Dow Silicones Corporation Hazardous Waste Management Facility Operating License Information

License and Renewal Information

Hazardous waste treatment, storage, and disposal facilities (TSDFs) are highly regulated, highly engineered facilities, with extensive design and oversight requirements.  The hazardous waste regulations that prescribe the standards that must be met in any license action taken by EGLE include, in part: waste analysis, personnel training, compliance inspections, preparedness and prevention, contingency and closure planning, recordkeeping and reporting, engineering, management of waste, environmental monitoring, corrective action, financial assurance, and air emission standards.

EGLE, MMD issues operating licenses for the management of hazardous waste, that remain effective for 10 years as provided under the state and federal regulations.  The license renewal process gives EGLE an opportunity to update facility information, review operations, and improve the license by clarify license requirements that enhances the protections included in the license.  To reissue a license, EGLE's review must conclude:  

• The license renewal application is sufficiently detailed to evaluate the facility and its potential for impact on human health and the environment.
• The facility satisfies all technical design, construction, and operating standards under governing regulations.
• The facility does not present a hazard to human health or the environment, as determined by EGLE inspections and compliance with applicable environmental regulations.
• The license includes all necessary conditions to ensure safe and proper waste treatment, storage and disposal.

Dow submitted a hazardous waste operating license renewal application on March 30, 2022, before the September 21, 2022, expiration date of the current license.  Timely submittal of the renewal application allows Dow to continue operating under the current license until EGLE takes final action on the renewal application.  The application is currently being reviewed for administrative completeness and technical adequacy.  The application and license are available electronically below, and can also be viewed by appointment at the following locations:

Completeness Review Information

• October 19, 2022, EGLE Administrative Completeness Determination
• September 19, 2022 Dow Revisions Received
• August 3, 2022, DRAFT EGLE, MMD Comments
• License Renewal Application Forms – Received March 30, 2022

• Module A1 – Facility Description
• Module A2 – Chemical and Physical Analyses
• Module A3 – Waste Analysis Plan
• Module A4 – Security Procedures and Equipment
• Module A5 – Inspection Schedule
• Module A6 – Preparedness and Prevention
• Module A7 – Contingency Plan
• Module A8 – Traffic Information
• Module A9 – Location Information
• Module A10 – Personnel Training
• Module A11 – Closure and Postclosure Care Plans
• Module A12 – Closure Postclosure Cost Estimates
• Module A13 – Topo and Floodplain Maps
• Module A14 – Liability Mechanism

• Module B1 – Status of Compliance with Other Federal Laws
• Module B2 – Corrective Action
• Module B3 – Hydrogeologic Report
• Module B4 – Environmental Assessment
• Module B5 – Environmental Monitoring Programs
• Module B6 – Proof of Issuance of Permits
• Module B7 – Capability Certification
• Module B8 – Recordkeeping

• Module C1 – Container Management
• Module C2 – Tank Systems
• Module C3 – Landfill
• Module C11 – Air Emissions

Current Dow Silicones License - Issued September 21, 2012

License Attachments

• Attachment 1 - Waste Analysis Plan
• Attachment 2 - Inspection Requirements
• Attachment 3 - Personnel Training Program 
• Attachment 4 - Contingency Plan 
• Attachment 5 - Closure Plan
• Attachment 6 – Postclosure Plan
• Attachment 7 – Engineering Plans
• Attachment 8 – List of Acceptable Hazardous Wastes
• Attachment 9 - Containers
• Attachment 10 – Tank Systems
• Attachment 11 - Landfill
• Attachment 12 – Environmental Monitoring Program
• Attachment 13 – Corrective Action

Public Involvement

The purpose of public involvement is to ensure that the people interested in a proposed EGLE action are aware of the license review and have an opportunity to provide input on the renewal application before EGLE reaches a final decision to approve or deny the application.  The community is encouraged to engage with EGLE throughout the application review process.  Prior to making a final decision, EGLE will host a formal public hearing to receive formal comments from the community.  

2023-01-26 Public Meeting Slides

In-Person Public Meeting
January 26, 2023, at 6:00 PM
Grace A. Dow Memorial Library, Community Room
1710 West Saint Andrews, Midland, Michigan

Background Inspection Information

EGLE, MMD oversees the hazardous waste operations at Dow by conducting at least four inspections annually.  Inspections are typically unannounced and are performed to verify the facility is operating in a manner that meets the license requirements.  Although the United States Environmental Protection Agency does not permit nor license the facility hazardous waste operations, they may also conduct inspections to verify compliance with pertinent regulations. EGLE's Water Resources Division has separate oversight authority and conducts extensive monitoring of Dow's discharges to the sanitary sewer system.

Stay Connected

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