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HomeMy WebLinkAboutDSHW-2024-0094381 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 Integrated Water Management North Blue Bench Facility Address (Street or Directions to Facility) 20250 W 2000 S County Duchesne City. Duchesne Zip Code 84021 Telephone (435) 454-4646 Township T2S Range R4W Section 29 Quarter Section SW Quarter/Quarter Section SW Main Gate Latitude: Longitude: II. Existing E&P Facilities ☐ Open Landfarm Cell(s) Closed X Evaporation Pond(s) Yes Number of Open Landfarm Cells: 1 Number of Evaporation Ponds: 2 (2 skim ponds, 2 Evap Ponds) III. Facilities to be Permitted by DWMRC X Landfill Cell(s) 2 permitted Cells X Surface Impoundment(s) 4 Number of Landfill Cells:2 Number of Surface Impoundments:4 (2 skim ponds, 3 Evap Ponds) III. Facility Owner(s) Information Legal Name of Facility Owner Integrated Water Management LLC Mailing Address PO Box 1068 City Duchesne State UT Zip Code 84021 Telephone (435) 454-4646 IV. Facility Operator(s) Information Legal Name of Facility Operator Integrated Water Management LLC Mailing Address PO Box 430 City Duchesne State UT Zip Code 84021 Telephone (435) 454-4646 V. Property Owner(s) Information Is the property leased? NO Name of Property Owner Integrated Water Management LLC Mailing Address PO Box 430 City Duchesne State UT Zip Code 84021 Telephone (435) 454-4646 VI. Designated Contact Information 3 Facility Owner Designated Contact (if different than above) Russell Sorensen Title Operations Manager Mailing Address PO Box 430 City. Duchesne State UT Zip Code 8401 Telephone (435) 454-4646 Email Address rsorensen@iwmutah.com 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 X Exploration and Production wastes that are exempt from hazardous waste rules (R315-260-4(b)(5)). ☐ Very Small Quantity Generator hazardous waste NO Hazardous Waste Facility Area: 90 acres Disposal Area: 1.6 acres IX. Application Documents Indicate documents attached to this application (all are required): x Facility Map with each landfarm cell, landfill cell, and surface impoundment labeled x Copy of Division of Oil, Gas, and Mining Permit x Copy of Division of Oil, Gas, and Mining Approval/Issuance Letter x Copy of Division of Oil, Gas, and Mining Bonding (Financial Assurance) 1:6,000 ± Integrated Water ManagementTempoary PermitDuchesne, UTProject Number: 751-109 Site Vicinity Map 0 300 600 900 1,200150Feet Plate1 Copyright GeoStrata, 2024 Legend Facilty Evaporation Pond Land Farm Closed Landfill Skim Pond 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: IWM/North Blue Bench Facility Type: Commercial Waste Disposal Facility Location: Section 30, Township 2S, Range 4W County: Duchesne Approval Date: November 19, 2018 1. Issued to: INTEGRATED WATER MANAGEMENT, LLC 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 IWM’s “Permit Renewal Application” dated 04/24/2018 and received by the Division on 07/26/2018, (“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: The Facility shall comply with the reporting and recordkeeping requirements in Utah Admin. Code § R649-9-11. 1594 West North Temple, Suite 1210, PO Box 145801, Salt Lake City, UT 84114-5801 telephone (801) 538-5340 • facsimile (801) 359-3940 • TTY (801) 538-7458 • www.ogm.utah.gov Sundry Number: 88041 RECEIVED: May. 11, 2018 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 IWM/North Blue Bench 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 Sundry Number: 88041 RECEIVED: May. 11, 2018 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. 2. Landfarms 2.1 E and P waste accepted by the landfarm shall be sufficiently free of liquid content to pass a 60-mesh liquid paint filter test (i.e., no produced water or drilling mud). 2.2 Pooling of liquids in the landfarm is prohibited. 2.3 Within 72 hours after receipt of E and P waste, the operator shall prepare materials for remediation. 2.4 Soils shall be turned regularly, a minimum of once a month. 