Notification Accumulation & Manifesting 1
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 2
Environmental Assistance Center Environmental Assistance Center (EAC) (EAC) 1-800-NO2-WASTE 1-800-NO2-WASTE Phone: Phone: (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 3
Waste Session 2 Waste Session 2 � Generator Requirements for: � Notification � Accumulation � Manifesting 4
Notification Notification Site (EPA) Site (EPA) Identification Number Identification Number 5
Notification of Notification of Regulated Waste Activity Regulated Waste Activity (Rule 303 and Section 12103) (Rule 303 and Section 12103) � Requires submittal of completed Site Identification Form (EQP 5150) 6
Notification of Notification of Regulated Waste Activity Regulated Waste Activity (Rule 303 and Section 12103) (Rule 303 and Section 12103) � Requires payment of a $50 user charge for new/initial or subsequent/updated owner/operator notifications � Notifies DNRE & EPA of: � site owner/operator � site contact � site waste activity 7
Notification of Notification of Regulated Waste Activity Regulated Waste Activity (Rule 303 and Section 12103) (Rule 303 and Section 12103) � Results in issuance of a Site (aka. EPA) Site (aka. EPA) Identification Number Identification Number � Submittal of Site Identification Form required for: � SQGs & LQGs SQGs & LQGs � CESQGs manifesting LIW; CESQGs manifesting LIW; � transportation of hazardous waste and/or LIW transportation of hazardous waste and/or LIW � used oil collection & processing used oil collection & processing � large quantity universal waste handlers large quantity universal waste handlers 8 � generators of generators of ≥ 100 PPM PCB wastes 100 PPM PCB wastes
Notification of Notification of Regulated Waste Activity Regulated Waste Activity (Rule 303 and Section 12103) (Rule 303 and Section 12103) � Subsequent/updated notification filed for changes in site waste activity (e.g. change is generator classification/status) � Request pre-populated Site Identification Form for subsequent/updated notifications from Lansing Manifest Unit at 517-335-2690 9
Notification of Notification of Regulated Waste Activity Regulated Waste Activity (Rule 303 and Section 12103) (Rule 303 and Section 12103) � Expedite form processing by faxing notification & paying on-line with credit card � Liquid industrial waste generators who are not required to manifest wastes are not required to notify 10
Accumulation Accumulation 11
Accumulation Requirements Accumulation Requirements for All Generators for All Generators (Satellite, CESQG, SQG, and LQG) (Satellite, CESQG, SQG, and LQG) � Characterize wastes and maintain records for 3 years from last off-site shipment or on-site treatment and/or disposal � Obtain and utilize Site ID Number if LQG, SQG, or CESQG manifesting waste for disposal � Keep records of all hazardous waste generated, treated and/or disposed on-site � Keep records of HW generated monthly to verify generator status/classification 12
Accumulation Requirements Accumulation Requirements for All Generators for All Generators (Satellite, CESQG, SQG, and LQG) (Satellite, CESQG, SQG, and LQG) � Container or tank accumulation only � Containers/tanks must be compatible with the wastes, closed, and in good condition � Protect waste from weather, physical damage, fire, and vandals � Accumulation conducted to prevent escape of wastes/waste constituents to air, water, sewers or the ground 13
Containers must be in good condition and Containers must be in good condition and compatible with the waste compatible with the waste 14
Note Note corrosive corrosive label label Drums must be Drums must be compatible with compatible with Excessive Excessive the waste! the waste! corrosion corrosion and rust and rust 15
Note Note corrosive corrosive label label Incompatible corrosives in leaking steel drums 16
Excessive rust Excessive rust 17
Danger!! Danger!! Excessive Excessive pressure pressure 18
Dents, broken Dents, broken seams, etc. seams, etc. 19
Containers cannot be exposed to Containers cannot be exposed to weather or vandals weather or vandals 20
Compromised fencing provides access to Compromised fencing provides access to vandals vandals 21
Containers cannot be exposed to Containers cannot be exposed to weather or vandals weather or vandals Good labeling Good labeling Good containers Good containers Closed containers Closed containers No weather protection No weather protection Accessible to vandals Accessible to vandals No containment No containment 22
Container must be stored to prevent physical damage Unsafe pallets Unsafe pallets Stacked too high Stacked too high Inadequate aisle space Inadequate aisle space 23
Drums must be stored closed! Drums must be stored closed! (solids and liquids) (solids and liquids) 24
Best option is to close containers manually! Best option is to close containers manually! 25
Drum bung in place Drum bung in place 26
Funnels must allow for closure of the container Funnels must allow for closure of the container to prevent emissions and spillage to prevent emissions and spillage Notice the Notice the splashing on splashing on wall wall 27
Funnel is Funnel is removed removed Bung is Bung is replaced replaced 28
Notice the Notice the valve? valve? If kept closed it If kept closed it would be OK would be OK 29
Lidded funnel Lidded funnel Ball valve must Ball valve must be cl be closed osed 30
revent the escape of Accumulation must pre waste to the enviro ronment 31
CESQG Exemption Records CESQG Exemption Records (Section 11138 & Rules 205, 302 & 307) (Section 11138 & Rules 205, 302 & 307) Records required to be maintained for 3 years to verify the CESQG exemption: See DNRE Publication G Guidance ce Center CESQG � Waste characterizations � Monthly waste volumes (show generate < 220 lbs per month) � Manifests and/or disposal receipts/logs showing proper disposal of CESQG wastes 32 under Parts 31, 121, 115
CESQG Exemption Requirements CESQG Exemption Requirements (0 - (0 - < 220 lbs/mo) 220 lbs/mo) � Must get Site/EPA ID number to manifest liquids, solids exempt OT O NOT � Must generate < 220 lbs/mo EXCEED!! DO � No accumulation time limit � Maximum volume < 2200 lbs � CESQG’s ≥ 2200 lbs are SQG � No user fees 33
CESQG Disposal Options CESQG Disposal Options (0 - (0 - < 220 lbs/mo) 220 lbs/mo) � Licensed Hazardous Waste Facility � Licensed Solid Waste Facility (solids only, no liquids) � Facility that will recycle or arrange for recycling � Off-site or on-site WWTP if in compliance with pre-treatment rules 34
Additional SQG & LQG Additional SQG & LQG Accumulation Requirements Accumulation Requirements See DNRE Publication See DNRE Publication � Date and Label Containers Center SQG Guidanc Center SQG Guidance � 90/180 day accumulation limit (LQG/SQG) (LQG/SQG) � Subpart AA, BB, CC (LQG) (LQG) � Provide secondary containment (LQG/SQG > 2200 lbs) (LQG/SQG > 2200 lbs) � Provide proper training � Prepare emergency response plans � Conduct frequent inspections � Use licensed hazardous waste disposal sites � Follow preparedness and prevention rules � File a Biennial Report every 2 years (LQG) (LQG) 35
Hazardous Waste Hazardous Waste Accumulation Label Accumulation Label 36
Date by day, not month 37 (mm/dd/year)
Hazardous Waste Hazardous Waste Shipping Label Shipping Label 38
Hazardous Hazardous Waste Shipping Waste Shipping Labels Labels 39
Satellite Satellite Containers ontainers (Rule 306(2)) (Rule 306(2)) � Container must be at, or near, point of generation and under operator control � Label at start of filling with “HAZARDOUS WASTE” AND waste code number OR chemical name � Label when filled or total volume exceeds 55 gallons (1 quart for acute wastes) with accumulation date 40
Satellite Satellite Containers ontainers (Rule 306(2)) (Rule 306(2)) � Move container to accumulation area within 3 days of accumulation date � Fill date = accumulation date � See Op Memo 111-2 for more information 41
Satellite Label Example Satellite abel Example 42
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