4 *'sc,*A Div of Waste Management and Hadration Control March 1,2018 Scott Anderson Director Utah Department of Environmental Qualtty Division of Waste Management and Radiation Control 195 North 1950 West Salt Lake City, UT 84116 MAR 0 0s llw -aot6-oon)b Dear Mr. Anderson, SC&A, Inc. has prepared this report in response to a request from the Utah Department of Environmental Quality's Division of Waste Management and Radiation Control to evaluate the "Needs Assessment Report Addendum" submitted by Promontory Point Resources, LLC (PPR) on Decernber 20,2017. The Needs Assessment Report Addendum was submitted to fulfill the requirements of Section 19-6-108, Subsections (10) and (11), of the Utah Solid and Hazardous Waste Act ("Acf'). The Division requested an evaluation that included both data validation and analysis using professional judgment and opinion. Overall, SC&A's review found that the Needs Assessment Report Addedum improves on the previous report. However, it does not demonstrate the need for addtional Class V landfill capacity in Utah, does not provide a robust market analysis, and has some remaining data gaps and therefore does not establish the need for the facility. SC&A's attached report provides more detailed information. Appendix A to the report examines the completeness of the PPR's submittal in terms of statutory requirements, Appendix B provides a review of the missing content from the previous report, and Appendix C addresses the validity of the data submitted. Sincerely, Greg Beronja President & CEO SC&A,Inc. 2200 Wllson Boulevard, Sulte 300 . Arlington, Vlrglnla .22201 I 20t8 . 703.893.6600 . Fax 703.821.8236 -*sc&A EYALUATION OF TEE PROMONTORY POrNT RESOURCES, LLC, NEEDS ASSESSMEI{T REPORT ADDENDT]M March 1,201E for Utah Department of Environmental QuaHty 195 North 1950 West SattLake City, UT E4116 SC&A,Inc. 2200IYiIson Blvd., Suite 300 Arlington, YA2220l Summary of Findings SC&A, Inc. (SC&A) has prepared this report in accordance with a scope of work from the Utah Department of Environmental Quality's Division of Waste Management and Radiation Control requesting evaluation of the 'T.{eeds Assessment Report Addendum" (Addendum) submitted by Promontory Point Resources, LLC (PPR), dated December 20,2017. The Addendum was prepared to respond to comments SC&A had made on PPR's Needs Assessment Report ("Report"), dated March2017, to fulfrll the requirements of Section 19-6-108, Subsections (10) and (11), of the Utah Solid ard,Hazardous Waste Act ("Act"). The intent of the Addendum was to provide additional or revised justification for the need for additional capacity in Utah for the disposal of nonhazardous waste per Subsections (10) and (11). The Division requested an evaluation that included both data validation and analysis using professional judgment and opinion. The evaluation is intended to determine whether the following conclusions can be made: 1. 2. 3. 4. 5. 6. 7. The analysis meets the statutory requirements in completeness. The analysis supports PPR's conclusions. Data and information provided in the analysis are valid and accurate Data gaps in PPR's economic market analysis exist. The analysis identifies existing landfill capacity in the State of Utah. There is a need for additional capacity of nonhazardous solid waste. The analysis complies with the requirements of the act. PPR is currently a permitted Class I landfill seeking a Class V permit. A Class V permit would allow PPR to operate as a commercial nonhazardous solid waste disposal facility and receive waste directly from industry as well as from out-of-state generators (specifically from California, as mentioned in the Addendum). Therefore, SC&A's analysis will review the Addendum focusing on generation and capacity information as related to these waste types. To meet these objectives, SC&A compared each requirement from Subsections (10) and (11) with relevant information from the Addendum, identified data gaps and any unsupported claims, verified the accuracy of content and data, reviewed relevant landfills to determine existing landfill capacity, and utilized primary and secondary sources to verify unsupported claims and identiff additional information required. Summary analysis for each objective is presented below. More detailed information can be found in the referenced appendices. 