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HomeMy WebLinkAboutDSHW-2024-0094121 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 Seep Ridge Waste Management Facility Facility Address (Street or Directions to Facility) 38180 South Seep Ridge Rd. County Uintah City. Zip Code 84078 Telephone 435-722-2800 Township T10S Range R20E Section S36 Quarter Section Quarter/Quarter Section Main Gate Latitude: 39°54'13.84"N Longitude: 109°36'17.83"W II. Existing E&P Facilities ☐ Open Landfarm Cell(s) ☐ Evaporation Pond(s) Number of Open Landfarm Cells: Number of Evaporation Ponds: 5 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? 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: 654 acres Disposal Area: 28.3 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: 4/15/2019 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 Seep Ridge   7. Address of Contractor                   City            State      Zip 14425 South Center Point Way  Bluffdale  UT  84055 7. Phone Number 9. Additional Comments April 15, 2019 Sundry Number: 95391 RECEIVED: Apr. 15, 2019 ENERGY SERVICE 2180 S 1300 E Ste 310, Salt Lake City, UT 84106 and 2002 Timberloch Pl. The Woodlands, TX 77380 Rev 20190325 Engineering and Geo-Sciences Permit Renewal Application for RN Industries (a subsidiary of DHI) Seep Ridge 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 March 25, 2019 Initial Submittal Date: May 15, 2018 Property Location: 640 Acres in Section 36, T 10S, R 20E, SLB&M Uintah County, Utah Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Utah Division of Oil Gas & Mining Permit Renewal Application for Seep Ridge Exploration & Production Waste Disposal 38180 South Seep Ridge Road, Uintah County, Utah Rev 20190325 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: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Utah Division of Oil Gas & Mining Permit Renewal Application for Seep Ridge Exploration & Production Waste Disposal 38180 South Seep Ridge Road, Uintah County, Utah Rev 20190325 2 Page of 7 Engineering and Geo-Sciences 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) wastes, and other wastes as may be permitted. The Facility is located about 34 miles south-southeast of Roosevelt, Utah and is outside of the Roosevelt City limits. The address to the Facility is: 38180 South Seep Ridge Road Uintah County, Utah 84021 Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Utah Division of Oil Gas & Mining Permit Renewal Application for Seep Ridge Exploration & Production Waste Disposal 38180 South Seep Ridge Road, Uintah County, Utah Rev 20190325 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 RN Industries (RNI) Seep Ridge Exploration & Production(E&P) Waste Disposal occupies Section 36, T 10S, R 20E, SLB&M. Section 36 has been leased from Utah State Institutional Trust Lands by RNI. About 100 acres in the southeast corner of Section 36 is being used for E&P Waste disposal and treatment. See DISPOSAL site map in Attachment 1. The current site has one small office building, an off-loading area, one concrete oil/water separation vault (OWS), and three API-12 above-ground storage tanks. The site has a single skimming pond and five operational evaporation ponds. The operational evaporation ponds are nominally 6.6 acres each. 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 from all treatment processes are transported off-site. See Existing Process Flow Diagram in Attachment 1. One stormwater detention basin, located near the center of Section 36 has 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. Site has been mapped by the US Army Corps of Engineers (USACOE) in accordance with procedures to satisfy Rapanos v. United States, 547 U.S. 715 (2006). USACOE has determined that over 75% of the site contains “Waters of the United States” and cannot be disturbed without obtaining a 33 CFR Part 323, Section 404 Permit specific to the site and each drainage channel on the site. 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 Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Utah Division of Oil Gas & Mining Permit Renewal Application for Seep Ridge Exploration & Production Waste Disposal 38180 South Seep Ridge Road, Uintah County, Utah Rev 20190325 4 Page of 7 Engineering and Geo-Sciences 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. 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 excessive erosion. iv. Observable portions of piping and HDPE liners are not excessively worn or weathered. v. No observable pump seals showed excessive leakage and drips are installed where necessary for bearing water. 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 - An approximately 300 square foot, stick-framed office building with no potable water or wash water supply or wastewater drainage is located in the northeast portion of the area that has been developed for a waste disposal. 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: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Utah Division of Oil Gas & Mining Permit Renewal Application for Seep Ridge Exploration & Production Waste Disposal 38180 South Seep Ridge Road, Uintah County, Utah Rev 20190325 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 regularly. - Solids that accumulate in onsite tanks and vaults will be periodically cleaned out and disposed offsite. - 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 leak detection monitoring should be decreased (i.e. allow a longer time between subsequent observations) to quarterly time periods when the ponds are empty. Otherwise, if ponds remain full, monitoring should be weekly. 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. 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. 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 is performed 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. i. To enhance early detection of inadvertent waste release and more accurately determine leak sources RNI should consider: - Adding a chemical tracer to certain waste streams. - Low pressure leak testing followed by Dry Lay-Up of buried pipe. - Periodic liner leak testing. Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Utah Division of Oil Gas & Mining Permit Renewal Application for Seep Ridge Exploration & Production Waste Disposal 38180 South Seep Ridge Road, Uintah County, Utah Rev 20190325 6 Page of 7 Engineering and Geo-Sciences 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 Any salt precipitated out and remaining on liner after evaporation will be cleaned off and removed by hydrovac. Rates were determined by Badger Daylighting of SLC, Utah and are included in this component of closure cost estimate. 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. 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. As a general rule, 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. *Soil used for embankment was sourced from offsite and is classified as common earth and will be referenced as so in bonding estimates. e. Seeding and Revegetation Scope of Work Seeding/revegetation cost is based 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. Closure PID survey results and required sampling and lab testing. Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Utah Division of Oil Gas & Mining Permit Renewal Application for Seep Ridge Exploration & Production Waste Disposal 38180 South Seep Ridge Road, Uintah County, Utah Rev 20190325 7 Page of 7 Engineering and Geo-Sciences 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. 3. Observations and Recommendations Included in Articles 1. d. and 1. f, above. Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Utah Division of Oil Gas & Mining Permit Renewal Application for Seep Ridge Exploration & Production Waste Disposal 38180 South Seep Ridge Road, Uintah County, Utah Rev 20190325 Engineering and Geo-Sciences ‘C. Attachments Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Utah Division of Oil Gas & Mining Permit Renewal Application for Seep Ridge Exploration & Production Waste Disposal 38180 South Seep Ridge Road, Uintah County, Utah Rev 20190325 Engineering and Geo-Sciences ATTACHMENT 1 MAPS and DRAWINGS Site & Vicinity PFD Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 0 500 1,000 1,500 2,000250Feet 1:9,019 BASE MAP: 2016 NAIP 1 Meter Orthophotography Obtained from the State of Utah AGRC ± Disposal Facility Permit RenewalRN IndustriesProject Number 524-084 Seep Ridge Disposal Facility Map1 Legend Site Boundary 5 4 3 7 6 Copyright GeoStrata, 2018 SKIM POND Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 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 Figure 2 Solids Disposed at off site Landfarm Seep Ridge Process Flow Diagram Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Utah Division of Oil Gas & Mining Permit Renewal Application for Seep Ridge Exploration & Production Waste Disposal 38180 South Seep Ridge Road, Uintah County, Utah Rev 20190325 Engineering and Geo-Sciences ATTACHMENT 2 CLOSURE COST ESTIMATE DOGM summary & GeoStrata Backup Calcs Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 RN Industries Date: 3/25/2019 Facility: Seep Ridge E&P Disposal Number of Acres to be Reclaimed 91.0 Acres 0 Contamination Remediation Cost Estimates 53,537$ 2 Removal of Infrastructure Costs Estimates 40,787$ 3 Earthwork and Grading Cost Estimates 437,506$ 4 Revegetation Cost Estimates 54,721$ 5 Final Closure & Post Closure Cost Estimates 34,000$ 6 Total Cost Estimate 620,551$ (Increase above total cost estimate by 14% if indirect costs are not included) 86,877$ Total Reclamation Cost Required 707,428$ Bond Posted 1,171,244$ 7 Difference Between Cost Estimate and Bond 463,816$ Direct and Indirect Costs Five Year E&P Waste Disposal Facility Bond Calculation Summary Form Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 Item 0 References & Comments Percentage 7% 01 21 55.50 0200 With an additional 2% of unforseeable events 3% 01 31 00 Adjusted to reflect a percentage, also referenced ACEC and ASCE for rates 1% 01 41 26.50 0100 0% 01 51 00 Not applicable for the scope and scale of a project like this 3% 01 71 00 Adjusted to reflect a percentage, also referenced ACEC and ASCE for rates Total: 14% 1 91 Acres Total Site 640 Acres 2 Unit Quantity Unit Price Extended Cost Reference Gallon 574,983 -$22,760$02 65 10.30 0130 (modifed for scale) Bbl 17,869 0.72$12,780$ 31 23 23.20 4096 adjusted to cy for hauling (with $.65 / bbl cost for disposal facility to accept waste) Includes removal by Vac Truck and disposal of 10% of tank bottom Day 6.75 2,000.00$6,100$ Badger Daylighting, SLC. Cost for total removal with Hydrovac 0 -$-$ 0 -$-$ Positive Samples 3.528736 Varies 11,898$MWH Standard 0 -$-$ Total: 53,537$ 3 Unit Quantity Unit Price Extended Cost Cubic Feet 1,284 Varies 655$02 41 19.20 0020 Each 3 Varies No Cost (net of salvage) 02 65 10.30 1253 No Cost net of Salvage Each 4 200.00$No Cost (net of salvage) 02 65 10.30 1253 No Cost net of Salvage Cubic Yard 67 8.10$543$22 05 05.10 2164 Modified to add truck loading Cubic Yard 2,538 Varies 6,903$31 23 16.42 1550 Modified to add truck loading Square Foot 2,176 Varies 2,621$02 41 16.17 0440, 2500,2620 Linear Foot 7,342 Varies 16,593$02 41 13.60 1600 Cubic Yard 207 1.73$4,737$31 23 23.20 4104 Modified for Proximity to Duchesne LF Ton 209 20.00$8,735$Tonnage Rates for Wasatch/Bluebench Disposal Total: 40,787$ 4 Unit Quantity Unit Price Extended Cost cubic yard 234,659 1.76$415,485$31 23 16.46 5020 cubic yard -2.83$-$31 23 16.46 5040 cubic yard -1.53$-$31 23 16.46 5000 square foot 440,432 0.05$22,022$31 22 13.20 0280 (modifed for scale) Total: 437,506$ 5 Unit Quantity Unit Price Extended Cost MSF 1,891 28.94 54,721$32 92 19.14 5800 (modified with specific seeding costs of Granite Seed in Lehi, UT) Total: 54,721$ 6 Unit Quantity Unit Price Extended Cost Year 1 450.00$4,500$GeoStrata estimates based off of inhouse estimates Year 10 120.00$1,200$GeoStrata estimates based off of inhouse estimates Year 10 600.00$6,000$GeoStrata estimates based off of inhouse estimates Annual 9 1,000.00$9,000$32 91 13.23 Structural Soil Mixing (pg 331) Year 1 Varies 2,100$GeoStrata estimates based off of inhouse estimates Year 8 1,000.00$8,000$GeoStrata estimates based off of inhouse estimates Year 2 1,600.00$3,200$GeoStrata estimates based off of inhouse estimates Total: 34,000$ 7 Type ID Number Posted Amount 1 7 1,171,244$ Total: 1,171,244$ Initial and Final Post Closure Report Descripiton Well Inspection & Sampling Rough Grading Revegetation Cost Estimates Descripiton Listed Reclamation Water Quality Meter Rental Lab Analysis Grounds Maintenance Monitoring Well Abandonment Annual Report Initial and Final Post Closure Report Bond Posted Bond Descripiton & Date Hydro Seeding of Indian Rice Grass Sand & Gravel to be Moved Tanks Gensets Buried Piping Concrete Vault Fencing Earthwork and Grading Cost Estimates Descripiton Common Earth to be Dozed Clay to be Moved Hauling Dumping Removal of Infrastructure Costs Estimates Descripiton Buildings Shred and Remove Liner RN Industries Seep Ridge E&P Disposal Site Assessment, Closure & Post Closure Cost Estimate & Re-statement of Existing Bonds in Suport of DOGM Bonding Evaluation Reclaimed Area Contamination Remediation Cost Estimates DOGM Line Item Indirect Costs Descripiton Contingencies Price and Payments Procedures Administrative Requirements Quality Requirements Temporary Facilities and Controls Executions of Closeout Requirements PID Closure Soil Sampling Post Remediation Monitoring Descripiton Removal of Contaminated Liquid Disposal of Contaminated Liquid (Haul and Dump) Removal of Salt Deposits Pump & Treat Self Attenuating Sundry Number: 95391 File: Detailed Site Description RECEIVED: Apr. 15, 2019 &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 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BTK Army Corps of Eng 404 permit(?)-ASM Site Diagram Attachment 1 -BTK 1/14/2019 07/05/18 ASM Volume of solids contained by evaporation ponds not addressed in cost estimate -BTK 1/14/2019 07/05/18 ASM 07/05/18 ASM Fencing for facility, and the Sludge Pond in place? Sundry Number: 95391 RECEIVED: Apr. 15, 2019 /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 ƉƌŽƉŽƐĞĚƉƌĂĐƚŝĐĞƐǁŚŝĐŚĐĂŶƌĞĚƵĐĞƚŚĞƌŝƐŬŽĨĨƵƚƵƌĞĐŽŶƚĂŵŝŶĂƚŝŽŶͿĐŽŶƚĂŵŝŶĂƚŝŽŶͿ 03/25/19 ASM Leak detection system will be monitored on a weekly basis-ASM. Corrected in V3-25-2019 - ASM 03/25/19 BW See notes. Updated submitted. 03/25/19 BW Liners and buried piping will be removed. SITLA Lease. 03/25/19 BW 03/25/19 BW 01/14/2019 Cost Estimate Notes -BTK 1. Sec 3 Removal of Infrastructure estimate is based on shredding liner material. Anticipating SITLA will require removal. Response: New Cost include liner and buried piping removed. 2. Sec 2 Contamination Remediation Cost unable to see figures for removal of accumulated salts contained by ponds. Response: Additional contamination removal costs added. 3. Sec 4 Earthwork and Grading used Common Earth instead of clay in unit price, NRCS soils survey indicates clay is 20% of the site. Response: The soil, Common Earth, was brought in during construction are not the original clay soils. An email was sent to GeoStrata requesting updated cost to include items 2 and 3 above. 1/14/2019 3/26/2019 $710,000. bond required includes updates for corrected sq. Current bond held is about $1,171,244.00 These cost also Includes Monitoring, annual, initial and final closure reports and well abandonment costs. BW Sundry Number: 95391 RECEIVED: Apr. 15, 2019 State of Utah DEPARTMENT OF NATURAL RESOURCES GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor MICHAEL R. STYLER Executive Director Division of Oil, Gas and Mining JOHN R. BAZA Division Director Permit to Operate ******************** Facility Name:Seep Ridge Facility Type: Commercial Waste Disposal Facility Location: Section 36, Township 10S, Range 20E County:Uintah Approval Date:April 15, 2019 1. Issued to: R N Industries (80635) 2. Authority: Pursuant to Utah Code Ann. §§ 40-6-1 et seq., and Utah Admin. Code §§ R649-9 et seq., the Utah Division of Oil, Gas and Mining (“Division”) issues this Permit to operate an E and P waste disposal facility. 3. Duration: This Permit shall expire five years from the Approval Date. The Division may revoke, suspend, or impose additional operating conditions or limitations on a disposal facility permit at any time, for good cause, after notice to the operator. The Division may suspend a waste disposal permit or impose additional conditions or limitations in an emergency to forestall an imminent threat to fresh water, public health, or safety of the environment. Suspension of a disposal facility permit may be for a fixed period of time or until the operator remedies the violation or potential violation. If the Division suspends a disposal facility permit, the disposal facility shall not accept E and P waste during the suspension period. 4. General: 4.1 Effect on Prior Permits. This Permit supersedes any existing E and P waste disposal permit previously obtained for the Facility and provides the terms that govern operations at this Facility. 4.2 Incorporation of Application.The Division issues this Permit in response to RNI’s “Permit Renewal Application” dated 3/25/2019 and received by the Division on 3/25/2019, (“Application”). The Facility shall operate in accordance with the best management practices described in the Application. 4.3 Compliance with Applicable Laws. The Facility shall comply with Utah Code Ann. §§ 40-6- 1 et seq. and Utah Administrative Code §§ R649-9 et seq.. 5. Reporting and Recordkeeping Requirements: 1594 West North Temple, Suite 1210, PO Box 145801, Salt Lake City, UT 84114-5801 telephone (801) 538-5340 x facsimile (801) 359-3940 x TTY (801) 538-7458 x www.ogm.utah.gov Sundry Number: 95391 RECEIVED: Apr. 15, 2019 The Facility shall comply with the reporting and recordkeeping requirements in Utah Admin. Code § R649-9-11. 6. Modifications: This Permit only applies to the Facility as it is described in the Application. Any additions to the Facility or modifications of the waste treatment processes described in the Application are not allowed and require a permit modification. 