What Type of Wastes Do I Generate? 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 1 Waste Session 1 � Characterizing Your Waste � Identifying Hazardous Waste Exclusions � Determining Your Hazardous Waste Generator Status 4
Why Do the Hazardous Waste Why Do the Hazardous Waste Regulations Exist? Regulations Exist? Prevent Excessive Accumulation Prevent Excessive Accumulation 5
Why Do the Hazardous Waste Why Do the Hazardous Waste Regulations Exist? Regulations Exist? Prevent Illegal Prevent Illegal Disposal Disposal 6
Why Do the Hazardous Waste Why Do the Hazardous Waste Regulations Exist? Regulations Exist? Prevent Environmental Prevent Environmental Contamination Contamination 7
Why Do the Hazardous Waste Why Do the Hazardous Waste Regulations Exist? Regulations Exist? Prevent Prevent Community Community Emergencies Emergencies 8
Why Cover These Topics? Why Cover These Topics? 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 9
Why Cover These Topics? Why Cover These Topics? 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 10
Why Cover These Topics? Why Cover These Topics? 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 11
Why Cover These Topics? Why Cover These Topics? � 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 12
Why Cover These Topics? Why Cover These Topics? Site specific disposal needs will vary based on: � Type of hazardous wastes generated Type of hazardous wastes generated � Amount of hazardous wastes generated Amount of hazardous wastes generated � Regulatory disposal options Regulatory disposal options � Proximity of disposal facilities Proximity of disposal facilities � Cost of disposal Cost of disposal � On-site “real-estate” On-site “real-estate” for sorting, storing, treating for sorting, storing, treating � On-site disposal options (POTW?) On-site disposal options (POTW?) � Waste hazards Waste hazards � Employee culture (trainability) Employee culture (trainability) 13
Waste Waste Characterization Characterization 14
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 Act 368, Michigan Public Health Code � Part 138, Medical Waste Regulatory Act � Part 2 Ionizing Radiation Rules � Federal Toxic Substance Control Act Federal Toxic Substance Control Act 15
Waste Characterization Waste Characterization Regulatory Overview Regulatory Overview Waste Waste Solid Solid Liquid Liquid Hazardous Hazardous Non-hazardous Non-hazardous Industrial Industrial 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 � 16
E Publication Waste Characterization Waste Characterization racterization Guidance Center Waste See DNRE Where Do I Start? Where Do I Start? Chara � 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 17
Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams Look outside and inside… including discontinued work areas Drains catch spills 18
Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams Look at office and maintenance activities Electronics Batteries Heavy Metals 19
Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams Look at office and maintenance activities Electric lamps Thermostats Mercury 20
Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams Look at aerosol cans Ignitable Can crushing May have & puncturing TLCP issues 21
Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams Look at remodeling/demolition waste e 20, 1999 9 ee DNRE June e Blasting Memo o See brasive Abr Gym Floors Lead Paint Demolition Waste Heavy Metals 22
Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams Look at wastewaters from cleaning operations Power Washing Carpet Cleaning 23
Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams Look at waste from fleet maintenance operations Ignitable & TCLP issues Antifreeze & Used Oil Mercury Switches Degreasing 24
Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams Look at waste from painting Ignitable & TCLP issues 25
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 26 issues
Waste Survey Waste Survey Do Not Overlook Waste Streams Do Not Overlook Waste Streams Look at laboratory wastes Ignitable, Corrosive, Reactive, TCLP, and listed waste issues 27
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 28
How Do You Characterize? How Do You Characterize? (Rules 202, 203, and 302) (Rules 202, 203, and 302) 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 Testing Knowledge : : � MSDS � Facility Process Information � Technical Information � Manufacturer Information � Hazardous Waste Listings � Other Lab Results 29
How Do You Characterize? How Do You Characterize? What is a Hazardous Waste? What is a Hazardous Waste? � Listed Hazardous Waste Listed Hazardous Waste Common waste stream known to be hazardous without testing � Characteristic Hazardous Waste Characteristic Hazardous Waste Waste stream found to be ignitable, corrosive, reactive, and/or toxic due to the characteristics or composition of the 30 waste via testing
How Do You Characterize? How Do You Characterize? � Hazardous Waste Mixture Rule Hazardous Waste Mixture Rule Mixture of a listed listed hazardous waste with other 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 31
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 volume of hazardous waste generated � number of regulations that apply number of regulations that apply � disposal costs disposal costs 32
Waste Stream Characterization Waste Stream Characterization Basic Steps Basic Steps st STEP 1 st 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 nd STEP 2 nd STEP – Review if waste is a characteristic characteristic hazardous waste by testing or relying on knowledge rd STEP 3 rd STEP – Review if a hazardous waste exclusion exclusion or exemption applies to waste 33
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