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HomeMy WebLinkAboutDSHW-2024-0094091 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 Chapita Waste Management Facility Facility Address (Street or Directions to Facility) 26770 S. Fantasy Canyon County Uintah City. Vernal Zip Code 84078 Telephone 435-722-2800 Township T9S Range R22E Section S2 Quarter Section Quarter/Quarter Section Main Gate Latitude: 40° 4'2.23"N Longitude: 109°24'45.71"W II. Existing E&P Facilities ☐ Open Landfarm Cell(s) ☐ Evaporation Pond(s) Number of Open Landfarm Cells: 0 Number of Evaporation Ponds: 7 III. Facilities to be Permitted by DWMRC ☐ Landfill Cell(s) ☐ Surface Impoundment(s) Number of Landfill Cells: 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? Yes Name of Property Owner SITLA-Utah School and Institutional Trust Lands Mailing Address 152 E. 100 N. 4th Floor S. City Vernal State Utah Zip Code 84078 Telephone 435-781-5304 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: 183 acres Disposal Area: 40 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) Sundry Number: 93411 STATE OF UTAH Waste Disposal Permit DEPARTMENT OF NATURAL RESOURCES AMENDED REPORT ✓ 1.Name of Operator R N Industries 3.Address of Operator City PO Box 98 Roosevelt UT 84066 5.Name of 3rd Party Contractor GeoStrata Engineering & GeoSciences 7. Address of Contractor City 14425 South Center Point Way Bluffdale 9.Additional Comments DIVISION OF OIL, GAS AND MINING UT WASTE DISPOSAL PERMIT 2.Utah Account Number 101818.0 State Zip 4.Phone Number 435-722-3800 6.Facility Name Chapita State Zip 7. Phone Number 84055 Approved by the Utah Division of Oil, Gas and Mining Date: February 22, 2019 By:� Original Filing Date: 1/15/2019 RECEIVED: Jan. 15, 2019 RECEIVED DIV. OF OIL, GAS & MINING Sundry Number: 93411 File: Detailed Site Description Utah Division of Oil Gas & Mining Permit Renewal Application for Chapita Exploration & Production Waste Disposal 26770 South Fantasy Canyon Road Uintah County, Utah TABLE OF CONTENTS A.Introduction and Narrative B.Site Description and Assessment and Closure and Post Closure Cost Estimate 1.Description and Assessment of Existing Conditions a.Site Description b.Contamination Evaluation C.Equipment Assessment d.Practices Assessment e.Monitoring Program 2.Closure Cost and Bonding Evaluation a.Contamination Evaluation b.Remediation of E&P Waste Contamination C.Site Closure Evaluation Scope of Work d.Infrastructure Removal Scope of Work e.Seeding and Revegetation Scope of Work f.Initial Closure Monitoring Report g.Post Closure Monitoring Scope of Work 3.Observations and Recommendations c.Attachments 1.Attachment 1 -Maps and drawings 2.Attachment 2 -Third Party Closure Cost Estimate Rev 20180515 1 Page of 7 r-�"' c .............. .,._,�v.-11 W IW Engineering and Geo-Sciences RECEIVED: Jan. 15, 2019 Sundry Number: 93411 File: Detailed Site Description Utah Division of Oil Gas & Mining Permit Renewal Application for Chapita Exploration & Production Waste Disposal 26770 South Fantasy Canyon Road Uintah County, Utah A.Introduction and Narrative RNI submits this Exploration and Production (E&P) Waste Disposal Permit Renewal Application (Application) for the subject facility (Facility) in accordance with the requirements of Utah Administrative Code, Rules R649-9-8.2, R649-9-8.2.1 and R649-9-8.5.1. This Application includes an assessment of site reclamation requirements and closure cost estimates compiled by a responsible third-party contractor. RNI understands that permit renewals may be approved for a five-year period depending on the results of DOGM's review and consideration of the Application and historic Facility compliance performance. The Facility receives and treats produced water, natural gas liquids (NGL), other Exploration and Production (E&P) liquid wastes. This facility does not receive solid E&P wastes. The Facility is located about 27 miles southwest of Vernal, Utah and is outside of any incorporated City Limits. The address to the Facility is: Rev 20180515 26770 South Fantasy Canyon Road Uintah County, Utah 84078 2 Page of 7 r-�"' C,1, .. ..,.1,..,..,._,�v.