Soil Relocation in British Columbia: A Practical Guide for Project Teams

Moving soil from one site to another in British Columbia can involve more than excavation, hauling and finding a destination.

Depending on the source site, soil quality, volume, receiving site and other project circumstances, provincial soil relocation requirements may apply.

For contractors, environmental consultants, developers and project managers, understanding the process before material moves can help clarify what testing, documentation, notification and receiving considerations apply to the project.

What Is Soil Relocation in British Columbia?

Soil relocation involves moving soil from a source site to a receiving site.

British Columbia regulates certain soil relocations through the Environmental Management Act and Contaminated Sites Regulation.

The Province also operates the Soil Relocation Information System, which provides information about soil relocation activity and supports the provincial notification process.

Not every movement of soil follows exactly the same regulatory pathway.

The requirements depend on the circumstances of the project and the material being moved.

What Is a Source Site?

The source site is the location from which the soil is being removed.

The history and use of that property can be important.

British Columbia's Contaminated Sites Regulation identifies specified industrial and commercial uses that can trigger requirements when soil is removed, subject to exemptions contained in the regulation.

This is one reason understanding the history of the source site is an important part of soil relocation planning.

What Is a Receiving Site?

The receiving site is the location where the relocated soil will be deposited.

The receiving site is not simply a transportation destination.

The standards applicable to the receiving site are relevant when determining whether soil is considered waste or non-waste in relation to that site.

That makes the proposed destination an important part of the soil relocation assessment.

Does Soil Need to Be Tested Before It Is Moved?

Testing is required in certain circumstances.

For applicable soil removals from properties associated with specified industrial or commercial uses, British Columbia's requirements may require investigation and analysis of the soil.

Protocol 19 provides requirements for investigating, analyzing and assessing soil for relocation from applicable source sites.

Exemptions can apply.

The project's Qualified Professional should determine whether testing is required and what investigation and analytical work is appropriate for the specific project.

What Is Waste Soil?

Under British Columbia's Contaminated Sites Regulation, soil can be 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.

The regulation also contains exceptions, including provisions involving applicable site specific standards and local background concentrations.

This means waste status is not determined simply because soil originated from a commercial, industrial or contaminated site.

The analytical results and proposed receiving site matter.

What Is Non-Waste Soil?

Protocol 19 describes non-waste soil in relation to concentrations below the soil and vapour standards applicable at the receiving site.

Understanding whether soil is waste or non-waste is important because the regulatory requirements for moving the material can differ.

A Qualified Professional should make the appropriate project-specific assessment.

When Is a Soil Relocation Notification Required?

British Columbia requires a Soil Relocation Notification in specified circumstances.

For applicable non-waste soil relocation from certain source sites, notification must be submitted before the soil is relocated.

The regulation also establishes exemptions.

Where notification is required, the Province requires information about the source site, receiving site and soil being relocated.

A Qualified Professional is required to complete and sign the notification.

Project teams should determine whether notification is required before material begins moving.

What Information Is Included in a Soil Relocation Notification?

The Province's current Soil Relocation Notification process includes project information such as:

Source site information

Receiving site information

Quantity of soil proposed for relocation

Soil quality information

Characterization method

Qualified Professional information

Where required, analytical data is also submitted.

The exact requirements depend on the applicable regulatory pathway.

What About Waste Soil?

Waste soil follows a different regulatory pathway from non-waste soil.

Where soil is prescribed as waste, authorization under British Columbia's environmental legislation may be required for its discharge at a receiving site.

Project teams should not assume that the process applicable to non-waste soil also applies to waste soil.

The appropriate Qualified Professional and receiving facility should be involved in determining the requirements for the specific material and project.

What Are High Volume Receiving Sites?

British Columbia's Contaminated Sites Regulation contains additional requirements for sites meeting the regulatory definition of a high volume site.

These provisions include soil management planning and detailed tracking requirements for managed soil.

The regulation requires applicable soil management plans to include procedures for tracking source sites and identifying where soil from each source is deposited at the receiving site.

Specific definitions, thresholds and exemptions apply, so project teams should refer to the current regulation when determining whether these provisions apply.

Why Does the Receiving Facility Need the Soil Information?

A receiving facility needs enough information to evaluate whether the material falls within its acceptance requirements.

Depending on the project, useful information can include:

Soil characterization and analytical results

Source site information

Estimated volume

Known contaminants and concentrations

ARD or other relevant geochemical information

Project timing

Available regulatory and environmental documentation

Providing this information before hauling begins allows the facility to review the material before trucks arrive.

What If the Soil Has a Complex Contamination Profile?

Some projects involve soil with hydrocarbons, metals, salts or multiple contaminants within the same material.

Other projects may involve acid-generating material or ARD leaching profiles.

These characteristics need to be considered when potential receiving options are evaluated.

Cache Creek #1 Logistics can receive and manage a range of complex CL+ and IL+ soil profiles, including hydrocarbon impacted, metal impacted, salt impacted and mixed contamination, as well as acid-generating material and soil with ARD leaching profiles.

Material is reviewed for project-specific acceptance before hauling is arranged.

A Practical Soil Relocation Checklist

Before material starts moving, project teams should understand the following:

What is the history and regulatory status of the source site?

Has the required characterization been completed?

What substances and concentrations were identified?

Is the soil considered waste or non-waste in relation to the proposed receiving site?

Is a Soil Relocation Notification required?

What other regulatory requirements apply?

Has the receiving facility reviewed the material?

What documentation needs to accompany or support the project?

Has transportation been coordinated with the receiving plan?

The project's Qualified Professional should determine the regulatory requirements applicable to the specific project.

Frequently Asked Questions

Can excavated soil simply be moved to another property in BC?

Not necessarily. Soil relocation can be subject to requirements under British Columbia's Environmental Management Act and Contaminated Sites Regulation. The applicable requirements depend on factors including the source site, soil quality and proposed receiving site.

Does all soil relocation require a notification?

No. Soil Relocation Notification requirements apply in specified circumstances, and the Contaminated Sites Regulation contains exemptions.

Who completes the Soil Relocation Notification?

Where a notification is required, the Province requires it to be completed and signed by a Qualified Professional.

Does all soil from an industrial property count as waste?

No. Waste status is determined in relation to the receiving site under the Contaminated Sites Regulation and applicable standards, subject to the regulation's provisions and exceptions.

Should the receiving facility review the soil before hauling?

The receiving facility should have the information it requires to determine whether the material meets its acceptance requirements before material is delivered.

Can Cache Creek review impacted soil for an upcoming project?

Yes. Cache Creek #1 Logistics can review available characterization information and project details for the complex soil profiles within its receiving capabilities and discuss whether the facility is an appropriate option.

Planning a Soil Relocation Project?

If your project involves impacted or complex soil, Cache Creek #1 Logistics can review the available characterization information and project details before material is scheduled for hauling.

Provide the soil characterization, estimated volume, source location and anticipated project timing to begin the receiving review.

Sources and Further Reading

Province of British Columbia, Soil Relocation Information and Guidance

British Columbia Contaminated Sites Regulation, B.C. Reg. 375/96

Province of British Columbia, Protocol 19 for Contaminated Sites

British Columbia Environmental Management Act