For consideration by the…

For consideration by the Ministry, a different philosophy should be applied to SPLP requirements. Since excess soil reuse is not a Brownfield scenario where the SCS can be considered clean-up criteria where potentially larger volumes of soil at those concentrations may occur; rather, in an excess soil context these would represent max concentrations not representative of bulk soil quality, with mean concentrations typically much lower. This makes the SPLP leaching assumptions overly conservative (and it involves very conservative modeling anyways). Further, practitioner experience through years of Brownfields work indicates that leaching issues are not typically seen unless concentrations are significantly higher than the SCS, and regardless of source size.

In addition, the SPLP is understood (and is preferred) to be analyzed once bulk data is reviewed and site specific COCs are confirmed. With respect to SPLP for VOCs, the hold times at the laboratory are short comparitive to standard bulk analysis timelines, and without rushing bulk data reports (and paying a premium for that rush of 50-100% per sample), laboratory analysis and SPLP hold times leave very little room to obtain, assess and request appropriate SPLP analysis within laboratory permitted hold times. For large projects with a significant number of samples being analyszed and reviewed in real time, this can create major problems related to analysis timing (to be in compliance with the Regulation) in addition to laboratory and QP flagged QA/QC issues.