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MEMBERS’ UPDATE – Spring 2024

In this issue:

Message from the President

Happy springtime everyone. I hope you are all enjoying the longer days (and I don’t mean by working more).

As our members will have seen, ENV recently made significant changes to the scenarios requiring a preapproval. I welcome these changes as I believe this will have a tangible effect in reducing timelines overall, which in turn will benefit our clients. Reducing administrative timelines is always a welcome outcome, especially since so many of our applications are related to housing developments. We continue to work with ENV to identify opportunities where we can provide support and potentially help reduce their queue. On a somewhat related note, I would encourage our members to provide feedback on ENV’s proposed P19 changes.

At CSAP Society, we finished the fiscal year with more submissions than anticipated. In particular, we saw even more Approvals in Principle than last year as well as a corresponding uptick in the number of Certificates of Compliance applications that have an AiP in place. The CSAP Operations team has done a great job keeping pace.

I look forward to seeing many of you at the AGM & PD Workshop in June and I hope folks can stick around for the happy hour afterwards.

Andrew Sorensen

Ministry Updates

Site Risk Classification Report Clarification

Question: Are separate SRCRs always required for affected parcels?

Separate Site Risk Classification Reports (SRCRs) are not always required for affected sites, but a quick answer is “it depends”; namely on the type of trigger that is being applied, and whether it is applied to the source or an affected site. In the scenario of a Notification of Migration or “NOM” trigger:

  • If there are no Upper Cap Concentrations (UCCs) at the source site, then a SRCR is required for the source site. An Exposure Pathway Questionnaire (EPQ) is not required (source site = SRCR).
  • If there are UCCs at the source site, then the source site requires an SRCR in addition to an EPQ (source site = SRCR + EPQ).
  • If there are UCCs at the affected site, then the affected site also requires a separate EPQ (source site = SRCR + EPQ and affected site = EPQ).
  • If there are UCCs at the source site and if the off-site affected site is or likely is high risk (HR) (as checked off on the NOM form), then the affected site also requires a SRCR. An EPQ for the affected site is also required if there are UCCs at the affected site (source site = SRCR + EPQ and affected parcel = SRCR + EPQ (if UCC present)).

However, an affected parcel may not always have UCC, but still may be HR due to mobile NAPL, and would therefore not need an EPQ. A general rule of thumb is that the source site will always require a SRCR (unless an exemption applies), an EPQ is required if UCC are present (regardless of which site it is, source or affected), and if an affected site is high risk then it will require a SRCR (unless an exemption applies).

Where the submission requirements get complicated is when you have a new trigger for affected parcels after submitting a NOM. Using the example above (i.e. NOM trigger, SRCR applies to the source site, assume the source site is not HR, with no UCC at either parcels), the client submits a NIRI for the affected parcel. The affected parcel would require an SRCR, despite not requiring one under the NOM trigger initially. You must also assess the multitude of exemptions, and determine if any of them apply to the site or at any affected parcels.

Additionally, when applying for multiple ministry certification documents, such as an Approval in Principle of a Remediation Plan or a Certificate of Compliance, each site is treated independently and requires its own SRCR, and requires a SRCR and EPQ if there are UCC present.

Performance Assessment Committee and Preliminary and Detail Administrative Screening Committee Updates

Site Risk Classification Reporting for Affected Parcels
Separate SRCRs are not always required for affected parcels but depend on site circumstances and on the type of trigger which applies. For a “NOM” trigger, the Source Site only requires an SRCR if there are no UCCs. If there are UCCs at the Source Site, then the Source Site also requires an SRCR + EPQ. If there are UCCs at the off-site Affected Parcel, then the Affected Parcel also requires an EPQ. If the off-site Affected Parcel is or likely is HR (as noted on the NOM), then the off-site Affected Parcel also requires a separate SRCR + EPQ if there are UCCs (which may not always the case if HR due to mobile NAPL).

New SRCRs can arise when a new trigger for Affected Parcels present themselves subsequent to the NOM. Using the example above (i.e., NOM trigger, SRCR applies to the source site, assume the source site is not HR, with no UCC exceedances), a client submits a NIRI for the Affected Parcel. The Affected Parcel would require an SRCR, despite not requiring one under the NOM trigger. There are also a multitude of exemptions, which practitioners must determine if any apply to the Source Site or Affected Parcels.

For a recent submission, SLRA was applied for a risk-based COC application to RLLD standards. Contaminated soil in the upper 1 m is present within a small area of the Site situated around an existing tree, having metals concentrations exceeding CSR Sch 3.1 Part 3 Eco Health and/or Toxicity to soil invertebrates and plants. The soil contamination did not appear to extend below a 1 m depth and the area was covered with concrete, which will remain as part of the Site’s redevelopment.