2.5 Additional materials shall not be added until the soil concentrations of the current lift meet the Division’s salinity and hydrocarbon cleanup standards. FAILURE TO COMPLY WITH THE ABOVE LISTED CONDITIONS OF APPROVAL MAY RESULT IN CLOSURE OF THE FACILITY. Sundry Number: 88041 RECEIVED: May. 11, 2018  STATE OF UTAH Waste Disposal Permit  DEPARTMENT OF NATURAL RESOURCES AMENDED REPORT   DIVISION OF OIL, GAS AND MINING Original Filing Date: 5/11/2018 WASTE DISPOSAL PERMIT   1. Name of Operator   INTEGRATED WATER MANAGEMENT LLC   2. Utah Account Number   101104.0   3. Address of Operator                   City            State      Zip   PO BOX 430   ALTAMONT  UT  84001     4. Phone Number    435-454-4646   5. Name of 3rd Party Contractor   GeoStrata   6. Facility Name   IWM North Blue Bench   7. Address of Contractor                   City            State      Zip   14425 South Center Point Way  Bluffdale  UT  84055     7. Phone Number    8015010583   9. Additional Comments November 19, 2018 Sundry Number: 88041 RECEIVED: May. 11, 2018 20250 W 2000 S, Altamont, Utah 84001-0430 Rev 20180515 Permit Renewal Application for Integrated Water Management a division of Integrated Energy Companies IWM 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 14425 South Center Point Way Bluffdale, UT 84055 on April 24, 2018 Property Location: Approximately 89 Acres in SE/4 & NE/4 of SE/4 Section 30 and SW/4 of SW/4 Section 29, T 2S, R 4W, UBSM Duchesne County, Utah Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180420 1 Page of 9 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 3. Attachment 3 – Landfarm Data and Drawings Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180420 2 Page of 9 A. Introduction and Narrative Integrated Water Management (IWM) 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 GeoStrata™, a third-party contractor. IWM understands that permit renewals may be approved for a five-year period depending on the results of DOGM’s review 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 8 miles north of Duchesne, Utah and 0.3-miles east of Utah State Route 87. The address to the Facility is: 2050 West 2000 South Altamont, Utah 84002-0430 Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180420 3 Page of 9 B. Site Description and Assessment, and Closure and Post Closure Cost Estimate 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 Site Description: The IWM Exploration & Production(E&P) Waste Disposal is located on approximately 89 Acres situate in SE/4 & NE/4 of SE/4 Section 30 and SW/4 of SW/4 Section 29, T 2S, R 4W, UBSM. a. Site Description. The current site has of four fixed buildings, an off-loading area, one covered, concrete, in-ground pump vault, 34-each, API-12 above-ground storage tanks which are in service, four operational evaporation ponds, one three-acre Landfarm and one E&P Waste Landfill. The E&P Waste Landfill is regulated by Utah Department of Environmental Quality, Division of Waste Management and Radiation Control, Solid Waste Program Management. Although the IWM Landfill is co-located at the Facility, it is not regulated by DOGM. The operational evaporation ponds are nominally 3.3, 1.0, 0.3 and 0.3 acres respectively. Heating fuel is stored in one 30,000 gallon propane tank. That tank is mechanically protected by an earthen berm on the north and a concrete wall on the south. One set of injection pumps and one injection well are also located on the 90-acre site. Liquid E&P Waste is discharged into the treatment system from transport trucks and above- ground pipelines. Water having relatively low solids content and no economically recoverable oil is routed directly to a bank of nine above-ground, injection-water holding tanks. Water having high solids content and/or a relatively economically recoverable oil content is piped to a set of, API-12, heated and un-heated gravity separation tanks, then to two, heated cone- bottom tanks for separation enhancement. Cone-bottom tank effluent is mixed with certain conditioning reagents before being pumped to three centrifuge separators. Solids from gravity and enhanced gravity separation are stored in holding tanks before being landfarmed. Water from gravity and enhanced-gravity separation is routed to injection water holding tanks. Treated water is temporarily held in the operational evaporation ponds only when injection water surge capacity is needed to equalize flow to injection water pumps. Oil from gravity and enhanced-gravity separation is temporarily held in an “oil-take-away tank” before being piped to oil sales holding tanks. Tank Bottoms waste and similar slurries are de-watered and conditioned for Landfarm treatment. Hydrocarbon Contaminated Soils are accepted to be treated in the Landfarm if those materials meet the paint filter test for moisture content. Other permitted E&P waste is taken to the 4.5-acre landfill which is not permitted or regulated by DOGM. Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180420 4 Page of 9 One, 3.5-acre Stormwater Detention basin is located in the southwest corner of the site. It 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. See Process Flow Diagram in Attachment 1. 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 at the Facility. There are no known records of incomplete spill clean-up. Process containment berms, sumps and similar enclosures are free from pooled oil and oil contaminated accumulation. c. Equipment Assessment Major equipment operated at this facility has been examined by Engineer. Engineer’s opinion of equipment service life expectations is included in this article. All tests were cursory in nature. A review of equipment repair and evaluation records provided by Owner forms the basis of the Engineer’s opinion of service life expectancy. All evaluations made were based upon the assumption that regular maintenance and equipment repair has been and will continue to be performed. More particularly: i. Site roadways are constructed and maintained with appropriate wearing surface, drainage and turning radii for expected traffic. ii. Roadway and site drainage channels show no signs of overflow 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. The two smallest evaporation ponds are currently being re-built. v. Pump seals do not leak and drips are installed where necessary for bearing water discharge. vi. Process heaters appear to be relatively new and automatically fire and shut off as would be expected. vii. Exposed surfaces of tanks and piping are corrosion free with the exception of mill scale and light, tightly adhering rust. No corrosion pitting was observed. viii. Buildings - Office building is a space-conditioned, double-wide trailer equipped with wash water supply and wastewater drainage. External siding, roofing and interior floors and walls were determined be in satisfactory condition based on cursory visual inspection. - Shop building is a 30 by 90-foot, pre-engineered metal building on a concrete mat foundation located immediately east of the office building. Only the second-floor process control room is space-conditioned. The recent 25 X-60-foot addition is also a Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180420 5 Page of 9 pre-engineered building constructed on a concrete mat foundation on the north side of the shop building. It is not space-conditioned. It houses three 150-bbl mixing tanks, three centrifuges, a number of feed pumps, metering pumps, transfer pumps and solids holding bin. - Regenerative blowers have been ordered and will be installed by the end of 2018 on the vapor extraction system in this structure. - The truck off-load building is a 10-year old, 12 X 15-foot, pre-engineered metal building on a concrete mat foundation located about 200 feet northwest of the office building. It has convenience electric power, but no water supply or wastewater systems. External siding, roofing and interior floors and walls were determined be in satisfactory condition based on cursory visual inspection. - The Injection Pump Building is a 20-year old, 10 X 12-foot, pre-engineered metal building on a concrete mat foundation located about 350 feet northeast of the office building. It has convenience and 480V electric power, but no wash water supply or wastewater systems. External siding, roofing and interior floors and walls were determined be in satisfactory condition based on cursory visual inspection. ix. Observable manual and motor-operated valves show signs of recent operation suggesting they perform satisfactorily for throttling and shut-off. x. Vapor Collection system was installed in 2017 to capture and route VOCs, water vapor and excess air to a Combustor located about 200 feet north of the main tank batteries. This system is constructed from three-inch, A106, socket-welded pipe. It was given a cursory visual inspection last fall and showed no signs of excess wear, corrosion or weld embrittlement. Even with small leaks the vapor collection system will operate safely because it will always have, on average, a negative five-inch water column internal pressure. xi. Injection Pump and associated piping has operated within factory and regulatory parameters since being overhauled about six months ago. xii. Landfarm operation shows no sign of excess water or oil present in the mix. Landfarm soil sampling and lab testing are performed at least monthly. Care is being taken to accurately collect five-point composite samples that are representative of the landfarm waste being treated. 