Chemical Waste Management Overview. Preparer: Owner: Approver: ENV Team Leader ENV Team Leader EHS Hub Manager David Sheaves David Sheaves Kara Sparks

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1 Procedure No.: WYN Page: 1 of Revision History Revision Date Revision Number 5/18/20 1 Details of Change Revise document and format to new MI-CAN Standardized format. Document has been revised to provide a general overview of requirements for chemical waste management. Specific site standards will be created and implemented for the management of key waste management aspects such as satellite accumulation, manifest management, tanks etc.

2 Procedure No.: WYN Page: 2 of PURPOSE To outline operational procedures for the proper management and handling of hazardous and nonhazardous waste as defined by federal and state waste regulations. To ensure that all personnel involved with the generation of waste from Research and Development, Quality Assurance, Pilot, and Production activities are trained and have a working knowledge of the site's waste management procedures. DEFINITIONS Hazardous Waste Solid Waste Container Tank Spill and Releases A spill of Hazardous Waste is defined as the release of any quantity of hazardous waste or material that becomes a hazardous waste upon its release to the environment. SCOPE These procedures apply to those units and their personnel that are involved in the management of hazardous and non-hazardous wastes. PROCEDURE General Requirements New Waste Streams, Revisions to Existing Waste Streams When a Unit Coordinator determines a new waste stream is needed or additions or subtractions to an existing stream are necessary the following action shall be taken.

3 Procedure No.: WYN Page: 3 of Through the use of the Waste Determination Profile the Unit Coordinator will initiate the stream by completing sections A and B as well as providing an MSDS or other relevant chemical information. The initiated profile will then forwarded on to the MI-CAN Hub for regulatory assessment and completion. The MI-CAN Hub Environmental Team Leader is the first point of contact for the new stream or amended stream. The M-CAN Hub may request the following information in order to complete the waste determination process. A representative sample of the waste. Analytical data or the sample may be sent out for analysis. Other process information such as generating procedure etc. The MI-CAN Hub will complete the profile and submit it back to the Unit Coordinator for use in the Unit. Accumulation and Storage of Hazardous, Non-Hazardous, Universal and Electronic Wastes. All regulated wastes will be accumulated and stored at the Wyandotte Site in accordance with requirements stated in their respective Wyandotte Site Standards. These documents are: WYN032.XXX Satellite Container Management WYN032.XXX «Accumulation Storage Area Requirements WYN032.XXX Management of Hazardous Wastes in Tanks WYN032.XXX Management Requirements for Non-Hazardous Waste WYN032.XXX Management of Universal and Electronic Wastes Treatment of Hazardous Waste The MI-CAN Hub will evaluate on a case-by-case basis any requests to treat hazardous waste or any hazardous material that becomes a hazardous waste as a result of a spill or maintenance operation. Unauthorized treatment or neutralization is not permitted under any circumstances. Any request to treat a hazardous waste stream will be initiated through the use of the Management of Change system in AIMS. The requesting unit must initiate the Change Manager form to begin this process.

4 Procedure No.: WYN Page: 4 of Spill Procedures Spills of Hazardous Waste must be immediately reported to the following: Unit s Supervisor and or Plant Manager MI-CAN Hub On-Call via Each Unit is responsible for ensuring all employees and contractors responsible for managing hazardous waste have adequate training for their responsibilities in the event of a spill or release of a hazardous waste. TRAINING New employee and annual documented training must be given to all employees/contractors who have responsibility for the management of chemical waste materials. The training must be pertinent to the employee's responsibilities with regard to the management of hazardous or nonhazardous wastes in his/her work area. New employees or employees/contractors receiving a new position involving the management of chemical waste materials must be trained within six months. These employees/contractors must not work in unsupervised activities involving hazardous or nonhazardous waste unless they have completed the necessary training requirements. Training records must be maintained by the units for personnel involved in hazardous waste management until closure of all Hazardous Waste Storage Area(s) in the employee's work area. Personnel training records must accompany employees who are transferred to another unit. Upon termination of employment training records must be forwarded to the Human Resources Department where they will be retained for a minimum of three years. These training records must tie together the three following pieces of data: Employee Name Employee Job Classification Employee Waste Management Responsibilities The Central Waste Accumulation Storage Area Building 55M

5 Procedure No.: WYN Page: 5 of Hazardous and nonhazardous waste materials will be received into the CWASA on Monday, Wednesday between 1:00 pm and 2:00 pm as well as Friday between :00 and 11:00 a.m. If a holiday conflicts with this schedule, the CWASA will be open on TuMi-CAN Hubays and/or Thursdays to ensure that full waste containers are received in the allotted three-day time period from Satellite Storage Areas. Containers of waste materials will not be accepted into the Central Waste Accumulation Storage Area unless they are: Properly labeled. In a clean and undamaged condition. Securely sealed. In a container meeting the DOT specifications for the specific hazardous class that the material resides in. Note: A "Container Discrepancy Form" (Attachment II) will be issued to units for containers not meeting the above stated criteria. RESPONSIBILITES GENERAL REQUIREMENTS Plant/Department/Research (Unit) Waste Coordinators Initiate a Waste Data Sheet, see ES-14 BASF Waste Data Sheet Instructions and forward it to the Michigan Canada Hub (Mi-CAN Hub) when one of the following conditions occurs: a new waste stream is identified for characterization, or when an existing stream undergoes a significant change in composition Properly label and store hazardous and nonhazardous waste materials until received at the Central Waste Accumulation Storage Area (CWASA) or until properly manifested directly from the unit. Train all personnel involved with the management of hazardous and nonhazardous waste within the unit. Michigan Canada Hub Trains the Unit Waste Coordinators as to legal requirements and procedures established at the site for proper management of hazardous and nonhazardous waste.

6 Procedure No.: WYN Page: 6 of Determines which facility to use for the proper disposal of each hazardous and nonhazardous waste. Provides the unit, department, or plant with the waste container labeling requirements and information to obtain and complete the required labels. Manages the CWASA. Prepares, signs, and issues all Waste Manifests for shipments originating from the CWASA and tracks all Waste Manifests originating from the site. Assists Unit Waste Coordinators as needed. Purchasing Department Issues the Purchase Order, Disposal Order, Blanket Purchase Order, and/or contracts for disposal of chemical wastes. Negotiates with waste management vendors commercial aspects of waste management in accordance with Corporate Policies and Procedures. REFERENCED DOCUMENTS

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