-11 W IW Engineering and Geo-Sciences RECEIVED: Jan. 15, 2019 Sundry Number: 93411 File: Detailed Site Description Utah Division of Oil Gas & Mining Permit Renewal Application for Chapita Exploration & Production Waste Disposal 26770 South Fantasy Canyon Road Uintah County, Utah B.Site Description and Assessment, Closure and Post Closure Cost Estimate and Bond Evaluation The following narrative addresses requirements established for permit renewal of the titled facility as described in in Utah Division of Oil, Gas and Mining guidance document, Five Year E&P Waste Disposal Facility Permit Renewals. (re: Utah Oil & Gas Conservation General Rules R649-9-8.5.1 Bonding of Disposal Facilities), dated August 2017. 1.Description and Assessment of Existing Conditions a.Site Description: The RN Industries (RNI) Chapita Exploration & Production (E&P) Waste Disposal is located on approximately 240 Acres in the NW/4 of Section 2 of T 9S, R 22E, SLB&M. See site map in Attachment 1. The current site has one Skimming pond, an off-load area and nine operational evaporation ponds. The operational evaporation ponds range nominally from 0.11 to 4.46 acres in size. Liquid E&P Waste is discharged from tank trucks into the skim pond. It is then directed into one of the nine operational evaporation ponds. Oil is removed from the skimming pond as needed and transported to a separate oil cleaning facility. See Existing Process Flow Diagram in Attachment 1. Stormwater Detention basins are located in the NW/4, NW/4, SE/4, NW/4 and SW/4, NE/4, Sect 9 have been designed to hold runoff generated by a 25-year, 24-hour storm until the runoff can be sampled and lab-tested. Depending on lab results the water will be either released to the local drainage, held to evaporate in place, diverted to evaporation ponds or disposed by some combination of the three aforementioned methods. b.Contamination Evaluation There is no known or observable surface soil contamination on this site. No process-induced vadose zone soil or unconfined aquifer contamination is known to exist. There are no known records of incomplete spill clean-up. Process containment berms, sumps and similar enclosures are free from pooled oil and/ or measurable contaminated oil accumulation. c.Equipment Assessment Major construction and equipment operated at this facility has been observed by Engineer. Any tests performed to assess equipment condition were cursory in nature. A review of equipment repair and maintenance records provided by Owner form the basis of the Engineer's opinion of service life expectancy. Service life expectancy is based upon the assumption that appropriate, regular maintenance and equipment repair has been and will continue to be performed. It is the Engineer's opinion that all major equipment and infrastructure construction at this facility is in expected condition for its age. Future assessment of life expectancy can be based on age. Rev 20180515 3 Page of 7 r-�"' C,1, .. ..,.1,..,..,._,�v.-11 W IW Engineering and Geo-Sciences RECEIVED: Jan. 15, 2019 Sundry Number: 93411 File: Detailed Site Description Utah Division of Oil Gas & Mining Permit Renewal Application for Chapita Exploration & Production Waste Disposal 26770 South Fantasy Canyon Road Uintah County, Utah More particularly: i.Site roadways are constructed and maintained with appropriate wearing surface, drainage and turning radii for expected traffic. ii.Road and site drainage show no signs of overflow, debris accumulation or excessive erosion. iii.Earthen structures are free of piping and excessive erosion. iv.Observable portions of piping and HDPE liners are not excessively worn or weathered. v.When last operated no observable pump seals showed excessive leakage. vi.Buildings -There