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HomeMy WebLinkAboutDSHW-2024-0093732 Exploration and Production Waste Facility Temporary Permit Application Form I. Facility Name and Location Name of Facility Facility Address (Street or Directions to Facility) County City. Zip Code Telephone Township Range Section Quarter Section Quarter/Quarter Section Main Gate Latitude: Longitude: II.Existing E&P Facilities ☐ Open Landfarm Cell(s) ☐ Evaporation Pond(s) Number of Open Landfarm Cells: Number of Evaporation Ponds: III.Facilities to be Permitted by DWMRC ☐ Landfill Cell(s) ☐ Surface Impoundment(s) Number of Landfill Cells: Number of Surface Impoundments: III.Facility Owner(s) Information Legal Name of Facility Owner Mailing Address City State Zip Code Telephone IV.Facility Operator(s) Information Legal Name of Facility Operator Mailing Address City State Zip Code Telephone V. Property Owner(s) Information Is the property leased? Name of Property Owner Mailing Address City State Zip Code Telephone VI.Designated Contact Information Facility Owner Designated Contact (if different than above) Title ContractnEnvironemntal Services, Inc. San Juan x 9 X 2 Contract Environmental Services, Inc. 925 S. Broadway, Suite 251 Cortez CO 81321 (970) 565-1198 - same as above - No Contract Environmental Services, Inc. - same as above - Tsuyoshi Okano President 19 mile north of Aneth, UT (970)565-1198 39 South 26 East 18 Northeast East and West 37.400087 -109.098160 3 Mailing Address City. State Zip Code Telephone Email Address Alternative Telephone (cell phone or other) 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: acres Disposal Area: acres 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) 1718 Cochita Drive Cortez CO 81321 (858) 401-3985 yoshi@contractenv.com (858)401-3985 x 160 6 xx x x Contract Environmental Services, Inc. Landfarm Facility Map Entrance and Exit Gate West 80 Acres East 80 Acres East and West 1/2, Northeast Quarter, Section 18, Township 39 South, Range 26 East San Juan County, Utah Asbestos Landfill Cells C/D Landfil l Asbestos Landfill Cells C/D Landfill Cell #1 Cell #2 Cell #3 Cell #6 Cell #5 Cell #4 Cell #7 Cell #14 Cell #18 Cell #17 Cell #13 Cell #14 Cell #14 Cell #14 Cell #14 Cell #14 Cell #12 Cell #14 Cell #14 Cell #14 Cell #14 Cell #14 Proposed Asbestos Landfill Cells Proposed C/D Cell State of Utah DEPARTMENT OF NATURAL RESOURCES GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor MICHAEL R. STYLER Executive Director Division of Oil, Gas and Mining JOHN R. BAZA Division Director Permit to Operate ******************** Facility Name:Hovenweep Facility Type: Commercial Waste Disposal Facility Location: Section 18, Township 39S, Range 26E County:San Juan Approval Date:October 1, 2018 1. Issued to: CONTRACT ENVIRONMENTAL SERVICES, INC 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 Contract Environmental Services, Inc.’s “Permit Renewal Application” dated 05/24/2018 and received by the Division on 05/25/2018, (“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: The Facility shall comply with the reporting and recordkeeping requirements in Utah Admin. Code § R649-9-11. 1594 West North Temple, Suite 1210, PO Box 145801, Salt Lake City, UT 84114-5801 telephone (801) 538-5340 x facsimile (801) 359-3940 x TTY (801) 538-7458 x www.ogm.utah.gov Sundry Number: 88231 RECEIVED:May. 25, 2018 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 Hovenweep 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, Permit Manager: 801-538-5303 Bart Kettle, Operations Manager: 435-820-0862 Ammon McDonald, Environmental Scientist: 801-538-5337 Approved By: ________________________ By: Dayne Doucet Title: Permit Manager Sundry Number: 88231 RECEIVED:May. 25, 2018 Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o, ou, email=daynedoucet@utah.gov, c=US Date: 2018.10.04 11:15:52 -06'00' 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 considered 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 E and P waste accepted by the landfarm shall be sufficiently free of liquid content to pass a 60-mesh liquid paint filter test (i.e., no produced water or drilling mud). 2.2 Pooling of liquids in the landfarm is prohibited. 2.3 Within 72 hours after receipt of E and P waste, the operator shall prepare materials for remediation. 2.4 Soils shall be turned regularly, a minimum of once a month. 2.5 Additional materials shall not be added until the soil concentrations of the current lift meet the Division’s salinity and hydrocarbon cleanup standards. 2.6 This approval does not include the Phase B expansion cells. They will be approved at a later date after the required information is received by the Division. FAILURE TO COMPLY WITH THE ABOVE LISTED CONDITIONS OF APPROVAL MAY RESULT IN CLOSURE OF THE FACILITY. Sundry Number: 88231 RECEIVED:May. 25, 2018 &RQWUDFW(QYLURQPHQWDO6HUYLFHV,QF 7VX\RVKL2NDQR &RFKLWD'U&RUWUH]&2   &HOO3KRQH RECEIVED DIV. OF OIL, GAS & MINING May 23, 2019 67$7(2)87$+:DVWH'LVSRVDO3HUPLW '(3$570(172)1$785$/5(6285&(6 $0(1'('5(3257 ',9,6,212)2,/*$6$1'0,1,1*2ULJLQDO)LOLQJ'DWH :$67(',6326$/3(50,7 1DPHRI2SHUDWRU &2175$&7(19,5210(17$/6(59,&(6,1& 8WDK$FFRXQW1XPEHU  $GGUHVVRI2SHUDWRU &LW\ 6WDWH =LS 6%52$':$<67( &257(= &2  3KRQH1XPEHU  1DPHRIUG3DUW\&RQWUDFWRU (QYLURWHFK )DFLOLW\1DPH +RYHQZHHS $GGUHVVRI&RQWUDFWRU &LW\ 6WDWH =LS 86+LJKZD\ )DUPLQJWRQ 10  3KRQH1XPEHU  $GGLWLRQDO&RPPHQWV 2FWREHU Sundry Number: 88231 RECEIVED:May. 25, 2018 Sundry Number: 88231 File: Detailed Site Description RECEIVED:May. 25, 2018 RECEIVED DIV. OF OIL, GAS & MINING May 25 2018 925 S. Broadway, Suite 251 Cortez, CO 81321 PH: (970)565-1198 Fax: (970)565-7688 www.contractenv.com Five Year E & P Waste Disposal Facility Permit Renewal for Contract Environmental Services, Inc. Landfarm Permit Renewal Presented To: State of Utah Division of Oil, Gas and Mining Department of Natural Resources Permit Renewal Prepared by: Contract Environmental Services, Inc. 925 S. Broadway, Suite 251 Cortez, CO 81321 Permit Renewal Date: May 24th, 2018 Property Location: East and West 1/2, Northeast Quarter, Section 18, Township 39 South, Range 26 East San Juan County, Utah Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 RECEIVED DIV. OF OIL, GAS & MINING May 25 2018 TABLE OF CONTENTS I. Introduction ……………………………………………………………………………………………………..