 49-2161 and 49-2168 made within a one- mile radius of the Facility suggest there are no unconfined aquifers underlying the Parcel. iii. Analysis of all soil samples taken within the proposed 16.5 acre operating area, but outside of tanks and ponds showed mineral content consistent with background soils. No sample contained hydrocarbon or heavy metal concentrations in excess of those allowed for Site Sensitivity Level II. See Attachment 4 for Site Sensitivity Level Evaluation and Standards. See Appendix 5 for Offload Area Soil Sampling and Analysis. iv. Samples of wastes from tanks and ponds showed hydrocarbon species consistent with previously received E&P waste. No chlorinated or fluorinated hydrocarbons were found in any sample. v. Records provided by BBD did not contain evidence of salts from spray-type evaporation enhancement traveling outside of Evaporation Ponds. vi. Pond liners and impoundment crest roads are free of salt which might be expected from overspray. vii. The Offload area and roadways around the Headworks Tank showed no evidence of Produced Water spills. Page 008 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 8 | Page of 16 c. Previous Waste Disposal Design Configurations Proposed and/or permitted on the Parcel) i. The Glen Bench site was first permitted by DOGM for the existing headworks and existing Pond No. 1 on June 17, 2008. Construction was completed and operation began by the end of 2008. ii. Pond Nos. 2 and 3 were permitted and constructed in 2009. iii. Permit applications for proposed evaporation Pond Nos. 4 through 8 and two landfarms were submitted to DOGM in 2009. Neither the additional five evaporation ponds nor the two landfarms were permitted or constructed. See Fig 1, below. Page 009 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 9 | Page of 16 Page 010 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 10 | Page of 16 iv. The Offload area, Concrete Headworks Tank, Pond Nos. 1, 2 and 3 and the Storm Water Detention shown in Figure 2, below, were operated from November 2009 until February 2021 on the 51.5 acre portion of the Parcel shown in Figure 2, below. d. Status of Facility after February 2021 i. DOGM deactivated the Facility operating permit on February 17, 2021 at the request of BBD. The terms of the deactivation included: - A written Cleanup Plan and Financial Assurance in an amount sufficient to implement the Cleanup Plan. - Timely cleanup and removal of existing E&P Waste from the Facility. - An amount of Financial Assurance sufficient to implement all outstanding Cleanup work to be kept in place until DOGM inspects and notifies BBD that Facility Cleanup has been successfully completed. - No requirement for removal of uncontaminated real property improvements (e.g. Tanks and Ponds) from which E&P Waste is removed. - No requirement to return the Parcel to its state prior to installation of real property improvements. Page 011 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 11 | Page of 16 - The allowance for real property improvements, which improvements would contain no E&P Waste, to remain in place was based upon BBD ownership in fee of the land on which the existing disposal was built and BBD’s desire keep the real property improvements in place for future use. - A full description of the Facility deactivation terms is provided in Attachment 3, DEACTIVATION TERMS. ii. Status of Completion of Deactivation Terms. - As of the date of June 7, 2022 BBD has submitted and DOGM has approved a Site Level Sensitivity and Cleanup Standard Evaluation in accordance with UAC Part R649, Rule 9, Article 12 and DOGM Cleanup Level Selection Guidance Document, dated January 2020. BBD and DOGM have concurred that Facility has a DOGM Level II Sensitivity. e. Site and Equipment Assessment Major Equipment at the Facility consists of one Concrete Headworks Tank, HDPE Pond Liners, Roadways and Earthen Embankments. This equipment 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 BBD formed 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: i. Site roadways are constructed and maintained with appropriate geometry, 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 HDPE liners are not torn, excessively worn or weathered. Evaporation Ponds 2 and 3 are currently empty. v. No permanent pumps are installed. vi. No permanent buildings have been or are intended to be installed on the site. vii. The interior and observable portions of the concrete headworks tank exterior do not show signs of distress or disrepair. f. Description and Assessment of Proposed Site Operations and Equipment Engineer has reviewed operating procedures provided by BBD and has observed those procedures in practice at the BBD 12-Mile Disposal. The following assessment is based on BBD’s intent to operate the Facility in the same manner and with the same care as with the 12-Mile Disposal. Page 012 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 12 | Page of 16 i. Oil Cleaning, Water Disposal and Solids Disposal Operation Assessment - Operators will be trained to understand the overall Facility process. Operators sample process liquids for anomalies. Whenever process liquids or Headworks tank operation appears abnormal operators will intervene in one of two ways. Normally the operator will make process adjustments for which the operator has been trained and given authority to perform. Produced water receiving tank valving adjustments which appear to be needed, but which operator has not been authorized to perform, will be brought to the attention of other operating staff and Facility management for resolution. - Leak detection observation wells will be monitored weekly. ii. The proposed process control plan is based on operator sampling of receiving tanks, allowing appropriate time for solids to settle and hydrocarbons to coalesce, thief hatch sampling and sequencing of receiving tank valves. It will be similar the that employed at 12-Mile Disposal and, when appropriately applied, will be sufficient to prevent process excursions which could cause a waste oil or brine water spills. iii. Based upon Engineer’s calculations for leak time-of-travel and the physical inability of excessive hydraulic heads to develop on the secondary liner it is the Engineer’s opinion that proposed weekly leak detection well monitoring is appropriate and frequent enough to determine if the primary liner has developed leaks. iv. If liquid appears in any observation well, the operator will sample that liquid for lab testing to determine if the liquid is representative of impounded water. v. If lab tests cannot rule out a primary liner leak BBD will notify DOGM and develop a leak location and repair plan on a case-by-case basis. g. Proposed Monitoring Program i. Spills and Leaks Water and soil sampling and testing. - Sampling and testing of soil or water affected by spill and/or impoundment or tank leakage has been performed to determine the extent of any needed clean-up. - Water Sampling and testing will be performed on all liquid taken from leak detection sumps. - Spills will be cleaned by removal of contaminated material. Contaminated material will be disposed in a landfill. ii. Equipment Monitoring Mechanical equipment efficiency and safety could be enhanced by performing the following. - Annual condition assessment of valve packing, valve seats and gaskets for excessive wear and leaks. Page 013 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 13 | Page of 16 - Annual cursory check of process and stoichiometry and mass balance to rule out leaks and verify process efficiency. - BBD will perform electrical liner leak testing per ASTM D7007 when necessary to enhance early detection of inadvertent waste release and determine impoundment leak sources. iii. Electric Power System - None required because the Facility only has periodic convenience electrical power supplied by portable generator sets. 3. Closure Cost and Financial Assurance Evaluation a. General Scope of Closure Work The Approved Permit and this Request are intended to reactivate the existing Off-Loading Area, Evaporation Pond No. 1, Perimeter Roads, Headworks