DSHW-2023-208057 - 0901a0688125977c

State of Utah Mail - Response to Informal Meeting from July 17, 2023
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Response to Informal Meeting from July 17, 2023
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[e-mail] <[e-mail]>Mon, Aug 14, 2023 at 4:51 PM
To: [e-mail], Craig Jorgensen <[e-mail]>, [e-mail], Bradley Day
<[e-mail]>
Attached is the Response to the Informal Meeting Summary from July 17, 2023, as well as exhibits referred to within the
response.
Regards,
Adam Dunn
Owner
Cache Valley Plating
Alpine Creations, LLC
435-755-8000
6 attachments
Exhibit 1.png
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Exhibit 2.png
574K
DSHW-2023-208057
State of Utah Mail - Response to Informal Meeting from July 17, 2023
Exhibit 3.png
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Response to Informal Meeting Summary July 17, 2023.docx
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Exhibit 4.pdf
3149K
Exhibit 5.pdf
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Date Electronically Mailed: August 14, 2023

Douglas J. Hansen, Director
Division of Waste Management and Radia�on Control
PO Box 144880
Salt Lake City, UT 84114-4880

RE: Informal Mee�ng Summary
Compliance Evalua�on Inspec�on
UTR000007807

Dear Mr. Hansen,

Included in this response is the addi�onal informa�on we discussed with you and the other members of
the Utah Department of Environmental Quality in atendance at the in-person informal mee�ng which
your office hosted on 7/17/2023. We appreciate this opportunity to further address some of the
concerns our company had about the results of the inspec�on the UDEQ conducted at Cache Valley
Pla�ng 9/27/2022.

Part 1 Spacing of Hazardous Waste Materials in Storage
On 4/18/2016, Tom Ball, Compliance Inspector for the UDEQ, performed an on-site inspec�on at Cache
Valley Pla�ng. Following that inspec�on, Tom no�fied us that the spacing for the storage of the
hazardous waste at Cache Valley Pla�ng was insufficient, and that we needed to allow enough aisle
space to conduct weekly inspec�ons of the storage containers.
Exhibit 1 is a screenshot of an email sent to Tom Ball that addresses the ac�on Cache Valley Pla�ng took
to address the lack of aisle space. Atached to that e-mail is a picture of the aisle space created to allow
weekly inspec�ons. Exhibit 2 is a copy of that picture. Exhibit 3 is a screenshot of Tom Ball’s response to
the previous email. Please note that Tom says, “It looks like things are moving along in the right
direc�on,” and there is no other reference to aisle spacing further in this correspondence. Per this
interac�on, and subsequent interac�ons with Tom Ball, and later UDEQ Inspector Karen Wallner,
leadership at Cache Valley Pla�ng believed that sufficient ac�on had been taken to address UDEQ
concerns about aisle space for hazardous waste.
During the UDEQ inspec�on of Cache Valley Pla�ng on 9/27/2022, inspectors Judy Moran and Craig
Jorgensen men�oned that aisle space for storage of hazardous waste appeared to them to be
insufficient. Please refer to Picture 008 of Exhibit 1 of NOV/CO No. 2211136. It is a picture of the aisle
space between hazardous waste storage and regular waste storage as witnessed during that inspec�on.
If one compares the aisle space shown in Exhibit 2, to that of Picture 008, one will see that the spacing is
similar, if not the same. This seems to demonstrate that the determina�ons for aisle space may be
rather subjec�ve: on one occasion, aisle space is sufficient, on another, it is insufficient. Cache Valley
Pla�ng leadership therefore asks that this finding from the NOV/CO 2211136 be removed.
Cache Valley Pla�ng leadership would like to point out that the company has changed its prac�ce of
hazardous waste storage to comply with the recommenda�ons from the most recent inspec�on.

Part 2 Hazardous Waste On-Site Accumula�on
If one were to peruse the previous compliance findings the UDEQ gathered from 2016 to 2019, and then
compare those findings to the results of the 9/27/2022 inspec�on, one would surmise that in both
instances there was an excess of on-site accumula�on of Hazardous Waste, and the assump�on could be
made that this is simply a con�nuous problem. However, that assump�on would be incorrect.
When current Cache Valley Pla�ng ownership took over administra�on of the company, there was an
excessive amount of hazardous waste on site. Throughout 2016 to 2019, Both Tom Ball and Karen
Wallner facilitated the educa�on and guidance for Cache Valley Pla�ng leadership to beter iden�fy, treat
and ship that waste. During the course of this process, many other old chemicals in storage that had
previously been determined to be “good” product, were tested and iden�fied to in fact be chemicals
that would also have to be disposed of. This further drew out the processing �me, un�l the whole
mater was closed out January 15, 2020.
However, the hazardous waste accumula�on that was witnessed during the 9/27/2022 inspec�on is the
result of two en�rely different problems: 1- equipment malfunc�on and damage, and 2- inability to find
hazardous waste shippers able to schedule shipments in a �mely manner.

