[PPT] - What Type of Wastes Do I Generate? 1 Michigan Environmental PowerPoint Presentation

SLIDE 1

1

What Type of Wastes Do I Generate?

SLIDE 2

2

Michigan Environmental Michigan Environmental Compliance Conference Compliance Conference

Christine Grossman Christine Grossman Compliance Assistance Specialist Compliance Assistance Specialist Waste Regulations Waste Regulations grossmanc@michigan.gov grossmanc@michigan.gov 517-373-0590 517-373-0590

SLIDE 3

3

Environmental Assistance Center Environmental Assistance Center

(EAC) (EAC) Phone: Phone:

1-800-NO2-WASTE 1-800-NO2-WASTE

(1-800-662-9278) Hours: Hours: 8:00 a.m. to 5:00 p.m. Monday through Friday Technical Assistance Services Include: Technical Assistance Services Include: Air Shoreline Development Waste Brownfield Redevelopment Water Site Remediation Wetlands Storage Tanks

SLIDE 4

4

Waste Session 1 Waste Session 1

Characterizing Your Waste Identifying Hazardous Waste Exclusions Determining Your Hazardous Waste

Generator Status

SLIDE 5

5

Why Do the Hazardous Waste Why Do the Hazardous Waste Regulations Exist? Regulations Exist?

Prevent Excessive Accumulation Prevent Excessive Accumulation

SLIDE 6

6

Prevent Illegal Prevent Illegal Disposal Disposal

Why Do the Hazardous Waste Why Do the Hazardous Waste Regulations Exist? Regulations Exist?

SLIDE 7

7

Prevent Environmental Prevent Environmental Contamination Contamination

Why Do the Hazardous Waste Why Do the Hazardous Waste Regulations Exist? Regulations Exist?

SLIDE 8

8

Prevent Prevent Community Community Emergencies Emergencies

Why Do the Hazardous Waste Why Do the Hazardous Waste Regulations Exist? Regulations Exist?

SLIDE 9

9

Hazardous waste regulations. . .

Apply to all businesses, including

municipalities, hospitals, and service industries, not just manufacturing industries

Are written broadly to address hazards

posed by all waste streams

Why Cover These Topics? Why Cover These Topics?

SLIDE 10

10

Hazardous waste regulations require each business, by site, to . . .

Evaluate the character and composition of

their wastes

Determine the total weight of all hazardous

waste generated each month on a continuous basis

Why Cover These Topics? Why Cover These Topics?

SLIDE 11

11

Hazardous waste regulations require each business, by site, to . . .

Based on the amount and types of

hazardous waste generated each month, the business is required to determine the legal disposal options

Less hazardous waste = less regulation and

more disposal options under the law

Why Cover These Topics? Why Cover These Topics?

SLIDE 12

12

Hazardous waste regulations require each

business, by site, to customize their

waste program to meet their site specific business needs

There is no 1 best answer for how to

dispose of waste for all businesses and all locations

Each business location must evaluate and

select their own preferred disposal options based on their facility circumstances

Why Cover These Topics? Why Cover These Topics?

SLIDE 13

13

Site specific disposal needs will vary based on:

Type of hazardous wastes generated

Amount of hazardous wastes generated

Regulatory disposal options

Proximity of disposal facilities

Cost of disposal

On-site “real-estate”

On-site “real-estate” for sorting, storing, treating for sorting, storing, treating

On-site disposal options (POTW?)

Waste hazards

Employee culture (trainability)

Why Cover These Topics? Why Cover These Topics?

SLIDE 14

14

Waste Waste Characterization Characterization

SLIDE 15

15

What Regulations Require Waste What Regulations Require Waste Characterization? Characterization?

Act 451, Michigan Natural Resource and

Act 451, Michigan Natural Resource and Environmental Protection Act Environmental Protection Act

Part 111, Hazardous Waste Part 121, Liquid Industrial Waste Part 115, Solid Waste Part 169, Scrap Tires

Act 368, Michigan Public Health Code

Part 138, Medical Waste Regulatory Act Part 2 Ionizing Radiation Rules

Federal Toxic Substance Control Act

SLIDE 16

16

Waste Characterization Waste Characterization Regulatory Overview Regulatory Overview

Waste Waste Liquid Liquid Industrial Industrial Hazardous Hazardous Solid Solid Non-hazardous Non-hazardous Subject unless excluded: Subject unless excluded:

Hazardous if listed or characteristic

Hazardous if listed or characteristic

Liquid industrial if free liquids

Liquid industrial if free liquids

SLIDE 17

17

Waste Characterization Waste Characterization Where Do I Start? Where Do I Start?