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. Oil Cleaning, Water Disposal and Solids Disposal Operation Assessment Controls for the process described in B., 1., a., above and shown on the Process Flow Diagram in Attachment 1, are mostly automated. Instrumentation is mostly not 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. Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180420 6 Page of 9 Most often the operator will make equipment and process adjustments for which the operator has been trained and given authority to perform. Process and equipment adjustments which appear to be needed, but which operator has not been authorized to perform, are immediately brought to the attention of other operating staff and plant management for resolution. - Large equipment temperatures, pressures, flowrates and the like are constantly monitored by operating staff and management. Although some process monitoring parameters are observed via remote displays, most instrument monitoring and all sampling is locally observed/performed. - Leak detection equipment is monitored weekly. - It is the Engineer’s opinion that: Some additional process monitoring automation would increase overall plant efficiency and lessen the probability that accidental waste discharge would occur. Installation of a Sequence of Events Recorder would also be beneficial after automated process monitoring is implemented. Weekly leak detection monitoring is appropriate. Process sampling should continue to be performed manually and locally because this operation is not big enough to warrant remote, automated process sampling. The biggest process variable is the type of waste brought to the Facility. It is the Engineer’s opinion there is no commercially available, off- the-shelf (COTS) equipment to classify incoming waste. There is no Reasonably Available Control Technology (RACT) or even Best Available Control Technology (BACT) that is economically viable for IWM 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 IWM operation and should continue to be used. ii. Landfarm Operation Assessment - The existing landfarm accepts frac sands, filtered tank bottom sludges, and other acceptable E&P solid wastes that pass a paint filter test and contain hydrocarbons. This "Landfarm" is a wind-row, soil remediation process that reduces petroleum contaminated soil (PCS) concentrations through biodegradation. - Contaminated soils are periodically turned over using common farming or similar equipment to aerate landfarmed soils. This practice supports naturally occurring aerobic and/or augmented micro-organisms (archaea and bacteria) consuming E&P waste in the contaminated soil. Landfarm waste bulk density, texture and porosity are controlled by addition of straw, sawdust, pearlite and similar conditioning material. Clean, low salinity water is applied as needed to keep the soils moist enough to support micro-organism growth. - Runoff water is detained in the northwest corner of the landfarm. Excess stormwater is drawn of as necessary and treated with incoming E&P waste. - Visual and olfactory screening is used to monitor the landfarming process. Before material is removed from the landfarm, samples are taken and lab tested to ensure the treatment process is completed. Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180420 7 Page of 9 - Engineer has determined that this treatment process and associated lab test results are being correctly applied. No changes to this treatment process are needed to comply with regulation or improve the process. iii. Monitoring Program Soil and water sampling and testing, visual equipment inspection, pressure tests, sampling and analysis of material collected by leak detection systems used at this facility are described below. i. Sampling and testing for spill and/or leak clean-up is always performed to verify that all needed clean-up is complete. Sampling of landfarm soil is performed to evaluate process efficiency, completeness of hydrocarbon removal and salinity thresholds before removal of treated soil. ii. Water Sampling and testing is performed on all liquid taken from leak detection sumps. iii. Injection well water Pressure is monitored and recorded daily. iv. Injection Well Metal Integrity Testing is performed every five years. v. Injection Well flow rate is monitored and recorded daily. vi. Leak Detection Monitoring of designated leak detection sumps is performed weekly. iv. Additional or