Comment
Requirements of Registry reporting should match the scope of the project. For both large-scale or small projects, the required reporting is not practical and is significantly onerous (assessment of past uses for many kms and properties does not add value to the projects). Potentially contaminating activities can be identified by a QP through more practical/streamlined approaches, and/or can be mitigated by more robust sampling parameters (i.e., small low risk industrial uses where smaller volumes of soil will become excess can benefit from assessing the potential site COCs). Also, Soil Characterization Reports should also allow for QP flexibility to present data in a meaningful but practical way (i.e., allow for exemption to cross sections for shallow or limited excavation areas or small number of samples that do not).
Submitted December 3, 2022 10:44 PM
Comment on
Amendments to Certain Requirements under the Excess Soil Regulation
ERO number
019-6240
Comment ID
77502
Commenting on behalf of
Comment status