Tank and adjacent areas shown in Fig. 3 below. Therefore, closure cost will apply only to those reactivated portions of the Facility. Financial Assurance for remediation of extra regulatory contamination, testing and removal of E&P Waste from Pond No. 2 and No. 3 is NOT INCLUDED in this Application and will be addressed in the separate BBD Site Assessment proposal requested by DOGM. See paragraph 2.d.i, above, Attachment 3 and pages 2 and 3 of Attachment 4. This proposal will include a cleanup plan, schedule and estimated cost to stop operating Pond No. 2 and No. 3 and remove any existing E&P Waste and contamination from those ponds. Page 014 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 14 | Page of 16 The proposal will also be based on the Terms of February 17, 2021 Facility Deactivation in Attachment 3 and the DOGM approved Site Level Sensitivity and Cleanup Standard Evaluation in Attachment 4. b. Detailed Scope of Closure and Post Closure Work i. Site Closure Plan Upon closure the existence and extent soil contamination will be identified with a Photo Ionization Detector (PID) survey. Where encountered, groundwater quality and surface water will be sampled and lab-tested. Hazardous substances stored or used on site will be inventoried. Costs for this evaluation are included in calculated closure costs in Attachment 2. ii. Infrastructure Removal The cost to remove all unserviceable and contaminated site infrastructure and equipment as may be reasonable and necessary to prevent pollution of the reclaimed site and its stormwater runoff 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: - Removal all tanks, fences, unserviceable and contaminated natural and synthetic liner materials, piping and concrete structures which are potential sources of contamination from E&P Waste as identified in the “Infrastructure Removal” portion of closure costs. - Earthwork and grading to restore site to a serviceable condition similar to, and in keeping with surrounding land use and drainage. - Seeding and Revegetation 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. - Initial Closure Monitoring Report This report will describe: Closure PID survey results and required sampling and lab testing. Sampling of any ground and surface water encountered. Inventory of hazardous substances removed from site. Description of site grading, revegetation and erosion controls installed. Page 015 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 15 | Page of 16 - Post Closure Monitoring Post closure monitoring and care cost includes annual: Erosion control and surface water management. Sampling and testing of site soil and any surface water as described in the initial closure report. Written report describing the condition of the reclaimed site and work performed to monitor and maintain reclaimed site. - Note: No groundwater sampling has been included because no unconfined aquifer underlies this site. c. Financial Assurance Computation Method Financial Assurance cost components referenced in this Application have been determined by applying unit costs to a quantity take-off from drawings in Attachment 1, field measurements and documents provided by BBD. Unit costs use 2022-dollars and have been taken from: - Heavy Construction Costs, RS Means, - Walker’s Building Estimator’s Reference Book, Frank Walker Company, - Budget Estimates requested from local construction companies, - Equipment Rental pricing by Wheeler Equipment of Salt Lake City, - Historical Contractor Bid Prices and Tabulations, - American Society of Civil Engineers and National Society of Professional Engineers fee structures and - America West Analytical Labs test pricing d. Contamination Evaluation No existing extra-regulatory site contamination at the Facility is known to BBD or has been observed by the Engineer. Geotechnical exploration borings advanced to over 50 feet below natural grade in 2008 did not encounter ground water. Geologic maps do not indicate the presence of unconfined aquifers and there are no nearby well boring logs showing the