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1 Division of Waste Management and Radiation Control Solid Waste Management Program Mailing Address Office Location Phone (801) 536-0200 P.O. Box 144880 195 North 1950 West Fax (801) 536-0222 Salt Lake City, Utah 84114-488 Salt Lake City, Utah 84116 www.deq.utah.gov APPLICATION FOR A TEMPORARY PERMIT TO OPERATE AN EXPLORATION AND PRODUCTION WASTE FACILITY In 2019, the Utah Legislature made changes to the Solid and Hazardous Waste Act, Utah Code § 19-6- 101 et seq., which required jurisdiction over the disposal of Oil and Gas Exploration and Production Waste move from the Department of Natural Resources’ Division of Oil, Gas, and Mining (DOGM) to the Department of Environmental Quality’s Division of Waste Management and Radiation Control (DWMRC). In preparation for this regulatory shift, DWMRC has proposed a temporary permitting mechanism for existing Exploration and Production (E&P) facilities as defined in the proposed Utah Admin. Code R315- 301-2(22)(a). The proposed rules state that the Director of DWMRC may issue a temporary permit for the purposes of facilitating the owner’s or operator’s good faith transition from regulation under Utah Admin. Code R649-9 to regulation under Utah Admin. Code R315-321 or R315-322. Applications for temporary permits must be received by the Director of DWMRC no less than 30 days before October 1, 2024. The temporary permits will expire one year from the effective date, which is the date the financial assurance mechanism held by DOGM is transferred to DWMRC. To complete a temporary permit application to operate an E&P facility, an owner or operator of an existing E&P facility must: 1. Register the company in DWMRC’s Community Portal and complete facility information within the Community Portal. 2. Complete the attached Exploration and Production Waste Facility Temporary Permit Application Form. 3. Provide DWMRC with the following required documentation, to the extent it has not already been provided to DWMRC or is not already in DWMRC’s possession: a. Facility map with each landfarm cell, landfill cell, and surface impoundment labeled; b. Copy of Division of Oil, Gas, and Mining Permit; c. Copy of Division of Oil, Gas, and Mining Permit Approval/Issuance Letter; and d. Copy of Division of Oil, Gas, and Mining Bonding (financial assurance). 4. Submit the Application Form and required documentation to DWMRC through the Community Portal Miscellaneous Document Submission. 5. Within 120 days of DWMRC’s issuance of a temporary permit, the financial assurance mechanism held by DOGM must be transferred to DWMRC. If the Director issues a temporary permit, it shall not become effective until the financial assurance mechanism held by DOGM is transferred to DWMRC. An effective temporary permit is required to operate an E&P Facility under DWMRC’s jurisdiction. 2 Exploration and Production Waste Facility Temporary Permit Application Form I. Facility Name and Location Name of Facility Bluebell Waste Management Facility Facility Address (Street or Directions to Facility) 6000 W. 1500 N. County Duchesne City Roosevelt Zip Code 84078 Telephone 435-722-2800 Township T2S Range R2W Section Sec 09 & Sec 04 Quarter Section Quarter/Quarter Section Main Gate Latitude: 40°19'41.12"N Longitude: 110° 7'23.86"W II. Existing E&P Facilities ☐ Open Landfarm Cell(s) ☐ Evaporation Pond(s) Number of Open Landfarm Cells: 3 Number of Evaporation Ponds: 2 III. Facilities to be Permitted by DWMRC ☐ Landfill Cell(s) ☐ Surface Impoundment(s) Number of Landfill Cells:3 Number of Surface Impoundments:0 III. Facility Owner(s) Information Legal Name of Facility Owner R.N. Industries Inc. Mailing Address P.O Box 1168 City Vernal State Utah Zip Code 84087 Telephone 435-722-2800 IV. Facility Operator(s) Information Legal Name of Facility Operator Dalbo Holdings, Inc. Mailing Address P.O. Box 1168 City Vernal State Utah Zip Code 84078 Telephone 435-828-0867 V. Property Owner(s) Information Is the property leased? No Name of