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):

• define the appropriate current or intended federal land-use scenario according to the Canadian Council of Ministers of the Environment (CCME) guidelines for land use of studied site
• confirm, based on the assessment results, and the current or intended land use, if the site is contaminated according to the Treasury Board of Canada (TB) definition
• conduct a preliminary assessment on the effects of climate change at the site and determine whether there will be any short, medium, or long-term impacts on contaminant types, concentrations, or distribution or changes in the residency media
• determine options for integrating sustainable practices into the site assessment including sustainable contracting clauses
• determine whether the site can be closed because no further action is required
• proceed to site classification at Step 4

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.

• Agricultural: growing crops, raising livestock, natural areas including National Wildlife Areas and Migratory Bird Sanctuaries¹
• Residential/Parkland: residential or recreational activities, buffer areas between residences, campgrounds
• Commercial: ³ public access, malls, cultivated lawns, flowerbeds², gas stations
• Industrial: ⁴ restricted access, production, manufacturing or construction of goods

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

• assist with identification of fish, fish habitat and fish/fisheries information
• provide advice on:
  • characterization of fish habitat or habitat mapping
  • confirmation of aquatic species, including species listed under the Species at Risk Act (SARA)
  • expectations associated with fish and fish habitat data collection
• document review (e.g., Phase II ESA (CSA, 2004) report, conceptual site model [CSM]) with respect to the risk(s) (including receptors, hazard and exposure) to fish and fish habitat
• review sampling plan to ensure that data collected will accurately represent the site and assess risks to fish and fish habitat
• participate in site visit activities with custodians and other stakeholders to address potential issues and become familiar with the site
• provide assistance in applying the Framework for Addressing and Managing Aquatic Contaminated Sites under the FCSAP (FCSAP, 2011)
• provide advice on compliance requirements under the Fisheries Act and other environmental requirements

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

• provide advice on and/or review of the Phase II ESA (CSA, 2004) report, with respect to ecological risks (including receptors, hazard and exposure)
• provide advice on planning of the Phase III investigation (including providing advice on sampling plan, sampling techniques and technologies, quality assurance/quality control (QA/QC) program, and Conceptual Site Model (CSM)
• provide advice on CCME Canadian Environmental Quality Guidelines or other applicable guidelines:
  • A Protocol for the Derivation of Water Quality Guidelines for the Protection of Aquatic Life (CCME, 2007)
  • A Protocol for the Derivation of Environmental and Human Health Soil Quality Guidelines (CCME, 2006)
  • A Protocol for the Derivation of Canadian Sediment Quality Guidelines for the Protection of Aquatic Life (CCME, 1995)
• participate in site visit activities with custodians and other stakeholders to address potential issues and become familiar with the site
• provide advice on the analysis of data

How Health Canada (HC) expert support can assist

• provide advice on and/or review of the CSM
• provide advice on the characterization of the site and whether there are data gaps associated with site characterization that may impact assessment of human health risks
• provide advice and training on sampling techniques and technologies
• review sampling plan to ensure that data collected will accurately represent the site and assess human health risks.
• provide advice on QA/QC programs
• provide advice on Canadian Environmental Quality Guidelines or other guidelines that are applicable to screening chemicals for potential human health risks:
  • A Protocol for the Derivation of Water Quality Guidelines for the Protection of Aquatic Life (CCME, 2007)
  • A Protocol for the Derivation of Environmental and Human Health Soil Quality Guidelines (CCME, 2006)
  • A Protocol for the Derivation of Canadian Sediment Quality Guidelines for the Protection of Aquatic Life (CCME, 1995)
• participate in site visit activities with custodians and other stakeholders to address potential issues and become familiar with the site
• provide advice on the analysis of data from laboratories (adequate detection limits, etc.)
• provide advice on CCME Canadian Environmental Quality Guidelines (soil, water or sediment) for the protection of human health and Canadian Drinking Water Guidelines (HC, 2014), and/or on the adoption of standards from other jurisdictions
• provide advice, guidance and training on the characterization and delineation of contamination at a site in ESA reports so that custodians can better risk-manage sites and obtain adequate data for use in Human Health Risk Assessment (HHRA), including:
  • advice on and/or review of CSM with respect to human health
  • advice on characterization of the site
  • advice on the sampling and analysis plan to ensure that data collected will accurately represent the site and supply sufficient data to allow for the assessment of potential human health risks
• participate in site visit activities with custodians and other stakeholders to address potential issues and become familiar with the site

