Will “Clean Sites” in Ontario Now Require Soil Remediation?

As you may be aware, there have been several changes to the environmental regulations in Ontario. One of these changes (O.Reg. 511) revises sampling and laboratory protocol for Volatile Organic Compounds (VOC) analysis in soil or sediment. On the surface this seems like a “technical detail,” that means little to the regulated community in Ontario; however, this change can have a dramatic affect on the detection of VOCs.

Background
On July 1, 2011, the new protocol specified in O.Reg. 511 will require soil or sediment samples collected with zero headspace (including “encore” sample devices) be received at the testing laboratory within 48 hours. Additionally, the laboratory must extract or freeze the samples on the day of receipt. The laboratory must extract frozen or field preserved samples within 14 days of sampling. The purpose of using the new method is to reduce VOC loss from sample collection to analysis.

From a logistics standpoint, remote locations where overnight shipping is limited or unavailable, there needs to be consideration given to field preservation techniques. The approved field preservation includes the use of aqueous sodium bisulphate or methanol techniques to preserve the soil or sediment samples (United States Environmental Protection Agency Method 5035A).

What to Expect
Several US states have used the Method 5035A technique since the late 1990s and have observed (where VOCs were present) that VOC concentrations increase by up to two orders of magnitude than previously detected. Obviously, this may affect soil remediation requirements; sites that once were “clean” may require some additional remediation.

You may want to consider how this could affect you and your company if you are involved in environmental site assessments, site closures, transactions, etc… It may also affect your strategy of when you may want to conduct your investigation and what it might mean if you are assessing property after July 1, 2011.

If you have any questions or require assistance with site investigation and/or remediation, please contact Clifford Lawton (clawton@dragun.com) or Christopher Paré (cpare@dragun.com) at 519.979.7300

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