Initial testing: step 3 of federal contaminated sites decision-making framework

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Step 3: initial testing program

Step 3 involves focusing on the identified environmental issues and potential risks. An Initial Testing Program, also known as a Phase II Environmental Site Assessment (ESA) (CSA, 2004) is conducted to investigate actual site conditions, and stakeholders should be consulted. Stakeholders can provide key information about the site history and condition, end use of the site, exposure pathways, receptors, contaminants of potential concern, and safe exposure limits.

A Phase II ESA (CSA, 2004) includes six stages:

  1. planning
  2. field investigation and sampling
  3. sample analysis
  4. data interpretation and evaluation
  5. risk Identification
  6. conceptual Site Model Development

This step will provide a preliminary assessment of the degree, nature and extent of the contamination.

In developing the scope of work and conducting a Phase II ESA (CSA, 2004), climate change effects should be considered at the ESA’s Risk Identification (Stage 5) and Conceptual Site Model Development (Stage 6) stages. This involves the collection of data on climate conditions (e.g. temperature, precipitation, wind) to assist with the assessment of future predicted climate conditions.

The Framework for Addressing and Managing Aquatic Sites under the FCSAP program (FCSAP, 2011) should also be consulted if aquatic ecosystems are present on the site. The Aquatic Sites Framework provides guidance on the management of aquatic sites for every step of the DMF.

ESAs should use sustainable methods that reduce energy use and waste generation, and contracting clauses encouraging the use of sustainable practices should be integrated into the procurement plan.

Key decision(s):

Step 3: Initial Testing Program
Long description

Review findings of the historical review from Step 2, and develop a scope of work for the Phase II ESA, ensuring to consider future impacts of climate change. Conduct a Phase II ESA and develop the Conceptual Site Model (CSM) using sustainable methods to investigate contaminants concentrations and consult with stakeholders. Given current or intended federal land use, determine if the site is contaminated based on the Treasury Board definition. If the site is contaminated, proceed to Step 4. If the site is not contaminated, no further action needed. Close the site on the FCSI and record the rationale.

Identify current or intended federal use for impacted area

Before remediation or risk management (R/RM) strategies are identified and evaluated, the current or intended federal land use of a site must be agreed upon to determine the appropriate standard for remediation. Whether the site is used for industrial, commercial, agricultural or residential/parkland purposes, each will have varying degrees of human health and ecological protection. The levels of protection provided by CCME standards ensure that the remediated land has the potential to support most activities associated with the intended land use.

Under the TB Secretariat Policy on Management of Real Property (TBS, 2006), remediation must be undertaken to the extent required for current or intended federal use. If a custodian plans to divest the property, he/she may remediate beyond federal standards, but the supplementary (above the current or intended federal land use) remediation will not be covered by FCSAP funds.

Treasury Board of Canada (TB) definition of a contaminated site

According to the TB definition, a contaminated site is “one at which substances occur at concentrations (1) above background (normally occurring) levels and pose or are likely to pose an immediate or long-term hazard to human health or the environment, or (2) exceeding levels specified in policies and regulations.”

If there are no guidelines available, custodians should base their determination of a contaminated site on the background level, by looking at existing literature or undertaking additional sample analysis. Before moving to the next step, the custodian should be able to confirm whether or not the site is contaminated.

How Fisheries and Oceans Canada (DFO) expert support can assist

How Environment and Climate Change Canada (ECCC) expert support can assist

How Health Canada (HC) expert support can assist

How Public Services and Procurement Canada (PSPC) expert support can assist

How the FCSAP Secretariat can assist

Supporting documents and tools specific to Step 3

Please also refer to the list of supporting documents and tools useful throughout the 10-step process at the beginning of the document.

Canadian Council of Ministers of the Environment (CCME) Guidance

Federal Contaminated Sites Action Plan (FCSAP) Guidance

Other guidance

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