Thank you for this opportunity to comment. I applaud the agency for your efforts and diligence. This is truly an excellent approach to beneficial reuse of excess soil.
I have read the Act and the regulations and amendments and think this commendable. I like the BRAT especially. Would it be possible that the owner/operator/processor/end user to complete the BRAT and have it verified by the QP? Saves a lot of money.
I didn't see how excess soil processing facilities would be treated specifically. For example, soil drying, decanting of liquid soil, solidification, etc. Could this be defined further?
Could appropriate excess soil be used for backfilling in sand pits/mines, quarries, etc.?
Can the excess soil be more liquid at the disposition site which will then allow for evaporation or other separation technologies to afford useable dry material onsite or at an approved offsite facility?
I would be interested in a better definition of commercial use vs industrial use.
Submitted May 24, 2019 10:33 PM