Presentation for the Michigan Department of Environmental Quality

December 2015

Any site which was a Large Quantity Generator (LQG) of hazardous waste (HW) in any one calendar month during the reporting year.

Facilities that have a permit to treat, store or dispose of HW.

No, the rules do not contain an exemption for one-time generators or remedial activities.

Being a LQG for one month doesn’t make you a LQG forever. Follow the rules applicable to whatever size generator you are at the time.

The report instruction booklet – Please read it!

Shipment manifests Results of laboratory analysis of the wastes Records of quantities of HW generated or

accumulated Documents you’ve exchanged with the

facilities that will receive your HW shipments Copies of previous reports can be helpful

Federal booklet is located here with fillable PDF forms: http://www2.epa.gov/hwgenerators/2015-hazardous-waste-report-instructions-and-form

There are five forms that together comprise the Biennial Report (BR): ◦ RCRA Subtitle C Site Identification (Site ID) Form ◦ Michigan Site ID Form (EQP 5150)DEQ - Hazardous

Waste Program Forms and License Applications ◦ Waste Generation and Management (GM) Form ◦ Waste Received From Off Site (WR) Form – TSDFs only ◦ Off-Site Transporter and Receiving Facility Information

(OI) Form – not required in Michigan

MI DEQ requires you to complete their Site ID form, on paper. Doing the federal form is optional.

However, Florida’s free Biennial Report software (BRS) is based on the federal RCRA Subtitle C Site Identification form.

If you use the software, mail the signed MI DEQ form to DEQ along with the BRS export file of the data saved to a CD.

Site identification and regulated activities, one form per report

The US Census Bureau maintains the list of NAICS codes. You can search for appropriate codes on their web site. The URL is in the instruction booklet.

All owners and operators should be included, property as well as business. Additional owners or operators can be listed in the Comment section at the end of

the Site ID form.

Once all forms are completed, number the pages consecutively, not by form type.

To date, there are no Subpart K notifiers in Michigan so the answers to this section would most likely be No. You can’t Withdraw unless you opted in previously.

Use the Comments section to provide information you want us to know that isn’t captured elsewhere. This includes extra owners or waste

codes that didn’t fit into the space provided.

Section 12: Michigan has not adopted the rules applicable to this activity so the Hazardous Secondary Material answer should be No. Do not complete the

federal HSM Addendum form.

The report should be signed by a Responsible Official or their Authorized Representative. Please remember to print the certifier’s name and title –

signatures are sometimes illegible!

One form per waste stream to report generation, on-site management, and off-site shipment

Report what was generated and what you did with it

One form per waste stream - Sum the amount of the waste generated during the year

If the waste codes varied a bit but you still consider it the same waste stream, report it all together

Consider consolidating based on matching combinations of Form Code and Source Code ◦ TSDs reporting trans-shipments: may consolidate by

grouping similar waste profiles that have the same Form and Source Codes

Generated and accumulated on-site and ◦ Then managed on-site or shipped in 2015 ◦ Not managed or shipped until 2016 ◦ Managed on-site or shipped in 2015 but generated

in a previous year Notice the emphasis on “accumulated”

Generated on-site from a production process, service activity, or routine cleanup

Generated from equipment decommissioning, spill cleanup, or remedial cleanup activity

Removed from on-site storage Derived from management of non-haz waste Derived from on-site treatment, disposal, or

recycling of HW HW shipped off-site Radioactive waste mixed with RCRA HW

See list and rule references in the instruction booklet

Treatability study samples Materials in a closed loop system PCB waste, unless mixed with a HW Used oil, unless mixed with a HW Batteries or lamps managed as Universal

Waste Wastes recycled without prior storage in an

on-site process exempt from permit requirements

Wastes managed immediately upon generation only in on-site elementary neutralization units, wastewater treatment units, or totally enclosed treatment facilities. ◦ Any HW residuals from this are reportable, though

Federal detailed guidance “Biennial Report: Reportable and Non-Reportable Wastes” on US EPA’s BR website http://www3.epa.gov/epawaste/inforesources/data/biennialreport/index.htm

Describe what the waste is and how it was created, e.g. Spent solvent from paint gun cleaning; Out-of-date lab chemicals; Contaminated soil from remediation

Enter Federally-defined waste codes in Box B and Michigan waste codes in Box C. If you have more than 6 waste codes, enter the overflow in the Comments Section.