presence of near surface groundwater. For the purposes of this Request, it is assumed there is no groundwater or groundwater contamination in the unconfined strata underlying the Facility. e. Extra-Regulatory E&P Waste Contamination Page 016 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 16 | Page of 16 No remediation is required as no E&P Waste Contamination is known or has been observed at the Facility. f. Cleanup Level Cleanup standards for site reclamation will be based on the DOGM approved Site Level Sensitivity and Cleanup Standard Evaluation for Brennan Bottom Glen Bench Disposal included in Attachment 3. g. Post Closure Monitoring Scope of Work Glen Bench Disposal reclamation closure cost and bond amount has been estimated on the basis of a Clean Closure. Section A. 3., Closure Cost and Bonding Evaluation, and the Third-Party Closure Cost Estimate in Attachment 2 contain the Clean Closure reclamation scope of work and its cost. DOGM Clean Closure means the removal or remediation of all DOGM-regulated waste from a given DOGM-regulated unit so that further regulatory control under by DOGM is not necessary to protect human health and the environment. 4. Engineer’s Observations and Recommendations are Included in Article 2.e, 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: cjnebeker@yahoo.com 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: kspiroff@earthlink.net 3. Sampling/Testing Supervisor C.J. Nebeker Brennan Bottom Disposal, LLC 4091 West 3000 South, Roosevelt, UT 84066 435-823-1144 E-mail: cjnebeker@yahoo.com Page 017 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 D Attachments Page 018 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 ATTACHMENT 1 DRAWINGS Revised, deleted and/or added are listed below Sequential No. Drawing No. Drawing Title Comments 1 C-001 Cover Sheet – Permit Application Superseded by C-002 2 C-002 Cover Sheet – Permit Modification Added drawing 3 S-001 Site Location and Land Parcel No changes 4 S-002 Site Topography - North Rev 2 5 S-003 Site Topography - South No changes 6 S-004 Site Section A No changes 7 S-005 Site Section B No changes 8 S-006 Site Development & Development Plans No changes 9 S-007 Historic & Proposed Land Use No changes 10 S-008 Proposed Single Evap Pond Site Rev 3 11 S-009 Pond Leak Collection & Detection System No changes 12 S-010 Entry & Offload Area Rev 4 13 S-011 (1 of 2) Headworks Tank Plan Superseded by C-021 14 S-021 Headworks Tank w/ Liner – Plan Added drawing 15 S-011 (2 of 2) Tank Battery & Spill Containment - Plan Rev 3 16 S-012 (1 of 2) Headworks Sections Superseded by C-022 17 S-022 Headworks Tank w/ Liner - Sections Added drawing 18 S-012 (2 of 2) Tank Battery & Spill Containment - Sections Rev 1 19 S-013 Headworks Details Superseded by C-023 20 S-023 Headworks w/ Liner – Details Added drawing 21 S-024 Headworks Tank, Liner & Penetrations Added drawing 22 S-025 Liner & Batten Details Added drawing 23 S-026 Headworks Leak Collection Sump - Details Added drawing 24 S-014 Pond 1 Closure Grading No changes 25 S-015 Closure Grading – Cut Sections No changes 26 PFD-001 Process Flow Diagram Superseded by PFD-002 27 PFD-002 Permit Modification Process Flow Diagram New drawing Page 019 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 020 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 021 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 022 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 023 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 024 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 025 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 026 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 027 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 028 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 029 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 030 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 031 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 032 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 033 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 