Phase Two Environmental Site
Assessment Guidance
An overview of the requirements of amended O. Reg. 153/04 in completing the phase
two environmental site assessment report
Association of Professional Geoscientists of Ontario
June 13, 2013
Presentation
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APGO’s Role
Background
Reminders
Highlights
Discussions
APGO-MOE Interaction
• 2008 – 2010: APGO Worked closely with MOE in
developing requirements of the new Phase One
and Phase Two environmental site assessment
(ESA) and Tier 2 risk assessment (RA).
• 2009: Received grant from MOE to prepare ESA
guidance manual.
• 2010: APGO Guideline on ESA completed in
March 2010.
APGO-MOE Interaction continued
2010 – 2012:
• APGO conducted information/training sessions on
the Guideline.
• The need for further editing and clarification of
certain aspects in the Guideline was identified.
• Inclusion of report templates for Phase One and
Phase Two ESAs was also recommended.
Phase One/Two Report Templates
• Report templates recommended by client groups
including lending institutions and municipalities to
facilitate standardization of reports.
• Templates would follow O. Reg. 153/04 reporting
requirements.
• The purpose of today’s training session is to
provide overview of the phase two guidance
template
Background
• The amended Ontario Regulation 153/04
(O. Reg. 153/04) governing requirements of
Record of Site Condition (RSC) came into effect on
July 1, 2011
• There are prescriptive requirements for completion
of the phase two ESA in support of the RSC,
before it can be submitted for filing in the
Environmental Site Registry
Background continued
• The phase two ESA must meet general and
specific objectives
• The phase two ESA must also meet
requirements of Schedule E of O. Reg. 153/04
• Finally, the phase two ESA report must meet
minimum requirements of Table 1 of
Schedule E
• The APGO’s phase two guidance template
provides a simplified step by step explanation of
the requirements in a plain language
(a check list)
Background Continued
• The phase two ESA guidance published by the
Ministry of the Environment (Ministry) is focused
on providing interpretation of rules of O. Reg.
153/04.
• The APGO thus has put forward this template to
provide explanatory notes where needed to
facilitate completion of a report which would
meet requirements of O. Reg. 153/04.
• It also provides reference to relevant sections of
already published APGO’s ESA guidance.
Reminders
• The requirements of O. Reg. 153/04 are applicable and
should be fulfilled when a phase two ESA was conducted
for the purpose of submitting the RSC for filing.
• The phase two ESA must meet all requirements of O.
Reg. 153/04 including requirements of Schedule E and
the minimum requirements of Table 1 of Schedule E
• The phase two ESA must meet general objectives
(Section 33.1, O. Reg. 153/04) which is achieved by:
– Developing an understanding of geological and hydrogeological
condition; and
– Conducting one or more rounds of field investigation for all area
of potential environmental concern (APECS)
Reminders Continued
• Must consists of components as per Section 33.2, O.
Reg. 153/04
• The remediation is now apart of the phase two ESA and
should be included in the report as an appendix.
• The phase two conceptual site model (CSM) is required
to demonstrate the current condition of the phase two
property or, where remedial actions have been
undertaken, the condition of the phase two property
before the remedial actions were undertaken
• Although a phase two ESA report may be completed for
a larger property, for the purpose of submitting a RSC all
requirements of the phase two ESA should meet
requirements for the RSC property
Reminders Continued
• It is imperative that the phase two ESA report
covers all sections, subsections and paragraphs
of Schedule E, including Table 1
• If any part/sections of Schedule E is not relevant
it should be mentioned in the report and
rationale should be provided
• For example if ground water was not part of the
assessment it should be mentioned in the report
with rationale and an explanation that sections
pertaining to the ground water requirements are
not relevant.
Highlights
• The phase two ESA guidance is applicable only
if the work is in support of submitting a RSC for
filing.
• The guidance is structured in a tabular format
• It does not take away any freedom of
professional judgments and/or deviation from
the proposed outline
• It meant to provide guidance to meet minimum
requirements of O. Reg. 153/04
Highlights Continued
• The guidance template is in no way a
complete interpretation of requirements of
O. Reg. 153/04.
• In all cases the Ministry’ s interpretation
and directive will supersede.
• The following will give a brief account and
discuss some of more important aspects in
detail
Highlights Continued
Mandatory Requirements For phase two ESA
Report
Executive Summary
• Provide a brief summary of the report
• The executive summary should include a brief overall
description of each section of the report
• It should be a stand-alone document sufficient in content
to allow the reader to understand all aspects of the
phase two ESA
• Typically, the length of the executive summary should
not be more than 10% of the full text of the report (not
including data, appendices and figures).