Property Owner R.N. Industries Inc. Mailing Address P.O. Box 1168 City Vernal State Utah Zip Code 84078 Telephone 435-722-2800 VI. Designated Contact Information Facility Owner Designated Contact (if different than above) Title 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: 196.88 acres Disposal Area: 27.5 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) GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor State of Utah DEPARTMENT OF NATURAL RESOURCES 1594 West North Temple, Suite 1210, PO Box 145801, Salt Lake City, UT 84114-5801 telephone (801) 538-5340 x facsimile (801) 359-3940 x TTY (801) 538-7458 x www.ogm.utah.gov BRIAN C. STEED Executive Director Division of Oil, Gas and Mining JOHN R. BAZA Division Director Permit to Operate ******************** Facility Name: Bluebell Facility Type: Waste Crude Oil Treatment Facility Location: Section 4, Township 2S, Range 2W County: Duchesne Approval Date: November 13, 2020 1. Issued to: R N Industries (80635) 2. Authority: Pursuant to Utah Code Ann. §§ 40-6-1 et seq., and Utah Admin. Code §§ R649-6 et seq., the Utah Division of Oil, Gas and Mining (“Division”) issues this Permit to operate a waste crude oil treatment 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 crude oil treatment 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 crude oil treatment 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 waste crude oil treatment facility permit, the crude oil treatment facility shall not accept waste crude oil during the suspension period. 4. General: 4.1 Effect on Prior Permits. This Permit supersedes any existing waste crude oil treatment 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 RNI’s “Permit Renewal Application” dated 10/16/2020 and received by the Division on 10/16/2020, (“Application”). The Facility shall operate in accordance with the best management practices described in the Application. 4.3 Compliance with Applicable Laws. The Facility shall comply with Utah Code Ann. §§ 40-6- 1 et seq. and Utah Administrative Code §§ R649-6 et seq.. 5. Reporting and Recordkeeping Requirements: JOHN R BAZA The Facility shall comply with the reporting and recordkeeping requirements in Utah Admin. Code § R649-6-2.3. 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 crude oil 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 Bluebell 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 §§ R649-6 et seq., final approval to operate the Facility in accordance with this Permit is hereby granted. 9. Contact Information: The following are Division of Oil, Gas and Mining contacts and their telephone numbers: Dayne Doucet, Oil and Gas Permitting Manager: 801-538-5303 Bart Kettle, Interim Deputy Director: 435-820-0862 Ammon McDonald, Environmental Scientist: 801-538-5337 Approved By: ________________________ By: Dayne Doucet Title: Oil and Gas Permitting Manager pp y ________________________________________________ 1594 West North Temple, Suite 1210 PO Box 145801 Salt Lake City, UT 84114-5801 Telephone (801) 538-5340 www.ogm.utah.gov State of Utah SPENCER J. COX Governor DEIDRE M. HENDERSON Lieutenant Governor July 7, 2023 RN Industries C/O Mr. Spencer Merrell P.O. Box 1168 Vernal, UT 84078 SUBJECT: RNI Bluebell Pond #3 Reclamation Dear Mr. Merrell: The Utah Division of Oil, Gas and Mining (Division) received DHI Energy Service’s Proposed Pond Closure Plan prepared for the RNI Bluebell Evaporation Facility. Division approval was granted, for the submitted reclamation proposal. Sampling points have shown that the soil samples, beneath Pond #3, all have hydrocarbon levels below required clean-up standards; however, some sample points are not within the expected background range for salinity. Areas that exceed required salt clearance levels have been excavated down to the bedrock. The Division is of the opinion that no further reasonable actions can be taken to continue to remediate salinity levels. The point source for salt contamination is removed and the soils disposed of properly. Therefore, DHI