Excess soil meeting Table 1…

ERO number

019-4801

Comment ID

59580

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

Excess soil meeting Table 1 may be considered appropriate for reuse in sensitive areas, but it should not be assumed that this material is clean inert fill. The testing ratios for excess soil are not extensive enough to cover the entire source site. For example, a roadside ditching program may be considered harmless, and testing in reaches spaced at 200 m apart still have the possibility and probability of missing accident sites where fluids from vehicles have leaked and leached into the soils. Soils from agricultural fields will contain pesticides and herbicides and artificial/manufactured fertilizers that are inappropriate for placement below the groundwater table.
Quarries that are allowed to mine below the groundwater table are no different that a water well, only on a magnitude of millions of times the size. When a well owner abandons a water well, they must follow O. Reg. 403, which has strict controls on the materials and methods for decommissioning. The same strict standards should apply in the case of rehabilitation of a pit or quarry below the water table, including the areas surrounding the sites where surface water may be tributary to the sites; and, pits and quarries that do not extend to the groundwater table are not be acceptable sites for excess soils if surface water must traverse these sites, since some of the water will also infiltrate downwards to the aquifers.
Thank you for accepting comments on this important topic.