I don't see the need for my personal info. comments are comments regardless of who I am.
There is too much focus on RSCs. Excess soils are removed from sites undergoing an RSC as they have to meet the table criteria. The number of RSC sites compared to remediation at contaminated sites is minimal, likely less than 1% RSC sites, yet all this discussion is about the 1% of the sites. Where is some concrete legislation surrounding remediation of sites not going through RSC process. There is no legislative link to the Tables yet everyone is using them. Have the tables be regulated to all remediation sites not just RSCs.
The MOECC needs to define inert fill. You should not be arbitrarily defining excess soils as wastes. Just set the criteria; if Table 2 values of soil and gw are safe enough for a park/residence using groundwater as source of drinking water then have levels meeting table 2 as inert and those exceeding table as a waste. That way someone can test the soil if unknown concentrations exist and deem it a non-waste....inert fill. Defining something depending on how its used is ridiculous....if the soil is brought to a landfill it is a waste but put on a farmers field it is not. Having it defined as a waste going to a landfill means the landfill has to put it in the footprint but in many cases they could use as berms, landscaping or just pile on the buffer land the same as on the farm field. that's the way to stop this material from going to the landfill footprint and the environment remains protected as there are surface and ground water monitoring programs with a responsible party with financial assurance in the event something happens. I prefer these soils going to a landfill (buffer lands) rather than the farm field across the road from where I live and I hope that my well doesn't get contaminated given no one is monitoring the situation. if you were truly trying to protect human/environmental health this material would not go to a farm field. So for the sites where the excess soils did go to farm fields why was this soil removed in the first place given agriculture use is just as restrictive as residential....it had to have exceeded table 2 which is drinking water exceedances and therefore risk for potable wells.
I agree there needs to be a registry as currently no one is watching. Don't count on by-laws or municipalities to do anything. RSC reg has been around for over 10 years and many townships are not even aware of 'applicable law' Hope you do better educating this time as I'm sure there are lots of houses built on contaminated sites post RSC reg.
I don't see how this reg will 'reduce greenhouse gas emissions associated with the movement of excess soils' I'm certain there has been no such study for this. whether it is transported to a landfill site or a farm field is irrelevant. Both are local. check your clothing, food, appliances, cars and car parts.....these things come from across the globe so your assertion that some dump trucks going to a farm field rather than a landfill site is better for the environment is meaningless to say the least.
[Original Comment ID: 209145]
Soumis le 8 février 2018 12:59 PM