Case Study: Ensuring Compliance at Soil Storage Site

Project: Regulatory Compliance at Soil Storage Facility

Background: New guidance from the MOE around excess soil management raised concerns for the client who owned a soil storage facility in Toronto. The client had questions regarding their site and compliance with the guideline. In order to proactively meet the new guideline, AEL was retained to assist the client in implement the best management practices (BMP’s) outlined by the MOE.


The team uses soil sample testing results to ensure compliance.

Approach: Multiple steps were involved in this project. First, the site was screened to determine background levels of contaminants anticipated to be of concern in excess fill (PHCs, VOCs and metals). AEL sampled soil and groundwater from 3 locations. Soil samples were tested on-site for PHCs, VOCs and metals using AEL’s industry leading on-site screening technology, and confirmatory samples sent to the lab. On-site testing was used to reduce the number of samples sent to the lab, and saving cost for the client.

Second, AEL and the client designed an erosion control plan for the site, including new surface water drainage control ponds. AEL used GIS to outline the changes to be made, allowing for a visual picture of the finished plan.

Third, a survey was completed of the site, using high resolution GPS (the hat method). The current site, and newly configured settling ponds were mapped, to show the configuration and outline control measures in place.

Fourth, the first stockpiled soil from the newly configured settlement ponds was audited. Sample numbers were determined from O. Reg. 153/04 soil stockpile sampling frequency. A total of 77 samples were field screened for PHCs, VOCs and metals. 15 of the highest samples were then submitted for laboratory confirmation. Through the use of on-site testing, AEL were able to identify any portion of the pile that did not meet Table 2 residential criteria (Table 2 was chosen as the soil was to be used on a residential, potable water site), and segregate only a small affected portion of the total stockpile. Had only 15 samples been submitted, a much larger portion of the stockpile would have needed to be removed. Client saved significant amount of money in laboratory and disposal costs associated with delineation, removal and disposal at a landfill facility.

Finally, AEL completed an Operations and Maintenance Plan for the site, suitable for submittal to the MOE outlining the site features and procedures for appropriate storage and re-use of excess soil.

Results: Ensured that the client is responsible in managing excess soil in an environmentally safe manner in accordance with all applicable regulations.

Benefits: Client saved significant amount of money in laboratory and disposal costs associated with delineation, removal and disposal at a landfill facility by using on-site testing. Client’s site now conforms to the MOE’s BMPs outlined in the guidance document, and the baseline study provides a level of due diligence once the client’s use of the site is complete.

For a copy of the MOE Best Practices for Excess Fill Management, contact AEL.