Features

The three Ps for specifying work at contaminated sites

April 7, 2023
Project team members communicating plans and parameters clearly prior to and throughout the duration of the project is critical.

Parameters

Parameters is the second “P” for specifying work at contaminated sites. Knowing the project’s regulatory parameters is essential to allow for the preparation of complete, concise, and co-ordinated bidding documents. If performing a project in jurisdictions where there are applicable local regulations, bylaws, guidelines or policies, the project must comply with these regulations and clearly convey their requirements in the bid documents. Sometimes the owner will be a large enough entity to warrant its own set of local regulations that will apply to their project only, for instance, mining reclamation projects involving the process of restoring land to its original condition (prior to beginning mining activities) typically consist of water treatment for settling ponds, backfilling open pits, removal of tailing piles, and so forth. These reclamation projects are often susceptible to the mining company’s policies and procedures, making it easy for the contractor to identify what can and cannot be performed at the site. Reclamation parameters may also be provided by a local work order—often referred to as an enforcement or consent order—which will outline the timelines a project must abide by, with penalties that can be incurred for failure to comply.

Many remediation projects require the importing clean soils for backfill, and the qualification of the source of the imported fill must also be specified. The specifier must specify imported fill material which is obtained from a provincially acceptable or Ministry of Natural Resources and Forestry (MNRF) licensed facility; or require submission of environmental reports to ensure the imported materials meet MECP soil, groundwater, and sediment standards in accordance with province-specific regulations such as O. Reg. 153/04, Record of Site Conditions, and/or O. Reg. 406/19, On-Site and Excess Soil Management and Ontario’s Rules for Soil Management and Excess Soil Quality Standards, 2020. Specification of specific regulatory compliance requirements in accordance with these regulations is critical for proper soil management such as source quality control (QC) and soil handling. The specifications must state the remedial design does not allow for “contaminated” soil to be introduced to a newly “clean” site in the project.

 APPENDIX A: Remediation-related plans
Examples of plans to be outlined in the contract documents provided to the contractor for submission prior to mobilization can include:
• Temporary traffic control plan to describe vehicle or pedestrian traffic, including temporary traffic signals, sequences of construction affecting the use of roadways, temporary access roads, road mats, provisions for decking over excavation, and phasing of operations to provide safe passages for pedestrians and vehicles if required. Further details can be found in the Ontario Traffic Manuals for Temporary Conditions.
•Development, implementation, and maintenance of the contractor’s site-specific health and safety plan (HASP) detailing the practices and protocols to be followed by the contractor during the remedial project implementation is standard practice. It is the legal obligation of the owner to disclose any hazardous substances the contractor may encounter when working on a project. Based on this information, the contractor develops HASP, and should provide the owner’s consultant an opportunity to review and ensure important considerations are made on behalf of the contractor, for the sake of the owner’s responsibilities—this may be a driving force in phasing project sequencing decisions. Some of the key items required in a properly prepared HASP are as follows:
◦Establishment of work areas/zones, depending on the work activity and the sequence in which it is performed, such as the following can be considered:

  •  Exclusion or “hot”* zone—Areas where hazardous or potentially hazardous contaminated soils, debris, and other materials are being, or may be contacted, disturbed, or handled; and areas where equipment or personnel travel are when working with contaminated materials. Exclusion zones are typically delineated with temporary fencing and warning signs to restrict access in efforts to reduce the spread of contamination.
  • Contaminant reduction/“warm”* zone—Occurs at the interface of the exclusion zone and support zone. It provides for the prevailing upwind transfer of construction materials from the clean (off-site) to site dedicated equipment, the decontamination of equipment and vehicles prior to entering the support zone from the exclusion zone, the decontamination of personnel and clothing prior to entering the support zone from the exclusion zone, and the physical segregation of the support and exclusion zones.
  • Support/“cold”* zone—A clearly delineated predominantly upwind area outside of the exclusion zone and contaminant reduction zone.
  • Personnel protective levels and equipment.
  • Personnel monitoring.
  • Environmental monitoring.
  • Reporting.

• Site layout drawing which show an overall plan featuring existing facilities, proposed construction facilities, and temporary controls to be provided by contractor, including existing property lines, structures, roads, utilities, and other existing site features or facilities, temporary access roads and utilities to be constructed, field offices and sheds, the means of ingress, egress, and temporary traffic control facilities, equipment and material staging areas, and soil stockpile areas.The following are examples of other plans for which minimum requirements are provided in the specifications for preparation and submission by the contractor prior to initiation of project activities.
• Soil erosion and sediment control plan to provide locations, design, and product names of features to reduce the risk of spreading contaminants to neighbouring sites, waterbodies, etc.
• Air quality control plan to describe procedures that will be implemented to control odours and air emissions where required and to identify equipment, materials, standard operating procedures, and contingency procedures for control of odours and air emissions to mitigate airborne contaminants that may be disturbed during remedial activities.
• Stormwater pollution prevention plan to describe existing and proposed site drainage and best management practices to be implemented to prevent contaminants from entering stormwater systems and the environment during construction.
• Temporary wastewater treatment plan to describe the installation, operation, and maintenance of a temporary on-site wastewater treatment facility needed for treatment of wastewater generated during remediation to avoid contaminated water from being directly discharged from
the site to adjacent water bodies.
• Excavation plan to describe the methods, procedures, sequencing, and scheduling of excavation and backfilling in excavations areas, including allocated time required by the consultant and/or owner for sampling and an analysis of completed excavations (to determine levels of contamination, effectiveness of treatments, etc.) that will be the most appropriate for the project.
• Material handling and on-site transportation plan to describe how contaminated and non-contaminated materials will be separately handled, staged, loaded, transported on-site, and how equipment will be decontaminated, including listing types and sizes of transport vehicles. The plan shall be designed so handling and transportation measures prevent the spread of contamination and ensure compliance with local restrictions. The plan shall be designed with traffic controls in compliance with applicable traffic regulations with respect to public roads, including flag persons and appropriate signage when vehicles are utilizing entrances to and from public roads.
• Stabilization/solidification plan requirements for a limited, focused bench scale study to determine the most effective reagent and approach to stabilizing soil and sediments where this remedial technology is being implemented. The study shall evaluate locally available reagents typically used to stabilize and solidify soils and sediments; and it shall also evaluate various techniques and approaches to stabilize the soils and sediments and their associated costs. Reagents typically used for stabilization and solidification are fly ash, cement, hydrated lime, lime kiln dust, and cement kiln dust (CKD).
• Transportation and off-site disposal plan to provide to relevant transporter and disposal facilities, including identification and regulatory classification and status, methods of transportation and disposal, contingency plans for spills during transportation, and schedules for transportation and disposal. Identification of facility specific requirements for waste characterization sampling and analyses to determine acceptance of the facility is also involved. The plan should also include local permits required when transporting hazardous materials on public roads. Work must comply with transportation requirements and must follow Transport Canada’s Transportation of Dangerous Goods Act, 1992 (TDGA), while waste management must comply with local provincial regulation such as R.R.O. 1990, Reg. 347, General–Waste Management.

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