Disposal at sea permit application guide: permitting process for excavated material, chapter 3.1

Official Title: Disposal at Sea Permitting Process for Excavated Material, Chapter 3.1, Step I: Pre-application

3.1.1 Consult with Disposal at Sea Program regarding proposed project

If you are planning a project that may involve disposal of excavated material at sea, contact your nearest Disposal at Sea Program regional office listed in Appendix A as soon as possible to ensure that all pre-application requirements are completed. If you are planning to apply for a multi-site permit, you should be aware that steps 3.1.2 to 3.1.5 may come later in the process, hence it is essential that you contact the nearest Disposal at Sea Program regional office for further guidance pertaining to multi-site permits.

Prior to being considered and assessed for a permit, candidate material must first be demonstrated to meet the definition of inert, inorganic geological matter (known as "excavated material" in this guide) that is uncontaminated. Appendix E provides detailed information on excavated material characterization.

3.1.2 Submit project and site information to help inform sampling approach

Your project description submission should include:

• purpose of project
• who is involved, and their roles
• scope of project, as a minimum:
  • excavation area
  • transport to and from the disposal site, and
  • disposal activity
• general location map
• detailed site map
• disposal site map
• project schedule

The information you submit must confirm that only excavated material, unaffected by known contaminant sources, and with chemical concentrations no greater than those naturally found in geologically similar material, remains at the site as outlined in Appendix E.

Preliminary site information should provide an overview of the project environment, the project’s purpose, and identify such factors as:

• excavation site(s) description and maps
• volume (place measure) and known physical and chemical characteristics of the material to be disposed
• current and historical site uses or events that could impact quality of excavated material
• current and historical uses of, or events at, adjacent sites that could impact quality of excavated material
• excavation site characteristics or activities that could affect movement of contaminants (for example, site stratigraphy and hydro-morphology, sampling or drilling efforts conducted to date)

Much of this information may be available in an initial site assessment (for example, a Stage 1 or Phase 1). If a site has required a Stage 2, more detailed site assessment, or if any remediation or site clean-up has been required at the site, that disturbed material may not be considered for disposal at sea. The information you submit must confirm that only in-situ undisturbed, inorganic geological material, unaffected by known contaminant sources, and with chemical concentrations no greater than those naturally found in geologically similar material, remains at the site, as outlined in Appendix E.

Related links

• Appendix C: Disposal site selection
• Appendix D: Data requirements for excavated material

3.1.3 Develop and submit sampling plan

Sampling is required in order to characterize the excavated material. You must contact the nearest Disposal at Sea Program regional office listed in Appendix A prior to developing a sampling plan to ensure that sampling will appropriately characterize the excavated material. We can also provide guidance on the preparation of a sampling plan, including the collection and handling of samples, essential field information, and collection and preparation of samples for analysis. Contaminants should be analyzed according to the standards of the minimum sample analytical requirements for metals, and physical and organic parameters provided in Appendix C.4.

The sampling plan should:

• outline the project proposal
• set out the study objectives
• detail the proposed sampling, analysis and quality assurance/quality control procedures (QA/QC)

Once drafted, the sampling plan is submitted to your nearest Program office for review. It is critical that you have the Program's endorsement of the sampling plan in advance of sampling. You may be required to collect additional samples or supporting information if you do not have agreement from us on the sampling approach or fail to follow our sampling advice.

Prior to beginning to sample or mobilizing sampling equipment, you must ensure that the site is suitable for sampling (for example, no surface organic material or fill material is present, and all site structures, pavement and other debris have been removed). For the purposes of quality control, we may participate both as on-site observer(s) and advisor(s) during the collection of samples by applicants or their representatives.

3.1.4 Submit characterization report

Following sampling, a characterization report that includes the results of analysis and relevant QA/QC documentation must be provided to Program staff to ensure an efficient review and assessment.

If initial sampling results indicate further remediation is required at the site, you must conduct this work before we will consider any excavated material for disposal at sea. Following remediation work, a new sampling plan will be needed to allow consideration of the remaining, undisturbed native till for disposal at sea.

Related links

• Disposal at Sea Permit Application Regulations, appendix 1, part 1: Minimum information requirements
• CEPA schedule 6: Assessment of waste or other matter
• Appendix D: Data requirements for excavated material

3.1.5 Submit assessment of alternative disposal options

A detailed description and characterization of the excavated material proposed for disposal is an essential precondition for the consideration of disposal alternatives, and the basis for a decision as to whether the material may be disposed of at sea. Adequate characterization is required so that proper assessment can be made of its potential impacts on human health and the environment. If the material is not sufficiently characterized, we will not give further consideration to the application.

You are obligated to reduce the necessity for disposal and consider if there are any possibilities for reduction, re-use and recycling. This includes the consideration of other beneficial uses for the material. A comparison of land-based disposal options versus disposal at sea is also required. Environment and Climate Change Canada will issue a permit only when disposal of the waste at sea is demonstrated to be necessary and demonstrated to be the preferable and practical waste management option.

3.1.6 Publish notice of application in local newspaper

This notice explains the proposed activities, including duration, location and quantities of material intended for disposal. The public is invited to submit comments throughout the application process. A template for the Notice of Application is found in Appendix B.