…...……….. 1 I-1. Introduction ……………………………………………………………………………………………….…..……… 1 I-2. Previous Permits and Permit Statement of Basis …………………………………..….…..……….. 3 II. Detailed Site Description ……………………………………………………………………………….………………. 12 II-1. Function of the waste disposal facility …………………………………………………….……………. 12 II-2. Current Facility Map …………………………………………………………………………………………….. 13 II-3. Site descriptions annotated with facility infrastructure and associated function ….. 21 III. Contamination Assessment ………………………………………………………………………………..………… 23 III-1. Description of existing contamination with sample results …………………………….….... 23 III-2. Proposed monitoring/remediation …………………………………………………………………….. 113 III-3. Proposed practices to prevent further contamination ………………………………………… 113 IV. Equipment Assessment ……………………………………………………………………………………………….. 114 IV-1. Description and assessment of equipment located at the facility ……………………….. 114 V. Practices Assessment …………………………………………………………………………………………………... 114 VI. Monitoring Program …………………………………………………….……………………………………………… 114 VII. Estimating Closure Cost and Bonding Evaluation ………………………………………………………… 123 Envirotech, Inc. Closure and Post Closure Plan …………………………………………………………… 124 Cost Break Down ……………………………………………………………………………………………………….. 131 (Five Year E&P waste Disposal Facility Bond Calculation Summary Form) Appendex: Third Party Cost Estimates ………………………………………………………………………… 133 V.III. Plans for Reclaiming Current Cells and Phase B Expansion Cells ………………………………… 137 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 I. Introduction I-1. Introduction Contract Environmental Services, Inc. (CESI) currently operates a permitted 80 acre Oilfield Exploration & Production Waste Disposal Landfarm Facility in East 1/2, Northeast Quarter, Section 18, Township 39 South, Range 26 East, in San Juan County, Utah. CESI is currently permitted for a landfarm through the State of Utah, Division of Oil, Gas and Mining (DOGM) since 1999. The facility is also permitted for Class V landfill through the Division of Waste Management and Radiation Control (DMWRC) since 2005. Additionally, CESI would like to propose to utilize additional 24 acres (6 cells) the Landfarm Facility as a part of phase B, in West 1/2, Northeast Quarter, Section 18, Township 39 South, range 26 East, san Juan County, Utah, which permit was previously approved in 2001 by the Division. Property is built and maintained through the previous approved permits including following features; 1) A four foot dike around the perimeter 2) Barbwire fence around the perimeter 3) Locked gates at the entrance 4) Controlled access – one point 5) Sign with operators name and emergency phone numbers 6) Sparsely populated area 7) Estimated 1,000’ to groundwater 8) Relatively flat property with only grazing on adjacent property 9) Clay sand natural barrier to leaching 10) Not visible from highway 11) All weather road leading to the facility form pavement 12) Internal road system complete 13) Privately owned property 14) Managed and operated by an environmental consulting firm 15) Approved for operation since 1999 16) Bonds in place – financial assurance active 17) Record keeping history – manifests and other reports The permitted property still has active cells # 1, #2, #3, #14 and #18 approved by the state inspector for the operation in the existing permitted 80 acres of east half of the 160 acres of the property. For the 1/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 past 19 years since property was permitted in 1999, CESI has used 14 cells (#4, #5, #6, #7, #8, #9, #10, #11, #12, #13, #15, #16, and #17) in the east 80 acres. The cells #10, #11 and #15 were transferred into Landfills in 2004, and the cell # 8 and #9 were also transferred in to Landfills in 2016, modification approved including cell #16 for the future use by the Division of Waste Management and Radiation Control (DWMRC) with approved financial assurance mechanism. And the rest of the cells will be modified and transferred into the landfill in the future as needed. In addition, CESI is planning to utilize 6 more cells in the Phase B area (24 acres of the west half side of 160 acres) for the landfarm which permit was once approved in 2001 and, yet, no E&P or other waste has been placed on the west 80 acres. The nearest small community is Aneth, Utah to the south some 20 miles, Montezuma Creek and White Mesa communities are located to the southwest some 30 miles from the Landfill site where surrounded by the Greater Aneth Field in San Juan County, Utah. The nearest sizeable community with standard services, is Blanding, Utah at 38 miles and Cortez, Colorado to the east and south at 41 miles. CESI main office is located at 925 S. Broadway, Suite 251, in Cortez, Colorado 81321. The Landfarm and Landfill operators are trained appropriately to operate the landfarm. Also, the manager is trained include certificates in Hazardous Waste Operations and Emergency Response, Asbestos Building Inspector, Asbestos Management Planner, Asbestos Contractor / Supervisor, and others. CESI has operated with new management for the Oil & Gas Landfarm and Class V Landfill since 2007. After the fully transferred to the new management in 2008, CESI has not received any Notice of Violation or warnings or adverse observation from DOGM nor DWMRC staff. The permitted facility has been inspected several times visually by DOGM staff and a few times by DWMRC staff each year in the past. (Inspection Reports are available) CESI has put effort to improve operation and facility each year and will continue to improve the facility and operations. In addition, CESI has excellent documentations and record keeping during operations. 