MEMBERS UPDATE – Summer 2018
Ministry Updates/ Clarifications:
- The Ministry is requesting your assistance to complete a survey regarding the suite of contaminated site services provided by the Land Remediation Section. The survey is part of an internal Ministry effort to examine and evaluate the ways in which contaminated sites services are provided in support of administering the Environmental Management Act and Contaminated Sites Regulation, and feedback will inform efforts to improve the client experience in obtaining these services. Take survey here.
The survey takes approximately 10 minutes to complete, allowing for more or less time depending on how many or few contaminated sites services you use. The survey is open for approximately 6 weeks, and will close on September 5, 2018. Questions regarding the survey can be forwarded to email@example.com.
- Progress report on clean-up of contaminated sites has been released, see
A summary of all Ministry Clarifications is available here.
CSAP Committee Reports
Full content for all committee reports is available in the News section of the CSAP website.
Performance Assessment Committee Updates
1. Clarification regarding the vapour refinement step for substances listed in Table 1 of Technical Guidance 4 was provided by the ministry at the November 2017 PD Workshop. A Q&A relating to this clarification is provided below.
Q: Can the absence of detectable concentrations of substances listed in Table 1 of TG4 be used to refine the list of vapour PCOCs when the contaminant source is not diesel or gasoline. For example, if naphthalene is identified as a vapour PCOC at a site where poor quality fill has been identified as an APEC, can it be removed as a vapour PCOC if no detectable concentrations are reported in soil or groundwater?
A: Yes, the substances listed in the Table 1 of TG4 can be removed as vapour PCOCs regardless of the source. Substances not listed in Table 1 of TG4 cannot be refined based on non-detectable concentrations in soil and groundwater data and must be assessed using the approaches described in TG4. (Reference – Peter Kickham at November 2017 PD Workshop)
While the reference to gasoline and diesel sources in TG4 appears to limit the refinement step for the substances listed in Table 1 to vapours originating these sources, the ministry response to the question broadens this interpretation to allow the vapour refinement step for Table 1 substances originating from other contaminant sources.
2. The PAC has been reviewing the Submissions Screening Guidelines and the Performance Assessment Guidelines. The following clarifications have been added to the Guidelines, and the new versions will be posted to the CSAP website in August:
a) During a Performance Assessment (PA) only a single Addendum report can be submitted. This typically includes a Draft Addendum report submitted to CSAP prior to the submitting AP(s) meeting with the PA panel, followed by a Final Addendum report within two months from the date that the submitting AP(s) receive the PA Stage 1 Review Finding
b) Submitting AP(s) must respond to Detailed Screening questions within 30 days of receiving them from the Administrative Screener (Anna).
3. For the specification of reasonable and foreseeable future land uses at a site and/or affected property, the AP should provide information in consideration of the factors listed in CSR Section 12:
(5) In specifying the primary land use, water use or sediment use under subsections (3), (4) and (4.1), a director must take into account current and reasonable potential future land, water and sediment uses based on the following factors:
(a)current and proposed zoning for the site;
(b)land use and planning policies of the government or the municipality or municipalities in which the site and neighbouring sites are situated;
(c)current site activities;
(d)proposed site activities;
(e)current and proposed uses for surface water and groundwater on the site;
(f)current and proposed land use, and surface water and groundwater uses of neighbouring sites;
(g)current nearby uses of other surface water and groundwater;
(h)the potential for surface water and groundwater to cause pollution;
(h.1)current and proposed uses for sediment at neighbouring sites;
(h.2)potential for surface water, groundwater and sediment to cause pollution on neighbouring sites;
(i)other factors that a director considers appropriate in the circumstances.
Detailed Administrative Screening Update
The Submission rate for Omnibus submissions continues to be below historic averages (10 per month) with twelve submissions received between Nov 1st, 2017 and March 31st, 2018 and a further sixteen received since April 1st (an average of less than 3 a month).
AP’s are again reminded that some of you are not using the new Version 9.0 instrument templates which are available in the CSAP Submission Manager. Please ensure that the instrument version you are using includes “Version 9.0 R” in the footer of the instruments.
The new Annotated Summary of Site Condition has been posted to the CSAP website and Submitting AP’s are encouraged to refer to this document when preparing submissions.
Screening issues that have come to light since our last newsletter include the lack of a metes and bounds survey for CoCs that list specific areas where different risk controls apply. It is not acceptable to reference these areas in figures in reports and these areas should be shown either directly in Schedule A site plan, or in an attached figure, and include a metes and bounds description in the CoC.
- The committee has completed updates to the Membership Guidelines, Application Guidelines and Application Forms in order to improve clarify and streamline the application review process. Highlights of changes were presented at the June 6th AGM and are expected to be ready for posting to the website by end of July.
- Reminder that the deadline is September 7th, 2018 for applications to write the regulatory exam for those members who were unable to complete a CSAP submission as part of their renewal requirements.
Professional Development Updates:
*New Forum for APs – Hello APs! CSAP is happy to announce that we now have our Member’s Forum up and running. Now all we need is YOU. Got a question about a submission you are working on? Want to double check some of your assumptions? Why not post a question to the Forum. Or why not provide your thoughts in response to someone else’s question? Remember, the dialogue is intended to be open, BUT none of the responses replace or supersede those that may be provided by ENV or the requirements under the Environmental Management Act. No question is a bad question, and no answer is necessarily correct. So why not try this out? We hope to see you there soon! Sign up here.
PCOC List has been posted and can be found here.
Congratulations to Raminder Grewal of Keystone Environmental Ltd., for being named as an EY Entrepreneur of the Year 2018 Pacific Region finalist! Read more
CSAP Event Calendar:
Webinar – CSAP Submissions
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
More info to come
Industry Event Calendar:
SABCS 8th Annual Technical Workshop on Contaminated Sites
Earl and Jennie Lohn Policy Room, SFU Harbourside Centre, 515 West Hastings Street Vancouver, BC
Sept. 26th, 2018
SABCS 8th Annual Conference on Contaminated Sites
Segal Building, Room 1200 – 1500, 500 Granville Street, Vancouver, BC
Sept. 27th, 2018
*The Technical Workshop theme is Innovation in Data Acquisition, Analytics and Automation for Contaminated Sites and Mining Environmental Applications ~ All speakers are by invitation including several from the US. Agendas will be available shortly.
Message From the President
I hope everyone is getting some time away this summer. I thought it would be good to provide a couple of updates:
Professional Reliance: The Professional Reliance review has come out and there were two suggestions for improvement at CSAP. We are reviewing them now.
Background Groundwater: ENV is working hard on background groundwater and CSAP continues to provide support when asked. We anticipate an increase in the number of submissions when ENV is finished their review.
Welcome Back Catherine: Catherine is returning to work after a little time away. A big thank you to everyone while Catherine was away healing.
In The News: