Section 2) Enhanced reuse…

Section 2) Enhanced reuse opportunities for salt-impacted soil (Section D, Part I in the Soil Rules)

Comment
It is indicated that a site plan needs to be needs to be prepared by a landscape architect but there is a different paragraph for agricultural lands. Is a site plan required for placing soil on agricultural lands? Is there a volume limit where the site plan is not required?

Section 9) Other clarifications and corrections

Under Regulation second bullet "Clarify under section 3 of the regulation that if excess soil is being finally deposited at a landfill property, outside of the fill area, for a beneficial purpose (such as building berms) consistent with the waste ECA and site plan, it is not designated a waste."

Comment
Can the MECP further clarify if the excess soil being referred to is only soil meeting Table 2.1 (clean soil as per the Soil Rules) or if soil with some chemical parameters exceeding Table 2.1 is also allowable to be beneficially reused on the landfill property, either on the fill area or outside of the fill area?

Section 9) Other clarifications and corrections

Under Soil Rules second bullet "With respect to leachate analysis, clarify that if petroleum hydrocarbons and metal parameters are only being sampled because of the mandatory sampling and analysis plan requirements (i.e., they were not also associated with a potentially contaminating activity), they do not need leachate analysis as well."

Comment
Agree. Leachate analysis should be tailored to the chemicals likely to be observed from past/current land use.