Comments on ERO 019-0987 A.1…

Comments on ERO 019-0987
A.1. Requirement for properties in the Phase One Study Area to be serviced by a municipal drinking water system.
Recommend that this requirement be changed so that the QP has to demonstrate why it is not necessary to sample groundwater if there are potable water supply wells within the Phase One Study Area. That allows additional flexibility but still sets the bar high for QPs.

A.3. Requirement that the property is not an enhanced investigation property etc.
This requirement is problematic because there are several types of businesses that fall into the "enhanced investigation property" when they don't truly belong there. I worked on an RSC for a recently built commercial bakery that was deemed "industrial" and hence an enhanced investigation property because of its classification in the Ontario Building Code. It was basically like calling Tim Horton's shops an enhanced investigation property except this commercial bakery produced baked goods on a larger scale. This is a systemic problem in cross referencing the RSC regulation to the OBC. The best way to properly remedy this issue is to address the ways the OBC is improperly used to define an enhanced investigation property.

B.2.No APECs from off-site PCAs.
Rephrase so that there cannot be APECs from off-site PCAs that have not been fully assessed. The way it is currently written suggests that if there is an APEC from an off-site PCA on one part of the site that has been fully addressed and investigated, it is still not sufficient if there is an area of the site where there is an unrelated "no soil left" issue.

B.3. Confirmed that VOCs in soil, if present, meet applicable site condition standards.
Clarify that this pertains to situations where VOCs are contaminants of potential concern or contaminants of concern, and that VOCs don't need to be sampled if they are not COCs. I worked on a site where a homeowner had stored old car batteries in their backyard and there was a fire resulting in lead contamination in soil. Bedrock was very shallow. In this case, lead impacted soils were removed and the soil beneath (above bedrock) was present and sampled. However, if we had to excavate to bedrock and hadn't been able to collect confirmatory soil samples, it would not have made sense to test for VOCs in groundwater since the COC was lead.