The following is a guide for regular people regarding CCDD – which stands for Clean Construction Demolition Debris. In this primer, we’re going to take a beat to cover background information you’ll need to keep in mind while reading. I’m making the assumption that you, the reader, is not an engineer or environmental consultant but is in an industry that is touched by these regulations. This will be written to keep the technical jargon to a minimum and explain things thoroughly.
Table Of Contents
There is mandatory vocabulary that needs to be understood so you can communicate effectively with the engineers and environmental consultants.
Soil Disposal Vocabulary:
CCDD – is the abbreviation of “Clean Construction Demolition Debris” and it refers to a body of laws and regulations from the Illinois Environmental Protection Agency regarding the proper disposal of dirt, fill and debris normally created in the process of demolishing some structure. Beyond this point, we will only refer to it as CCDD.
Fill – Fill is stuff like dirt, clay and rock that is usually dug out of a hole that was created as part of a construction project. Excavating for a basement or water retention pond creates fill. Usually this fill, for economic reasons (hauling fill is expensive) is used onsite but very frequently there’s nowhere to put it and it needs to be disposed of.
To be as clear as possible; people are comfortable with the word “dirt” because they understand it. It brings to mind that beautiful black stuff you grow tomatoes in. In reality, that’s almost never what we mean about the pile we need hauled. It’s almost always clay, chunks of rock and concrete or broken asphalt. When talking with your professionals; engineers, environmental consultants, and the landfill, you should probably call it “fill” so everyone is on the same page.
Illinois Environmental Protection Agency – It’s super important to remember CCDD regulations are Illinois specific. No other state in the union does CCDD. This is significant in many philosophical ways which I intend to get into once the important work is out of the way. We will refer to the Illinois Environmental Protection agency as the IEPA from this point forward.
LPC-662 – This is a regulation subsection in the laws and regulations regarding CCDD disposal. This particular subsection is built for soil that comes from an area where the assumption is that it is clean. Imagine a typical suburban street with single family houses in rows. These rows are part of a residential subdivision that was carved out of a farmers field 50 years ago. The soil under these houses is presumed clean based on the usage. If someone is excavating for a basement, or a utility is running a natural gas main, the soil that gets collected from these activities is presumed clean and is treated differently than the next regulation subsection, LPC-663.
LPC-663 – This is a regulation subsection regarding CCDD disposal where the assumption is the soil is “Impacted”. Think soil that comes from, in and around, gas stations and industrial sites. Soil in these areas may be clean but the assumption is to start with the conclusion that it is not. We work backward to prove it is clean and can be disposed of in a CCDD facility.
LPC-667 – This regulation subsection is in reference to uncontaminated, broken concrete. Painted concrete and other painted materials can contain lead and other heavy metals which are toxic for humans to drink. Rainwater can wash these heavy metals through the unlined bottoms of CCDD facilities and into the drinking water wells of the surrounding homes and community. Going forward, this is the last we’ll talk about LPC-667.
Impacted – When we say “Impacted” it’s jargon-y, inside baseball way of saying “Contaminated by something”. It’s really short for “impacted soil”. We’ll be using the word “impacted” going forward.
Landfill – A landfill is any officially recognized place to dispose of things society doesn’t want. I’m being deliberate in avoiding the term “garbage, waste, refuse, junk” or any other shorthand term for things that end up in landfills. There are many different types of waste streams and they are very specific and all treated differently. To name a few; medical waste, household waste, electronic waste, contaminated soil, and construction waste.
Subtitle D – Subtitle D refers to a specialized type of modern landfill which accepts hazardous waste. Even though Subtitle D refers to a place (landfill) we use the term as shorthand for the thing that goes into the Subtitle D landfill (fill). Just to be overly clear, fill is not the only thing that goes into Subtitle D landfills.
MAC Value – Maximum Allowable Concentration. This refers to the state maximums for different contaminants over which the fill will not be allowed into a CCDD facility. The MAC values only come into play for LPC-663.
USFO – Definition is: Uncontaminated Soil Fill Operations. This differs from CCDD in that CCDD can be construction debris while USFO is a very specific term for just uncontaminated soil. Some operations take USFO only. Others take only construction debris.
Modern landfills are built with enormous, thick and seamless plastic liners like a giant swimming pool. These liners separate the contents of the landfill from the surrounding soil by an impermeable barrier. This barrier keeps the leachate, which is a fancy way of saying “rainwater that filtered through the landfill” from mingling with groundwater which may be used by humans to drink.
