On large infrastructure…

On large infrastructure tunnelling projects, the current liquid soils (including solidifided liquid soils) storage capacity limits within a project area pose a major constraint due to the significant volumes of soil generated over a short period of time. Storage capacity of 10,000 m3 for liquid soils on-site are exceeded quickly (i.e., in less than 1 week) where between 1,500 and 2,000 m3 of liquid soils (crushed shale with water and lubricating agents) can be generated daily, and where soil processing (solidification) and sampling is occurring onsite to meet project and receiver requirements. Can the MECP consider adjusting the language in the Rules for Soil Management and Excess Soil Quality Standards, Section C 1.(2) paragraph 2 where it states "No more than 10,000 cubic metres of liquid soil, processed or dewatered or solidified soil and process residues may be present at the site at any one time." Please consider amending the storage capacity limits related to processed / solidified soils as it relates to large infrastructure projects; liquid soils are often solidified on these projects almost immediately following removal and commonly meet slump as they are placed into storage. If changes are not made to the storage capacity, there are significant cost and schedule delay implications for current and future tunnelling projects; within the current limits, there is no excess storage capacity available to account for any type of delay in the liquid soils system (e.g., trucking or equipment, receiver site constraints, or sampling result delays), and if a delay occurs, clean soils may need to be managed as waste to avoid tunnelling shut-down (which has significant cost implications at the project scale). Also, we note that landfilling will not be possible after 2025 for much of the liquid soils due to landfilling restrictions in the Regulation, and may result in even further significant project delays.