In 2015/2016, the Contaminated Sites Program of the Department of National Defence (DND) established a vision for the management of its portfolio. That vision has guided the development of strategies, tools and action plans which are helping to maximize their FCSAP spending, reduce the size of DND’s portfolio, focus energy on high priority sites, and reduce the level of unknown liability.

Program management of contaminated sites is more than just the financial management of a group of contaminated sites projects. It also requires regular comparison of the program to the goals of the organization as well as those of other stakeholders. Good program management provides the best support to contaminated site project managers to ensure that resources are being allocated effectively.

DND’s experience has revealed many lessons and indicated some new approaches for program management of federal contaminated sites. These lessons learned and new approaches have allowed DND to increase its rate of closure of contaminated sites and to target resources where they are best used to reduce liability and risks to human health and the environment.

The keys to the success of DND’s program management can be divided into the following categories.
• Inventory management;
• Funding (tools and processes);
• Regular reporting to constantly measure our progress; and,
• Setting priorities for action.

These elements have allowed DND to improve the performance of its contaminated sites program year over year, reducing the contaminated sites under management consistently.

At the end of fiscal year-end 2014/15, the Department of National Defence (DND) Contaminated Sites Program developed a Contaminated Sites Management Plan (CSMP) that listed over 1,200 active sites. This inventory was divided into approximately thirds: low priority sites (National Classification System for Contaminated Sites (NCSCS) Class N and 3); suspected sites (no classification or NCSCS Class “I”); and, higher priority sites (NCSCS Class 1 and 2).

Further analysis of the CSMP identified inconsistencies in the management of the portfolio. This led to the development of the DND Contaminated Site Program Management Guidance. The Program Management Guidance divides contaminated sites into major types, and maps the route to closure for each type. The Program Management Guidance allows for easier identification of good candidates for site closure and is a central tool that supports the Site Closure Program initiated by DND in 2015/16.

The combined regional and centralized efforts since the initiation of the Site Closure Program has resulted in approximately 350 documented site closures. The ratio of site closure over the entire inventory increased from approximately 1% to 15% before and after the implementation of the Site Closure Program, respectively.

The documentation of contaminated sites closure demonstrates progress and due diligence. By reducing its inventory of active sites to only sites that require additional work, DND is also best positioned to focus its efforts on site assessment and high priority remediation, to answer questions with regards to departmental liability and to plan for future funding requirements.

A data quality evaluation, or data validation, is an important part of an environmental sampling program. While many analytical laboratories in Canada have strong data quality programs, they are often focused on ensuring that the analytical data are correct and complete, that appropriate standard operating procedures have been followed, and that quality control (QC) results are within the acceptable laboratory limits. This presentation describes additional data validation activities that should be employed when using Canadian environmental laboratories to assess possible data limitations and usability.

Data validation is a quality assurance step that provides an opportunity to make sure that analytical data are of sufficient quality to meet project-specific objectives. These objectives will vary depending on how the data are used and the potential risks associated with the project decision being made. Project objectives could include short-term water quality impacts during dredging, missed inventory assessments resulting in re-dredging, or litigation issues regarding sources of contamination and liability. In general, project decisions with a high risk (i.e., human health impacts) should have a higher level of data quality evaluation to ensure that important decisions are based on good quality data.

Specific data validation steps that should be employed after laboratory reporting include review of QC analysis frequencies, field sample results, laboratory blank contamination, instrument calibration and performance checks, surrogate recoveries, laboratory control samples, matrix spikes, compound identification and quantification, and chromatogram interference. Some agencies are also requiring additional validation steps, such as use of standard reference materials be conducted alongside some sediment analyses. The use of a broader range of data qualifiers identified during data validation is recommended, as some sample results that do not meet all project-specific objectives can still be used for some limited purposes.

This presentation provides an overview of the different levels of data validation routinely used on U.S. Environmental Protection Agency (USEPA)-regulated projects, and examples of how to determine the right level of validation for your project. The level-of-effort and estimated costs for these different validation levels will be provided. Examples of Public Services and Procurement Canada (PSPC) projects that have included data validation will also be provided. Additionally, case studies that demonstrate how data validation can change the outcome of data usability will be provided.

Lastly, this presentation will include data management strategies to help project managers maintain high quality, validated data in a project database. Project databases are useful for clean-up sites that have, or in the future may have, additional sampling to monitor the effectiveness of a clean-up. Strategies include information on data completeness, sampling nomenclature, and consistency.

The Treasury Board of Canada Secretariat (TBS) develops government-wide policy and provides guidance on the management of federal assets (i.e., TB Policy on Management of Real Property). In accordance with policy, TBS also administers the Directory of Federal Real Property (DFRP) and the Federal Contaminated Sites Inventory (FCSI), where federal organizations are required to report specified data on their real property assets and all known or suspected contaminated sites.

The FCSI is a central database of all known or suspected contaminated sites for which federal departments, agencies or consolidated Crown corporations are accountable. It is also a web-based application that allows federal organizations to directly report and manage their data as well as offer all users the ability to conduct analysis with a variety of search criteria, auto-generated reports, and mapping capabilities. The FCSI is used to inform the Government of Canada, ministers, Members of Parliament, and Canadians about the state of federal contaminated sites.

