The ESQSs for Petroleum…

ERO number

019-6240

Comment ID

77104

Commenting on behalf of

Dillon Consulting Limited

Comment status

Comment approved More about comment statuses

Comment

The ESQSs for Petroleum Hydrocarbons F2 are too low and have resulted in a significant amount of soil to be managed as waste. The Table 3.1 ICC ESQS for PHC F2 is 26 ug/g, while the Table 3 SCS for PHC F2 is 230 ug/g, which is almost 10 times higher. The rationale for such a low PHC F2 ESQS has not been provided and a more reasonable ESQS should be established. There are many road reconstruction and redevelopment projects where the PHC F2 concentrations meet the Table 3 SCS for PHC F2 but do not meet the Table 3.1 ICC ESQS, resulting in a large volume of soils requiring management as waste.