7. Enforcement: The issuance of this permit does not supersede local ordinances, county planning and zoning requirements, or other permits required to conduct business at the Facility. A copy of this approval should be kept at the Seep Ridge field office, and field personnel shall be aware of the Conditions of Approval. 8. Approval: Therefore, having met all the technical permit requirements of Utah Admin. Code §§ R649-9 et seq., final approval to operate the Facility in accordance with this Permit is hereby granted. 9. Contact Information: The following are Division of Oil, Gas and Mining contacts and their telephone numbers: Dayne Doucet, Permit Manager: 801-538-5303 Bart Kettle, Operations Manager: 435-820-0862 Ammon McDonald, Environmental Scientist: 801-538-5337 Approved By: ________________________ By: Dayne Doucet Title: Permit Manager Dayne Doucet Digitally signed by Dayne Doucet DN: cn=Dayne Doucet, o=DNR, ou=DOGM, email=daynedoucet@utah.gov, c=US Date: 2019.04.15 10:32:24 -06'00' Sundry Number: 95391 RECEIVED: Apr. 15, 2019 Conditions of Approval: 1. Evaporation Facilities 1.1 A minimum of 2 feet of freeboard shall be maintained in the pit(s) at all times, and that a method of obviously displaying the freeboard shall be devised and implemented. Utah Admin. Code § R649-9-4.6.4. 1.2 Pit(s) are to be maintained such that hydrocarbons will not collect on the surface. Hydrocarbon accumulations, other than de minimis quantities, shall be removed within 24 hours. Utah Admin. Code § R649-9-4.6.4. 1.3 Spraying water to accelerate evaporation should be closely monitored. Overspray outside the lined pit area is considered a violation. Utah Admin. Code § R649-9-4.9.2. 1.4 The leak detection system must be checked weekly. Any leak must be reported to the Division immediately, and corrective measures must be taken as directed by the Division. 1.5 The compacted secondary containment berms at the Facility shall be inspected quarterly and after a major rainstorm or windstorm to ensure integrity Utah Admin. Code § R649-9-11.3.2. 1.6 Evaporation ponds are permitted to accept produced water. FAILURE TO COMPLY WITH THE ABOVE LISTED CONDITIONS OF APPROVAL MAY RESULT IN CLOSURE OF THE FACILITY. Sundry Number: 95391 RECEIVED: Apr. 15, 2019 GARY R. HERBERT Governor SPENCER J. COX /LHXWHQDQW*RYHUQRU State of Utah DEPARTMENT OF NATURAL RESOURCES 1594 West North Temple, Suite 1210,6DOW/DNH&LW\87 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 MICHAEL R. STYLER Executive Director Division of Oil, Gas and Minin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ate of Mailing: Certified Mail No.: &RPSOLDQFH'HDGOLQH 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 Well or )DFLLW\1DPH API # Date of Inspection )LQHVPD\EHOHYLHGXSWRSHUGD\IRUHYHU\ZHOOLQYLRODWLRQ 5HTXLUHG$FWLRQV JLYHQWKHDXWKRULW\SURYLGHGXQGHU8&$SDUW This notice shall remain in effect until it is modified, terminated, or vacated by a written notice of an authorized representative of the director of the Division of Oil, Gas and Mining. Failure to comply with this notice will result in the Division pursuing further actions against said operator. Further actions may include initiation of agency actions to order full cost bonding and plugging and abandonment of wells and requests for bond forfeiture and civil penalties. &RPSOLDQFH'HDGOLQH cc /LVWRI:HOO V RU)DFLOLW\LQ9LRODWLRQ 3DJHRI 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 Jean Sweet <jsweet@utah.gov> Fwd: March 2020 Monthly AOC Reports 1 message Dayne Doucet <daynedoucet@utah.gov>Thu, Apr 9, 2020 at 3:11 PM To: Jean Sweet <jsweet@utah.gov> Dayne Doucet Oil &Gas Permit Manager Utah Division of Oil, Gas, and Mining 801-538-5303 (office) oilgas.ogm.utah.gov @UtahOGM ---------- Forwarded message --------- From: Bart Kettle <bartkettle@utah.gov> Date: Thu, Apr 9, 2020 at 3:10 PM Subject: Fwd: March 2020 Monthly AOC Reports To: Chase Hanberg <chanberg@utah.gov>, Ammon McDonald <ammonmcdonald@utah.gov>, Dayne Doucet <daynedoucet@utah.gov> Bart Kettle Utah Division of Oil, Gas and Mining Acting Deputy Director, Oil and Gas Program Phone 435-820-0862 ---------- Forwarded message --------- From: Kirk Fleetwood <kfleetwood@dalboholdings.com> Date: Mon, Apr 6, 2020 at 9:43 AM Subject: March 2020 Monthly AOC Reports To: McNeill, Kristin <McNeill.Kristin@epa.gov> Cc: Bart Kettle <bartkettle@utah.gov> Kristie, Here are the monthly reports. I am waiting on some additional pictures from Seep Ridge and them I will be ready to submit the Corrective Measures Summary Report for that facility. Regards, Kirk Fleetwood Regulatory/Compliance DHI Energy Service T 435.828.3451 E kfleetwood@dalboholdings.com W www.dalboholdings.com This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. 3 attachments image001.png 10K March 2020 Wonsits.pdf 135K March 2020 Seep Ridge.pdf 134K Seep Ridge Disposal Monthly Progress Report March 2020 RN Industries submits the following report per the requirements of Section VIII, 39 Reporting. A1 Activities conducted • The tasked identified in Section VIII 37 Corrective Measures A1 and A3 have been completed. • Per the Operations and Maintenance Plan, the skim pond netting was inspected every day that the facility was staffed during the month and no holes are gaps in the netting was observed. • Per the Operations and Maintenance Plan, the bird deterrent devices were visually inspected every day that the facility was staffed during the month and they were found to be operating as designed. • On March 15 the facility operator installed additional reflective deterrent tape around Pond 7 • Per the Operations and Maintenance Plan, the pond and grounds were monitored for birds and other wildlife. No dead or injured birds were observed. No other wildlife was observed in or on the banks of the ponds. A2 Summary of problems encountered • There were no problems were encountered during the month. A3 Changes in work performed at the Facility • All work required in the Seep Ridge Disposal AOC Work Plan has been