MEMBERS UPDATE – Fall 2018
CSAP Committee Reports
Full content for all committee reports is available in the News section of the CSAP website.
Performance Assessment Committee Updates
- An issue has been identified relating to site risk classification where vapour concentrations with subslab attenuation applied exceed the Protocol 11 upper cap concentrations, but ambient air measurements within the building show that the breathing zone concentrations of volatile substances meet CSR Schedule 3.3 vapour standards. ENV has clarified that if subslab with attenuation fails high risk, ENV classifies the site as high risk regardless of the breathing zone concentrations.
The response from ENV is based on the Protocol 12 flowchart and the exposure pathway questionnaire for vapour exposure as below:
HV-1: Do substances in air or soil vapour exceed UC concentrations for human inhalation for the applicable land use?
HV-2: Is the site land use urban park, agricultural, residential, commercial or industrial?
If yes to both then = high risk
CSAP members are encouraged to contact ENV to seek clarification regarding situations where soil vapour concentrations are classified as high risk and ambient air concentrations are being considered for site risk classification.
- ENV’s review of the Summary of Site Condition Section 4.2 Hydrogeology section for pre-Omnibus submissions identified issues that were not noted in Detailed Screening and required a Water Use Determination. The issues were as follows:
- Site located within 500m of Fraser River; poor natural water quality exceeding sodium standards. Ruled out DW and AW despite site located next to the Fraser River. They needed a water use determination for no AW; ultimately agreed that AW does apply and submission to be re-submitted.
- Poor natural water quality, 570 m from Fraser River, exceeded TDS but missing elements in P21; DW excluded. Water Use Determination was required and ultimately received from ENV.
- Adjacent to Fraser River, greater than 500 m; estuarine receptor so Water Use Determination was required.
Please ensure that identification of water uses follows the procedures in Protocol 21 and considers the guidance in TG6 and TG8.
- Members are reminded that the Protocol 22 Parkade Attenuation Adjustment Divisor (PAAD) can only be used in a risk-based submission. Use of the PAAD relies on the assumption that an engineered system is in place to increase the air exchange rate within the parkade; such a system is considered risk management, and thus, the requirements for risk management in Technical Guidance 4 apply. Reference should be made to Protocol 22 and Technical Guidance 4 for clarification.
Detailed Administrative Screening Update
The Post Omnibus submission rate continues to lag below historic averages (ten per month) with forty submissions received between Nov 1st, 2017 and October 9th, 2018 (an average of little more than three a month).
AP’s are reminded that the Transmittal Letter is mandatory and to please use the updated template on the CSAP Website and submit as a Word document (the Word format allows the information to be directly imported into the CSAP database, saving hours of data re-entry).
The CSAP Detailed Screening Committee met with the ENV and will be working on the tracking of conditions in the instruments to allow for the updating of the ENV instrument templates among other tasks.
Technical Review Updates:
The Technical Review Committee’s calendar is highly seasonal – just like BC’s climate. Over the summer, we were wrapping up projects and now we are planning for and beginning the next set of projects. For the 2018-2019 fiscal year, budget for Special Projects has been allocated to the following:
- Wrapping up and communicating Toolkits 3 and 4, related to management of petroleum hydrocarbon sites. These documents will undergo is ENV review prior to release.
- Ongoing Leachate test verification using real-world sites, intended to support leachate tests under Protocol 2
- Updates to CSAP’s 2009 vapour sampling guidance; CSAP Soil Vapour Advice and Practice Guidelines were developed nearly 10 years ago before Technical Guidance 4 (TG4) Version 1 was published. Now with the update of the TG4 (version 2) and a new protocol (Protocol 22) in place, there is a need to revisit the CSAP Soil vapour practice guidelines and identify what need to be updated. This year’s project is to develop a detailed scope of work for updating the guidelines. CSAP has established a team of vapour specialists to meet and develop the scope of work.
- Perfluorinated and polyfluorinated substances are emerging contaminants for which ENV prioritized the development of standards that were recently introduced to the Contaminated Sites Regulation on November 1, 2017. CSAP recently issued a Request for Proposals to prepare a guidance document on the investigation these substances. Proposals are currently under review and the project will begin in November 2018.
- Engagement with ENV on risk-based remediation in the broader context of remedial options analysis – submission rates for instruments dependent on risk assessment have been increasing quickly (64% of submissions for Nov 1 2017); however, there are ongoing discussions about the conditions on the Certificates of Compliance for source and affected parcels. Using this seed money, CSAP will explore with ENV the development of remedial options guidance for greater certainty by both qualified and approved professionals.
CSAP’s Technical Review Committee continues to solicit ideas for the next fiscal year (2019-2020) – submissions using this format (see attached) are welcomed.
In addition to the above Special Projects, the Technical Review Committee will be conducting technical reviews on incoming guidance. If you are interested in volunteering for these reviews, please email Nelly Pomareda, indicating your area(s) of expertise.
The Membership Committee is reviewing feedback from the 2018 applicants and experience reviewers to identify opportunities to further clarify guidance (1) to new applicants regarding the application process and the necessary documentation of experience and (b) to experience reviewers to regarding the minimal level of competence that must be demonstrated by applicants to be approved to write examinations.
A reminder to those who are due for membership renewal December 31, 2018 that at least one AP submission is needed before that date and also a record of 150 PD hours in order to complete the renewal process along with proof that you remain a member in good standing of your parent organization. Refer to Appendix 9 of the CSAP Membership Guidelines for specific details on the CPD hour requirements. PD hours may be submitted through the online submission manager.
Examinations are scheduled to be held November 6th and 7th. This year’s examination candidates break down as follows:
|Nov 2018||Rewriting||New Applicants||CSAP Member||TOTAL|
CSAP would like to express our sincere appreciation for Paul Gordon’s active participation as our Industry Representative Director for the past two years. Thank you Paul for your service and support to the CSAP community.
It is our pleasure to welcome Anne Bancroft-Jones from Polygon Homes & UDI’s Contaminated Sites Committee as she steps into the appointed Industry Representative Director role. We look forward to working with Anne and her valuable insights and new ideas. Please join us in welcoming Anne and wishing her the best as our new board member.
CSAP AP Forum Now Open! Join Now
CSAP Event Calendar:
CSAP Fall PD Workshop
Date: Nov.15th, 2018
Time: 8:30 check-in, 9 am start – 4:00pm
Venue: 1055 Canada Place, West Meeting Level two, Rooms 211 – 214
BCEIA Vancouver Winter Social
Date: Nov.15th, 2018
Time: 4pm – 8pm
Venue: Terminal City Club, Vancouver, BC
Message from the President
Fall has come again. A little more relaxed than last year, but I hope everyone is comfortably busy. Here are a couple updates.
Submissions: After the flood of submissions last year, the amount of submissions has decreased, but are starting to pick up again.
Background Groundwater: ENV has released the background groundwater numbers. Have a look, they have certainly helped on several sites.
Protocol 27 Soil Leaching: I have heard of at least one successful application of Protocol 27 for arsenic in the Victoria area. If others have been able to use it successfully would you please consider emailing Lavinia with the location and the parameter and copying myself? We are trying to find a way to share areas that the protocol works for.
In The News: