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Dow Midland Plant and Salzburg Landfill Hazardous Waste Management Facility Operating License Information
Daniel Dailey, Project Manager: 517-242-7261
Joseph Rogers (Salzburg Landfill Only): 517-284-6569
Regulatory oversight of the Dow Chemical Company (Dow) hazardous waste operations at the chemical manufacturing complex located at 1790 Building, Washington Street, Midland Michigan, and the Dow Salzburg Road Landfill located at 2314 West Salzburg Road, in Midland, Michigan, is conducted by the Michigan Department of Environment, Great Lakes, and Energy (EGLE), Materials Management Division (MMD). Dow is required to comply with state and federal hazardous waste regulations for the management of hazardous waste at both facilities. Dow also conducts non-hazardous solid waste operations at the Salzburg Landfill, which is regulated by EGLE, MMD under a solid waste license. Frequent inspections are conducted at both facilities by EGLE's hazardous waste and solid waste programs to ensure compliance with the law. Inspections are also conducted by EGLE's Air Quality Division. Extensive monitoring of Dow's discharge to the sanitary sewer system is conducted by EGLE's Water Resources Division.
Dow operates its own hazardous waste licensed facility. Dow has been licensed for its hazardous waste treatment, storage, and disposal activities at the Midland Plant since 1988 and at the Salzburg Road Landfill since 1987. Both locations were issued a combined license to operate in 2015. Dow has been operating the chemical manufacturing complex since 1897. Dow's license covers its hazardous waste container storage, tank storage and treatment, surface impoundment storage and treatment, incinerator, landfill, and on-site and off-site clean-up (corrective action) activities. The hazardous waste regulations require that hazardous waste licensing be renewed every ten years . Dow is required to submit a license renewal application to EGLE by no later than March 29, 2025.
Since issuance of the current license, Dow has amended the license 15 times. Details on current license and amendments 11 through 15 are available below. Details on amendments 1 through 10 are available upon request. Information on the license and corrective action can also be viewed by appointment at the following locations once offices reopen.
EGLE, Lansing Headquarters
525 West Allegan Street, Lansing, Michigan
Contact: Ms. Vickie Terry
EGLE, Bay City District Office
401 Ketchum Street, Suite B, Bay City, Michigan
Grace A. Dow Memorial Library
1710 West St. Andrews Street, Midland, Michigan
Where portions of the license are not available, they were not posted due to file size limitations.
Current Dow License - Issued September 25, 2015
- Attachment 1 - Waste Analysis Plan (Updated only to incorporate Revised Dow Site-Specific LDR Treatability Variance Approval in Appendix A3-3)
- Attachment 2 - Inspection Schedule
- Attachment 3 (MP) - Personnel Training Program Midland Plant (Replaced by Amendment 1)
- Attachment 3 (SLF) - Personnel Training Program Salzburg Landfill (Replaced by Amendment 1)
- Attachment 4 - Contingency Plan (Figures for Tertiary Pond and No. 6 Brine Pond Part 315 Dam Safety Emergency Action Plan are not available on-line due to large file size) - Updated by Amendment 1
- Attachment 5 - Closure and Post Closure Care Plans Midland Plant
- Attachment 6 - Closure and Post Closure Care Plans Salzburg Landfill
- Attachment 7 - Subpart BB Air Emissions from Equipment Leaks and Subpart CC Air Emissions from Tanks, Containers, and Surface Impoundments
- Attachment 8 - Use and Management of Containers - (Amendment 14)
- Attachment 9 - Midland Plant Facility Boundary Topographic and Part A Maps
- Attachment 10 - List of Acceptable Waste Types for Management at the Dow Michigan Operations, Midland Plant & Salzburg Landfill Facilities
- Attachment 11 - Tank Systems
- Attachment 12 - Incineration or Thermal Treatment
- Attachment 13 - Surface Impoundments
- Attachment 14 - Salzburg Landfill Drawings and Topographic Maps (Amendment 1)
- Attachment 15 - Replaced by Attachment 20
- Attachment 16 - Replaced by Attachment 20
- Attachment 17 - Replaced by Attachment 20
- Attachment 18 - Off-site Corrective Action Midland Area Soils
- Attachment 19 - On-site Corrective Action
- Attachment 20 - Sampling and Analysis Plan
Revised Dow Site-Specific LDR Treatability Variance Approval - September 25, 2015
Recent License Amendments
Operating License Amendment 15
On June 18, 2020, EGLE approved a minor modification to the operating license issued September 25, 2015, based on a request from Dow to replace an existing monitoring well, MW 4666, in the Salzburg Road Landfill detection monitoring program in Part IX of the operating license. The minor modification request and approval letter for Amendment 15 to the facility operating license are provided below.