Highlights Continued
• The executive summary should be applicable to the RSC
portion of the property
• If the phase two covers an area greater than the RSC
property, make sure that this is clarified in the executive
summary and include the aspects of the phase two ESA
relevant to the RSC property (e.g., number and locations of
samples).
Scope of the Investigation
(i) Overview of Site Investigation
• Provide an overview of the site investigation conducted
with respect to the phase two property
• Summarize all tasks that are to be under taken in
completion of the phase two ESA
Highlights Continued
• This includes description of health and safety plan, utility
clearance, selection of drilling equipment, all field tasks,
including equipment used, methods of sample collection,
when work was performed, field observations, summary
of samples collected, and analyses performed, and
laboratory used
• Provide a brief description of the phase one conceptual
site model (CSM)
• Provide details of any deviations from the sampling and
analysis plan
• Any deviation should be justified and documented
• Provide description of any physical impediments or
denial of access to the phase two (RSC) property.
Highlights Continued
Planning the Site Investigation
Sampling and Analysis Plan
• Provide the sampling and analysis plan of the site
investigation as referred to in section 3 (2) to (7) of
Schedule E
• Perhaps it is the most important document to be
prepared at the planning stage
• Following are essential in writing sample and analysis
plan. It should as a minimum include the following.
Highlights Continued
Subsection 3 (2), Schedule E
• The qualified person shall ensure that there is a sampling
and analysis plan that includes a quality assurance and
quality control program, data quality objectives, standard
operating procedures and a description of any physical
impediments that interfere with or limit the ability to conduct
sampling and analysis.
Subsection 3 (3), Schedule E
• The quality assurance and quality control program shall
include the following requirements:
Highlights Continued
• All non-dedicated sampling and monitoring equipment
must be cleaned following each use.
• Minimum number of soil duplicates should be collected
and analyzed
• Minimum number of ground water trip blanks and field
duplicate should be collected and analyzed
• Sufficient field duplicate samples shall be collected in
each medium being sampled, so that at least one field
duplicate sample can be submitted for laboratory
analysis for every ten samples submitted for laboratory
analysis
• Calibration checks should be performed on all field
equipments and should be documented
Highlights Continued
• Where ground water samples are to be analyzed for
volatile organic compounds, one trip blank sample shall
be submitted for laboratory analysis with each laboratory
submission.
• Collecting quality control/quality assurance samples is a
requirement regardless whether soil and /or ground
water samples exceed applicable site condition
standards or standards identified in a risk assessment
(RA)
Highlights Continued
Subsection 3 (4), Schedule E
• The data quality objectives for all types of field data collected during
the phase two environmental site assessment field investigation that
set the level of uncertainty in environmental data shall be such that,
a) the decision-making is not affected; and
(b) the overall objectives of the investigation are met.
• Data quality objectives are qualitative and quantitative statements
that define the type, quality, and quantity of data necessary to
support the phase two ESA
• This should be completed at the planning stage and should be part
of the sampling and analysis plan
• It should include:
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a description of the objective of the data collection
a description of the most appropriate type of data to collect
a description of acceptable levels of decision errors
a description of the quantity and quality of data to be collected
Highlights Continued
Subsection 3 (5), Schedule E
• Standard operating procedures (SOP) shall be developed for all of
the following field investigation methods used in the field
investigation,
(a) borehole drilling; excavating; soil; ground water sampling;
(d) field screening measurements; including calibration
procedures;
(e) monitoring well installation and development;
(g) field measurement of water quality indicators, including
calibration procedures.
• Summarize all tasks that are to be under taken in completion of the
phase two ESA work and the report.
• This includes description of health and safety plan; utility clearance;
selection of drilling equipment; all field tasks, including equipment
used, methods of sample collection etc.
• A SOP incorporating site-specific consideration should be prepared
Highlights Continued
Subsection 3 (6), Schedule E
• The sampling and analysis plan shall include identification of and
rationale and procedures for,
(a) the choice of sampling system, such as a judgmental,
random or grid sampling system;
(b) the sampling media;
(c) the number of samples;
(d) sampling frequency;
(e) sampling points;
(f) sampling depth intervals, including the screened intervals of
the monitoring wells;
(g) other field information to be obtained, including water levels,
field measurements and elevation surveying; and
(h) samples to be submitted for laboratory analysis.
Highlights Continued
Subsection 3 (7), Schedule E
• The sampling and analysis plan shall meet the following criteria:
i. findings as to potentially contaminating activity,
ii. all contaminants of potential concern or appropriate subsets of
such contaminants, and
iii. any other information and matters relating to the environmental
condition of the property which are relevant to an informed
professional judgment.