From this point forward, if the soil is known beyond a shadow of a doubt to be “impacted” by hazardous chemicals we will call it “Subtitle D”.
If you have read this far, you should be comfortable calling up your environmental consultant and having a conversation about your pile-o-dirt and how to properly dispose of it. That conversation should go something like this;
You: I have 6 cubic yards of soil from the corner of 5th and Maple in Westmont Illinois.
Me: LPC-662? (While I pull up the address on Google Streets)
You: 663. It’s next to a corner gas station. We are fixing water mains.
What Problems Was CCDD Regulation Trying to Address?
Economics drove the necessity for CCDD. Meaning; Illinois industry needed to find a less expensive way to dispose of construction waste.
Pardon me while I put on my economics nerd glasses and pontificate. Landfills are natural monopolies (as opposed to coercive monopolies). Based on the fact that they are ugly, stinky and nobody wants to live near them they are located in places that are often distant. The permitting and regulatory burden the state governments require from landfills combined with the difficulty of creating new landfills causes there to be precious few landfills in any given metropolitan area. As we all remember in fundamentals of economics, when you have high demand and very low supply, the prices are high.
In response the Illinois legislature passed a series of laws and handed it to the IEPA which allowed old (and current) aggregate operations (think sand or limestone quarries) to be turned into places where CCDD materials could be deposited. This had a ton of unexpected consequences which we won’t cover here but ultimately it increased the supply of landfills which naturally dropped the price of dumping clean fill.
As with anything in law and politics, uncontaminated soil fill operations in Illinois created a constituency and lobbying group. Clean fill operators have a trade organization that helps to manage the IEPA while the IEPA manages them.
From our experience, clean fill operators are very serious about doing a good job and following the regulations. They also provide a valuable revenue stream for the IEPA to manage the criminal organizations in the same way that buying a fishing license provides revenue for the Department of Natural Resources to hire officers to patrol our lakes, rivers and streams.
Deep Dive Into CCDD LPC-662
LPC-662 soil is presumed clean based on the area it is collected from. The regulatory paperwork is designed around this assumption and is built for contractors, excavators, and trucking companies to fill it out themselves.
There are three components to LPC-662 waste disposal:
- LPC 662 Form – This is the paperwork that a clean fill operator will need at the scales to let you in. It will need to be properly filled out, if you need help, we can do that for you. Call us at (888) 405-1742.
- pH Test – This test will tell your CCDD fill operator if the soil is acidic or basic and if it is inside the parameters which they can take which, by law, is 6.25 to 9.0. For frame of reference, the world around you is roughly a pH of 7. A quick google search tells me your blood is a pH of 7.35.
In our experience, clean fill operators want the pH test run by a certified laboratory. There is a provision in the IEPA CCDD documentation that allows you to use handheld electronic pH meters. However, the facilities we use have asked for official lab work. The fastest a lab will be able to turn this around is 24 hours. Even then it will cost extra money for a rush. However their regular turn times are pretty quick too, expect 5 days. These tests are pretty inexpensive. You should expect to pay roughly $30.
- Environmental Database Report (EDR) – We use a company called ERIS for our EDR Reports. This is a radius map of every known environmental contamination location in a circle around the location where the 662 soil was generated. Ideally, this EDR should come back empty. This emptiness is one of the factors that lends credence to the fact that the uncontaminated soil fill operations you are conducting are, in fact, uncontaminated. These databases cost approximately $225.
Deep Dive into LPC-663
With industrial site soil removal the presumption is the soil is impacted and we work backward to prove that it is not. If we, as environmental consultants, can prove that the soil is CCDD LPC-663 we can save the client substantial amounts of money, depending on the size of the project. There are costs associated with the testing necessary to do this work but if soil removal is necessary, regardless of if it’s CCDD or not, then these tests will need to be done anyway in order for it to be accepted into a Subtitle D landfill.
There are three components to LPC-663 waste disposal:
- LPC 663 Form – This is the paperwork that a clean fill operator will need at the scales to let you in. It will need to be properly filled out. If you need help, we can do that for you. Call us at (888) 405-1742.
- EDR – Just like above, this is the environmental database radius report which checks every Federal, State, County and Municipal database for known environmental contamination. The database is the same as the LPC 662 and costs the same, approximately $225.
