New rules governing facilities accepting Clean Construction or Demolition Debris (CCDD) and Uncontaminated Soil Fill Operations (USFO) have been adopted by the Illinois Pollution Control Board and are being enforced by the Illinois Environmental Protection Agency (IEPA).

In October, three informational meetings for operators were held to discuss implementation of these new rules. Representatives from the IEPA outlined important changes to CCDD & USFO rules which took effect on Aug. 27. Members of the IAAP’s Environmental Committee offered the environmental consultant’s point of view as well as the operator’s point of view given these new rules. Important points from these presentations are outlined below.

New rules define “other excavation,” “potentially impacted property,” and “uncontaminated soil” and require that the pH of all uncontaminated soil fall between 6.25 and 9. IEPA officials noted the IDOT intergovernmental agreement is no longer valid, rules for groundwater monitoring are still being discussed, and the current Maximum Allowable Concentrations (MAC) table, on the IEPA Web page, could change in the future.

Every load containing soil must be “covered” by an LPC-662 or LPC-663 form. A new rules section 1100.615 allows incidental amounts of stone rock, gravel, roots and other vegetation in USFO’s. It is important to remember if you have a CCDD permit you must submit quarterly fee forms whether or not fill was accepted; this goes the same for quarterly reports at CCDD and USFO operations. A new LPC-667 form has been developed for painted concrete accepted as fill under certain conditions.

All other forms have been updated as well and can be obtained from the IEPA Web site, which also includes an overview of recent changes to rules and requirements, CCDD fill operation fees, the new MAC table, facility information, and answers to many frequently asked questions.

Greg Wilcox of Winston Engineering presented the consultant’s perspective during these informational meetings. Wilcox stressed that if a violation of IEPA rules occurs on a fill site you operate then all parties involved could be required to pay cleanup costs. For that reason it is critical to comply with all requirements — including appropriate testing and certification by a professional engineer or geologist — as well as undertake thorough “due diligence” to ensure that sites do not accept contaminated soils.

Josh Quinn of Vulcan Materials Company offered the fill site operator’s point of view during these meetings. Due diligence is so important that it can’t be overlooked or done carelessly, said Quinn. He offered a due diligence checklist and strategies for evaluating information gathered from public and private database reviews as well as on-site visits. Quinn also gave a detailed description of load inspection procedures and stated that the final decision to accept the load lies with the fill site operator who can reject it — as well as the entire project.

For more information, visit http://www.iaap-aggregates.org/CCDDUpdate.htm

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