034 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 035 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 036 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 037 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 038 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 039 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 040 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 041 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 042 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 043 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 044 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 045 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Page 046 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 Utah Division of Oil Gas & Mining Request to Modify Existing E&P Disposal Permit for BBD llc Exploration & Production Waste Disposal 27545 South Coyote Wash Rd, Vernal, Utah Rev 20220915 ATTACHMENT 2 CLOSURE COST ESTIMATE DOGM Closure Summary Form Supporting Calculations Changed Based on Attachment 3, Deactivation Terms And Attachment 4, Site Sensitivity Level Evaluation Page 047 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM DISPOSAL GLEN BENCH FACILITY PERMIT MODIFICATION FINANCIAL ASSURANCE ESTIMATE SUMMARY Brennan Bottom Disposal, llc Date: 9/19/2022 Facility: Glen Bench Area to be Reclaimed 16.5 Acres Cost Estimates Contamination Remediation 28,463$ Removal of Infrastructure 64,486$ Earthwork and Grading 91,430$ Revegetation 17,638$ Final Closure & Post Closure 47,176$ Total Cost Estimate 249,194$ (Increase above total cost estimate by 14% if indirect costs are not included) 34,887$ Total Estimated Reclamation Cost 284,081$ Direct and Indirect Costs If you have questions about this form please contact Bev Wiser at 801-538-5346 or email btwiser@utah.gov. E&P Waste Disposal Facility Bond Calculation Summary Form REV 09192022 KK+E, llc ~a OIL, GAS a MINING Page 048 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 1 CALCULATION SUMMARY DOGM Line Item 0 Percentages Reference Numbers are to RS Means 2022 Heavy Construction Costs 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 Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 170.5 AC Less 7.0 AC Less 112.0 AC Less 35.0 AC 16.5 AC 2 Quantity Unit Price Extended Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 2,451 BBL 2.02$ 4,941$02 65 10.30 0130 (modifed for scale) 2,451 BBL 3.16$ 7,753$ 31 23 23.20 4096 adjusted to cy for hauling (with $1.25/bbl cost for disposal facility to accept waste) 0 EA -$ -$ Above costs include the removal (by vac truck) and disposal of 10% of tank volume 0 EA -$ -$ 0 EA -$ -$ 1.3 EA 11,886$ 15,769$MWH Historical Sampling Freq & Chentech Lab Pricing 0-$ -$ 28,463Total: $ Remove Contaminated Liquid (1" across Pond Bottom & 6" in Tanks) Disposal of Contaminated Liquid (Hauling & Tipping Fee) Vapor Extraction Pump & Treat Managed Self Attenuating Contamination Description Descripiton Total Site Area Total Undisturbed Area Total Disturbed Area Total Well Pad Area Total De-activated Area (1) Brennan Bottom Disposal, llc Site Assessment, Closure & Post Closure Cost Estimate 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 Other REV: 09192022 KK+E, llcPage 049 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 1 CALCULATION SUMMARY 4 3 Quantity Unit Price Extended Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 8,492 CY Varies 4,857$02 41 19.20 0020 (includes 20 Mile Haul) 2 EA Varies No Cost (net of salvage)02 65 10.30 1253 4 EA 200.00$ No Cost (net of salvage)02 65 10.30 1253 17,602 LF Varies -$ Removal Included with 60 Mil HDPE Liner & Leak Collection Pipe Removal Cost , below 519,267 CY Varies 24,321$31 23 16.42 0260 modified to add truck loading 0. SF 1.09$ -$02 41 16.17 0440 6,712 LF Varies 2,739$No cost net of salvage 0 CY 0.81$ -$Closest Landfill 5 miles away 651 T 50.00$ 32,569$Wonsits Landfill Tipping Fee Total:64,486$ 4 Quantity Unit Price Extended Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 44,832 CY 1.94$ 86,795$31 23 16.46 