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

• provide advice on, or develop statements of work for the completion of Phase II ESAs (CSA, 2004)
• assist in determining whether further work is required or no further action is necessary

How the FCSAP Secretariat can assist

• provide assistance in using the Eligible Cost Guidance document, 5.0 (FCSAP, update in progress) as required

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

• Guidance Manual on Sampling, Analysis, and Data Management for Contaminated Sites – Volume I: Main Report (CCME, 1993)
• Guidance Manual on Sampling, Analysis, and Data Management for Contaminated Sites – Volume II: Analytical Method Summaries (CCME, 1993)
• Subsurface Assessment Handbook for Contaminated Sites (CCME, 1994)
• Canada-Wide Standard for Petroleum Hydrocarbons in Soil (CCME, 2008)
• CCME Canadian Environmental Quality Guidelines:
  • A Protocol for the Derivation of Water Quality Guidelines for the Protection of Aquatic Life (CCME, 2007)
  • A Protocol for the Derivation of Environmental and Human Health Soil Quality Guidelines (CCME, 2006)
  • A Protocol for the Derivation of Canadian Sediment Quality Guidelines for the Protection of Aquatic Life (CCME, 1995)
  • A Protocol for the Derivation of Groundwater Quality Guidelines for Use at Contaminated Sites (CCME, 2015)

Federal Contaminated Sites Action Plan (FCSAP) Guidance

• Phase II ESA SOW incorporating Science-based Expert Support Input (A Federal Approach to Contaminated Sites, Appendix C, CSMWG, 1999)
• Framework for Addressing and Managing Aquatic Contaminated Sites Under the Federal Contaminated Sites Action Plan (FCSAP, 2011)
• FCSAP Guidance Document on Statements of Work for Ecological Risk Assessments (ERAs) at Federal Sites (FCSAP, 2011)
• FCSAP Ecological Risk Assessment Guidance (FCSAP, 2012)
  • Module 1: Toxicity Test Selection and Interpretation (FCSAP, 2010)
  • Module 2: Selection or Development of Site-specific Toxicity Reference Values (FCSAP, 2010)
  • Module 3: Standardization of Wildlife Receptor Characteristics (FCSAP, 2012)
  • Module 4: Causality Assessment: Determining the Causes of Impairment at Contaminated Sites: Are Observed Effects Due to Exposure to Site-Related Chemicals or Due to Other Stressors? (FCSAP, 2013)
  • Module 5: Defining Background Conditions and Using Background Concentrations (not currently available)
• Federal Interim Groundwater Guidelines (FCSAP, 2016)
  • Federal Interim Groundwater Guidelines Update (FCSAP, 2016)

Other guidance

• Canadian Standards Association (CSA) Standards for Phase II Environmental Site Assessment (CSA, 2000)
• For Human Health Risk Assessment (HHRA): Federal Contaminated Site Risk Assessment in Canada:
  • Part I: Guidance on Human Health Preliminary Quantitative Risk Assessment (PQRA), Version 2.0 (HC, 2012) available on request from cs-sc@hc-sc.gc.ca,
  • Part II: Health Canada Toxicological Reference Values (TRVs) and Chemical-Specific Factors, Version 2.0 (HC, 2010), available on request from cs-sc@hc-sc.gc.ca:
  • Part III: Guidance on Peer Review of Human Health Risk Assessments for Federal Contaminated Sites in Canada, Version 2.0 (HC, 2010)
  • Part V Guidance on Human Health Detailed Quantitative Risk Assessment for Chemicals (DQRA_CHEM) (HC, 2010)
  • Part VI: Guidance on Human Health Detailed Quantitative Radiological Risk Assessment (DQRA_RAD) (HC, 2010)
  • Part VII: Guidance for Soil Vapour Intrusion Assessment at Contaminated Sites (HC, 2010)
• Supplemental Guidance on Developing a Contract Statement of Work for Human Health Preliminary Quantitative Risk Assessment (PQRA) and Detailed Quantitative Risk Assessment (DQRA) (HC, 2010)
• Guidance and Orientation for the Selection of Technologies (GOST) (PSPC/NRC, 2012)
• Guidelines for Canadian Drinking Water Quality (HC, 2014)