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CCDD Rules and Regulations Training Seminar. Visual Inspection of Incoming CCDD Mitch Mariotti – Prairie Group. Inspections. Section 1100.205 Load Checking
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CCDD Rules and RegulationsTraining 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/special-waste/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 • better visual inspection • better access for PID sample • have a shovel or other implement handy to dig below the surface of the load • 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
