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HomeMy WebLinkAboutDSHW-2024-0094101 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 Glen Bench North Waste Management Facility Facility Address (Street or Directions to Facility) 26348 S. Glenbench Road County Uintah City. Vernal Zip Code 84078 Telephone 435-722-2800 Township T9S Range R22E Section S5 Quarter Section Quarter/Quarter Section Main Gate Latitude: 40° 4'20.08"N Longitude: 109°27'33.68"W II. Existing E&P Facilities ☐ Open Landfarm Cell(s) ☐ Evaporation Pond(s) Number of Open Landfarm Cells: Number of Evaporation Ponds: 9 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 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 3 Facility Owner Designated Contact (if different than above) Title 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: 105 acres Disposal Area: 46 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)  STATE OF UTAH Waste Disposal Permit  DEPARTMENT OF NATURAL RESOURCES AMENDED REPORT   DIVISION OF OIL, GAS AND MINING Original Filing Date: 1/15/2020 WASTE DISPOSAL PERMIT   1. Name of Operator   R N Industries   2. Utah Account Number   101818.0   3. Address of Operator                   City            State      Zip   PO Box 1168  Vernal  UT  84078     4. Phone Number    435-722-3800   5. Name of 3rd Party Contractor   GeoStrata Engineering & Geo-Sciences   6. Facility Name   Glen Bench North   7. Address of Contractor                   City            State      Zip   14425 South Center Point Way  Bluffdale  UT  84055     7. Phone Number       9. Additional Comments April 27, 2020 Sundry Number: 101724 RECEIVED: Jan. 15, 2020 ENERGY SERVICE 2180 S 1300 E Ste 310, Salt Lake City, UT 84106 and 2002 Timberloch Pl. The Woodlands, TX 77380 Rev 20181108 Engineering and Geo-Sciences Permit Renewal Application for DALBO, Inc. and RN Industries (subsidiaries of DHI) Glen Bench North E&P Waste Disposal Facility Five Year Permit Renewal Presented To: State of Utah Division of Oil, Gas and Mining Department of Natural Resources Prepared by: GeoStrata Engineering & Geo-Sciences 14425 South Center Point Way Bluffdale, UT 84055 on November 8, 2019 Property Location: 160 Acres in NE/4, Section 5, T 9S, R 22E, SLB&M Uintah County, Utah Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20181108 1 Page of 7 Engineering and Geo-Sciences 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 Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20181108 2 Page of 7 Engineering and Geo-Sciences A. Introduction and Narrative The Glen Bench North Exploration & Production(E&P) Waste Disposal facility has three separate Company Bonds associated with it. Each of these Bonds are in the name of DALBO Inc. DALBO, Inc. and RN Industries are both wholly owned subsidiaries of DHI Energy Service. The reason for the multiple entity names for this facility is a direct result of facility ownership, expansion, acquisition, and rebranding throughout the lifetime of said facility. DALBO, Inc. and RN Industries (The Company) 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. The