Understanding Contaminated Soil Management in British Columbia
Excavating soil is often only one part of managing it.
For construction, redevelopment, infrastructure and remediation projects in British Columbia, soil may need to be characterized before it can be moved off site. The results help determine what is present in the material and which regulatory requirements and receiving options may apply.
For project teams, understanding that process early can help clarify what needs to happen before material starts moving.
What Is Contaminated Soil?
Contaminated soil contains substances at concentrations that require consideration under British Columbia's environmental framework.
The important point is that soil cannot always be classified simply by looking at where it came from or whether contamination is suspected.
Laboratory analysis and the applicable regulatory standards help determine the characteristics of the soil and how it may be managed.
Depending on the site and its history, potential contaminants of concern can include substances such as hydrocarbons, metals, salts and other compounds associated with past or current activities.
Why Soil Characterization Matters
Soil characterization provides information about what is actually present in the material.
In British Columbia, soil testing is required in certain circumstances, including when soil is being removed from a property that has been used for specified industrial or commercial activities. Provincial requirements also provide exemptions in particular circumstances.
Where testing is required, a Qualified Professional plays an important role in the process.
Characterization can identify the substances present and their concentrations. Those results can then be evaluated against the standards that apply to the proposed receiving site.
This is an important distinction.
The question is not simply:
"Is this soil contaminated?"
Project teams also need to understand the characteristics of the material and the requirements that apply to where it may be received.
Waste and Non-Waste Soil in British Columbia
British Columbia's Contaminated Sites Regulation distinguishes soil that is waste from soil that is non-waste in relation to a receiving site.
Under the regulation, soil is generally prescribed as waste in relation to a receiving site when concentrations of substances in the soil or applicable vapour emissions exceed the standards specified for that receiving site, subject to regulatory exceptions including applicable site specific standards and background concentrations.
This means the same soil should not automatically be assumed to have the same classification for every potential destination.
The receiving site matters.
That is one reason characterization and receiving need to be considered together.
What Is a Receiving Site?
A receiving site is the location to which soil is proposed to be relocated.
Determining whether a receiving site is appropriate involves more than identifying a facility or property willing to receive material.
The quality of the soil and the standards applicable to the receiving site are part of the regulatory framework governing soil relocation in British Columbia.
For project teams, this makes the receiving decision an important part of material management planning.
What Happens After Soil Testing?
Once testing is complete, the results are analyzed to determine whether potential contaminants of concern are present and how the soil compares with applicable standards.
From there, the regulatory pathway depends on the material and project circumstances.
For non-waste soil being relocated from a site with a specified industrial or commercial use, a Soil Relocation Notification may be required. Where required, the notification must be completed and signed by a Qualified Professional and submitted to the Province.
There are exemptions, including certain small-volume removals and other circumstances defined by the legislation.
If soil is considered waste, different requirements apply and a waste discharge authorization may be required before it is moved to a receiving site.
Project teams should rely on their Qualified Professional to determine the requirements applicable to a specific project.
Why Receiving Options Should Be Considered Before Hauling
Characterization provides the information needed to begin evaluating potential receiving options.
Before trucks are scheduled, project teams may need to understand:
What material is being moved?
What substances and concentrations were identified?
How much material is expected?
Where did the material originate?
What requirements apply to the proposed receiving site?
What documentation is required?
Having these questions addressed before material starts moving can give contractors, consultants, haulers and receiving facilities a clearer understanding of the project requirements.
Managing More Complex Soil Profiles
Some projects involve material with more than one environmental consideration.
A soil profile may contain hydrocarbons, metals, salts or a combination of contaminants. Other projects may involve acid generating material or soil with ARD leaching characteristics.
These profiles can require careful evaluation when determining an appropriate management and receiving approach.
Cache Creek #1 Logistics can receive and manage a range of complex CL+ and IL+ soil profiles, including material impacted by hydrocarbons, metals, salts and mixed contamination, as well as acid generating material and soil with ARD leaching profiles.
Acceptance of material depends on the specific project and soil profile.
Soil Relocation and Traceability in BC
British Columbia maintains the Soil Relocation Information System to track soil relocation activity across the province.
The Contaminated Sites Regulation also establishes specific requirements for high volume receiving sites. These include soil management planning and detailed tracking of the source sites of managed soil and where material from each source is deposited at the receiving site.
These requirements demonstrate why documentation and traceability are important parts of modern soil management.
Cache Creek #1 Logistics uses its Soil Tracker system to provide a digital chain of custody for loads of soil moving into our care, supporting organized project documentation and visibility.
What Should Project Teams Have Ready?
If you are evaluating a receiving option for impacted or complex soil, having the available project information ready can make the initial conversation more productive.
Useful information can include the soil characterization or analytical results, estimated material volume, source location, project schedule and other available documentation relevant to the material.
The appropriate regulatory requirements should be determined with the project's Qualified Professional.
The receiving facility can then review the information relevant to its own acceptance requirements.
Frequently Asked Questions
Does all excavated soil in BC need to be tested?
No. Testing requirements depend on factors including the history and use of the source site, and exemptions can apply. British Columbia's soil relocation requirements and Protocol 19 should be reviewed to determine whether testing is required for a particular project.
Is all soil from an industrial or commercial site considered waste?
No. British Columbia determines whether soil is waste in relation to a receiving site using the applicable regulatory standards and the concentrations identified in the soil, subject to the provisions and exceptions in the Contaminated Sites Regulation.
Who submits a Soil Relocation Notification?
Where a Soil Relocation Notification is required, the Province states that it must be completed and signed by a Qualified Professional.
Can complex contaminated soil be received at Cache Creek #1 Logistics?
Cache Creek #1 Logistics can receive and manage a range of complex CL+ and IL+ soil profiles, including material impacted by hydrocarbons, metals, salts and mixed contamination, as well as acid generating material and soil with ARD leaching profiles.
Material should be reviewed for project specific acceptance before hauling is arranged.
When should a receiving facility be contacted?
Once sufficient information about the material is available, discussing the soil profile, anticipated volume and project requirements with a potential receiving facility can help determine whether that facility is an appropriate option before hauling is scheduled.
Have a Soil Profile You Need Reviewed?
If your project involves impacted or complex soil, Cache Creek #1 Logistics can review the available project information and discuss whether our facility is an appropriate receiving option.
Contact our team with your soil characterization information, anticipated volume and project details to begin the conversation.
Sources and Further Reading
Province of British Columbia, Soil Relocation
British Columbia Contaminated Sites Regulation, B.C. Reg. 375/96
Environmental Management Act, British Columbia
