HomeMy WebLinkAboutDSHW-2013-004399 - 0901a06880398d77HAZARDOUS WASTE COMPLIANCE
INSPECTION REPORT
Date of Inspection: 71812013
Facility: ATK Launch Systems, Promontory
P.O. Box 707
Brigham City, UT 84302
uTD009081357
Facility Contact: George Gooch, Manager
Environmental Services
Phone: (801) 699-0319
Applicable Regulations: Part 'rB" Permits for Treatment and Storage
and Post-Closure, Utah Administrative Code
(UAC) R315, Federal Rule 40 CFR 264,
Subpart H
Type of Inspection:
Report Prepared by:
Financial Assurance Evaluation
David McClearv
An evaluation of the financial assurance documents (DSHW log #s 2013-003575,2012-
010665, 2013.00357 8, and 2013-004331) for the ATK Promontory Facility has been
performed.
This financial assurance inspection review evaluates the compliance status of the ATK
Promontory Facility subject to financial assurance requirements specified by R3l5-8-8
[40 CFR 264.140 through 264.151] of the Utah Administrative Code (the Rules).
The evaluation covered the required sudden and non-sudden liability requirements,
closure and post-closure care cost estimates, and the financial assurance mechanisms
required under R315-8-8 of the Rules. The liability coverage and costs associated with
closure and post-closure were determined to be proper and appropriate for the
Promontory Facility.
DSHW-2013{04399
Liability Coverage
The Promontory Facility is insured [see 264.147(a)], through Chartis Specialty Insurance
Company for sudden liability coverage (See document 2013-003578. The amount of the
insurance for Promontory is the ma:<imum amount to meet the requirements of the Rules
lsee264.l47(a)1. The wording of the "HAZARDOUS WASTE FACILITY
CERTIFCATE OF LIABILITY INSURANCE" meets the requirements and the wording
of the Rules 1264.151fr)1.
ATK, Promontory is also required by its Permit to maintain non-sudden liability coverage
lsee264.l47(b)]. The insurance coverage is issued through Great American Insurance
(see document2012-010665 for the non-sudden liability coverage in the maximum
amount to meet the requirements of the Rules lsee 264.147(b)1. The wording of the..HAZARDOUS WASTE FACILITY CERTIFCATE OF LIABILITY INSURANCE''
meets the requirements and the wording of the Rules [264.I51fr)1.
Closure/Post-Closure Cost Estimates and Financial Assurance Coverage
ATK provided a 2013 closure cost estimate of $660,475 dollars and a post-closure care
cost estimate of $592,297 (see document 2013-003575). ATK has elected to use
insurance coverage issued by Great American Insurance Group with Insurance Policy
Number CPC 37 62254 02 with an effective date of Jun e 28, 2013 (see document 20 I 3 -
004331), (see264.143fia5@)) as the financial assurance mechanism for closure and post-
closure at multiple facilities in Utah (see 40 CFR 264.146). The amount of the insurance
policy is $1,668,558 dollars which equals the amount necessary for the closure and post-
closure at the Promontory and Bacchus ATK Facilities. The wording of the insurance
policy and "CERTIFCATE OF INSURANCE FOR CLOSURE AND POST-CLOSURE
CARE" meets the requirements and the wording of the Rules [264.151(e)]. The ATK
financial assurance review indicates that the Promontory Facility has met the
requirements under R3l5-8-8 for closure and post-closure care requirements.
Signature:
DM
Attachments: DSHW-2O I 3-004400, DSHW-20 I 3-00440 1, DSHW-20 13 -004402,
DSHW-2013-004403
c: Brad Maulding, Hazardous Waste Facilities Section
DSHW-2013-004399
r;iir-j ;:.sd
Divlslon of
Solid and HazardousWaste
ocT 2 2 mv.
Au a -00bb5
PO Box98
Magna. Utalr 84044-0@8
October 22,2012
Scott T. Anderson, Executive Secretary
Utah Solid and Hazardous Waste Control Board
Department of Environmental Quality
Division of Solid and Hazardous Waste
P.O. Box 144880
Salt [.ake City, Utah 84114-4880
Subject: Non-Sudden Accidental Liability Coverage
ATK Launch Systems -Promontory Facility UTD009081357
Dear Mr. Anderson:
As required by ATK Launch Systems Inc. - Promontory Hazardous Waste Storage
Permit module ILR.2, signed duplicate original certificates of liability insurance for non-
sudden accidental ocsunences effective 0l November 2012 are enclosed. Refer
questions on this topic to George Gooch at (801) 699-0319.
