Environmental Services in Ontario

Recently Posted Records of Site Condition

2011-12-22T12:14:00.000-08:00

Did you know that all RSCs that have been acknowledged and posted by the MOE are available to view online? This can be a good resource for understanding what information is required in an RSC and can provide a list of Qualified Persons (QPs) who have successfully navigated the changes in legislation and are able to provide environmental consulting services for you as you seek to file an RSC.

Since the changes to O.Reg 153/04 (amended 269/11) in July of 2011, less than 20 RSCs have been posted by the MOE. AEL is the firm responsible for 3 of the 12 RSCs (25%) that have been successfully posted for privately held land (as of today). This is something that our team is very proud of and attributes to strong leadership by our Qualified Person, Paul Wilson, as well as efficient project management, field work, and reporting by all members of our team. We have found that clear communication between all parties, attention to detail in every task, and the use of on-site laboratory testing allows us to complete RSCs with an extremely high level of efficiency.

If you're interested in discussing an environmental consulting project for 2012, please feel free to give us a call. We're happy to answer any questions you might have and wish you the best in the new year.

Excavating equipment on one of our 2011 sites

Remediation and Clean-Up

2011-11-29T07:57:00.000-08:00

So, you've completed your Phase I ESA, and there were some red flags indicating possible contamination on your site because of historical activities. You tested the soil and groundwater in a Phase II ESA, and some chemicals of concern were above allowable limits. Now what?

First, take time to get a complete picture of what you're dealing with. Have all areas of the site been examined thoroughly? A call to the MOE is often necessary in order to ensure that all all the necessary investigation is complete before remediation starts. This will save time and money in the long run!

Next, discuss remediation options with a environmental consultant, qualified under O.Reg 153/04, who can help you decide what type of remediation is most practical, as well as thinking critically about the viability of a remediation project in general. Some sites are very difficult to remediate and an environmental consultant has the knowledge and tools to help you make the best decisions in an efficient way.

When you plan your remediation, three strategies may be used.

In Situ Remediation - Means that the contamination is dealt with on site. This may be done, for example, using bacteria to break down hydrocarbons in the case of PHC contamination. In situ remediation is often fairly expensive and slow, but can be very useful as it is the least disruptive type of remediation, making it ideal for contaminants that have been spread under buildings or in large plumes around groundwater resevoirs.
Ex Situ Remediation - Means contamination is dealt with in a place other than its original location. This could mean removing truckloads of soil, treating with bacteria (in the case of PHC contamination) and returning it to the site. Ex situ remediation employs some of the same techniques as in situ, but can be much faster but also much more disruptive. Ex situ remediation can be less costly than removing large amounts of soil and backfilling, which is discussed below.
Removal from Site - This, as the name suggests, involves excavating contaminated material (soil, sediment) and disposing of it, then backfilling the area with uncontaminated material. This is used in sites with easy access and where disposal costs are lower than remediation costs. It is a relatively quick solution but can be extremely disruptive- it is hard to operate a business around 50+ dump trucks coming and going and a 20ft deep hole in the parking lot!

Once contamination has been removed to within regulatory standards, the owner must show the MOE proff that the property has been remediated. This can be done by collecting closure samples - keep in mind that closure samples should be finalized before backfill is added in order to avoid having to re-excavate soil that wasn't thoroughly cleaned!

We hope that this has been helpful. As always, feel free to send questions or comments - info@aelenv.com

3 Things to Know Before Filing an RSC

2011-11-24T13:03:00.000-08:00

Under the new O.Reg 153/04 amendments, filing a record of site condition has become more challenging. There are good reasons for the changes that were made- more consistency in reporting and tracking contaminated properties, more stringent requirements for remediation- but the amendments have created a lot of stress and confusion for some people who have filed RSCs in Ontario after July 2011.

To avoid this stress and confusion, there are a few things you should know.

1. Submissions now occur through the Service Ontario website- while they have worked out many of the bugs that were found when they switch-over happened, a few things are still giving people trouble. For example, the site won't accept large attachments (like the PDFs necessary for submitting the RSC), so instead, you can talk to the MOE and let them know you'll upload a blank PDF and then email them the documents.
2. When submitting a certificate of status on behalf of a client, MOE requires the certificate to be less than a month old. For this reason, wait until just before you're ready to submit to request the certificate of status.
3. The new submission requirements include more drawings of the site than previous RSC filings needed. For this reason, it is essential to have a team of people who are experienced in providing drawings of lateral and vertical extents of impact. AEL environment can help you with those, and other needs related to RSC filing.