1. The analysis meets the statutory requirements in completeness In its review of the Needs Assessment Report in July 2017, SC&A compared each item within Subsections (10) and (11) with the relevant sections of the Report to determine whether it met the statutory requirements and found it had failed to: (l) provide a market analysis of the need for the facility, (2) identify and review a proposed facility within the region as well as review additional existing/proposed facilities outside of the immediate region, (3) provide information 1 on methane generation, (4) discuss waste reduction management methods, (5) adequately address information on treatment, if applicable, and storage of potential waste, and (6) disclose potential adverse environmental impacts of the facility. In reviewing the Addendum, SC&A revisited the omissions listed above. Based on this further analysis, PPR made ptogress on these requirements. However, specific pricing information, capacity information for out-of-state landfills, and a more detailed analysis of the ECDC Environmental (ECDC) landfill are lacking. Appendix A, "Completeness of Statutory Requirements," provides more detailed information. The validity of data and analysis provided will be explained in subsequent sections. 2. The analysis supports PPR's conclusions Based on the previous Needs Assessment Report, SC&A determined that the analysis was incomplete as it omitted the following: A. Robust market analysis B. Support for claim that proximity to rail offers a competitive advantage for out-of-state waste C. Analysis of trends in waste generation D. Site-specific information about location, geology, and potential adverse environmental impact E. Implications of a court case that is pending (Young Resources Limited Partnership v. Promontory Landfill & Promontory Point Land Resources, LLC) F. Resumes and disclosure of any noncompliance issues for facility founders and all senior management G. Information on storage or treatment processes prior to landfilling, if the facility plans to offer these services The Addendum improves on the above, and detailed information can be found in Appendix B "Review ofNeeds Assessment Report Missing Content." However, the Addendum still lacks a complete analysis, including where regional industrial waste is generated and the capacity of outof-state landfills currently receiving this waste. The validity of data and analysis prwided will be explained in subsequent sections. 3. Data and information provided in the analysis are valid and accurate SC&A validated data with sources provided and/or additional sources. Of 16 items identified for data validation, l l had sources provided and were confirmed. However, three claims did not have sources provided and required additional research. Two claims are unconfirmed due to lack of needed information. Appendix C, "Data Validation," provides more detailed information. 2 4. Data gaps in PPR's economic market analysis exist SC&A's review of the Needs Assessment Report identified the followingdata gaps in the market analysis to show the need for the facility: (a) assumed waste quantities for disposal at PPR from waste sources listed, (b) PPR's pricing information to determine competitiveness, and (c) capacity infomation for current and proposed regional and out-of-state landfills. The Addendum only partially addresses these data gaps. 4(a). Assumed waste quantities for disposal at PPRfrom waste sources listed The Addendum identifies two main waste sources relevant to a Class V designation: regional non-hazardous industrial waste and regional special waste. For industrial waste, the Addendum states that DWMRC reported disposal of more than 1.2 million tons of industrial waste in Utah's landfills in 2015 and that PPR expects to receive 15-20% of this tlpe of waste (180,00G-240,000 tons). However, when excluding the Intermountain Power Agency's large Class lllb ash landfill, only about 704,A00 tons of industrial waste were disposed in Utah in 2015.r SC&A evaluated the referenced DWMRC disposal information and found slightly lower figures for industrial waste disposed of in the state (see Table 1) but verified the large portion disposed at the Intermountain Power Agency's landfill (522,447 tons in 201r.2 Additional industrial waste is disposed of on site at other industrial facilities. It is not expected that the generators disposing of waste on site will change this practice soon. Therefore, the amount of waste from this 1.2 million tons that PPR will be able to compete for is the amotrnt currently being disposed of at other Utah Class V landfills, which totals 440,166 tons. Therefore, PPR's expectation of 15-20% expectation should be modified to reflect what portion of this waste PPR will receive versus the other Class V facilities. It is possible PPR could attract additional out-of-state waste if the economics of disposing of the waste at its site are better than other current options. Table l: Annual Industrial Waste Disposed in Utah -' Tons of Material Recvcled 2015 3,476,296 t,204,056 1,144,375 189,788 270,331 2016 3,765,990 1,373,938 889,017 210,49 t99,074 I 2015 waste volumes from a DWMRC tracking spreadsheet provided by Allan Moore to PPR ln2016 2015 waste volumes from a DWMRC tracking spreadsheet provided by Allan Moore to SC&A in 2018 2 3 :' To assess the feasibility of these estimates, SC&A evaluated where industrial waste is generated. Unfortunately, this information is not tracked in Utah, but the EPA Biennial Report shows the top generators of