Perform a waste survey to identify what

wastes are generated at your facility

Tour your entire facility and inventory all

waste streams

Don’t overlook identifying and

characterizing ALL waste streams

See DNRE E Publication Center Waste Chara racterization Guidance

SLIDE 18

18

Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams

Drains catch spills Look outside and inside… including discontinued work areas

SLIDE 19

19

Heavy Metals

Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams

Look at office and maintenance activities Batteries Electronics

SLIDE 20

20

Electric lamps Look at office and maintenance activities

Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams

Mercury Thermostats

SLIDE 21

21

Look at aerosol cans Ignitable May have TLCP issues Can crushing & puncturing

Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams

SLIDE 22

22

Look at remodeling/demolition waste Lead Paint

Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams

Demolition Waste Gym Floors Heavy Metals

See ee DNRE June e 20, 1999 9 Abr brasive e Blasting Memo

SLIDE 23

23

Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams

Carpet Cleaning Power Washing Look at wastewaters from cleaning operations

SLIDE 24

24

Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams

Look at waste from fleet maintenance operations Antifreeze & Mercury Switches

Ignitable & TCLP issues

Used Oil Degreasing

SLIDE 25

25

Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams

Look at waste from painting Ignitable & TCLP issues

SLIDE 26

26

Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams

Look at rags and textiles Ignitable, TCLP, and/or F-listed issues

SLIDE 27

27

Look at laboratory wastes Ignitable, Corrosive, Reactive, TCLP, and listed waste issues

Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams

SLIDE 28

28

Who Does the Who Does the Waste Characterization? Waste Characterization?

Do the waste characterization

yourself

Hire a consultant Use the disposal company services Use a combination of the above

SLIDE 29

29

To properly comply with the regulations, To properly comply with the regulations, busi businesses must determine if their wastes nesses must determine if their wastes are hazardous or non- are hazardous or non- hazardous hazardous

Knowledge : Testing :

MSDS Facility Process Information Technical Information Manufacturer Information Hazardous Waste Listings Other Lab Results

How Do You Characterize? How Do You Characterize?

(Rules 202, 203, and 302) (Rules 202, 203, and 302)

SLIDE 30

30

How Do You Characterize? How Do You Characterize?

What is a Hazardous Waste? What is a Hazardous Waste?

Listed Hazardous Waste

Common waste stream known to be hazardous without testing

Characteristic Hazardous Waste

Waste stream found to be ignitable, corrosive, reactive, and/or toxic due to the characteristics or composition of the waste via testing

SLIDE 31

31

Hazardous Waste Mixture Rule

Hazardous Waste Mixture Rule Mixture of a listed listed hazardous waste with

ther non-hazardous wastes is a listed

hazardous waste

Hazardous Waste Derived From Rule

Hazardous Waste Derived From Rule Residues derived from treating a listed listed hazardous waste is listed hazardous waste

How Do You Characterize? How Do You Characterize?

SLIDE 32

32

Recommendation Recommendation

Do not mix listed hazardous waste Do not mix listed hazardous waste with other wastes to minimize: with other wastes to minimize:

volume of hazardous waste generated

number of regulations that apply

disposal costs

SLIDE 33

33

Waste Stream Characterization Waste Stream Characterization Basic Steps Basic Steps

1st

st STEP

STEP – Review if waste is a listed listed waste by reviewing lists of waste types & codes in the rules & considering whether mixture or derived from rules apply, or if it is media impacted by listed hazardous waste 2nd

nd STEP

STEP – Review if waste is a characteristic characteristic hazardous waste by testing or relying on knowledge 3rd

rd STEP

STEP – Review if a hazardous waste exclusion exclusion

r exemption applies to waste

SLIDE 34

34

4th

th STEP

STEP – Determine if other regulations

ther regulations apply

(liquid industrial, solid waste, tire, etc.) 5th

th STEP

STEP - Create and maintain records records of characterization for not less than 3 years from the date the waste was last shipped off-site or treated and/or disposed on-site 6th

th STEP

STEP – Re-characterize Re-characterize whenever there is a process or materials change