Section 3.2 of Protocol 13 indicates this protocol must not be used at contaminated sites where any of the following conditions are present: “deep-rooting plants or trees (root structures extending below 1 m depth) in areas of soil or groundwater contamination [at sites where wildlands (natural or reverted), agricultural or low-density residential land uses apply]”. It further states “This protocol must also not be used at contaminated sites where exposure pathways are present that are not specifically identified in Section 4.3.” Answers to EPQ items HS-3 and TS-3 (Is the ground surface above contaminated soils uncovered?) indicated ‘No’, given the contaminated soil is covered by concrete.

Clarification was sought from ENV on whether SLRA could be used in this site circumstance given tree roots were exposed to contaminated soil in the upper 1 m.

ENV indicated DRA was required mainly because of Point 1 below:

  1. The intent of TS-3 is to determine if ecological receptors may be exposed to contamination in the top metre, which is the case given that there’s a tree in the area of contamination. The “No” answer to TS-3 means Detailed Risk Assessment (DRA) is required to assess the current and potential future health of the tree.
  2. The precluding condition related to the presence of “deep-rooting plants or trees” indicates that if the tree’s roots do or may extend below the top metre (which this precluding condition is assuming to be “clean”) then DRA is required to evaluate contamination below 1 metre.

ENV also indicated some proponents choose to remove trees instead of applying risk-based standards, which may not be an option depending on where the site is located and whether the local municipality has bylaws protecting healthy trees (e.g., City of Vancouver). If they aren’t allowed to remove the tree, then DRA is the only option to apply CSR risk-based standards when there’s contamination in the top metre associated with a tree.

Protocol 6 (P6) Preapprovals
ENV recently updated its P6 Preappovals webpage earlier this month. Scenarios that no longer require P6 Preappovals include Wide Area Fill sites and sites with Flow Through Contamination, for example. Members should review the ENV updates to the webpage (Preapprovals – Province of British Columbia ( to confirm whether a P6 Preapproval is still required for submissions going forward. Reporting guidance and expectations are also provided for various scenarios. Find the ENV Webinar on P6 Preapprovals here.

Please note that because Protocol 6 would have also required a revision, which was not included with the Preapprovals update, AIP recommendations by APs still require remediation to be completed within a 5-year period, as per Table 1 of Protocol 6, Version 12.0, dated March 20, 2023.

A summary of previous PAC Updates is available here.

Screening Updates

Detailed Screening

Since our last update, the quality of submissions continues to be high and generally speaking, only minor issues are identified during Detailed Screenings. Here are a few tips beyond the standard ones (e.g., spelling of substances!) that will help to avoid issues being identified during Detailed Screenings:

  • The following requirements for Site Risk Classification Records should be considered when preparing applications:
    • In cases where a SRCR has been submitted to ENV within the last 5 years, or if the application is for a Determination, an SRCR is not required.
    • If you tick the box on the CSSAF indicating that an SRCR was submitted within the last 5 years, please check the dates to ensure that this is the case.
    • If the SOSC and CSSAF indicate that the parcel is not a high-risk site, check that this is consistent with the SRCR (i.e., SRCR also indicates non-high risk).
    • If concentrations greater than the Protocol 11 Upper Cap Concentrations are identified in the SRCR, UCC cross-sections or plume figures must be included with the SRCR.
  • As noted in the PAC update, there have been changes to the scenarios for which Protocol 6 Preapprovals are required. The following are scenarios where preapproval is no longer required:
    • You are remediating a flow-through contaminated site;
    • There is area wide contamination;
    • You want to get certification for an affected parcel before the source site is fully remediated;
    • You are only remediating part of an operating facility and need a certification document or
    • site release for that area; and,
    • Contaminants appear in environmental media because of beneficial uses.

For the above scenarios, P6 applications for certification documents must include a summary of the scenario in Section 4.8 of the Summary of Site Condition. Where there is information presented in the submission documents that are reviewed as part of a Detailed Screening that indicate one of these scenarios is likely, screeners will be checking to confirm that the scenario is sufficiently summarized, with supporting details to demonstrate that the conditions assessed are aligned with one of these scenarios. Further details on each scenario are provided on ENV’s preapproval webpage.

Review Services Committee Updates

The RSC continues to complete reviews of reports submitted in support of the Director’s requirements identified in certification documents. For further details regarding the type of work the RSC completes please see our webpage.

For those completing submissions we encourage you to use the supporting information found at the link above including utilizing our required transmittal letter and considering our recommended checklist.

Generally, the RSC does not review reports submitted regarding high-risk sites but in some circumstances the applicant has received permission or direction from ENV to submit through CSAP Society rather than directly to the ENV. In those instances we ask that you note on the CSAP transmittal letter that ENV permission was obtained to submit directly to CSAP Society to avoid delays.