To date, departments, agencies and consolidated Crown corporations have identified and classified over 23,000 contaminated or suspected contaminated sites in urban, rural and remote areas across Canada. The Inventory displays a standard set of basic tombstone and annually-updated information for federal contaminated sites. Each of these site records include information such as site location, the severity of contamination, the contaminated medium, the nature of the contaminant, progress made to date in identifying and addressing contamination, and how much liquid and solid-based media have been treated.

This presentation will provide a summary of policy requirements related to the management of contaminated sites, information management and reporting requirements for contaminated sites, and a walkthrough of the available data, functionality and limitations of the FCSI.

The industry standard “single point” or determination cost estimates for mine closures, etc., are commonly used but provide very little information on potential financial risks or cost savings opportunities and hence are not good planning tools. This presentation will outline various probabilistic-based methods of estimating closure costs and discuss how these can be used for mine closure planning, development of risk management plans, financial reserve estimates and budgeting. These tools include decision trees to track alternative outcomes, Monte Carlo simulations to capture cost variability, as well as risk and opportunity identification and management matrices. Since mine closure has much uncertainty these tools provide the ability to isolate key uncertainty variables, which in turn facilitates strategic planning, focused investigations and cost effective analyses. These methods will be described and how these can be used to improve closure planning will be discussed.

Two case histories will be presented to illustrate the application of these tools. The first case history involves a mine in Canada at which preliminary closure approaches and cost estimates had been developed. Decision trees were established to represent the feasible alternatives for closing the Tailings Storage Facility (TSF), the underground mine, open pits, waste rock piles, and the site facilities and associated impacted soils. Estimated costs and probabilities the alternatives for each of these major features were applied to develop the 80% confidence level cost to be used for budgeting purposes, the most likely closure approach and cost, the potential maximum and minimum costs, and the breakdown of costs for these features as well as the site holding costs. These data were then used to identify strategies, data collection and evaluation plans for minimizing the potentially more costly approaches, as well as identifying strategies for minimizing closure costs. This approach supports, but does not replace the formalized decision analyses recommended for closure planning.

The second case history describes a more complex mine closure which involves planning for closure of a mine site where some of the land and mine features had been sold for sand and gravel production. Closure options included not only the various technical approaches to closure, but various property repurchase scenarios as well.

Finally the presentation will conclude with a discussion of how Indigenous and Northern Affairs Canada proposes to apply the above tools and procedures to improve both its forecasting and budgeting as well as the mine closure planning process.

Multi-year programs are a common approach for the Canadian federal government to address environmental and human health protection, site liability reduction and site closure of historically contaminated sites. Public Services and Procurement Canada (PSPC) has a number of contaminated sites arising from the expedited construction of the Alaska Highway in 1942 by the US Army and ongoing highway maintenance (from fuel spills and releases, dumping and landfilling, and ongoing storage of road salt). The delivery of a multi-year program for the assessment, remediation and risk assessment of three of these active Highway Maintenance Yards along the Alaska Highway in remote Northern British Columbia has been tasked by PSPC.

A robust program management framework was developed to ensure that program (and specific project) objectives are being delivered. This presentation outlines how the overarching program management objectives were achieved while providing maximum flexibility to small, independently managed assessment/remediation teams to address the unique site requirements of each site – each with different technical challenges and logistical complexities. The customized program management framework was developed and then applied with a philosophy of ‘project management as a service’ addressing:
• Integration management, scope management, budge, schedule, risk and lessons learned.
• Consistency of quality and communications between three independent teams.
• Program information and decision-making within the project team, program stakeholders, and client.
• The guiding document, which will be discussed in this presentation, is a multi-year road map developed for the Alaska Highway program. The road map provides an accessible one-page visual model of the overall program describing the individual work steps required, and how they contribute to annual program goals. This provides each member of the project team with a high level overview, and the client can readily see how the funding requirements translate to the practicalities of workplan preparation and execution, ensuring objectives are met within annual funding allocations and constraints. This approach has also supported appropriate use of contracting mechanisms, integration of internal resources from centres across western Canada, and focus on critical path activities.

The road map is applicable to:
• Progress reporting – supports identification of early warnings for specific activities.
• Live/dynamic document – presenting a unified picture of situational awareness to the client, internal management and to a large geographically diverse project team.
• Partnership – the roadmap is a live working document, continually updated and changed as opportunities arise and learnings become apparent. While each site has custom technical challenges, the commonalities of specific site challenges are more easily shared when the team shares the same project picture.

This tool allows the program manager to provide a near real-time picture of project cost and funding that can be shared with the full team - while giving each site-specfic project manager the accountable flexibility needed to deliver multiple small-scale high quality projects efficiently with appropriate cross-site consistencies.

