Soil Categories

Updated: December 15, 2020

Clean Category:

  • NJ Res - This is a very generic term that states material meets New Jersey Residential Direct Contact Soil Remediation Standards (NJ RDCSRS). This does not say anything about the material also meeting NJ default Impact to Groundwater (IGW) Soil Screening Levels, which is required by certain clean fill facilities (not all). Meeting NJ Res also does not necessarily mean that the soil is 'native' (native soil excludes historic/urban fill material, but just underlying indigenous soil and rock) or that it excludes other physical constituents (e.g., ash, cinder, asphalt, coal, slag - and sometimes any non-native material) that would disqualify it from a NJ Clean Fill facility. Finally, it doesn't account for the geotechnical nature of the soil - certain facilities don't want excessively silty, clayey, or wet material.

  • NJ Clean Fill Native Sands - Even more generic than NJ Res, this category relies on a term that doesn't exist in the regulations ("NJ Clean"). It doesn't specify whether is meets either NJ Res or NJ IGW. It does however specify that the material meets the geotechnically standard as a sand (favorable in most cases), and that it originates from native strata (i.e., contains no fill constituents such as incidental concrete, brick/block, asphalt, wood, metal, ash/cinder/slag/coal, etc.).

  • Uncharacterized Soils (Assumed NJ clean fill native sands) - This is the same as above, except it is saying there is no available waste characterization sampling data, so they are assuming it is native sand, and clean (unclear if NJ Res and/or IGW).

  • NY Res - Just states that material meets NYCRR Part 375 Table 6.8(b) Residential (more restrictive) or Restricted Residential (less restrictive) cleanup objectives - not clear which. It also doesn't state whether it meets Protection of Groundwater objectives (often required for Long Island Facilities) or if it contains physical contaminants such as ash/cinders/slag/coal/asphalt.

  • PA Clean Fill - this category is specifically defined in the latest PADEP Management of Fill Policy (MoFP) that went into effect at the beginning of 2020. It does include constituents such as asphalt or incidental slag. The concentrations have now been tied to the PADEP Act 2 (chapter 250) standards, which has an incredibly low limit on the metal vanadium. The result of that is that currently almost no material will fit into this category right now - don't believe anyone that tells you otherwise without a second opinion. However, the state changes the Act 2 standards every 3 years, so I expect within the next 3-6 months they will change. If they decide to revise vanadium up to a reasonable level, PA Clean Fill will suddenly be very viable again, and will include soil that would be considered contaminated in other states.

Contaminated Non-Haz Category:

  • NJ Alternative Fill Soils (aka, 'Alt Fill') - this means that the NJDEP has approved soil capping on a contaminated site in New Jersey as a cleanup remedy for that site, making it a 'Alt Fill Facility' (i.e., approved for beneficial reuse of contaminated soil). Such alternative fill approval assigns site-specific contaminant levels (exceeding NJ Res and/or NJ IGW) and total quantities that can be imported from various donor construction sites. Again, the concentrations that each Alt Fill facility can accept are specific to that facility, so you need to actually review tables in the facility Fill Use Plan or Materials Acceptance Plan to see what meets on your site. Such a facility can often accept physical contaminants such as incidental ash, cinder, asphalt, coal, slag - but not all Alt Fill facilities can. Since these facilities are usually former contaminated industrial sites that are being redeveloped into new buildings, they are often very concerned with geotechnical considerations as well (e.g., excludes extensive clays, silts, meadow mat, wet materials).

  • NJ Regulated/Non-hazardous Contaminated - This basically is the same as 'Alt Fill' in concept, but generally broader in definition. In other words, it means any soil that is contaminated (i.e., not clean for NJ Res or IGW) by NJDEP standards, but is also not considered hazardous. It could be appropriate for a number of facility types, including Alt Fill facilities, other approved beneficial use facilities, certain NJ Class B recyclers, subtitle D solid waste landfills (as solid waste or beneficial use as daily cover), etc.

  • Non-Haz Treatment - Same as above category and doesn't say anything about the material other than it is non-hazardous. It just refers to the facility's approach to the material, which is to treat the contamination at the facility (e.g., thermal treatment, bioremediation, addition of stabilizing agents, etc.). Such facilities are required to have a state-issued permit.

  • PA Regulated Fill Soils ("PA Reg Fill") - this category is specifically defined as soils that meet the standards listed on tables in PADEP General Permit WMGR096 ('Regulated Fill Use Permit'). Facilities with this permit are typically contaminated sites that are undergoing capping as a remedy, so this permit represents a beneficial use of soils brought in from donor sites. PA Reg Fill is also discussed in the MoFP, but concentration limits conflicts with the current General Permit - so the permit prevails for now. This will be reconciled early to mid-2021, and will likely result in higher limits for contaminants. Typically PA Reg Fill limits are pretty high, and can include petro odors/staining, slag & asphalt constituents, and are often more flexible geotechnically.

  • PA Regulated/Non-hazardous Contaminated - Same as PA Reg Fill.

Recycling Special Category (Non-Haz)

  • NJ Class B Recycling Facility - these facilities have been issued a Class B license by NJDEP to accept and recycle Class B materials (e.g., brick/block/concrete/rock/terracotta/asphalt). Some of these sites have permits that allow them to also accept clean soils to use in making products for resale, and some have permits to accept contaminated soils for treatment, product manufacture, or back end disposal after screening. Here are the subcategories you provided:

    • NJ Class B Soil Beneficial Use Facility - This is the same as a Class B Recycling Facility. It's really recycling, which could be considered a beneficial reuse. Doesn't provide any information about what type of soil (if any) the facility can accept (clean fill, contaminated fill).

    • NJ Class B Recyclable Masonry Debris (NJ Clean) - Same as above, but this descriptor is not saying anything about the ability for the facility to accept soil. It is just stating that the facility can accept clean masonry (brick, block, concrete, rock). If it is proposing accepting soil, it should mean that such soil meets either NJ Res or both NJ Res and NJ IGW (not clear which - "NJ Clean" is the most generic term you can use, and is not defined).

    • NJ Class B Recyclable Masonry Debris (NJ Alternate Fill) - This implies that there will be soil mixed in with the masonry debris (or vise-versa), and that it is contaminated above NJ Res and NJ IGW. Some Class B recycling facilities allow this contaminated soil to be screened out, segregated, and either treated, made into an approved product, or transported by the facility to a separate end-use alt fill site or other site that can take contaminated materials (PA Reg fill site, Subtitle D Solid Waste Landfill, etc.). You would need to request the specific acceptance limits.

    • NJ Class B Petroleum Recycler - this is a special designation of Class B license that allows the recycling facility to also accept and treat petroleum contaminated soil and masonry (visible oil contamination, high odors, tank related contamination, high PID hits, very high petro constituents, etc.). Few of these facilities exist (I can think of 3), and they are used on most jobs for petro soils.

Hazardous

  • Characteristically Hazardous Lead Soil - This is stating that the soil is classified as hazardous for the metal lead (also known as 'D008' soil). If something is characteristically hazardous, it means that it either fails the TLCP test for toxicity (in the case of lead, a result > 5 mg/l is hazardous), or fails a RCRA Characteristics test for either ignitability (flash point), corrosivity (pH), or reactivity. Haz wases can also be hazardous 'by definition', which means they are in a category that is considered haz regardless of how the material tests, such as F-list residual chlorinated solvents tied to a known/probably historical release. Characteristically Hazardous Lead Soil does not include material that may be hazardous for other compounds (not very common), and also doesn't consider other limits the facility may have regarding max TCLP results, underlying haz constituents, pH of material, etc.