DWQ-2025-003306

April 11, 2025

Tandy Bair, Manager
3B Powder Coating
358 North 2040 East
St. George, Utah 84790

VIA EMAIL
(Read Receipt Requested)
[e-mail]

Subject: Department of Environmental Quality Permitting Requirements for the 3B Powder Coating Facility and Pond

Dear Ms. Bair:

On February 24, 2025, Ash Creek Special Service District notified the Utah Department of Environmental Quality’s (DEQ) Division of Water Quality concerning your metal finishing business,
3B Powder Coating, located at 3287 E. Washington Dam Road, in Washington, Utah. It is the Division’s understanding that the activities occurring at 3B Powder Coating were first identified
during an Industrial Waste Survey conducted by the St. George Water Reclamation Facility in 2023. Based on the survey document, the facility was identified as a metal finishing business
with an associated evaporative pond containing process water with acids/corrosives.

Woodrow Campbell (Woody), of the Division of Water Quality, first contacted Carol Bair, by phone on February 27, 2025. Carol subsequently provided pictures of the pond and a concrete
area next to the building with various metal objects hung to dry. She also provided product description sheets for the Dura-Skrim N30B Reinforced Linear Low-Density Polyethylene (LLDPE)
liner that was used to line the existing pond and Safety Data Sheets (SDSs) for the Flash Clene 1414 203-014 Heavy-Duty Alkaline Cleaner and the Surcoat SW 12 173-012 Iron Phosphate
Cleaner/Coater. The SDSs indicate that these chemicals may be considered hazardous. Woody also visited the facility on March 25, 2025, and met with Carol Bair and Eric Bair.

Based on the information obtained to date, and assuming 3B Powder Coating continues using a pond for storage of process water and the products described above, the following permits
will be required:

The facility will need to obtain a ground water discharge permit from the Director of the Division of Water Quality. Requirements for a ground water discharge permit can be found under
the Ground Water Quality Protection rule Utah Admin. Code R317-6-6(6.3). All applications for a groundwater discharge permit must be performed under the direction of and bear the seal
of a professional engineer or professional geologist. Additionally, a construction permit will be necessary per Utah Admin. Code R317-1-2(2.2). The pond will need to be engineered properly
including the requirement for a double liner with leak detection between the two liners. Pursuant to R317-1-2(2.2), the pond design must be performed under the direction of and bear
the seal of a professional engineer. You may obtain a copy of the ground water discharge permit application package by visiting our website at: https://deq.utah.gov/water-quality/current-permits-utah-ground-water-quality-protection-program.
Please contact Woody Campbell at [e-mail] if you have questions about the ground water discharge or construction permitting requirements.

An industrial storm water permit will be required. Please contact Jordan Bryant, Industrial Storm Water Coordinator with the Division of Water Quality, at [e-mail] if you have
questions about the industrial storm water permitting requirements. Our website does offer some helpful permit files, including a template for a Stormwater Pollution Prevention Plan,
that you can use or reference at: https://deq.utah.gov/water-quality/general-multi-sector-industrial-storm-water-permit-updes-permits
EPA’s NPDES eReporting Tool for the Multi-Sector General Permit (NeTMSGP) is used to electronically prepare and submit a complete and accurate Notice of Intent (NOI), including payment
of the appropriate permit fee. The NOI certifies the permittee is eligible for coverage as outlined in Part I.B of the MSGP, has developed a Plan in accordance with Part VII of the MSGP,
and has provided information on the industrial activities and related discharges. NeT-MSGP can be accessed by going to https://npdes-ereporting.epa.gov/net-msgp/action/login. To obtain
instructions for how to create an account, submit a new NOI, and to obtain a copy of the permit and find other helpful permit files, you can visit the DWQ website at: https://deq.utah.gov/water-quality/general-multi-sector-industrial-storm-water-permit-updes-permits.

Because the pond is an unpermitted surface impoundment/hazardous waste storage unit, a hazardous waste permit will likely be required. Please contact Kari Lundeen, Environmental Scientist
with the Division of Waste Management and Radiation Control at [e-mail] if you have questions about the hazardous waste permitting requirements.

Approval or permits from the local authority or the county may also be necessary. In consultation with the Southwest Utah Public Health Department, we understand that an unpermitted
septic system was installed for this business. Please work with the health department to properly design
and install a permitted septic system. Also, the septic system should only be used for domestic waste and not for any industrial discharges.

We appreciate your responsiveness and willingness to work with DEQ staff on concerns about the activities happening at this property. Please obtain the proper permits before continuing
any industrial activities at your facility.

Sincerely,

Deidre Beck, P.G.
Groundwater Protection Section
Permitting Manager

DLB/WC/JB

cc: Via email
Carol Bair, 3B Powder Coating, [e-mail]
Deidre Beck, PG, Division of Water Quality
Leanna Littler-Woolf, Division of Water Quality
Woody Campbell, PE, Division of Water Quality
Jordan Bryant, Division of Water Quality
Debroah Ng, Division of Waste Management and Radiation Control
Kari Lundeen, Division of Waste Management and Radiation Control
J. Paul Wright, PE, DEQ District Engineer
Mike Chandler, Ash Creek Special Service District, [e-mail]
Jeremy Roberts, Southwest Utah Public Health Department

DWQ-2025-003306