I certifi under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel'properly gather and evaluate the information submitted. Based on
my inquiry of the person or persons who manage the system, or those'persons directly
responsible for gathering the iffirmation. the information is, to the best of my knowledge
and belief, true, accurate, and complete. I am aware that there are significant penalties
for submittingfolse information, including the possibility of fine and imprisonment for
knowing violations.
Sincerely,
6fn"r.l,* b"{
Robert Ingersoll
Director, Environmental Services
c: David McCleary, DSHW
Jeff Vandel. DSHW
w/o attachments
w/o attachments
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HAZ/NTDOUS WASTE FACI.ITY GERTIFICATE OF LIABILIW INSURANCE
1. Great American E&S tnsrrance Company, $he 'lnsurei), ol 301 E. 4h Street, Cincinnati,
Ohio 45202 hereby certifies thet it has issnd [ebility insurance covedng bodily injury and
property damage to Allhnt Techsy$ems lnc., (the'insured'). d 7480 Flying Gloud Drive,
Minneapolis, MN 55344 in connection with the insured's obligation to demmstrate financial
responsibiliU under 40 CFR 264.147 or fr5.117. The co\rerage applies at EPA lD
UTD009081357, ATK taunch Sysilems - Promontory, P.O. Box 707, Btigham City, LJteh
84307 br non-sudden accilental ocanrences- The lknits ot liebility are $3,000,000 each
occunenoe and $6,il)0,000 annuel aggregate, exclusive of legal debnse co$s. The
coverage is povided under poliry number PEL39150E6 01 and is efiec{ive as off n1ao12.
2. The Insurer further cedifies the fof,owing with respect to the insurance descdbed in
Paragraph 1:
(a) Bankruptcy or insolvency of the insured shall not plieve the Insurer ol its obligations
under the policy.
@) The lnsurer is lhble for the payment of amounts within any dedudible applicable to the
policy, with a right of reimbursement by the insured for any such payment made by the' In$rer. This provisbn does not apply with respect to that amount of any dedudible fur
which coverage is demonstrated as gecifed in 40 CFR M.147A or265.147(f).
(c) Whenever requested by the Director of the Utah Division d SdH and Hazardous Wa$e,
the Insurer egees b fumish to the Direstor a signed duplicete odginal of the policy and
all endorsements.
(d) Gancellation of the insurance, whether by the insuref, the insured, a parent corporation
providing insrrance covrrage for ils subsidiary, or by a fim having an inslrable interest
in and oilaining lhbility insurance on behalt of the owner or operator of the hazadous
wase management facilfi, will be efhdirre only upon writen notice and on|y af,er the
expiratbn of 60 dap efler a copy of such written notice is received by the Director of the
utah DMsbn ol Solid and Hezardous Waste.
(e) Any othertermination of the insurance will be efiective only upon wdtten notice and only
afrer the expiratbn of thirty B0) days efler a copy of such written ndice is received by
the Diredor of the Ljtah Division of Solid and Hazardous We$e.
I hereby certify that the wodlng of this instument is identical to the woding specilied in 40 CFR
264.1510 as incorponted by reference in the l.Jtah Administrative Code R31$&8, as such
regulation was con$ihrted on the date first above written, and that the Inslrer is licensed to
transad the business of insurance, or eligible to provide insurance 8s 8n excess or zuplus lines
Sr. Wce Rres'nf Autlnfzed Repesnlalne olGnat.Nrrian E&S lnsurance 6mpny.
tO1 Plymwth Ropld, &rtfe tOO, Plymwth llbethg, PA 19462
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4C I PttEou:h R.-ad SJ,te leo
Pi/r-outh r.l.rtro. P.{ lil52'i'-lr{:iryr r.r;:r71;r eOS a:a +-,39 pi.
