Avoiding Unnecessary Site Assessment Delays

Are environmental consultants providing the necessary technical information for the Technical Standards and Safety Authority (TSSA) to evaluate a site investigation or remedial action report of a fuel storage site?  It appears not.  This can be troubling because when this technical information is missing, it could lead to unnecessary frustrations, specifically a site that is not closed.

The shortcomings of site assessments were pointed out in a 2013 TSSA newsletter, in which they outlined problems encountered when reviewing environmental reports.  According to the TSSA, consultants are not providing their rationale for determining the applicable site condition standards.

Background: In Ontario, if you store and/or handle gasoline, diesel, fuel oil, or other associated products at your facility, you must abide by TSSA guidance documents.

The TSSA Environmental Management Protocol (EMP) outlines the requirements for reporting, assessing, and managing a site following a petroleum leak, spill, or discovery.  The EMP adopted the Background Generic Site Condition Standards set by MOE O.Reg. 511/09 (amended O.Reg. 153/04).

O.Reg. 153/04 and the EMP contain a total of nine possible standard scenarios from which to select.  To select the appropriate standards for the subject property, the QP must obtain information regarding the subject property and surrounding properties (e.g. is potable groundwater used near the subject property, the type of land use, and soil texture to name a few).  Provided you have collected the necessary data, this is fairly easy to evaluate.

The TSSA requires QPs to include “justification” for the standards selected.  By providing this rationale, the TSSA can evaluate the work and ensure the consultant has completed an adequate assessment of site conditions or adequately remediated the site.

These are not new requirements, and your consultant should be evaluating these factors to determine the appropriate standards as a matter of course.  And by “stamping” the report, they are indicating that, to the best of their knowledge, the work was done in accordance with TSSA EMP.  But if they are not evaluating the standard scenarios and providing their justification for their choice, they are providing an incomplete report.

Certainly, conducting site assessment or remediation activity is something you want to get through as efficiently and as quickly as possible – with no surprises.  And to do so, your process must include providing the TSSA the necessary information so they can make a determination on the adequacy of the investigation or remediation.

If you have questions about site investigation or remediation, contact Christopher Paré (cpare@dragun.com) at 519-979-7300.

Thanks to Katherine Rey (krey@dragun.com) who authored this blog.

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