completed. There were no deviations from the approved Operations and Maintenance Plan. A4 Projected work for the next reporting period • N/A, all work required in the Seep Ridge Disposal AOC Work Plan has been completed. I will be submitting a Corrective Measures Summary Report this month that demonstrates and certifies that all work committed to in the Work Plan has been complete and requesting approval to transition to Quarterly Reporting. A5 Monitoring log for deceased birds • There were no deceased, or injured birds observed at the facility during the month. I certify that the information contained in or accompanying this report is true, accurate, and complete. As to the identified portions of this report for which I cannot personally verify their accuracy, I certify under penalty of law that this report and all attachments were prepared in accordance with procedures designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, or the immediate supervisor of such persons, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Signature· Name: Austin Weddle Title: Operations Manager Date: 4/6/2020 Jean Sweet <jsweet@utah.gov> Fwd: Seep Ridge CMSR approval 1 message Dayne Doucet <daynedoucet@utah.gov>Tue, Apr 21, 2020 at 8:20 AM To: Jean Sweet <jsweet@utah.gov> FYI. Should probably go in the file. Dayne Doucet Oil &Gas Permit Manager Utah Division of Oil, Gas, and Mining 801-538-5303 (office) oilgas.ogm.utah.gov @UtahOGM ---------- Forwarded message --------- From: Bart Kettle <bartkettle@utah.gov> Date: Tue, Apr 21, 2020 at 8:12 AM Subject: Fwd: Seep Ridge CMSR approval To: Chase Hanberg <chanberg@utah.gov>, Ammon McDonald <ammonmcdonald@utah.gov>, Dayne Doucet <daynedoucet@utah.gov> Bart Kettle Utah Division of Oil, Gas and Mining Acting Deputy Director, Oil and Gas Program Phone 435-820-0862 ---------- Forwarded message --------- From: McNeill, Kristin <McNeill.Kristin@epa.gov> Date: Mon, Apr 20, 2020 at 3:38 PM Subject: Seep Ridge CMSR approval To: kfleetwood@dalboholdings.com <kfleetwood@dalboholdings.com> Cc: bartkettle@utah.gov <bartkettle@utah.gov>, Cline, Chris <Chris_cline@fws.gov>, Agee, Erin <Agee.Erin@epa.gov> Hi Kirk, Please see the attached letter approving the RNI Seep Ridge Corrective Measures Summary Report that you submitted on April 10, 2020. Because this letter was electronically signed and processed, you will not be receiving a hard copy. Please let me know if you have any questions. Thanks, Kristie Kristie McNeill U. S. EPA Region 8 RCRA Enforcement Branch Enforcement and Compliance Assurance Division 1595 Wynkoop St, 8ENF-RO-R Denver, CO 80202 303.312.6278 RNI Seep Ridge CMSR approval_signed.pdf 166K April 20, 2020 REF: 8ENF-RO-R SENT VIA EMAIL DIGITAL READ RECEIPT REQUESTED Mr. Kirk Fleetwood RN Industries kfleetwood@dalboholdings.com Re: Approval of Seep Ridge Disposal Corrective Measures Summary Report, RN Industries Seep Ridge OWDF, EPA ID No. UTR000014761 Dear Mr. Fleetwood: This correspondence serves to notify RN Industries that, per section VIII.37.K. of the RCRA 7003 Administrative Order on Consent (AOC), Docket No. RCRA-08-2020-0003, the Corrective Measures Summary Report (CMSR) for the Seep Ridge Oilfield Wastewater Disposal Facility, dated April 10, 2020, is approved by the U.S. Environmental Protection Agency. Per VIII.39.C. of the RCRA 7003 AOC, upon the acceptance of the CMSR, the reporting requirement in VIII.39.A. becomes a quarterly reporting requirement. The first report will be due on July 10, 2020, with subsequent reports due quarterly. Recent photographs showing the up-to-date status of netting and evaporation ponds shall be included, at minimum, twice annually. According to VIII.39.D., RN Industries shall continue submitting quarterly reports until the EPA determines that reporting can continue on a semi-annual or annual basis, which may be requested at any time after two quarterly reports have been submitted. Thank you for your attention to this important matter. If you have questions regarding this correspondence, please contact Ms. Kristin McNeill of my staff at (303) 312-6278 or mcneill.kristin@epa.gov. Any legal questions should be raised with Ms. Erin Agee at (303) 312-6374 or agee.erin@epa.gov. Sincerely, Janice Pearson, Chief RCRA/OPA Enforcement Branch cc via email: Bart Kettle, Utah Division of Oil, Gas and Mining Christine Cline, U.S. Fish and Wildlife Service Erin Agee, EPA UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595 Wynkoop Street Denver, CO 80202-1129 Phone 800-227-8917 www.epa.gov/region8 Seep Ridge Disposal Monthly Progress Report May 2020 RN Industries submits the following report per the requirements of Section VIII, 39 Reporting. A1 Activities conducted • All tasked identified in Section VIII 37 Corrective Measures A1 and A3 have been completed. • Per the Operations and Maintenance Plan, the skim pond netting was inspected every day that the facility was staffed. There were and no holes or gaps observed in the netting. • Per the Operations and Maintenance Plan, the bird deterrent devices were visually inspected every day that the facility was staffed during the month. They were found to be in good condition and operating as designed. • Per the Operations and Maintenance Plan, the pond and grounds were monitored for birds. No dead or injured birds were found • No other wildlife was observed in or on the banks of the ponds. A2 Summary of problems encountered • There were no problems were encountered during the month. A3 Changes in work performed at the Facility • All work required in the Seep Ridge Disposal AOC Work Plan has been completed. There were no deviations from the approved Operations and Maintenance Plan. A4 Projected work for the next reporting period • In March of this year we submitted a Corrective Measures Summary that demonstrated and certified that all work committed to in the Work Plan has been completed. In the April 2020 Progress report, we requested approval to transition to Quarterly Reporting. We are still waiting for approval to make that transition and