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March 31,2025
Mr. Douglas J. Hansen
Director
Division of Waste Manaqement and Radiation Control Board
P.O. Box 144880
Salt Lake City, UT 84114-4880
RE: Financial Assurance Test
Dear Mr. Hansen:
I have enclosed the 2024 filing requirement for Financial Assurance ("Public" and
"Confidential" versions) along with the Independent Auditor's Special Report, and the
audited financial statements. I have also enclosed a special report from our Independent
Accountants which supports the requirement for total assets in the United States. Be
advised that McWane is submitting this information under a claim that it is Confidential
Business Information (CBI), exempt from disclosure under Utah Code Sections 63-2-308
and the Freedom of Information Act, 5 U.S.C. $ 552(bX4), and that unauthorized
disclosure of this information will subject agency employees to criminal penalties under
the Trade Secrets Act, 18 U.S.C. $ 1905.
McWane is making a claim for business confidentiality pursuant to U.C.A. $63G-
2-309, for the attached document, based upon U.C.A. $63G-2-305(2)(a): disclosure of the
production information contained in the attached document/report would result in unfair
competitive injury to McWane. McWane, as a closely-held company, is not required to
disclose this financial information, and takes, and intends to continue to take, all
reasonable measures to protect its confidentiality. It is made available only to upper
echelon corporate officers, directors, and other employees who obtain access only on a
need-to-know basis. This information is not, and has not been, obtainable by legitimate
means without the consent of McWane.
If you have any questions please give me a call.
Sincerely,
AA/i(L.-/{_
Kirk Petty U
Enclosures
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PUBLIC
Mc\ilAI'{E,
NC
March 31,2025
Mr. Douglas J. Hansen
Director
Division of Waste Management and Radiation Control Board
P.O. Box 144880
Salt Lake ciry, uT 841l4-4880
Dear Mr. Hansen:
I am the Chief Financial Officer of McWane, Inc. This letter is in support of this firm's
use of the financial test to demonstrate financial assurance for closure, post closure, or
corrective action as specified in Utah Administrative Code 315-309-9 (relating to
Financial Assurance).
1. McWane, Inc. is the owner or operator of the following facility in Utah for which
financial assurance for closure and post closure costs is being demonstrated through a
financial test specified in Utah Administrative Code 315-309-9: On-Site, non-hazardous,
industrial waste landfill located at McWane Ductile Utah(formerly known as Pacific
States Cast Iron Pipe Company),2550 South Industrial Parkway, Provo, Utah 84603.
2.The current estimate for closure and post closure costs for this facility is $ 994,600.
3. This firm, as owner and operator is demonstrating financial assurance for the closure,
post closure, or coffective action of the following facilities through the use of a test
equivalent to a financial test specified in Utah Administrative Code 315-309-9. EPA ID#
OHD-004-294-849, McWane Ductile Ohio(formerly known as Clow Water Systems
Company) Division of McWane Incorporated, South 6th Street, P.O. Box 479,
Coshocton, Ohio 43812; EPA ID# IAD-981-711-807, Oskaloosa Plant, Valve Division of
McWane Incorporated,g}2 South Second Street, Oskaloosa,\owa52577. The following
is the total of all environmental liabilities and other environmental obligations that
McWane, Inc. carries that are under a financial test arrangement:
3.1 Utah
3.2 Ohio
Iowa
3.3 Total
$ 994,600
2,548,408
983,258
s 4,526,266
PUBLIC
4.1. None.
4.2.Ratio of Total Liabilities to Net Worth is less than 1.5.
4.3. None.
5. Tangible Net worth minus $10,000,000 is greater than item 3 above.
6. None.
7. Assets located in the United states are greater than item 3 above.
8. McWane, Inc. has received an unqualified opinion from the independent auditor.
The figures for the following items are derived from this firm's independently audited,year-end financial statements for the latest completed fiscal year, en-ded Decimber 31,2024.
l. Total liabilities $ "Confidential Treatment Requested',
2. Tangible Net worth $ "confidential Treatment Requested"
3. Net Worth $ "Confidential Treatment Requested,'
4. Total assets in u. S. $ "confidential Treatment Requested"
I hereby certifr the firm meets all requirements set forth in Utah Administrative Code
315-309-9 to demonstrate financial assurance for the closure and post closure.
A. /\f/\('r )1.-t,\/ rr
o.
Senior Vice President and Chief Financial Officer
CC: David Georgeson, McWane Ductile Utah
Buslness
Confl dentlal
have been removed from this
public file.
For assistance, pfease
contact the GRAMA
Coordinator.