The Source Code describes how the waste originated. Review the entire list and pick the one that best fits.

G25: If the waste is a residual from a TDR process, the correct code is G25 and a Management Method code needs to be reported that describes the process.

Waste trans-shipped by a TSD Facility should be coded as G61 with zero as the amount generated.

Do not report foreign exports on the BR. MI DEQ gets this information from manifests.

Form Code corresponds to the physical form or chemical composition of the HW

Some are very specific, some general ◦ Categories for Liquids, Solids, and Sludges split into

Organic and Inorganic ◦ Mixed Media/Debris/Devices

Read through the entire list and pick the most appropriate

A single unit of measure applies to the entire page

If the waste was shipped in two different units of measure, convert into one and add the quantities

Density is required when the unit is in volume. It is recommended that you report it when you covert into pounds.

US EPA wants to know if you have new or existing waste min efforts to reduce quantity or toxicity of HW

Review the codes and determine if any apply; otherwise enter X, no efforts implemented

Use the Comments section to provide additional information if desired

Report on-site treatment, disposal or recycling of waste you generated

Management in an exempt unit should be reported if the waste was accumulated after generation

Management in a permitted treatment or disposal unit should always be reported

Same unit of measure as Section 1

Can report up to 2 different processes ◦ This is not for the reporting of a “treatment train” of

sequential processes

List all receivers for the HW as recorded on the manifest you completed

List the management method for the initial receiving facility the waste was shipped to, not the ultimate destination if it was re-shipped by Receiver 1.

Manifests should list the management method code but if you have doubts, contact the TSD Facility.

If a TSD Facility used more than one management method on the same waste, list the receiver on multiple lines and split the amount by management method code

Use the Comments section if you have more than 3 receivers

Scenario: A TSDF recycles solvents in a distillation unit. The still bottoms are fuel-blended on-site and then shipped for energy recovery.

Section 1Box D: Source Code = G25, Management Method Code = H020

Section 2: System 1 H061 with quantity Section 3: List receivers with H050 as the

management method code

Use this to report information not captured elsewhere on the form but you feel is important

Provide text for items that you want to explain, such as when “Other” codes were reported or issues with waste minimization

Comments do get entered into the database

TSD Facilities report hazardous waste received from off-site generators

Sum the year’s receipts for each customer by waste stream and report each waste separately ◦ Consider consolidating by grouping similar waste

profiles that have the same Form Code and waste codes

When reporting HW imported from foreign generators, the customer’s ID can begin with MI or CD

Don’t report yourself as a customer. If you’re not sure how to report something, call MDEQ.

If there is a treatment train of processes, pick the management method code that best describes it.

Stabilization followed by: ◦ Shipment = H110 ◦ Disposed of on-site after stabilization = H132

Fuel blending followed by ◦ Shipment = H061 ◦ Energy recovery on-site = H050

Underground injection after wastewater processing = H134 not wastewater treatment

One-step neutralization = H121 not wastewater treatment

Re-shipped without any treatment or recovery = H141

Up to three wastes can be listed on a single paper form. The customer’s ID is reported for each record.

Comment section can be used as needed. State which Waste the comment is about.

2015 reports are due at MDEQ no later than Tuesday, March 1, 2016

We do not accept faxed forms. We do not issue automatic fines for being

late.

MDEQ may use manifest data to find LQGs that didn’t file and should have, and then issue NOVs.

Many paper-based report forms are incomplete, so we have to contact you to resolve the problems.

Reporting software is designed to prevent omissions and produce a higher quality report.

Read the instructions and review the forms thoroughly before sending them in.

Enter them to a database and share the information with U.S. EPA.

Review them as part of pre-inspection prep Compile statistics and mine the information

to help DEQ oversee the RCRA program in MI Answer information requests for internal and

external customers

MI DEQ BR Contact: BiennialReport@michigan.gov

MI DEQ BR web page: DEQ - Hazardous Waste Biennial Reporting

US EPA’s BR web page: http://www3.epa.gov/epawaste/inforesources/data/biennialreport/index.htm