Comment
The proposed regulation states that if after completion of a Phase One Environmental Site Assessment and associated evaluation, rationale and certification by a QP, it is determined that intrusive testing is not required to sample and analyze the quality of the excess soil to be removed from any part of the project area, excess soil characterization would not be required. It is felt that while complete excess soil characterization would not be required, there should be a required minimum soil characterization. This may be as simple as three represented samples submitted for inorganic parameters and a leachate sample to confirm that the soil is non-hazardous and no risk to the receiving site’s groundwater.
[Original Comment ID: 209787]
Submitted February 8, 2018 2:00 PM
Comment on
Excess soil management regulatory proposal
ERO number
013-0299
Comment ID
278
Commenting on behalf of
Comment status