Waste Stream Characterization Waste Stream Characterization Basic Steps Basic Steps

SLIDE 35

35

F Codes

F Codes (Table 203a) – Common wastes from a non-specific sources

(e.g. spent chlorinated solvents, wastewater & metal treatment sludges)

K Codes

K Codes (Table 204a) – Wastes from specific industries - includes some Michigan only codes

(e.g. petroleum refining and wood treatment wastes)

Step 1 – Step 1 – Review Review Listed Hazardous Waste Codes Listed Hazardous Waste Codes

SLIDE 36

36

P & U Codes

P & U Codes (Table 205a-c): Commercial chemical products, off- specification products, container & spill residues - includes some Michigan only U codes

(e.g. formaldehyde, parathion, benzene, DDT, xylene)

P Codes are all acutely hazardous

Step 1 – Step 1 – Review if Review if Listed Hazardous Waste Listed Hazardous Waste

SLIDE 37

37

Acutely Acutely hazardous hazardous when “H” when “H” hazard hazard code code included included

How to Look-Up Listed Hazardous Waste Codes

SLIDE 38

38

Step 2 – Step 2 – Review if Characteristic eview if Characteristic Hazardous Waste Hazardous Waste

Characteristic Hazardous Waste Codes: Characteristic Hazardous Waste Codes:

Ignitable - D001 Corrosive - D002 Reactive - D003 Toxic - D004 – D043 (Table 201a) Severely Toxic – 001S - 007S

(Table 202, includes dioxins & furans)

SLIDE 39

39

Characteristic Hazardous Waste Characteristic Hazardous Waste Common Tests Common Tests

Flash point

Flash point – Used for testing Ignitability < 140 F (D001)

Examples: paints, solvents

pH

pH – Used for testing corrosivity ≤ 2 or ≥ 12.5 (D002)

Examples: acids, bases

Reactivity

Reactivity – Test as required for DOT classification for materials that are unstable at normal conditions, reacts violently with water, explode, and/or emit toxic gas (D003)

Examples: lithium hydride & trichlorosilane

SLIDE 40

40

TCLP

TCLP (Toxicity Characteristic Leaching (Toxicity Characteristic Leaching Procedure) Procedure) - Used for testing leaching potential for Table 201a hazardous constituents (D004-D043)

Examples: Paints or sludges containing metals or MEK, contaminated media

Total Halogens

Total Halogens - Used for testing used oils for chlorine, fluorine, bromine, etc. to determine if a “presumed” hazardous waste

Characteristic Hazardous Waste Characteristic Hazardous Waste Common Tests Common Tests

SLIDE 41

41

Common Exemptions and Exclusions

SLIDE 42

42

Step 3 - Step 3 - Review if Exemption eview if Exemption

r Exclusion Applies
r Exclusion Applies

(Rules 202, 203, 204, 206, 207 and 228 of Part 111 111 -not all inclusive)

Some, but not all, materials being recycled

may be excluded (see 40 CFR, Part 261 of RCRA, specifically 261.2, Table 1)

Wastewater discharges to POTW’s that are

approved pproved by that sewer authority are exempted at the point of discharge to the sewer (management prior to discharge may be subject to regulation)

SLIDE 43

43

(Rules 202, 203, 204, 206, and 228 of Part 111 – (Rules 202, 203, 204, 206, and 228 of Part 111 – not all inclusive) not all inclusive)

Review Exemptions & Exclusions Review Exemptions & Exclusions

Universal waste rule allows alternative

handling for specified waste types (batteries, pesticides, mercury devices, electric lamps, pharmaceuticals, consumer electronics and antifreeze)

Wastes that are used or reused in a process

to make a product are excluded provided there is no reclamation - Beware of sham

recycling and get DNRE concurrence on exemption & supporting documentations required

