ENVIRONMENTAL MANAGEMENT PROTOCOL FOR OPERATING FUEL HANDLING FACILITIES IN ONTARIO

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1 ENVIRONMENTAL MANAGEMENT PROTOCOL FOR OPERATING FUEL HANDLING FACILITIES IN ONTARIO October 2001 Fuels Safety Division Technical Standards & Safety Authority

2 CONTENTS 1.0 Purpose Background Operational Fuel Handling Facilities Spills Leaks Discovery of a Petroleum Product that has Escaped to the Environment or Inside a Building Environmental Conditions within the Property Boundary Environmental Conditions at the Property Boundary Environmental Conditions Beyond the Property Boundary Site Restoration at Operational Fuel Handling Facilities Contaminant Management Plan Permanent Closure of Fuel Handling Facilities Reporting Requirements..12 APPENDIX Appendix A: Site Assessment and Environmental Restoration Process - i -

3 1.0 Purpose The purpose of is to provide direction for the reporting, assessment and management of petroleum products that have escaped to the environment or inside a building. This document addresses petroleum products used as either motive or appliance fuel such as gasoline, diesel and fuel oil at operational fuel handling facilities such as gasoline service stations, bulk plants, marinas and private fuel outlets. replaces the Ministry of Consumer and Commercial Relation's (MCCR) Gasoline Handling Standard 13 (GH13) dated August The information is consistent with that provided in the February 1997 version of the Ministry of Environment s (MOE) "Guideline for Use at Contaminated Sites in Ontario". This document applies only to obligations pursuant to the Technical Standards and Safety Act (TSS Act) and associated Regulations (O. Reg. 217/01 and O. Reg. 213/01) and Codes (Liquid Fuel Handling Code and Fuel Oil Code). Staff of the Technical Standards and Safety Authority (TSSA) and MOE work cooperatively to minimize the duplication of effort in responding to environmental matters at fuel handling facilities. When the remediation or management of a petroleum product release occurs at an operating fuel handling facility, the regulatory lead falls under the Fuels Safety Division (FSD), TSSA. The direction within will assist a proponent (the owner of the fuel handling equipment or the real property on which the fuel handling equipment is installed or the licencee of the facility) in determining whether the site is in compliance with the environmental requirements of the Liquid Fuel Handling Code (LFHC) or the Fuel Oil Code (FOC), under the TSS Act. This document does not apply to refineries and petrochemical plants where petroleum is being used as a feedstock. Such facilities are not regulated by the TSS Act. The TSSA has been designated as the sole authority for the purpose of administering the LFHC and FOC. Further information may be obtained by contacting FSD s Environmental Coordinator at (416) Background Environmental matters at operating facilities are regulated by the TSS Act. They may also be regulated by other provincial legislation such as the Environmental Protection Act (EPA) and the Ontario Water Resources Act (OWRA). Parties involved in the ownership and operation of fuel handling facilities must be aware of the regulatory requirements of applicable Acts. In the event of a spill, leak or the discovery of a petroleum product that has escaped to the environment or inside a building (further referred to as an escape of product ), the LFHC and the FOC obliges the proponent to take immediate corrective action including, but not necessarily limited to, reporting and recovering escaped product. The LFHC and the FOC also empowers FSD to require the provision of an environmental assessment report and if necessary, the remediation or management of the environmental impact caused by the escape of a petroleum product(s). The reporting procedure for an escape of product requires the proponent to contact Spills Action Centre (SAC), MOE. Where an escape of product occurrence has been reported to SAC, FSD will be informed. An FSD Inspector may conduct an on-site visit to supplement the investigation. An order to bring about compliance may be issued. Where an environmental impact caused by the Technical Standards & Safety Authority 1