- May 19, 2020, Dow Minor Modification Request
- May 19, 2020, Dow Work Plan to Replace MW 4666
- May 19, 2020, Dow Work Plan Figure 1
- May 19, 2020, Dow Work Plan Well Construction Log
- June 18, 2020, EGLE Minor Modification Approval Letter
Operating License Amendment 14
On April 16, 2020, EGLE approved a minor modification to the operating license issued September 25, 2015, in order to:
- perform administrative and informational updates to the license language;
- to process Dow's February 22, 2019, voluntary minor modification request to combine the environmental monitoring Sampling and Analysis Plans for the Midland Plant and Salzburg Road Landfill, Attachments 15, 16, and 17 to the License, into a new Attachment 20, Sampling and Analysis Plan, to the License;
- to update forms and include new Figures in Attachment 1, Waste Analysis Plan, to reflect the management of hazardous wastes under the Industrial Park Concept; and
- to incorporate as-built drawings for the southeast diking area for Waste Storage Area I in Attachment 8 to the license.
Due to the size and number of the documents included in the minor modification request, copies of the information regarding the minor modification request are available upon request. Please contact Daniel Dailey at the number listed above for further information. The Amendment 14 minor modification approval letter, copies of updated boilerplate language, and updated Attachments 1, 8, and 20 to the license are provided below. Previous Attachments 15, 16, and 17 to the license have been replaced by Attachment 20 and were removed from the license.
- April 16, 2020, EGLE Minor Modification Approval Letter
- Hazardous Waste Management Facility Operating License Boilerplate Clean Copy
- Hazardous Waste Management Facility Operating License Boilerplate Track Changes Copy
- Attachment 1, Waste Analysis Plan with Amendment 14 Updates
- Attachment 8, Containers with Amendment 14 Updates
- New Attachment 20, Sampling and Analysis Plan
Operating License Amendment 13
On March 27, 2019, EGLE approved a minor modification to the facility operating license based on a request received January 29, 2019, from Dow to replace existing purge wells PW-5, PW-6, and PW-7 in the Facility 7th Street monitoring program with a horizontal well subject to the same monitoring conditions as purge wells PW-5, PW-6, and PW-7 in Part IX of the operating license. The minor modification request and approval letter for Amendment 13 to the operating license are provided below.
Operating License Amendment 12
On April 8, 2019, EGLE approved a minor modification to the operating license based on a November 16, 2018, notification of a new area of concern (AOC), the Mark Putnam AOC, received from The Dow Chemical Company. The notification identified this area as a release to soils of chlorinated volatile organic compounds requiring remediation. The notification and minor modification approval letter are provided below.
- November 16, 2018 Notification of new Mark Putnam AOC
- April 8, 2019 New AOC Minor Modification Approval
Operating License Amendment 11
On June 25, 2018, EGLE approved a minor modification to the operating license based on an April 10, 2018, request from Dow for Waste Storage Area I (WSAI) Southeast Dike Concrete Replacement. The WSAI request and approval letter for Amendment 11 to the facility operating license are provided below.
Subscribe to the Dow mailing list to receive updates from EGLE related to the Dow license and corrective action activities. You are the eyes and ears of your community. Through your observations and reporting of activities of concern, you play a valuable role in helping the EGLE protect human health and the environment. To file a complaint or share details about improper waste handling or disposal, contact EGLE through the Pollution Emergency Alerting System (PEAS) Hotline at 800-292-4706