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SB 14 Waste Minimization Plan <br /> DTE Stockton, LLC April 2018 <br /> Land - The facility has historically transported the ash waste offsite to a hazardous waste landfill. <br /> More recently, the facility has been investing resources in evaluating options for the beneficial <br /> reuse of the ash instead of routinely transporting the material to a landfill. The preferred source <br /> reduction method discussed in Section 2.7 does not transfer waste impacts to impacts on land. <br /> Water - The preferred source reduction method discussed in Section 2.7 does not transfer waste <br /> impacts to impacts on water resources. <br /> 2.7 Rejected Source Reduction Measures <br /> Source reduction is defined as any action which causes a net reduction in the generation of <br /> waste. Source reduction does not include steps taken after the material becomes waste. <br /> 1. Input changes: The input for the facility is biomass as fuel. Fuel providers are or required to <br /> limit the ash product of their wood. <br /> 2. Operational Improvements: The operational improvement of converting the use of coal fuel to <br /> biomass fuel was implemented in 2013. Further operational improvements are not technically <br /> feasible/available at this time. <br /> 3. Production Process Changes: The DTE Stockton facility uses biomass to produce electricity <br /> via a proven production process. A change to the process of producing electricity is not <br /> technically feasible at this time. <br /> 4. Product Reformulations: The DTE Stockton facility `product" is electricity. Reformulation <br /> options to produce electricity are not technically feasible at this time. <br /> S. Administrative Steps:Administrative steps to reduce the volume of ash as a hazardous waste <br /> have been implemented. The company has invested significant resources to idents beneficial <br /> reuse locations for the ash byproduct. However,for the purposes of this report, this reduction <br /> of hazardous waste does not change at the source, the disposal options for the byproduct of <br /> using biomass to produce electricity changes. <br /> 2.8 Preferred Measure to Reduce Hazardous Waste Generation <br /> Over the years, the DTE Stockton facility has made operational and process changes that have <br /> reduced environmental impacts. Originally designed and operated to use coal to produce <br /> electricity,the change to biomass fuel in 2013 was a significant path forward.As the facility settled <br /> into the process and generated ash as a byproduct of using biomass, the company realized the <br /> impact of generating a material that required disposal in a hazardous waste landfill. As a result, <br /> the facility developed an Ash Management Program to invest resources toward identifying options <br /> for the beneficial reuse of the material. Although "source" reduction options are restricted, <br /> identifying locations that will accept the ash byproduct as a beneficial reuse is a positive step <br /> forward. <br /> The Ash Management Plan outlined the steps that would be taken to implement a beneficial reuse <br /> strategy.A sample of the ash byproduct was analyzed to determine a waste profile.A waste profile <br /> would provide the data for characterizing the ash byproduct.If the results of the analyses are below <br /> the threshold characteristics of a hazardous waste, and can be maintained <br /> 294354 6 <br />