4 escape of product poses the likelihood to cause an off-site adverse effect or an adverse effect to any drinking water supply, the regulatory lead over environmental remediation will be transferred to MOE even though the facility remains operational. Providing the facility remains under the jurisdiction of FSD, the process within will be applied. Upon permanent closure of a fuel handling facility, refer to the direction provided in sections and 7.3 and of the LFHC and section 16.3 of the FOC. MOE is the regulatory lead for all environmental matters at the permanent closure of a fuel handling facility. A fuel handling facility is considered operational provided that the fuel handling equipment remains installed on the property even if such equipment is not currently in use. In such a case, the facility is regulated by TSSA. The removal of all fuel handling equipment from a property constitutes a permanent closure and, as such, the property is regulated by MOE. Reporting to the Director of FSD is accomplished by contacting the MOE s Spills Action Centre (SAC) at Operational Fuel Handling Facilities Where product has escaped at an operational facility, certain reporting, investigative and corrective action is necessary. Appendix A of this guideline provides an outline of an acceptable process for conducting a site investigation study. If environmental conditions at a facility exceed those discussed below, corrective action acceptable to the Director must be initiated. The following explains the obligation and methodology to report, assess and manage or cleanup an escape of product: 3.1 Spills Any spill of a petroleum product in excess of: 100 litres at sites restricted from public access (ie. bulk facility) 25 litres at sites with public access (ie. retail service station) must be immediately reported to the Director, FSD, in accordance with the provisions of the LFHC and the FOC (similar to the requirements of MOE s O. Reg. 675/98, EPA). Spills of lesser quantities need not be reported to FSD unless the spill would: create a hazard to public health or safety, contaminate any fresh water source or waterway, interfere with the rights of any person, or allow entry of product into a sewer system or underground stream or drainage system. The implementation of appropriate investigative and mitigative actions as per the LFHC or the FOC, as applicable, and is required to ensure environmental impact is properly evaluated and, if necessary, mitigated. Technical Standards & Safety Authority 2

5 3.2 Leaks All confirmed leaks, regardless of quantity released, must be immediately reported to the Director, FSD. Where applicable, the implementation of mitigative actions as per the LFHC or the FOC, as applicable, and is also required. 3.3 Discovery of a Petroleum Product that has escaped to the Environment or Inside a Building The discovery of a petroleum product that has escaped to the environment or inside a building must be addressed pursuant to the following protocols. Three scenarios are described below which consider environmental conditions on-site, at the property boundary and off-site: Environmental Conditions within the Property Boundaries Separate Phase Product Discovered in a Monitoring Well or Excavation: Where separate phase product is detected within an on-site monitoring well or excavation, the initial discovery must be reported to the Director, FSD. A full delineation of the extent of separate phase product and related dissolved and residual contamination must then be completed. All practical efforts to recover the product must be employed. Findings of the delineation must be reported to the Director, FSD. Discovery of Petroleum Product Derived Vapour in an Enclosed Space, Excavation or Monitoring Well: Where petroleum product derived vapour is discovered in an on-site enclosed space, excavation or monitoring well, an investigation of the cause of the vapours is necessary. This investigation may indicate a leak or spill. If the findings of the investigation reveal the potential for a fire or explosion hazard, the Director, FSD must be notified immediately. The potential for any explosion or fire hazards must be eliminated. If the findings confirm a spill, leak or escape of product by any other means, the occurrence must be reported to the Director if environmental conditions contravene those presented in Table 1. Discovery of Soil/Groundwater Impact Related to a Petroleum Product: Where on-site soil/groundwater quality has been altered due to impact from a petroleum product, yet the soil/groundwater quality meets permissible conditions for an operational facility (Tables C or D remediation criteria, as applicable), no reporting or mitigative actions are required providing: confirmation of Table A or B remediation criteria, as applicable, are met at the property boundary, and no immediate corrective action is required as per section 4.0 of this document. the property is not classified as potentially sensitive as defined within the MOE's "Guideline for Use at Contaminated Sites in Ontario". Technical Standards & Safety Authority 3

