Michigan Accumulation Time regulations & environmental compliance analysis

Michigan Accumulation Time: What you need to know

Governing Law and Regulations

Generator accumulation time requirements: Michigan Administrative Code (MAC) r. 299.9306

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Large quantity generators (LQGs) accumulating F006 on-site:

Units: MAC r. 299.9306(7)(d)(i) and MAC r. 299.9306(7)(d)(ii)

Containers: MAC r. 299.9306(7)(d)(i)

Tanks: MAC r. 299.9306(7)(d)(ii)

Fire, explosions, and releases: MAC r. 299.9306(7)(g) and MAC r. 299.9306(7)(i)

Accumulation area: MAC r. 299.9306(7)(h)

Closure: MAC r. 299.9306(7)(j)

Regulatory Agency

Michigan Department of Natural Resources and Environment (DNRE) Hazardous and Liquid Industrial Waste Program Hazardous Waste Program Section

See ADDRESSES & CONTACTS for addresses and telephone numbers.

See national section for basic information and federal regulations.

Comparison: State vs. Federal

Rules. Michigan has adopted the federal accumulation time rules that allow generators to accumulate hazardous waste on-site without a permit for specific periods of time. See the national section ACCUMULATION TIME to review the specific time periods applicable to each type of generator.

DNRE has adopted the federal accumulation time standards that allow LQGs that generate wastewater treatment sludges from the metal finishing industry (i.e., EPA Waste F006) to accumulate F006 beyond the usual 90-day LQG limitation. However, Michigan has added its own state requirements to these F006 provisions.

Generators should note that Michigan requires generators to comply with on-site storage standards in addition to those required under federal law. See the state section HAZARDOUS WASTE STORAGE for guidance on how to store hazardous waste on-site without a permit in compliance with the state's more stringent requirements.

Administration and enforcement. DNRE's ...

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