2/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 I-2. Previous PermitsϭϵϵϵĂŶĚϮϬϬϭ 3/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 4/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 5/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 6/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 7/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 8/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 9/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 10/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 11/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 II. Detailed Site Description II-1. Function of the waste disposal facility The facility has been permitted for landfarm to utilize for the bioremediation of oil contaminated soils to breakdown hydrocarbon compounds. The entire operation is enclosed within a fence with one access gate and oily soils are farmed and composted within the cells designated for the purpose. Within the permitted 80 acres of the 160 acres, landfarm is divided in 18 sections (cells), approximately 4 acres per cell. Each cells has at least 2 feet berms around with 1 cut off section that are located in the highest point of the cell for the operator to be able to access for the monthly and other requirements. At least one cell (or more depends on the amount of incoming loads) are opened with 2 to 3 cut off sections to be able to unload truck loads with daily monitoring. Each truck loads are manifested with CESI Landfarm Soil Delivery Manifest as the arrivals with date and time waste was received, origin, volume, type, transporter and generator of the waste, and other information after loads are inspected for volume, type of waste and sufficiently free of liquid content by CESI operators. Within 72 hours of receipt of the waste, the wastes are spread and tilled in twelve-inch or less lifts in the active cell(s). Soils are turned regularly, a minimum of once a month. The most of cells are ripped with a dozer quarterly or more often as needed including unloading area. Each quarter, quarterly reports required and provided by the division are submitted. All the records are filed and kept in the main office of CESI located in 925 S. Broadway, Suite 251, Cortez, CO 81321 for inspection by the division for at least six years. The normal operating hours of the facility are Monday through Friday 9:00 am to 5:00 pm and closed on weekends and holidays with option of early openings and late closing hours. The facility has at least one employee during the operation hours with additional employee on call for safety and assistance matters. Each employee has cellular phone for communication and emergency contacts. 12/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 II-2. Current Facility Map 13/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 CESI Landfarm Location: San Juan County, UT 14/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 San Juan County, Utah CESI Landfarm Location: San Juan County, UT 15/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 Contract Environmental Services, Inc. Facility Location Utah / Colorado state border East and West 1/2, Northeast Quarter, Section 18, Township 39 South, Range 26 East San Juan County, Utah 16/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 Proposed Additional West Landfarm Area (Phase B) Current East Landfarm Area East and West 1/2, Northeast Quarter, Section 18, Township 39 South, Range 26 East San Juan County, Utah 17/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 Proposed Additional West Landfarm Area (Phase B) Current East Landfarm Area East and West 1/2, Northeast Quarter, Section 18, Township 39 South, Range 26 East San Juan County, Utah 18/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 Contract Environmental Services, Inc. Landfarm Facility Layout Entrance and Exit Gate Proposed additional 24 Acres (6 Cells) to utilize for Landfarm Additional West 80 Acres (Phase B) Current East 80 Acres East and West 1/2, Northeast Quarter, Section 18, Township 39 South, Range 26 East San Juan County, Utah Asbestos Landfill C/D Landfil Asbestos Landfill C/D Landfill Cell #1 Cell #2 Cell #3 Cell #6Cell #5 Cell #4 Cell #7 Cell #14 Cell #18 Cell #17 Cell #13 Cell #12 Cell #B18Cell #B17 Cell #B13Cell #B14 Cell #B12Cell #B11 19/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 Contract Environmental Services, Inc. Landfarm Facility Current Active Cells Entrance and Exit Gate Current active cells for landfarm (Cell #1, #2, #3, #14 and #18) East and West 1/2, Northeast Quarter, Section 18, Township 39 South, Range 26 East San Juan County, Utah Asbestos Landfill C/D Landfil Asbestos Landfill C/D Landfill Cell #1 Cell #2 Cell #3 Cell #6Cell #5 Cell #4 Cell #7 Cell #14 Cell #18 Cell #17 Cell #13 Cell #12 Cell #B18Cell #B17 Cell #B13Cell #B14 Cell #B12Cell #B11 20/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 II-3. Site descriptions annotated with facility infrastructure and associated function The site is located in southeastern San Juan County and is 1/2 mile north of the paved road which leads to Hovenweep National Monument. A portion of Hovenweep National Monument is approximately 1 mile southeast of the facility but is lower in elevation and the site cannot be seen from the monument. In this part of eastern San Juan County is Cretaceous age Dakota Sandstone. It is a light tan, nearly white, to light gray. The sands are medium brown to reddish brown and very clayey. The clays are of a good compacting nature making an overall moderately permeable soil. It is an area that is mostly flat mesa top land, with steep canyons that bisect the area where erosion has cut