6 Where the above conditions are not met, the occurrence must be reported to the Director. A delineation of the full extent of the exceedance is necessary. Options available to mitigate such an occurrence include: restore the on-site environment to within Table C or D remediation criteria, as applicable; restore the property boundary environment to Table A or B remediation criteria, as applicable; or implement a Contamination Management Plan (CMP), as per section 4.1. An alternative measure, acceptable to the Director, to address situations where permissible conditions within the facility limits are exceeded is the submission of a Site Specific Risk Assessment (SSRA) to MOE, as per MOE s most recent version of the Guideline for Use at Contaminated Sites in Ontario. In order for the Director to accept the SSRA option, the SSRA must be reviewed and accepted by MOE. A copy of MOE s acceptance must be provided to FSD. In the case of a potentially sensitive site, a proponent must either submit an SSRA to MOE for their review and acceptance or restore the environment to background conditions pursuant to Table F within "MOE's Guideline for Use at Contaminated Sites in Ontario" Environmental Conditions at the Property Boundary Where soil/groundwater quality at the property boundary of the facility meets Table A or B remediation criteria, as applicable, no reporting or mitigative actions are required providing on-site conditions are acceptable (no exceedence of Table C or D, as applicable and no immediate corrective action required). Where soil/groundwater quality at the property boundary of the facility exceeds Table A or B remediation criteria, as applicable, report the findings to the Director. A delineation of the full extent of the exceedance is necessary. Off-site migration of petroleum product derived impacts above applicable full depth remediation criteria must be mitigated through restorative action or the implementation of a CMP. Written acknowledgement from the affected property owner(s) or their respective agent is necessary for FSD s approval to implement a CMP. Failure to address the environmental management of an off-site impact will result in the transfer of jurisdiction to MOE Environmental Conditions Beyond the Property Boundary Where soil/groundwater quality beyond the property boundary of the facility meets Table A or B remediation criteria, as applicable, no reporting or mitigative actions are required providing on-site and property boundary conditions are acceptable. Where soil/groundwater quality beyond the property boundary of the facility exceeds Table A or B remediation criteria, as applicable, and where it is reasonable to conclude that the exceedance has been caused by the migration of petroleum related contaminants from the facility, report the findings to the Director. A delineation of the full extent of the exceedance is necessary. Where off-site migration of petroleum product derived impacts above applicable full depth remediation criteria has occurred, a full depth remediation of the affected soil/groundwater to Table A or B criteria, as applicable, on the impacted property(s) and at the property boundary of the fuel Technical Standards & Safety Authority 4

7 handling facility may be required. The implementation of a CMP may be acceptable in such a case where the owner(s) of the impacted off-site property(s) has been apprised of the situation and has provided written concurrence to the use of a CMP and where FSD has accepted the use of the CMP. The CMP must ensure that further accumulation or migration of petroleum related contamination does not occur and that site conditions remain safe for continued operation (see section 4.1 for details on the CMP). Table 1 summarizes the reporting investigative obligations of a proponent where there has been the escape of product at a facility. Table 1 SUMMARY OF REPORTING AND INVESTIGATIVE OBLIGATIONS Within the Property Spill: Situation Reporting Obligations Investigative Obligations Report to FSD as per the Liquid Fuels Handling Code one of the following conditions exist: >100 litres at facilities restricted from public access (bulk plant); >25 litres at facilities with public access (retail operation); or where reporting exemptions as approved by the Director have been contravened. Recover escaped product. Determine extent of contamination as necessary. Leak: Discovery of liquid product in a monitoring well: Petroleum vapours in an enclosed space, excavation or monitoring well: Discovery of petroleum related soil or groundwater contamination: (cont. below) Report all confirmed leaks to FSD. Report all such occurrences to FSD. Report if source is confirmed to be from a leak, spill (as per spill section above) or if it is determined that related contamination is above reportable levels. Investigate all suspected leaks. Recover escaped product from confirmed leaks. Determine extent of contamination as necessary. Recover product and determine extent of product and related contamination. Determine source and extent of vapours. Technical Standards & Safety Authority 5

