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Things to consider: Stakeholder consultation conducted by the Canadian Urban Institute, it was generally agreed by those involved in source site operations that allowing excess soil to temporarily be stored at sites without excessive approval requirements will likely reduce the amount of potentially reusable excess soil currently going to landfills and could reduce the amount of truck traffic related to soil hauling. Due to the sometimes lengthy process of determining a permanent receiving site and/or remediation requirements, source site owners/operators could use temporary soil storage sites as an almost immediate area for soil placement.

However, some municipalities are concerned with the potential consequences of soil being left on a temporary soil storage site past the intended time. They also expressed the need to ensure that soil placed on temporary sites does not have an adverse effect on the environment, community or cultural heritage areas.

The majority of municipal by-laws reviewed currently do not differentiate between receiving sites and temporary soil storage sites; any site where excess soil is placed is typically treated as a receiving site and any site where soil is removed is typically treated as a source site.

Municipalities may choose to follow the MOECC Proposed Excess Soil Management Policy Framework that recommends policy:
  • "Encourage and allow for temporary excess soil storage where it supports beneficial reuse at an appropriate location.
  • Authorize generators of excess soil to temporarily store the excess soil at another location where they comply with a set of minimal requirements without approval.
  • Define appropriate temporary storage sites for excess soil and encourage storage close to source/receiving site to reduce transportation and environmental impacts.
  • Clarify requirements for excess soil storage and soil processing sites.
  • Distinguish between interim storage and processing sites governed by waste approvals.
  • Promote widespread remediation of contaminated soils to enable re-use and help minimize the quantity sent to landfills for disposal, unless appropriate.”1
The MOECC document Management of Excess Soil – A Guide for Best Management Practices (BMP) also outlines guidance for monitoring and regulating temporary soil storage sites.
(See MOECC BMP for more).

The best management practices are typically the responsibility of the owner/operator of the temporary soil storage site, along with ensuring the excess soil to be stored has a confirmed predetermined receiving site for after the specified storage duration. By-laws could incorporate these as requirements of a temporary soil storage management plan or reference the MOECC BMP directly.
The MOECC BMP recommends the following for Temporary Soil Storage Sites: “[…]
  • having a paved or otherwise impermeable surface;
  • covering soil storage piles while not in use;
  • limiting stockpile heights based on site location and site specific information, including adherence to local by-laws where applicable;
  • conducting site inspections to ensure that the site is operating in accordance with its operational practices and that the storage of excess soil is not causing an adverse effect;
  • notifying surrounding land owners to ensure they are aware of the site purpose and activities;
  • establishing the following:
    • dust and noise control measures;
    • site security measures;
    • Traffic and Transportation Management Plan;
    • protocol for incoming excess soil specifying:
      • that each incoming load have documentation signed by the Source Site QP that includes appropriate and representative soil analyses confirming the soil quality is acceptable for an intended Receiving Site;
      • that visual and olfactory inspections will be conducted of all incoming loads to screen for odour, visible staining or debris; and
      • contingency measures for load rejections.
  • a record keeping system to create and store written documentation that tracks each incoming load of excess soil including written records of:
    • date and time of arrival of the load to the Temporary Soil Storage Site;
    • name and location of the Source Site;
    • volume of excess soil received;
    • documentation from the Source Site signed the QP, including soil analytical results for incoming loads;
    • rejections of any loads of soil due to visual inspection or review of analytical results; and
    • documentation to the Source Site owner/operator and QP, once excess soil is received, confirming the soil was received and the type, quality and quantity was appropriate.
  • clear signage at the site, which identifies a contact name, hours of operation (with reference to local by-laws where appropriate), and daily and after-hours contact telephone numbers;
  • stormwater management plan, which includes provisions to prevent ponding and flooding;
  • erosion control and run-off controls sufficient to prevent impacts to drainage and sediment discharge to nearby watercourse or stormwater systems, and to ensure materials remain where placed;
  • soil placement/segregation protocol sufficient to identify where excess soil from each Source Site has been placed, such that it can be assessed if required.
Where Temporary Soil Storage Sites are accepting soil from multiple Source Sites, an audit sampling protocol should also be developed consisting of:
  • sampling protocols (designed by a QP) sufficient to produce results that would be representative of the volume of excess soil that is being received from each Source Site; and a
  • contingency plan to identify actions that are to be taken in the event that audit sampling or other information identifies concerns with soil quality from a Source Site.”2
MOECC BMP
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DEFINITIONS

Things to consider: If temporary storage is permitted, the by-law should specify the allowed duration. The MOECC BMP recommends a storage duration of no longer than two years. However, a municipality may find this too short or too long. While a longer duration provides more flexibility, some municipalities that CUI consulted expressed concern with two years being too long and felt more comfortable with six months, as written in the example below:

“‘Temporary Storage’ means storage of fill material for a period of 6 months or less;”3

See the Definitions Page for additional definitions relevant to any site alteration or fill by-law.

GENERAL PROHIBITIONS & REGULATIONS

Things to consider: Temporary sites can be regulated based on duration and/or amount of excess soil, as the MOECC BMP recommends: “Consideration should be given to whether municipal approvals or permits are required for Temporary Soil Storage Sites. These may include local restrictions for storage site volumes as a permitted use, or stockpile heights.”4 The example below allows temporary storage of excess soil without a permit under a certain volume, likely determined based on risk of soil contamination.

“No person shall undertake site alteration or cause site alteration to occur on any land for temporary storage purposes where the quantity of fill is in excess of 500 m³, without first having obtained a Permit.”5

The municipal zoning by-law may regulate the temporary storage of excess soil and, if so, should be referred to in the site alteration by-law.

REQUIREMENTS FOR ISSUANCE OF A PERMIT

Things to consider: Permitting requirements will likely be similar to those of Receiving Sites and the additional Issues of this tool should be consulted.

For monitoring and inspection purposes, if temporary soil storage is permitted, it is recommended that the municipality require in addition:

“the location and dimensions, of all temporary soil or fill stockpiles;”6