How to Complete and Submit the Illinois LPC-663 Soil Certification Form

The Illinois LPC-663 form is an Illinois EPA certification that a Licensed Professional Engineer or Licensed Professional Geologist signs to confirm that soil from a “potentially impacted property” is uncontaminated and safe to deposit at a Clean Construction or Demolition Debris (CCDD) fill operation or an Uncontaminated Soil Fill Operation (USFO). You need it whenever the source site has a history or surrounding context that suggests possible contamination. Without it, no permitted fill facility in Illinois will accept the load. The form is a free PDF from the Illinois EPA website, and the completed packet goes directly to the receiving facility with the soil shipment.

When the LPC-663 Applies Instead of the LPC-662

Illinois uses two soil certification forms, and picking the wrong one will get your load turned away at the gate. The LPC-662 is the simpler version: the source site owner or operator signs it, certifying the property is not potentially impacted and the soil is presumed uncontaminated. No laboratory chemical analysis is required for an LPC-662, just pH testing and a description of current and past site uses.

The LPC-663 kicks in when the source site qualifies as a “potentially impacted property” under 35 Ill. Adm. Code 1100. The regulation defines this as property where a historical or current use, or contaminant migration from a nearby site, increases the presence or potential presence of contamination.¹ Once a property carries that designation, the soil must be evaluated, sampled, and certified by a PE or PG on the LPC-663 before it can go to any fill site.

If a PE or PG evaluates the site and determines it is not potentially impacted, the project can drop back to the LPC-662 process. The owner or operator signs the LPC-662 and attaches the professional’s supporting documentation confirming the property does not require chemical testing against the Maximum Allowable Concentrations (MAC) table.¹ Getting that call made up front can save significant lab costs if the site turns out to be non-impacted.

What Makes a Property “Potentially Impacted”

Three factors drive the determination: the current use of the property, the prior uses of the property, and the prior and current uses of adjoining property.² Common triggers include:

Commercial or industrial operations such as manufacturing plants, auto repair shops, dry cleaners, or gas stations that handle chemicals or petroleum products.
Any current or former underground or aboveground storage tanks on the property.
Past use of the site for waste treatment or disposal.
Any government notice of environmental violations tied to the property.
Private wells on site that exceed Illinois groundwater quality standards.
Transformers or capacitors manufactured before 1979 that were used, stored, or disposed of on site.
Fill material previously brought to the site from an unknown source.
Adjacent properties with uses that could cause contaminant migration onto the source site.

Where to Download the Form

The LPC-663 is available as a PDF on the Illinois EPA’s CCDD forms page at epa.illinois.gov/topics/forms/land-forms/ccdd.html.³ There is no filing fee.

What Goes on the Form and in the Packet

The form collects three categories of information: site identification, site history and context, and laboratory analytical data. Missing or inaccurate entries in any category give the receiving facility grounds to reject the load.

Site Identification

You need the exact street address of the source site, GPS coordinates, and parcel identification numbers. A street address alone is not enough for large or irregularly shaped parcels. Owner and operator contact information for the source site is also required so accountability traces back to the people responsible for the excavation.

Site History and Soil Description

The form requires a written description of why the soil is being excavated and a detailed account of current and past site uses. This narrative is where you document whether any of the triggers above apply. Physical descriptions of the soil (color, texture, and any visible anomalies) supplement the chemical data. High-quality maps showing sampling locations are also part of the package, tying the lab results to specific areas of the site.

Laboratory Analytical Results

For soil from a potentially impacted property, a PE or PG certification under Section 1100.205(a)(1)(B) must include analytical testing results showing two things: the soil pH falls within the allowable range of 6.25 to 9.0, and chemical constituents comply with the MAC values in Subpart F of Part 1100.² Attach the full laboratory report, not just a summary.

Sampling and Laboratory Rules

The PE or PG determines which chemical constituents to test for and where to collect samples based on a site-specific evaluation. The regulation does not prescribe a one-size-fits-all sample count or grid pattern.⁴ Several rules constrain how samples are handled once collected:

Soil samples from a potentially impacted property cannot be composited before analysis. Each sample must be tested individually.
Results from individual samples cannot be averaged to meet a threshold. Every sample must independently comply with the MAC values.
All quantitative analysis must be performed by a laboratory accredited under 35 Ill. Adm. Code 186.
Chemical analysis must follow USEPA Publication SW-846 test methods. If a SW-846 method cannot detect a constituent at the required concentration, the lab may use a modified method to reach the lowest practical detection level.

The lab documentation package must include chain-of-custody records, a copy of the full analysis, the laboratory’s accreditation status, and a certification from an authorized lab representative confirming the analysis followed accreditation rules.⁴ Missing any of these elements gives the facility a reason to refuse the soil.

