Sampling Frequency is too extensive:
- 1/200m3 for the first 10,000m3
- 1/450m3 afterwards becomes very onerous on the source site.
As an example of the Crosstown LRT Project; there is an estimated 2 million m3 of soil to be excavated, costing an estimated $2.2 million on sampling costs ONLY. This initial cost will discourage source sites in conducting soil characterization and sampling plans and it may even be less expensive to just remove the excess soil as waste, which defeats the purpose of the new proposed regulations.
Suggestion: create a sampling frequency that takes into consideration the depth of excavation. For example, along the Crosstown LRT, the excavation will be reaching 30+ meters below ground surface, in some areas. Once the contamination is confirmed to be absent at shallower depths, the frequency should be reduced significantly (~1/1000 m3).
Submitted June 17, 2019 11:19 AM