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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
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RECEIVED
DIV. OF OIL, GAS & MINING
May 23, 2019
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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
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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.
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I-2. Previous PermitsϭϵϵϵĂŶĚϮϬϬϭ
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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.
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II-2. Current Facility Map
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CESI Landfarm Location: San Juan County, UT
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San Juan County, Utah
CESI Landfarm Location: San Juan County, UT
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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
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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VII. Estimating Closure Cost and Bonding Evaluation
Third Party Closure and Post Closure Plan by Envirotech, Inc.
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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
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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
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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.
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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.
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Contract Environmental Services
Facility Location
GPS Coordinates of Landfarm facility:
37.400087° N, -109.098160° W
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Contract Environmental Services
Site Diagram
Contract Environmental Services
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Cost Break down
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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 -$4,729.41
㻲㻲㼕㼢㼑㻌㼅㼑㼍㼞㻌㻱㻒㻼㻌㼃㼍㼟㼠㼑㻌㻰㼕㼟㼜㼛㼟㼍㼘㻌㻲㼍㼏㼕㼘㼕㼠㼥㻌㻮㼛㼚㼐㻌㻯㼍㼘㼏㼡㼘㼍㼠㼕㼛㼚㻌㻿㼡㼙㼙㼍㼞㼥㻌㻲㼛㼞㼙
㻰㻰㼕㼞㼑㼏㼠㻌㼍㼚㼐㻌㻵㼚㼐㼕㼞㼑㼏㼠㻌㻯㼛㼟㼠㼟
㻵㼒㻌㼥㼛㼡㻌㼔㼍㼢㼑㻌㼝㼡㼑㼟㼠㼕㼛㼚㼟㻌㼍㼎㼛㼡㼠㻌㼠㼔㼕㼟㻌㼒㼛㼞㼙㻌㼜㼘㼑㼍㼟㼑㻌㼏㼛㼚㼠㼍㼏㼠㻌㻮㼑㼢㻌㼃㼕㼟㼑㼞㻌㼍㼠㻌㻤㻜㻝㻙㻡㻟㻤㻙㻡㻟㻠㻢㻌㼛㼞
㼑㼙㼍㼕㼘㻌㼎㼠㼣㼕㼟㼑㼞㻬㼡㼠㼍㼔㻚㼓㼛㼢㻚
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RECEIVED:May. 25, 2018
Appendix: Third Party Cost Estimates
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4
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134/138
Sundry Number: 88231 File: Description of Equipment
RECEIVED:May. 25, 2018
Phon
FAX:
COMPANY: DATE: INVO
CUSTOMER:MIX
ADDRESS: PHONE: P.O. #
ALT: 50 A
SHIPPING: FAX:
TOTA
ACRES
UPS: CPU: DEL:CREDIT CARD INFO
%LOT #PLS%
PER/
ACRE
TOTAL
#COST
PER/
ACRE TOT
1 05
2 0
3 05
4 03.5
5 01.5
6 0
7 0
8 0
9 0
10 0.0 0
TOTALS 00 15
3.81$
*** 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
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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
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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