Confused about the RSC process in Ontario? Let us help- we're happy to answer any questions!

Potentially Contaminating Activities

2011-11-21T09:33:00.000-08:00

Under the amended O.Reg 153/04, you must file a Phase II if the land in question has been the location of a potentially contaminating activity, at any time in its history. You may be wondering what activities qualify as "potentially contaminating"...check out the lists below (adapted from Table 2 of the regulation) - one before the amendments, one after.

Old List

- areas where dry cleaning operations have occurred
- areas where fuel storage tanks are or were present
- areas were PCB containing materials were used or stored
- areas of a property adjacent to industrial activities
- areas of a property adjacent to or across the street from a gas station
- areas where pesticides or herbicides were potentially used

New List

Acid and Alkali Manufacturing, Processing and Bulk Storage

Adhesives and Resins Manufacturing, Processing and Bulk Storage

Airstrips and Hangars Operation

Antifreeze and De-icing Manufacturing and Bulk Storage

Asphalt and Bitumen Manufacturing

Battery Manufacturing, Recycling and Bulk Storage

Boat Manufacturing

Chemical Manufacturing, Processing and Bulk Storage

Coal Gasification

Commercial Autobody Shops

Commercial Trucking and Container Terminals

Concrete, Cement and Lime Manufacturing

Cosmetics Manufacturing, Processing and Bulk Storage

Crude Oil Refining, Processing and Bulk Storage

Discharge of Brine related to oil and gas production

Drum and Barrel and Tank Reconditioning and Recycling

Dye Manufacturing, Processing and Bulk Storage

Electricity Generation, Transformation and Power Stations

Electronic and Computer Equipment Manufacturing

Explosives and Ammunition Manufacturing, Production and Bulk Storage

Explosives and Firing Range

Fertilizer Manufacturing, Processing and Bulk Storage

Fire Retardant Manufacturing, Processing and Bulk Storage

Fire Training

Flocculants Manufacturing, Processing and Bulk Storage

Foam and Expanded Foam Manufacturing and Processing

Garages and Maintenance and Repair of Railcars, Marine Vehicles and Aviation Vehicles

Gasoline and Associated Products Storage in Fixed Tanks

Glass Manufacturing

Importation of Fill Material of Unknown Quality

Ink Manufacturing, Processing and Bulk Storage

Iron and Steel Manufacturing and Processing

Metal Treatment, Coating, Plating and Finishing

Metal Fabrication

Mining, Smelting and Refining; Ore Processing; Tailings Storage

Oil Production

Operation of Dry Cleaning Equipment (where chemicals are used)

Ordnance Use

Paints Manufacturing, Processing and Bulk Storage

Pesticides (including Herbicides, Fungicides and Anti-Fouling Agents) Manufacturing, Processing, Bulk Storage and Large-Scale Applications

Petroleum-derived Gas Refining, Manufacturing, Processing and Bulk Storage

Pharmaceutical Manufacturing and Processing

Plastics (including Fibreglass) Manufacturing and Processing

Port Activities, including Operation and Maintenance of Wharves and Docks

Pulp, Paper and Paperboard Manufacturing and Processing

Rail Yards, Tracks and Spurs

Rubber Manufacturing and Processing

Salt Manufacturing, Processing and Bulk Storage

Salvage Yard, including automobile wrecking

Soap and Detergent Manufacturing, Processing and Bulk Storage

Solvent Manufacturing, Processing and Bulk Storage

Storage, maintenance, fuelling and repair of equipment, vehicles, and material used to maintain transportation systems

Tannery

Textile Manufacturing and Processing

Transformer Manufacturing, Processing and Use

Treatment of Sewage equal to or greater than 10,000 litres per day

Vehicles and Associated Parts Manufacturing

Waste Disposal and Waste Management, including thermal treatment, landfilling and transfer of waste, other than use of biosoils as soil conditioners

Wood Treating and Preservative Facility and Bulk Storage of Treated and Preserved Wood Products

Is your property affected by these changes? Check out our information on filing a Phase II ESA or contact us for more help.

Phase II Environmental Site Assessment (ESA)

2011-11-21T09:11:00.000-08:00

As mentioned in the last post, the Phase I ESA is focused on the history or legacy of the property. The Phase II ESA is centered around different data- the current condition of the site, confirming or dismissing the possibility of contamination as "unearthed" (see that? A remediation pun!) in the Phase I.