are no permanent buildings located at the Chapita Disposal Site. vii.Mobile Equipment No mobile equipment is permanently assigned to this site d.Practices Assessment Engineer has reviewed Owner provided operating procedures and has observed those procedures in practice. Owner and Engineer offer the following practice changes to improve efficiency and environmental protections. i.Water Disposal Operation Assessment Rev 20180515 This Disposal has been operated less than 50% of the time during the last five years. The following observations apply to time periods when the Disposal is regularly used in a normal operating mode. Strong consideration should be given to complete closure, step-wise closure or sale of this facility to reduce Owner liability unless there is a superseding business reason to do otherwise. Controls for the process described in B.1.a., above and shown on the Process Flow Diagram in Attachment 1, have, for the most part not been automated. Only minor portions of equipment and controls are automated. Most automation is intrinsic to individual pieces of equipment. Operators appear to be very familiar with the overall plant process and perform process Quality Control for a large percentage of their time. Throughout their working hours operators sample process liquids for anomalies. Whenever process liquids or machinery operation appears abnormal operators will intervene in one of two ways. Most often the operator will make equipment and process adjustments for which the operator has been trained and given authority to perform. Process and equipment adjustments which appear to be needed, but which operator has not been authorized to perform, are immediately brought to the attention of other operating staff and plant management for resolution. Large equipment temperatures, pressures, flowrates and the like are constantly monitored by operating staff and management. Although some process monitoring parameters are observed via remote displays, most instrument monitoring and all sampling is locally observed/performed. Leak detection equipment is monitored regularly. 4 Page of 7 r-�"' C,1, .. ..,.1,..,..,._,�v.-11 W IW Engineering and Geo-Sciences RECEIVED: Jan. 15, 2019 Sundry Number: 93411 File: Detailed Site Description Utah Division of Oil Gas & Mining Permit Renewal Application for Chapita Exploration & Production Waste Disposal 26770 South Fantasy Canyon Road Uintah County, Utah It is the Engineer's opinion that: No additional process monitoring automation is warranted for any reason at this Disposal unless it is returned to regular, continuous use or operation. Frequency of leak detection monitoring should be decreased (i.e. allow a longer time between subsequent observations) to quarterly time periods. Process sampling should continue to be performed manually and locally when Disposal is in operation because this facility is not big enough to warrant remote and/or automated process sampling. The biggest process variable is the type of waste brought to the Facility. It is the Engineer's opinion there is no commercially available, off-the-shelf (COTS) equipment to classify incoming waste. There is no Reasonably Available Control Technology (RACT) or even Best Available Control Technology (BACT) that is economically viable for RNI to implement. The methods that remain ( client waste certification, periodic waste testing by client, waste evaluation by experienced staff and similar) are best available for the RNI operation and should continue to be used. ii.Landfarm Operation Assessment No landfarms have ever been operated at this facility. e.Monitoring Program Water sampling and testing, visual equipment inspection, pressure tests, sampling and analysis of material collected by leak detection systems and waste mass balance calculations used at this facility are described below. Additional or re-configured monitoring practices which could reasonably and economically