Disposal at sea permit application guide: excavated material characterization
Appendix E: Excavated material characterization
Schedule 5 of the Canadian Environmental Protection Act, 1999 (CEPA) lists the types of wastes that can be considered for a Disposal at Sea permit. One of the eligible waste types is “inert, inorganic geological matter,” often referred to as “excavated material.” To be considered for a permit to dispose of excavated material at sea, an assessment must be completed to demonstrate that the candidate material meets the definition of “inert, inorganic geological matter” established in the guidance titled “London Convention / London Protocol Eligibility Criteria for Inert, Geological Matter LC 28/15, ANNEX 8.”Footnote1 This guidance lays out the preliminary steps that must be taken to determine whether an excavated material is eligible to be considered for a disposal at sea permit. These steps are listed below.
1. Determining if material is geological
To be considered geological matter, it must only be comprised of materials from the solid portion of the Earth, such as rock or mineral. In addition, the geological matter should not be altered from its original state by physical or chemical processing in a way that would result in different or additional impacts to the marine environment compared with those expected from the unaltered material.
Decision criteria:
To determine whether the candidate matter is geological in nature, answer the following questions:
- Does the candidate material only comprise materials from the solid mineral portion of the Earth?
- Has the material been altered from its original state by physical or chemical processing in a way that would result in different or additional impacts to the marine environment, compared with those expected from unaltered material?
If the answer to question 1 above is YES and the answer to question 2 is NO, the material is geological in nature.
If the answer to question 1 is NO or the answer to question 2 is YES, the material is not geological and cannot be considered for disposal at sea.
2. Determining if material is inert
In order to determine if a proposed material is inert, knowledge of the material’s constituents is key, including any potential contaminants, and what reactions may occur following the material’s exposure to physical, chemical, or biological processes in the marine environment. Material that may result in acute or chronic toxicity or in the bioaccumulation of any of its constituents, should not be considered inert.
Decision criteria:
- Considering both the pre-disposal nature of the material, and any alterations to it that may occur as a result of physical, chemical, or biological processes in the sea, are the only effects of concern those resulting from the physical properties of the material?
If the answer to the above question is YES, the material is inert.
If the answer is NO, the material is not inert and cannot be considered for disposal at sea.
3. Determining if material is inorganic
Candidate geologic material must also be inorganic materials, usually of mineral origin (for example, sand, salt, iron, calcium salts and other mineral materials). If a material doesn't contain any more than incidental or trivial amounts of compounds with carbon chemically bound to hydrogen, it is also considered inorganic.
Decision criteria:
To determine whether candidate geological material is inorganic, answer the following questions:
- Are the materials of inorganic mineral origin?
- Does the material contain no more than incidental and trivial amounts of compounds with carbon chemically bound to hydrogen?
If the answers to both questions above are YES, the material is inorganic.
If the answer to either question is NO, the material is not inorganic and cannot be considered for disposal at sea.
4. Determining if material is uncontaminated
Inert, inorganic geological matter proposed for disposal at sea must be uncontaminated and have chemical concentrations no greater than those found in geologically similar material. This assessment is not limited to just those contaminants identified in the Disposal at Sea Regulations under CEPA.
Decision criteria:
- Have contaminants been introduced at the materials source? For example, has the material been exposed to spills or other sources of contamination or subject to inadequate pollution controls?
- Have contaminants been introduced or concentrated beyond a magnitude greater than naturally found in geologically similar material?
If the answers to both questions above are NO, the material can be considered uncontaminated. An example of this would be a site where a Stage 1 Preliminary Site Investigation doesn't identify any Potential Contaminants of Concern.
If the answer to either question above is YES, the material is contaminated and, therefore, may not be considered for disposal at sea.
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