Federal approach to contaminated sites: introduction
This Approach document has been developed by the Contaminated Sites Management Working Group (CSMWG) to provide a common federal approach to managing contaminated sites under federal custody.
In the context of sustainable development, pollution prevention and the need for effective budgetary considerations, the CSMWG, an interdepartmental committee, was established in the summer of 1995 to provide advice on federal contaminated sites to the Federal Committee on Environmental Management Systems (FCEMS).
In pursuit of its mandate, the CSMWG has developed a generic definition and a policy statement for contaminated sites:
A contaminated site is defined as a site at which substances occur at concentrations: (1) above background 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.
"Contaminated sites on federal lands shall be identified, classified, managed and recorded in a consistent manner."
1.2 Objective and Scope
This Approach has been developed to support and augment the above CSMWG's Policy. It will assist the CSMWG mandate in establishing a consistent and uniform government-wide approach to the management of contaminated sites.
The Approach serves as a proactive management tool so that the necessary steps are taken to characterize, classify and prioritize contaminated sites and to ensure environmental site management initiatives are implemented in a timely and cost-effective manner. The Approach comprises a significant supporting tool in attaining sound overall due diligence in the management of federal contaminated sites. This systematic approach will ensure that limited resources are allocated to the most high-risk sites.
The potential benefits as a result of meeting the Approach's objective include:
- a consistent federal approach to environmental site management;
- long-term strategic planning of overall investigation and clean-up efforts;
- more effective allocation of federal resources between departments;
- better selection of cost-effective site management strategies; and
- implementation of risk-based clean-up criteria and management options.
1.3 Intended Use
The intended audience for the Approach is managers and operational personnel who are responsible for managing contaminated sites on federal lands. Each step in the Approach process is designed to stand alone and to outline key components for investigating, managing and remediating contaminated sites. References to specific source documents for additional information are found in each of the steps. The Approach was developed mainly to build upon these source documents and provide guidance for their use within the context of the federal contaminated site management process.
The appendices supplement information found within the Approach. Appendix A references the numerous scientific tools, guidance documents and generic remediation objectives that have been developed by the Canadian Council of Ministers of the Environment (CCME), the National Contaminated Sites Remediation Program (NCSRP), Environment Canada and Health Canada to provide direction in the management of contaminated sites. Generic Statements of Work are provided in Appendix B-E to assist proponents in developing Statements of Work for specific projects.
1.4 Approach Process
The Approach incorporates a risk-based approach to the management of contaminated sites. The objectives of a risk-based environmental management approach are to assess risks to human health and the natural environment under the current and intended land use scenarios and to implement risk management solutions considered to be protective of those risks. This involves identifying the contaminants of concern, identifying potential receptors, determining potential exposure pathways, and estimating the level of risk based on the pathways. In addition, the risk-based approach implies a prioritized allocation of resources within the federal departments.
The risk-based approach incorporates several components including site identification and characterization, detailed site investigations and risk assessment, evaluation of different risk management strategies, implementation of a selected management strategy, assessment and monitoring. These components are realized through a 10-step process known as the Steps for Addressing a Contaminated Site, which are briefly described below and are illustrated in Figure 1. These steps identify scientific tools and documents that are available for use in the management of federal contaminated sites. Each step is explained in further detail in the following section.
1.5 Reporting Requirements
Treasury Board Secretariat has developed two policies that need to be considered in the management and reporting of contaminated sites. The 2000 Contaminated Sites Inventory Policy and the 1999 Draft Policy on Accounting for Costs and Liabilities Related to Contaminated Sites provide details on the reporting requirements.
The 2000 Contaminated Sites Inventory Policy requires all federal departments to establish and maintain a database of their known contaminated sites and their solid-waste landfills and to provide this information to Treasury Board Secretariat for incorporation into a central Federal Contaminated Sites Inventory and Federal Solid Waste Landfills Inventory within the Directory of Federal Real Property.
The 1999 Draft Policy on Accounting for Costs and Liabilities Related to Contaminated Sites requires all federal departments to account for all costs and liabilities related to management and remediation of their contaminated sites. Departments are to report these costs to the Treasury Board Secretariat on an annual basis.
More information about these two policies is available from the Treasury Board Secretariat web site (www.tbs-sct.gc.ca).
Figure 1 Steps for Addressing a Contaminated Site
Step 1 - Identify Suspect Sites: Identifies potentially contaminated sites based on activities (past or current) on or near the site.
Step 2 - Historical Review: Assembles and reviews all historical information pertaining to the site.
Step 3 - Initial Testing Program: Provides a preliminary characterization of contamination and site conditions.
Step 4 - Classify Contaminated Site Using the CCME National Classification System: Prioritizes the site for future investigations and/or remediation/risk management actions.
Step 5 - Detailed Testing Program: Focuses on specific areas of concern identified in Step 3 and provides further in-depth investigations and analysis.
Step 6 - Reclassify the Site Using the CCME National Classification System: Updates the ranking based on the results of the detailed investigations.
Step 7 - Develop Remediation/Risk Management Strategy: Develops a site-specific plan to address contamination issues.
Step 8 - Implement Remediation/Risk Management Strategy: Implements the site-specific plan that addresses contamination issues.
Step 9 - Confirmatory Sampling and Final Reporting: Verifies and documents the success of the remediation/risk management strategy.
Step 10 - Long-Term Monitoring: If required, ensures remediation and long-term risk management goals are achieved.
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