through the Dakota Sandstone into the Morrison formation. The facility is in an area that is mostly made up of broad flat- topped areas which are dissected by steep sided canyons. The canyons are seen where erosion has cut down through the Massive Dakota Sandstone and into the Morrison formation. The ladfarm facility is located on one of the higher flat areas and is stratigraphically about 100 feet above the top of the Dakota Sandstone. The closest of these canyons is to the west about one half mile, and it eventually intersects with Cross Canyon about two miles northwest of this site. It is partially covered with Sagebrush and is in soils which are a mixture of clays, silts, and some eolian sands. The surface formation is made up of interbedded shales and sandstones which are either the Base of the Mancos Shale or the top of the Dakota Formation. The site slopes gently from east to west across the entire area with about 20 feet of elevation difference from the high point on the north, to the low area on the south. There are only minor drainages that bisect the property from southwest to northeast. They are of such low relief that they pose no impact to the overall project and shall be farmed across as if they were not there. There are no surface water within a mile of the facility. There is a water seep within confines of the Monument, which exits at the base of the Dakota Sand south and west from the Ranger Station. The monument obtains its water from a well that produces from about 1,440 feet, and there is no known water within 1,000 feet of the surface. The noted seep does not actually flow water but is more of a wet puddle below the overhang. In relation to the landfarm the seep is about 150 feet stratigraphically lower than the surface at the landfarm site. There is no evidence of flowing water on the surface at the facility location. The previous owner stated that nearest ground water was at a depth of approximately 1,000 feet. The Ranger at Hovenweep stated, also, that the water used at their site was from a well which produced water at 1,600 feet. There is a small seep which is located in an overhand at the base of the Dakota Sandstone near the Ranger Station. The Ranger told that this seep does not flow and is only seen as a puddle under the overhang. This would be approximately 150 feet stratigraphically below the facility site. 21/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 There are no other points of diversion in the Division of Water Rights database within 12,000 feet of the facility, and the US Parks services is greater than 10,000 feet from the landfarm operation. The entire property of the 160 acres is fenced with one access gate and has 4 feet secondary berms inside along with the fence. The property is separated into 18 cells with at least 2 feet berms with access dirt road between the separations. And there is a 20 feet by 12 feet mobile shack in the center of the property which trucks check in before unloading the materials for documentation and visual inspections. Each truck loads are manifested with CESI Landfarm Soil Delivery Manifest as the arrivals with date and time waste was received, origin, volume, type, transporter and generator of the waste, and other information. Once the documents and inspections are completed, loads are specifically instructed to active cell(s) to unload by CESI operators. The active cell(s) are tested prior to use for TPH, SAR, and EC for the current contaminations. At least one active cell or more depends on the amount of incoming loads are opened with 2 to 3 cut off sections to be able to unload truck loads with daily monitoring. And the wastes are spread and tilled in twelve-inch or less lifts in the active cell(s) within 72 hours of receipt of the waste. The landfarm cell sections in the current phase are #1, #2, #3, #4, #5, #6, #7, #12, #13, #14, #17, and #18 that are turned regularly, a minimum of once a month. The cells #8, #9, #10, #11, #15, and #16 were transferred into Landfills for Asbestos and C/D (Construction and Demolition) waste that permits were approved by the State of Utah, Division of Waste Management and Radiation Control in 2005 and 2016. Other cells in current phase will be transferred into the landfills in the future as needed. Currently, active cells #1, #2, #3, #14 and #18 are approved to utilize for taking loads by the DOGM inspector after reviewing sample results. Cells #4, #5, #6, #7, #12, #13 and #17 in current phase will be processed for closure and the phase B will be constructed to add 6 more cells in 2018 or 2019 to be utilized for the landfarm with the Division’s approval. (Cell #B11, B12, B13, B14, B17 and B18) Referenced Documents: State Decision Document and Permit Statement of Basis 22/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 III. Contamination Assessment III-1. Description of existing contamination with sample results 㻞㻞㻜㻝㻟㻛㻞㻜㻝㻠㻌㻌 㻯㻯㼑㼘㼘㻌㻌 㻰㻰㼍㼠㼑㻌㻌 㼀㼀㻼㻴㻌㻌 㻰㻾㻻㻌 㻱㼄㼀㻌㻰㻾㻻㻌 㻳㻾㻻㻌 㻿㻿㻭㻾㻌㻌 㻱㻱㻯㻌㻌 㼙㼓㻛㼗㼓㻌 㼙㼓㻛㼗㼓㻌 㼙㼓㻛㼗㼓㻌 㼙㼓㻛㼗㼓㻌 㼡㼙㼔㼛㼟㻛㼏㼙㻌 㻝㻝㻌㻌 㻝㻝㻜㻛㻞㻠㻛㻝㻟㻌㻌 㻝㻝㻢㻟㻥㻌㻌 㻝㻟㻜㻜㻌 㻟㻟㻥㻌 䠘㻝㻜㻜㻌 㻞㻞㻜㻚㻡㻌㻌 㻝㻝㻡㻜㻜㻜㻌㻌 㻞㻞㻌㻌 㻝㻝㻜㻛㻝㻣㻛㻝㻠㻌㻌 㻤㻤㻠㻜㻌㻌 㻡㻜㻣㻌 㻟㻞㻟㻌 䠘㻝㻜㻌 㻝㻝㻡㻚㻝㻌㻌 㻝㻝㻞㻝㻜㻜㻌㻌 㻟㻟㻌㻌 㻝㻝㻜㻛㻝㻣㻛㻝㻠㻌㻌 㻡㻡㻥㻚㻤㻌㻌 㻟㻟㻚㻥㻌 㻝㻡㻚㻥㻌 䠘㻝㻜㻌 㻝㻝㻜㻚㻠㻌㻌 㻡㻡㻤㻝㻜㻌㻌 㻠㻠㻌㻌 㻣㻣㻛㻞㻠㻛㻝㻠㻌㻌 㻟㻟㻤㻞㻠㻌㻌 㻟㻜㻥㻜㻌 㻢㻝㻟㻌 㻝㻞㻝㻌 㻝㻝㻥㻚㻥㻌㻌 㻝㻝㻞㻜㻜㻜㻌㻌 㻡㻡㻌㻌 㻣㻣㻛㻞㻠㻛㻝㻠㻌㻌 㻣㻣㻜㻡㻌㻌 㻡㻤㻞㻌 㻝㻞㻟㻌 䠘㻡㻜㻌 㻝㻝㻡㻌㻌 㻥㻥㻤㻜㻜㻌㻌 㻢㻢㻌㻌 㻝㻝㻜㻛㻞㻠㻛㻝㻟㻌㻌 㻝㻝㻤㻟㻡㻌㻌 㻝㻠㻢㻜㻌 㻟㻣㻡㻌 䠘㻝㻜㻜㻌 㻝㻝㻡㻚㻤㻌㻌 㻝㻝㻢㻤㻜㻜㻌㻌 㻣㻣㻌㻌 㻝㻝㻜㻛㻝㻣㻛㻝㻠㻌㻌 㻣㻣㻠㻜㻚㻠㻌㻌 㻠㻣㻡㻌 㻞㻡㻠㻌 㻝㻝㻚㻠㻌 㻞㻞㻠㻚㻟㻌㻌 㻝㻝㻥㻤㻜㻜㻌㻌 㻤㻤㻌㻌 㻝㻝㻜㻛㻞㻠㻛㻝㻟㻌㻌 㻝㻝㻜㻟㻣㻌㻌 㻤㻠㻡㻌 㻝㻥㻞㻌 䠘㻝㻜㻌 㻠㻠㻞㻚㻞㻌㻌 㻤㻤㻜㻥㻜㻜㻌㻌 㻥㻥㻌㻌 㻣㻣㻛㻞㻠㻛㻝㻠㻌㻌 㻤㻤㻜㻠㻠㻌㻌 㻢㻢㻣㻜㻌 㻝㻝㻜㻜㻌 㻞㻣㻠㻌 㻞㻞㻠㻚㻝㻌㻌 㻞㻞㻝㻜㻜㻜㻌㻌 㻝㻝㻞㻌㻌 㻠㻠㻛㻟㻛㻝㻟㻌㻌 㻝㻝㻠㻡㻝㻚㻢㻌㻌 㻝㻝㻥㻜㻌 㻞㻝㻟㻌 㻠㻤㻚㻢㻌 㻝㻝㻢㻚㻞㻌㻌 㻝㻝㻡㻢㻜㻜㻌㻌 㻝㻝㻟㻌㻌 㻠㻠㻛㻟㻛㻝㻟㻌㻌 㻡㻡㻞㻤㻌㻌 㻠㻞㻜㻌 㻝㻜㻤㻌 䠘㻝㻜㻌 㻟㻟㻜㻚㻟㻌㻌 㻞㻞㻞㻝㻜㻜㻌㻌 㻝㻝㻠㻌㻌 㻤㻤㻛㻣㻛㻝㻟㻌㻌 㻠㻠㻣㻝㻠㻌㻌 㻟㻢㻠㻜㻌 㻥㻟㻟㻌 㻝㻠㻝㻌 㻝㻝㻞㻚㻣㻌㻌 㻝㻝㻞㻜㻜㻜㻌㻌 㻝㻝㻢㻌㻌 㻤㻤㻛㻣㻛㻝㻟㻌㻌 㻝㻝㻠㻥㻠㻌㻌 㻝㻜㻝㻜㻌 㻠㻤㻠㻌 䠘㻡㻜㻌 㻡㻡㻚㻟㻥㻌㻌 㻝㻝㻥㻝㻜㻌㻌 㻝㻝㻣㻌㻌 㻤㻤㻛㻣㻛㻝㻟㻌㻌 㻞㻞㻟㻟㻝㻌㻌 㻝㻣㻞㻜㻌 㻢㻝㻝㻌 䠘㻡㻜㻌 㻞㻞㻥㻚㻡㻌㻌 㻟㻟㻝㻤㻜㻜㻌㻌 㻝㻝㻤㻌㻌 㻠㻠㻛㻟㻛㻝㻟㻌㻌 㻠㻠㻥㻡㻌㻌 㻟㻠㻤㻌 㻝㻠㻣㻌 䠘㻝㻜㻌 㻝㻝㻡㻚㻝㻌㻌 㻝㻝㻝㻡㻜㻜㻌㻌 㻞㻞㻜㻝㻢㻌㻛㻌㻞㻜㻝㻣㻌㻌 㻯㻯㼑㼘㼘㻌㻌 㻰㻰㼍㼠㼑㻌㻌 