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Home My WebLink AboutDSHW-2024-0094131 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 Wonsit Waste Management Facility Facility Address (Street or Directions to Facility) County Uintah City Vernal Zip Code 84078 Telephone Township 8S Range 21E Section 26 Quarter Section Quarter/Quarter Section Main Gate Latitude: Longitude: II. Existing E&P Facilities ☐ Open Landfarm Cell(s) ☐ Evaporation Pond(s) Number of Open Landfarm Cells: 0 Number of Evaporation Ponds: 6 III. Facilities to be Permitted by DWMRC ☐ Landfill Cell(s) ☐ Surface Impoundment(s) Number of Landfill Cells:6 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 Dalbo Inc. Mailing Address P.O. Box 1168 City Vernal State Utah Zip Code 84078 Telephone 435-722-2800 VI. Designated Contact Information Facility Owner Designated Contact (if different than above) Title 3 Mailing Address City. State Zip Code Telephone Email Address Alternative Telephone (cell phone or other) Facility Operator Designated Contact (if different than above) Title Mailing Address City State Zip Code Telephone Email Address Alternative Telephone (cell phone or other) Property Owner Contact (if different than above) Title Mailing Address City State Zip Code Telephone Email Address Alternative Telephone (cell phone or other) VII. Waste Types to be Disposed of (check all that apply) VIII. Facility Area ☐ Exploration and Production wastes that are exempt from hazardous waste rules (R315-260-4(b)(5)). ☐ Very Small Quantity Generator hazardous waste Facility Area: 161 acres Disposal Area: 47.1 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: 6/17/2020 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 6. Facility Name Wonsit 7. Address of Contractor City State Zip 14425 S Center Point Way Bluffdale UT 84065 7. Phone Number 8015010583 9. Additional Comments August 11, 2020 Sundry Number: 104605 RECEIVED: Jun. 17, 2020 RN Industries Date: 4/29/2020 Facility: Wonsit E&P Disposal Number of Acres to be Reclaimed 63 Acres 0 Contamination Remediation Cost Estimates $ 76,296 2 Removal of Infrastructure Costs Estimates 26,666$ 3 Earthwork and Grading Cost Estimates $ 585,719 4 Revegetation Cost Estimates $ 79,064 5 Final Closure & Post Closure Cost Estimates 52,403$ 6 Additional cost associated with inflation from 2018-2020 16,106$ Total Cost Estimate $ 836,253 (Increase above total cost estimate by 14% if indirect costs are not included) $ 117,075 Total Reclamation Cost Required $ 953,328 Bond Posted 1,461,497$ 7 Difference Between Cost Estimate and Bond $ 508,169 Direct and Indirect Costs Five Year E&P Waste Disposal Facility Bond Calculation Summary Form Sundry Number: 104605 File: Bond Calculation Summary Form RECEIVED: Jun. 17, 2020 Item 0 Percentages 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 62.7 Acres Total Site 160 Acres 2 Unit Quantity Unit Price Extended Cost Gallons 1,140,697 0.04$44,487$02 65 10.30 0130 (modifed for scale) Bbl 27,159 0.68$17,653$ 31 23 23.20 4096 adjusted to cy for hauling (with $.65 / bbl cost for disposal facility to accept waste) 0 0 -$Above costs include the removal (by vac truck) and disposal of 10% of tank volume 0 0 -$ 0 0 -$ Positive Samples 5 Varies 14,155$GeoStrataStandard 0 0 -$ Total: 76,296$ 3 Unit Quantity Unit Price Extended Cost Cubic Yard 1,070 Varies 546$02 41 19.20 0020 Each -Varies No Cost (net of salvage)02 65 10.30 1253 Each 4 200.00$No Cost (net of salvage)02 65 10.30 1253 Linear Foot 3,700 Varies -$Leak Detection Pipe will be ground up with liner shredding cubic yard -4.28$1,875$31 23 16.32 0020 Cubic Yard -1.09$-$02 41 16.17 0440 Linear Foot 9,959 Varies 22,507$02 41 13.60 1600 Cubic Yard 116 1.61$186$31 23 23.20 4104 Modified for Proximity to Duchesne LF Ton 78 20.00$1,552$Duchesne/ Wasatch Bluebench Landfill Tonnage Rates Total: 26,666$ 4 Unit Quantity Unit Price Extended Cost cubic yard 262,414 1.76$461,849$31 23 16.46 5020 cubic yard -2.83$-$31 23 16.46 5040 cubic yard -1.53$-$31 23 16.46 5000 square foot 2,477,398 0.05$123,870$31 22 13.20 0280 (modifed for scale) Total: 585,719$ 5 Unit Quantity Unit Price Extended Cost MSF 2,732 28.94 79,064$32 92 19.14 5800 (modified with specific seeding costs of Granite Seed in Lehi, UT) Total: 79,064$ 6 Unit Quantity Unit Price Extended Cost Year 10 990.00$9,900$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 Month 9 1,000.00$9,000$32 91 13.23 Structural Soil Mixing (pg 331) Month 12 850.21$10,203$32 91 13.23 6000 Tilling 6" Cost for 12 tillings Year 1 Varies 2,100$GeoStrata estimates based off of inhouse estimates Year 8 1,200.00$9,600$GeoStrata estimates based off of inhouse estimates Year 2 2,200.00$4,400$GeoStrata estimates based off of inhouse estimates Total: 52,403$ 7 Type ID Number Posted Amount 1 7 1,461,497$ Total: 1,461,497$ Self Attenuating PID Closure Soil Sampling Post Remediation Monitoring Descripiton Removal of Contaminated Liquid Disposal of Contaminated Liquid (Haul and Dump) Vapor Extraction Pump & Treat RN Industries Wonsit 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 