5020 0 CY 2.83$ -$31 23 16.46 5040 0 CY 1.68$ -$31 23 16.46 5000 68,817. SF 0.08$ 4,634$31 22 13.20 0280 (modifed for scale) Total:91,430$ 5 Quantity Unit Price Extended Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 652 MSF 28.94 17,638$32 92 19.14 5800* Total:17,638$ Descripiton Building Demolition Tanks & Major Equipment (No cost - net of salvage) Gensets (No cost - net of salvage) Buried Piping 60 Mil HDPE Liner & Leak Collection Pipe Removal Concrete Demo Fencing Hauling (Included w/ Demolition Line item) Landfill Fees Descripiton Common Earth to be Dozed Clay Liner to be Moved Earthwork and Grading Cost Estimates Revegetation Cost Estimates Sand & Gravel to be Moved Rough Grading Descripiton Hydro Seeding of Native Grass Removal of Infrastructure Costs Estimates REV: 09192022 KK+E, llcPage 050 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 1 CALCULATION SUMMARY 6 Quantity Unit Price Extended Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 1 YR 570.00$ 6,050$Based on MWH inhouse fee estimates 10 YR 125.00$ 1,485$Rental Quote 10 YR 800.00$ 8,250$Based on AWA Labs pricing 9 Mo 1,050.00$ 9,900$32 91 13.23 Structural Soil Mixing 12 Mo 3.42$ 41$32 91 13.23 6000 Tilling 6" Cost for 12 tillings 1 YR Varies 2,310$Based on MWH scope & ASCE/NSPE pricing 8 YR 1,700.00$ 13,200$Based on MWH scope & ASCE/NSPE pricing 2 YR 2,800.00$ 5,940$Based on MWH scope & ASCE/NSPE pricing Total: 47,176$ Notes: 1.De-Activated Area is the area taken out of service by the Febraury 17, 2021 Permit De-Activation less the operating area in the June 7, 2022 Permit Landfarm Monitoring Well Abandonment Annual Report Final Closure & Post Closure Cost Estimates Descripiton Well Inspection & Sampling Water Quality Meter Rental Initial and Final Post Closure Report Lab Analysis Grounds Maintenance REV: 09192022 KK+E, llcPage 051 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE -PART 2 INDIRECT COSTS Percentage Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 7%01 21 00 01 21 55.50 0200 With an additional 2% of unforseeable events Percentage Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 3%01 31 00 01 31 00 Adjusted to reflect a percentage, also referenced ACEC and NSPE for rates Percentage Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 1%01 41 00 01 41 26.50 0100 2. Project Management and Coordination INDIRECT COST EVALUATION 3. Permits Item Administrative Requirements Quality Requirements Contingencies Price and Payments Procedures Item 1. Economic Conditions (Unfavorable) Item REV: 09192022 KK+E, llcPage 052 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 2 INDIRECT COSTS Percentage Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 0%01 51 00 01 51 00 Not applicable for the scope and scale of a project like this Percentage Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 3%01 71 00 01 71 00 Adjusted to reflect a percentage, also referenced ACEC and ASCE for rates 14%Total Indirect Cost: 5. Examination and Preparation Item 4. Temp Utilites Item Temporary Facilities and Controls Execution of Closeout Requirements REV: 09192022 KK+E, llcPage 053 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE PART - 3 CONTAMINATION AND REMEDIATION Location Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Pond 1 2,094 BBL $2.02 /BBL 4,222$ 02 65 10.30 Line 0130 (modifed for scale) Pond 2 0 BBL $2.02 /BBL -$ 1" RESIDUAL IN POND BOTTOM Pond 3 0 BBL $2.02 /BBL -$ Headworks Tank 301 BBL $2.02 /BBL 608$ 6" RESIDUAL IN FOUR HEADWORKS TANK CELLS Tank Battery 55 BBL $2.02 /BBL 111$ 6" RESUDUAL IN TWO 600 BBL FRAC TANKS Total 2,451 BBL $2.02 /BBL 4,941$ Location Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Pond 1 2,094 BBL $3.16 /BBL 6,625$ 31 23 23.20 4104 Pond 2 0 BBL $3.16 /BBL -$ Pond 3 0 BBL $3.16 /BBL -$ Headworks Tank 301 BBL $3.16 /BBL 953$ TWO 600 BBL FRAC TANKS Tank Battery 55 BBL $3.16 /BBL 175$ 4 CELLS OF HEADWORKS Total 2,451 BBL $3.16 /BBL 7,753$ Location Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 1.3 Positives Positive Samples Varies 15,769$ CONTAMINATION ASSESSMENT & REMEDIATION