improve detection of inadvertent waste release are also described below. According to Owner provided records, sampling and testing for spill and/or leak clean-up is always performed to verify that all needed clean-up is complete. i.Water Sampling and testing is performed on all liquid taken from leak detection sumps. ii.Leak Detection Monitoring of designated leak detection sumps occurs regularly. f.Additional or re-configured monitoring practices which could reasonably and economically improve operational efficacy and detection of inadvertent waste release are described below. To enhance early detection of inadvertent waste release and more accurately determine leak sources while this Disposal is dormant RNI should consider adding a chemical marker to certain waste streams. 2.Closure Cost and Bonding Evaluation Bond cost components referenced in this section have been determined by applying unit costs to quantity take-off from drawings and documents provided by Owner and cursory field inspections and surveys by the Engineer. a.Contamination Evaluation No evidence of Soil, Surface Water or Groundwater contamination was found at this facility. b.Remediation of E&P Waste Contamination Rev 20180515 5 Page of 7 r-�"' c .............. .,._,�v.-11 W IW Engineering and Geo-Sciences RECEIVED: Jan. 15, 2019 Sundry Number: 93411 File: Detailed Site Description Utah Division of Oil Gas & Mining Permit Renewal Application for Chapita Exploration & Production Waste Disposal 26770 South Fantasy Canyon Road Uintah County, Utah None required. c.Site Closure Evaluation Scope of Work Upon closure, potential soil contamination will be identified with a Photo Ionization Detector (PID) survey. Groundwater quality and surface water will be sampled lab-tested. Hazardous substances stored or used on site will be inventoried and removed as appropriate. Costs for this evaluation are included in calculated closure costs. d.Infrastructure Removal Scope of Work The cost to remove all site infrastructure and equipment as may be reasonable and necessary to return site to a condition similar to its use and appearance before being used as an E&P Waste Disposal is included in reclamation cost estimate. No costs are included to reclaim and/or improve the site to conditions better than those occurring before its use as and E&P Disposal or markedly better than exist on adjacent property. Grading and contouring the site to the exact site geometry before site was used as an E&P Disposal has not been used as a reclamation criterion. Generally, infrastructure removal closure cost estimates include: i.Removal all tanks, security fence, buildings, liner materials, piping and concrete structures which do not add value to the site are included in the Infrastructure Removal portion of closure costs. ii.Earthwork and grading to restore site to a serviceable condition similar to, and in keeping with surrounding land use and drainage. e.Seeding and Revegetation Scope of Work Seeding/revegetation cost based on drag harrowing and hydroseeding is included in the closure cost estimate. Seed mixture and application rate determined by Great Basin Company of Ephraim, Utah are included in this component of closure cost estimate. f.Initial Closure Monitoring Report This report will describe: i.Estimated closure PID survey results and required sampling and lab testing. ii.Groundwater and surface water sampling and lab-testing. iii.Inventory of hazardous substances removed from site. iv.Site grading, revegetation and erosion control. g.Post Closure Monitoring Scope of Work Post closure monitoring and care cost will include annual: i.Erosion control and surface drainage management. ii.Sampling and testing of site ground and surface water as described in the initial closure report. iii.Written reports describing the condition of the reclaimed site and work performed to monitor and maintain reclaimed site. Rev 20180515 6 Page of 7 r-�"' C,1, .. ..,.1,..,..,._,�v.