SLIDE 44

44

Laboratory samples are exempt from many

regulations until determined to be a hazardous waste

Used oils that are recycled Scrap metal (pieces of metal) that are

recycled

Review Exemptions & Exclusions Review Exemptions & Exclusions

(Rules 202, 203, 204, 206, 207 and 228 of Part 111 – not all inclusive inclusive)

SLIDE 45

45

Petroleum contaminated media (soils,

groundwater) from leaking UST systems that fail the TCLP for D018 – D043 only and are being remediated under DNRE approval pursuant to Part 213

Off-specification fuel (gasoline, kerosene,

diesel, etc) being recycled for use as fuel or burned as fuel

(Rules 202, 203, 204, 206, 207 and 228 of Part 111 – not all inclusive inclusive)

Review Exemptions & Exclusions Review Exemptions & Exclusions

SLIDE 46

46

Materials remaining in manufacturing units

that would otherwise be hazardous wastes - if taken out of service the material becomes a hazardous waste (degreasers, paint pots)

Properly drained non-terne used oil filters that

have not been mixed with listed hazardous waste

Laundered rags that are reused that would

therwise be hazardous waste

(Rules 202, 203, 204, 206, 207 and 228 of Part 111 – not all inclusive inclusive)

Review Exemptions & Exclusions Review Exemptions & Exclusions

SLIDE 47

47

Hazardous wastes from which precious

metals are recovered (partial exemption)

Dredge spoils from projects permitted by

the U.S. Army Corps of Engineers or DNRE

Used chlorofluorocarbon refrigerants from

heat transfer equipment provided they are reclaimed for further use

(Rules 202, 203, 204, 206, (Rules 202, 203, 204, 206, 207 and 228 of Part 111 – 207 and 228 of Part 111 – not all inclusive) not all inclusive)

Review Exemptions & Exclusions Review Exemptions & Exclusions

SLIDE 48

48

Wastes generated by households, including

single and multiple residents, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day-use recreational areas

Residues in containers are

excluded if empty

(Rules 202, 203, 204, 206, (Rules 202, 203, 204, 206, 207 and 228 of Part 111 – 207 and 228 of Part 111 – not all inclusive) not all inclusive)

Review Exemptions & Exclusions Review Exemptions & Exclusions

See DNRE P Publication Center Empty ty Conta tainers Guidance

SLIDE 49

49

After all non-acute hazardous waste non-acute hazardous waste

r liquid industrial waste has been

removed using common practices:

No more than 1 inch or not more than 3.0%

the weight of the capacity of the container for containers less ≤ to 119 gallons in size

No more than 1 inch or not more than 0.3%

the weight of the capacity of the container for containers > than 119 gallons in size

Empty Containers Empty Containers

(Rule 207) (Rule 207)

SLIDE 50

50

Acute Hazardous or Severely Toxic Waste:

Triple rinse with appropriate solvent or

cleaned by proven equivalent method

Remove inner liner that prevented contact

with container

If listed due to characteristic, empty if no

longer exhibits the characteristic

Rinse water/removed residue would be

hazardous waste based on knowledge

Empty Containers Empty Containers

(Rule 207) (Rule 207)

SLIDE 51

51

Compressed Gas:

Container pressure is equal to

atmospheric pressure

Container is not clogged No audible liquids in container when

shaken

Empty Containers Empty Containers

(Rule 207) (Rule 207)

SLIDE 52

52

CESQG hazardous wastes are exempt if :

Monthly hazardous waste generation < 220 lbs Total hazardous waste accumulation always

< 2200 pounds

Wastes are properly disposed under other

regulations

Records of waste characterization and

generator status are maintained for 3 years

PARTIAL PARTIAL EXEMPTION EXEMPTION

Conditionally Exempt Small Quantity Conditionally Exempt Small Quantity Generator (CESQGs) (Rule 205) Generator (CESQGs) (Rule 205)

SLIDE 53

53

No exclusions for 1 time or periodic events

that change generators status

Establish procedures to limit or prevent

1 time or periodic changes in generator status/classification

Be prepared to meet higher regulatory

requirements for events changing generator status/classification

Review Exemptions & Exclusions Review Exemptions & Exclusions

SLIDE 54

54

Review Exemptions & Exclusions Review Exemptions & Exclusions

(Rule 202(5)) (Rule 202(5))

