DSHW-2018-007085 - 0901a0688088892a

DSHW-2018-007085 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director

State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
July 31, 2018
Newspaper Agency Corporation Legal Advertising Department
143 South Main
Salt Lake City, Utah 84101 EMAIL: [e-mail] RE: NAC Account #9001350993

Dear Sirs: This email constitutes authorization to publish the attached NOTICE in the Salt Lake Tribune and Deseret News on August 6, 2018.

Please send invoice and affidavit of publication to: Scott T. Anderson, Director Division of Waste Management and Radiation Control P.O. Box 144880
Salt Lake City, Utah 84114-4880 Attachment: Public Notice c: Brian Hatch, Health Officer, Davis County Health Department
David W. Spence, Deputy Director, Davis County Health Department
Dennis Keith, Environmental Health Director, Davis County Health Department Edward C. Graves, Environmental Engineer, Nexeo Solutions
Michael Hahn, Facility Manager, Nexeo Solutions Jesse Newland, USEPA, Region 8 Donna Spangler (Email), Carlee Christoffersen (Email), Tom Ball (Email) Larene Wyss (Email), Kimberly Diamond-Smith (Email)
Mailing List (Email)
Facility File, Public Participation File, Alisa Westenskow

DSHW-2018-007085 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director

State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor

July 31, 2018
Standard Examiner
332 Standard Way P.O. Box 12790 Ogden, Utah 84412
Dear Sirs: This email constitutes authorization to publish the attached NOTICE in the Standard Examiner on August 6, 2018.
Please send invoice and affidavit of publication to: Scott T. Anderson, Director Division of Waste Management and Radiation Control P.O. Box 144880
Salt Lake City, Utah 84114-4880 Attachment: Public Notice c: Brian Hatch, Health Officer, Davis County Health Department
David W. Spence, Deputy Director, Davis County Health Department
Dennis Keith, Environmental Health Director, Davis County Health Department
Edward C. Graves, Environmental Engineer, Nexeo Solutions
Michael Hahn, Facility Manager, Nexeo Solutions
Jesse Newland, USEPA, Region 8
Donna Spangler (Email), Carlee Christoffersen (Email), Tom Ball (Email)
Kimberly Diamond-Smith (Email), Larene Wyss (Email)
Mailing List (Email)
Facility File, Public Participation File, Alisa Westenskow

NOTICE OF PUBLIC COMMENT
Nexeo Solutions, LLC – Permit Reissuance
UTD048406144 The Director of the Division of Waste Management and Radiation Control is seeking public comment on an
application from Nexeo Solutions, LLC to renew its Hazardous Waste Permit. The permit application has
been reviewed by Division staff and a draft permit has been prepared. The public comment period to receive comments on the draft permit will commence on August 7, 2018 and end on September 20, 2018. A public hearing has been scheduled at 6:00 p.m. on Wednesday, September
12, 2018 at Clearfield City Hall Multi-Purpose Room, 55 South State Street Clearfield, UT .
Documents related to this application can be reviewed at the following location: Utah Department of Environmental Quality (Multi Agency State Office Building) Division of Waste Management and Radiation Control
195 North 1950 West, 2nd Floor Salt Lake City, Utah For the public’s convenience, an unofficial copy of the draft permit is available on the Internet at “https://deq.utah.gov/waste-management-and-radiation-control/waste-management-radiation-control-public-
notices”. Written comments will be accepted if received by 5:00 p.m. on September 20, 2018 and should be submitted to the address below. Comments can also be hand delivered to the Division address above and must be
received by 5:00 p.m. on September 20, 2018. Scott T. Anderson, Director Division of Waste Management and Radiation Control
Department of Environmental Quality P.O. Box 144880 Salt Lake City, Utah 84114-4880 Comments can also be sent by electronic mail to: “[e-mail]”. Comments sent in electronic
format should be identified by putting the following in the subject line: Public Comment on Nexeo Solutions Draft Permit. All documents included in comments should be submitted as ASCII (text) files or in pdf format. Under Utah Code Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an
issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue.
For further information, contact Karen Wallner of the Division of Waste Management and Radiation Control at [phone]. In compliance with the Americans with Disabilities Act, individuals with special needs (including auxiliary communicative aids and services) should contact Kimberly Diamond-Smith, Office of Human Resources at [phone], Telecommunications Relay Service 711, or by email at
“[e-mail]”.

