Suncor Energy Inc. - Certificate of property use

One (1) electronic comment was received through the ERO with respect to ERO 019-2040 (ministry reference 7232-BPZQMQ) from a member of the public. A member of the public also contacted the Guelph District Office directly through email and telephone on several occasions regarding historical on and off-site contamination related to this site. These questions were answered directly by Ministry of the Environment, Conservation and Park’s (ministry) staff.

All questions and comments received regarding this proposal were considered by the director and the following additional general information has been provided:

The property located at 288 and 290 Woolwich Street, Guelph (the property) was a former automotive station and retail fuel outlet which was decommissioned in the early 1990’s and has remained vacant ever since.

The property is bounded by two residential properties to the west and municipal roadways to the north (London Road West), east (Woolwich Street) and south (Edwin Street).

The property is currently owned by Suncor Energy Inc. (Suncor) and ongoing environmental investigations have been completed since the early 1990’s with remedial excavations being undertaken in 2012 and 2013. 

Based upon the information provided, Suncor intends to file a Record of Site Condition in accordance with Ontario Regulation 153/04 (as amended) for the intended future residential use of the property. The Record of Site Condition process is a proponent driven process and is only applicable to the property for which the Record of Site Condition is filed. In order to obtain a Record of Site Condition for this property, Suncor has chosen to undertake a risk assessment to address any remaining contaminants of concern that have been identified.

Risk assessments are an option to property owners under Ontario Regulation 153/04 (as amended) and scientifically examines the potential risks posed to humans, plants, wildlife and the natural environment for the contaminants of concern for all identified pathways on the risk assessment property.

Through the risk assessment process, property specific standards are generated that are protective of human health and the environment for the intended future use of the property and must also demonstrate that the current site conditions do not pose unacceptable risks off-site. Within the risk assessment, the qualified person evaluates the potential risks to human health and the environment and identify any risk management measures that may be required to be implemented on the property in relation to it’s intended future use. These risk management measures are incorporated into a Certificate of Property Use which is only applicable to the former Suncor property and is binding on the current property owner along with any future property owner.

The specific questions within the electronic ERO submission were considered and are addressed as follows:

1. In posting this notice, it seems like the Guelph Office (GO) has concluded that the data provided by Suncor is satisfactory, including that it demonstrates no offsite contamination. However, the GO has not been provided with any data from the adjacent properties - so I ask, how can this conclusion be made?

The risk assessment for this property was received by the ministry and reviewed by several different technical groups, all who provide their own property specific risk-based comments, perspectives and recommendations as may be required. As part of the review process for the risk assessment, the local district office engineer reviewed the information provided within the risk assessment along with all available historical information on file with the ministry. This information was used to evaluate the property itself and any potential off-property issues that may exist before and after redevelopment.

After reviewing the initial risk assessment, the local district office specifically requested that Suncor’s consultant complete an evaluation of the potential risk to the residential properties that abut the western property boundary. As a result of this additional evaluation, taking into consideration the historical information on file, no adverse effects are anticipated off-site. Despite this, a confirmatory groundwater monitoring program, that includes a contingency plan and the installation of an additional well along the western property boundary, was incorporated into the proposed Certificate of Property Use along the western property boundary. The results of the groundwater monitoring program will be reviewed by the ministry on an annual basis to determine if any additional action in the area is warranted.

As noted above, the conclusions of the risk assessment and requirements of the ministry’s Certificate of Property Use only apply to the former Suncor property.

2. Can I plant vegetables? Would you? Can i eat from the mulberry tree near the property line? Would you?

With respect to the ingestion of garden produce/fruit on the former Suncor property, this was evaluated in the risk assessment and it was concluded that no risks to human health were anticipated through the ingestion of home-grown garden produce/fruit. That being said, the consultant opted to include a risk management measure in the Risk Management Plan to prohibit vegetables/fruit from being planted on that property in the future as an additional control measure. This is a typical risk management measure that is included by consultants in many brownfields being redeveloped into residential properties.

As noted above, the conclusions of the risk assessment and requirements of the ministry’s Certificate of Property Use only apply to the former Suncor property.

3. Should I go into my basement when the CPU conditions will stipulate that the next build on that site would not be allowed to have below grade dwelling? Can my children?

The risk assessment evaluated the potential for vapour intrusion into a typical residential building, that includes a typical residential basement on the former Suncor property. The conclusion was that no unacceptable risks were identified. As a result, no risk management measures are required for typical residential buildings with basements.

Risk management measures for vapour intrusion were included in the proposed Certificate of Property Use for potential future residential buildings that may be constructed with more than one sub-grade level (i.e. multiple levels of underground parking or multiple sub-grade levels) on the former Suncor Property.

As requested by the local district office, Suncor’s consultant completed an evaluation of the potential risk to the residential properties that abut the western property boundary. As a result of this additional evaluation along with the information the ministry has reviewed to date, no adverse effects are anticipated off-site. Despite this a confirmatory groundwater monitoring program, that includes a contingency plan, was incorporated into the proposed Certificate of Property Use along the western property boundary. The results of the groundwater monitoring program will be reviewed by the ministry on an annual basis to determine if any additional action in the area is warranted and is to be implemented upon the issuance of the Certificate of Property Use.

As noted above, the conclusions of the risk assessment and requirements of the ministry’s Certificate of Property Use only apply to the former Suncor property.

After considering all of the above, no changes were made to the proposed Certificate of Property Use by the Director prior to it being finalized.