Regulation and Permitting of Construction and Demolition Recycling in Illinois

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Tom Hubbard, the Manager of the Disposal Alternative Unit Permit Section at the Illinois Environmental Protection Agency, sheds light on the classification, regulation, and permitting processes for Construction and Demolition (C&D) recycling in Illinois. The article explores the definitions of Clean C&D (CCDD) and General C&D (GC&D), along with the classifications and permissible uses for both types of waste. Additionally, it discusses the conditions under which GC&D recycling is allowed without requiring local siting approval under Section 22.38 of the Illinois Environmental Protection Act.

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Uploaded on Jul 19, 2024 | 1 Views

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REGULATION AND PERMITTING OF CONSTRUCTION AND DEMOLITION RECYCLING IN ILLINOIS TOM HUBBARD MANAGER, DISPOSAL ALTERNATIVE UNIT PERMIT SECTION, BUREAU OF LAND ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

CLASSIFICATION OF C&D IN ILLINOIS THE ILLINOIS ENVIRONMENTAL PROTECTION ACT (ACT) LISTS C&D AS A SUBPART OF MUNICIPAL SOLID WASTE. IT FURTHER DIVIDES C&D INTO CLEAN C&D (CCDD) AND GENERAL C&D (GC&D). THE DEFINITIONS ARE IN THE ACT: SECTION 3.160(A) FOR GC&D AND 3.160(B) FOR CCDD.

GC&D CLASSIFICATION AND USE GC&D IS A WASTE AND MUST BE EITHER REUSED, RECYCLED, OR LANDFILLED. SECTION 22.38 OF THE ACT ALLOWS GC&D RECYCLING WITHOUT REQUIRING LOCAL SITING APPROVAL, PER SECTION 39.2 OF THE ACT, IF SEVERAL CONDITIONS ARE MEET, MOST NOTABLY THAT AT LEAST 75% OF THE GC&D IS RECYCLED* *SOME LANDFILL USES ARE COUNTED AS RECYCLING ALTHOUGH LOCAL SITING IS NOT REQUIRED, A PERMIT FROM THE AGENCY IS STILL REQUIRED.

CCDD CLASSIFICATION AND USE CCDD IS DEFINED TO BE UNCONTAMINATED MASONRY MATERIAL, ASPHALT PAVEMENT, AND SOILS GENERATED FROM C&D. CCDD IS DEFINED TO NOT BE A WASTE AND CAN BE USED AS FILL WITH THE FOLLOWING RESTRICTIONS: MUST BE BELOW GRADE, OUTSIDE ANY SETBACK ZONES, AND COVERED WITH SOIL OR A STRUCTURE WITHOUT ANY PERMITTING REQUIREMENTS* ALSO CONCRETE W/O PROTRUDING REBAR CAN BE USED AS RIPRAP FOR EROSION CONTROL * ANY FILLING OF A MINE, QUARRY, OR OTHER MANMADE EXCAVATION OF A RESOURCE REQUIRES PERMITTING. THERE ARE ALSO SOME OTHER RESTRICTIONS IN SECTION 3.160(B)

POSSIBLE OTHER USES OF GC&D, INCLUDING FINES ALTERNATE DAILY COVER MATERIAL AT A LANDFILL SITE REMEDIATION PROJECTS CAN USE WASTES AS LONG AS THE TACO RESTRICTIONS ARE MET THERE IS A PROVISION IN SECTION 22.54 OF THE ACT TO ALLOW THE AGENCY TO APPROVE USE OF A WASTE WERE IT REPLACES A RAW MATERIAL OR PRODUCT. A BENEFICIAL USE DETERMINATION (BUD) CAN BE MADE FOR SOME WASTES (NON- HAZARDOUS, NO CCP, NO SLUDGES, NO USED OIL, NO PIMW) TO ALLOW ITS USE. THE BUD MUST SPECIFY THE WASTE, HOW IT S MANAGED, AND HOW IT REPLACES A MATERIAL OR PRODUCT.