Energy is hereby permitted to continue with the final reclamation of Pond#3, as proposed in the approved Pond Closure Plan. If you have questions, feel free to contact Ammon McDonald at (801) 538-5337. Sincerely, Bart Kettle Deputy Director, Oil & Gas Program BK/AM/js cc: Facility File N:\O&G Permits\Disposal Facilities (Pits, LF, etc)\RN Industries (Bluebell – S4 & 9, T2S, R2W, Duchesne) Department of Natural Resources Division of Oil, Gas and Mining JOEL FERRY Executive Director JOHN R. BAZA Division Director DEIDRE M. HENDERSON Engineering & Geosciences 14425 South Center Point Way Bluffdale, Utah 84065 ~ T: (801) 501-0583 ~ F: (801) 501-0584 Copyright © 2020 GeoStrata October 16, 2020 Bart Kettle Interim Deputy Director of Division of Oil, Gas and Mining 1594 West North Temple Salt Lake City, Utah 84116 Subject: Waste Crude Oil Treatment Facility Mr. Kettle, This letter is in regard to submitting an application for a Waste Crude Oil Treatment Facility on behalf of RN Industries (RNI). The application has been updated with a revised drawing of the oil cleaning facility layout. This revised application is to replace the previously submitted application of August 3, 2020. All information required for the application is attached to this letter. The Waste Crude Oil Treatment Facility will be using the same equipment that has been part of the disposal facility and no new construction or expansion of the facility or property is proposed in this application. Please confirm with our office that you have received the application. If you have any questions or comments about this application contact me at 801-501-0583 or email at mikev@geostrata-llc.com. Sincerely, Mike Vorkink, P.G. GeoStrata 14425 South Center Point Way Bluffdale, UT 84065 (801) 501-0583 Copyright © 2020, GeoStrata 1 PERMIT APPLICATION TO OPERATE AN OIL CLEANING FACILITY AT THE BLUEBELL DISPOSAL FACILITY FOR RN INDUSTRIES DUCHESNE COUNTY, UTAH Copyright © 2020, GeoStrata 2 1.0 INTRODUCTION RN Industries (RNI) is submitting this permit application for the existing crude oil cleaning facility located at its Bluebell Disposal Facility located approximately 7 miles north and west of Roosevelt, Utah (Plate 1). The crude oil cleaning facility is currently permitted as part of the Bluebell Disposal facility. RNI is in the process of reclaiming produced water ponds and landfarm at the Bluebell Disposal facility, however the crude oil cleaning facility at Bluebell will continue to operate under a Crude Oil Treatment (R649-6-2) permit as reclamation continues. This application is requesting that the Utah Division of Oil Gas and Mining (UDOGM) allow RNI to operate the oil cleaning facility as a Crude Oil Treatment facility. Plate 2 shows the general layout of the facility and the equipment to be used. The equipment will consist of fourteen (14) upright 500 BBL tanks and one (1) 2000 BBL tank, and a filter press. The storage and processing tanks are insulated and heated. The tanks are surrounded by a containment berm with a minimum capacity of 500 BBLS. The following sections describe the ownership, location, type of facility, and capacity of the proposed oil cleaning facility. 1.1 OWNERSHIP The Bluebell Disposal Facility is owned and operated by RNI. The oil cleaning facility will be located on land owned by RNI and will be operated by RNI personnel. The entire oil cleaning operation is on the same property that is used for the RNI Bluebell Disposal facility. 1.2 LOCATION OF THE FACILITY The facility is located in Section 9, T2S, R2W, of the Uintah Special Meridian. The Facility is located approximately 7 miles north and west of Roosevelt, Utah in Duchesne County. See the Site Vicinity Map for a map of the location of the subject site (Plate 1). 