hazardous waste, which may serve as a good proxy. In 2015, Utah generated33,927 tons of hazardous waste. At least 83% of that waste came from the following counties (noted in red on the map): Box Elder, Tooele, Salt Lake, Utah, and Davis; 52Yo of the state's hazardous waste was generated in Box Elder County alone.3 @ 3f,V!ai In2015,45%o of the industrial waste was disposed in Millard County. Five landfills located in Millard, Carbon, Box Elder, and Toole Counties (noted in black on the map) received almost 90% of the industrial waste for the year. Of the five facilities, three were Class V: ECDC (28%), Wasatch (5%\, and Clean Harbors Grassy Mountain (5%).0 Table 2 summarizes the municipal waste, industrial waste, and remaining capacity for the four Class V landfills that are competitors to PPR, according to information from their 2016 Annual Reports. According to these data, ECDC and Wasatch together received about 45% of the total in-state and out-of-state industrial waste in2016. Both landfills currently have significant capacity. Therefore, PPR's argument for receiving industrial waste is not based on capacity needs but rather an assumption they will be competitive enough to incentivize generators to redirect industrial waste to PPR. Table 2: Class Class Y Facility ECDC Environmental V Landfills Disposal and Capacity Municipal In-State (Tons) Municipal Industrial Out-of- In-State (Tons) State (Tons) Industrial Out-of- Capacity (Years) State (Tons) 15,749 0 15,749 17,466 321,540 339,006 1,606 563,963 0 563,963 57,942 6,355 64,297 305 139,140 0 139,140 0 0 0 43 26,037 0 0 0 0 0 l6 Wasatch Regional Landfill Intermountain Resional Payson City Landfill Total 3 718,852 403,303 EPA Biennial Hazardous Waste Report, 2015 htfps ://rcrainfo. epa. gov/rcrainfoweb/action/modules/br/summary/view 4 2015 waste volumes from a DWMRC tracking rp."uArn""[6rria"a by Allan Moore to SC&A in 20lg 4 a For regional special waste, the Addendum again states that PPR expects to receive 1510% of remediated soil from northern California (44,117-58,822 tons) and southern California (59,92279,896 tons), although no evidence supporting this assumption is given. 4(b). PPR's pricing information to determine competitiveness The Addendum does not give specific pricing information as it is proprietary, although PPR states that it will be competitive. The Addendum references the Northem Utah Environmental Resource Agency (NUERA), which states "nationally, landfill tipping fees average around $45lton and are commonly around $80/ton" and that PPR would be similar to other Utah area landfills (with tipping fees less than $30/ton), thereby showing competitiveness.s In addition, Table 9 of the Addendum uses $25-$35 as a potential range for PPR. The Addendum compares "all-in" costs of California industrial wastes being disposed of in California versus PPR. However, it is unclear why the transportation costs (per ton) to Promontory from California generators only include rail; it assumes they are rail served without providing evidence. 4(c). Capacity informationfor curuent and proposed regional and out-of-state landfills The Addendum provides capacity information for other in-state landfills (see Section 4.1.3 and swnmary information in Table 12) including two potential scenarios for the Bayview site. However, ECDC is missing from the table and no capacity information is given for out-of-state landfills, such as those in California. Focusing on in-state landfills that are competitive for receiving industrial waste, ECDC and Wasatch landfills together have over 1,000 years of capacity. 5. The analysis idenfiftes *isting landftll capacity in the State of Utah Section 4.1.3 of the Addendum examines capacity of the facilities SC&A identified as PPR's main competitors: ECDC Environmental, Payson City Corporation, Intermountain Regional Landfill (IRL), and Wasatch Regional (Class V), as well as Bayview (Class I). In addition, srmrmary capacity information is presented in Table 12 of the Addendum which includes other Class I and V landfills including Logan North Valley Landfill (a Class I landfill) which has a reported maximum capacrty of 81 years. While the Addendum argues many landfills throughout the state are nearing capacity, the analysis shows significant existing capaclty in Utah. Rather, its argument for need relies on PPR as a cost-competitive commercial landfill option for the northernmost Wasatch Front communities due to relatively low transportation costs. In addition, the Addendum states that PPR will ensure "IRL and Republic (Wasatch Regional) do not form a duopoly, which could drive disposal prices higher" and that if IRL fills up, it will prevent Wasatch Regional from becoming a monopoly. However, for in-state waste options, ECDC is an additional disposal option, but it is owned by Republic, so the duopoly argument still holds some merit. For out-otstate wastes, California andNevada waste management options will remain an option versus the use of landfills in Utah. 5 Information Sheet, Bayview Landfill Project, FAQ #4, Northern Utah Environmental Resource Agency, no date. 5 6. There is a needfor additional capacity of nonhazardous solid waste SC&A has determined there is not a present need for additional capacity of nonhazardous solid waste. For in-state options, there is over 1,000 years of capacity among Class V landfrlls able to receive local and out-of-state industrial and special waste. Analysis of out-of-state options, such as those in California and Nevada, was lacking from the Addendum, and they may provide additional capacity. 