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Many commercial or industrial facilities generate large quantities of industrial process waste. Once a waste determination has been performed to ensure that an industrial process waste is not hazardous, the commercial or industrial facility which generates such waste has several disposal options. One such option is for a generator to obtain an IDEM permit to construct and operate a restricted waste site. A restricted waste site is a monofill permitted to accept one type or similar types of waste(s).
IDEM issues three different types of Restricted Waste Site permits -- Types III, II, and I -- with progressively more stringent levels of monitoring and containment. The permit process involves two parts. The first step is determining the restricted waste type. Prior to disposal, all waste must be classified by IDEM. The second is obtaining the corresponding facility permit. All wastes disposed in the restricted waste site must be specifically listed in the facility permit.
As mentioned earlier, restricted waste sites may only receive wastes which are similar in origin or chemical character and, additionally, are not subject to organic decomposition. For example, a foundry may dispose of foundry sand but not absorbents used to clean up oil spills in their restricted waste site landfill. Both testing results and a generator's knowledge of the waste is used to obtain a waste classification showing the restricted waste type. A generator may review their own data but IDEM makes the final determination and issues the waste classification.
An applicant seeking a permit for a restricted waste site must first submit a formal request to the Industrial Waste Section of IDEM for a waste classification for the waste that will be placed at the site. The complete waste determination documentation must be submitted along with that formal request. After review, the Industrial Waste Section will notify the applicant, or in the case of waste classification renewals, the facility, of the classification of its waste(s). The waste will be classified as Type I, II, III, or IV.
Once the restricted waste type is determined, the generator then may apply for the permit for the disposal facility. The generator must select a facility type that meets or exceeds the waste type. The decision on the best disposal option for your waste will be based on several factors:
The generator may choose to apply for a restricted waste site that matches their waste type. For example, a Type III site for waste that has a Type III waste classification. Alternatively, a generator may wish to apply for a restricted waste site that exceeds the waste type. For example, a Type II site for Type III waste. Remember, a Type II waste cannot go into a Type III site. Restricted Waste Site Types I and II, which have the most stringent standards for construction and operations, both require a compacted clay liner and groundwater monitoring wells. Type III sites require a compacted clay liner; no groundwater monitoring. Additional protective features may be required depending on the chemical characteristics of your waste. Type IV waste is excluded from regulation with a few provisions found at 329 IAC 10-3-4.
Once the permit is issued, the generator must maintain compliance with the permit and rules for the site. One important requirement is keeping a current waste classification and monitoring any changes in the nature of the wastes being disposed of at the site. IDEM must be notified of changes and if the change is substantial, further disposal must be pre-approved by IDEM. Unless there is a process change which could alter the nature of the waste, the schedule for re-sampling corresponds with the expiration of the waste classification.
Permitting and operating a Restricted Waste Site could be more expensive than transporting waste off-site, even out-of-state, to another such disposal site or municipal solid waste landfill. However, the advantages of building, permitting and using such a disposal site are: 1) the material is available for possible re-use at a later time, and 2) because the material is not co-mingled with other wastes, the generator limits their future liability should the material, or material with which it is co-mingled be subject to a cleanup or enforcement action.
Some of the Things a Generator Must do to Develop an IDEM Permitted Restricted Waste Site Include (but are not limited to):
There is no fee associated with the waste classification process. In addition, IDEM is under no statutory deadline for completing a waste classification for a restricted waste site. However, once IDEM staff have been provided with all the necessary information, a waste classification is usually issued within 60 days.
The costs of permitting and operating the various levels of Restricted Waste Sites I, II, and III are:
|Solid Waste Disposal Facilities|
|Restricted Waste Sites I, II, and III|
Generally Monofills for Non-hazardous Industrial Waste
(365 days allotted to IDEM for permit review)
|Type I||Permit Fee:||$31,300|
|Annual Operating Fee:||$35,000|
|Type II||Permit Fee:||$31,300|
|Annual Operating Fee:||$25,000|
|Type III||Permit Fee:||$20,000|
|Annual Operating Fee:||$10,000|
IDEM is allotted 365 days to review a permit application for a new Restricted Waste Site landfill. Applications for a major modification to a Restricted Waste Site landfill also may be reviewed for up to 365 days. The application fee for a major modification is the same as for a new permit. The application fee for a minor modification is $2,500, and IDEM is allotted up to 90 days to review requests for minor modifications.
To learn more about permitting a Restricted Waste Site or to obtain an application form, contact the IDEM Solid Waste Permit Section at 317/232-4473 or visit the OLQ Permit Application Forms page. For more information on waste testing for waste classification purposes, please contact IDEM at (800) 451-6027, ext. 308-3110.