The MAC Table

The Maximum Allowable Concentrations table is the benchmark every sample is measured against. It lists upper limits in milligrams per kilogram for a wide range of chemicals: metals like arsenic, barium, and chromium; volatile organics like benzene and toluene; pesticides like DDT and chlordane; and dozens of other compounds.⁵ Some values vary by location. Arsenic limits differ between metropolitan statistical area (MSA) counties and non-MSA counties, and certain polycyclic aromatic hydrocarbons have separate thresholds for properties within Chicago city limits, within other MSA populated areas, and outside populated areas.

If your soil contains a chemical not listed on the published MAC table, you can request a chemical-specific concentration from the Illinois EPA.¹ Do not assume an unlisted chemical has no limit. That assumption will get the certification rejected.

Who Can Sign the Form

Only a Licensed Professional Engineer or Licensed Professional Geologist registered in Illinois can sign the LPC-663. Their license number and official seal must appear on the form.¹ By signing, the professional certifies that the soil does not contain chemical constituents above MAC values and that the pH is within the 6.25 to 9.0 range. The PE or PG is staking their license on the accuracy of the sampling plan, the lab results, and the conclusion. Before hiring one for this task, confirm they have experience with CCDD soil certifications; general engineering or geology credentials alone do not mean the professional understands the specific MAC table comparisons and sampling protocols Part 1100 requires.

How to Submit the Completed LPC-663

The finished packet (signed form, lab reports, chain-of-custody records, maps, and site history documentation) goes to the owner or operator of the CCDD fill operation or USFO receiving the soil. The form does not get filed with the Illinois EPA first. The receiving facility reviews the packet for completeness and accuracy before any soil is unloaded.

Coordinate with the receiving facility before showing up with a loaded truck. Facilities have their own intake procedures, and many want to review the paperwork in advance. If the facility identifies missing information, incomplete lab documentation, or pH results outside the 6.25 to 9.0 range, the load gets turned away. The facility must provide the driver with a written rejection notice explaining the reasons.

What Gets a Load Rejected at the Gate

Even with a completed LPC-663, soil can be rejected. The most common triggers:

Photoionization detector (PID) or flame ionization detector (FID) readings above background. Facilities screen incoming loads, and any reading above background results in automatic rejection with no tolerance threshold.¹
pH outside the 6.25 to 9.0 range, regardless of what the certification says.
Incomplete documentation: missing lab accreditation status, absent chain-of-custody records, or an unsigned form.
Visual or odor discrepancies. If the soil looks or smells different from what the certification describes, the facility can reject at its own discretion.

A rejected load cannot simply be taken to a different fill site. Under the regulations, rejected soil must go to a permitted landfill unless the reasons for rejection are corrected and the soil is re-tested and re-certified on a new LPC-663.¹ That means additional lab costs and delays.

Record Retention

Owners and operators of CCDD fill operations must keep all soil certification documentation for at least three years after receiving each load. If the documentation relates to an appeal, litigation, or other disputed claim, the retention period extends to at least three years after the final disposition of that dispute. Copies must be available to the Illinois EPA and local government agencies for inspection during normal business hours.⁶ Source site owners and the certifying PE or PG should maintain their own copies for at least the same period.

Penalties for Noncompliance

Using soil other than uncontaminated soil as fill at a CCDD operation is prohibited under 415 ILCS 5/22.51(g), and operating a fill site without a permit or in violation of permit conditions violates subsection (b).⁶ A knowing violation of the Illinois Environmental Protection Act’s waste disposal provisions is a Class A misdemeanor, which carries up to 364 days in jail and fines. Civil penalties and cleanup orders can compound the exposure. If contaminated soil ends up in a quarry or excavation, the responsible parties may be on the hook for the full cost of remediation.

Filing an LPC-662 when the property actually qualifies as potentially impacted, whether through ignorance or intentional misrepresentation, creates the same liability. The simpler form skips the chemical analysis that would have caught contamination. When in doubt about whether a property is potentially impacted, hiring a PE or PG to make that determination is far cheaper than the consequences of getting it wrong.

1
Illinois Environmental Protection Agency. Clean Construction or Demolition Debris (CCDD)
2
Illinois Pollution Control Board. Title 35 Illinois Administrative Code Part 1100
3
Illinois Environmental Protection Agency. Clean Construction or Demolition Debris (CCDD) Forms
4
Illinois General Assembly. 35 Illinois Administrative Code 1100
5
Illinois Environmental Protection Agency. Summary of Maximum Allowable Concentrations
6
Illinois General Assembly. 415 ILCS 5/22.51