Special WasteA special waste is any industrial process waste, pollution control waste, or toxic waste, which presents a threat to human health or the environment, or a waste that is difficult to handle at the landfill. Common materials that may require special waste authorizations (SWA) include sludges, slags, filter cakes, paint booth exhaust filters, floor sweepings, spent foundry sand, and sand blast media. Wastes that could also present a handling problem at the landfill, including those that could combust or present human or environmental health threats, are also subject to SWA requirements. 

The SWA regulation reduces potential liability from disposal of industrial wastes in Iowa landfills.  The rule requires testing to ensure wastes are non-hazardous and informs the landfill of the material disposed and the quantities involved.  It also assists the landfill in determining if the material can be handled at the facility and if any special packaging/handling requirements will be necessary.

The Iowa Department of Natural Resources (DNR) and the landfill determine the applicability of a waste to SWA requirements. Therefore, it is advisable to treat all non-hazardous process/production wastes as potential special wastes and follow the requirements in this summary. The Iowa DNR can then determine if the waste requires a SWA and send back written notification either in the form of a SWA or an exemption letter.

General Requirements

  • Some non-hazardous solid wastes from industry require an SWA prior to disposal
  • A Request for an SWA must be submitted to the proposed receiving landfill.
  • Special wastes cannot contain free liquids
  • SWA’s are issued for a maximum of three years
  • Waste disposal facilities/landfills are not required to accept special wastes.  However, if they refuse acceptance, they must identify alternative waste management options.

Handling Requirements

  • Special wastes cannot be delivered to or accepted at a landfill without an SWA.
  • Wastes that receive an SWA must be disposed of following the requirements outlined in the approved SWA (may include packaging, pretreatment, handling, etc.).
  • The issuance of an SWA does not exempt your facility from complying with other state, local, or federal regulations.

Materials Not Issued an SWA

  • Hazardous wastes as defined in the Resource Conservation and Recovery Act.
  • Wastes containing free liquids (this can be determined by the paint filter liquids test - place a 100 gram sample on a standard mesh number 60 conical paint filter and if no liquid drips from the waste within five minutes it does not contain a free liquid)
  • Wastes with Polychlorinated Biphenyl (PCB) concentrations above 50 ppm
  • Polynuclear aromatic hydrocarbon (PAH) contaminated soil (if the total PAH level exceeds 1600 ppm, or if the total carcinogenic PAH level exceeds 200 ppm)
  • Wastes with cyanide concentrations above 1,000 ppm
  • Radioactive wastes

Testing Requirements

  • Toxicity characteristic leaching procedure (TCLP) analysis may be necessary to ensure that the waste is not hazardous (contact the IWRC for a list of testing labs and recommended TCLP parameters specific to your wastes).
  • Other tests may be necessary to determine physical and chemical composition of the waste.                     

Permits

  • Use the Special Waste Authorization Application form to apply for the SWA (link on the right).
  • SWA applications must include at least the request form, chemical composition of the waste including TCLP analysis if necessary, physical form of the waste, and weight/quantity of the waste, (other information may be requested after submission)
  • Three SWA requests and supporting data should be sent to the proposed receiving landfill.  If approved by the landfill, the application will then be forwarded to the DNR for its review and approval
  • SWAs are authorized for no longer than three years
  • SWAs must be reapplied for at least 30 days prior to expiration
  • Notify the DNR within 30 days of any change in the type or amount of waste being disposed

Recordkeeping

 SWAs and associated test data should be kept on file with all other environmental records.

 

Regulation

  • IAC 567-109 - Special Waste Authorizations (PDF)

Links

Form

  • Iowa DNR Special Waste Authorization Application (DOC) / (PDF)