1.3 DESCRIPTION OF FACILITIY The Facility will accept waste crude oil from other RNI facilities as well as external sources that generate crude oil in the region. The waste oil will be delivered to the Facility via truck where it will then be transferred to a receiving tank. The tank will be heated, and oil will be allowed time for gravitational separation to occur. When necessary, chemical flocculation to remove entrained solids will be utilized. Oil that still maintains high solids content may be processed by an onsite filter press or centrifuge. Upon meeting the desired crude oil specifications, the crude oil will be stored in an oil sales tank and eventually transferred offsite via truck for sale. Access to the site Copyright © 2020, GeoStrata 3 will be from existing roads. No additional road construction will be necessary. RNI has applied for and will have applicable air quality permits from the Utah Division of Air Quality. 1.4 METHODS FOR HANDLING WASTE DISPOSAL Solids generated during the oil cleaning process will be sent to the onsite landfill permitted through the Utah Division of Waste Management and Radiation Control (UDWMRC) for permanent storage. Wastewater generated during the oil cleaning will be sent off site to a permitted disposal facility. As mentioned previously, the Bluebell Disposal facility is not and will not be operating the landfarm or evaporation ponds. 1.5 CONSTRUCTION MATERIALS The Facility has existing upright tanks that are currently onsite. The tank battery has containment berms constructed from onsite soils. 1.6 FACILITY CAPACITY The Facility will have a total capacity of cleaning 36,000 bbl of crude oil per year. 2.0 RECLAMATION PLAN 2.1 EXTENT AND LOCATION OF SURFACE DISTURBANCE The Facility is located on RNI property and the tanks are already located on site. The oil cleaning equipment and tanks will be operated on land that is already cleared and used for oil storing, loading, and off-loading purposes. A map with the location of the equipment and roads for access to the tanks is provided as Plate 2. The approximate area of the oil cleaning facility is 6.3 acres including the access road. 2.2 RECLAMATION PLAN When RNI determines that there is no further need for the oil cleaning facility, the facility will be reclaimed. Fluids will be drained from tanks and disposed at an appropriate permitted disposal facility. Tanks will be disposed if they are not salvageable and salvageable tanks may be removed from the site and used at other RNI facilities or sold. Copyright © 2020, GeoStrata 4 Soils inside the containment berm or in other areas used for the oil cleaning facility operations will be tested according to UDOGM cleanup standards and following R649-9-12. If soils are evaluated that do not meet the UDOGM cleanup guidance these soils will be either reclaimed in place until they meet the UDOGM standards or they may be disposed in the Bluebell Landfill. Following disposal of the tanks, liner materials, and soils the earth work will be performed to restore the site back to the natural grades and contours. 2.3 BONDING The equipment and associated land surface area to be used for the oil cleaning facility is included in the current bonding that is posted for the RNI Bluebell Disposal facility. The RNI bond that is posted for disposal facility includes the extent of the proposed oil cleaning operation and meets the requirements for bonding under R649-6-2. T2S R2W 4T2S R2W 5 T2S R2W 9T2S R2W 8 T2S R2W 16T2S R2W 17 T2S R2W 3 T2S R2W 10 T2S R2W 15 T1S R2W 32 T1S R2W 33 T2S R2W 7 T1S R2W 34 T2S R2W 6 T2S R2W 18 T1S R2W 31 BluebellRN IndustriesRoosevelt, U tahProject Number 524-106 0 825 1,650 2,475 3,300412.5 Feet 1:2 4,0 00 BASE M AP: NAIP 2011 Obta ine d from the Sta te of Utah A GRC Oil Cleaning FacilityLocation Map Copyright GeoStrata, 2020 Plate1 Legend Oil Cleaning Facility Crude Oil Tank Location Filter Press Location Site Boundary 2 ft Secondary Containment Filter Press Building 2000 B B L T a n k Filter Press Oil Supply Tank Filter Press Out-put Tank Propane Tank REV DATE BY DESCRIPTION DUCHESNE COUNTY, UTAHSCALE ENERGY SERVICE BLUEBELL OIL CLEANING FACILITY SCALE ENERGY SERVICE Oil Processing Tanks Brine Tank 1:50 All locations are approximate Plate 2 Copyright GeoStrata 2020 Out-of-service tank