will continue to submit Monthly reports until it is approved. A5 Monitoring log for deceased birds • There were no deceased, or injured birds observed at the facility during the month. I certify that the information contained in or accompanying this report is true, accurate, and complete. As to the identified portions of this report for which I cannot personally verify their accuracy, I certify under penalty of law that this report and all attachments were prepared in accordance with procedures designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, or the immediate supervisor of such persons, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Signature· Name: Austin Weddle Title: Operations Manager Date: 6/2/2020 RECEIVED: Apr. 02, 2021   STATE OF UTAH DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL, GAS, AND MINING  FORM 9 SUNDRY NOTICES AND REPORTS ON FACILITIES 1. TYPE OF FACILITY   Waste Facility/Commercial  5. FACILITY NAME:  Seep Ridge  2. NAME OF OPERATOR:  R N Industries  6. FACILITY NUMBER:  273  3. ADDRESS OF OPERATOR:  PO Box 1168 , Vernal, UT, 84078  7. PHONE NUMBER:  435-722-3800  4. LOCATION OF FACILITY     Qtr/Qtr:NWSE Section: 36 Township: 10S Range: 20E Meridian: S  COUNTY:  UINTAH  STATE:  UTAH  11. CHECK APPROPRIATE BOXES TO INDICATE NATURE OF NOTICE, REPORT, OR OTHER DATA  TYPE OF SUBMISSION TYPE OF ACTION     NOTICE OF INTENT  Approximate date work will start:     SUBSEQUENT REPORT  Date of Work Completion: 4/2/2021     New Facility Construction        Repair of Facility        Facility Reclamation        Facility Status Report        Results of Sampling         Change to Previous Plans        E&P Waste Disposal Facility Permit        Other EPA Administrative Order of Consent Monthly Report 12. DESCRIBE PROPOSED OR COMPLETED OPERATIONS. Clearly show all pertinent details including dates, depths, volumes, etc. The Quarterly OAC report as required by US EPA NAME (PLEASE PRINT)    Austin Weddle   PHONE NUMBER 435-790-6690  TITLE  Disposal Manager  SIGNATURE  N/A  DATE  4/2/2021  (This is not an approval) April 12, 2021 Sundry Number: 109300 Facility Number: 273 RECEIVED: Apr. 02, 2021 Seep Ridge Disposal Quarterly Progress Report March 2021 RN Industries submits the following report per the requirements of Section VIII, 39 Reporting. A1 Activities conducted • The facility was closed to new water deliveries in February. RNI does not currently have plans to reopen the facility. • Per the Operations and Maintenance Plan, the skim pond netting was inspected every day that the facility was staffed. • Per the Operations and Maintenance Plan, the bird deterrent devices were visually inspected every day that the facility was staffed during the month. During the quarter, additional reflective tape and flashers were installed to replace some which had become degraded by UV light. The owl decoys were inspected and found to be in good condition and operating as designed. • Per the Operations and Maintenance Plan, the pond and grounds were monitored for birds. No dead or injured birds were found • No other wildlife was observed in or on the banks of the ponds. A2 Summary of problems encountered • On March 13th, the site received 6 inches of heavy wet snow. The weight of the snow on the pond nettting pulled one of the cable support anchors out of the ground which allowed the net to sag. The anchor was repaired, and the net retightened the following week. There were and no holes or gaps observed in the netting during the quarter. There were no other problems encountered. A3 Changes in work performed at the Facility • There were no deviations from the approved Operations and Maintenance Plan. A4 Projected work for the next reporting period • Per Section VIII 39 (D) RNI would like to propose that the reporting interval be changed to semi-annually starting in July. A5 Monitoring log for deceased birds • There were no deceased birds observed at the facility during the 4th quarter of 2020 Sundry Number: 109300 Facility Number: 273 RECEIVED: Apr. 02, 2021 I certify that the information contained in or accompanying this report is true, accurate, and complete. As to the identified portions of this report for which I cannot personally verify their accuracy, I certify under penalty of law that this report and all attachments were prepared in accordance with procedures designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, or the immediate supervisor of such persons, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Signature· Name: Austin Weddle Title: Operations Manager Date: 4/2/2021 Sundry Number: 109300 Facility Number: 273 RECEIVED: Jul. 07, 2021   STATE OF UTAH DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL, GAS, AND MINING  FORM 9 SUNDRY NOTICES AND REPORTS ON FACILITIES 1. TYPE OF FACILITY   Waste Facility/Commercial  5. FACILITY NAME:  Seep Ridge  2. NAME OF OPERATOR:  R N Industries  6. FACILITY NUMBER:  273  3. ADDRESS OF OPERATOR:  PO Box 1168 , Vernal, UT, 84078  7. PHONE NUMBER:  435-722-3800  4. LOCATION OF FACILITY     Qtr/Qtr:NWSE Section: 36 Township: 10S Range: 20E Meridian: S  COUNTY:  UINTAH  STATE:  UTAH  11. CHECK APPROPRIATE BOXES TO INDICATE NATURE OF NOTICE, REPORT, OR OTHER DATA  TYPE OF SUBMISSION TYPE OF ACTION     NOTICE OF INTENT  Approximate date work will start:     SUBSEQUENT REPORT  Date of Work Completion: 7/7/2021     New Facility Construction        Repair of Facility        Facility Reclamation        Facility Status Report        Results of Sampling         Change to Previous Plans        E&P Waste Disposal Facility Permit        Other EPA Administrative Order of Consent Monthly Report 12. DESCRIBE PROPOSED OR COMPLETED OPERATIONS. Clearly show all pertinent details including dates, depths, volumes, etc.  