ITT Canon Work Plan Identifying Gaps to Support Record of Site Condition

In 2008, XCG took over the remediation of a former manufacturing facility in Whitby, Ontario. As part of the remedial activities, reports detailing previous environmental investigations were reviewed. The reports reviewed included the findings of a Phase I Environmental Site Assessment (ESA), Phase II ESA, Soils Remedial Action Report, Remedial Investigation and Feasibility Study Report, Site Specific Risk Assessment (SSRA) and the Ontario Ministry of the Environment and Climate Change (MOECC) review comments, and the resubmission of the SSRA. The original and resubmission of the SSRA were completed based on the MOECC document “Guidance on Site Specific Risk Assessment for Use at Contaminated Sites in Ontario,” dated May 1996.


Previous investigations at the site indicated soil and groundwater impacts of volatile organic compounds. The original investigation and remedial activities completed at the site were conducted in accordance with the MOECC document “Guideline for Use at Contaminated Sites in Ontario,” dated Revised February 1997. Since 2008, XCG designed and completed a site characterization investigation to characterize the impacts at the site as described in Ontario Regulation (O Reg.) 153/04, the Record of Site Condition (RSC) Regulation, which came into force in 2004.


In December 2009, the Ontario MOECC filed extensive changes to its Brownfield’s regulations, including O. Reg. 153/04. The amendments, amongst others, include a complete rewrite of the requirements for Phase I and Phase II ESAs prepared for the purpose of submitting a RSC, and revisions (strengthening) of the soil, groundwater, and sediment standards used in the development of RSCs. The amendments to O. Reg. 153/04 were filed as new O. Reg. 511/09. Additional administrative updates were also filed in June 2010 as O. Reg. 245/10. It is noted that O. Reg.153/04 (as amended in 2009/2010) came into force on July 1, 2011.


Based on the issuance of the amendments to O. Reg. 153/04; XCG completed a data gap analysis of the investigations and remedial activities completed at the site to date. A work plan to address the gaps identified in the site characterization data has been prepared and is currently being implemented. The purpose of the work plan is to obtain all necessary site information to support the filing of a Risk Assessment in compliance with O. Reg. 153/04 (as amended in 2009/2010) and a subsequent RSC for the site.

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