- Soil Sampling – There is laboratory work that needs to be done. This time it’s to prove your soil is clean. The specific tests depend on what kind of information the environmental database dredges up, what kind of businesses are close to the site and what kind of industry they are in. For example, if your soil comes from near a gas station, we’ll look for fuel indicator chemicals in the soil. If it comes from near a dry cleaner we’ll be looking for other chemicals. A good environmental consultant will have one eye on the data needs of the CCDD facility operator and another on what a Subtitle D landfill will need, which can be different. We do this because we know the soil is going somewhere and our clients don’t want us burning their budgets and time making two trips to sample a pile of dirt.
Prices for this can vary widely depending on what we are samping for. What we are sampling for, as I mentioned earlier is dependent on the results of the database and how many samples we need to take.
What to Expect at the CCDD Facility
I’d like to start by saying that uncontaminated soil fill operators in Illinois are serious, professional and committed to the goals of the Illinois EPA. By extension they are committed to protecting the health and welfare of the surrounding communities and their drinking water. Why did I start this section with such a statement? Well, there have been numerous bad actors in the trash hauling and disposal business. If you need me to spell it out for you I’m talking about organized crime. If the place you’re dumping your waste seems dodgy, that’s because it is. This brings a whole host of liability issues for anyone who participated in the dumping. The long arm of the law always catches up to these people.
Like any aggregate facility, you will get weighed when you enter and exit. Your weight will determine the cost to dump and is generally expressed as a cost per ton.
You’re going to have to have the proper paperwork and the facility will need to be expecting you. You’ll need to have your LPC 662 or 663 forms filled out, stamped if necessary by a professional geologist or engineer and an EDR report in hand.
They are going to run a handheld device called a PID – Photoionization Detector, which is a tool for electronically sniffing for volatile organic compounds (VOCs). If the PID has readings in excess of the ambient background VOCs they will reject your load and you won’t be able to dump. They will also report your truck, company and paperwork to the IEPA and you won’t be able to dump at any other CCDD facility. Your truck will need to be rerouted, either back to the site it came from or to a Subtitle D landfill.
If you do everything correctly, you will find substantial savings between the decreased distance the trucks need to travel to the (alternative) landfill and in what are called “Tipping Fees”.
How much can you save by utilizing CCDD facilities?
Pricing for tipping fees varies from location to location. Someday I will do a deep dive into the economics of waste disposal as I understand it because it’s fascinating. I can tell you that the people at Waste Management have it dialed in like a boss. That’s not to say they win every project, what it does mean is they understand where the pricing comes from and how and why they pick the prices they do.
Tipping a 20 ton truckload of CCDD soil at a Waste Management landfill costs approximately $22 per ton, or $440 per truck load. A CCDD fill site might cost half that price or less.
What is the lead time for sample testing for CCDD soil?
Two weeks is a standard for any environmental consultant to turn samples and paperwork around.
What does it cost to have an environmental consultant help you with a CCDD fill material?
For LPC-662 it’s approximately $1,500.
For LPC-663 it’s approximately $2,100
To be clear, this is just the cost for the science that will permit you to deposit your soil in a CCDD facility. This doesn’t include the cost for excavation, trucking or tipping at the CCDD fill operation.
Why is there such a price differential between LPC-662 and LPC-663?
LPC-663 is more expensive because we have to do extensive laboratory work to prove the soil is clean. Additionally, when we as environmental consultants are certifying the soil as clean we stamp it as professional geologists. Our stamp carries all the responsibilities that come with errors and omissions insurance. Essentially, if the soil is contaminated and it gets past our professionals, it’s our fault.
I own the pile of fill, can I do any of this work myself?
If your soil is LPC-662, yes you can do the paperwork, labs and possibly the database work yourself. Most of our clients would prefer to not mess with it. This line of work comes with environmental liability which can be a heavy responsibility. If the soil is LPC-663, you will need us or an engineer because it will take a professional stamp to be able to dump in a CCDD landfill.
What else do I need to know about CCDD?
Every facility has their own profile of background levels of contaminants in the soil. For instance, arsenic is a naturally occurring metal which is water soluble to some degree. It’s also poisonous at high enough concentrations. One CCDD facility might have a high background level of arsenic when another’s is low. Depending on the natural concentration of contaminants for the CCDD facility, you may still be able to dump if the fill is over MAC values.
Are there any trade groups that help CCDD operators?
If you need Clean Construction Demolition Debris support, give A3 Environmental Consultants a call. We’ll work to get your clean fill into the closest, most economical location to save you time and money. Our reports meet the requirements of all lenders and government agencies such as the Small Business Administration (SBA), Housing and Urban Development (HUD) and the United States Department of Agriculture (USDA). A3 Environmental Consultants can be reached at (888) 405-1742 or by email at Info@A3E.com.