We also note the CSAP fee schedule footnotes were recently clarified regarding submissions that reference more than one compliance document. The CSAP review fee of $2000 is applicable to each certification document being reviewed by the RSC. For example, if one Monitoring Report is submitted to cover two AiPs, the fee would $2000 for each of the two AiPs.

Technical Review Committee Updates

Over the past three months the TRC has been working on developing the scope and writing the request for proposals (RFPs) for the Special Projects that CSAP will be funding for 2024/25. The Special Projects selected this year were generated from a running list of projects and topics suggested by members. This year the TRC will be undertaking three (rather than two) special projects which we hope will be of interest to all CSAP members. The CSAP Board recently approved the budget for all three projects and the RFPs will be circulated to members in late April/early May. Further details on these projects are below.

  • Background Soil Concentrations – Feedback from the CSAP membership has indicated that the current list of regional soil background concentrations may not accurately reflect the range of parameter concentrations commonly observed during investigation. The purpose of this project is to identify whether there is sufficient information available to support changes/additions to the Protocol 4 background soil concentrations.
  • Background Groundwater Concentrations – CSAP practitioners have identified that natural background levels of metals in groundwater are still an issue at sites in other parts of the province including the Northeast BC Region and the Prince George Region. When conducting investigation of these sites, elevated concentrations of metals unrelated to site activities are often encountered and result in additional costs and time delays. At the time of development of Table 1 of Protocol 9, insufficient data was present in these two regions and in other areas of the province to develop a suitable database for evaluation. The purpose of this project would be to expand the dataset such that background concentrations for groundwater could potentially be developed for other regions of the province.
  • Review of Groundwater Plume Stability Assessment Methods – The purpose of this project is to provide practitioners with some options for stability assessment methods that can be used for assessing the stability of groundwater contaminant plumes to confirm that contaminated sites in BC are being assessed using the best available technology.

The TRC is also working on wrapping up the last of its 2023/24 projects:

  • Shallow Vapour Attenuation Factors – The purpose of this project was to provide practitioners with science-based approaches for assessment of vapours in indoor air where groundwater is near to or in contact with the building foundation. The project also included a desktop evaluation of attenuation factors and information from other jurisdictions as it relates to the new soil relocation legislation and the triggers for soil vapour assessment.

Other TRC activities underway include evaluation of scholarship applications received at the end of March. CSAP awards up to three scholarships annually to graduates studying in the area of contaminated site investigation and remediation. This year we received nine applications and the TRC is currently reviewing the applications. Scholarships will be awarded in May and announced at our Spring AGM.

If you have any suggestions for a topic that you would like the TRC to tackle, please send your ideas to [email protected].

Membership Committee Updates

The Membership Committee would like to thank everyone who submitted a record of their PD hours by the December 31 deadline. The Committee reviewed the renewal requirements for 29 members who renewed their membership at the end of 2023.

The 2024 exam development process is underway. Thank you to all the Experience Reviewers and Exam Developers who have contributed their time and expertise to aid the Exam Sub-Committee in preparing for this year’s exam process.

Please note the following deadlines and dates:

  • Deadline for Applications for New Members: April 26, 2024
  • Deadline to Application for Sitting of the Regulatory Exam for Existing Members (who have not fulfilled submission requirement): August 31, 2024

2024 Exam Dates

  • Numerical Technical Assessment: September 10, 2024
  • Risk Assessment Technical Assessment: September 11, 2024
  • Regulatory Exam: November 14, 2024

Professional Development Committee Updates

AGM & PD Workshop coming up June 4
Our AGM & PD Workshop for CSAP members is being held June 4 at the Vancouver Convention Centre West. We’re putting the final touches on the agenda but can confirm the following sessions:

  • ACEC-BC 2024 Consulting Engineer Fee Guideline
  • ENV sessions: Director’s Update, Policy Update, and Site Release Process
  • TRC Special Project: Shallow Vapour Attenuation Factor
  • Validity of Older ENV Approvals Panel Discussion

Members, register at the link above and watch your email for more details in the coming weeks.

Lunch and Learn
We’ve held two sessions for far this year, a public session on Using Statistics to Assess Soil in February and a Members’ Open Forum in April. Your participation is valuable and we look forward to more fruitful discussions at future sessions.

The next session, open to the public, takes place May 23 at 11 a.m. and will be a panel session on tetraethyl lead. Watch your email and the Lunch and Learn webpage for the Zoom link.

Submission Statistics update (as of March 31, 2024)

What’s new at CSAP

  • Register now for the AGM & PD Workshop, June 4 at the Vancouver Convention Centre West.
  • A reminder that all P6 Submissions and Report Review applications are to be sent to [email protected] including all follow-up communications and correspondence.

In the news

If you have a link of interest, please forward it to [email protected].

Professional development opportunities