Carry out remediation strategy: step 8 of federal contaminated sites decision-making framework

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Step 8: implement Remediation/Risk Management (R/RM) strategy

Step 8, which is based on the analysis and planning outcomes from Step 7, involves implementing the Remediation/ Risk Management Strategy (which includes the Remedial Action Plan (RAP) and Remediation Management Plan (RMP) to reduce the risk from contaminants at the site to acceptable levels. Other responsibilities include:

• meeting requirements under the Canadian Environmental Assessment Act (CEAA 2012)
• obtaining all permits and approvals required to undertake any work at the site
• developing sustainable contracting clauses
• selecting the contractor
• conducting operations, maintenance and monitoring during implementation of the remediation during the RAP/RMP
• verifying the efficacy of the RAP/RMP

This step should include strict documentation control and adherence to the remediation/risk management (R/RM) objectives, as any unanticipated occurrences will require modification of the RAP and potential re-evaluation of the technologies applied. Stakeholders should be consulted as appropriate. Effects of climate change should be taken into consideration, and sustainable R/RMs should be included at all stages of the RAP/RMP. If it is determined that the remediation objectives will not be met, a full review of the R/RM Strategy and RAP/RMP for the site is required. It may be necessary to revisit earlier steps to determine what supplemental work is required or to determine if the site management strategy needs to be refined.

Key decision(s)

• Categorize site strategy based on approach and determine whether short, medium, or long-term plans will be affected by climate change by reviewing the assessment conducted in Step 7
• Develop integrate sustainable contracting clauses
• Determine if the performance expectations of the R/RM strategy have been met

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

• provide advice during implementation of the R/RM strategies related to:
  • mitigation measures and compliance requirements under the Fisheries Act
  • effectiveness and compliance monitoring
  • unforeseen issues
  • revisions to the sampling and monitoring plans, if required
• provide support to the public engagement process
• provide assistance in applying the Framework for Addressing and Managing Aquatic Contaminated Sites under the FCSAP (FCSAP, 2011)

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

• provide advice related to the implementation of R/RM strategies (specific to potential environmental)
• provide advice on compliance requirements under the Fisheries Act and other ecological requirements
• provide advice on revising the design, implementation and objectives for the long-term management plan including a long-term monitoring plan (to be developed and implemented in Step 10)
• provide advice on the preparation of the site closure report and assist with the Site Closure Tool (SCT) (FCSAP, 2012) including the Tool for Risk Assessment Validation (TRAV) an optional component of the SCT

How Health Canada (HC) expert support can assist

• provide advice related to the implementation of R/RM strategies (specific to potential human health impacts)
• provide advice and support in the determination of the site’s significant environmental effects as defined under the CEAA 2012
• provide advice and support on risk communication to stakeholders (including the general public).
• provide advice on the accuracy of model and other assumptions made during the Human Health Risk Assessment (HHRA) and the RM Strategy

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

• provide advice on, among other things, finalizing the RAP/RMP, developing tender specifications, selecting contractors, providing oversight of remedial activities, and completing the SCT. Ensure that the monitoring and control of the site, such as the status, scope, schedule, communication, risk control and lessons learned, are complete

How the FCSAP Secretariat can assist

• provide support to custodian as they complete the SCT/TRAV and assesse effectiveness of R/RM strategy

Supporting documents and tools specific to Step 8

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

Legislation

• Canada Wildlife Act(1985)
• Fisheries Act (1985)
• Canadian Environmental Assessment Act (CEAA) 1992, CEAA 2012
• Migratory Birds Convention Act (1994)
• Canadian Environmental Protection Act (CEPA), 1999
• Species at Risk Act (SARA) (2002)

General guidance

• Federal Guidelines for Landfarming Petroleum Hydrocarbons Contaminated Soils (FCSAP, 2006, Editorial Update 2013)
• Project/Program Risk Management Guidance for Federal Contaminated Sites Remediation/Risk Management (R/RM) Projects
• Guidance and Orientation for the Selection of Technologies (GOST)(PSPC/NRC, 2012)
• Site Closure Tool (SCT) and Tool for Risk Assessment Validation (TRAV) (FCSAP, 2012)
• Remediation Checklist (internal, HC)
• Contaminated Site Remediation Projects Roadmap (Website)(PSPC)

Other

• Fisheries and Oceans Canada (DFO) Pathways of Effects (DFO, 2011)
• Sustainable Remediation Forum (SuRF) Canada (Website)