THINGS TO CONSIDER
Before excess soil is transported to a receiving site, it should be confirmed that there is a Fill Management Plan (FMP) for the receiving site. The FMP should be completed by a QP, once a site assessment has demonstrated the receiving site is suitable for excess soil placement.
Fill Management Plans, or at least a number of FMP components, can be incorporated as part of the requirement for a site alteration permit.
A complete Fill Management Plan, in accordance with the MOECC BMP, addresses a broad range of issues, including:
- Invasive species;
- Soil quality and sampling;
- Dust and noise;
- Site security;
- Traffic and transportation;
- Record keeping;
- Water quality protection.[1]
For the detailed list of components, see Best Management Practices below.
[1] Ministry of the Environment and Climate Change. Management of Excess Soil – A Guide for Best Management Practices (https://www.ontario.ca/page/management-excess-soil-guide-best-management-practices)
MOECC BEST PRACTICE
MANAGEMENT
As written in the MOECC BMP, a Fill Management Plan: “…outlines the overall condition and operation of the Receiving Site and should include the following:
- procedures to prevent the introduction of invasive plant or animal species;
- copies of any documentation regarding municipal or Conservation Authority licences/permits, provisions of provincial plans which apply to the site, and any requirements of provincial ministries;
- identification of appropriate soil quality and soil types for excess soil to be received at the site as determined by the QP based on site location/sensitivity, anticipated land use, ground water use/sensitivity, pre-existing site conditions or other factors as to ensure that there is no likelihood of adverse effect;
- dust and noise control measures;
- site security measures;
- Traffic and Transportation Management Plan;
- protocol for incoming excess soil specifying:
- that each incoming load have documentation signed by the Source Site QP that includes appropriate and representative soil analyses confirming the soil quality is acceptable for the Receiving Site;
- that visual and olfactory inspections will be conducted of all incoming loads to screen for odour, visible staining or debris; and
- contingency measures for load rejections.
- a record keeping system to create and store written documentation to track each incoming load of excess soil including records of:
- date and time of arrival of the load to the Receiving Site;
- name and location of the Source Site;
- volume of excess soil received;
- documentation from the Source Site signed by a QP, including soil analytical results;
- confirmation by the Receiving Site QP acknowledging that the incoming excess soil is acceptable for receipt at the site;
- rejections of any loads of soil due to visual inspection or review of analytical results; and
- documentation to the Source Site owner/operator and QP, once excess soil is received, confirming the soil was received and the type, quality and quantity was appropriate.
- clear signage at the site, which identifies a contact name, hours of operation (with reference to local by-laws where appropriate), and daily and after-hours contact telephone numbers;
- stormwater management plan, which includes provisions to prevent ponding and flooding;
- erosion control and run-off controls sufficient to prevent impacts to drainage and sediment discharge to nearby watercourses or stormwater systems, and to ensure materials remain where placed;
- audit sampling protocols consisting of:
- sampling protocols (designed by a QP) sufficient to produce results that would be representative of the volume of excess soil that is being received from each Source Site; and a
- contingency plan to identify actions that are to be taken in the event that audit sampling or other information identifies concerns with soil quality from a Source Site.
- soil placement/segregation protocol sufficient to identify where excess soil from each Source Site has been placed, such that it can be assessed if required.” [1]
[1] Ministry of the Environment and Climate Change. Management of Excess Soil – A Guide for Best Management Practices (https://www.ontario.ca/page/management-excess-soil-guide-best-management-practices)