Comment
Will all receiving sites (for beneficial reuse and waste sites) have to register with MOECC? Can there be a registry for source sites to locate nearby landfill and beneficial reuse facilities and minimize travel distance?
“The elements of the attainment approach were developed to ensure that the soil results from a single population and require that the 90th percentile and the 95% upper confidence level of the mean of the data set meet the applicable excess soil reuse standards”
How is the single population defined? Area, depth etc.?
Can the MOECC work closely with City districts and Municipalities to allow for backfilling of soil. meeting property use standards except that of EC/SAR standards? As Cities and Municipalities constantly make use of road salting activities during the winter months.
Will the O.Reg 153 standards remain in place? The soil standards from the Proposed Excess Soil Regulatory Package proposed a different set of standards referring to Tables A-F and were found to be far more stringent than the current O.Reg 153/04 standards and therefore do not promote the sustainability framework of maximizing the ability for reuse. Which standards will apply, the O.Reg 153 Tables 1-9 or Tables A-F like previously proposed?
The responsibility of the BRAT tool on the source site QP may not be practical. Gathering all the required information seems more fitting for the receiving site QP.
Thank you,
Karim
Submitted June 15, 2018 6:03 PM
Comment on
Excess soil management regulatory proposal
ERO number
013-2774
Comment ID
5603
Commenting on behalf of
Comment status