DSHW-2024-007482

7/29/2024
Aerospace Aluminum Processing, LLC
Doug Chacon, Operations Manager
2882 South 1030 West
South Salt Lake, UT 84119
RE:Compliance Advisory No. 2407107Compliance Evaluation InspectionUTR000013847
Dear Mr. Chacon:
This Compliance Advisory is being sent to your attention as a representative of Aerospace Aluminum Processing, LLC (the Respondent). According to the Division of Waste Management and
Radiation Control’s (Division) records, you are the designated contact person for the Respondent. On June 6, 2024, representatives of the Division conducted a compliance evaluation inspection
at the Respondent’s facility. The scope of the inspection was to verify compliance withUtah Administrative Code R315 (the Rules), and the Utah Solid and HazardousWaste Act (the Act).
Based on observations and information obtained during the inspection, the Director of the Division (Director) is issuing this Compliance Advisory to provide the Respondent with notice
of the followingcompliance issues as well as an opportunity to correct these apparent compliance issues: Utah Administrative Code R315-262-11(d)requires “a person who generates a hazardous
waste to determine whether the waste exhibits one or more hazardous characteristics as identified in Sections R315-261-20 through R315-261-24 by following the procedures in Subsections
R315-262-11(d)(1) or (2), or a combination of both.”
No hazardous waste determination had been made on rags contaminated with chromium primer and solvent.
A waste determination was emailed to the inspectors after the inspection and photos were sent of the container in which the rags are being accumulated labeled with the words “hazardous
waste’ and an indication of the hazards of the contents. AAP will dispose of the rags offsite as (D007)hazardous waste. Utah Administrative Code R315-262-15(a)(5)(ii) requires that “a
generator shall mark or label its container with an indication of the hazards of the contents.”
All containers in the CAA and one container in the SAA were not labeled with the words “Hazardous Waste” or an indication of the hazards of the contents.
Facility personnel added the Hazardous Waste label and indication of the hazards after the inspection and sent photos.Utah Administrative Code R315-262-17(a)(7)(i): requires that facility
personnel successfully complete a program of classroom instruction, online training, e.g., computer based or electronic, or on-the-job training that teaches them to perform their duties
in a way that ensures compliance with this part and that theprogram be directed by a person trained in hazardous waste management procedures.AAP failed to document hazardous waste, emergency
response, or hazardous materials shipping training to teach AAP employees to perform their hazardous waste management and emergency response duties to ensure compliance with the hazardous
waste rules. AAP failed to document that Doug Chacon, the individual directing AAP’s training program, was trained in hazardous waste management procedures.
Please conduct and document hazardous waste, emergency response, and Department of Transportation (DOT) Hazardous Material Shipping General Awareness, Function-Specific, Safety, and
Security (49 CFR 172.704) training.
Please provide records that document the training required in 49 CFR 172.704. Recordkeeping. Each hazmat employer must create and retain a record of current training of each hazmat employee,
inclusive of the preceding three years for as long as that employee is employed by that employer as a hazmat employee and for 90 days thereafter. The record must include: (1) The hazmat
employee's name; (2) The most recent training completion date of the hazmat employee's training; (3) A description, copy, or the location of the training materials used to meet the requirements
in paragraph (a) of this section; (4) The name and address of the person providing the training; and (5) Certification that the hazmat employee has been trained and tested.
Utah Administrative Code R315-262-262: requires an LQG “to submit a quick reference guide of the contingency plan to the local emergency responders.”
AAP failed to prepare and submit a Quick Reference Guide to its local emergency responders or the LEPC., an equipment list, and map of locations of the hazardous waste.
Prepare and submit a Quick Reference Guide to the local emergency responders or the LEPC. Provide the quick reference guide and documentation to demonstrate that it was submitted to
the necessary local emergency responders.Utah Administrative Code R315-262-261 requires a LQG to list in their hazardous waste contingency plan all emergency equipment at the facility,
such as fire extinguishing systems, spill control equipment, communications and alarm systems, internal and external, and decontamination equipment. The plan shall include the location
and a physical description of each item on the list, and a brief outline of its capabilities.
AAP failed to include an equipment list with the location of the emergency equipment, a description of the equipment, and an outline of the capabilities of the equipment in its hazardous
waste contingency plan.
Please revise your hazardous waste contingency plan to include all emergency equipment at the facility, such as fire extinguishing systems, spill control equipment, communications and
alarm systems, internal and external, and decontamination equipment. The plan shall include the location and a physical description of each item on the list, and a brief outline of its
capabilities. Submit a copy of the contingency plan and all revisions to all local emergencyresponders (i.e., police departments, fire departments, hospitals and State and local emergency
response teams that may be called uponto provide emergency services). This document may also be submitted to the Local Emergency Planning Committee, as appropriate.Provide to the Division
the revised hazardous waste contingency plan and documentation to demonstrate that it was submitted to the necessary local emergency responders
Utah Administrative Code R315-262-273-13(d): requires a handler of universal waste to store used aerosol cans in a structurally sound container labeled “Universal Waste”.
Aerosol cans were being thrown in the garbage. This was corrected after the visit and a photo was sent to the inspector.
Pursuant to this Compliance Advisory, the Director is providing the Respondent an opportunity to correct the apparent compliance issues. The Director will also consider any evidence
and additional information provided by the Respondent.
Within 30 days of the date of this Compliance Advisory, please submit the following requested documentation regarding each compliance issue and associated corrective actions to the Director:
the cause of each compliance issue;
the specific corrective actions taken, results achieved, and applicable dates;
if future corrective actions are proposed, the specific corrective actions and proposed completion dates, including intermediate milestones, as applicable; and
how the corrective actions will prevent similar compliance issues from recurring.
All information regarding corrective actions relating to this matter should be addressed to the Director at:
Douglas J. Hansen, DirectorDivision of Waste Management and Radiation ControlP.O. Box 144880Salt Lake City, UT 84114-4880or by email at: [e-mail]
DO NOT submit any documents or information through email that are protected,confidential, proprietary, orfor which you are claiming business confidentiality underUtah Code § 63G-2-305.
To better ensure records are protected, all suchdocuments and information must be submitted using the mailing address above and
in accordance with Utah Code § 63G-2-309.
If the Respondent demonstrates that it has taken appropriate corrective actionsregarding the matters addressed in this Compliance Advisory, the Director will issue a closeout letter
and will consider this matter to be closed.However, if the Respondent fails to demonstrate appropriate corrective actions within the30-day timeframe, the Director will consider taking
escalated enforcement actions, including seeking financial penalties. In all events, the matters addressed in this Compliance Advisory, including the Respondent’s corrective actions,

will become part of the Respondent’s compliance record and may be considered in connection with future enforcement matters.
If you have any questions, please contactRachel Winters at 385-515-7771.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/RJW/JK
c:Dorothy Adams, Health Officer, Salt Lake County Health Dept.
Ron Lund, Environmental Health Director, Salt Lake County Health Dept.
Eric Peterson, Environmental Health Deputy Director, Salt Lake County Health Dept.
Judy Moran, Division of Waste Management and Radiation Control, UDEQ
Alexis Adams, Division of Waste Management and Radiation Control, UDEQ