re-configured monitoring practices which could reasonably and economically improve operational efficacy and detection of inadvertent waste release are described below. i. Mechanical and electrical equipment efficiency and safety could be enhanced by performing the following. - Quarterly survey of valve packing and gaskets for excessive wear and leaks. - Annual evaluation of mechanical and hydraulic operating efficiency of pumps, blowers and combustor. Such an evaluation would include verifying that equipment is matched to system operating pressures and temperatures. - Annual calibration of pressure release/vacuum relief valves and thief hatch springs and weights. - Annual cursory check of process and stoichiometry and mass balance to rule out leaks and verify process efficiency. - One-time evaluation of each pump and blower to verify that the correct type of equipment has been chosen for the operating condition. For example, verifying that the most appropriate equipment types and ratings have been selected. - Quarterly readings to determine that individual large motor and plant-wide power factor correction is within reasonable ranges to reduce electric power consumption and demand. - One-time power quality evaluation to determine Total Harmonic Distortion induced by variable frequency drives and addition of inductors or other filters as may be needed to cancel or block extraordinary levels of odd harmonics. Eliminating or lowering these harmonics will allow motors to run cooler, lengthen motor life and lower the frequency of unplanned outages. Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180420 8 Page of 9 ii. To enhance early detection of inadvertent waste release and more accurately determine leak sources IWM is considering: - Adding a chemical marker to certain waste streams. - Annual pressure testing of buried pipe. - Five year liner leak testing. 2. Closure Cost and Bonding Evaluation Bond cost components referenced in this section have been determined by applying unit costs to a quantity take-off from drawings and documents provided by Owner and cursory field inspections and surveys by the Engineer. a. Contamination Evaluation No evidence of Soil, Surface Water or Groundwater contamination was found at this facility. b. Remediation of E&P Waste Contamination None required. c. Site Closure Evaluation Scope of Work Upon closure the existence and extent soil contamination will be identified with a 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 in Appendix 2. 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, fences, buildings, liner materials, piping and concrete structures which do not add value to the site are included in the Infrastructure Removal portion of closure costs. ii. Earthwork and grading to restore site to a serviceable condition similar to, and in keeping with surrounding land use and drainage. e. Seeding and Revegetation Scope of Work Seeding/revegetation cost 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: Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180420 9 Page of 9 i. Closure PID survey results and required sampling and lab testing. ii. Groundwater and surface water required to be sampled lab-tested. iii. Inventory of hazardous substances removed from site. iv. Description of site grading, revegetation and erosion control installed. g. Post Closure Monitoring Scope of Work Post closure monitoring and care cost includes annual: i. Erosion control and surface water management. ii. Sampling and testing of groundwater. iii. Sampling and testing of site and Landfarm soil and surface water as described in the initial closure report. iv. Written report describing the condition of the reclaimed site and work performed to monitor and maintain reclaimed site. 3. Observations and Recommendations Included in Articles 1. d. and 1. f, above. Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180515 C Attachments Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180515 ATTACHMENT 1 Maps and Drawings Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 1:80,000 ± Integrated Water Management Oil Cleaning Plant Duchesne, UT Project Number: 751-061 Facility Location 0 5,000 10,000 15,000 20,0002,500 Feet Figure A-1 Copyright GeoStrata, 2018 Legend Site Boundary Facility Location 751-064 Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 1:988 ± Permit Application for E&P Landfill Integrated Water Management Duchesne, UT Project Number: 751-064 Landfarm Layout 0 40 80 120 16020 Feet Plate A-4 Copyright GeoStrata, 2018 Landfarm Leachate Collection Area Legend Landfarm Drainage Landfarm Leachate Collection Area Staging Areas Wind Row Areas IWM Property Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180515 ATTACHMENT 2 CLOSURE COST ESTIMATE DOGM Closure Summary Form GeoStrata Backup Calculations Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Item 1 60.0 Acres 2 Unit Quantity Unit Price Extended Cost References - 01 20 00 - 01 30 00 - 01 40 00 - 01 50 00 - 01 70 00 Total: -$ 3 Unit Quantity Unit Price Extended Cost gallon 175,090 0.04$ 6,930.60$ 02 65 10.30 0130 (modifed for scale) cubic yard 4,169 0.68$ 2,846.19$ 0 0 -$ 0 0 -$ 0 0 -$ 0 0 -$ 0 0 -$ Total: 9,776.79$ 4 Unit Quantity Unit Price Extended Cost Cubic Yard 18,786 Varies 6,956.16$ 02 41 16.13 0020 Each 41 880.00$ 2,585.00$ 02 65 10.30 1253 Uprights are no cost Each 4 200.00$ No Cost (net of salvage) 02 65 10.30 1253 Uprights are no cost Linear Foot 4,500 0.26$ -$ Leak Detection Pipe will be ground up with liner shredding HR 3 75.00$ 501.62$ Time to use a D5-mounted Rototiller (for shredding) was applied to how many linear feet of liner there is on site Cubic Yard 14,920 1.09$ 14,621.60$ 02 41 16.17 0440 Linear Foot 7,830 Varies 17,122.20$ 02 41 13.60 1600 Cubic Yard 1,037 0.04 44.70$ Hauling Costs were adjusted for specific distances to the Duchesne County Landfill: 31 23 23.20 4104. Weights associated with specific material type were derived from WasteCap Resource Solutions Inc Ton 853 20.00$ 17,063.41$ Duchesne/ Wasatch Bluebench Landfill Tonnage Rates Total: 58,894.70$ 5 Unit Quantity Unit Price Extended Cost cubic yard 66,597 1.76$ 117,210.68$ 31 23 16.46 5020 *Of note, Pond 3 (landfill is not included in bonding estimates, as it does not fall under DOGM cubic yard - 2.83$ -$ 31 23 16.46 5040 cubic yard - 1.53$ -$ 31 23 16.46 5000 square foot 780,793 0.05$ 39,039.65$ 31 22 13.20 0280 (modifed for scale) of other disturbed area within site boundaries Total: 156,250.33$ 6 Unit Quantity Unit Price Extended Cost MSF 1,124 28.94 32,538.08$ 32 92 19.14 5800 (modified with specific seeding costs of Granite Seed in Lehi, UT) Total: 32,538.08$ 7 Unit Quantity Unit Price Extended Cost Year 1 6,300.00$ 6,300.00$ GeoStrata estimates based off of inhouse estimates Year 10 120.00$ 1,200.00$ GeoStrata estimates based off of inhouse estimates Year 10 600.00$ 6,000.00$ GeoStrata estimates based off of inhouse estimates Month 9 1,152.44$ 10,371.94$ GeoStrata estimates based off of inhouse estimates Month 12 33.00$ 396.00$ GeoStrata estimates based off of inhouse estimates Year 1 2,100.00$ 2,100.00$ GeoStrata estimates based off of inhouse estimates Year 8 1,200.00$ 9,600.00$ GeoStrata estimates based off of inhouse estimates Year 2 2,200.00$ 4,400.00$ GeoStrata estimates based off of inhouse estimates Total: 40,367.94$ 8 Type ID Number Posted Amount 1 7 380,037.00$ Total: 380,037.00$ 31 23 23.20 4096 adjusted to specific distance from nearby water disposal facility. For tank volume 10% of total volume was used Final Closure & Post Closure Cost Estimates Descripiton Well Inspection & Sampling Rough Grading Revegetation Cost Estimates Descripiton Listed Reclamation Water Quality Meter Rental Lab Analysis Grounds Maintenance Landfarm Tilling Monitoring Well Abandonment Bond Posted Bond Descripiton & Date Annual Report Final Post Closure Report Hydro Seeding of Indian Rice Grass Sand & Gravel to be Moved Tanks Gensets Burried Piping Concrete Pads 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 Liner Integrated Water Management IWM E&P Disposal Site Assessment, Closure & Post Closure Cost Estimate & Re-statement of Existing Bonds in Suport of DOGM Bonding Evaluation Site Area Contamination Remediation Cost Estimates DOGM Line Item Descripiton Contingencies Price and Payments Procedures Administrative Requirements Quality Requirements Temporary Facilities and Controls Executions of Closeout Requirements Indirect Costs Self Attenuating Post Remediation Sampling Post Remediation Monitoring Descripiton Removal of Contaminated Liquid Disposal of Contaminated Liquid Vapor Extraction Pump & Treat Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Utah Division of Oil Gas & Mining Permit Renewal Application for IWM Exploration & Production Waste Disposal 20250 W 2000 S, Altamont, Utah Rev 20180515 ATTACHMENT 3 LANDFARM DATA AND DRAWINGS Sample Data Sample Locations Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Plate C-1Copyright GeoStrata, 