DSHW-2018-007085 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director
July 31, 2018
Deanne Tetzl, National Sales Rep
Cell: [phone] | Work: [phone] [e-mail] KSL.com 55 North 300 West
SLC, UT 84101
Dear Ms. Tetzl: Enclosed is a public notice we would like aired on your radio station two separate times during the day on August 7, 2018: 1) between 5:00-10:00 a.m. and 2) between 7:00 p.m. and midnight .
Please send invoice and affidavit of airtime to: Scott T. Anderson, Director Division of Waste Management and Radiation Control
P.O. Box 144880 Salt Lake City, Utah 84114-4880 Enclosure: Public Notice
c: Brian Hatch, Health Officer, Davis County Health Department David W. Spence, Deputy Director, Davis County Health Department Dennis Keith, Environmental Health Director, Davis County Health Department Donna Spangler (Email), Carlee Christoffersen (Email), Tom Ball (Email), Kim Diamond-Smith (Email), Larene Wysee (Email)
Facility File, Public Participation File, Alisa Westenskow

NOTICE The Director of the Division of Waste Management and Radiation Control is seeking comment on a draft Permit for the Nexeo Solutions, LLC facility in Davis County.

A public hearing on the draft Permit will be held September 12, 2018, at 6:00 p.m. Clearfield City Hall, Multi-Purpose Room, 55 South State Street, Clearfield. A public comment period begins August 7, 2018 and ends September 20, 2018. A copy is available for
review at the Multi Agency State Office Building, 195 North 1950 West, Salt Lake City.
For questions, contact Karen Wallner at [phone]. In compliance with the Americans with Disabilities Act, individuals with special needs (including auxiliary communicative aids and services) should contact Kimberly Diamond-Smith, Office of Human Resources at [phone],
Telecommunications Relay Service 711, or by email at “[e-mail]”.
.

State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director
August 1, 2018 CERTIFICATION OF MASS MAILING

Facility: Nexeo Solutions, LLC Mail Notification Activity
1. Part B Hazardous Waste Operations Permit Renewal
I Kathy Lundy, certify that the attached DWMRC mass mail notification was sent to the Nexeo Soutions LLC. Mail list 8-2-18 by email and U.S. Postal service on August 2, 2018 in accordance with applicable rules in R315-15 and 124 through 273.

Enclosure: Email and Mail list

NOTICE
Nexeo Solutions, LLC – Permit Reissuance UTD048406144

Proposed action Permit Reissuance
When is the public hearing?
A public hearing has been scheduled at 6:00 p.m. on Wednesday,
September 12, 2018 at Clearfield City Hall Multi-Purpose Room, 55 South State Street Clearfield, UT
Who can I talk to about the proposed action?
Please contact Karen Wallner of the Division at [phone] if you
have any questions concerning this draft permit.
How long is the public comment period?
In accordance with R315-124-10(b) UAC, the public comment period is allowed 45 days to review the draft approval and submit comments. The public comment period will begin on August 7, 2018 and will end on September 20, 2018.
Where can I see the draft permit?
“https://deq.utah.gov/waste-management-and-radiation-control/waste-management-radiation-control-public-notices”
or Division of Waste Management and Radiation Control Multi-Agency State Office Building 195 North 1950 West Salt Lake City, Utah 84116
How do I comment on the draft permit?
Written comments, addressed to the Director of the Division of Waste
Management and Radiation Control, can be submitted in person at the Division office listed above or mailed to the following address: Scott T. Anderson, Director Utah Division of Waste Management and Radiation Control P.O. Box 144880 Salt Lake City, Utah 84114-4880 Written comments will be accepted until 5:00p.m.on September 20, 2018. Comments can also be sent by electronic mail to: “[e-mail]”. Comments sent in electronic format should be identified by putting the following in the subject line: Public Comment on Nexeo Solutions Draft Permit. All documents included in comments
should be submitted as ASCII (text) files or in pdf format. Under Utah Code Section 19-1-301.5, a person who wishes to challenge a permit order may only raise an issue or argument during an adjudicatory proceeding
that was raised during the public comment period and was supported with sufficient information or documentation to enable the director to fully consider the substance and significance of the issue.

Nexeo Solutions, LLC August 2, 2018 Draft Permit Fact Sheet UTD048406144 DSHW-2018-007085
Nexeo Solutions, LLC Draft Permit Renewal Fact Sheet

