Successful re-use requires that existing environmental
concerns are appropriately identified, cleaned up and managed and
that future uses protect the environment. Staged investigations
help focus the environmental studies towards the areas and locations
where clean-up is required; then technologies and techniques for
clean-up can be assessed. The final step is implementation of the
clean-up and re-use of infrastructure.
While the steps are sequential, there is no need to delay moving
forward in some areas of the property because other areas are delayed
due to environmental issues. This approach has been used on the
Coke Ovens/Tar Ponds project. For example, capping of the landfill
is nearly complete and the interceptor sewer is under construction
at the same time that technologies are still being evaluated for
the more complex environmental areas including the tar ponds.
In Nova Scotia, industrial sites are cleaned up following a process
which is pro-scribed by the Nova Scotia Department of Environment
and Labour (NSDEL). The NSDEL Guidelines for the Management of Contaminated
describes the process which results in a Certificate of Compliance
(CoC) for a property. A CoC is confirmation that environmental liabilities
have been addressed to the satisfaction of the regulator, and is
essential before most lending institutions and insurance companies
will back future re-use projects. A CoC is issued by an Environmental
Site Professional, and accepted by NSDEL.
The Guidelines are designed to address the issue of chemical contamination
in soil and groundwater. In order to issue a CoC, the Environmental
Site Professional must first be able to demonstrate that the contamination
source is controlled, and that no pure form of the contaminant exists
in the soil or groundwater. Secondly, it must be shown that trace
contaminant concentrations in the soil and groundwater on the property
do not exceed the applicable guideline values. Failing this, various
options are available for further assessment, remediation or management
of the contaminated area.
The phased approach typically begins with a Phase 1 ESA, which
consists of three main activities: interviews with knowledgeable
individuals, site reconnaissance, and a review of historical site
information. Based on this data, a determination is made regarding
the need to investigate particular environmental concerns. If further
assessment is not warranted, then the Environmental Site Profession
states this in writing, and the process ends. At SYSCO the Phase
1 study is complete.
If further assessment is warranted, a Phase 2 ESA is carried out.
A Phase 2 ESA is intended to further assess specific issues (such
as an underground storage tank) in order to determine if soil or
groundwater contamination is present. Following sample collection,
laboratory results are compared with the applicable guideline values.
If this comparison shows that contaminant levels are acceptable
(i.e., be-low guideline values), then the Environmental Site Professional
states this in writing, and the process ends. At SYSCO a number
of items are currently advancing to Phase 2, including, for example;
the high dump area and site sewers. A complete list is included
in the Phase 1 report.
In the event that contamination levels in excess of guideline values
are identified, several options are possible. The first is to remove
the contaminated materials to a treatment or disposal facility,
or provide for the treatment of the contamination in place. In Nova
Scotia, the former option is more frequently selected as the results
are assured, and the acquisition of a CoC expedited.
Site clean up can frequently be an expensive endeavor, and is often
unnecessary from an environmental and health & safety point
of view. Another commonly used option in Nova Scotia is Risk Assessment.
Briefly, Risk Assessment is a process by which an Environmental
Site Professional collects physical, chemical and meteorological
data for a property and uses those data to calculate “site-specific
guideline values”. The calculated values are intended to reflect
the actual risk that the contamination poses to a variety of potential
receptors, including people living near the site or fish swimming
in a stream across the road from the site.
As part of the Risk Assessment process, certain site management
activities may be implemented in order to separate potential receptors
from the contaminated area. This may include such activities as
“capping” the contaminated area to reduce the potential
for direct contact with contaminated soils, or the installation
of soil vapor extraction pipes to prevent vapors from entering a
It should be noted that depending on the complexity of the site,
further sampling and analyses might be required following the Phase
2 ESA in order to gauge the extent of a remediation process, or
alternatively, provide the required information to perform a Risk