One of Cambium’s areas of expertise is with Environmental Site Assessments (ESAs) and Peer Reviews. Our team completes hundreds of ESAs and Peer Reviews annually. If you require a phase I or phase II ESA, this technical update provides general information on common, frustrating mistakes in Environmental Site Assessments related work and reporting. With added due diligence and words of wisdom, many of these common errors should and can be avoided.
Scenario One: Consultant conducts a Phase I ESA and recommends Phase II ESA work as during the records review; hazardous waste generation took place on neighbouring sites within the prescribed 250 m search radius.
Solution: Regulators allow Consultants to make arguments for exclusion, based on 3 facts, including but not limited to depth to groundwater, the direction of groundwater flow, soil stratigraphy etc. Did your Consultant postulate with reasoning why a Phase II ESA was required here or merely provide default recommendations without further consideration?
Scenario Two: Consultant conducts Phase II ESA – Soils Investigation and finds samples near surface elevated with pH, EC and SAR. Consultants then suggest site remediation take place.
Solution: Regulators allow Consultants to take mathematical approaches to averaging pH within a 2-metre radius within the same soil unit. Regulators also allow Consultants to consider whether the Site Condition Standards were exceeded at the property solely because a substance was applied to a highway (i.e. street etc.) which is deemed exempt from the regulations. Did your Consultant examine these possibilities prior to rendering a judgement?
Scenario Three: Consultant provides a Phase II ESA – Proposal and recommends analytical testing for just about every regulated parameter listed in the regulation. Realtor solicits two (2) more proposals from competitors and finds completely different analytical work programs.
Solution: Experienced professionals understand which analytical test groups are associated with a particular industry or activity. There is no need to overanalyze a site and test for all regulated compounds. If in doubt, Consultants should rely on MOECC and CCME Guidance Manuals and reference documents, rather than offering everything available via our regulations.
Scenario Four: Consultant conducts a Phase III ESA – Environmental Site Cleanup at a former petroleum tankfarm location. Compliance is achieved for soils remediation, however, no groundwater sampling was undertaken or if done, did not include recovery of groundwater within the open excavation.
Solution: A mandatory requirement of Ontario Regulation 153/04, as amended includes sampling and analysis of groundwater when a property was used in part for the following commercial uses: as a garage, gasoline outlet, or dry cleaner. Furthermore, to validate this requirement, groundwater must be recovered within the former remediation area, which means that installation of a monitoring well is necessary, post-remediation to ensure satisfactory site cleanup.
Scenario Five: Consultant conducts a Phase II ESA Groundwater Investigation and finds elevated concentrations of several petroleum hydrocarbon compounds and/or volatile organic compounds. The consultant then suggests that site remediation take place, or worse yet, nothing can be done here.
Solution: Never rely on one set of data in such a circumstance. Have your Consultant resample and examine trends within the due diligence period. Consultants need to recognize when more advanced sampling techniques should be employed. Examples – Low Flow (Minimal Drawdown) Sampling, finer field filtration (0.20 um filters, when permitted) etc. Consultants also need to recognize whether the results are truly representative (repeatable, defendable) or perhaps due to sampling/lab error.
We hope you find value in this blog. If you have any questions or would like further information on our ESA services, feel free to contact our experienced professionals: David Mably, P. Eng., out of the Cambium Barrie office or Brad Sawdon, P. Geo., at the Peterborough office.