㼀㼀㻼㻴㻌㻌 㻰㻾㻻㻌 㻱㼄㼀㻌㻰㻾㻻㻌 㻳㻾㻻㻌 㻿㻿㻭㻾㻌㻌 㻱㻱㻯㻌㻌 㼙㼓㻛㼗㼓㻌 㼙㼓㻛㼗㼓㻌 㼙㼓㻛㼗㼓㻌 㼙㼓㻛㼗㼓㻌 㼡㼙㼔㼛㼟㻛㼏㼙㻌 㻝㻝㻌㻌 㻟㻟㻛㻞㻞㻛㻝㻣㻌㻌 㻠㻠㻥㻢㻌㻌 㻟㻠㻟㻌 㻝㻠㻟㻌 䠘㻝㻜㻚㻜㻌 㻝㻝㻜㻚㻤㻌㻌 㻢㻢㻝㻣㻜㻌㻌 㻞㻞㻌㻌 㻟㻟㻛㻞㻞㻛㻝㻣㻌㻌 㻥㻥㻡㻚㻞㻌㻌 㻠㻤㻚㻡㻌 㻟㻢㻚㻣㻌 䠘㻝㻜㻚㻜㻌 㻤㻤㻚㻟㻟㻌㻌 㻠㻠㻣㻝㻜㻌㻌 㻟㻟㻌㻌 㻟㻟㻛㻞㻞㻛㻝㻣㻌㻌 㻠㻠㻜㻟㻌㻌 㻟㻜㻢㻌 㻤㻣㻌 䠘㻝㻜㻚㻜㻌 㻤㻤㻚㻥㻢㻌㻌 㻡㻡㻡㻠㻜㻌㻌 㻠㻠㻌㻌 㻝㻝㻝㻛㻝㻛㻝㻢㻌㻌 㻟㻟㻥㻜㻜㻌㻌 㻞㻤㻡㻜㻌 㻝㻜㻜㻜㻌 䠘㻡㻜㻚㻜㻌 㻞㻞㻞㻚㻡㻌㻌 㻝㻝㻟㻜㻜㻜㻌㻌 㻡㻡㻌㻌 㻝㻝㻝㻛㻝㻛㻝㻢㻌㻌 㻣㻣㻜㻣㻚㻠㻌㻌 㻡㻟㻠㻌 㻝㻠㻞㻌 㻟㻝㻚㻠㻌 㻝㻝㻢㻌㻌 㻝㻝㻜㻤㻜㻜㻌㻌 㻢㻢㻌㻌 㻣㻣㻌㻌 㻝㻝㻝㻛㻝㻛㻝㻢㻌㻌 㻢㻢㻣㻚㻣㻌㻌 㻟㻞㻚㻞㻌 㻞㻡㻚㻡㻌 䠘㻝㻜㻚㻜㻌 㻞㻞㻟㻚㻞㻌㻌 㻝㻝㻞㻟㻜㻜㻌㻌 㻝㻝㻞㻌㻌 㻥㻥㻛㻝㻛㻝㻢㻌㻌 㻡㻡㻡㻤㻌㻌 㻟㻤㻤㻌 㻝㻢㻜㻌 䠘㻝㻜㻚㻜㻌 㻝㻝㻢㻚㻝㻌㻌 㻝㻝㻜㻟㻜㻜㻌㻌 㻝㻝㻟㻌㻌 㻥㻥㻛㻝㻛㻝㻢㻌㻌 㻝㻝㻡㻜㻠㻌㻌 㻝㻜㻠㻜㻌 㻠㻡㻠㻌 䠘㻝㻜㻚㻜㻌 㻝㻝㻢㻚㻥㻌㻌 㻝㻝㻜㻢㻜㻜㻌㻌 㻝㻝㻠㻌㻌 㻡㻡㻛㻞㻢㻛㻝㻢㻌㻌 㻢㻢㻝㻤㻌㻌 㻠㻣㻝㻌 㻝㻟㻣㻌 䠘㻝㻜㻚㻜㻌 㻣㻣㻚㻟㻡㻌㻌 㻢㻢㻜㻤㻜㻌㻌 㻝㻝㻢㻌㻌 㻡㻡㻛㻞㻢㻛㻝㻢㻌㻌 㻣㻣㻜㻣㻜㻌㻌 㻡㻤㻞㻜㻌 㻝㻜㻥㻜㻌 㻝㻢㻜㻌 㻝㻝㻝㻚㻟㻌㻌 㻝㻝㻜㻞㻜㻜㻌㻌 㻝㻝㻣㻌㻌 㻡㻡㻛㻞㻢㻛㻝㻢㻌㻌 㻢㻢㻣㻣㻌㻌 㻠㻢㻡㻌 㻞㻜㻞㻌 䠘㻝㻜㻚㻜㻌 㻝㻝㻝㻚㻟㻌㻌 㻝㻝㻜㻞㻜㻜㻌㻌 㻝㻝㻤㻌㻌 㻥㻥㻛㻝㻛㻝㻢㻌㻌 㻝㻝㻣㻤㻜㻌㻌 㻝㻝㻢㻜㻌 㻢㻝㻜㻌 䠘㻝㻜㻚㻜㻌 㻝㻝㻠㻚㻥㻌㻌 㻤㻤㻜㻠㻜㻌㻌 㻱㻯㻌㻝㻘㻜㻜㻜㻌㼡㼙㼔㼛㼟㻛㼏㼙㻌㻩㻌㻝㻌㼙㼙㼔㼛㼟㻛㼏㼙㻌 㻰㻾㻻㻌㻔㻰㼕㼑㼟㼑㼘㻌㻾㼍㼚㼓㼑㻌㻻㼞㼓㼍㼚㼕㼏㻕㻌㻩㻌㻰㻾㻻䠚㻯㻝㻜㻙㻯㻞㻤㻌 㻱㼄㼀㻌㻱㻾㻻㻌㻔㻻㼕㼘㻌㻾㼍㼚㼓㼑㻕㻌㻩㻌㻱㼄㼀㻌㻰㻾㻻䠚㻯㻞㻤㻙㻯㻟㻡㻌 㻳㻾㻻㻌㻔㻳㼍㼟㼛㼘㼕㼚㼑㻌㻾㼍㼚㼓㼑㻌㻻㼞㼓㼍㼚㼕㼏㻕㻌㻩㻌㻳㻾㻻㻌㻯㻢㻙㻯㻝㻜㻌 23/138 Sundry Number: 88231 File: Description of Contamination RECEIVED:May. 25, 2018 III-2. Proposed monitoring/remediation CESI may require generator for soil analysis for TPH, SAR, EC and others for contamination of the soil prior for arrival. Visual inspections at the time of arrival for volume and free liquids. There are no vacuum trucks, tankers, or other tank vessels allowed for unloading the waste to this facility. Moisture and pH monitoring are required by DAQ. 8oz soil sample is taken for each initial location of the waste origin every two weeks and composited for TPH testing every month to monitor overall TPH level for the application. Samples are composited into one sample for TPH analysis each month. Each applied loads are required to till every week for a month after the oil is spread and tilled within 72 hours by DAQ in addition to the monthly requirement by DOGM for remediation. Normal weekly and monthly remediation are tilled with a dragging devise with 12 inch teeth that is pulled by a frontend loader for up to 12 inches. All permitted cells excluding landfill cells are tilled monthly until closure plans are in progress. Every quarter or more often, the cells are ripped with a dozer with 20 inch ripper if necessary. Weekly and Monthly Landfarm Cells Maintenance Reports are recorded for each required activities. All of these monitoring are recorded and available for the state inspectors for review. III-3. Proposed practices to prevent further contamination Once the waste loads are spread out evenly up to 12 inches within 72 hours in the active cell(s), the soils are tilled monthly until further testing for TPH, EC, and SAR to review by DOGM inspector for additional lifts. Each landfarm cell, takes average of 24 months before the additional lifts from the past 10 year experience. Each loads are recorded in the Landfarm Soil Delivery Manifest with date and time waste was received, origin, volume, type, transporter and generator of the waste, and other information to keep track of the active cell(s). An 8oz samples for each waste origin location are collected for TPH to monitor overall contamination. Samples are composited and sent to an accredited lab for TPH analysis monthly. Application of the soil in the active cell(s) are up to 12 inches throughout the cell and remediation process starts immediately 72 hours after the application to meet the DOGM cleanup level. The applied loads are tilled weekly for a month and monthly remediation continues until additional lifts are approved by the division. Closure plans begin in progress if any cells are no longer capable for the additional lifts any time after cells are tested for TPH, SAR, and EC to eliminate further contamination. Weekly and Monthly Landfarm Cells Maintenance Reports are recorded for each required activities. All the remediating cells have at least 2 feet berms to prevent storm water runoff with one cut off access point in the highest corner for monthly operation. Furthermore, the facility has UPDES Storm Waster Industrial Permit No. UTR000713 and DAQ Air Quality Permit Approval Order No. N15565-0001 approved by State of Utah Department of Environmental Quality for additional permits. 113/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 IV. Equipment Assessment IV-1. Description and assessment of equipment located at the facility The landfarm facility utilize a frontend loader to spread and drag a tilling devise for soil remediation for daily, weekly and monthly operations. A dozer with 20 inch ripper for further remediation that may occur quarterly. These equipment are maintained by experienced mechanics every 500 hours. There are no other operational equipment at the facility. V. Practices Assessment Normal weekly and monthly remediation are tilled with a dragging devise with 12 inch teeth that is pulled by a frontend loader for up to 12 inches. The teeth of dragger are repaired and replaced periodically. Each quarter or more often, the cells are ripped with a dozer with 20 inch ripper to improve efficiency of operations if necessary. Rocks, liners, trash and other debris that may resist remediation process are monitored and removed periodically to improve the process. After 12 inches are applied to the designated cells, TPH, SAR, and EC are tested for contaminations before the additional lifts to prevent or reduce probability of future contaminations. Landfarm Soil Manifest, Weekly and Monthly Landfarm Cells Maintenance Reports are recorded for each required activities. VI. Monitoring Program Once the loads arrive at the landfarm, operators perform visual inspections at the time of arrival for type of soil, volume and free liquids. There are no vacuum trucks, tankers, or other tank vessels allowed for unloading the waste to this facility. All the loads are recorded with Landfarm Soil Delivery Manifests prior to the application. 