Removal of Infrastructure Costs Estimates Descripiton Buildings Shred Liner Final Closure & Post Closure Cost Estimates Descripiton Well Inspection & Sampling 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 Landfarm Rough Grading Revegetation Cost Estimates Descripiton Hydro Seeding of Indian Rice Grass Sand & Gravel to be Moved Tanks (No cost - net of salvage) Gensets Buried Piping Concrete Pads Fencing Earthwork and Grading Cost Estimates Descripiton Common Earth to be Dozed Clay to be Moved Hauling Dumping Sundry Number: 104605 File: Bond Calculation Summary Form RECEIVED: Jun. 17, 2020 ENERGY SERVICE 355 S 1000 E Vernal UT, 84078 Permit Renewal Application RN Industries (a subsidiary of DHI) Wonsits E&P Waste Disposal Facility Five Year Permit Renewal May 1, 2020 Property Location: 162 Acres in SESE QTR/QTR Section 26 and NE QTR Section 35, T8S, R21E, SLB&M Uintah County, Utah Sundry Number: 104605 File: Detailed Site Description RECEIVED: Jun. 17, 2020 Wonsits E&P Waste Disposal Facility 374 East Chapita Grove Road Uintah County, Utah 1 Page of 7 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 – Operations Procedure 3. Attachment 3 – Third Party Closure Cost Estimate Sundry Number: 104605 File: Detailed Site Description RECEIVED: Jun. 17, 2020 Wonsits E&P Waste Disposal Facility 374 East Chapita Grove Road Uintah County, Utah 2 Page of 7 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. The Facility receives and treats produced water and associated entrained hydrocarbons and solids from Oil and Gas producers. The Facility is located about 25 miles South of Vernal, Utah. The address to the Facility is: 374 East Chapita Grove Road Uintah County, Utah 84078 Sundry Number: 104605 File: Detailed Site Description RECEIVED: Jun. 17, 2020 Wonsits E&P Waste Disposal Facility 374 East Chapita Grove Road Uintah County, Utah 3 Page of 7 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) Wonsits E&P Waste Disposal is located on approximately 162 Acres in the SESE QTR-QTR of Section 26 and the NE QTR of Section 35, T 8S, R 21E, SLB&M. See Attachment 1. The current site has one small office building, an off-loading area, one concrete oil/water separation vault (OWS), and two API-12 above-ground storage tanks. The site has a single skim pond, seven operational evaporation ponds, and one pond that is currently being reclaimed. The operational evaporation ponds range from 5.5 to 8.4 acres in size. The Facility also has one inactive landfarm that is also in the reclamation process. Liquid E&P waste is discharged from tank trucks into the inground oil water separation vault (OWS). Entrained solids settle to the bottom of the vault and oil collects on the surface. Water flows through a downcomer pipe from the OWS to the skim pond for further oil separation and removal. Water is then discharged from the skim pond to the operational evaporation ponds. Oil that is recovered from the OWS and skim pond is stored in above ground tanks. Solids are dewatered and transported to the onsite landfill. See Process Flow Diagram in Attachment 1. Water diversion ditches and stormwater detention basins have been designed and constructed to hold runoff generated by a 25-year, 24-hour storm. If it became necessary to remove storm water from the detention basins, it will be transferred either via pump or vacuum truck to OWS and allowed to enter the evaporation ponds. In 2018 a large volume of waste oil was released from the netted skim pond and ended up in evaporation pond 5. The waste material was contained within the impoundment banks of the pond. The pond has been closed and drained of free liquids. During the operational life of the pond, solids built up and will now need to be removed. The solids are currently being removed and placed in the onsite landfill. It is anticipated that pond will be emptied by the end of 2020. After the pond is emptied, the soil under the liner will be tested for contamination and following UDOGM approval it will be reclaimed. The skim pond that was in place in 2018 has been removed and replaced with a new design that was approved by the Division in December 2019. With the receiving evaporation pond (pond 5) being taken out of service, it will be necessary to reroute the flowline from the skim pond to the new receiving pond which will be pond 3. The construction drawings of the proposed reroute we submitted to the Division in March of 2020. Work will begin on the reroute following approval by the Division. The Operations and Maintenance Plan (Attachment 2) describes the procedures that RNI has implemented to ensure the new receiving pond will be kept free of hydrocarbons. b. Contamination Evaluation Sundry Number: 104605 File: Detailed Site Description RECEIVED: Jun. 17, 2020 Wonsits E&P Waste Disposal Facility 374 East Chapita Grove Road Uintah County, Utah 4 Page of 7 There is no known surface soil contamination on this site. No process induced vadose zone soil or unconfined aquifer contamination is known to exist. Monitoring wells drilled to the uppermost aquiclude have always been dry. There are no known records of incomplete uncontained spill clean-up. Process containment berms, sumps and similar enclosures that are currently operational are free from pooled oil and/or measurable oil accumulation. c. Equipment Evaluation 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. Process heaters are appropriately maintained. They are thermostatically controlled and manually brought in and out of service by facility operators when needed. vi. 