-11 W IW Engineering and Geo-Sciences RECEIVED: Jan. 15, 2019 Sundry Number: 93411 File: Detailed Site Description Utah Division of Oil Gas & Mining Permit Renewal Application for Chapita Exploration & Production Waste Disposal 26770 South Fantasy Canyon Road Uintah County, Utah 3.Observations and Recommendations Included in Articles 1. d. and 1. f, above. Rev 20180515 7 Page of 7 r-�"' C,1, .. ..,.1,..,..,._,�v.-11 W IW Engineering and Geo-Sciences RECEIVED: Jan. 15, 2019 Rev 20180515 Utah Division of Oil Gas & Mining Permit Renewal Application for Chapita Exploration & Production Waste Disposal 26770 South Fantasy Canyon Road Uintah County, Utah 'C. Attachments Engineering and Geo-Sciences Rev 20180515 Utah Division of Oil Gas & Mining Permit Renewal Application for Chapita Exploration & Production Waste Disposal 26770 South Fantasy Canyon Road Uintah County, Utah ATTACHMENT 1 MAPS and DRAWINGS Site & Vicinity PFD Engineering and Geo-Sciences 7 98 4 5 2 6 1 3 Disposal Facility Permit Renewal RN Industries Project Number 524-084 0 200 400 600 800100 Feet Chapita Disposal Facility Map 1 Legend Site Boundary Copyright GeoStrata, 2018 ±1:6,000 BASE MAP: Aerial Orthphotography obtained from the State of Utah AGRC Produced Water Copyright GeoStrata, 2018 Permit Renewal RN Industries Project Number: 524 Legend Water Oil Skim Pond Evaporation Ponds Oil Tanks Chapita Process Flow Diagram Rev 20180515 Utah Division of Oil Gas & Mining Permit Renewal Application for Chapita Exploration & Production Waste Disposal 26770 South Fantasy Canyon Road Uintah County, Utah ATTACHMENT 2 CLOSURE COST ESTIMATE Bev summary & GeoStrata Backup Cales Engineering and Geo-Sciences Five Year E&P Waste Disposal Facility Bond Calculation Summary Form Direct and Indirect Costs OIL GAS• MINING RN Industries Facility: Chapita E&P Disposal Number of Acres to be Reclaimed Contamination Remediation Cost Estimates Removal of Infrastructure Costs Estimates Earthwork and Grading Cost Estimates Revegetation Cost Estimates Final Closure & Post Closure Cost Estimates Total Cost Estimate Date: (Increase above total cost estimate by 14% if indirect costs are not included) Total Reclamation Cost Required Bond Posted Difference Between Cost Estimate and Bond 7/19/2018 60.3 Acres $ 79,547 $ 59,276 $ 606,520 $ 75,960 $ 53,813 $ 875,115 $ 122,516 $ 997,632 $ 1,598,959 $ 601,327 0 2 3 4 5 6 7 Sundry Number: 93411 File: Detailed Site Description RN Industries Olapita E&P Disposal Site Assessment Closure & Post Closure Cost Estimate & Re-statement of Existing Bonds in Suport of DOGM Bonding Evaluation Item I DOGM Une Item 0 I Indirect Costs Desaioltoo Contingencies Price and Payments Procedures Administrative Requirements Quality Requirements Temporary Facil�ies and Controls Executions of Ooseout Requirements I Total: 1 I Site Arel 2 I Contamination Remediation Cost Estimates Descrioiton Unit Ouantitv Unit Price Removal of Contaminated Liauid Gallon 1162529.535 $ D�oosal of Contaminated Liouid bbl 27 679 $ Vaoor Extraction 0 Pumo & Treat 0 Self Attenuatino 0 PID Oosure Soil samolino Positive 5amoles 5.503266079 Post Remediation Monitoring 0 Total: 3 I Removal of lnfrastrudura Costs Estimates Descripiton Unit Buildinas Cubic Yard Tanks Each Gensets Each Buried Pioina Linear Foot Cut and Remove Liner Cf Concrete Pads Cubic Yard Fencino Linear Foot Haulina Cubic Yard Dumoino Ton 4 I Earthwork and Gradina Cost Estimates Descrioiton Unit Common Earth to be Dozed cubic vard Oav to be Moved cubic vard sand & Gravel to be Moved cubic vard Rough Grading square foot 5 I Reveaetatlan Cast Estimates Descr1Ditoo Unit Hydro Seeding of Indian Rice Grass MSF I 6 I Inltlal and Flnal Past aosure Renart Descrioiton Unit Well Insnomon & samolino Year Water Qualitv Meter Rental Year Lab Analvsis Year Grounds Maintenance Annual Monitorino Well Abandonment Year Annual Reoort Year Initial and Final Post Closure Reoort Year 7 I