DSHW-2024-009354

November 21, 2024
Kent Nay, QA Manager, Utah PaperBox
Utah PaperBox Inc.
920 South 700 West
Salt Lake City, UT 84104
RE:Closeout LetterCompliance Evaluation InspectionUTR000015438
Dear Mr. Nay:
On October 29, 2024, representatives of the Division of Waste Management and Radiation Control (Division) conducted a compliance evaluation inspection at your facility. The scope of
the inspection was to determine compliance with the Utah Solid and Hazardous Waste Rules.
The inspectors noted the following compliance issues:
In accordance with Utah Admin. Code R315-262-17(a)(7)(iv) The large quantity generator shall maintain job titles, job descriptions, and descriptions of the type and amount of introductory
and continuing training at the facility.
Utah PaperBox failed to provide the type and amount of introductory and continuing training for job titles at the time of the inspection.
On November 8, 2024, Utah PaperBox provided the type and amount of introductory and continuing training for job titles.
In accordance with Utah Admin. Code R315-262-262(b)(4), The quick reference guide shall include a map of the facility showing where hazardous wastes are generated, accumulated and treated
and routes for accessing these wastes.
Utah PaperBox failed to identify where hazardous wastes are generated, accumulated and treated.
On November 8, 2024, Utah PaperBox provided an updated quick reference guide that included a map of the facility showing where hazardous wastes are generated, accumulated and treated
and routes for accessing these wastes.
In accordance with Utah Admin. Code R315-261-4(a)(26)(i) Solvent-contaminated wipes that are sent for cleaning and reuse are not solid wastes from the point of generation, provided that
when accumulated, stored, and transported, are contained in non-leaking, closed containers that are labeled “Excluded Solvent-Contaminated Wipes”.
Utah PaperBox failed to label the containers holding the solvent-contaminated wipes with a “Excluded Solvent-Contaminated Wipes” label.
On November 1, 2024, Utah PaperBox provided pictures of the containers labeled as “Excluded Solvent-Contaminated Wipes”.
In accordance with Utah Admin. Code R315-273-11(a) A small quantity handler of universal waste is prohibited from disposing of universal waste.
Utah PaperBox failed to collect and ship aerosol cans as universal waste.
On November 8, 2024, Utah PaperBox stated that they had set up accumulation containers and that a contractor had created a waste profile to accept and ship the aerosol cans generated
at the facility.
In accordance with Utah Admin. Code R315-15-2.3(c)(1) Containers and aboveground tanks used to store used oil at generator facilities shall be labeled or naked clearly with the words
“Used Oil”.
Utah PaperBox failed to label containers and aboveground tanks used to store used oil with the words “Used Oil”.
On November 1, 2024, Utah PaperBox provided pictures of their aboveground tanks and containers of used oil labeled with the words “Used Oil”.
As a result of these corrective actions your facility is considered to be in compliance with the applicable rules.
If you have any questions, please contact Jordan Payne by email at [e-mail] or by phone at 385-499-0346.
Sincerely,
Deborah Ng, Manager, Hazardous Waste Program
Division of Waste Management and Radiation Control
DSN/JWP/wa
c:Dorothy Adams, Health Officer, Salt Lake County Health Dept.
Eric Peterson, Deputy Health Officer, Salt Lake County Health Dept.
Ron Lund, Environmental Health Director, Salt Lake County Health Dept.
Kent Nay, QA Manager, Utah PaperBox (Email [e-mail])