Any claim that a material is not a

waste or is exempt from hazardous waste regulation must be demonstrated by the generator

Where exemption is questionable,

seek concurrence with hazardous waste regulatory staff

SLIDE 55

55

Step 4 – Step 4 – Review if Other eview if Other Regulations Apply Regulations Apply

Act 451, Michigan Natural Resource and

Act 451, Michigan Natural Resource and Environmental Protection Act Environmental Protection Act

Part 111, Hazardous Waste

Part 121, Liquid Industrial Waste Part 115, Solid Waste Part 169, Scrap Tires

Act 368, Michigan Public Health Code

Part 138, Medical Waste Regulatory Act Part 2 Ionizing Radiation Rules

Federal Toxic Substance Control Act

SLIDE 56

56

Review if Review if Liquid Industrial Waste? Liquid Industrial Waste?

Determined using the Paint Filter Test,

Method 9095 in EPA SW-846

Includes liquid wastes from other locations

besides “industrial” sites (e.g. municipal, health care facilities, etc.)

SLIDE 57

57

Includes liquid CESQG hazardous wastes

conditionally excluded from hazardous waste manifest & disposal at a licensed hazardous waste disposal facility

Rule of thumb – if there are any free liquids

in the waste or if the waste is thinner than butter at or below 100 F, it should be managed as a liquid industrial waste

How to Determine How to Determine Liquid Industrial Waste? Liquid Industrial Waste?

61 61

SLIDE 58

58

Common Liquid Industrial Common Liquid Industrial Waste Examples Waste Examples

Most antifreeze Some wastewater including most mobile

power washing wastewater, carpet cleaning wastewater, food processing wastewaters

Most sludges from trench drains or blind

sumps (unless there’s been a release making it a hazardous waste)

SLIDE 59

59

Storm sewer cleanout waste Grease trap waste Most used oils being recycled Off-specification fuels being recycled

Common Liquid Industrial Common Liquid Industrial Waste Examples Waste Examples

SLIDE 60

60

Liquid Industrial Waste Codes Liquid Industrial Waste Codes (Uniform Manifest Instructions) (Uniform Manifest Instructions)

SLIDE 61

61

Waste Characterization Waste Characterization Other Regulations Other Regulations

Act 451, Michigan Natural Resource and

Act 451, Michigan Natural Resource and Environmental Protection Act Environmental Protection Act

Part 111, Hazardous Waste Part 121, Liquid Industrial Waste

Part 115, Solid Waste Part 169, Scrap Tires

Act 368, Michigan Public Health Code

Part 138, Medical Waste Regulatory Act Part 2 Ionizing Radiation Rules

Federal Toxic Substance Control Act

SLIDE 62

62

Review Part 115 Solid Waste Review Part 115 Solid Waste Requirements & Banned Items Requirements & Banned Items

(Section 11514) (Section 11514)

Solid waste landfill banned items Solid waste landfill banned items generally recycled: generally recycled:

Used oil Lead acid batteries Returnable beverage containers Yard clippings/compost Empty drums unless crushed

SLIDE 63

63

Solid waste landfill banned items Solid waste landfill banned items generally disposed under other generally disposed under other regulations or burned for energy: regulations or burned for energy:

Whole tires

Regul

Regulated hazardous waste ted hazardous waste

Liquid industrial waste

Radioactive waste

Asbestos wa

bestos waste unless the landfil ste unless the landfill meets federal regulations meets federal regulations

Medical waste unless decontaminated

PCB waste as defined in federal regulations

B waste as defined in federal regulations

Sewage unl

Sewage unless specifical ss specifically authorized ly authorized

Part 115 Solid Wastes Part 115 Solid Wastes Banned from Landfills Banned from Landfills

(Section 11514) (Section 11514)

SLIDE 64

64

Talk to your landfill to determine what

they accept

Seek waste vendor or DNRE assistance

for more information on recycling or disposal options

To send solid waste out of county, the

destination location must be designated in the County Solid Waste Plan

Review Part 115 Review Part 115 Solid Waste Requirements Solid Waste Requirements

SLIDE 65

65

Step 5 – Step 5 – Create & Maintain Waste reate & Maintain Waste Characterization Record Characterization Record

