Proposed Amendment 8 (iii):…

ERO number

019-9196

Comment ID

122058

Commenting on behalf of

Dillon Consulting Limited

Comment status

Comment approved More about comment statuses

Comment

Proposed Amendment 8 (iii): With regards to select substances added to soil to facilitate excavation (e.g. drilling muds, solidifying agents), the contents of these substances are often proprietary in nature. While content/contaminant inclusions in this material can be requested from the vendor, it is unlikely to be shared in sufficient detail to ensure that the substances are identified or appropriately characterized in a sampling and analysis plan. A QP cannot ensure or take on the liability to ensure to a receiver that the materials have been sufficiently characterized due to these unknowns, but can simply communicate the presence of an added substance in the soils to a potential receiver for them to decide if they will accept it.