This is the Quarterly AOC report NAME (PLEASE PRINT)    Austin Weddle   PHONE NUMBER 435-790-6690  TITLE  Disposal Manager  SIGNATURE  N/A  DATE  7/7/2021  July 09, 2021 Sundry Number: 110898 Facility Number: 273 RECEIVED: Jul. 07, 2021 Seep Ridge Disposal Quarterly Progress Report June 2021 RN Industries submits the following report per the requirements of Section VIII, 39 Reporting. A1 Activities conducted • The facility was closed to new water deliveries in February 2021. RNI does not currently have plans to reopen the facility and will notified UDOGM that they intend to close the facility and begin reclamation this year. • Per the Operations and Maintenance Plan, the skim pond netting was inspected every day that the facility was staffed. • Per the Operations and Maintenance Plan, the bird deterrent devices were visually inspected every day that the facility was staffed during. The owl decoys were inspected and found to be in good condition and operating as designed. • Per the Operations and Maintenance Plan, the pond and grounds were monitored for birds. Ducks were observed swimming on Pond #7 on June 10th and June 20th. Both times when the facility operator approached the pond the ducks flew away. • No dead or injured birds were found. • No other wildlife was observed in or on the banks of the ponds. A2 Summary of problems encountered • There were no other problems encountered. A3 Changes in work performed at the Facility • There were no deviations from the approved Operations and Maintenance Plan. A4 Projected work for the next reporting period • Per Section VIII 39 (D) RNI proposes that the reporting interval be changed to semi- annually. If this proposal is approved the next report for the facility would be due in January of 2022. A5 Monitoring log for deceased birds • There were no deceased birds observed at the facility during the 2nd quarter of 2021 Sundry Number: 110898 Facility Number: 273 RECEIVED: Jul. 07, 2021 I certify that the information contained in or accompanying this report is true, accurate, and complete. As to the identified portions of this report for which I cannot personally verify their accuracy, I certify under penalty of law that this report and all attachments were prepared in accordance with procedures designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, or the immediate supervisor of such persons, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Signature· Name: Austin Weddle Title: Operations Manager Date: 7/7/2021 Sundry Number: 110898 Facility Number: 273 RECEIVED: Aug. 04, 2021   STATE OF UTAH DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL, GAS, AND MINING  FORM 9 SUNDRY NOTICES AND REPORTS ON FACILITIES 1. TYPE OF FACILITY   Waste Facility/Commercial  5. FACILITY NAME:  Seep Ridge  2. NAME OF OPERATOR:  R N Industries  6. FACILITY NUMBER:  273  3. ADDRESS OF OPERATOR:  PO Box 1168 , Vernal, UT, 84078  7. PHONE NUMBER:  435-722-3800  4. LOCATION OF FACILITY     Qtr/Qtr:NWSE Section: 36 Township: 10S Range: 20E Meridian: S  COUNTY:  UINTAH  STATE:  UTAH  11. CHECK APPROPRIATE BOXES TO INDICATE NATURE OF NOTICE, REPORT, OR OTHER DATA  TYPE OF SUBMISSION TYPE OF ACTION     NOTICE OF INTENT  Approximate date work will start:     SUBSEQUENT REPORT  Date of Work Completion: 8/4/2021     New Facility Construction        Repair of Facility        Facility Reclamation        Facility Status Report        Results of Sampling         Change to Previous Plans        E&P Waste Disposal Facility Permit        Other EPA Administrative Order of Consent Monthly Report 12. DESCRIBE PROPOSED OR COMPLETED OPERATIONS. Clearly show all pertinent details including dates, depths, volumes, etc.  July EPA AOC Report NAME (PLEASE PRINT)    Austin Weddle   PHONE NUMBER 435-790-6690  TITLE  Disposal Manager  SIGNATURE  N/A  DATE  8/4/2021  August 09, 2021 Sundry Number: 111576 Facility Number: 273 RECEIVED: Aug. 04, 2021 Wonsits Disposal Monthly Progress Report July 2021 RN Industries submits the following report per the requirements of Section VIII, 41 Reporting. 1. Activities Conducted in the Previous Month • Additional progress was made in removing material from Pond 5 and transferring it to the landfill during July. I have included a video and a couple images that show the current state of the pond remediation. 2. Summary of problems encountered, and solutions employed • No problems were encountered during the month 3. Changes in work performed at the Facility • The source of the netted skim pond leak was identified and repaired. We are waiting on UDOGM approval to add water to the netted pond 4. Projected work for the next reporting period • We will continue moving material from Pond 5 to the landfill. • Receive approval from UDOGM and begin taking water at the facility. Sundry Number: 111576 Facility Number: 273 RECEIVED: Aug. 04, 2021 I certify that the information contained in or accompanying this report is true, accurate, and complete. As to the identified portions of this report for which I cannot personally verify their accuracy, I certify under penalty of law that this report and all attachments were prepared in accordance with procedures designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, or the immediate supervisor of such persons, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Signature· Name: Austin Weddle Title: Operations Manager Date: 8/4/2021 Sundry Number: 111576 Facility Number: 273 RECEIVED: Jan. 21, 2022   STATE OF UTAH DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL, GAS, AND MINING  FORM 9 SUNDRY NOTICES AND REPORTS ON FACILITIES 1. TYPE OF FACILITY   Waste Facility/Commercial  5. FACILITY NAME:  Seep Ridge  2. NAME OF OPERATOR:  R N Industries  6. FACILITY NUMBER:  273  3. ADDRESS OF OPERATOR:  PO Box 1168 , Vernal, UT, 84078  7. PHONE NUMBER:  435-722-3800  4. LOCATION OF FACILITY     Qtr/Qtr:NWSE Section: 36 Township: 10S Range: 20E Meridian: S  COUNTY:  UINTAH  STATE:  UTAH  11. CHECK APPROPRIATE BOXES TO INDICATE NATURE OF NOTICE, REPORT, OR OTHER DATA  TYPE OF SUBMISSION TYPE OF ACTION     NOTICE OF INTENT  Approximate date work will start:     SUBSEQUENT REPORT  Date of Work Completion: 1/21/2022     New Facility Construction        Repair of Facility        Facility Reclamation        Facility Status Report        Results of Sampling         Change to Previous Plans        E&P Waste Disposal Facility Permit        Other AOC Reprot 12. DESCRIBE PROPOSED OR COMPLETED OPERATIONS. Clearly show all pertinent details including dates, depths, volumes, etc.  