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HAZARDOUS WASTE FACilJTY CERTIFICATE OF I.IABILITY INSURANCE
1. Great American E&S hsurance Company, (lhe 'lnsuref), of 3Ol E- 4s Street, Gincinnati,
Ohao 452tP hereby certifies thst lt has issued liebilty insurance correring bodily injury and
Property damage to Alliant Techsydems Inc.. flhe Insured1, d 7180 Flying Cloud Drive,
Mhneapolis, MN 55344 in connedbn wilh the hsured's obligation to demonslrEte fnancial
responsibility undell0 CFR 2U.147 or 265.147. The coverage applies at EPA lD
UTD00$81357, ATK Leunch Systens - Pmmonlory, P.O. Box 707, Bdgham Cig, LJtah
84307 for non-sudden accilental ocqrnences. The limits of liabilny are $3,il)0,000 each
occurence and $6,000,(XX) annuel aggregale, exclusive of bgal dehnse cosls. The
coverege is provided under policy number PEL3915086 01 end is efiective as of
11n1/2012.
2. The Insurer fuilher certiFres the following wilh resped to the insurance described in
Par4naph 1:
(a) Bankruptcy or insolvency of the insured shall not relieve the Insurer of its obligations
under the policy.
(b) The lnsurcr is liable for lhe payment of amounts within any deductible applicable to the
policy, with a right d eimbursemenl by the insured for any sucfr paynent made by the
lnsurer. This provision does not apply with respect to thst amount of any deduetible br
which correrage is demonstnted as specited in 40 CFR 264-147(f, or265.147(Q.
(c) Whenever requested bythe Direstor of the Utah Division of Solid and Hazardous Wasle,
the Insurer sgrces to fumish to the Director a signed duplicate orighal of the poliry and
all endorsements.
(d) Cancelhtbn of lhe insurance. whether by the insurer, the insured. a parent corporation
providhg insrrance coyerege for ils subsidiary, or by a flm having an insurable interest
in and oHaining liabilily insurance on behalf of the otilner or operdor of the huardous
wasie management facility, will be efteclive only upon written notice and only afrer the
expiration of 60 days afler a copy of such wrlten notice is received by lhe Diredor of the
tXsh Diybion of Solid and Ha'ardous Waste.
(e) Any othertermination of the insurance will be effedive only upon wdtten notice and only
afler the elgiration of lhitty (30) days der a copy of such written notice is received by
the Director of the utah Division d Solid end Hazardous Waste.
I hereby ceilify that the wordhg of this instrument is identical to the woding specilied in 40 CFR
240.1510 as incorporated by reference in the tJtah Administrdive Code R31$8-8, as suchrcguhtion was constiluted on the date firsl above writlen, and that the lnsurer is licensed to
transad the business of hsurance, or eligible to provide insurance as an excess or surplus lines
lnsurer, in one or tnore Slates.
Sr. Vice Pesdenl, futtlolrhed Reprcsenlafftre of GrealAmen'can E&S fisuriance Compar4rel Hyznl,orrfr Roa4 Suife 10O, Ptyltrclufrt lfretirg PA 19/ttz
Dfvlslon ofSolld and Hazardous Waste
MAY 2 2NB
LOtZ-ooeeluPO Bor9E
Magna. Utah E4044{098
May 22,2013
Scott T. Anderson
Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
P.O. Box 144880
Salt Lake City, Utah 841l4-4880
Re: Closure Post-Closure Cost Annual Update
ATK Launch Systems -Promontory Facility UTD00908 n57 y'
ATK Launch Systems - Bacchus Facility UTD001705029
Dear Mr. Anderson:
ATK Launch Systems is updating financial assurance coverage for closure and post-
closure costs. Revised closure and post-closure cost estimates in the amount of
$1,668,559 are itemized below.
The existing insurance policy for closure and post-closure costs expires on June 28,2013,
and is in the process of being reissued at the new value. The certificates of liability
insurance for sudden coverage for both locations have been provided, and the policy for
non-sudden coverage will be reissued when it expires on November 1,2013. We
continue to review our financial assurance mechanism to ensure coverage is being
provided in a responsible manner. If you have questions on this topic feel free to contact
me at (801) 699-0319.
I certi/y under penalty o.f law that this document and all auachments u,ere prepared
under nty direction or supervision in accordance u,ith a.sy.slem designed lo assure lhat
Location Amount Description of Chanse
Bacchus Closure s41s.486 I .01 767inflation adiustment
Promontorv Closure $660.475 | .017 67 inflation adiustment
Promontorv Post-Closure $592,597 Updated cost estimate based on
year 2l of 30 in the current post-
closure permit using a 1.01767
inflation adiustment.