8oz soil sample is taken and recorded for each initial location of the waste origin every two weeks and composited for TPH testing every month in addition of monitoring and recording moisture and pH level each load that are required by DAQ. Each loads applied in the active cell(s) are required to till every week by DAQ in addition to the monthly requirement by DOGM for remediation after the 72 hours requirement. Weekly and Monthly Landfarm Cells Maintenance Reports are recorded for each required activities. And quarterly reports are filled to the Division each quarter. Composite samples are taken each cells for TPH, SAR and EC for analysis to determine contaminations before the additional lifts. All of these monitoring are recorded and available for the state inspectors for review. 114/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Attachments Monitoring Program and Documents 115/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 㻭㻭㼏㼠㼕㼢㼕㼠㼕㼑㼟㻛㻾㼑㼝㼡㼕㼞㼑㼙㼑㼚㼠㼟 㻰㼛㼏㼡㼙㼑㼚㼠㼟 㻰㼍㼥㻌㻝 㻾㼑㼏㼑㼕㼢㼕㼚㼓 㻹㼍㼚㼕㼒㼑㼟㼠 㻰㼍㼠㼑 㼂㼛㼘㼡㼙㼑 㻰㼡㼙㼜㻌㼛㼚㻌㼟㼡㼞㼒㼍㼏㼑 㻰㻭㻽㻌㻹㼛㼚㼕㼠㼛㼞㼕㼚㼓㻌㻲㼛㼞㼙 㼃㼍㼠㼑㼞㻌㻯㼛㼚㼠㼑㼚㼠 㼜㻴 㻿㼍㼙㼜㼘㼑 㻰㼍㼥㻌㻟 㻭㼜㼜㼘㼕㼏㼍㼠㼕㼛㼚 㻰㼍㼕㼘㼥㻌㻾㼑㼜㼛㼞㼠 㼛㼞㻌㼎㼑㼒㼛㼞㼑 㻰㼍㼠㼑㻌㼛㼒㻌㼠㼞㼑㼍㼠㼙㼑㼚㼠 㻰㼍㼥㻌㻡 㼃㼑㼑㼗㼘㼥㻌㼠㼞㼑㼍㼠㼙㼑㼚㼠 㻯㼑㼘㼘㻌㻹㼍㼕㼚㼠㼑㼚㼍㼚㼏㼑㻌㻾㼑㼜㼛㼞㼠 㼑㼢㼑㼞㼥 㻰㼍㼠㼑㻌㼛㼒㻌㼠㼞㼑㼍㼠㼙㼑㼚㼠 㼣㼑㼑㼗㼘㼥 㻲㼞㼕㼐㼍㼥 㻰㼍㼥㻌㻝㻞 㼃㼑㼑㼗㼘㼥㻌㼠㼞㼑㼍㼠㼙㼑㼚㼠 㻯㼑㼘㼘㻌㻹㼍㼕㼚㼠㼑㼚㼍㼚㼏㼑㻌㻾㼑㼜㼛㼞㼠 㼑㼢㼑㼞㼥 㻰㼍㼠㼑㻌㼛㼒㻌㼠㼞㼑㼍㼠㼙㼑㼚㼠 㼣㼑㼑㼗㼘㼥 㻲㼞㼕㼐㼍㼥 㻰㼍㼥㻌㻝㻥 㼃㼑㼑㼗㼘㼥㻌㼠㼞㼑㼍㼠㼙㼑㼚㼠 㻯㼑㼘㼘㻌㻹㼍㼕㼚㼠㼑㼚㼍㼚㼏㼑㻌㻾㼑㼜㼛㼞㼠 㼑㼢㼑㼞㼥 㻰㼍㼠㼑㻌㼛㼒㻌㼠㼞㼑㼍㼠㼙㼑㼚㼠 㼣㼑㼑㼗㼘㼥 㻲㼞㼕㼐㼍㼥 㻰㼍㼥㻌㻞㻢 㼃㼑㼑㼗㼘㼥㻌㼠㼞㼑㼍㼠㼙㼑㼚㼠 㻯㼑㼘㼘㻌㻹㼍㼕㼚㼠㼑㼚㼍㼚㼏㼑㻌㻾㼑㼜㼛㼞㼠 㼑㼢㼑㼞㼥 㻰㼍㼠㼑㻌㼛㼒㻌㼠㼞㼑㼍㼠㼙㼑㼚㼠 㼣㼑㼑㼗㼘㼥 㻲㼞㼕㼐㼍㼥 㻰㼍㼥㻌㻟㻜 㻹㼛㼚㼠㼔㼘㼥㻌㼠㼞㼑㼍㼠㼙㼑㼚㼠 㻯㼑㼘㼘㻌㻹㼍㼕㼚㼠㼑㼚㼍㼚㼏㼑㻌㻾㼑㼜㼛㼞㼠 㼑㼢㼑㼞㼥㻌 㼙㼛㼚㼠㼔㼘㼥 㼙㼛㼚㼠㼔 㻰㼍㼥㻌㻟㻜 㻿㼍㼙㼜㼘㼑㻌㻭㼚㼍㼘㼥㼟㼕㼟 㻯㻻㻯 㼑㼢㼑㼞㼥㻌 㻝㻜㻌㼐㼍㼥㻌㼠㼡㼞㼚㻌㼍㼞㼛㼡㼚㼐 㼑㼚㼐㻌㼛㼒 㼙㼛㼚㼠㼔 㻰㼍㼥㻌㻠㻜 㻭㼚㼍㼘㼥㼦㼑㻌㻿㼍㼙㼜㼘㼑㻌㻾㼑㼟㼡㼘㼠㻌㼍㼚㼐㻌㻯㼍㼘㼏㼡㼘㼍㼠㼕㼛㼚 㻭㼚㼍㼘㼥㼟㼕㼟㻌㻾㼑㼜㼛㼞㼠㻌㼒㼞㼛㼙㻌㼘㼍㼎 㻣㻌㼠㼛㻌㻝㻜 㻮㼡㼟㻚㻌㻰㼍㼥㼟 㻰㼍㼥㻌㻠㻞 㻯㼛㼙㼜㼘㼑㼠㼑㻌㼙㼛㼚㼠㼔㼘㼥㻌㼏㼍㼘㼏㼡㼘㼍㼠㼕㼛㼚 㻿㼜㼞㼑㼍㼐㻌㻿㼔㼑㼑㼠 㻝㻞㼠㼔㻌㼐㼍㼥 㼛㼒㻌㼚㼑㼤㼠 㼙㼛㼚㼠㼔 㻻㼠㼔㼑㼞㻌㻹㼛㼚㼕㼠㼛㼞㼕㼚㼓㻌㻭㼏㼠㼕㼢㼕㼠㼕㼑㼟 㻾㼍㼕㼚㼒㼍㼘㼘 㻰㼍㼕㼘㼥㻌㻾㼑㼜㼛㼞㼠 㻭㼐㼐㼕㼠㼕㼛㼚㼍㼘㻌㻭㼜㼜㼘㼕㼏㼍㼠㼕㼛㼚 㻯㼑㼘㼘㻌㻹㼍㼕㼚㼠㼑㼚㼍㼚㼏㼑㻌㻾㼑㼜㼛㼞㼠 㼃㼑㼍㼠㼔㼑㼞㻌㻛㻌㻯㼛㼚㼐㼕㼠㼕㼛㼚㼟 㻰㼍㼕㼘㼥㻌㻾㼑㼜㼛㼞㼠 㻯㻱㻿㻵㻌㻻㼜㼑㼞㼍㼠㼕㼛㼚㻌㻲㼘㼛㼣㻌㼒㼛㼞㻌㻰㻭㻽㻌㼞㼑㼝㼡㼕㼞㼑㼙㼑㼚㼠 116/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Sundry Number: 88231 File: Description of Equipment 㻰㻰㼍㼠㼑 㻹㼍㼚㼕㼒㼑㼟㼠㻌㻏 㼃㼍㼠㼑㼞㻌㻯㼛㼚㼠㼑㼚㼠 㼜㻴 㻿㼍㼙㼜㼘㼑㻌㻏 㻯㼑㼘㼘㻌㻏 㻺㼛㼠㼑㼟 㻰㻭㻽㻌㻹㼛㼚㼕㼠㼛㼞㼕㼚㼓㻌㻾㼑㼏㼛㼞㼐 118/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 㻻㻻㼜㼑㼞㼍㼠㼛㼞㻌㻺㼍㼙㼑㻦 㻰㼍㼠㼑㻦 㼃㼃㼑㼍㼠㼔㼑㼞㻛㻿㼕㼠㼑㻌㻯㼛㼚㼐㼕㼠㼕㼛㼚㼟 㻾㼍㼕㼚㻌㻛㻌㻿㼚㼛㼣㻌㻲㼍㼘㼘㼟㻌 㻌㼕㼚㼏㻚 㼀㼕㼙㼑 㻹㼍㼚㼕㼒㼑㼟㼠㻏 㼅㻰 㻰㼍㼠㼑 㼃㼛㼞㼗㼑㼐 䐟 䐠 䐡 䐢 䐣 䐤 䐥 䐦 䐧 䐨 䐩 䐪 䐫 䐬 䐭 䐮 䐯 䐰 䐱 䐲 䞡 䞢 䞣 䞤 䞥 䞦 䞧 䞨 䞩 䞪 㼃㼛㼞㼗㼕㼚㼓㻌㻯㼛㼚㼐㼕㼠㼕㼛㼚㼟㻌㼑㼠㼏㻚 㻯㼑㼘㼘㼟㻌㼣㼛㼞㼗㼑㼐㻌㼛㼚㻌㼠㼛㼐㼍㼥 㻭㻭㼏㼠㼕㼢㼕㼠㼕㼑㼟㻌㻼㼘㼍㼚㼚㼑㼐㻌㼒㼛㼞㻌㼠㼛㼙㼛㼞㼞㼛㼣 㻺㼛㼠㼑㼟㻌㻒㻌㻯㼛㼙㼙㼑㼚㼠㼟 㻸㼛㼍㼐㼑㼞 㻴㼛㼡㼞㼟 㻲㼡㼑㼘 㻰㼛㼦㼑㼞 㻟㻜㻜㻌㻳㼍㼘㼘㼛㼚㻌㻲㼡㼑㼘㻌㼀㼍㼚㼗㻌㻳㼍㼡㼓㼑 㼃㼛㼞㼗㻌㻰㼑㼠㼍㼕㼘㼟 㻰㼕㼟㼗㻛㼠㼕㼘㼘㻌㻌㻏 㻴㼛㼡㼞㼟 㻰㼞㼍㼓㻌㻏 㻯㼛㼢㼑㼞㻌㻏 㻾㼕㼜㻌㻏 㻻㼠㼔㼑㼞 㻲㼡㼑㼘 㻝㻤 㻝㻡 㻝㻠 㻝㻟 㻝㻢 㻝㻣 㻝㻞 㻥 㻤 㻣 㻝㻜 㻝㻝 㻟 㻞 㻝 㻠 㻡 㻢 㻞㻦㻜㻜㻌㻼㻹 㻟㻦㻜㻜㻌㻼㻹 㻠㻦㻜㻜㻌㻼㻹 㻡㻦㻜㻜㻌㻼㻹 㻭㼒㼠㼑㼞㻌㻡㻦㻜㻜㻌㼜㼙 㻝㻦㻜㻜㻌㻼㻹 Contract Environmental Services, Inc. Site Daily Activity Report 㼀㼕㼙㼑㻌㻛㻌㻭㼏㼠㼕㼢㼕㼠㼕㼑㼟㻌㻛㻌㼂㼕㼟㼕㼠㼛㼞㼟 㼀㼞㼡㼏㼗㼕㼚㼓㻌㻯㼛㼙㼜㼍㼚㼥㻛㼀㼞㼡㼏㼗㻌㻏 㻹㼍㼠㼑㼞㼕㼍㼘 㻮㼑㼒㼛㼞㼑㻌㻤㻦㻜㻜㻌㼍㼙 㻱㼚㼠㼑㼞 㻏 㻴㼑㼞㼑 㻤㻦㻜㻜㻌㻭㻹 㻥㻦㻜㻜㻌㻭㻹 㻝㻜㻦㻜㻜㻌㻭㻹 㻝㻝㻦㻜㻜㻌㻭㻹 㻝㻞㻦㻜㻜㻌㻼㻹 119/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Cell #Operator Year Month Week Date 㻼㼘㼑㼍㼟㼑㻌㼙㼍㼞㼗㻌㼍㼜㼜㼘㼕㼏㼍㼠㼕㼛㼚㻌㼍㼞㼑㼍㻌㼍㼚㼐㻌㼐㼍㼠㼑㻚 㻖㻼㼘㼑㼍㼟㼑㻌㼚㼛㼠㼑㻌㼍㼚㼥㻌㼍㼐㼐㼕㼠㼕㼛㼚㼍㼘㻌㼍㼜㼜㼘㼕㼏㼍㼠㼕㼛㼚㻌㼕㼚㻌㼐㼑㼠㼍㼕㼘㼟㻚㻌㻔㻭㼞㼑㼍㻘㻌㻽㼀㼅㻘㻌㻹㼍㼠㼑㼞㼕㼍㼘㻘㻌㼑㼠㼏㻚㻕 Notes: 㻻㼜㼑㼞㼍㼠㼛㼞㻌㻿㼕㼓㼚㼍㼠㼡㼞㼑 CESI Landfarm Cells Weekly Maintenance Report 120/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Cell #Operator Year Month Date 㻖 㻼㼘㼑㼍㼟㼑㻌㼚㼛㼠㼑㻌㼍㼚㼥㻌㼚㼛㼠㼕㼏㼑㼎㼘㼑㻌㼕㼟㼟㼡㼑㼟㻚㻌㻻㼕㼘㼥㻌㼍㼞㼑㼍㻘㻌㼞㼛㼏㼗㼟㻘㻌㼔㼡㼙㼜㼟㻘㻌㼣㼑㼑㼐㼟㻘㻌㼑㼠㼏㻚 Sample Date:For DOGM Sample Result: TPH SAR EC Notes: 㻻㼜㼑㼞㼍㼠㼛㼞㻌㻿㼕㼓㼚㼍㼠㼡㼞㼑 CESI Landfarm Cells Monthly Maintenance Report 121/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Year #1 #2 #3 #4 #5 #6 #7 #8 #9 January Februrary March April May June July August September October November December #10 #11 #12 #13 #14 #15 #16 #17 #18 January Februrary March April May June July August September October November December *Please write date and operator's initial. Contract Environmental Services, Inc. Landfarm Cells Maintenance Log 122/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 VII. Estimating Closure Cost and Bonding Evaluation Third Party Closure and Post Closure Plan by Envirotech, Inc. 123/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 124/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 TABLE OF CONTENTS 1. Introduction ……………………………………………………………………….1 2. Closure Notifications ……………………………………………………………..1 2.1 Closure Activities by Tasks ……………………………………………………... 1 3. Cost-Estimate to perform all Tasks ………………………………………………3 4. Limitations ………………………………………………………………………..3 5. Conclusion………………………………………………………………………...3 Figures: Figure A, Facility Location Figure B, Site Diagram 125/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 1. Introduction Contract Environmental Services Landfarm facility is located in southeast Utah near the Hovenweep National Monument. The facility location is Section 18, Township 29N, Range 26E; see Figure A, Facility Location. The facility is permitted through the State of Utah Division of Natural Resources Oil, Gas and Mining. The facility is divided into two separate facilities, the landfarm facility which consists of approximately 50 acres and a landfill facility which consists of approximately 30 acres. The Landfill portion of the facility is permitted through the State of Utah Division of Solid and Hazardous Waste. The following plan discusses the closure and post closure plan for Contract Environmental Services’ Landfarm portion of the facility only. Closure of the Landfill portion is handled under a separate closure bond as specified in that permit. Closure and closure cost for the Landfarm portion are based on applicable sections of Utah Administrative Code R649-3 and R649-9 for Waste Management and Disposal Facilities. 2. Closure Notifications Closure requests and activities will be determined and delegated by the Utah Division of Oil, Gas and Mining. 