AOC report, pictures were included to Bart Kettle in email from Austin Weddle NAME (PLEASE PRINT)    Austin Weddle   PHONE NUMBER 435-790-6690  TITLE  Disposal Manager  SIGNATURE  N/A  DATE  1/21/2022  January 21, 2022 Sundry Number: 114692 Facility Number: 273 RECEIVED: Jan. 21, 2022 Seep Ridge Disposal Semi-Annual Progress Report, July-December 2021 RN Industries submits the following report per the requirements of Section VIII, 39 Reporting. A1 Activities conducted •The facility was closed to new water deliveries in February 2021. RNI does not currently have plans to reopen the facility. •Per the Operations and Maintenance Plan, the skim pond netting was inspected every day that the facility was staffed. •Per the Operations and Maintenance Plan, the bird deterrent devices were visually inspected every day that the facility was staffed. The owl decoys were inspected and found to be in good condition and operating as designed per each inspection. •Per the Operations and Maintenance Plan, the pond and grounds were monitored for birds. •No dead or injured birds were found. •No other wildlife was observed in or on the banks of the ponds. A2 Summary of problems encountered •A few small holes were found in netting and repaired with zip ties. A3 Changes in work performed at the Facility •There were no deviations from the approved Operations and Maintenance Plan. A4 Projected work for the next reporting period •Per Section VIII 39 (D) RNI will report on a smei-annual basis, and the next report will be sent out on July of 2022. A5 Monitoring log for deceased birds •There were no deceased birds observed at the facility during the 2nd half of 2021 Sundry Number: 114692 Facility Number: 273 RECEIVED: Jan. 21, 2022 I certify that the information contained in or accompanying this report is true, accurate, and complete. As to the identified portions of this report for which I cannot personally verify their accuracy, I certify under penalty of law that this report and all attachments were prepared in accordance with procedures designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, or the immediate supervisor of such persons, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Signature· Name: Austin Weddle Title: Operations Manager Date: 1-14-22 Sundry Number: 114692 Facility Number: 273 RECEIVED: Jul. 14, 2022   STATE OF UTAH DEPARTMENT OF NATURAL RESOURCES DIVISION OF OIL, GAS, AND MINING  FORM 9 SUNDRY NOTICES AND REPORTS ON FACILITIES 1. TYPE OF FACILITY   Waste Facility/Commercial  5. FACILITY NAME:  Seep Ridge  2. NAME OF OPERATOR:  R N Industries  6. FACILITY NUMBER:  273  3. ADDRESS OF OPERATOR:  PO Box 1168 , Vernal, UT, 84078  7. PHONE NUMBER:  435-722-3800  4. LOCATION OF FACILITY     Qtr/Qtr:NWSE Section: 36 Township: 10S Range: 20E Meridian: S  COUNTY:  UINTAH  STATE:  UTAH  11. CHECK APPROPRIATE BOXES TO INDICATE NATURE OF NOTICE, REPORT, OR OTHER DATA  TYPE OF SUBMISSION TYPE OF ACTION     NOTICE OF INTENT  Approximate date work will start:     SUBSEQUENT REPORT  Date of Work Completion: 7/14/2022     New Facility Construction        Repair of Facility        Facility Reclamation        Facility Status Report        Results of Sampling         Change to Previous Plans        E&P Waste Disposal Facility Permit        Other AOC Report 12. DESCRIBE PROPOSED OR COMPLETED OPERATIONS. Clearly show all pertinent details including dates, depths, volumes, etc.  Seep Ridge Semi annual AOC report NAME (PLEASE PRINT)    Kendal Hacking   PHONE NUMBER 435-828-8712  TITLE  Operations Manager-Environment  SIGNATURE  N/A  DATE  7/14/2022  August 17, 2022 Sundry Number: 118027 Facility Number: 273 RECEIVED: Jul. 14, 2022 Seep Ridge Disposal Semi-Annual Progress Report, January-June 2022 RN Industries submits the following report per the requirements of Section VIII, 39 Reporting. A1 Activities conducted • The facility was closed to new water deliveries in February 2021. RNI does not currently have plans to reopen the facility. • Per the Operations and Maintenance Plan, the skim pond netting was inspected every day that the facility was staffed. • Per the Operations and Maintenance Plan, the bird deterrent devices were visually inspected every day that the facility was staffed. The owl decoys were inspected and found to be in good condition and operating as designed per each inspection. • Per the Operations and Maintenance Plan, the pond and grounds were monitored for birds. • No dead or injured birds were found. • No other wildlife was observed in or on the banks of the ponds. A2 Summary of problems encountered • A few small holes were found in netting and repaired with zip ties. • Small hole in top of cell liner ~1” in diameter was found and fixed. A3 Changes in work performed at the Facility • There were no deviations from the approved Operations and Maintenance Plan. A4 Projected work for the next reporting period • Per Section VIII 39 (D) RNI will report on a semi-annual basis, and the next report will be sent out on January of 2023. A5 Monitoring log for deceased birds • There were no deceased birds observed at the facility during the 1st half of 2022. Sundry Number: 118027 Facility Number: 273 RECEIVED: Jul. 14, 2022 I certify that the information contained in or accompanying this report is true, accurate, and complete. As to the identified portions of this report for which I cannot personally verify their accuracy, I certify under penalty of law that this report and all attachments were prepared in accordance with procedures designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, or the immediate supervisor of such persons, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Signature· Name: Kendal Hacking Title: Operations Manager Date: 7-14-22 Sundry Number: 118027 Facility Number: 273 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