(Rule 307) (Rule 307)

Records for Records for each each waste stream may waste stream may include: include:

Waste type/description Source of waste Test results Waste analyses records MSDS Sample procedure Representative sample information

SLIDE 66

66

Re-characterize whenever there is a process or material change

Step 6 – Step 6 – Re-characterize e-characterize

SLIDE 67

67

Waste Characterization Waste Characterization Highlights Highlights

Without proper waste characterization, it is

impossible to comply with the hazardous waste regulations

A waste survey is recommended to identify

all wastes being generated at a facility

It is recommended that all records be kept

together in a file for easy access in the event

f a DNRE/EPA inspection

SLIDE 68

68

Wastes can be classified as either

hazardous or non-hazardous via knowledge and/or actual analytical methods

Whether using knowledge and/or actual

analysis, proper record keeping is required and records must be retained for at least three years

Waste Characterization Waste Characterization Highlights Highlights

SLIDE 69

69

Is waste listed or characteristic hazardous waste? No No Does a Part 111 exemption apply? Yes Yes Manage as Part 111 hazardous waste Does waste fail the paint filter test? Yes No Manage as Part 121 liquid industrial waste Manage as Part 115 solid waste

Waste Characterization Flow Chart

Flow chart does not apply to medical, PCB, radiological, or asbestos wastes.

SLIDE 70

70

Determining Hazardous Waste Generator Status

SLIDE 71

71

Once you know what wastes are Once you know what wastes are hazardous or non-hazardous, hazardous or non-hazardous, including what is exempted or including what is exempted or excluded, you must determine excluded, you must determine where you fall within the regulations where you fall within the regulations

Generator Generator Status Status

SLIDE 72

72

1st

st STEP

STEP – Calculate total amount of hazardous waste generated in the month 2nd

nd STEP

STEP – Review total amount of hazardous waste accumulated at any time during the month 3rd

rd STEP

STEP – Compare amount generated and maximum accumulated to the limits in the rule to determine generator status and corresponding disposal requirements

Determining Generator Status Determining Generator Status Basic Steps Basic Steps

SLIDE 73

73

Add up ALL the hazardous waste generated

at the site in a calendar month

Calculate amounts per site One site is under one identification number

and is contiguous property

Step 1 - Step 1 - Calculating Amount of alculating Amount of Hazardous Waste Generated Hazardous Waste Generated

SLIDE 74

74

Calculate the amount in pounds or kilograms Calculate the amount generated, not the

amount shipped

Include hazardous waste treated and/or

disposed on-site unless it is hard piped to POTW

Step 1 - Step 1 - Calculating Amount of alculating Amount of Hazardous Waste Generated Hazardous Waste Generated

SLIDE 75

75

Do not include hazardous waste managed

as a universal waste

Do not include waste specifically excluded

from Part 111 (scrap metal being recycled, fuel

being recycled, or POTW approved direct discharges)

Do not include liquid industrial waste Do not include used oil

Step 1 - Step 1 - Calculating Amount of alculating Amount of Hazardous Waste Generated Hazardous Waste Generated

SLIDE 76

76

Review total/maximum amount of

hazardous waste accumulated at any 1 time during the month

Compare amount of hazardous waste

generated and total accumulated during the month to the CESQG, SQG, and LQG definitions/limits

Generator limits are found in Rule 306 of

the Part 111 rules

Steps 2 & 3 – Steps 2 & 3 – Determining etermining Generator Status Generator Status

SLIDE 77

77

Determining Determining Generator Status Generator Status

Specific requirement that apply are based

n the volume of hazardous waste

generated monthly and the total amount of hazardous waste accumulated at 1 time

The more waste generated monthly or the

more waste stored at any 1 time, the more regulatory requirements a facility must meet

SLIDE 78

78

Conditionally Exempt Small Quantity Generator (CESQG) Conditionally Exempt Small Quantity Generator (CESQG)

Generates < 220 pounds of non-acute* HW per month Never accumulates 2200 pounds or more

Small Quantity Generator (SQG) Small Quantity Generator (SQG)

