DSHW-2018-005915 - 0901a0688085c8d4

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COMPLIANCE EVALUATION INSPECTION
WAST€ MANAGEMFNI
: RAOIATION CONTROI
Date of Inspection:
Facility:
Facility Address:
County:
EPA ID # (if applicable)
Latitude / Longitude:
Arrival / Departure Time:
Weather Conditions:
Report Prepared By:
Names of Inspectors:
Names of Facility Participants:
Permit #:
LHD Notifications / Date:
Facility Notification / Date:
Applicable Rules:
15 June 2018
E.T. Technologies, Inc.
3110 West California Ave, Suite D
Salt Lake City, UT 84104
[phone]
Salt Lake County
uTR000009639
40.7 42008, - | | t.9 65406
1:00 - 2:11 pm
Mostly sunny, 83-88o F
David Wheeler
David Wheeler
Tim Ard, Project Supervisor
uoP-O182
15 June 2018 @ l0:33, Pih-Fhai Hui
15 June 2018 @ 10:28, Tim Ard
R315-15 of the Utah Administrative Code
CREDENTIALS
On l5 June 2018, I met with and presented credentials to Tim Ard, Project Supervisor, of
E.T. Technologies, Inc. (ETT).
PURPOSE AND SCOPE
The purpose of this Compliance Evaluation Inspection (CEI) was to evaluate the ETT's
management practices for compliance with R315- 15 of the Utah Administrative Code (the
Rules), Utah Used Oil Management Act 19-6-701, and ETT's Used Oil Transporter Permit.
The inspection included a discussion, document review, and facility walk-through.
Page I of5
FACILITY DESCRIPTION AND WASTE MANAGEMENT OPERATIONS
ETT is a company specializing in waste management and response. A small portion of
their operations involves used oil transport. According to Mr. Ard of ETT, the majority
of the used oil they transport originates from decommissioning underground storage
tanks and sumps. The used oil is transported to Sump & Trap, which is a permitted used
oil transporter and processor. For large loads, ETT contracts with permitted transporters
like Emerald Services and Thermo Fluids. They have a website which explains what
they do as a company: http://www.ettech-env.com/.
ETT only recently became permitted as a used oil transporter on 4 June 2018. This was
the first used oil inspection of the facility since becoming permitted.
COMPLIANCE STATUS:
Since ETT has been permitted less than two weeks and used oil transportation constitutes
only a small portion of the company's activities, there was not as much to review as with
most permitted facilities. Overall, ETT seems to be in general compliance with the Used
Oil Rules with some minor exceptions which were corrected during the inspection. Much
of the time was taken up with discussions of the topics like waste oil vs. used oil, on-spec
vs. off-spec vs. hazardous waste, and similar topics.
The inspection included a review of the transportation tracking documents, insurance
documents, training procedures, and equipment.
R315-15 Standards for the Manaeement of Used Oil
R315-15-l Applicabilitv. Prohibitions. and Definitions,/ --ETT appears to be in compliance with this portion of the Rules.
R315-15-2 Standards for Used Oil Generators
n.a.
R315-15-3 Standards for Used Oil Collection Centers and Assregation Points
n.a.
R315-15-4 Standards for Used Oil Transporters and Transfer Facilities4.1 APPLICABILITY
,/ --ETT is permitted as a used oil transporter as of 4 June 2018. ETT
transported used oil prior to being permitted, but applied for and received a
permit once they were alerted to the requirement by another transporter.4.2 RESTRICTIONS ON TRANSPORTERS WHO ARE NOT ALSO
PROCESSORS...
,/ --ETT appears to be in compliance with this portion of the Rules.4.3 NOTIFICATION
./ -- ETT appears to be in compliance with this portion of the Rules.4.4 USED OIL TRANSPORTATION
,/ --ETT appears to be in compliance with this portion of the Rules.4.5 REBUTTABLE PRESUMPTION FOR USED OIL,/ --ETT is a company which only rarely deals with used oil that would
require halogen testing for the pulposes of this section. However, all used
oil shipments examined for this year had Clor-d-Tect test kit results, despite
the fact that ETT was not permitted at the time of the transportation. There
were several types of Dexsil test kits present in Mr. Ard's office, all of them
well within their expiration date (December 2018).