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. vii. Buildings - An approximately 150 square foot portable wood-framed structure with no potable water, wash water supply or wastewater drainage is used as an office and for parts storage. d. Practices Assessment As discussed in section b, in 2018 a large volume of waste oil was released from the netted skim pond and ended up in evaporation pond 5. An investigation into the cause of the release showed that it was a primarily a result of failure of the facility supervisor and operations personnel to maintain the oil levels of the skim pond and OWS at levels that would allow sufficient retention time for them to work as they are designed and also processing liquid wastes through the headworks at a rate higher than they could work efficiently. At the direction of UDOGM and the US EPA, RNI personnel have reviewed the operational practices at the facility and have made the following changes: i. RNI has implemented an operations policy which will require regular cleaning of oil and sediment from the concrete receiving vault and will also limit the rate that water is accepted at the facility (see Attachment 2). The objectives of these operational changes are to reduce or eliminate the amount of oil flowing from the concrete receiving vault to the covered skim pond. ii. The facility operator is required to measure and record the depth of oil on the skim pond and OWS daily. Oil will be removed from the skim pond when it reaches a depth equal to or greater than 4 inches. iii. RNI will reduce the number of offload connections to the cement vault from 4 to 2 increase the minimum retention time before fluid moves to the skim pond. Sundry Number: 104605 File: Description of Contamination RECEIVED: Jun. 17, 2020 Wonsits E&P Waste Disposal Facility 374 East Chapita Grove Road Uintah County, Utah 5 Page of 7 iv. Process sampling will continue to be performed manually and locally because the Facility is not big enough to warrant remote, automated process sampling. v. The biggest process variable is the type of waste brought to the Facility. There is no available commercially off- the-shelf (COTS) equipment to automate the incoming waste classification process. 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, 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 Water Sampling and testing is performed on all liquid taken from leak detection sumps. i. Leak Detection Monitoring of designated leak detection sumps is performed weekly. ii. Facility inspection will be performed daily when the Facility is open and the inspection results will be recorded on a tablet-based inspection form. The forms are automatically forwarded to the Disposal Manager for review and saved in the RNI corporate database. 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 RNI is considering: i. Annual low-pressure (< 15 psig) testing of buried pipe between the skim pond and the receiving pond. ii. Periodic liner leak testing. 2. Closure Cost and Bonding Evaluation Bond cost components referenced in this section have been determined by GeoStrata, a third party Geologic and Engineering company based in Bluffdale Utah. applying unit costs to quantity take-off from drawings and documents provided by Owner and cursory field inspections and surveys by GeoStrata personnel. a. Contamination Evaluation No evidence of Soil, Surface Water or Groundwater contamination has been found at the 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 PID survey. Groundwater Sundry Number: 104605 File: Description of Equipment RECEIVED: Jun. 17, 2020 Wonsits E&P Waste Disposal Facility 374 East Chapita Grove Road Uintah County, Utah 6 Page of 7 quality will be sampled tested in an approved lab. Any hazardous substances stored or used on site will be inventoried and either repurposed at another RNI property or disposed of in an approved disposal facility. 