2018 IWM Landfarm Sampling Results Project Number: 751-064 Integrated Water Management Highway 87 Duchesne, UT 84021 (IWM-Duchesne) Land Farm Sampling Results Location Date Sample Number TDS TPH (DRO) TPH (GRO) Electrical Conductivity (EC) Electrical Conductivity (EC) Exchagable Sodium Percentage (ESP) Sodium Absorption Ratio (SAR) Laboratory Laboratory Laboratory Field Laboratory Laboratory Laboratory mg/kg mg/kg mg/kg mmho/cm mmho/cm % ratio ≤ 4 mmho/cm ≤ 4 mmho/cm ≤ 15% ≤ 12 Land Farm 8/18/2015 TP-1 (0-1) 2650 32800 1.92 NA NA NA NA Land Farm 8/18/2015 TP-1 (1-2) 5070 21600 51.9 NA NA NA NA Land Farm 8/18/2015 TP-1 (2-3) 4700 33800 2.85 NA NA NA NA Land Farm 8/18/2015 TP-1 (3-4) 4520 27700 2.57 NA NA NA NA Land Farm 8/18/2015 TP-1 (4-5) 2610 2570 2.3 NA NA NA NA Land Farm 8/18/2015 TP-2 (0-1) 2360 37400 3.18 NA NA NA NA Land Farm 8/18/2015 TP-2 (1-2) 4170 36100 15 NA NA NA NA Land Farm 8/18/2015 TP-2 (2-3) 2590 34600 10.3 NA NA NA NA Land Farm 8/18/2015 TP-2 (3-4) 2940 22300 0.765 NA NA NA NA Land Farm 8/18/2015 TP-2 (4-5) 2560 9090 1.01 NA NA NA NA Land Farm 8/18/2015 TP-3 (0-1) 2790 25100 3.59 NA NA NA NA Land Farm 8/18/2015 TP-3 (1-2) 2160 30300 245 NA NA NA NA Land Farm 8/18/2015 TP-3 (2-3) 3330 25200 5.64 NA NA NA NA Land Farm 2/16/2017 TP-1 2020 12600 3.97 NA NA NA NA Land Farm 2/16/2017 TP-2 5560 22800 52.4 NA NA NA NA Land Farm 2/16/2017 TP-3 3820 19600 23.6 NA NA NA NA Land Farm 2/16/2017 TP-4 3430 26500 14.1 NA NA NA NA Land Farm 2/16/2017 TP-5 6040 22900 13.7 NA NA NA NA Land Farm 8/18/2015 TP-3 (3-4) 2670 11700 5.17 NA NA NA NA Land Farm 8/18/2015 TP-4 (0-1) 3320 18300 4.15 NA NA NA NA Land Farm 8/18/2015 TP-4 (1-2) 2740 28000 773 NA NA NA NA Land Farm 8/18/2015 TP-4 (2-3) 3630 40200 11.1 NA NA NA NA Land Farm 8/18/2015 TP-4 (3-4) 2520 24500 4.37 NA NA NA NA Land Farm 1/11/2018 A (0-12") NA NA NA NA 6.92 13 10.7 Land Farm 1/11/2018 A (12-24") NA NA NA NA 6.29 13 11.4 Land Farm 1/11/2018 B (0-12") NA NA NA NA 20.10 33 33.8 Land Farm 1/11/2018 B (12-24") NA NA NA NA 17.80 29 28.3 Land Farm 1/11/2018 C (0-12") NA NA NA NA 20.40 26 24.7 Land Farm 1/11/2018 C (12-24") NA NA NA NA 20.80 30 29.3 Land Farm 1/11/2018 D (0-12") NA NA NA NA 7.48 14 12.1 Land Farm 1/11/2018 D (12-24") NA NA NA NA 8.31 16 13.5 Land Farm 1/11/2018 E (0-12") NA NA NA NA 9.54 16 13.6 Land Farm 1/11/2018 E (12-24") NA NA NA NA 10.80 17 15.0 Land Farm 1/11/2018 F (0-12") NA NA NA NA 6.95 12 10.4 Land Farm 1/11/2018 F (12-24") NA NA NA NA 8.09 13 10.9 Land Farm 5/2/2018 1 NA NA NA 0.03 3.27 7.1 6.02 Land Farm 5/2/2018 2 NA NA NA 0.57 3.57 10 8.61 Land Farm 5/2/2018 3 NA NA NA 0.06 9.18 22 19.8 Land Farm 5/2/2018 4 NA NA NA 0.05 4.98 16 13.7 Land Farm 5/2/2018 5 NA NA NA 3.36 6.80 18 15.4 Land Farm 5/2/2018 6 NA NA NA 2.74 6.41 15 12.7 Background 5/25/2018 LF-1-BGSS NA NA NA NA 0.102 -0.78 0.333 Background 5/25/2018 LF-2-BGSS NA NA NA NA 0.072 -1.2 0.061 Background 5/25/2018 LF-3-BGSS NA NA NA NA 0.178 0.16 0.961 Background 5/25/2018 LF-4-BGSS NA NA NA NA 0.059 -1.2 0.044 Background 5/25/2018 LF-5-BGSS NA NA NA NA 0.117 -1 0.157 Land Farm 7/18/2018 IWM-WR-SS-1 NA NA NA AL AL AL AL Land Farm 7/18/2018 IWM-WR-SS-2 NA NA NA AL AL AL AL Land Farm 7/18/2018 IWM-WR-SS-3 NA NA NA AL AL AL AL Land Farm 7/18/2018 IWM-WR-SS-4 NA NA NA AL AL AL AL BOLD -The Analytical Result is Above Applicable Limit (00.0) NA - Not Analyzed AL - At the Laboratory for Analysis Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 Plate C-2Copyright GeoStrata, 2018 IWM Landfarm Sample Locations Project Number: 751-064 Integrated Water Management Highway 87 Duchesne, UT 84021 8/18/2015 1/11/2018 1/11/2018 5/2/2018 5/25/2018 7/3/2018 Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018 For Division Use Only Compliance Review Completed: No outstanding compliance Active violation/compliance matter Signature: Comments Five Year E&P Waste Disposal Facility Permit Renewal Checklist Permit Renewal Application Submission Submit an assessment of site reclamation requirements from a certified third party contractor R649-9-8.2 Submit closure cost estimates from a certified third party contractor R649-9-8.2 Provide bond amount approved by the Division R649-9-8 Detailed Site Description Function of the waste disposal facility Current facility map Site descriptions annotated with facility infrastructure and associated function Contamination Assessment Description of existing contaminatioin with sample results Proposed monitoring/remediation Proposed practices to prevent further