DSHW-2018-003404 - 0901a068807f1a4d

DSHW-2018-003404 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
April 19, 2018 Randy Rowe, Operations Manager
Metal Coatings (Formerly Shawn Enterprises)
2050 South 7500 West Magna, Utah 84044 RE: Warning Letter
UTR000007476
Dear Mr. Rowe: On April 4, 2018, a representative from the Division of Waste Management and Radiation Control
inspected your facility to determine compliance with the Utah Solid and Hazardous Waste Rules.
During the inspection, you explained that you had purchased the property and facility from Shawn Enterprises and are now operating two new businesses at this location. The first business is a scrap metals recycling operation where metal parts are either shredded or will be
melted in a furnace. The furnace is currently under construction. You indicated that you have recently
obtained an air quality permit to operate the furnace from the Division of Air Quality. The furnace will be used to melt steel and aluminum engines and transmissions purchased from scrap auto yards. The engine blocks, transmissions, etc. are stored on site until processed. Once these wastes are shredded and melted, the metals are segregated and re-sold to other metal recyclers. In accordance with R315-302 and
R315-312 of the Utah Administrative Code, a recycling facility is required to submit a plan of operation,
to the Director that demonstrates compliance with the applicable standards of R315-302-2 and R315-312 prior to acceptance of the waste. The second business is a metals coating shop where metal parts are sand blasted and painted with various types of coatings, e.g., oil, water based and epoxy paints. You indicated that hazardous waste
has not yet been generated by this coating operation. (Over)
During the inspection, numerous containers of unknown materials were documented at your facility.
You indicated that most of these materials were left behind by Shawn Enterprises. The left-over materials are waste paint related materials which were previously managed as hazardous waste by Shawn Enterprises. Subsequently, you have consolidated and placed most of these materials in a metal storage shed. The majority of these containers were not labeled in accordance with R315-262 of the
Utah Administrative Code. Some of these wastes may be incompatible with one another. Therefore, it
is imperative that a hazardous waste determination be made as soon as possible. In addition, there were numerous containers of various sizes, scattered around the facility that appeared to be used oil, antifreeze and other unknown materials. None of these containers were properly labeled.
Located in the back of the facility were several containers of dirt that you indicated were generated by a
former person associated with Shawn Enterprises who was apparently trying to extract gold from the dirt. Based on the inspection, the following compliance issues need to be immediately addressed:

1. Submission of a plan of operation for the recycling facility pursuant to R315-302-2 of the Utah Administrative Code. The plan must be approved prior to accepting wastes. 2. Compliance with applicable provisions of the Utah Administrative Code regarding hazardous
waste generation and management.
a. R315-262-11 of the Utah Administrative Code requires that anyone who generates a solid waste, as defined in R315-261-2 shall make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to
applicable RCRA regulations. Hazardous waste characterizations are required to be
made at the time and point of generation b. R315-262-16 of the Utah Administrative Code requires that if after hazardous wastes characterizations have been made, and it is determined that more than 1,000 kilograms
(2,200 pounds) of hazardous waste are on site, the wastes must be sent offsite for proper
disposal within 180 days. c. R315-262 of the Utah Administrative Code requires wastes be properly labeled.
d. R315-261-177 of the Utah Administrative Code requires incompatible materials be stored
and protected from other materials. A RCRA Subtitle C Reporting Form 8700-12 will need to be updated with your current information. The form can be filled out and submitted at
https://rcrainfo.epa.gov/rcrainfoweb/documents/rcra_subtitleC_forms_and_instructions.pdf
The Division recognizes that, even though you inherited much of these abandoned wastes from the previous owner when you purchased the property and facility, you are responsible for proper management of these wastes.

You are hereby requested to submit to this office on or before May 25, 2018, a plan of operation for metals recycling and a waste sampling and management plan for the other wastes. A schedule for compliance with the rules for the other issues identified above should be included.
If you have any questions, please call Alex Pashley at [phone].

Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
STA/AP/kl c: Gary Edwards, MS, Health Officer, Salt Lake County Health Dept.
Royal DeLegge, MPA, EHS, Environmental Health Director, Salt Lake County Health Dept.
Alan Humpherys, UDEQ, Division of Air Quality Allan Moore, UDEQ, Division of Waste Management and Radiation Control