May 15,2013
Mr. Scott T. Anderson. Director
Utah Division of Solid and Hazardous Wastc 4_rb
quali/ied personnel properly gather and evaluole lhe information submilted. Based on
my inquiry of the person or persons who manage the system, or those persons direclly
responsible Jbr gathering the information. the inl'ormation is, lo the best oJ'my knowledge
and betief true. accurate. and complete. I am awure lhat lhere are significant penallies
.for submitting false informalion, including the possibilily ofJine and imprisonmenl.for
knowing violalions.
Sincerely,
6r*t1r6oouL'--'
George Gooch
Manager, Envi ronmental Services
c: David McCleary, DSHW
Jeff Vandel, DSHW
Hoa Zhu, DSHW
Chris Falkenberg, ATK Launch Systems
Paul Hancock, ATK Launch Systems
Re: Sudden Accidental Occurrence Coverage Update
ATK Launch Systems -Promontory Facility UTD00908 l3S7 /
ATK Launch Systems - Bacchus Facility UTD001705029
Dear Mr. Anderson:
As required by the liability requirements in 40 CFR 264.147(a)(l )(i), ATK Launch
Systems is providing signed duplicate original certificates of liability insurance for
sudden accidental occurences. If you have questions on this topic feel free to contact me
at (801) 699-0319.
I certifu under penalty of law that this document and all attachments u,ere prepared
under my direction or supervision in accordance wilh a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on
nty inquiry of the person or persons who manage lhe system, or those persons directly
responsible for gathering the information, the information is, to the best of my knowledge
and belief, true, accurate. and complele. I am aware that there are significant penalties
for submittingfalse informalion. including the possibility offine and imprisonment;for
knowing violalions.
Sincerely,
t,qtt{^*$tutLv
George Gooch
Manager, Environmental Services
c: David McCleary, DSHW
Jeff Vandel, DSHW
Hoa Zhu. DSHW
Division of
Solid and Hazardous Waste
lifAY 2 2 nBP 0- Llor 9E
\'lngna. Utah 84044-0098
May 22.2013
Scott T. Anderson
Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
P.O. Box 144880
Salt Lake City, Utah 841l4-4880
Tntb -oo3g-tg
1.
I'LAZARDOUS WASIE FACnJTY C;ERTIFrcATE OF LIABIUTY II{SURANCE
Chartis Specialty Insurance Company (the "lnsuref'), of 175 Water Street, New
York, NY 10038 hereby certifies that it has issued liability insurance covering
bodily injury and property damage to Alliant Techsystems, Inc. (the "insured"), of
7480 Flying Cloud Drive, Minneapolis, MN 55344, in connection with the
insured's obligation to demonstrate financial responsibility under 40 CFR
264J47 or 265.147. The coverage applies at UTD009081357, ATK Launch
Systems, lnc., 9160 North Highway 83, Brigham Ctty, UT 84302 for "sudden
accidental occurrences". The limits of liability are $1,000,000 "each occurrence"
and $2,000,000 "annual aggregate", exclusive of legaldefense costs. The
coverage is provided under policy number PLS 18030352, issued on April 27,
2A13. The effective date of said policy is April 27,2013
The Insurer further certifies the following with respect to the insurance described
in Paragraph 1:
(a) Bankruptcy or insolvency of the insured shall not relieve the Insurer of its
obligations under the policy,
(b) The Insurer is liable for the payment of amounts within any deductible
applicable to the policy, with a right of reimbursement by the insured for
any such payment made by the Insurer. This provision does not apply
with respect to that amount of any deductible for which coverage is
demonstrated as specified in (40 CFR 264.147(fl or 265.147(f))-
(c) Whenever requested by the Director of the Division of Solid and
Hazardous Waste (the Director), the Insurer agrees to furnish to the
Director a signed duplicate original of the policy and. all endorsements.
(d) Cancellation of the insurance, whether by the Insurer or the insured, will
be effective only upon written notice and only after the expiration of 60
days after a copy of such written notice is received by the Director.
(e) Any other termination of the insurance will be effective only upon written
notice and.only after the expiration of 30 days after a copy of such written
notice is received by the Director.
I hereby certifo that the wording of this instrument is identical to the wording specified in
40 CFR 2U.151(i), as incorporated by reference in Utah Administrative Code R315-8-8
as such regulations were constituted on the date first above written, and that the Insurer
2.
lrorrn 151(j) November 2012
is licensed to transact the business of insurance, or eligible to provide insurance as an
excess or surplus lines insurer, in the State of Utah.