7. The analysis complies with the requirements of the act Overall, the analysis partially complies with the requirements of the Act. While it includes most information and data required to meet all stafutory requirements, an analysis of relevant out-ofstate (specifically CA) landfrlls and a more detailed analysis of the ECDC landfill are lacking. In addition, the Addendum cites several non-capacity-related benefits (discouraging a duopoly, keeping market prices down, attractingindustry) and the forthcoming population growth expected in the area in establishing need rather than a present capacity problem. 6 Appendix A Completeness of Statutory Requirements (10) The director may not approve a commercial nonhazardous solid or hazardous waste operation plan that meets the requirements of Subsection (9) unless it contains the information required by the board, including: (10 - A) evidence that the proposed commercialfacility has solid or hazardous waste, including: (i) information onthe source, quantity, and price chargedfor treating, storing, and disposing of potential nonhazardous solid or hazardous waste in the state and regionally; Did not provide detailed information on waste quantrty, pricrng for each waste type, or sufficient information on storage and treatment at the facility, if applicable. A-1 a proven market of nonhazardous Section 4.1.1 provides expectations (in tons) for regional nonhazardous industrial waste and remediated soil, though assumptions ,rnderlyrng these later estimates are unsupported. Overall, estimates 284,000 to 379,000 tons annually in addition to MSW. This differs from Section2.3.3 which states PPR pssumes an initial disposal of 200,000 tons/year. Addendum states fees charged to PPR customers are proprietary but will be competitive. Compares rates to national and regional averages. Does not give specifics on price per waste tlpe or for treating, storing, and disposing. Additional information on cost savings associated with regionalization of waste disposal given in Appendix E, pg. 5-6. The report has not Section 4.1 . I provides estimates of regional nonhazardous industrial waste and remediated soil from Northern and Southern California to PPR. Section 4.1.2 focuses on reduced provided a market analysis since it does not present the transportation costs as a main incentive for quantities from each both Northern Utah and CA to use PPR and waste source and provides calculations for both tnrck and rail PPR's pricing (it) a market analysis transport. For potential waste from California, information is of the needfor a Section 3.2.4 cites more-stringent disposal lacking. It does commercialfacility regulations on a number of non-RCRA present claims of given existing and wastes, proximity of UP's main line, and need based on p otential generation of higher tipping fees in CA as incentives for reduced supply and nonhazardous solid or disposal at PPR. Appendix E, pg. 8-9 states increased demand, hazardous waste in the PPR has already secured Service Agreements as well as general state and regionally; from several industrial customers, contingent benefits of the and upon receipt of the Class V designation and facility. Other construction of rail infrastrucfure at the site. information Despite the above, the Addendum does not analyztngtrends in provide a robust market analysis waste generation and demonstrating the need for the facility. More more in-depth information needs to be presented on why review of other PPR will athact state and regional waste landfills is required. versus other state and regional landfills. A-2 The report identifies A (iii) a review of other existing and proposed commercial nonhazardous solid or hazardous waste facilities regionally and nationally that would competefor the treatment, storage, or disposal of the nonhazardous solid or hazardous waste; all facilities within a 50-mile radius except a new facility ("Logan CityNorth Valley'') set to open in Fall 2017. However, the report lacks a robust review of these local sites and presents little information on facilities outside the region. The main argument for the facility's competitive advantage is its proximity to rail; however, much of the evidence and rationale for that claim is unsupported in the report. Section 4.1.3 cites five landfills (four Class V's and one Class I) that could compete for non-hazardous waste and then provides analysis on each. The Addendum cited relatively low capacity (21-29 years) for Payson City (Class V) and for two potential scenarios for Bayview (Class I). Intermountain Regional and Wasatch, however, were cited as potential competitors given capacity and rates. The Addendum highlights the need for PPR to compete to discourage a duopoly and/or future potential monopoly, to keep prices down, and to extend the life of municipal landfills. However, ECDC could also prohibit a duopoly when considering in-state waste options and landfills in CA would be competitors for outof-state waste. Overall, the Addendum lacks a substantial analysis ofthe ECDC landfill (Class V), which has significant capacity and currently receives a large portion ofthe state's industrial waste. (10 - B) a desuiption of the public beneJits of the proposedfacility, including: (i) the need in the statefor the additional capacity for the management of nonhazardous solid or hazardous waste; The report lacks information to demonstrate the need for additional capacity. A-3 Section 4.2.1 provides Table 12: Landfill Capacity Summary. This table shows relatively low capacity for municipal facilities (15-38 years) and relatively high capacity for commercial facilities, PPR included (up to 305 years). ECDC is missing from the table and has significant capacity (over 1000 years). Overall, this section cites non-capacity related benefits (discouraging a duopoly, keeping market prices down, attracting industry) and the forthcoming population growth expected in the area in establishing need rather than a present capacity problem. Although the report presents some information on methane recovery and the (ii) the energt and resources recoverable by the proposedfactlity; facility's ability to "store" certain wastes for re-use, it should provide additional information on storage, treatment, and potential methane Section 4.2.2 cites PPR plans to install a solar microgrid and use the renewable power as well as to install a landfill gas collection system to directly generate electricity or to use as fuel for mobile equipment. The Addendum seems to satisff this requirement but if PPR intends to sort recyclable materials in the fufure, this should be mentioned. generation. (iii) the reduction of nonhazardous solid or hazardous waste management methods, which are less suitablefor the environment, that would be made possible by the proposed facility ; and (iv) whether any other available site or method for the management of hazardous waste would be less detrimental to the public health or safety or to the quality of the environment; and Although the report briefly mentions recovery techniques, it lacks a discussion of waste reduction management methods. Section 4.3.3 acknowledges potential methods PPR would consider and reiterates commitment to best use of materials. Given the intent of the PPR facility is primarily to landfill materials, the Addendum satisfies this requirement. As mentioned above, ifthe sorting of recyclable materials is an option for the future, this should be mentioned. This requirement is not applicable. Section 4.2.4 states Promontory Point Landfill will only take nonhazardous waste. However, PPR has mentioned in their previous report the potential to accept waste considered hazardous in CA that is not defined as hazardous in Utah. A-4 Addendum Q0 - C) compliance history of an owner or operator of a proposed commercial nonhazardous solid or hazardous w aste treatment, storage, or disposal facility, which may be applied by the director in a nonhazardous solid or hazardous waste operation plan decision, including any plan conditions. Additional information is needed to confirm that facility owners/upper management have no history ofnoncompliance (i.e., resumes or work history offounders and senior leadership). Section 4.3 states PPR leadership and support staffhave over 100 years of experience and have not received notice of any major violations. However, they do not define a minor versus major violation. Brief bios of leadership and management team are provided, and resumes can be upon request. (l l) fhe director may not approve a commercial nonhazardous solid or hazardous wastefacility operation plan unless based on the application, and in addition to the determination required in Subsections (9) and (10), the director determines that: Although the report describes (It-A)the several facility probable attributes beneficial demonstrating environmental beneficial environmental ffict of the impact, much of to the facility this information state outweighs the lacks needed probable detail. The report also fails to adverse environmental include potential adverse effect; and environmental impacts. Section 5.1.1 states PPR does not have any significant adverse environmental impacts and will not have any materially different impacts with a Class V permit and will work to offset any curently unforeseen direct environmental impacts in accordance with environmental laws and regulations. Section 5.1.2 summarizes design standards and highlights some environmental protection features. Section 5. 