DSHW-2024-009363

Erik Otto
Univar Solutions USA LLC
3075 Highland Pkwy Suite 1000
Downers Grove, IL 60515

Utah Department of Environmental Quality
Waste Management and Radiation Control
195 North 1950 West
Salt Lake City, UT 84116

RE: Exception Report

To Whom it May Concern,

Univar Solutions USA LLC Clearfield, UT (Univar) EPA Transporter ID TXR000084869 is
submitting an exception report on behalf of Ultradent Products Inc. (Ultradent) EPA ID
UT0000449181.

Univar received 1 drum of D001 Flammable waste from Ultradent on September 20, 2024, into its
less than 10-day storage facility. The waste was scheduled to be delivered to Systech
Environmental Corp EPA ID KSD980633259.

Generator: Ultradent Products Inc. 505 W 10200 S South Jordan, UT 84095
EPA ID: UT0000449181

Transporter: Univar Solutions USA- EPA ID: TXR000084869

Designated Facility: Systech Environmental Corp - EPA ID KSD980633259

Waste Description:
1-DF, 218P, UN1197, Waste Extracts, Flavouring, Liquid, 3, II, RQ (D001), ERG 127

Thank you,

Erik Otto
Regional Regulatory Manager
Univar Solutions
P: 425-324-1275
M: 425-324-1275
[e-mail]
UnivarSolutions.com

Timeline of Incident and Investigation
Time line:
9/20: Univar Solutions picked up one (1) 218lb fiber drum of UN1197, Waste Extracts,
Flavouring, Liquid, 3, II, RQ (D001), ERG 127 from Ultradent Products Inc. EPA ID
UT0000449181. The drum was received into inventory at Univar Solutions USA LLC
Clearfield’s (Clearfield) 10-day hazardous waste storage. Receipt was recorded into SAP and
drum was added to site’s inventory. The waste’s designated facility was Systech Environmental
Corp EPA ID KSD980633259

9/24am: Clearfield performed its physical inventory as required by Corporate Standards.
Clearfield confirms it had possession of the drum during the inspection.
• Note- Univar Clearfield performs physical inventory of its 10-day waste twice per
week.
9/24pm: Clearfield loaded a trailer of waste and shipped it to Tradebe Environmental Services
4343 KENNEDY AVE, EAST CHICAGO, IN, 46312– EPA ID IND000646943

9/25: No shipments of waste left the facility

9/26am: Clearfield loaded a trailer of waste headed to Clean Earth 1689 Shar-Cal Rd, Calvert
City, KY 42029 EPA ID KYD985073196

9/26: Clearfield performed its second inventory of the week. At this time, Clearfield discovered
one drum of UN1197, Waste Extracts, Flavouring, Liquid, 3, II, RQ (D001), ERG 127 was
missing from inventory

9/26: Clearfield assumed it mistakenly loaded the missing drum onto the trailer it had loaded
earlier bound for Clean Earth. Clearfield off-loaded the trailer to locate the missing drum. The
drum was not on the trailer. Clearfield then performed an additional inventory check.

9/26: Clearfield concluded that the drum must have been loaded on the trailer headed to Tradebe.
Clearfield contacted Tradebe to alert them of the mistake and asked Tradebe to notify Clearfield
when the drum arrived.

9/27: Truck bound for Tradebe arrived on 9/27
Tradebe did not respond on 9/27 Friday

9/30: Clearfield contacted Tradebe via email to follow up on drum – no response

10/1: Univar’s Escalation team contacted Tradebe and was informed that they did not receive it.

10/15: Univar’s regulatory team contacted to start investigation
Tradebe, Systech, and Clean Earth are the only three TSDFs that received shipments of waste
during the time of the incident.

Investigation included contacting Tradebe, Systech, and Clean Earth; and review of all shipments
from Clearfield to Tradebe, Systech, and Clean Earth: a review of all invoices from each of the
three TSDFs.