Martine Houston
Regional Manager, Authorized Representative of Chartis Specialty Insurance Company
300 S. Riverside Plaza, Suite 2100, Chicago, lL 60606
2r'orm 1s1(j) November 2012
I.IAZARDOIJS} WASIE FACIUW CERNFGATE OF LI,ABIUTY I}.ISURANCE
1. Chartis Specialty Insurance Company (the "lnsure('), of 175 Water Street, New
York, NY 10038 hereby certifies that it has issued liability insurance covering
bodily injury and property damage to Alliant Techsystems, Inc. (the "insured"), of
7480 Flying Cloud Drive, Minneapolis, MN 55344, in connection with the
insured's obligation to demonstrate financial responsibility under 40 CFR
2U.147 or 265.147. The coverage applies at UTD001705029, ATK Launch
Systems, Inc. Bacchus Works (Plant 1), 8400 West 500 South, Magna, UT
UU4 for "sudden accidental occunences". The limits of liability are $1,000,000
"each occurrence" and $2,000,000 "annual aggregate", exclusive of legal
defense costs. The coverage is provided under policy number PLS 18030352,
issued on April 27 ,2013. The effective date of said policy is April 27 ,2013
2. The Insurer further certifies the following with respect to the insurance described
in Paragraph 1:
(a) Bankruptcy or insolvency of the insured shall not relieve the Insurer of its
obligations under the policy.
(b) The Insurer is liable for the payment of amounts within any deductible
applicable to the policy, with a right of reimbursement by the insured for
any such payment made by the Insurer. This provision does not apply
with respect to that amount of any deductible for which coverage is
demonstrated as specified in (40 CFR 2et.147(f) or 265.147(f))-
(c) Whenever requested by the Director of the Division of Solid and
Hazardous Waste (the Director), the Insurer agrees to furnish to the
Director a signed duplicate original of the policy and all endorsements.
(d) Cancellation of the insurance, whether by the Insurer or the insured, will
be effective only upon written notice and only after the expiration of 60
days after a copy of such written notice is received by the Director.
(e) Any other termination of the insurance will be effective only upon written
notice and only after the expiration of 30 days after a copy of such written
notice is received by the Director.
I hereby certiry that the wording of this instrument is identical to the wording specified in
40 CFR 2il.151fi), as incorporated by reference in Utah Administrative Code R315-8-8
as such regulations were constituted on the date first above written, and that the Insurer
lForm 151(j) November 2012
Martine Houston
Regional Manager, Authorized Representative of Chartis Specialty Insurance Company300 S. Riverside Plaza, Suite 2100, Chicago, lL 60606
is licensed to transact the business of insurance, or eligible to provide insurance as an
excess or surplus lines insurer, in the State of Utah.
2gorm 151(j) November 2o1z
lt (). ik'r 'lI\l.l':nii- I r.rir Sit)"1 i-{}".!q$
.luly- l.201"i
Sr:txt-l'. Anderson
Deparrment oJ' fnvironmental Qual ity
Division o{'Solid ar:d ll;rzardous Wasle
2tllt Norrh 1460 t est
P"O. Box l448ll0
Sah l.akc Cir;-', lirah 8.tl l4*1880
Ite: Closure and Pclst-Closurc Ccrtillcates of Insurancc
zlA'I'K Launch Systenrs *Pramontory l;acil iry' U'l'D00908 I 3 5 ?
A'l'K Launch $ystems * Ilacchus Facility IJTDO01705029
l)ear !1r. Anderson:
lliviilar: i::i
$*iid ar*l l-lnzavcj*ti", ir*t:,zr:
";l"fx- B I fffl3
fclj- ooL+"b31
As required by the requirements in 40 C:pR 2&1.143 and 40 C"PR 26,{.i44. Al"K Launch
Systems is providing signed duplicate original cr:rtillcates ol'insurance ftlr closure rurd
post-closure care fur our Bacchus and Prourontor,v lacilities. 'l'he revised cost estimates
for closurct and post-closurc t:ar* w$r* itemizcd in our May' 22. 2013 curr*spontlen*e. If
y'ou have questions on this topic" I can be contaued &t (801) 6gS-0j l g.