On April 18, 2017, Nexeo Solutions, LLC submitted an application to the Division of Waste Management and Radiation Control to renew its hazardous waste permit. The current permit was issued on October 17, 2007.
Nexeo Solutions operates a commercial hazardous waste transfer and storage facility in the Freeport Center, Clearfield, Utah which is located in Davis County. The facility is located approximately 1.6 miles west of Exit 334, the Freeport Center exit on Interstate 15. The Division of Waste Management and Radiation Control has completed its review of the permit renewal application. A draft permit has been prepared and is available for review during the public comment period, which begins on August 7, 2018 and will conclude on September 20, 2018, at 5:00 p.m. A public hearing to receive comment on the draft permit has been scheduled for 6:00 p.m. on September
12, 2018, in the Clearfield City Hall Multi-purpose Room, which is located at 55 South State Street
Clearfield, Utah.
The fact sheet and draft permit are available for review during the public comment period at the following location: Division of Waste Management and Radiation Control
Multi Agency State Office Building 195 North 1950 West, 2nd Floor Salt Lake City, Utah
For the public’s convenience, a copy of the fact sheet and draft permit is available online at: http://www.hazardouswaste.utah.gov/Public/PublicHearingsandComment Periods.htm
Written comments will be accepted if received by 5:00 p.m. on September 20, 2018 and should be submitted to the address below. Comments can also be hand delivered to the Division address above as long as they are received by 5:00 p.m. on September 20, 2018.
Nexeo Solutions, LLC August 2, 2018 Draft Permit Fact Sheet UTD048406144 DSHW-2018-007085
Scott T. Anderson, Director
Division of Waste Management and Radiation Control Department of Environmental Quality P.O. Box 144880
Salt Lake City, Utah 84114-4880 Comments can also be sent by electronic mail to: [e-mail]. Comments sent in electronic
format should be identified by putting the following in the subject line: Public Comment on Nexeo Solutions, LLC Draft Permit Renewal. All documents included in comments should be submitted as ASCII (text) files or in pdf format. Following the public comment period on the draft Nexeo Solutions, LLC (Nexeo) permit, all public comments will be evaluated and where appropriate will be included in the final decision on whether to reissue the permit. A final permit determination will then be made and the corresponding action taken. Under Utah Code Section 19-1-301.5 a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the director to fully consider
the substance and significance of the issue. The Nexeo facility is a permitted transfer and storage facility. Nexeo can manage RCRA waste streams.
Waste is received and transported by truck. The facility is located at latitude 41° 06' 17" North and longitude 112° 02' 05" West. Nexeo has one permitted storage unit. All waste sent to the Nexeo facility is sent to other facilities for reclamation, treatment, and disposal.
The Draft Permit consists of three modules and 11 attachments. A summary of each is provided below with the significant changes from the review noted. In June 2016, Title R315 of the Utah Administrative Code waste substantially changed. Most of the changes involved modification of the Code references. This resulted in a document where the numbering system reflected, to a large extent, the numbering
system used in the Code of Federal Regulations (CFR). As a result, a citation that began as 40 CFR 264.32(a) became R315-264-32(a). There are exceptions to the changes, but they are few. Information that was included in the Permit to show that Nexeo had evaluated all required permit application contents that did not pertain to the Nexeo facility was deleted.
References to the Executive Secretary of the Division of Solid and Hazardous Waste have been changed throughout the Permit to the Director of the Division of Waste Management and Radiation Control.
Module 1, Standard Conditions Waste analysis detail was moved to the Waste Analysis Plan, Attachment 1.
A clarification of the time frame (30 days) for providing requested information to the Director was added.
The period for record retention was modified to include an automatic extension during the course of any unresolved enforcement action regarding this facility. A Corrective Action section was added to address releases of hazardous waste at the facility as the Corrective Action Module (Module 4) has been deleted from the permit.
Nexeo Solutions, LLC August 2, 2018 Draft Permit Fact Sheet UTD048406144 DSHW-2018-007085
A condition was added to address verification of new and modified Hazardous Waste Management Units
in accordance with the approved design. Any construction not in accordance with designs and specifications approved in the Permit may require removal and replacement.
Language describing specific situations defining a significant discrepancy and requiring a manifest discrepancy report was added.
A section containing definitions was added to end of Module 1. Module 2, General Facility Conditions A condition was added that clarifies use of appropriate sampling and analytical methods. A condition was added that clarifies the process for requesting an equivalent, substitute or additional analytical method. A clarification for personnel training was added to not allow personnel to work unsupervised in positions dealing with or around hazardous waste until they have completed the training requirements.
Conditions which require update of the financial assurance mechanism were added.
Module 3, Storage and Processing in Containers Nexeo requested a modification to Permit Condition III.J.1, Attachment 3, and Attachment 4 to remove
the requirement for daily inspection of containers (i.e., change of frequency of an inspection schedule). DWMRC evaluated this request and determined that the focus of Permit Condition III.J.1 is the loading and unloading areas rather than the containers themselves. Based on the requirements in R315-264-15(b)(4), the requested change will not be accepted and the area shall continue to be inspected daily when in use. The title of Module 3 was changed to “Containers.” The list of hazardous wastes prohibited from storage under this Permit has been amended to include “Infectious Waste” and “Liquid PCB-containing Wastes.” Module 4, Corrective Action for Solid Waste Management Units and Schedule of Compliance This module was deleted from the Permit. The Division completed a RCRA Facility Assessment of the