8 Situation Reporting Obligations Investigative Obligations Conditions meet Table B/D No reporting required provided (nonpotable) that environmental conditions at the property boundary meet Table B. Conditions exceed Table D (nonpotable) Conditions exceed Table A/C (potable) At the Property Boundary: Conditions meet Table A/B, as applicable: Conditions exceed Table A/B, as applicable: Off Property: Conditions meet Table A/B, as applicable: Conditions exceed Tables A/B, as applicable: Report to FSD. Determine the extent of contamination and either restore to applicable levels or implement a CMP. Report to FSD. Determine the extent of contamination and either restore to applicable levels or implement a CMP. Report to FSD only if environmental conditions on property exceed Table C or D, as applicable. Report to FSD. Determine the extent of contamination and either restore to applicable levels or implement a CMP. No Reporting. Report to FSD. Determine the extent of contamination. If restricted to non-sensitive, municipally owned receptors, communicate with affected owners and restore to applicable levels or implement a CMP. If contamination has migrated to any other property, contact MOE. 4.0 Site Restoration at Operational Fuel Handling Facilities The intent of site remediation at an operational facility is to return petroleum-impacted soils and groundwater to conditions such that there will be no likelihood of the following: off-site migration of petroleum related contaminant(s); or unacceptable safety conditions for continued operation. A proponent driven or voluntary remediation may be conducted at any time at a facility. An environmental remediation will be required by FSD if immediate corrective action is deemed necessary based on the site conditions. Technical Standards & Safety Authority 6

9 FSD encourages communication with our Environmental Office to discuss proposed remediation programs to facilitate compliance with legislated requirements. It is the responsibility of the proponent and their consultant to ensure the applicability and effectiveness of the selected program. FSD recommends the use of personnel experienced in completing environmental assessment and remediation programs when addressing environmental matters. FSD reserves final approval of the remediation program. Immediate corrective action is necessary to eliminate: the presence of all liquid phase-separated product evident on the surface or in the subsurface and/or migrating off-site; any potential explosion hazards caused by petroleum vapour accumulation in enclosed spaces; or the potential for off-site migration of a petroleum product and related contaminants. As per the LFHC or the FOC, where required by the Director, the proponent shall submit an environmental assessment report acceptable to the Director documenting the full extent and severity of a petroleum product release and that the resulting impact does not require immediate or additional remediation. Numerous technologies are available to utilize throughout a site remediation project. The use of certain technologies may require approval from other regulatory agencies. FSD encourages the use of innovative solutions providing all applicable approvals and certificates have been obtained. The remediation criteria for soil and groundwater, as presented in the following Tables A-D, are those contained within MOE s Guideline for Use at Contaminated Sites in Ontario. The selection of applicable criteria for a specific site is based on whether the local groundwater is designated as being potable or nonpotable, local land use concerns, soil texture types, depth of overburden, soil ph and whether a full depth or stratified remediation will be completed. The same qualifications for usage of these remediation criteria as discussed within MOE's guideline apply. Site remediation to nonpotable criteria may be considered only when: the area is already serviced by a communal or municipal drinking water supply which does not rely on local groundwater, the present or future surface water or groundwater sources of drinking water will not be adversely affected, including water for agricultural and aquicultural uses, and the proponent has notified the municipality of the proposal to use criteria which would restore groundwater to nonpotable levels. The first condition to use the nonpotable criteria (Table B for full depth remediation or Table B/D for stratified remediation) refers to whether the drinking water supply to the site and the surrounding area is obtained from groundwater and not whether the groundwater directly underlying the subject site is currently used as a drinking water source. The nonpotable criteria may also be applied at such Technical Standards & Safety Authority 7