The objective of updating the PWGSC 2003 Contaminated Sites Risk Management Guidance Document (guidance document) was to ensure consistency with current Federal Contaminated Sites Action Plan (FCSAP) guidance and relevancy to all federal custodians, as it will be used in the development, implementation, monitoring, and documentation of risk management plans for federally contaminated sites consistent with the current FCSAP Decision-Making Framework (DMF). The revised guidance document will replace the 2003 PWGSC-specific document and enable all federal custodians to determine whether risk management and/or remediation is appropriate and how it can be implemented consistently across contaminated sites. The updated guidance document provides a tool to allow consistent decision-making regarding the management and/or remediation of federally contaminated sites and provides a consistent approach to site closure when risk management or remediation is required.

Key changes to the guidance document include the consideration of aquatic sites. The decision-making flowcharts were also updated to correspond with the current FCSAP 10-step DMF and a revised set of criteria for risk management was established. The guidance document now differentiates remediation from risk management and allows for both remediation and risk management to be used at the same site for different contaminants of concern (COCs) and/or media. Information on active site monitoring and control measures was expanded to include designing a monitoring program, how to set targets, how to implement and make decisions about termination of monitoring or triggers for additional work. In addition, guidance on the consideration for ecological receptors, how to use administrative controls and suitability of use have been added. Direction on the development of monitoring plans to evaluate the effectiveness of risk management measures, identifying suitable triggers for application of additional work, and processes for recording decisions throughout the risk management process were also included. Lastly, guidance was provided with respect to evaluating the effectiveness of risk management measures to determine how and when to close a site.

The revised guidance document was reviewed by a FCSAP expert support working group in March 2018 and is currently in draft for custodian review prior to finalization.

Remote contaminated sites in Canada present unique challenges during the assessment, remediation and management phases. Common remediation strategies are often not practicable at remote northern sites and the impact of these technologies needs to be balanced with the overall ecological benefit that can be achieved. The isolated location of these sites and difficult access also mean that, under normal circumstances, humans do not visit these sites.

As part of the Federal Contaminated Sites Action Plan 10-step process guidance for site closure, a quantitative human health and ecological risk assessment (HHERA) is often conducted to determine the best risk management strategy for a site. The level of effort and cost for these risk assessments can be significant. A framework to determine the likelihood of potential risk to human and ecological health in a qualitative way was developed to provide guidance on the evaluation of small, northern remotes sites managed by Parks Canada Agency in the progression towards closure of these sites. The framework follows the principles of a preliminary quantitative risk assessment for human health and an ecological risk assessment but proposes an effort that is commensurate with the impact of these sites on humans and the environment. The framework considers the unique attributes of remote sites in Canada and avoids unnecessary disturbance of the site if the site is unlikely to pose significant risk to human and ecological receptors. The proposed framework was applied to two sites within Ivvavik National Park, Yukon; an abandoned oil exploration site and a Warden Station. The framework and the resulting site-specific recommendations and implications for the future management of these sites will be discussed.

Environment and Climate Change Canada (ECCC) operates on Crown owned land, leased properties, or properties in agreement with other government organizations. The ECCC Contaminated Sites Assessment group (CS-A) reviews, prioritizes and conducts environmental assessments of these properties in order to identify potential human health or environmental risks. Sites identified with potential risks are then evaluated for remedial or risk management activities.

ECCC conducts activities on approximately 7,000 sites that could potentially result in an environmental impact resulting in a risk to human health or the environment. Given the number of sites, the CS-A requires a process for long term planning and the prioritization of the properties to be assessed. The process would be used to guide the annual project planning cycle and be able to incorporate shifts in organizational objectives and allow flexibility to adapt to new risks and challenges or shifting priorities.

CS-A established a process for the screening of sites for prioritization, evaluating physical and technical information, and political, social, and economic factors. This approach integrates Government of Canada and departmental priorities, facilitates collaboration with other networks and real property groups, assists in the planning of real property acquisitions and divestments, and supports the planning process for capital projects. Upon completion, a ranked priority list of properties with planned assessment activities (The Prioritization Tool) is established. The Prioritization Tool is used as a guide for managers’ annual business planning, program management, and project planning and implementation. It is reviewed and updated annually.

The established process follows the standard model for continual improvement (plan, do, check, act). This cycle allows an adaptive approach to address in-year program changes and ensures an annual review to ensure alignment with changing departmental priorities, new physical and technical information, and any political, social, and economic changes.

Within each fiscal year, once a program has been approved and implemented, quarterly reviews identify potential changes in departmental funding, project scope, costs and potential other factors (weather, access, permits, etc.) that could result in project delays or cancellations. The Prioritization Tool allows for information to be quickly reviewed to identify other priority projects that could easily be implemented. Information such as the selected projects current status, locations, stage of preparation for implementation, and cost estimates allow staff to make informed decisions on the selection of new projects mid-year and allow for the mitigation of potential risk associated with implementation.

Annually, the completed projects and priorities are also reviewed. The goal is to ensure that the ranking of sites and assessment activities with the Prioritization Tool be updated accordingly prior to the initiation of the next business cycle. The process ensures that program and project delivery are in constant alignment and integrated with other departmental activities.