Restricted Cash Balance Detail Facility State Agency Bonding Type Account # Issuer RNI GL Account Number Actual Interest Rate as of 12/31/2023 Confirmed 12/31/2023 Value YTD ESTIMATED Interest Income(net of interest earned and released) YTD Y/E Interest Adjustment to actual 2024 Deposits Releases Transfer In/Out Ending Estimated Balance EOM Per GL Difference Exceed FDIC Per 12/31/2024 Confirm GL Confirm Difference Actual Interest Rate as of 12/31/2023 BlueBell RNI Utah DOGM Business MM 027766005 Zions Bank 18201 see statement $144,810.23 $0.00 $91.96 reconciled at cash recon worksheet $144,821.87 reconciled at cash recon worksheet $0.00 144,810.23 -$11.64 0.75% Glen Bench RNI Utah DOGM Business MM 027765999 Zions Bank 18202 see statement $123,860.37 $0.00 $78.66 reconciled at cash recon worksheet $123,870.33 reconciled at cash recon worksheet $0.00 123,860.37 -$9.96 0.75% Pleasant Valley - RNI Utah Duchesne County Business MM 027765973 Zions Bank 18203 see statement $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 - $0.00 0.00% Pleasant Valley - RNI Utah DOGM Business MM 027765932 Zions Bank 18204 see statement $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 - $0.00 0.00% Seep Ridge Utah DOGM Business MM 027765940 Zions Bank 18205 see statement $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 - $0.00 0.00% Bluebell Utah DOGM CD 579-156795-0 Zions First National 18206 5.07% $601,621.13 $17,792.94 -$404,215.86 $215,198.21 $215,198.21 $0.00 $0.00 601,621.13 $386,422.92 5.07% Chapita Utah DOGM CD 579-156799-2 Zions First National 18207 0.19% $57,809.07 $64.07 $57,873.14 $57,873.14 $0.00 $0.00 57,809.07 -$64.07 0.19% Chapita Utah DOGM CD 579-156796-8 Zions First National 18208 5.07% $941,783.28 $27,853.24 -$208,573.00 $761,063.52 $761,063.52 $0.00 $511,063.52 941,783.28 $180,719.76 5.07% Glen Bench - RNI Utah DOGM CD 579-156797-6 Zions First National 18209 5.07% $643,711.72 $19,037.77 $662,749.49 $662,749.49 $0.00 $412,749.49 643,711.72 -$19,037.77 5.07% Wonsit Utah DOGM CD 579-156798-4 Zions First National 18210 5.07% $1,201,951.28 $35,547.71 -$87,599.67 $1,149,899.32 $1,149,899.32 $0.00 $899,899.32 1,201,951.28 $52,051.96 5.07% Ace Utah DOGM CD 579-156800-8 Zions First National 18211 5.07% $197,568.34 $5,843.08 $203,411.42 $203,411.42 $0.00 $0.00 197,568.34 -$5,843.08 5.07% Glen Bench Utah DOGM CD 579-156801-6 Zions First National 18212 5.07% $574,582.63 $16,993.28 $591,575.91 $591,575.91 $0.00 $341,575.91 574,582.63 -$16,993.28 5.07% Seep Ridge Utah DOGM CD 579-156803-2 Zions First National 18213 5.07% $448,453.13 $13,263.00 $461,716.13 $461,716.13 $0.00 $211,716.13 448,453.13 -$13,263.00 5.07% Seep Ridge Utah DOGM CD 579-156804-0 Zions First National 18214 5.07% $306,868.61 $9,075.64 $315,944.25 $315,944.25 $0.00 $65,944.25 306,868.61 -$9,075.64 5.07% Ace Utah DOGM CD 579-156805-7 Zions First National 18215 5.07% $251,995.44 $7,452.77 $259,448.21 $259,448.21 $0.00 $9,448.21 251,995.44 -$7,452.77 5.07% Piceance Creek Colorado CDPHE CD 5780001086 Vectra Bank 18216 0.14% $138,699.61 $113.27 $138,812.88 $138,812.88 $0.00 $0.00 138,699.61 -$113.27 0.00% Piceance Creek Colorado CDPHE CD 5780001078 Vectra Bank 18217 0.14% $195,285.46 $159.48 $195,444.94 $195,444.94 $0.00 $0.00 195,285.46 -$159.48 0.00% Rangely Colorado CDPHE CD 11023600100407 Bank of the San Juans 18218 0.21% $285,283.72 $349.47 $285,633.19 $285,633.19 $0.00 $35,633.19 285,283.72 -$349.47 0.00% Wonsit Pond 9 Utah Solid Waste CD 579-234585-1 Zions Bank 18219 0.19% $542,893.64 $601.71 $543,495.35 $543,495.35 $0.00 $293,495.35 542,893.64 -$601.71 0.19% Bluebell Landfill Utah Solid Waste Savings 579-741682-2 Zions Bank 18220 0.19% $358,003.09 $396.79 $358,399.88 $358,399.88 $0.00 $108,399.88 358,003.09 -$396.79 0.19% Chapita Utah SITLA 8911974 Zions Money Market 18221 0.19% $117,260.43 $129.96 $117,390.39 $117,390.39 $0.00 $0.00 $117,260.43 -$129.96 0.00% TOTALS - RESTRICTED CASH $7,132,441.18 $154,674.18 $0.00 $0.00 -$700,388.53 $170.62 $6,318,056.23 $6,586,748.43 $0.00 $2,889,925.25 Rollforward