10 a site through the development of a SSRA as outlined in the February 1997 version of MOE s Guideline for Use at Contaminated Sites in Ontario. Where the SSRA option is selected, the proponent must provide FSD with a copy of an acceptance from MOE to show the SSRA process has been completed in accordance with the guideline. The following Tables A-D present selected provincial remediation criteria for petroleum fuel related contaminants in both potable and nonpotable environments. Tables A-D presented within this guideline do not represent the minimum standard for contaminant testing or a complete list of the contaminants that may be of interest at a given site. Please refer to MOE s Guideline for Use at Contaminated Sites in Ontario for a complete list of contaminant remediation criteria. TABLE A and C: SURFACE AND SUBSURFACE REMEDIATION CRITERIA FOR A POTABLE GROUNDWATER ENVIRONMENT* SOIL REMEDIATION CRITERIA (ug/g) CHEMICAL COMPOUND AGRICULTURAL LAND USE RESIDENTIAL / PARKLAND LAND USE INDUSTRIAL/ COMMERCIAL LAND USE POTABLE GROUNDWATER (ug/l) BENZENE ETHYLBENZENE PETROLEUM HYDROCARBONS (GAS/DIESEL) PETROLEUM HYDROCARBONS (HEAVY OILS) TOLUENE XYLENES LEAD** METHYL TERT BUTYL ETHER * Surface is considered grade to a depth of 1.5 metres not including the thickness of any non-soil surface treatments such as asphalt, concrete, aggregate, etc. * If, based on the results of a site characterization, the property is considered a potentially sensitive site as discussed in Section 6.1 of MOE s Guideline for Use at Contaminated Sites in Ontario, a revised set of site-specific remediation criteria must be developed via a limited SSRA which must be peer reviewed and submitted to MOE for review and approval. A remediation to background levels may also be acceptable. ** For lead, subsurface levels of 1000 ug/g and N/V have been assigned for a residential/parkland land use and for an industrial/commercial land use respectively. The lead criteria may only be applied where surface soil ph is and where subsurface soil ph is Technical Standards & Safety Authority 8

11 TABLE B: SURFACE REMEDIATION CRITERIA FOR A NONPOTABLE GROUNDWATER ENVIRONMENT* SOIL REMEDIATION CRITERIA (ug/g) CHEMICAL COMPOUND RESIDENTIAL/ PARKLAND LAND USE INDUSTRIAL/ COMMERCIAL LAND USE NONPOTABLE GROUNDWATER (ug/l) BENZENE (25) 5.3 (25) 5.3 (12000) 1900 ETHYLBENZENE (500) 290 (1000) 290 (50000) PETROLEUM HYDROCARBONS (GAS/DIESEL) PETROLEUM HYDROCARBONS (HEAVY OILS) 1000 (2000) 1000 N/V N/V TOLUENE (150) 34 (150) 34 (37000) 5900 XYLENES (210) 34 (210) 34 (35000) 5600 LEAD** METHYL TERT BUTYL ETHER 100 (410) ( ) Criterion value in brackets applies to medium and fine textured soils. N/V No value presently assigned, however such parameter must be considered * Surface is considered grade to a depth of 1.5 metres not including the thickness of any non-soil surface treatments such as asphalt, concrete, aggregate, etc. * If, based on the results of a site characterization the property is considered a potentially sensitive site as discussed in Section 6.1 of MOE s Guideline for Use at Contaminated Sites in Ontario, a revised set of sitespecific remediation criteria must be developed by completing a ecological risk assessment. A remediation to background levels may also be acceptable. ** The lead criteria may only be applied where surface soil ph is and where subsurface soil ph is Technical Standards & Safety Authority 9

12 TABLE D: SUBSURFACE REMEDIATION CRITERIA FOR A NONPOTABLE GROUNDWATER ENVIRONMENT* SOIL REMEDIATION CRITERIA (ug/g) CHEMICAL COMPOUND RESIDENTIAL/ PARKLAND LAND USE INDUSTRIAL/ COMMERCIAL LAND USE NONPOTABLE GROUNDWATER (ug/l) BENZENE 63 (230) 89 (12000) 1900 ETHYLBENZENE (50000) PETROLEUM HYDROCARBONS (GAS/DIESEL) PETROLEUM HYDROCARBONS (HEAVY OILS) 5000 (10000) 5000 N/V 5000 (10000) 5000 N/V TOLUENE (1000) 510 (2500) 510 (37000) 5900 XYLENES (1000) 460 (2500) 460 (35000) 5600 LEAD** 1000 N/V 32 METHYL TERT BUTYL ETHER ( ) Criterion value in brackets applies to medium and fine textured soils. N/V No value presently assigned, however such parameter must be considered * If, based on the results of a site characterization the property is considered a potentially sensitive site as discussed in Section 6.1 of MOE s Guideline for Use at Contaminated Sites in Ontario, a revised set of site-specific remediation criteria must be developed by completing a ecological risk assessment. A remediation to background levels may also be acceptable. ** The lead criteria may only be applied where surface soil ph is and where subsurface soil ph is Contaminant Management Plan While a facility remains operational, it is permissible to leave petroleum related contaminant(s) onsite that exceed permissible cleanup criteria (Tables C or D, as applicable) providing it is demonstrated that the level of contaminant(s) at the property boundary meets applicable full depth cleanup criteria (Table A or B, as applicable) and that environmental conditions on-site do not require immediate corrective action (see section 4.0). In such a case, the proponent may elect to defer remediation until the permanent closure of the fuel handling facility occurs. An option offered by FSD to accommodate this scenario is the Contaminant Management Plan (CMP). The intent of a CMP is to provide a formal mechanism for on-going monitoring of the petroleum related contaminant(s) over time rather than requiring the proponent to complete an environmental remediation. Technical Standards & Safety Authority 10

