In the period between 2010 and 2018, XCG was retained by Steelcraft Inc. to conduct site investigation activities with the ultimate goal of obtaining a Record of Site Condition (RSC) for the Clemmer Containment Division property located at 446 Albert Street in Waterloo, Ontario (subject site). The work was to facilitate the potential sale and future redevelopment of the subject site for mixed commercial/residential purposes and therefore triggers the requirement for a RSC. The project began with the review of soil and groundwater sampling reports prepared by others over the previous several years. Following review of previous reports, additional soil and groundwater quality investigations were conducted at the subject site, which indicated the presence of PHCs and chlorinated VOCs (CVOCs) in both soil and groundwater. Groundwater remedial activities were conducted to reduce the concentrations of CVOCs in the groundwater. Following receipt of favourable results from the remedial activities, a Phase One Environmental Site Assessment (ESA), and additional Phase Two ESA investigations were completed to satisfy the requirements of Ontario Regulation (O. Reg.) 153/04. The Phase One ESA included a summary of the previous investigations and an overall determination of potential contaminating activities within the study area and related on-site areas of potential Environmental Concern (APECs). Data from the historic reports was reviewed in detail and validated as appropriate as it relates to the requirements of O. Reg. 153/04.

Based on the information and data generated during the Phase One and Phase Two ESAs, XCG undertook the work on a Risk Assessment (RA). The RA was originally submitted to the Ministry of the Environment (MOE, or the Ministry) for review in June 2015. Throughout the RA review period, XCG maintained an open dialogue with the Ministry to ensure that the Phase Two CSM satisfied the requirements of O. Reg. 153/04 and the expectations of the Ministry Brownfield Filing and Review Group. Ministry comments received on the RA were addressed and a second submission of the RA was made in November 2015. The Ministry requested additional clarification on a few items related to the RA and ultimately, the RA was accepted by the Ministry in December 2016.

XCG developed a Risk Management Plan (RMP) that requires capping of areas of the site that do not have sufficient clean soil cover and installation of a vapour barrier with passive venting for any future commercial/residential building(s) to be constructed on-site. A Certificate of Property Use (CPU), specifying these Risk Management Measures (RMMs) and others, was prepared by the Ministry District Office. In addition, some minor remedial soil excavation activities were conducted on the subject site to remove volatile organic compounds (VOC) concentrations that were above the RA-developed property specific standards. Following the completion of these remedial activities, the RSC was filed by XCG and acknowledged by the Ministry in April 2018.

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