• After considering the matters referred to above the qualified person
shall determine,
i. sampling and analysis for all contaminants of potential concern, or
appropriate subsets of such contaminants, and
ii. appropriate sampling and analysis for any other relevant
contaminants.
• Refer to the Analytical Protocol. The analysis should be conducted
in parameter groups
• Individual analysis of some parameters are not allowed in the
revised analytical protocol
Highlights Continued
Conducting Site Investigation
Sampling and Analysis of Ground Water
Section 6, Schedule E
• Among other requirements of this section, the ground water
sampling is mandatory under the following circumstances:
– Where phase two property is an enhanced investigation property
– Where there is no soil on, in or under the phase two property
Delineation – Section 7, Schedule E
• Should collect samples from areas of highest concentrations
• The lateral and vertical delineation should extend to the next sample
point meeting the applicable site condition standard or standards
identified in a RA
• The lateral and vertical delineation could occur during the
characterisation of contaminants or during the actions taken to
reduce the concentrations (Remediation)
Highlights Continued
Section 16, Schedule E
Ground Water sampling - exceeding applicable site condition
standards
• Should collect samples from cross- gradient and downgradient
Section 17, paragraph 4, Schedule E – Grain size Analysis
• Is mandatory where fine-medium textured soil standards
are to be applied
• Soil sample for grain size analysis should be representative
of the soil and ground water horizons being investigated
• The samples should spread out to represent entire area
being investigated
Highlights Continued
Ground water flow directions
Section 23, Schedule E
• determining the ground water elevation of each aquifer in
which water level measurements were taken
• the reference elevation of each monitoring well should
be tied to the nearest geodetic or permanent and
recoverable benchmark
• installing a minimum of three monitoring wells, not
placed in a straight line, in each aquifer to be
investigated, at locations and in a manner appropriate to
interpret horizontal flow directions
• determining horizontal hydraulic gradients for each
aquifer
Highlights Continued
• determining vertical hydraulic gradient where ground
water exceeds applicable site condition standards or
standards identified in a RA
• pay particular attention to installing a minimum of three
monitoring wells where ground water sampling has been
conducted, regardless whether any parameter exceeds
applicable site condition standard or standards identified
in a RA
• The monitoring wells should be installed in APEC(s) and
aimed at finding maximum concentration.
Highlights Continued
Review and Evaluation
Phase Two Conceptual Site Model (CSM)
• Elements of the phase two ESA have already been covered in various
sections of the report.
• The challenge is to consolidate all relevant information here using the
headings and sub-headings in Section 43, Schedule E
• Make sure that all requirements under these sub-headings are
described in the CSM
• This include narratives as well as diagrams and figures
• Make sure CSM includes both plan and sections and must have
accurate scale. Approximate scale is not allowed.
• Additionally, all figures, maps, site plans and cross sections should
meet requirements of Section 47, paragraph 15 of Schedule E
Highlights Continued
• Remember that the phase two CSM should be prepared
before action to reduce concentration of contaminants
have been taken (remediation)
• In many situations where remediation has already taken
place, the CSM should construct assessment history
before the remediation.
• Each subsections of Section 43, Schedule E must be
covered in the completing the CSM
• For example lateral and vertical distributions of
contaminants exceeding applicable site condition
standards or standards specified in a RA should show
samples that met standards both in plan as well as
sections
Highlights Continued
Phase Two ESA Report
• In addition to meeting the minimum requirements in
Table 1 of Schedule E
• The report should meet all requirements of Sections 44
to 47 inclusive of Schedule E
• Important among other things are:
– How the general and specific objectives of a phase
two ESA including each of its components were met
– To document the basis for certification in the RSC
Highlights Continued
• In addition to the minimum requirements of Table 1 , the
qualified person is allowed to include any other relevant
information (sections, headings, sub-headings) in the report
• The report should contain original signature of the QP and a
statement by QP confirming of carrying out phase two ESA
• Finally, the phase two ESA report must have the
references, appendices, figures and tables specified in
Table 1of Schedule E
Highlights Continued
Appendices
Survey of Phase Two Property
• Provide a survey of the phase two property which has
been prepared, signed and sealed by a surveyor or,
where the phase two property consists of land that is
administered by the Ministry of Natural Resources under
the Public Lands Act, a description of the phase two
property approved by the Surveyor General.
Highlights Continued
Remediation
Where any action has been taken to reduce the
concentration of contaminants on, in or under a phase
two property
• Provide a remediation appendix that includes sections
specified in Table 1 of Schedule E
• All remediation work should be included in the phase two
ESA report as an appendix and where applicable should
be referred in the text of the report.
Discussions
The floor is now open for questions and
discussions