Under Sections B,2.(3)14-16…

Under Sections B,2.(3)14-16 with respect to Sampling and Analysis Plan requirements, "Soil" is the referenced term when setting out the minimum sampling parameters, as well as the in-situ and stockpile sampling requirements. The terms "Excess Soil" or "Crushed Rock" are omitted from these sections. It is understood that Section B,2.(1)2 indicates that sampling and analysis is required to be carried out to determine the concentration of contaminants in excavated Soil or Crushed Rock, and that the minimum requirements under Section B,2.(3)14-16 are applicable to Soil only which makes sense from a technical perspective, as Crushed Rock would inherently have limited COCs in most settings, and would also be expected to typically have more consistent chemical concentrations across larger volumes, and is also likely to be subject to processing (the requirements for which are noted to be outlined in Section 6 of the Regulation). As such, alternate sampling frequencies and parameters developed by a QP for Crushed Rock specific to a given project is interpreted to be considered appropriate. However, it is our experience that industry interpretation of this mixed application of terminology is inconsistent. Can the MECP consider clarifying that while Crushed Rock sampling frequencies and parameters do not need to meet the requirements set out for Soil as outlined in Sections B,2.(3)14-16, that per Section B,2.(1)2 (and Section 6 as applicable) there is still a requirement for a QP to establish appropriate sampling frequencies and parameters to assess the Crushed Rock and compare concentrations to the appropriate ESQS. (We note that this comment is directly linked to another comment related to laboratory protocols for analysis of Crushed Rock.)