Band Pasted Bond Descrioiton &. Date Tvoe ID Number I Quantity Ouantitv Ouantitv Ouantitv 4 40 606 1856 17 800 114 96 254 984 2,624,727 2,625 10 10 10 9 1 8 2 Listed Reclamation Unit Price $ $ $ $ $ Total: Unit Price $ • $ $ Total: Unit Price ITotal: Unit Price $ $ $ $ $ $ Total: 1 I Total: Percentaqe 7% 3% 1% 0% 3% 14% 60.3Aaeo Extended Cost 0.04 $ 46 016 0.68 $ 18 960 0 $ 0 $ 0 $ Varies $ 14 571 0 $ $ 79,547 Extended Cost Varies $ Varies No Cost (net of salvaoel 200.00 No Cost fnet of salvaoel Varies $ 2.28 $ 6 101 1.09 $ Varies $ 40 228 1.76 $ 3,473 20.00 $ 9,473 $ 59 276 Extended Cost 1.76 $ 595 545 2.83 • 1.53 $ o.os $ 10,975 $ 606 520 Extended Cost 28.94 $ 61,666 I $ 75 960 Extended Cost 630.00 $ 6 300 120.00 $ 1200 600.00 $ 6 000 2 690.35 $ 24 213 Varies $ 2100 1 200.00 $ 9 600 2,200.00 $ 4,400 $ 53 813 Posted Amount 7 I $ 1,598,959 $ 1 598 959 01 21 55.50 0200 With an additional 2% of unforseeable events 01 31 00 Adjusted to reflect a percentage, also referenced ACEC and ASCE for rates 01 41 26,50 0100 01 51 00 Not applicable for the scope and scale of a project like this 01 71 00 Adjusted to reflect a percentage, also referenced ACEC and ASCE for rates Total Site 240 Aaes I 02 65 10.30 0130 (modled for scale) 31 23 23.20 4096 adjusted to cy for hauling (w� $.65 / bbl cost for d�posal facility to accept waste) Above costs include the removal (by vac truck) and disposal of 10% of tank volume MWH Standard 02 41 19.20 0020 02 65 10.30 1253 No Cost net of salvage 02 65 10.30 1253 No Cost net of salvage Included in Liner Removal 31 23 16.42 1550 MoMied to add truck loading 02 41 16.17 0440 02 41 13.60 1600 31 23 23.20 4104 Modmed for proximity of Landfill Duchesne/ Wasatch Bluebench Landfill Tonnage Rates 31 23 16.46 5020 31 23 16.46 5040 31 23 16.46 5000 31 22 13.20 0280 (modled for scale) GeoStrata Inhouse Estimates GeoStrata Inhouse Estimates GeoStrata Inhouse Estimates 32 9113.23 Structural Soil Mixina foa 331) I GeoStrata Inhouse Estimates GeoStrata Inhouse Estimates GeoStrata Inhouse Estimates RECEIVED: Jan. 15, 2019 Compliance Review Completed: No outstanding compliance Active violation/compliance m Signature: Comments Disposal Facility ermit Renewal Check is Name of Operator: Name of RN Industries Chapita E&P Waste Disposal Section 2, T9S, R22E, SLBM 05/30/18 GeoStrata 05/30/18 ASM 01/10/19 BTK 05/30/18 ASM 01/10/19 BTK 05/30/18 BW 01/15/19 BW $ 998,000 Uncertainty regarding lease letters 12/17-3/18. SULA 07/03/18 ASM Facility Map included. 07/03/18 ASM No contamination anticipated 07/03/18 ASM Includes HDPE liners and 07/03/18 ASM Inactive 2013 Contouring or Regrading Seedi Notes: Comments 02/04/19 ASM Leak detection sumps will a weekly basis-ASM 01/11/19 BW 01/11/19 BW Liner and piping to be removed 01/11/19 BW 01/11/19 BW SITLA requires liner/solids to be removed, should be reflected in the bond estimate -BTK 6/25 Series of correspondence between SITLA and RNI between Dec 2017 and March 2018 -December 19, 2017 SITLA letter requesting reclamation plan by Jan 30, 2018 -January 29, 2018 RNI response containing reclamation plan for Chapita, requesting to continue use at Seep Ridge -March 19, 2018 SITLA response rejecting liner burial and requiring sediment removal from ponds. Request time line for reclamation steps. -January 11, 2019 reviewed most recent reclamation costs. Liner and Piping are being removed as per SITLA request. Bond Estimate is $998,000. 1111 ENERGY SERVICE Mr. Jim Davis SITLA I Utah Trust Lands Administration 675 East 500 South, Suite 500 Salt Lake City, UT 84102-2813 Mr. Davis; RU F b ... TRUST LAt✓o s .. , A DMINISTRATION FEB 2 8 20 1~ TRUST LAN r:J' AOMINI S H1 AI February, 25, 2019 The purpose of this letter is to respond to your questions regarding the Seep Ridge and Cha pita disposal facilities posed in an email to Austin Weddle on January 18. 2019: 1. Which of the ponds are currently in use? • The Seep Ridge facility is currently active and receiving water • The Chapita facility is currently inactive . 