The ESQSs for Petroleum…

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.