A Phase II ESA involves sampling soil and groundwater for potential contaminants. Laboratory results for the samples are compared to applicable criteria (based on land use, environmental factors and water use at the site). If no contamination is found at the site then it is possible to submit an RSC for the site. If contamination is found at a site then further rounds of sampling are usually performed in order to fully understand the scope of the problem. Test results, site maps and geological data are combined in data management programs to delineate the extent, identify sources and speculate the fate of contamination at the site.

Like the Phase I ESA, the Phase II ESA serves as a guidance document for future activities at the site. The conclusion of the investigation provides the owner with suggestions for remediation of the problem, cost estimates for remedial alternatives and rough timelines for remedial activities.

Also like the Phase I ESA, the Phase II ESA has undergone an overhaul under the amendments to O.Reg. 153/04. Major additions to the Phase II ESA process include:

i) Mandatory groundwater sampling at all sites where a Phase II ESA is performed

ii) A list of seventy one (71) potentially contaminating activities at sites that will likely warrant a Phase II ESA before the property can submit an RSC

iii) Mandatory Phase II ESAs for properties that have ever operated as gas stations, automobile repair facilities or dry cleaning facilities

These changes are aimed to bring a level of consistency to the quality of Phase II ESAs being performed and to ensure that all properties are thoroughly investigated prior to proceeding to the RSC submission or the site clean up phase.

What is a Phase I ESA?

2011-11-14T07:39:00.000-08:00

Simply put, a Phase I ESA (Environmental Site Assessment) is a review of all available information regarding a property, collected in order to understand the environmental legacy of the property and what has occurred there historically. To complete a Phase I ESA, your environmental consultant will need to look at:

Reviews of several private and government databases (spill records, underground tank records, waste disposal records)
Aerial site photos
Interviews with site occupants and neighbors
A site walkover by a QP (Qualified Person)

The Phase I ESA is important because it will determine next steps in submitting an RSC (Record of Site Condition). If the Phase I ESA isn't completed properly or thoroughly, it will result in costly changes during the RSC process.

As of July 2011, the MOE introduced legislature that significantly changes the requirements of the Phase I ESA. Notable changes include:

Title searches on the property must proceed back to 1850 or the time when the property was first developed
The QP must have access to all areas of the site, barring safety concerns
Any property that ever operated as a gas station, auto repair shop, or dry cleaner MUST automatically undergo a Phase II ESA in order to submit an RSC
If the owner chooses to change consultants during the process, all work previously performed on the site must be reviewed and signed off by the new consultant

These changes make the ESA process more time consuming and more in-depth, and consequently more expensive for owners. Property owners are advised to use a high degree of discretion when choosing a consultant to work with (see change #4). Questions? Email us.

Brownfields: What are they?

2011-11-10T12:46:00.000-08:00

Essentially, a brownfield is a piece of land that has been previously used and potentially contaminated. The land may be abandoned and run down, or it could have existing structures that are going to be removed in order to redevelop the property.

Brownfields matter to communities for a few reasons. First and probably most importantly, contamination on a brownfield site can be dangerous to human, animal, and plant health. Even if the site looks clean, there could be contaminants and unwanted chemicals in the soil or groundwater. For this reason, it is important to closely examine brownfields and know exactly what has happened on that piece of land (with a Phase I ESA), and complete necessary clean-ups (remediation).

A brownfield awaiting remediation and redevelopment

Brownfields are also important because they're a significant space for economic development. When previously unuseable or underused sites are redeveloped for new and exciting projects, communities grow and businesses can expand. Brownfield redevelopment really is a win-win activity. Have questions about brownfields in Ontario? Let us know!

Meet AEL environment

2011-11-10T12:26:00.000-08:00

Welcome!

We're a niche environmental engineering firm based in Mississauga, Ontario, Canada. Our work is focused on site assessment and remediation at a wide variety of sites across Ontario and beyond, with extensive experience on both residential and industrial projects.

One of our remediation sites in Northern Ontario.

Our team of engineers and scientists has over 20 years of experience providing smart and efficient solutions for contaminated sites and other environmental consulting projects, doing everything from small Phase I ESA work to large scale remediation projects.

Check back here for updates on projects as well as helpful information about environmental consulting issues and the RSC process in Ontario.