2. What work was done last year? • There was no reclamation work performed in 2018 3 . Please provide me a plan for this year including a rough anticipated timeline. • RHI is evaluating reclamation options for the Cha pita facility for 2019. We would prefer to do reclamation work with our own crews and equipment but for at least the first half of this year we will be using our resources to perform work that UDOGM has requested at our Wonsits and Bluebell facilities . We are also waiting on approval from the Utah State DEQ to begin expansion work on our landfill at the Wonsits facility. This expansion will be a necessary part of the Cha pita reclamation as it will provide us a place to take the liners and other solids from the facility prior to recontouring. If you have additional questions, please feel free to contact me . Kirk Fleetwood (435) 828-3451 DALBO HOLDINGS INC. 355 South 1000 East, Vernal UT 84078 0: 435 -722 -2800 www.dalboholdings .com Governor www.ogm.utah.gov Executive Director Austin Weddle Dalbo Holdings Inc./RN Industries P.O. Box 1168 Vernal, UT 84078 April 15, 2019 7017 1070 0000 9113 5570 4/15/2019 The operator has failed to submit 4th Quarter 2018 E&P Waste Facility Quarterly Reports for all Dalbo Holding Inc./RN Industries facilities to the Utah Division of Oil, Gas and Mining in an accurate and timely manner. R649-9-11.3 Reporting and Recordkeeping for Disposal Facilities E & P Waste Facility Quarterly Reports along with results of weekly leak detection system inspections should be properly completed and submitted to the division for the above facilities IMMEDIATELY. All reports thereafter should be submitted quarterly by the15th of the month following the end of the quarter in order to avoid additional enforcement action. 4/15/2019 Permit Manager (801) 538-8303 Compliance FileCompliance File Well / Facility File Bart Kettle, Operations Manager Josh Payne, Compliance Manager Dalbo Inc. Glen Bench facility 1/31/2019 Dalbo Inc. Ace Disposal facility 1/31/2019 RN Industries Bluebell facility 1/31/2019 RN Industries Chapita facility 1/31/2019 RN Industries Glen Bench facility 1/31/2019 RN Industries Pleasant Valley facility 1/31/2019 RN Industries Seep Ridge facility 1/31/2019 RN Industries Wonsit facility 1/31/2019 Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o=DNR, ou=DOGM, email=daynedoucet@utah.gov, c=US Date: 2019.04.12 14:32:34 -06'00' Dalbo Holdings Inc./RN Industries 2/5/2019 version Lieutenant Governor R. Division Director www.ogm.utah.gov OIL, GAS&. MINING GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor State of Utah DEPARTMENT OF NATURAL RESOURCES 1594 West North Temple, Suite 1210, Salt Lake City, UT 84116 PO Box 145801, Salt Lake City, UT 84114-5801 telephone (801) 538-5340 facsimile (801) 359-3940 TTY (801) 538-7458 www.ogm.utah.gov BRIAN C. STEED Executive Director Division of Oil, Gas and Mining JOHN R. BAZA Division Director November 24, 2020 RN Industries C/O Mr. Austin Weddle P.O. Box 1168 Vernal, UT 84078 SUBJECT: Re: RNI Chapita Pond #7 Reclamation Dear Mr. Weddle: The Utah Division of Oil, Gas and Mining (Division) received DHI Energy Service’s Proposed Pond Closure Plan prepared for the RNI Chapita Evaporation Facility. Division approval was granted for the submitted reclamation proposal. Sampling points have shown that the soil samples beneath Pond #7 are within the expected background range for all of the contaminants of concern. DHI Energy is hereby permitted to continue with the final reclamation of Pond #7, as proposed in the approved Pond Closure Plan. If you have questions, feel free to contact Ammon McDonald at (801) 538-5337. Sincerely, Dayne Doucet Oil & Gas Permit Manager DD/AM/js Mr. Jim Davis; SITLA N:\O&G Permits\Disposal Facilities (Pits, LF, etc)\RN Industries (Chapita – S2, T9S, R2E, Uintah) 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