Generates 220 to < 2200 pounds non-acute* HW per month Never accumulates 13,200 pounds, or for more than 180 days

r 270 days if shipping > 200 miles

Large Quantity Generator (LQG) Large Quantity Generator (LQG)

Specific Requirements Depend on the Specific Requirements Depend on the Hazardous Waste Generator Status Hazardous Waste Generator Status

Generates ≥ 2200 pounds non-acute* HW per month or Generates and accumulates 2.2 pounds acute hazardous or severely toxic HW per month Never accumulates wastes > 90 days

*Acute HW and severely toxic HW action level is 2.2 lbs per month for CESQG, SQG, and LQG. Subject to LQG requirements

All volumes are cumulative on All volumes are cumulative on a site wide basis and must be a site wide basis and must be counted at the point of initial management counted at the point of initial management

Less Regulation More Regulation

SLIDE 79

79

Do not mix listed hazardous wastes with

ther waste to minimize hazardous waste

volumes

Do not accumulate volumes of hazardous

waste that will cause you to be subject to additional regulations and management requirements

Determining Determining Generator Status Generator Status

SLIDE 80

80

Perform generator calculations on the first

day of each month

Add-up the weight of all full hazardous waste

containers placed into storage during the previous month (use accumulation date)

Add to the weight of all the waste in satellite

containers that are currently accumulating hazardous waste near the point of generation

Simple “How To” Simple “How To” Calculate Hazardous alculate Hazardous Waste Generated In a Month Waste Generated In a Month

SLIDE 81

81

Subtract from this amount the weight of the

prior month’s satellite containers

That should give the monthly generation rate

if there were no shipments directly from the equipment or a satellite accumulation area during the prior month.

Maintaining a running log of waste containers

put into service and their contents at the beginning of each month is an easy way to document generation rates.

Simple “How To” Simple “How To” Calculate Hazardous alculate Hazardous Waste Generated In a Month Waste Generated In a Month

SLIDE 82

82

A waste inventorying system that tracks the A waste inventorying system that tracks the amount of hazardous waste generated amount of hazardous waste generated monthly is necessary to continuously monthly is necessary to continuously evaluate your hazardous waste generator evaluate your hazardous waste generator status and determine your disposal options status and determine your disposal options

Determining Generator Status

SLIDE 83

83

Hazardous wastes managed using the universal

waste standards are not included in the monthly hazardous waste volume for determining generator status and can be used to reduce your generator status – USE THEM!!!

Use all possible exemptions and alternate

materials that are less toxic to minimize you hazardous waste volumes, minimize your regulatory burden, and ultimately minimize your compliance and disposal costs

Techniques For Minimizing the Volume of Hazardous Waste Generated Monthly

SLIDE 84

84

Techniques For Minimizing the Volume of Hazardous Waste Generated Monthly

Use materials as long as possible before

removing them from equipment

Confirm all equipment generating hazardous

wastes are used/needed or get rid of them (e.g. obsolete degreasing units, paints, etc.)

Bleed-off a portion of the process materials

and add an equivalent volume of virgin material for continued operation instead of removing the entire volume of a material

SLIDE 85

85

Reuse materials a second time in a second

process/operation without reclaiming

Engineer your process to allow for hard piping

through approved discharge to the POTW

Routinely review product inventories and purge

expired materials

Use less hazardous materials where possible

(e.g. powder versus solvent coatings)

Techniques For Minimizing the Volume of Hazardous Waste Generated Monthly

SLIDE 86

86

How Do I Manage the Following Wastes To Minimize Hazardous Waste Generator Status

Solvent Rags Scrap Metals Off-Specification Fuels Consumer Electronics Electric Lamps Pharmaceuticals Batteries Antifreeze Mercury Devices

SLIDE 87

87

Recycle

Solvent Rags Scrap Metals Off-Specification Fuels

Universal Waste

Consumer Electronics Electric Lamps Pharmaceuticals Batteries Antifreeze Mercury Devices

How Do I Manage the Following Wastes To Minimize Hazardous Waste Generator Status

SLIDE 88

88

Need Help? Need Help?

Go to www.michigan.gov/dnrewaste Contact the DNRE EAC at 1-800-662-9278 Search the DNRE Publication Center Contact DNRE district waste inspection staff Contact hazardous waste vendors Contact waste consultants