13 If the CMP option is selected, the plan should be developed by personnel experienced in completing environmental assessment and remediation projects. The proponent must submit the proposed CMP in the form of a signed, technical report which concludes that no immediate corrective action is required. The report must be submitted to FSD within 30 days of the discovery of the escape of product (unless otherwise directed). The proponent may implement a CMP at their discretion however, FSD will review all submitted CMP s and will provide a written response indicating whether or not the proposal is considered acceptable. FSD may require revision to the CMP. As a minimum, a CMP should include the following: Confirmations of: the extent and severity of the petroleum related contaminant(s) that the contaminants do not pose a threat to on-site or off-site receptors, including drinking water supplies; and that the concentration of the petroleum related contaminant(s) should not increase or migrate significantly over time. a proposed contaminant monitoring schedule for the documentation of environmental conditions over time while the petroleum related contaminant(s) of concern remains and for providing status reports to FSD; a written acknowledgement of the proposal to implement the CMP by all affected off-site property owner(s); and a written commitment to provide immediate reporting to FSD should conditions at the site degrade to where immediate corrective action is required and to notify FSD in writing as to when the monitoring program is to be revised or is no longer necessary. The management of off-site petroleum related contaminant(s) may only be considered when it has been determined that immediate corrective action is not necessary and when consent to the use of the CMP has been received in writing from impacted property owner(s). Please note: Should environmental conditions at a site under a CMP degrade such that immediate corrective actions become necessary FSD may rescind the approval for the CMP and may require immediate implementation of a contingency plan. In addition, should the facility be permanently closed, the jurisdiction over environmental matters reverts to MOE. 5.0 Permanent Closure of Fuel Handling Facilities Where a fuel handling facility is to be permanently closed (ie. all fuel handling equipment will be permanently removed and the facility will no longer handle fuel), the LFHC obliges the following: removal of all fuel handling equipment; notification to the FSD, MOE and local municipality in writing within 90 days after the removal of the fuel handling equipment; Technical Standards & Safety Authority 11

14 completion of an investigation which identifies the full extent and severity of all surface and subsurface contaminant(s) related to the fuels handling operations within and where necessary and practical, beyond the property; and, forthwith notify MOE if environmental conditions contravene applicable sections of the EPA or OWRA. Where a fuel oil handling facility is permanently removing the aboveground or underground storage tank systems, the FOC obliges the following: completion of an investigation which identifies the full extent and severity of all surface and subsurface contaminant(s) related to the fuels handling operations within and where necessary and practical, beyond the property; and, forthwith notify the TSSA of the removal of the tank(s) removal. FSD recommends that the proponent refer to the process outlined in the most recent version of MOE s Guideline for Use at Contaminated Sites in Ontario during permanent closure. Any questions related to environmental remediation obligations at the permanent closure of a fuel handling facility should be directed to the local District Office, MOE. 6.0 Reporting Requirements All information collected should be kept in a clear, organized technical report format and made available to FSD as requested. Submissions must be signed and include sufficient information to adequately evaluate the location, nature, extent and severity of the petroleum related contaminant(s), and the remediation efforts proposed or used to rectify the problem Technical Standards & Safety Authority 12