2.1.Closure by Contractor per Tasks Task 1. Remediation of Contamination Based on the current operation of the landfarm facilities it is anticipated that at any one time only one to two cells will be in use at one time. Since remediation times can vary widely for the type of material that is received, costs for the remediation after the facility stops accepting waste will be difficult to predict. As of the date of this estimate there are two cells that currently do not meet the regulated limits set forth in Utah Administrative Code R649-3 and R649-9 for DROmax only. These limits are also specified in Table 1 below. x Since the cells appear to meet the TPH limit of 10,000 mg/kg no additional remediation is necessary. Based on the analytical data provided for the remediation cells in the most recent sampling event in 2016/2017 Envirotech has included the cost to sample only the two (2) active cells of the landfarm and has assumed for the purposes of bonding that the other 11 cells are below the regulatory threshold. Since the need for additional remediation would be based on the sample results no cost for additional remediation are included in this estimate for disking and turning the cells. Table 1. Soil Remediation Standards per Code R649-3 and R649-9 Constituents Remediated Level GROmax <1,000 mg/kg DROmax <2,000 mg/kg TPH (GRO+DRO+ORO) < 10,000 mg/kg Electrical Conductivity <4 mmho/cm ESP <15% SAR <12 126/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Task 2. Removal of Infrastructure For the purposes of this cost estimate, Envirotech is not anticipating any infrastructure from this facility. It is assumed that the facility will need to continue to operate as a landfill and will need the office building and partial road infrastructure to operate. In addition, the fence and any of the exterior berms will need to stay in place to prevent unauthorized access and control run-on and run-off from the facility. The fence will also serve a beneficial purpose to allow the seed and vegetation to get re- established. Task 3. Earthwork and Grading For the purposes of this cost estimate and closure plan the length of the berms was estimated using Google Earth aerial imagery. Based on the measurements of the aerial there is an estimated 17,500 linear feet of berm surrounding the 13 cells of the landfarm. In addition, there is approximately 15,000 linear feet of roadway which allows access to the landfarm cells. Envirotech has included a third part cost estimate (T&M Dirtworks) in this closure estimate for the equipment and personnel to level the berms from the landfarm cells and rip/scarify the roadways to get the facility ready to seed. It is assumed that any exterior berm around the facility will remain in place to prevent run-on and run-off from the facility. The external berm around the fence will also prevent erosion on the facility while the vegetation is being established. Task 4. Re-seeding Upon meeting closure standards, the site will be re-seeded with a salt tolerant seed mix to re- establish vegetation on the site. Cost to re-seed 50 acres has been prepared by Coal Bed Creek Construction and included in the cost estimate. In addition, a seed quote has been prepared by Southwest Seed Inc. Task 5. Post closure The cost for post closure care will be for semi-annual visits to the site to check on the status of the revegetation of the landfarm areas. Included in this cost is mobilization to and from the site, onsite time to photograph the revegetation status and reporting on the findings. The estimate is for 1-year of total post closure visits or a total of two visits. 127/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 3. Cost-Estimate to Perform all the above-mentioned tasks Estimated Cost to Perform Task 1………………………………………………..…..$1,180.00 Estimated Cost to Perform Task 2…………………………………………….................. $0.00 Estimated Cost to Perform Task 3…………………………………………………....$3,000.00 Estimated Cost to Perform Task 4…………………………………………………....$5,076.25 Estimated Cost to Perform Task 5……………………………………………………$2,360.00 Total Estimated Cost to Perform the above-mentioned tasks……………………$11,616.25 **NOTE** In the event that Envirotech is contacted to conduct any of the tasks mentioned a formal job walk and proposal will be provided to cover a more accurate estimate. 4. Limitations 1.This price assumes soil in the cells will be completely remediated at the time the landfarm ceases operation and no remediation will be required. 2.No surface equipment (buildings etc.) will be removed. 3.The fencing and exterior berms around the facility will remain intact for erosion and limiting access. 4.The area to re-seed is only 50 acres and additional re-seeding is not included for areas having difficulty establishing re-vegetation. 5.Post closure activities are limited to site visits on a semi-annual basis for the period of one year regardless if the site has achieved the required revegetation percentage. 5. Conclusion Any changes to this closure and post closure plan, financial assurance secured, or other items that may trigger changes to this plan will be made and brought to the division’s attention. Contractor will work with the division to secure enough money and complete the appropriate closure and post closure activities for this landfarm facility. 128/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Contract Environmental Services Facility Location GPS Coordinates of Landfarm facility: 37.400087° N, -109.098160° W 129/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Contract Environmental Services Site Diagram Contract Environmental Services 130/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Cost Break down 131/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 㻻㻻㼜㼑㼞㼍㼠㼛㼞㻦㻌㻯㼛㼚㼠㼞㼍㼏㼠㻌㻱㼚㼢㼕㼞㼛㼚㼙㼑㼚㼠㼍㼘㻌㻿㼑㼞㼢㼕㼏㼑㼟㻘㻌㻵㼚㼏㻚 㻰㼍㼠㼑㻦㻌 㻡㻛㻞㻠㻛㻞㻜㻝㻤 㻲㼍㼏㼕㼘㼕㼠㼥㻦㻌㻯㼛㼚㼠㼞㼍㼏㼠㻌㻱㼚㼢㼕㼞㼛㼚㼙㼑㼚㼠㼍㼘㻌㻿㼑㼞㼢㼕㼏㼑㼟㻘㻌㻵㼚㼏㻚 Number of Acres to be Reclaimed 50.00 Contamination Remediation Cost Estimates $1,180.00 Removal of Infrastructure Costs Estimates $0.00 Earthwork and Grading Cost Estimates $3,000.00 Revegetation Cost Estimates $5,076.25 Post Closure Cost Estimates $2,360.00 㼀㼀㼛㼠㼍㼘㻌㻯㼛㼟㼠㻌㻱㼟㼠㼕㼙㼍㼠㼑 㻐㻝㻝㻘㻢㻝㻢㻚㻞㻡 (Increase above total cost estimate by 26.8% if indirect costs are not included) $3,113.16 㼀㼀㼛㼠㼍㼘㻌㻾㼑㼏㼘㼍㼙㼍㼠㼕㼛㼚㻌㻯㼛㼟㼠㻌㻾㼑㼝㼡㼕㼞㼑㼐 㻐㻝㻠㻘㻣㻞㻥㻚㻠㻝 㻮㼛㼚㼐㻌㻼㼛㼟㼠㼑㼐 㻐㻝㻜㻘㻜㻜㻜㻚㻜㻜 Difference Between Cost Estimate and Bond -$4,729.41 㻲㻲㼕㼢㼑㻌㼅㼑㼍㼞㻌㻱㻒㻼㻌㼃㼍㼟㼠㼑㻌㻰㼕㼟㼜㼛㼟㼍㼘㻌㻲㼍㼏㼕㼘㼕㼠㼥㻌㻮㼛㼚㼐㻌㻯㼍㼘㼏㼡㼘㼍㼠㼕㼛㼚㻌㻿㼡㼙㼙㼍㼞㼥㻌㻲㼛㼞㼙 㻰㻰㼕㼞㼑㼏㼠㻌㼍㼚㼐㻌㻵㼚㼐㼕㼞㼑㼏㼠㻌㻯㼛㼟㼠㼟 㻵㼒㻌㼥㼛㼡㻌㼔㼍㼢㼑㻌㼝㼡㼑㼟㼠㼕㼛㼚㼟㻌㼍㼎㼛㼡㼠㻌㼠㼔㼕㼟㻌㼒㼛㼞㼙㻌㼜㼘㼑㼍㼟㼑㻌㼏㼛㼚㼠㼍㼏㼠㻌㻮㼑㼢㻌㼃㼕㼟㼑㼞㻌㼍㼠㻌㻤㻜㻝㻙㻡㻟㻤㻙㻡㻟㻠㻢㻌㼛㼞 㼑㼙㼍㼕㼘㻌㼎㼠㼣㼕㼟㼑㼞㻬㼡㼠㼍㼔㻚㼓㼛㼢㻚 132/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Appendix: Third Party Cost Estimates 133/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 4 !