Company 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) wastes, and other wastes as may be permitted. The Facility is located about 27 miles south of Vernal, Utah and is outside of the Vernal City limits. The address to the Facility is: 26348 South Glen Bench Road Uintah County, Utah 84078 Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20181108 3 Page of 7 Engineering and Geo-Sciences 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 Company’s Glen Bench North Exploration & Production(E&P) Waste Disposal is located on approximately 102 Acres in NE/4 of Section 5 of T 9S, R 22E, SLB&M. See DISPOSAL site map below. The current site has one office/shop building, two small sheds, two off-loading areas, one concrete oil/water separation vault (OWS), and three API-12 above-ground storage tanks. The site has a single skimming pond and 9 operational evaporation ponds. The operational evaporation ponds are range nominally from 3.0 to 10.5 acres in size. The Facility also has one landfarm. Liquid E&P Waste is discharged from tank trucks into the treatment system at the in-ground OWS. It is then directed into the skimming pond for further oil removal, recovered oil is stored in another set of above ground storage tanks. Water is then discharged to the operational evaporation ponds. Solids are de-watered and transported to the on-site Landfarm. See Existing Process Flow Diagram in Attachment 1. Tank Bottoms waste, OWS solids and similar slurries are de-watered and conditioned for Landfarm treatment. Other contaminated soils can be accepted to be treated in the Landfarm if material meets the paint filter test for moisture content. 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. Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20181108 4 Page of 7 Engineering and Geo-Sciences 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. No observable pump seals showed excessive leakage. vi. Process heaters appear to be appropriately maintained. They are thermostatically controlled and manually brought into and out of service by facility operators. vii. Exposed surfaces of tanks and piping are corrosion free with the exception of mill scale and light, tightly adhering rust. No pitting corrosion was observed. viii. Buildings The site has three buildings that include an office/shop metal building and two stick- framed sheds for storing equipment. The office/shop building is approximately 7200 square foot and is heated and fan-cooled. The two sheds are each approximately 400 square feet. ix. 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 and Solids Disposal Operation Assessment 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. Only minor portions of equipment and controls are automated. - 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. Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20181108 5 Page of 7 Engineering and Geo-Sciences 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 weekly. - 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 because this operation is not big enough to warrant remote, 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 The Company 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 Company operation and should continue to be used. ii. Landfarm Operation Assessment Landfarms are currently dormant and have been so for about five years. The following description is applicable at such time as the landfarms are being operated. - The two existing landfarms accept frac sands, filtered tank bottom sludges, and other acceptable E&P solid wastes that pass a paint filter test and contain hydrocarbons. Landfarms are a wind-row, soil remediation process that reduces petroleum contaminated soil (PCS) concentrations through biodegradation. - Contaminated soils are periodically turned over using common farming or similar equipment to aerate landfarmed soils. Soils will be worked in either a traditional fashion or using a windrow technique depending on the soil composition and volume. This practice supports naturally occurring aerobic and/or augmented micro- organisms (archaea and bacteria) consuming E&P waste in the contaminated soil. Landfarm waste bulk density, texture and porosity are controlled by addition of straw, sawdust, pearlite and similar conditioning material. Clean, low salinity water is applied as needed to keep the soils moist enough to support micro-organism growth. - Runoff water from the landfarm area is detained on the landfarm. Excess stormwater is drawn of as necessary and treated with incoming E&P waste. Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20181108 6 Page of 7 Engineering and Geo-Sciences - Visual and olfactory screening is used to monitor the landfarming process. Before material is removed from the landfarm, sampled and lab tested to ensure the treatment process has run to completion. - Engineer has determined that this treatment process and associated lab test results are being correctly applied. No changes to this treatment process are needed to comply with regulation or improve the process. e. Monitoring Program Soil and 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. iii. When in operation, sampling of landfarm soil is performed to evaluate process efficiency, completeness of hydrocarbon removal and salinity thresholds before removal of treated soil. 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 The Company should consider: i. Adding a chemical tracer to certain waste streams. ii. Low pressure (< 15 psig) leak testing followed by Dry Lay-Up of buried pipe. iii. Periodic liner leak testing. iv. Reducing the number pf impoundments that contain wastewater by moving water to the fewest impoundments practicable and have liners in the best condition. 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 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 Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20181108 7 Page of 7 Engineering and Geo-Sciences substances stored or used on site will be inventoried. 