1 3 summarizes the plan of operations and states that the plan is essentially the same for a Class V permit as a Class I. Appendix E, pg. 17-18 also states that PPR will secure air quality and stormwater permits for construction and operation of the landfill, all of which are in place to protect the environment. Finally, it reiterates the landfill's potential for reducing VMTs. Assuming significant industrial waste is generated in NW Utah and disposed at ECDC, there is potential for significant reduction of VMT's in using PPR instead. However, the Addendum is lacking discussion on the potential adverse effects of installation of a rail spur line. that they . A-5 (11 - B) there is a needfor thefacility to serve industry within the state Although the report states that there is a need for the facility, it does not provide sufficient information to support that claim. As summarizedin Section 4.1.3 and Table 12, there is currently capacity at other Class V landfills in Utah. However, there may be cost or other reasons generators of industrial waste would use PPR. Section 5.2.2 examines industry within the state and reiterates PPR's ability to prevent a duopoly, keep market prices down and help meet projected growth in future waste needs. The Addendum is generally responsive to this requirement given PPR could satis$ industry waste needs and may serye to limit escalation of waste disposal prices, however there is not a lack of capacity to serve industry. A-6 Appendix B Review of Needs Assessment Report Missing Content Robust market analysis Support for claim that proximity to rail offers a competitive advantage for out-of-state waste Analysis of trends in waste generation Site-specifi c information about location, geology, and potential adverse environmental impact Section 3.2 outlines the waste market including industrial waste, special waste, and regional waste. Section 4.1 presents information on market for nonhazardous waste and identifies waste sources (northern Utah and the region). Section 4.1.2 builds on previous information and presents PPR's market analysis. This section argues PPR is a cost-effective, longterm option and focuses on the relatively lower transportation costs. Section 4.1.3 reviews other facilities and potential competitors. Overall, the market analysis provided capacity information and relied on PPR's potential to provide a long term costefficient solution and prevent a duopoly. Not enough information is provided as to why the ECDC Class V landfill is not a viable competitor, despite its listed capacity of 1,000 years and abilitv (and history) to receive industrial waste. Section 4.1.2 provided estimates for disposal at PPR vs. Californian landfills to show the incentive rail provides in Table 9. Despite rail still havrng higher transportation costs compared to CA local truck haul, when evaluated along with PPR's lower trpping fees the "all in costs (per ton)" was lower. It is unclear why the transportation costs (per ton) to Promontory from California generators only include rail; it may assume Califomia generators are also rail served without providing evidence. Section 5.2.1 examines industry within Box Elder County and cites analysis by the Gardner Policy institute providing estimates of projections of PPR job creation and net revenues. It also states that Box Elder County needs to develop longterm waste-disposal infrastructure to help attract new industry. The Addendum fulfills this requirement. Section 5. I . I reviews location standards and references a detailed description of compliance with location standards that was provided in Section l.C of the Class V Landfrll Permit Application (March 2017). The Addendum lacks details on the potential impacts of the facility being close to the Great Salt Lake and the construction of the rail and roadway infrastructure. Additional information on site geology should also be presented. B-1 Implications of a court case that is pending (Young Resources Limited Partnership v. Promontory Landfill & Promontory Point Land Resources, LLC) Resumes and disclosure of any noncompliance issues for facility founders and all senior management Information on storage or treatment processes prior to landfilling, if the facility plans to offer these services Appendix E, pg.1 states that the court case (160100006) was dismissed on July 26,2016 and that it would not have had an impact on the project. Section 4.3 provides biographies for leadership and management team and states PPR's management team does not have any major noncompliance issues. Resumes can be provided upon request. Not applicable. 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