1- Equipment Malfunc�on and Damage:
From September 2021 to September 2022 our waste treatment press experienced a series of
malfunc�ons that drama�cally impeded our ability to process waste. The following is a list of the
malfunc�ons. Please see Exhibit 4 to view the corresponding invoices.
September-October 2021 Various pipes on the filter press began leaking, and repair work was
made.
December 2021 The cloth that lined the filter of the press began to come undone, so we
had to order new cloth. Material cost $1,775.00.
December 2021 The main pump for the waste process malfunc�oned. We ordered a
new pump. Material cost $3,170.47.
April 2022 The new filter press cloth arrived and was installed. The center feed nut
broke during the cloth replacement. Material cost $56.04.
May 2022 More leaks began in the valve of the center feed for the filter press, so
we replaced a glued-in permanent version with a threaded version.
July 2022 The center feed pipe broke. We had to order an en�re new assembly.
Material cost $294.18.
July 2022 When the new center feed assembly arrived, we learned that it could
not be installed without a specially designed tool the manufacturer had
failed to tell us about. We then ordered that tool and were later able to
make the repair. Material cost $212.29.
August 2022 The filter press hydraulic assembly began to leak, and the necessary
pressure for opera�on was unable to be achieved. We ordered a new
hydraulic pump. Material cost $1,112.13.
September 2022 In the process of replacing the hydraulic pump, we discovered that the
hydraulic oil filter had broken, so a new filter was ordered. Material cost
$111.04.

Despite all of the setbacks from this damage, Cache Valley Pla�ng s�ll processed as much waste as it
could, given the limita�ons faced.

2- Inability to find hazardous waste shippers that can schedule shipments in a �mely manner.
This issue has already been discussed with both Judy Moran and Craig Jorgensen. There was Hazardous
Waste material on site that would have been shipped by the 9/27/2022 inspec�on, except that no
hazardous waste shipping company that had been contacted could facilitate a �mely shipment.

Part 3
In an effort to improve the processing of hazardous waste, Cache Valley Pla�ng is moving from a batch
treatment method to a con�nuous flow treatment method. We are making several large purchases of
equipment to facilitate this change.
We have purchased a large clarifier unit for our new process, the cost of which was $25,715 (Exhibit 5).
In addi�on to this large purchase, we are purchasing the following:
Second Used Clarifier- $15,600
Control Panel - $3,450.60
Filter Press - $5,000.00
Tanks - $5,000.00
Mixers - $2,000.00
Pumps - $1,000.00
Catwalk - $500.00
Stairs - $500.00

Please note the purchase of a new/used filter press for $5,000. This purchase will allow us to con�nue
to press wastewater when/if our current waste filter press experiences further malfunc�ons.
We will likely be flying an expert in waste treatment processing from Wisconsin to come and assist us
with the final set-up of the treatment process. The es�mated cost of this will be $1,830.
The total cost, not coun�ng the planning and labor investment, will be over $60,000.

It is the hopes of Cache Valley Pla�ng Leadership that the UDEQ will consider parts 2 and 3 when
determining any possible financial penalty to impose in the upcoming S�pula�on and Consent Order,
and that the financial investments Cache Valley Pla�ng has demonstrated, will be sufficient financial cost
to prevent further penal�es.

Please let us know if there are any ques�ons or concerns regarding this informa�on.

Regards,
Adam Spencer Dunn, Registered Principal

Alpine Crea�ons, LLC
DBA Cache Valley Pla�ng

700 W 200 North, Bay 4
Logan, UT 84321

PO Box 703
Logan, UT 84323

adam_dunn@cvpla�ng.com

Dated this 14 of August, 2023

Invoice# 150184
Bill To:Ship To:
Cache Valley Plating
700 W 200 N B#4
Logan, UT 84321
United States of America
Cache Valley Plating
700 W 200 N B#4
Logan, UT 84321
United States of America
Salesman:Jim Driesenga
Buyer:Redge Flake Ship Date:05/27/2022
Phone:[phone] FOB:
E-Mail:[e-mail] Freight Code:Prepaid And Add
Terms:50% Down/50% Before Ship Ship Via:BEST WAY
From SO:190 PO Number:Email - Redge
LN Ordered Shipped B/O Part Number, Description Rev Price Total
4 1 1 0 40033393 $0.0000 $0.00
PAINT AEROSOL ACRYLIC LACQUER 12 OZ TRAFFIC
BLUE (TRUE BLUE)
2 2 2 0 40033396 00 $1,415.0000 $2,830.00
MIXER 1/4 HP 3-PH 60 HZ 230/460V 1750 RPM 5/8"
X 15" 4" DIRECT 316SS
1 1 1 0 40045916 00 $19,635.0000 $19,635.00
SPC00193 - SPC-20 SLANT PLATE CLARIFIER 20
GPM
5 1 1 0 40021937 $0.0000 $0.00
MWW O&M MANUAL
3 1 1 0 40044505 $0.0000 $0.00
VFD 460VAC INPUT/OUTPUT 3PH 1HP NEMA 4X
Date Printed: 06/27/2022 If Total Price is not shown, see next page.Page 1 of 2
Invoice# 150184
Comments Sub Total $22,465.00
0% Tax $0.00
Freight $3,250.00
Total Invoice $25,715.00
Deposit $0.00
Balance $3,250.00
CARRIER: LANDSTAR RANGER VNT
Date Printed: 06/27/2022 If Total Price is not shown, see next page.Page 2 of 2