Dumping clean debris in quarries no threat to environment

This letter is in response to a Chicago Sun- Times editorial this week regarding notices of alleged “violations” issued to permitted clean construction or demolition debris ( CCDD) facilities. The overwhelming majority of notices sent by the Illinois EPA were for the detection of naturally occurring elements such as iron and manganese that are found at these concentrations in uncontaminated soils throughout Illinois. The naturally occurring elements cited in these notices DO NOT constitute a risk to the environment.

By law, CCDD is limited to uncontaminated materials which may only include broken concrete, bricks, rock, stone, reclaimed asphalt pavement or clean soil generated from construction activities. The CCDD program is an environmentally sound, common- sense management tool that benefits Illinois taxpayers by holding down construction costs and preventing needless filling of landfills. The program saves taxpayers millions in additional costs for public works projects while it decreases the number of heavy trucks on congested roadways.

In 2010, when the Illinois Legislature passed the current law related to CCDD, the Legislature charged the Illinois Pollution Control Board with the responsibility of adopting rules that were protective of the environment. The board adopted strong front- end requirements such as environmental and engineering review, soil analytical testing and on- site screening of every CCDD load — making Illinois’ regulations the most stringent in the country. As part of this process, the board twice conducted thorough hearings, accepted testimony and received documentation on the issue of mandating groundwater monitoring at these facilities. Based on the evidence, the board twice rejected mandating such monitoring and the Illinois appellate court recently confirmed their decision.

The operators I represent are committed to the responsible placement of CCDD in accordance with their permits and the rules adopted by the Board. The addition of costly groundwater monitoring mandates for these facilities has been determined unwarranted and should not be further legislated.