former Ashland facility (now Nexeo facility). Based on the results of the assessment, Ashland conducted a RFI in 2005. As a result of the RFI, a No Further Action letter was issued to the facility. Additionally, a Corrective Action condition was added to Module 1to provide a mechanism to address releases at the
facility. Attachment 1 – Waste Characteristics and Waste Analysis Plan (WAP)
A paragraph was added to address handling of hazardous waste generated at the Nexeo facility. Language was added to require screening for cyanide containing plating wastes (F007) which may also be characterized as a reactive waste (D003).
Nexeo Solutions, LLC August 2, 2018 Draft Permit Fact Sheet UTD048406144 DSHW-2018-007085
A section was added to require segregation of Transfer-Only Wastes from the wastes stored under this
Part B Operating Permit. Infectious waste and liquid PCB containing waste were added to the list of prohibited wastes for storage
under this Permit. RCRA metals analysis was changed from analyte specific methods to general analysis by SW-846 method
6010. Attachment 2 – Security Plan No significant changes were made. Attachment 3 – Inspection Plan As discussed in the Module 3 change summary, Nexeo requested a modification to Attachment 3 (Section 2.1) to change the requirement for daily inspection of containers. DWMRC evaluated this request and determined that the loading and unloading areas shall continue to be inspected daily when in use based on
the requirements in R315-264-15(b)(4). The requested change will not be accepted. Changes were made to automatically extend the record retention period for logged inspections in the
event of an enforcement action or as requested by the Director. Changes were made to the Monthly Inspection Log referencing the Nexeo inspection forms that contain
the number of pieces of equipment present at the facility and their locations. Attachment 4 – Spill Prevention control and Countermeasure and RCRA Contingency Plan As discussed in the Module 3 change summary, Nexeo requested a modification to Attachment 4 (Section 10.0) to change the requirement for daily inspection of containers. DWMRC evaluated this request and determined that the loading and unloading areas shall continue to be inspected daily when in use based on the requirements in R315-264-15(b)(4). The daily inspections must be documented as well. The requested change will not be accepted. A paragraph was added to specify how spilled material captured in the retention basin will be handled. The list of Emergency Incident Commanders was renamed Emergency Coordinators.
An Evacuation Map of the Nexeo facility has been added. Attachment 5 – Preparedness and Prevention Plan
No significant changes were made.
Attachment 6 – Facility Information The original attachment was deleted from the Permit as this information was required for obtaining the initial permit and is not required for permit renewal.
Nexeo Solutions, LLC August 2, 2018 Draft Permit Fact Sheet UTD048406144 DSHW-2018-007085
Attachment 6 – Training Plan
This attachment was renumbered and renamed “Attachment 6” and contains the information from the original Module 7 Training Plan.
No significant changes were made to the training plan information.
Attachment 7 – Closure, Post-Closure Plans, and Cost Estimates This attachment was originally numbered Attachment 8 and was renumbered as Attachment 7. Nexeo requested a modification to Section 1.5.2 in the Closure Plan to clarify the rinsate sampling and analysis for decontamination procedures. Nexeo has also updated closure costs to reflect current costs and changes to the closure plan. These changes have been included in the draft Permit. Changes were made to the Closure Performance Standard to require modification of the Closure Plan to add detailed procedures for sampling and decontamination or removal of all contaminated soil, groundwater, equipment and structures. A sampling and analysis plan must be submitted to the Director
prior to any sampling activities. Additionally, the Director may require baseline sampling prior to initiating closure.
Changes were made to Section 1.5.2 to require: inspection of the entire surface areas of the CSU and hazardous waste handling equipment for evidence of any spills; review of the operating record to identify the location of any spills; and conduct soil sampling if cracks, holes or evidence of potential leakage is
documented. A change was made to specify that necessary changes to the closure plan will require submission of a modified closure plan for Director approval at least forty-five (45) days prior to the date on which closure of the regulated unit is expected to begin. Attachment 8 – Financial Assurance This attachment was originally numbered Attachment 9 and was renumbered as Attachment 8. The financial assurance mechanism was changed from a closure trust fund to a letter of credit and standby trust. Attachment 9 – Container Storage
This attachment was originally numbered Attachment 10 and was named “Process Information”. renumbered and renamed “Attachment 9 – Container Storage”.
Management practices for locating specific containers of waste at the facility have been modified by removing the requirement for use of the grid container location system.
Attachment 10 – SWMU Map Drawing No. 71030-ZD-005 This attachment was originally numbered Attachment 11 and was renumbered Attachment 10. No significant changes were made to this attachment.
Nexeo Solutions, LLC August 2, 2018 Draft Permit Fact Sheet UTD048406144 DSHW-2018-007085
Attachment 11 – As-Built Drawings and Construction Standards
This attachment was originally numbered Attachment 12 and was renumbered Attachment 11.
Appendix A was updated with a new as-built drawing of the Truck Dock Hazardous Waste Area
Grounding and Lighting Plan.