I turlily untler ltenult.v ttf latr, thut thi:i dotuntent arul all ultuthmettts v,erc prtpurtd
untler m;' direttion or stqlerttision in accttrdanrc *,'itl', cr t;yste n designcl b assut { thtil
qwlifierl personntl proptr[y gather end evrtlailtr the inlbrnation submitttd. I!*:ted an
mS'intluiry of the person or persons w'lw munaga lhe sp'stttrn. or (hose person$ dircctll,
responsihle.fisr gatherin!{ the inJbrmution. the in/itrmuti*tn is, ta the hest ti'n}, kruwiedge
und heliel, lrue, ac(ur{It* und *tntplete. I &t r qware that tlwe are signilicant ptnulties
Jbr suhmitling,/hlse in{itrnation. indutling ihe possibili{y o{linc antl impri"sonment.li}r
kwtu,ing violatitnw.
Sinccrclv,
tl
,q 1{^p/.hVer!-'..**
(ieorue (io$ch
Manriger. linvi ronmental Scrvices
l)avid McCleary. DSll\tu
Jeti'Vandcl. DSIIW
iloa Z'hu" DSIIW
;' "." ' n > ,1.'il';... 18,1 1.#+', rf.f{ : \,'$/f j{ J}E\
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1. .,,'i: :l:: llftii ,' "'i ,;:;
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Pl';m*rf* i,t**trllp. P.q 3E!4S;
SS&.SfS.43?* plr
CHRT|FICAT€ OF $'f $UR*l{cE
FOR CLOSURE OR POST.CLOSURE CARE
NAilE AND ADARESS SF INSURER: GreatArnerican E&S Insurenca Comp*ny, 301 E. 4ft Strcet,
Cincinnati, (HEREIN CALLED THf IHSURER") Ohio 45202
NAME Ar*D ADDRESS OF IN$URFD: Alliant Techsystems Inc., 74$0 Flying Cloud Drive,
Minneapalis, {HEREllrl CALLED THE "INSUREF"} Minnesoia 55401
Faciliti*s Covsred:
1. UTDOS1705029 ATK t-aundt $ystems - Baccfiug, FO Box 93, Magna, Ufah 84044
- Closure Care: $415,485, Post- Closure Cara: $0
Z. UT00OS0813S7 ATK lsuncfr Systems - trrornonhry, PO Box 707, Brigtuam City, Utah 843t)2
- Closure Cere: $880,4?5, Fost- Closure Care: S5 2,597
Face Amount $1,668,558
Policy Number: CPC 37622&4 02
Effec{iva Dat*: SI?8IP0J 3
The Insurer her*y wrtifies that it has issred to tre lnsured tre pdicy of ins{lmnm identified above to
prnvide financial ersurance for dcture afid po$t*cklsufa cafe ior the kuilities identifistl ahove. The
insurerfurtherwarnar*$ frat such Folicy ca#orrns in all respe* with the requircments of R31$&8
Frftich incorporate 4CI CFR 4.143{€}, reA.t*te}1, or RS1$7-15 ltl'hich incorporata ?65.143{e}, and
iOS.t*S1Cl; a* applieable and as snrcfr regulations were constituted on fre date sho*n immediately
belrryv. li is eSreeO that arry provision sf fhe policy incsnsistentwith zuctr reg*lations is hereby
amended to eliminate zuch inconsi$tency.
l6lhenev*r raqucsted by tle Dir*c*or of the trivision *f fre Solid and Ha;ardass Wa*te of the $tate of
Utah, Fle Ineurer agrees tsfumish to the Dirdor a duplicate adginal of the policy listed above,
including all endor$€rnents thereon.
Page l of2
+:ri !,i:11y'iit+uiir {'}**,j. Si*i* ii}*
i:]ivrr':ul-it {dr,:'liil'lg trp, 1 S4{9:
.:. rif, i.'18 ..,i i. l'.J ci r
I heleby c€rtify fiSth€ trcrding cf &is c*rtificate is idstical to the rq.ording cpecified in R3'tS&8 nr
R31&7-15 ae such reguletions !!rer€ &nstituted on the date shown irnmediately beloriv.
Auhorized signafurc for Insuren
Name of person signing: itark Vsono
Tife of percon signing: Divi*isnal$eniorVire Fresident
$ignature of Wtnse$ w f{otary:
.t Ioate kJlTeoR
tAfhen *ompat*d *end thie doclrmrnt to:
Birector of the Division of $olid and Hazardous Waste
PO Box 144880
$alt Laks Clty, U{ah S4t14*4€8S
gitry R.6**f, Uo6ry hdrflcnyru$h Twp., l,lonlgodnry C(rtrry
Page 3 of?