COST Remove Contaminated Liquid (1" across Pond Bottom & 6" in Tanks) Disposal of Contaminated Liquid (Hauling & Tipping Fee) PID Closure Soil Sampling REV: 09192022 KK+E, llcPage 054 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 4 INFRASTUCTURE REMOVAL Material Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Steel 0 CF*$0.36 / CF*-$ 02 41 19.20 0020 (includes 20 Mile Haul) Masonry 0 CF*$0.39 / CF*-$ Concrete 8,492 CF* Headworks Tank $0.57 / CF*4,857$ 02 41 16.13 0050 IIncl 20 Mi Haul) Wood 0 CF*$0.39 / CF*-$ Total: 8,492 CF*4,857$ * Cubic Feet of Structure Type Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Upright 0 EA 880$ -$ 02 65 10.30 1253 Frac 2 EA 600 BBL*/EA 880$ -$ Cenrifuge 0 EA 825$ -$ Oil Take Away 0 EA 825$ -$ Total:2 EA -$ Type Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Welders / Generators - 200$ -$ Size Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 4"17,602 LF 0.90$ -$ -$ Total: 17,602 LF -$ Building Demolition Tanks & Major Equipment (No cost - net of salvage) Gensets (No cost - net of salvage) Leak Detection Piping Removal INFRASTRUCURE REMOVAL Removal Included with 60 Mil HDPE Liner & Leak Collection Pipe Removal Cost , below REV: 09192022 KK+E, llcPage 055 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 4 INFRASTUCTURE REMOVAL Size Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 4"-6"0 LF 0.90$ -$ 10"0 LF 1.00$ -$ 0 LF Location Liner Area For 6'' Depth Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Pond 1 506,587 SF 9,381 CY $2.16 /CY 20,293$ 31 23 16.42 0260 modified to add truck loading Pond 2 0 SF 0 CY $2.16 /CY -$1.881 Pond 3 0 SF 0 CY $2.16 /CY -$ Headworks Tank 6,680 SF Note 1 $0.57 /SF 3,788$ Use 30% of 31 05 19.43 - Reservoir Liner Tank Battery 6,000 SF 111 CY $2.16 /CY 240$ Total: 519,267 CY 24,321$ Note 1: Removing 6" of underlying soil has no meaning for Headworks & is not used w/ liner removal from headworks Size Quantity Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Walls (REINF)0 SF 1.09$ -$ 02 41 16.17 0440 Pad (REINF 0 SF 0.98$ -$ Headworks Tank Demo included in "Building Demo" above Total:-$ Transfer Piping on Ground Surface or with Shallow Bury 60 Mil HDPE Liner & Leak Collection Pipe Removal Concrete Demo REV: 09192022 KK+E, llc I Page 056 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 4 INFRASTUCTURE REMOVAL Type Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 1/0 & Smaller 0 MLF 15.65$ -$ 250 MCM 0 MLF 19.95$ -$ Total:0 MLF -$ Size Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Barbed Wire 5,532 LF 2.50$-$No cost net of salvage 5' Chain Link 1,180 LF 2.32$2,739$ 02 41 13.62 0600 Total: 6,712 LF 2,739$ Item Volume Notes Unit Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise HDPE Liner 0 CY Incl w/ Demo $0.00 /T/Trip -$31 23 23.20 4104 Modified for Proximity to Wonsit LF Concrete 315 CY Incl w/ Demo $0.00 /T/Trip -$ Rubble 0 CY $0.81 /T/Trip -$Costs for Wonsit Landfil Dry Wall 0 CY $0.81 /T/Trip -$5.1 Miles to Wonsits Scrap Metal 0 CY $0.81 /T/Trip -$10.20 Mile RT Scrap Wood 0 CY $0.81 /T/Trip -$ 4" PVC 57 CY Incl w/ Demo $0.00 /T/Trip -$ 6" PVC 0 CY $0.81 /T/Trip -$ 10" PVC 0 CY $0.81 /T/Trip -$ Total:$0.81 /T/Trip**-$** 10.2 Mi-RT Hauling (Included w/ Demolition Line item) Major Electrical Panels, Conduit, Conductor & Grounding Fencing REV: 09192022 KK+E, llc l Page 057 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 4 INFRASTUCTURE REMOVAL Item Unit Weight Total Weight Tipping Fee Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise HDPE Liner 0.3 lb/sf 81.8 T $50 /T $ 4,091 Costs for Wonsit Landfil Concrete 3,510 lb/CY (2)552.0 T $50 /T 27,599$ 5.1 Miles to Wonsits Rubble 1,400 lb/CY 0.0 T $50 /T -$10.20 Mile RT Dry Wall 500 lb/CY 0.0 T $50 /T -$ Scrap Metal 1,000 lb/CY 0.0 T $50 /T -$ Scrap Wood 300 lb/CY 0.0 T $50 /T -$ 4" PVC 2.0 lb/LF 17.6 T $50 /T 880$ 6" PVC 3.6 lb/LF 0.0 T $50 /T -$ 10" PVC 7.9 lb/LF 0.0 T $50 /T -$ Total:651.4 T 32,569$ Note 2: Cast-in-place concrete weight of 130 lb/CF Landfill Fees REV: 09192022 KK+E, llcPage 058 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 