I do feel that the source…

Numéro du REO

013-5000

Identifiant (ID) du commentaire

31630

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

I do feel that the source site (where excess soil comes from) should be a complete history of the site and not just the past couple of decades.
The qualified person that determines/controls/tracks the movement of the soil should be educated and need to update their qualifications on a regular basis.
The record keeping of the excess soil movement and testing should not only be kept by the stakeholders/developers but also a copy should be filed with each municipality/city/or government body for at least 20 years in case contamination is noted in the future.
****MOST IMPORTANTLY, using old quarries or depleted gravel pits including those created prior to the Aggregate Resources Act should not be considered as a site to dump excess soil because all too often these quarries/pits are dug to a depth that is much too close to the water table/aquifers; thereby, placing groundwater/aquifers/watersheds at an increased risk of contamination. Once an aquifer is contaminated there is no means to fix it.
**** ANY GRAVEL PIT OR QUARRY (aggregate source), whether licensed or not, that has been dug to a depth that is below the ground water level or even a couple meters above the groundwater level should NOT be utilized for the purposes of dumping excess soil at any time due to the risks of contaminating precious and highly vulnerable aquifers/watersheds. These quarries should be allowed to fill naturally with water and this in itself would greatly benefit the environment and ensure the least risk of contamination of our precious aquifers and connected ecosystems.
I also feel that an outside monitoring agency should conduct random visits and testing of both the generating sites and the receiving sites of excess soil and to randomly check the record keeping of the soil movement and testing.
Also, there should be a percentage of tipping fee dollars that would go to each municipality or some government body to assist with the costs of random inspections and any clean up of contamination that could occur due to poor testing, poor recording keeping, corrupt business practice and human error. After all, this proposal asserts that overall it will be a cost saving regulation that would benefit the developers/haulers/site receivers; thus, an extra fee imposed should not deter compliance.
SAR and EC should not be excluded from Table 1 and it should be considered that it would soak or leak to deeper depths; thereby, increasing risks to groundwater.