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 (excepting those materials abandoned in place), piping and concrete structures which do not add value to the site are included in the Infrastructure Removal portion of closure costs. ii. Pond liner and certain piping that do not harbor or contain E&P Waste and which will have at least two feet of soil cover will be abandoned in place. iii. 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 required to be sampled lab-tested. 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 water management. ii. Sampling and testing of groundwater. iii. Sampling and testing of site and Landfarm soil and surface water as described in the initial closure report. iv. Written report describing the condition of the reclaimed site and work performed to monitor and maintain reclaimed site. 3. Observations and Recommendations Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20181108 8 Page of 7 Engineering and Geo-Sciences Included in Articles 1. d. and 1. f, above. Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20181108 Engineering and Geo-Sciences ‘C. Attachments Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20181108 Engineering and Geo-Sciences ATTACHMENT 1 MAPS and DRAWINGS Site & Vicinity PFD Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 2 N 4 N 3 N 1 N 5 N 6 N 7 N 8 N 9 N 6 S 3 S 2 S 1 S 5 S 4 S LAND FARM LAND FARM Disposal Facility Permit RenewalRN IndustriesProject Number 524-065 0 200 400 600 800100Feet Glen Bench North Disposal Facility Map1 Legend North and South Facility Boundary Copyright GeoStrata, 2018±1:6,000BASE MAP: Aerial Orthphotography obtained from the State of Utah AGRC North Facility Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Produced Water Copyright GeoStrata, 2018 Permit Renewal RN Industries Project Number: 524-084 Legend Water Oil Solids Vault Oil/Water/solids Separator Skim Pond Evaporation Ponds Oil Tanks Imported Solids Figure 2 Imported Solids Disposed in Landfarm Glen Bench Process Flow Diagram Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Utah Division of Oil Gas & Mining Permit Renewal Application for Glen Bench Exploration & Production Waste Disposal 26348 South Glen Bench Road Uintah County, Utah Rev 20180515 Engineering and Geo-Sciences ATTACHMENT 2 CLOSURE COST ESTIMATE Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 Dalbo Inc Date: 1/10/2020 Facility: Glen Bench NORTH E&P Disposal Number of Acres to be Reclaimed 32.5 Acres 0 Contamination Remediation Cost Estimates 53,887$ 2 Removal of Infrastructure Costs Estimates 42,637$ 3 Earthwork and Grading Cost Estimates 465,386$ 4 Revegetation Cost Estimates 40,950$ 5 Final Closure & Post Closure Cost Estimates 51,621$ 6 Total Cost Estimate 654,481$ (Increase above total cost estimate by 14% if indirect costs are not included) 91,627$ Total Reclamation Cost Required 746,109$ Bond Posted 546,011$ 7 Difference Between Cost Estimate and Bond (200,098)$ Direct and Indirect Costs Five Year E&P Waste Disposal Facility Bond Calculation Summary Form Sundry Number: 101724 File: Detailed Site Description RECEIVED: Jan. 15, 2020 &ŽƌŝǀŝƐŝŽŶhƐĞKŶůLJ Compliance Review Completed: No outstanding compliance Active violation/compliance matter Signature: