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Exploring On-Site Reuse of Excavated Soil

Construction season is once again ramping up, with plans for road projects and development sites moving from the drafting
table to being bid out. One factor in any of these projects will be excavation and management of turf and soil and the
finished landscaping of the project. Several significant issues are surfacing on the horizon of soil handling practices that
are compelling planners and developers to consider changing the soil management practices of projects. The rising cost
of diesel driving up the cost of hauling soil to and from the job site as well as concerns about the introduction of soils
that are potentially dirtier than the soil found at the site are prompting a serious look at on-site reuse of soils, not only for
fill but increasingly for landscaping as well. While it is true that premium amended soil offers a more desirable base for
landscaped and rain gardens than unamended excavated dirt, Minnesota Mulch and Soil is seeing an uptick in interest in
on-site amendment and reuse of soil to address these concerns and can offer assistance and expertise in project planning
for this provision.

Put the soil to the test

Regardless of what use the existing
soil involved in a prospective
project will be put to, the important
first step is to test the soil to
determine what you are starting
with. Soils should be tested for
particle size and type for the
purposes of determining if the soil
offers optimal structure for the
intended use. Testing will also
provide an NPK classification to
determine the levels of nutrient
sources available to plants. It
is also a common practice that
soil contamination levels may be
identified in the process of doing
environmental due diligence with
a site scheduled for development
or redevelopment. According
to guidelines set by the MPCA,
contamination is characterized by
the type and level of pollutants in
soil, and is compared to established
Soil Reference Values (SRVs). Soils
sampled would fall into one of
three tiers characterized by levels
of known pollutants. Level 1 soil
(meeting Residential SRVs) is
considered to be relatively clean,
suitable for on-site or off-site reuse
on any type of property, as further

described in an MPCA Fact Sheet

titled Best Management Practices
for the Off-Site Reuse of Excess
Fill from Development Sites. Level
2 soil (meeting Industrial SRVs)
is often reused on-site during
redevelopment activities if the
property use will remain industrial
or commercial. This soil is not
currently approved for off-site
reuse; however, the MPCA is in
the process of developing a policy
which may allow the controlled
off-site reuse of such soil on certain
industrial properties, in accordance
with a site-specific reuse plan
approved by the MPCA. Level 3
soils are considered as having
significant contamination and are
suitable only for disposal at an
appropriate solid waste facility.
It is important to note here that
according to David Richfield,
supervisor of the water and land
rules and policy unit at the MPCA,
there has been much recent
discussion, proposed rules, and
consideration of possible legislation
surrounding the issue of off-site
reuse of Level 2 soils even for
industrial sites if the original soil at
the site is considered clean. Reuse

Testing on-site soil is a key first step to

determine amendment requirements.

of even somewhat contaminated

off-site soil on clean sites based
on usage is a bit of a regulatory
grey-zone right now. When we have
a clean site, we want to give all
Minnesotans a chance to weigh in
on these policy considerations.

The benefits of a well fed soil

Minnesota Mulch and Soil (MMS)
has been keeping a finger on the
pulse of how the state, cities, and
developers must deal with this
changing landscape of guidelines
and regulations. For over 25
years, MMS has been providing
fully tested soils, mulches, and
compost for commercial, public,

or custom-blended soil. However,

because the microbes wont adjust
instantly, tests done on amended
soil will change over time and the
soil will settle. If you are testing
for specifications youd want to
wait several weeks after combining
for best results.

Good soil needs to provide both nutrients and water management

to offer optimal plant growth.

and residential projects throughout

the area. MMS president Marty
Long recognizes the concerns
of planners and developers
regarding the sourcing of clean
soils. Nothing shows up on our
properties without tests from an
accredited lab. After weve mixed
it to hit spec, its tested again. We
not only test soils but the compost
we use to amend soil is tested for
contamination as well, along with
mulches and sand. Working in
collaboration with the department
of soil science at the University of
Minnesota and MNDOT, MMS has
developed premium certified clean
soils and composts that meet the
various MNDOT specs for a host of
applications.
Soil as it comes out of the ground
nearly always requires amendment
and alteration of its structure
to come up to the specifications
required for optimal rooting
and growability for any type of
plantings. According to Tom
Halbach, Professor and Extension
Educator with the Department

of Soil, Water, and Climate at the

University of Minnesota, Soils are
made up of minerals, weathered
materials, organic matter, free air
space, and water. These elements
have to be in the right proportion
for optimal plant growth. If there
are no voids, roots cannot grow.
If there is not enough water or
spaces for water, roots dry and
the plants die. Too much organic
material holds too much water, and
roots drown. In addition, there are
100 million microorganisms per
tablespoon in healthy soil. They
do the work of breaking down
materials and producing gases that
feed plants. Professor Halbach
describes the importance of proper
soil amendment as such; We can
measure the amount of organic
matter in soil and know that the
optimal soil contains 1-8% organic
material. Compost or shredded
bark gives structure to soil. It helps
the mineral parts aggregate and
allows for good drainage. Blending
compost and perhaps sand into
dirt as an amendment in the proper
ratios can make a very nice tailored

