Comment
Proposed Amendment 8 (iii): With regards to select substances added to soil to facilitate excavation (e.g. drilling muds, solidifying agents), the contents of these substances are often proprietary in nature. While content/contaminant inclusions in this material can be requested from the vendor, it is unlikely to be shared in sufficient detail to ensure that the substances are identified or appropriately characterized in a sampling and analysis plan. A QP cannot ensure or take on the liability to ensure to a receiver that the materials have been sufficiently characterized due to these unknowns, but can simply communicate the presence of an added substance in the soils to a potential receiver for them to decide if they will accept it.
Submitted November 21, 2024 3:52 PM
Comment on
Enabling greater beneficial reuse of excess soil
ERO number
019-9196
Comment ID
122058
Commenting on behalf of
Comment status