Comments &ŝǀĞzĞĂƌΘWtĂƐƚĞDisposal Facility Wermit Renewal Checkůisƚ WĞƌŵŝƚZĞŶĞǁĂůƉƉůŝĐĂƚŝŽŶ^ƵďŵŝƐƐŝŽŶ ^ƵďŵŝƚĂŶĂƐƐĞƐƐŵĞŶƚŽĨƐŝƚĞƌĞĐůĂŵĂƚŝŽŶƌĞƋƵŝƌĞŵĞŶƚƐĨƌŽŵĂĐĞƌƚŝĨŝĞĚ ƚŚŝƌĚƉĂƌƚLJĐŽŶƚƌĂĐƚŽƌZϲϰϵͲϵͲϴ͘Ϯ ^ƵďŵŝƚĐůŽƐƵƌĞĐŽƐƚĞƐƚŝŵĂƚĞƐĨƌŽŵĂĐĞƌƚŝĨŝĞĚƚŚŝƌĚƉĂƌƚLJĐŽŶƚƌĂĐƚŽƌ ZϲϰϵͲϵͲϴ͘Ϯ WƌŽǀŝĚĞďŽŶĚĂŵŽƵŶƚĂƉƉƌŽǀĞĚďLJƚŚĞŝǀŝƐŝŽŶZϲϰϵͲϵͲϴ ĞƚĂŝůĞĚ^ŝƚĞĞƐĐƌŝƉƚŝŽŶ &ƵŶĐƚŝŽŶŽĨƚŚĞǁĂƐƚĞĚŝƐƉŽƐĂůĨĂĐŝůŝƚLJ ƵƌƌĞŶƚĨĂĐŝůŝƚLJŵĂƉ ^ŝƚĞĚĞƐĐƌŝƉƚŝŽŶƐĂŶŶŽƚĂƚĞĚǁŝƚŚĨĂĐŝůŝƚLJŝŶĨƌĂƐƚƌƵĐƚƵƌĞĂŶĚĂƐƐŽĐŝĂƚĞĚĨƵŶĐƚŝŽŶ ŽŶƚĂŵŝŶĂƚŝŽŶƐƐĞƐƐŵĞŶƚ ĞƐĐƌŝƉƚŝŽŶŽĨĞdžŝƐƚŝŶŐĐŽŶƚĂŵŝŶĂƚŝŽŶǁŝƚŚƐĂŵƉůĞƌĞƐƵůƚƐ WƌŽƉŽƐĞĚŵŽŶŝƚŽƌŝŶŐͬƌĞŵĞĚŝĂƚŝŽŶ WƌŽƉŽƐĞĚƉƌĂĐƚŝĐĞƐƚŽƉƌĞǀĞŶƚĨƵƌƚŚĞƌĐŽŶƚĂŵŝŶĂƚŝŽŶ ƋƵŝƉŵĞŶƚƐƐĞƐƐŵĞŶƚ ĞƐĐƌŝƉƚŝŽŶĂŶĚĂƐƐĞƐƐŵĞŶƚŽĨĞƋƵŝƉŵĞŶƚůŽĐĂƚĞĚĂƚƚŚĞĨĂĐŝůŝƚLJ ĞƐĐƌŝďĞŝŶĚĞƚĂŝůƐĞƌǀŝĐĞůŝĨĞĨŽƌĞƋƵŝƉŵĞŶƚƵƐĞĚŝŶĨĂĐŝůŝƚLJŽƉĞƌĂƚŝŽŶƐĞƐĐƌŝƉƚŝŽŶŽĨƚĞƐƚŝŶŐ ĐŽŵƉůĞƚĞĚĨŽƌĞƋƵŝƉŵĞŶƚ;ƚĂŶŬƐ͕ƉŝƉŝŶŐ͕ůŝŶĞƌƐ͕ůĞĂŬĚĞƚĞĐƚŝŽŶĞƋƵŝƉŵĞŶƚ͕ĞǀĂƉŽƌĂƚŝŽŶĨĂŶƐͿ WƌĂĐƚŝĐĞƐƐƐĞƐƐŵĞŶƚ ƐƐĞƐƐŵĞŶƚŽĨŵĂŶĂŐĞŵĞŶƚƉƌĂĐƚŝĐĞƐƵƚŝůŝnjĞĚƚŽŽƉĞƌĂƚĞƚŚĞĨĂĐŝůŝƚLJ/ĚĞŶƚŝĨLJĂůƚĞƌŶĂƚŝǀĞ ƉƌĂĐƚŝĐĞƐǁŚŝĐŚĐŽƵůĚŝŵƉƌŽǀĞŽƉĞƌĂƚŝŽŶƐŽƌƌĞĚƵĐĞƉƌŽďĂďŝůŝƚLJŽĨĨƵƚƵƌĞĐŽŶƚĂŵŝŶĂƚŝŽŶ Name of &ĂĐŝůŝƚLJOperator: Name of &ĂĐŝůŝƚLJ͗ >ŽĐĂƚŝŽŶ͗ ĂƚĞ͗ WƌĞƉĂƌĞƌ͗ ĂƚĞ /ŶŝƚŝĂůƐ ĂƚĞ/ŶŝƚŝĂůƐ ZĞĐĞŝǀĞĚ ZĞǀŝĞǁĞĚ ZĞǀŝĞǁŽŵƉůĞƚĞĚ͗ƉƉůŝĐĂƚŝŽŶ^ƚĂƚƵƐ͗ WWZKs &ŽƌŝǀŝƐŝŽŶhƐĞKŶůLJĞůŽǁdŚŝƐ>ŝŶĞ RN Industries Glen Bench North E&P Waste Disposal Section 5, T9S, R22E, SLBM 05/30/18 GeoStrata ✔ Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o=DNR, ou=DOGM, email=daynedoucet@utah.gov, c=US Date: 2020.04.27 08:29:16 -06'00' 05/30/18 ASM 11/25/19 DKD 05/30/18 ASM 11/25/19 DKD 07/03/18 BW 09/26/19 BW $ 750,000 Additional bonding will be needed for this facility. Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o=DNR, ou=DOGM, email=daynedoucet@utah.gov, c=US Date: 2020.04.27 08:31:46 -06'00'✔ 07/03/18 ASM 11/26/18 ASM Landfarm test results are needed-ASM Landfarm has not been used since construction; baseline samples recommended but not required - ASM 07/03/18 ASM 11/08/19 ASM No drilling mud is allowed in the landfarm-ASM Sundry Number: 101724 RECEIVED: Jan. 15, 2020 /ŶĨƌĂƐƚƌƵĐƚƵƌĞZĞŵŽǀĂůŽƐƚƐ Contouring or RegradingŽƐƚƐ SeediŶŐŽƐƚƐ Notes: ŽŶƚĂŵŝŶĂƚŝŽŶŽƐƚƐ ƐƚŝŵĂƚŝŶŐůŽƐƵƌĞŽƐƚĂŶĚŽŶĚŝŶŐǀĂůƵĂƚŝŽŶ ZĞŵŽǀĂůͬZĞŵĞĚŝĂƚŝŽŶ ^ĂŵƉůŝŶŐ WŽƐƚĐůŽƐƵƌĞŵŽŶŝƚŽƌŝŶŐ džƉĞŶƐĞƐƚŽƌĞŵŽǀĞĂůůŝŶĨƌĂƐƚƌƵĐƚƵƌĞĂŶĚĞƋƵŝƉŵĞŶƚ WƌŽũĞĐƚĞdžƉĞŶƐĞƚŽĐŽŶƚŽƵƌƐŝƚĞďĂĐŬƚŽŽƌŝŐŝŶĂůŐƌĂĚĞ sŽůƵŵĞƐŽĨŵĂƚĞƌŝĂů ƋƵŝƉŵĞŶƚĐŽƐƚƐ >ĂďŽƌĐŽƐƚƐ DĞƚŚŽĚŽĨƌĞƐĞĞĚŝŶŐ ^ƉĞĐŝĞƐƵƐĞĚĨŽƌƌĞǀĞŐĞƚĂƚŝŽŶ ĂƚĞ/ŶŝƚŝĂůƐ ZĞĐĞŝǀĞĚ Comments DŽŶŝƚŽƌŝŶŐWƌŽŐƌĂŵ ĞƚĂŝůĞĚĚĞƐĐƌŝƉƚŝŽŶŽĨŵŽŶŝƚŽƌŝŶŐƉƌŽŐƌĂŵƐŝŶƵƐĞŽƌďĞŝŶŐƉƌŽƉŽƐĞĚ;ǀŝƐƵĂůŝŶƐƉĞĐƚŝŽŶƐŽĨ ĞƋƵŝƉŵĞŶƚ͕ƉƌĞƐƐƵƌĞƚĞƐƚƐ͕ůĞĂŬĚĞƚĞĐƚŝŽŶƐLJƐƚĞŵƐ͕ǁĂƐƚĞĂĐĐŽƵŶƚĂďŝůŝƚLJ͕ĂƵƚŽŵĂƚĞĚƐLJƐƚĞŵƐ͕ ƉƌŽƉŽƐĞĚƉƌĂĐƚŝĐĞƐǁŚŝĐŚĐĂŶƌĞĚƵĐĞƚŚĞƌŝƐŬŽĨĨƵƚƵƌĞĐŽŶƚĂŵŝŶĂƚŝŽŶͿ 11/08/19 ASM All leak detection sumps will be monitored and reported on a weekly basis-ASM 07/03/18 BW Is there a need for Contaminated Soil removal? Request made of GeoStrata on May 2, 2019. Land farms were tested. 07/03/18 BW 07/03/18 BW Earthwork and grading seems low. Review and questions asked. 07/03/18 BW BTW Visited both North and South Glen Bench. Sundry Number: 101724 RECEIVED: Jan. 15, 2020 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