contamination Equipment Assessment Description and assessment of equipment located at the facility Describe in detail service life for equipment used in facility operations Description of testing completed for equipment (tanks, piping, liners, leak detection equipment, evaporation fans) Practices Assessment Assessment of management practices utilized to operate the facility Identify alternative practices which could improve operations or reduce probability of future contamination Name of Facility Operator: Name of Facility: Location: Date: Preparer: Date Initials Date InitialsReceivedReviewed Review Completed: Application Status: APPROVED For Division Use Only Below This Line Sundry Number: 88041 RECEIVED: May. 11, 2018 Infrastructure Removal Costs Contouring or Regrading Costs Seeding Costs Notes: Contamination Costs Estimating Closure Cost and Bonding Evaluation Removal / Remediation Sampling Post closure monitoring Expenses to remove all infrastructure and equipment Project expense to contour site back to original grade Volumes of material Equipment costs Labor costs Method of reseeding Species used for revegetation Date Initials Received Comments Monitoring Program Detailed description of monitoring programs in use or being proposed (visual inspections of equipment, pressure tests, leak detection systems, waste accountability, automated systems, proposed practices which can reduce the risk of future contamination) Sundry Number: 88041 RECEIVED: May. 11, 2018 RECEIVED: Aug. 19, 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:  IWM North Blue Bench  2. NAME OF OPERATOR:  Integrated Water Management LLC  6. FACILITY NUMBER:  166  3. ADDRESS OF OPERATOR:  PO Box 430 , Altamont, UT, 84001  7. PHONE NUMBER:  435-454-4646  4. LOCATION OF FACILITY     Qtr/Qtr:SESE Section: 30 Township: 2S Range: 4W Meridian: U  COUNTY:  DUCHESNE  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: 8/19/2022 PREVIOUSLY APPROVED SUNDRY  Submitted PDF Copy       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 Tanks Added 12. DESCRIBE PROPOSED OR COMPLETED OPERATIONS. Clearly show all pertinent details including dates, depths, volumes, etc. New tanks will be added to the water receiving portion facility. 5 New 400 BBL tanks added with at least on old tank removed. No changes to the process or throughputs will be necessary. IWM has also started the modification to the air permit to add the tanks. The attached file shows the proposed location of the new tanks at the facility. NAME (PLEASE PRINT)    Nathan Robinson   PHONE NUMBER 435 454-4646  TITLE  Director  SIGNATURE  N/A  DATE  8/19/2022  Sundry Number: 118692 Facility Number: 166 RECEIVED: Aug. 19, 2022 PRE-INJECTION TANKS SEPARATION TANKS BRINE TANKS OFF-LOADING TANKS IMW Facility, Duchesne, UtahSCALE: 1" = ADD SCALE 751-074 Air Permit Modification 2019 NOA REV DATE BY DESCRIPTION BER Proposed Facility Layout07-12-19 A-2 X:\Projects\751-Integrated Water Management\060-Tabby Junction Landfill Permit\Design\Integrated Internet Symbol 2.png LEGEND Removed Tank New Tanks NEW TANK IN-SERVICE TANK REMOVED TANK Sundry Number: 118692 Facility Number: 166 RECEIVED: Aug. 19, 2022 0'25'50'100' Storage Tanks Centrifuge Bldg. Ramp Access Rd. Section Line Detention Basin 30 31170' SECT 30 SECT 31 T 2S, R 4W, UINTAH BASIN SPECIAL MERIDIAN IMW Facility, Duchesne, UtahSCALE:1" = ADD SCALE 751-074 Air Permit Modification 2019 NOA REV DATE BY DESCRIPTION BER Proposed Water Cleaning Facility07-12-19 A-3 X:\Projects\751-Integrated Water Management\060-Tabby Junction Landfill Permit\Design\Integrated Internet Symbol 2.png Sundry Number: 118692 Facility Number: 166 Integrated Water Management Date: 7/23/2018 Facility: IWM E&P Disposal Number of Acres to be Reclaimed 25.8 Acres 1 Incl Indirect? Indirect Costs - Contamination Remediation Cost Estimates N 9,776.79$ 2 Removal of Infrastructure Costs Estimates N 58,894.70$ 3 Earthwork and Grading Cost Estimates N 156,250.33$ 4 Revegetation Cost Estimates N 32,538.08$ 5 Final Closure & Post Closure Cost Estimates N 40,367.94$ 6 Total Cost Estimate 297,827.84$ (Increase above total cost estimate by determined percenetage if indirect costs are not included) 79,817.86$ Total Reclamation Cost Required 377,645.70$ Bond Posted 380,037.00$ 7 Difference Between Cost Estimate and Bond 2,391.30$ Direct and Indirect Costs Five Year E&P Waste Disposal Facility Bond Calculation Summary Form Sundry Number: 88041 File: Detailed Site Description RECEIVED: May. 11, 2018