Page 2 of 5
4.7 TRACKING
Tracking documents for the entire year (2018) were reviewed during the
inspection. ETT only transported used oil eight times during that period, all
prior to being permitted. On three occasions, ETT failed to record the EPA
ID numbers of the transporter (themselves) and receiving facility. Mr. Ard
of ETT filled in the missing EPA numbers during the inspection, thereby
bringing the facility back into compliance within minutes of the oversight
being noted. We discussed ideas on ensuring that this issue doesn't arise in
the future. All other required tracking information appeared to be recorded.4.8 MANAGEMENT OF RESIDUES
,/ --ETT takes all used-oil related residues to Sump & Trap.
R315-15-5 Standards for Used Oil Processors and Re-Refiners
n.a.
R315-15-6 Standards for Used Oil Burners Who Burn Off-Specification Used Oil...
n.a.
R315-15-7 Standards for Used Oil Fuel Marketers
n.a.
R315-15-8 Standards for the Disposal of Used Oil,/ --ETT appears to be in compliance with this portion of the Rules.
R315-15-9 Emergencv Controls
./ --ETT appears to be in compliance with this portion of the Rules.
R315-15-10 Liabilitv/Financial Requirements.
,/ --ETT appears to be in compliance with this portion of the Rules. The
Division rider arid the general liability ACORD were provided during the
inspection.
R315-15-11 Closure
n.a
R3 15- 15-12 Financial Assurance
This was not reviewed since the permit was approved less than two weeks
ago.
R315-15-L3 Reeistration and Permittine of Used Oil Handlers
,/ --ETT appears to be in compliance with this portion of the Rules as of
receiving their permit 4 June 2018.
R315-15-14 DIYer Reimbursement
n.a.
R315-15-l5Issuance and Revocation of Permits and Registrations
n.a.
R315-15-16 Grants
n.a.
PERMIT REVIEW:
The following issues were noted during a brief permit review:
1) There have been no used oil trainings since the permit was issued on 4 June 2OI8.
However, ETT intends to do hold their training prior to any future used oil transportation.
Page 3 of 5
2) The sump truck was not labeled with the words used oil. I gave Mr. Ard three used
oil stickers for use until they obtain their own (which they intend to do shortly).
FOLLOW-UP ACTIONS (If applicable):
None required at this time. Future inspections should review if the above-noted issues
have been dealt with appropriately.
lnspector Signature:15 June 2018
DateDavid Wheeler
ATTACHMENTS:
1. Photos
2. Used oil transporter inspection checklist
Page 4 of 5
E.T. Technologies, Inc.
3110 West California Ave, Suite D, Salt Lake City, UT 84104
15 June 2018
Figure 1.. E.T. Technologies vac truck used for used oil bulk transportation.
Figure 2. Close-up of the vac truck shown in figure 1.
Page 5 of 5
EPA ldentification No.:
Site:Date: iS ll-,^--e- Zo\RTime: (
Used
INSPECTION ITEM
Oil Transporter
I ctrenoru |
Person met: 'TT"- A*n
lnspection Ghecklist
Y I n lml COMMENTS
Mrscellaneous:
1. Does transporter also process used oil
other than by settling, water separation,
and other incidental processing?
(lf yes, see R315-15-5.)
R3l5-15-4.2 (a)&(b)
J
2. Does the transporter only deliver to:
a. another transporter (with EPA #)
b. processor/refiner (with EPA #)
c. off-spec burner (with EPA #)
d. on-spec burner?
R3l5-15-4.4 (a)
/L
>,:
3. Are all residues handled properly?R3l5-15-l.l (e)(3)P.-r^.r::-e.t.\ ctli >t -.g {ltzD
Records:
1. Does transporter have records of
oil analyses to prove compliance with
the rebuttable presumption (3 yrs)?
R3l5-15-4.5
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Does the transporter have records of
all accepted shipments, including:
a. name & address ol oil orovider /
b. EPA lD number of oil provider .,/.
c. quantity of used oil accegted ,'/
d. date ofacceptance \/
e. signature of oil provider? r/
R3 l5-15-4.7 (a)
&
R3 l5-15-4.5(d)
/
Does the tansporter have records of
all used oil deliveries by the transporter:
a. name & address of accepting fac. v/
b. EPA lD number of oil acceptor-[
c. quantity of used oil delivered "/d. date of delivery -/
e. signature of oil acceptor7 /
R3r5-15-4.7 (b)
IIJ
t\iesr^.\ I F* rDw "J- 3 .,.( <.
DOT Reouirements:
1. ls the company name written on the
side of the vehicles in 3-inch letters?
R3l5-r5-4.4 (b)
ls facility registered with DOT?R3l5-15-4.4 (b)/
ls liability insurance current & adequate?R3 l5-15-10
Has transporter met permit conditions?perrnll lV g^^r'
Inspector:Page
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