Comment
Obtaining representative sampling results of aggregate materials, where required (i.e. from PCA/APEC) is not possible. Exceedances are expected in this material - where sampling is required, it will generate waste where it would otherwise be suitable for reuse in a similar environment. Normal means and methods for sampling this material (as if it were excess soil) will not generate results that are representative of the material as a whole - when collecting the sample for laboratory analysis, only the fines would be collected, rather than a representative sample in the field. Larger rocks would be excluded rather than sent to the laboratory for crushing (to be analyzed as crushed rock), as crushing this material will also not be representative of the quality of the material. Due to the heterogeneous nature of the material, one sample collected that indicates an exceedance may not be representative of the material two feet away. Statistical analysis or point-source delineation of exceedances is not an appropriate method for determining the boundaries of potential waste in this material. Additionally, the conservative ESQS, including PHC F2 ESQS, would be expected to result in larger volumes of waste than necessary. The MECP should consider reuse of this material as aggregate so long as the material is free of visual or olfactory signs of contamination.
Submitted November 21, 2024 3:51 PM
Comment on
Enabling greater beneficial reuse of excess soil
ERO number
019-9196
Comment ID
122057
Commenting on behalf of
Comment status