CCDD Rules and
Regulations
Training Seminar
Visual Inspection of Incoming CCDD
Mitch Mariotti – Prairie Group
Inspections
 Section 1100.205 Load Checking

The owner or operator must institute and conduct a load checking program designed to detect
attempts to dispose of material other than CCDD at the facility. At a minimum, the load checking
program must consist of the following components:
 a) Routine Inspections
1) An inspector designated by the facility must inspect every load before its acceptance at the facility. In
addition to a visual inspection, the inspector must use an instrument with a photo ionization detector
utilizing a lamp of 10.6 eV or greater or an instrument with a flame ionization detector, or other
monitoring devices approved by the Agency, to inspect each load. Any reading above zero using any of
these instruments must result in the rejection of the inspected load. In addition, any reading above zero
on any monitoring device used by the Agency during an Agency inspection must result in the rejection of
the inspected load.
2) Cameras or other devices may be used to record the visible contents of shipments. Where such devices are
employed, their use should be designated on a sign posted near the entrance to the facility.

b) Random Inspections
1) In addition to the inspections required under subsection (a) of this Section, an inspector designated by the
facility must conduct a discharge inspection of at least one randomly selected load delivered to the
facility each day. The driver of the randomly selected load must be directed to discharge the load at a
separate, designated location within the facility. The inspector must conduct an inspection of the
discharged material that includes, but is not limited to, additional visual inspection and additional
instrument testing using the instruments required under subsection (a)(1) of this Section. Any reading
above zero using any of these instruments must result in the rejection of the inspected load. In addition,
any reading above zero on any monitoring device used by the Agency during an Agency inspection must
result in the rejection of the inspected load.
2) Cameras or other devices may be used to record the visible contents of shipments. Where such devices are
employed, their use should be designated on a sign posted near the entrance to the facility.
Visual Inspection
Now here’s what that should look like in the real world:
 At a minimum:


calibrate your PID per manufacturer’s instructions
look for obvious signs of color, odor, and disqualifying debris

does any part of the load look discolored/stained by liquids or other material?






powders or dusts
bright or unusual colors
smoke or fumes
sludge
liquids of any kind
any odors (even if faint)
 gasoline or diesel fumes
 chemical odors
 strange or offensive odor

any other inappropriate or disqualifying debris
 pipes sticking out
 drums or other containers
 hazardous placards or other markings

remember that the CCDD definition is a rule and not a suggestion
PID Inspection
Now here’s what that should look like in the real world:
 At a minimum:
 with the PID, sweep/cover as much of the surface of the load as possible
 zero means zero



it doesn’t mean 0.5 or 1 or 2 or anything else
if the meter moves, reject the load
other things to watch out for, courtesy of SWANA:
 (loads) “…that have an unusual appearance, create an offensive odor, or appear to
contain high moisture levels are good candidates for closer examination…”
 “Quantities of finely divided or granular material, powders, dust, and dried solids
all should be investigated…”
 “Soil or sod in the (load) may indicate that the (load) resulted from a spill…”
- vehicle rollover clean up for example
1Solid
Waste Association of North America – “Waste Screening at Municipal Solid Waste Management Facilities Training Manual”
Definitions
Now here’s what that should look like in the real world:
 At a minimum:

The definition of “Clean Construction & Demolition Debris“, one more time
for good measure:
"Clean construction or demolition debris" means uncontaminated broken concrete
without protruding metal bars, bricks, rock, stone, reclaimed asphalt pavement,
or soil generated from construction or demolition activities.”

Very concise definition leaving little open to interpretation
“Clean construction or demolition debris does not include uncontaminated soil
generated during construction, remodeling, repair, and demolition of utilities,
structures, and roads provided the uncontaminated soil is not commingled with
any clean construction or demolition debris or other waste.”

What the heck does that mean?
Source: Title 35: Environmental Protection, Subtitle J: Clean Construction Or Demolition Debris, Chapter I: Pollution
Control Board Part 1100, Clean Construction Or Demolition Debris Fill Operations, Section 1100.103 Definitions
Not approved CCDD
Now here’s what that should look like in the real world:
 At a minimum:

Notice that the definition of “Clean Construction & Demolition Debris” does
not include:







trees, brush, tree roots, landscape waste of any kind
concrete with protruding metal bars
trash or garbage of any kind
drums, barrels, metal of any kind
refrigerators, washers, dryers, dishwashers, etc.
mattresses, box springs, etc.
old cars, ready-mix trucks, boats, aircraft, etc.
I think you get the point!
Guidance
Now here’s what that should look like in the real
world:

Want more guidance? - Check out the IEPA’s
webpage “Do I Have a Special Waste?”

http://www.epa.state.il.us/small-business/specialwaste/index.html
Inspections
Now here’s what that should look like in the real world:
 Recommended, in addition to minimum requirements:

inspect the load from a platform/structure that provides a height advantage



have a shovel or other implement handy to dig below the surface of the load




better visual inspection
better access for PID sample
dig as deep as possible & disturb the pile
any vapors likely to be detected by your PID will most likely be present below
the surface
any vapors that may have been present on the surface of the load are likely to
have already evaporated
record inspections with video or still camera if possible

make sure you post signs
Inspect After Load is Dumped
Now here’s what that should look like in the real world:
 Ideally, in addition to the minimum standards & recommend procedures:

inspect the load again after it has been dumped


greater likelihood of catching unauthorized materials
use the PID
 greater likelihood of PID detection
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections
Inspections