Getting the best specified

soil at the lowest cost
MMS has been exploring the
possibility of developing a protocol
for on-site reuse of excavated fill
to be amended on-site through
the blending expertise possessed
by MMS and accomplished with
tested and clean composts and sand
provided by MMS. The current
process for specifying and bidding
for the soil required by a project
largely involves excavating a site
by scraping off topsoil and piling
it on-site, excavating underlying
soil and piling that elsewhere for
potential use as grade fill under
pavement or structures, and then
having any finishing landscaping

Landscape or raingarden plants will

enhance any project. Optimal soil
will ensure that they thrive.

soil purchased and trucked in. This

also requires the piles of excavated
topsoil and dirt to be trucked away
and deposited off-site or taken
to a landfill for a fee. There may
be some degree of on-site reuse
of soil for landscaping purposes,
but often no amendment is being
done to ensure optimal growability
and poor plant performance and
drainage management may result
when this is practiced. Amy
Hadiaris is a hydrogeologist in
the Remediation Division of the
Minnesota Pollution Control Agency
and has experience with developers
trying to reuse soil whenever
possible as a cost-saving measure.
If soils can be re-used on-site in
a safe and controlled way it is the
preferred option. On-site reuse
of contaminated soil is best done
under the oversight of the MPCA.
Developers are required by statute
to report contamination if they
find it. If contamination is found,
it does not mean that on-site soil
remediation and amendment cannot
be done, but developers may wish
to voluntarily enroll in an MPCA
Brownfield Program which lays out
guidelines for clean-up and reuse
and would in turn offer liability
protection and environmental
closure, as appropriate. Amy
was careful to point out that the
agency in no way condones the
mixing of amending materials to
dilute contaminants for off-site
use. She added that amendment
to on-site soils to enhance growing
conditions may occur during site
redevelopment and is not regulated.

Even roadside landscaping

benefits from optimal amending
of soil for growability.

Where does that

leave on-site re-use
and amendment of soil?
By far and away the largest
purchaser of soil for landscaping of
construction projects is MNDOT.
According to MNDOT official
Brett Troyer, Theres definitely
opportunities to save money on
these projects by on-site reuse of
soil; we just dont have a protocol
for producing Type A horizon soils
for plant establishment on-site.
Right now we allow contractors to
reuse on-site soils for the sub-base
of the roadway. They may have to
resize the soil but we have good
protocols for structuring soil. I
am aware that other states are
doing this though. Contractors
will get paid to take the top soil off
separately, stock pile it, salvage it,
and pay for amenities to be added
and then use it for landscaping.
When asked his concerns
about contaminated soils, Brett
responded that There are some hot

spots in certain parts of the state

that we know are too contaminated
for reuse. We generally test sites
scheduled for development by
doing borings every 100 ft along
the corridor. Well go down 10
or 20-30 ft so we generally know
what we are working with. It
would stand to reason that soil that
tests as Level 3 would be removed
to landfill, but soils with lesser
contamination could be amended
and reused on-site. As long as clean
amendments are used, no further
contaminants would be introduced
to the site in this process.

The How-To piece

MMS is prepared to work with
planners and developers, along
with public partners like the
MPCA and MNDOT to develop
protocols for optimal on-site
amendment and reuse of excavated
soils that can result in premium
soils meeting the specifications
for various landscaping uses.
MMS has clean, tested composts
and other amendments which can
be brought on-site and mixed to
spec, accomplishing the goals
of controlling transportation
costs, reducing landfill fees, and
preventing the risk of bringing in
soil of questionable cleanliness
from off-site. To request further
information on this process,
contact Minnesota Mulch
and Soil at 651-755-4371 or at
mnmulchsoil@comcast.net.

P.O. Box 270101

St. Paul, Minnesota 55127

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(651) 755-4371
mnmulchsoil@comcast.net

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