#&!"9: : :'+,/. "9 2+-,2 #4!#&!"5(: 31*63.06-,-+6(8" 31*63.06/-..6 8" 31*61-3630,*7$"#8" !""$###;#!#%!#  ;("5#!#%: ;2/26.*+6-32/ !(!"#!!#!""!(#!!!!#: #"$; #( $# '%#+1/**#!"!+/***#!#!!"$!! !#: <" $#$"#(! $#:!##( $# "! $!#&#$#: <  $!!#"&"$(&!: <!##" #("$!&"$$! $"#: &!""$!##""9#%&!# !!!&##"#""$### "$"##&!!!#"$)-***: (#!#!%#!%"#"%%'#!"#"9& '$#($&!##!!"9&'#!!%! %#"##:!#"!##$"#!"9#"9! ("($!#!: "#$("$##(4 !#&!"9: 134/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Phon FAX: COMPANY: DATE: INVO CUSTOMER:MIX ADDRESS: PHONE: P.O. # ALT: 50 A SHIPPING: FAX: TOTA ACRES UPS: CPU: DEL:CREDIT CARD INFO %LOT #PLS% PER/ ACRE TOTAL #COST PER/ ACRE TOT 1 05 2 0 3 05 4 03.5 5 01.5 6 0 7 0 8 0 9 0 10 0.0 0 TOTALS 00 15 3.81$ *** QUOTES VALID FOR 30 DAYS FROM DATE OF ISSUE COST/BLK # COST/PLS # TALL FESCUE SLENDER WHEATGRASS ALKALI GRASS RUSSIAN WILDRYE STRAWBERRY CLOVER PLS BU SPECIES TALL WHEATGRASS YOSHI ALKALI SEED858-401-3985 yoshi@contractenv.com SOUTHWEST SEED INC. MIX: ORDER / QUOTE CONTRACT ENVIRONMENTAL 2018/5/18 PROJECT ID: 135/138 Sundry Number: 88231 File: Description of Equipment REC 136/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 VIII. Plans for Reclaiming Current Cells and Phase B Expansion Cells CESI is planning an expansion of the landfarm cells to add 24 acres to operate 6 more cells as beginning of Phase B in the west 160 acres with the Division’s approval. (Cell #s B11, B12, B13, B14, B17, and B18) Furthermore, CESI will begin closure process for 7 cells total of 28 acres (cell #4, #5, #6, #7, #12, #13, and #17) in the current operating 50 acre landfarm area. As soon as the Phase B cells are approved to operate, closure process will begin based on the closure and post closure plan. Facility will have 11 active cells which totals of 44 acres and 7 reclaiming cells total of 28 acres in the west and east 160 acres. Access roads remain the same to be able to access the current active landfarm cells and landfill cells at this time. Proposed Total Bond Calculation for the Reclaiming and Phase B Expansion Based on the Third Party Closure and Post Closure Plan Total Bond Calculation Estimate for Current 13 Cells (50 Acres) ……..…. $14,729.41 Average Estimate per Cell (4 Acres per cell)………..…………………….….……… $1,178.36 6 Proposed Expansion Cells …………………………………………….…………….…….. $7,070.16 5 Current Active Cells …………………………………………………………….….………... $5,891.80 Total 11 Operating Cells (44 acres) ……………………………….……………….… $12,961.96 137/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 2018 Contract Environmental Services, Inc. Landfarm Facility Plans for Reclaiming Current Cells and Phase B Expansion Cells Proposing to reclaim (Cell #4, #5, #6, #7, #12, #13, and #16) Currently approved for landfarm (Cell #1, #2, #3, #14, and #18) East and West 1/2, Northeast Quarter, Section 18, Township 39 South, Range 26 East San Juan County, Utah Cell #13 Asbestos Landfill C/D Landfil Asbestos Landfill C/D Landfill Cell #1 Cell #2 Cell #3 Cell #6Cell #5 Cell #4 Cell #7 Cell #14 Cell #18 Cell #17 Cell #12 Cell #B18Cell #B17 Cell #B13Cell #B14 Cell #B12Cell #B11 Phase B Expansion Cells 138/138 Sundry Number: 88231 File: Description of Equipment RECEIVED:May. 25, 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 Contract Environmental Services, Inc. Hovenweep S18 T39S R26E 05/25/18 Yoshi Okano ✔ Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o, ou, email=daynedoucet@utah.gov, c=US Date: 2018.09.26 15:00:28 -06'00' 05/25/18 DD 09/26/18 DD 05/25/18 DD 09/26/18 DD 07/31/18 BW 08/21/18 BW $ 25,000 Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o, ou, email=daynedoucet@utah.gov, c=US Date: 2018.10.04 09:27:02 -06'00'✔ 06/13/18 ASM Allow expansion cells? Reclaiming cells? Elevated salinity in landfarm cells. 06/13/18 ASM 06/13/18 ASM 06/13/18 ASM /ŶĨƌĂƐƚƌƵĐƚƵƌĞZĞŵŽǀĂůŽƐƚƐ Contouring or RegradingŽƐƚƐ SeediŶŐŽƐƚƐ Notes: ŽŶƚĂŵŝŶĂƚŝŽŶŽƐƚƐ ƐƚŝŵĂƚŝŶŐůŽƐƵƌĞŽƐƚĂŶĚŽŶĚŝŶŐǀĂůƵĂƚŝŽŶ ZĞŵŽǀĂůͬZĞŵĞĚŝĂƚŝŽŶ ^ĂŵƉůŝŶŐ WŽƐƚĐůŽƐƵƌĞŵŽŶŝƚŽƌŝŶŐ džƉĞŶƐĞƐƚŽƌĞŵŽǀĞĂůůŝŶĨƌĂƐƚƌƵĐƚƵƌĞĂŶĚĞƋƵŝƉŵĞŶƚ WƌŽũĞĐƚĞdžƉĞŶƐĞƚŽĐŽŶƚŽƵƌƐŝƚĞďĂĐŬƚŽŽƌŝŐŝŶĂůŐƌĂĚĞ sŽůƵŵĞƐŽĨŵĂƚĞƌŝĂů ƋƵŝƉŵĞŶƚĐŽƐƚƐ >ĂďŽƌĐŽƐƚƐ DĞƚŚŽĚŽĨƌĞƐĞĞĚŝŶŐ ^ƉĞĐŝĞƐƵƐĞĚĨŽƌƌĞǀĞŐĞƚĂƚŝŽŶ ĂƚĞ/ŶŝƚŝĂůƐ ZĞĐĞŝǀĞĚ Comments DŽŶŝƚŽƌŝŶŐWƌŽŐƌĂŵ ĞƚĂŝůĞĚĚĞƐĐƌŝƉƚŝŽŶŽĨŵŽŶŝƚŽƌŝŶŐƉƌŽŐƌĂŵƐŝŶƵƐĞŽƌďĞŝŶŐƉƌŽƉŽƐĞĚ;ǀŝƐƵĂůŝŶƐƉĞĐƚŝŽŶƐŽĨ ĞƋƵŝƉŵĞŶƚ͕ƉƌĞƐƐƵƌĞƚĞƐƚƐ͕ůĞĂŬĚĞƚĞĐƚŝŽŶƐLJƐƚĞŵƐ͕ǁĂƐƚĞĂĐĐŽƵŶƚĂďŝůŝƚLJ͕ĂƵƚŽŵĂƚĞĚƐLJƐƚĞŵƐ͕ ƉƌŽƉŽƐĞĚƉƌĂĐƚŝĐĞƐǁŚŝĐŚĐĂŶƌĞĚƵĐĞƚŚĞƌŝƐŬŽĨĨƵƚƵƌĞĐŽŶƚĂŵŝŶĂƚŝŽŶͿ 06/13/18 ASM 06/14/18 BTW 06/14/18 BTW The small building, fence, and most of the berms will remain in place to support the Land Fill. (not our bond) 06/14/18 BTW The earthwork will include prep for seed, Estimate of 12 hours worth. + Mob - demob, (50 acres only). No E&P or other waste has been placed on the west 80 acres yet, 24 acre land farm (phase B) was approved in 2001 but not utilized yet. Estimates provided look reasonable. 06/14/18 BTW If the operator wants to expand or renew the application for "Phase B" I believe they will have to re apply, and at that time we will need to reevaluate the bond. the amount proposed by the operator is below the minimum rule amount of $25,000. The bond amount for this facility is to be the minimum amount $25,000. Phase B land farm cells need engineer drawings, hydraulic conductivity for soils and may require additional geologic information -BTK 6/15/18