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HomeMy WebLinkAboutDSHW-2024-008891Registration and Permitting of Used Oil Handlers (R315-15-13) David Wheeler, Environmental Scientist (385) 499-0683 dswheeler@utah.gov Registration and Permitting of Used Oil Handlers R315-15-13 Utah requires a person/company to apply for and obtain a used oil permit or registration prior to performing certain used oil activities. Who needs to submit an application? The following folks are required to obtain a permit or registration: Permits: Used Oil Transporters Used Oil Transfer Facilities Used Oil Processors/Re-refiners Off-specification Used Oil Burners Registrations: Used Oil Collection Centers (UOCCs) Used Oil Marketers Applications The forms are relatively self-explanatory but must be accurate and complete and accompanied with the application fee(s) as follows: Applicants are also charged for staff review time of the permits and marketer registration, so it pays to submit applications which are complete and accurate. Permits:$200 per permit Marketer Registration:$150 per registration UOCC Registration:free Permit Application Forms Permit and registration application forms are found on our web page at: https://deq.utah.gov/waste-management-and-radiation-control/for ms-division-of-waste-management-and-radiation-control#used-oil Notification Used oil marketers, transporters, transfer facilities, processors/re-refiners, and off-specification burners must obtain an EPA Identification number. Kaci Mcneill at DEQ can help you with this: (385) 454-5459 kmcneill1@utah.gov Things you should know Common questions & pitfalls Plan ahead. Even in the best case scenario, used oil permitting is a lengthy process lasting over a month. There is a 15-day comment period, financial assurance documents to obtain with your financial institutions, etc. Don’t wait until the last minute. How long will it take? Depends on the type of permit, staff workloads, and how complete and accurate the submitted application is. Common permitting questions & pitfalls (cont.) If you have questions, ask us rather than guessing. If you submit complete & accurate information, it speeds things up. Even small “issues” can delay things because resubmissions need to be officially logged in, etc. Common permitting questions & pitfalls (cont.) Get your financial information lined up as soon as possible. Obtaining the required, properly worded forms can be time consuming. Financial institutions sometimes resist the required language, so it is good to get this set up as quickly as possible. For help, call: Brent Gaschler: Phone: (385) 454-5330 Email: brgaschler@utah.gov Common permitting questions & pitfalls (cont.) Closure Plan. [Only required for transfer facility, processor, and off-specification burner permits.] The closure plan is a complicated document with itemized closure costs and third-party quotes that can cause delay. Common permitting questions & pitfalls (cont.) Use your legal business name. Make sure the name on the application form exactly matches the company’s legal name, as shown on the Utah Department of Commerce’s Utah Business Search. That includes commas and periods. For example, if the legal name is: Acme Inc. don’t submit an application with any of the following variations: Acme Inc ← missing period Acme, Inc.← added comma Acme ← missing “Inc.” Acme, LLC ← “LLC” rather than “Inc.” Avoid the use of DBAs because they are not legally legitimate. Used Oil Handler Certificates Used oil permittees and marketers are issued a used oil handler certificate with a new permit. This certificate must be renewed annually. It is the responsibility of these handlers to renew these certificates by December 31 of each year. Please do so in a timely manner, preferably in early December. Permittees are required to pay a fee of $100.00 per permit certificate. Used oil marketers must pay $50.00 per registration certificate. Used Oil Handler Certificates (cont.) I am currently the person who administers this annual renewal. We try to send out a courtesy reminder email every year before December to a list of handler certificate contacts on file, but this contact info changes as people retire, move on, or get different emails. If you wish to continue to receive these reminders, please let me know of any changes to this contact information. ➸ Again, it is the responsibility of the used oil handlers to renew these certificates by December 31 of each year irrespective of receiving a reminder. If you follow the described steps, you get a lovely handler certificate like this. Permit by Rule for (Certain) Transporters R315-15-13.4(f) In certain, limited scenarios, generators who self-transport used oil from their own vehicles to a central collection facility in quantities exceeding 55 gallons do not need to apply for a used oil transporter permit. If they meet the conditions in R315-15-13.4(f), the permit is, in a sense, assumed, saving these folks the time and expense of the full permit application process. Permit by Rule for Transporters (cont.) One needs to read R315-15-13.4(f) closely to see if they qualify, but the simplified general criteria for the transporter permit by rule are these: 1. The used oil is transported in the generator’s own vehicles. 2. The generator submits a written notification to the Director of their intent to operate under R315-15-13.4(f). 3. The generator's facility is defined under an NAICS code of 21 (Mining), 22 (Utilities), 23 (Construction), 485111 (Mixed Mode Transit Systems), or 541360 (Geophysical Surveying and Mapping Services). Permit by Rule for Transporters (cont.) 4. The generator self-transports and delivers the used oil to their own facility. 5. The generator notifies the Director with the information required by R315-15-13.4(b)(1) through (10). [This is a portion of the information submitted by regular used oil transporters applying for a permit.] Permit by Rule for Transporters (cont.) 6. The generator complies with, R315-15-4.3, R315-15-4.4(b) through (d), R315-15-4.6(b) through (f), R315-15-4.7(b) and (d), and R315-15-4.8 ➤Obtain/update their EPA Identification Number. ➤Follow DOT requirements, follow the spill rules, label their vehicles with the words “Used Oil.” ➤Store used oil in appropriate and labeled units with secondary containment. ➤Track their loads like a transporter. ➤Manage their residues appropriately. Permit by Rule for Transfer Facilities A Permit by Rule transporter is also allowed to store the used oil it transports to its facility and therefore act as Permit by Rule transfer facility under the following conditions: 1.The oil is stored for less than 35 days (otherwise must get a processor permit!), or 2.The oil has been certified by a used oil marketer to be on-specification and is being burned by the Permit by Rule facility (in which case the oil is regulated as a fuel). Permit by Rule for Transporters/Transfer Facilities (cont.) There are additional requirements on Permit by Rule transporters and transfer facilities who burn the oil they self-transport, including registering as a used oil marketer. Permit Modifications Permittees need to notify the Division of any changes in information affecting their permit. 1.Minor changes (contact information, mailing addresses, etc.): The permittee needs to notify the director within 20 days of those changes. 2.Major changes (addition of tanks or storage capacity, new type of vehicles, new process, etc.): The permittee needs to request a modification to the permit prior to implementing the change. The permittee may not make that change until the Director approves the modification and issues a modified permit. δ Δ Questions?