15 Appendix A Site Assessment and Environmental Restoration Process Where a spill or leak of a petroleum product is suspected or known to have occurred or where a petroleum product has escaped to the environment or inside a building where the cause of the escape is unknown, the proponent may be obliged, under the LFHC and FOC, to fulfil certain reporting, assessment and remediation actions (see section 3.0 of this document). Measures to address such occurrences, that are acceptable to the Director, include remediation of the petroleum related contaminant(s) to applicable criteria (see section 3.1 of this document), the submission of a SSRA to MOE or the development and implementation of a CMP. These options were discussed in detail in sections 3.0 and 3.2 of this document, respectively. In order to make an informed decision regarding available options, an assessment of the full extent and severity of the petroleum related contaminant(s) must be completed (both on- and, if required and where practical, offsite). An assessment of whether an adverse effect has or is likely to occur and if off-site migration of contaminant(s) of concern has or is likely to occur must be made. An environmental assessment is typically completed by personnel experienced in environmental assessment and remediation projects by using a program of strategically placed test pits and/or boreholes along with the installation of groundwater and/or vapour monitoring wells on-site and, if necessary and where practical, offsite. Results of a sampling and analysis program will assist in determining the extent and severity of the petroleum related contaminant(s). Impacts to soil and, if encountered, groundwater must be assessed in determining the severity of the environmental impact (it is necessary to assess groundwater quality if petroleum related contaminant levels within the soils are such that it is likely that groundwater has been impacted). The following is a list of the information which may be required by FSD in order to assess the appropriateness of site remediation efforts or whether the site is candidate for a CMP or other measure acceptable to the Director: a historic review of the type of equipment and type of petroleum fuels handled on-site; a general site location plan (ideally scaled at about 1:10000 showing a minimum one kilometre radius around the subject site) and a detailed site plan illustrating the location of buildings, service conduits (both on-site and adjacent to the site), underground/ aboveground storage tanks, pumps and lines, etc. a cursory assessment of adjacent sites, including an assessment of the likelihood of adverse effect at those sites. (ie. proximity of sensitive land uses and subsurface structures, surface water courses, etc.); an assessment of the full extent and severity (both on- and, if necessary and where practical, offsite) of all phases of petroleum related contaminant(s) (ie. separate phase product, soluble phase in groundwater, vapours, etc.). This should include a detailed, scaled site plan illustrating the location and extent of such contaminant(s); Technical Standards & Safety Authority

16 an assessment of the local use of groundwater, this should include a discussion of the susceptibility of on- and off-site water wells to petroleum related contaminant(s); and where necessary and to the extent possible, a detailed assessment of the physical hydrogeology of the site (ie. depth to and flow direction of groundwater, permeability of site soils, etc.). The methodology to be used for the site investigation should be developed by the proponent and their selected consultant. Please note that composite soil samples are not permitted for any volatile samples including BTEX and TPH (gas/diesel). Reference documents such as the most recent versions of MOE s Guidance on Sampling and Analytical Methods for Use at Contaminated Sites in Ontario., and Guidance on Site Specific Risk Assessment for Use at Contaminated Sites in Ontario., are available and are to be used to determine sampling methodology, sampling frequency, verification sampling and quality control/quality assurance program, etc. Site Remediation Should a proponent be required or elect to restore a petroleum impacted property then upon completion of the remediation program a verification sampling program is required to ensure that the restorative program has been completed adequately. Please refer to MOE s guidance documents as above for detailed information. For quick reference with regard to excavation as a restorative process, the following table is provided. The number of samples to be submitted for analytical testing is determined based on the size of the excavation in accordance with the following table: 1, 2, 4 Minimum Verification Sampling Requirements for Excavation of Underground Storage Tanks For Gasoline or Diesel Fuels Floor Area (m 2 ) Floor Samples Side Wall Samples 3 < Not to be used to determine the number of assessment samples 2 Not intended for excavations deeper than 4 metres or with floor areas greater than 1000 m 2 3 Side wall samples should not be all taken from the same wall 4 Samples for analysis should be selected based on TOV screening as outlined in Guidance on Sampling and Analytical Methods for Use at Contaminated Sites in Ontario., MOE, June 1996 and must represent worst-case. A specific soil sampling location is chosen based on the field VOC measurement determined in Step 1. The samples for analytical testing must be taken from the grid units with the highest VOC readings. The samples must not all be taken from the same side wall. Technical Standards & Safety Authority

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