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. Grading and contouring the site to the exact site geometry before site was used as an E&P Disposal has not been used as a reclamation criterion Generally, infrastructure removal closure cost estimates include: i. Removal all tanks, security fence, buildings, liner materials, piping and concrete structures which do not add value to the site are included in the Infrastructure Removal portion of closure costs. ii. Earthwork and grading to restore the site to a condition that does not create excessive ponding or erosion and is similar to the surrounding land use and drainage. e. Seeding and Revegetation Scope of Work Seeding/revegetation cost that is based on drag harrowing and drill seeding is included in the closure cost estimate. Seed mixture and application rate was determined by Great Basin Company of Ephraim, Utah. f. Initial Closure Monitoring Report This report describes: i. Closure PID survey results and required sampling and lab testing. ii. Groundwater and surface water required to be sampled and 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 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 Included in Articles 1. d. and 1. f, above. Sundry Number: 104605 File: Assessment of Managment Practices RECEIVED: Jun. 17, 2020 Wonsits E&P Waste Disposal Facility 374 East Chapita Grove Road Uintah County, Utah ATTACHMENT 1 MAPS and DRAWINGS Site & Vicinity Process Flow Diagram Sundry Number: 104605 File: Description of Monitoring Programs RECEIVED: Jun. 17, 2020 162. 325 650 975 1,300 Feet 16000 2 1 4 3 5 6 7 LAND FARM LAND FILL SKIM POND 8 Disposal Facility Permit Renewal RN Industries Wonsits E&P Disposal Facility Map 1 Legend Copyright GeoStrata, 2018 BASE MAP: 2016 NAIP Aerial Orth photography obtained from the State of Utah 0 Sundry Number: 104605 File: Description of Monitoring Programs RECEIVED: Jun. 17, 2020 Produced Water Vault Oil/Water/solids Separator Skim Pond Evaporation Ponds Legend Water Oil Solids Wonsits Process Flow Diagram Figure 2 Solids Disposed in Landfill Sundry Number: 104605 File: Description of Monitoring Programs RECEIVED: Jun. 17, 2020 Wonsits Exploration & Production Waste Disposal 374 East Chapita Grove Road Uintah County, Utah ATTACHMENT 2 Operations and Maintenance Plan Plans for operations of the concrete receiving vault and skim pond RNI has implemented an operations policy which will require regular cleaning of oil and sediment from the concrete receiving vault and will also limit the rate that water is accepted at the facility. The objectives of these operational changes are to reduce or eliminate the amount of oil flowing from the concrete receiving vault to the covered skim pond. To achieve this objective, RNI will reduce the number of offload connections to the cement vault from 4 to 2. And, although there will be two offload connections at the vault, the facility operators have been instructed to only allow two trucks to unload simultaneously when the fluid volume in the concrete vault is low enough that simultaneous offloading will not cause significant carry over of oil to the skim pond. RNI has also implemented a policy change that will require that the facility operator recover oil from the skim pond when the oil depth on the surface is greater than 4 inches. The oil depth on the skim pond will be measured each day and when it is greater than 4 inches it will be removed with a vacuum truck and placed in the above ground tanks. Regular and effective skimming (or other removal measures) of evaporation ponds to address oil sheens and oily waste RNI will install an oil absorbent double boom at the inlet of the receiving evaporation pond to capture and contain any oil that might reach the pond. The boom will be inspected daily and, if oil is present, it will be removed promptly. Ongoing inspection and maintenance of skim pond netting and synthetic liners When the facility is reopened for produced water deliveries, the skim pond netting will be inspected daily. During the inspection, the operators will be instructed to ensures that there are no gaps between the net and the ground surface and that the netting does not sag down into the pit and record the results of the inspection. If deficiencies are observed in the netting, the operator will attempt to correct them at that time. If it is not possible to correct them immediately, the operator is instructed to contact his supervisor who is the designated project coordinator for RNI. The project coordinator with arrange to have the netting fixed in a timely manner. When the operator inspects the containment booms of the receiving evaporation pond, he will also be inspecting the pond and liner surfaces to ensure that no oil is escaping containment. If oil is reaching the evaporation pond, he will notify his supervisor who is the designated project coordinator for RNI. The project coordinator will make an assessment to determine the cause. The primary cause of oil reaching the evaporation pond will be inadequate retention time in the headworks of the facility. If it is determined that the headworks are not functioning properly, he will divert produced water to other facilities until the problem with the headworks can be resolved. Sundry Number: 104605 Closure Cost Estimates From 3rd Party Contractor RECEIVED: Jun. 17, 2020 Wonsits Exploration & Production Waste Disposal 374 East Chapita Grove Road Uintah County, Utah ATTACHMENT 3 CLOSURE COST ESTIMATE Bev summary & GeoStrata Backup Calcs Sundry Number: 104605 Closure Cost Estimates From 3rd Party Contractor RECEIVED: Jun. 17, 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 Landfill 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