5 -EARTHWORK AND GRADING Location Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Pond 1 43,982 CY $1.94 /CY 85,149$31 23 16.46 5020 Pond 2 0 CY $1.94 /CY -$ Pond 3 0 CY $1.94 /CY -$ Headworks Tank 628 CY $1.94 /CY 1,216$ Tank Battery 222 CY $1.94 /CY 430$ OffLoad 0 CY $1.94 /CY -$ Stormwater 0 CY $1.94 /CY -$ Stormwater Detention Remain in place Roads 0 CY $1.94 /CY -$ Landfarm 0 CY $1.94 /CY -$ Total 44,832 CY 86,795$ Location Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Landfarm 0 CY $2.83 /CY -$31 23 16.46 5040 Pond 0 CY $2.83 /CY -$Uncontaminated Clay Liner to be left in Place Landfill 0 CY $2.83 /CY -$ Total 0 CY -$ Common Earth to be Dozed Clay Liner to be Moved REV: 09192022 KK+E, llcPage 059 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 5 -EARTHWORK AND GRADING Location Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Landfarm 0 CY $1.68 CY -$31 23 16.46 5000 Pond 0 CY $1.68 /CY -$ Landfill 0 CY $1.68 CY -$ Total 0 CY -$ Location Quantity Notes Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Pond 1 56,287 SY $0.08 SY 4,503$31 22 13.20 0280 (modifed for scale) Pond 2 0 SY $0.08 SY -$ Pond 3 0 SY $0.08 SY -$ Headworks Tank 35 SY $0.08 SY 3$ Tank Battery 942 SY $0.08 SY 75$ OffLoad 667 SY $0.08 SY 53$ Stormwater 0 SY $0.08 SY -$Stormwater Detention Remain in place Roads 10,886 SY $0.08 SY -$ Unpaved site roads to remain as is for inspection & maintenance access Landfarm 0 SY $0.08 SY -$ Other Disturbed Site 0 SY $0.08 SY -$ Total 68,817 SY 4,634$ Sand & Gravel to be Moved Rough Grading REV: 09192022 KK+E, llcPage 060 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 6 REVEGITATION Location Quantity Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Pond 1 507 MSF 31.83$ 16,127$ 32 92 19.14 5800* Pond 2 0 MSF 31.83$ -$ Pond 3 0 MSF 31.83$ -$ Headworks Tank 8 MSF 31.83$ 270$ Tank Battery 6 MSF 31.83$ 191$ OffLoad 33 MSF 31.83$ 1,051$ Stormwater 0 MSF 31.83$ -$Stormwater Pond Remains in place Roads 98 MSF 31.83$ -$ Unpaved site roads to remain as is for inspection & maintenance access Total 652 MSF 28.94$ 17,638$ *Note: Hydro Seeding of Native Grass Rate modified with specific seeding costs from Granite Seed in Lehi, UT REV: 09192022 KK+E, llcPage 061 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 7 CLOSURE + POST CLOSURE COSTS Location Quantity Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 10 YR $605 /YR 6,050$ACEC & NSPE Local Rates Total:6,050$ Meter Quantity Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 10 YR $149 /YR 1,485$ Enviro Equipment, Inc Total:1,485$ Labs Quantity Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 10 YR $825 /YR 8,250$ Based on America West Analytical Lab Fee Schedule Total:8,250$ Annual Maintenance Quantity Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 9 EA $1,100 /EA 9,900$ 32 91 13.23 Structural Soil Mixing Total:9,900$ Location Quantity Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 1 MSF $3.63 /MSF 41$32 91 13.23 6000 Tilling 6" Cost for 12 tillings Total:41$ Well Inspection & Sampling Water Quality Meter Rental Lab Analysis Grounds Maintenance Landfarm Tilling REV: 09192022 KK+E, llcPage 062 of 151 Sundry Number: 119373 Facility Number: 75 RECEIVED: Sep. 28, 2022 BRENNAN BOTTOM GLEN BENCH DISPOSAL PERMIT MODIFICATION RECLAMATION FINANCIAL ASSURANCE - PART 7 CLOSURE + POST CLOSURE COSTS Monitoring Wells Quantity Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise Driller 1 EA $1,320 /EA 1,320$ Based on Boart Longyear Qupte Driller Oversight 1 EA $990 /EA 990$ ACEC & NSPE Local Rates Total:2,310$ Location Quantity Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 8 EA 1,650$ 13,200$ACEC & NSPE Local Rates Total:13,200$ Location Quantity Unit Price Cost Reference Numbers are to RS Means 2022 Heavy Construction Costs Unless Noted Otherwise 2 EA 2,970$ 5,940$ ACEC & NSPE Local Rates Total:5,940$ Total Closure & Post Closure 47,176$ Initial and Final Post Closure Report Monitoring Well Abandonment Annual Report REV: 09192022 KK+E, llcPage 063 of 151 Sundry Number: 119373 Facility Number: 75