Bulletin 2: Closure Report Worksheet (Appendix H) Version 2.0

Declaration Letter

The 2020 Remediation Process Guide Appendix I provides a template for the Declaration Letter to be submitted with all Closure Reports that are submitted 01 January 2021 onward.

Site background

Summarize site history, setting, source(s) of contamination and previous site investigations.

Maps, figures and supporting documentation

Include site maps and figures relevant to the remedial activities, as applicable.

Some examples include:

• Site location
• Site topography or drone imagery depicting topography
• Previous extent of contamination and/or excavation footprint(s)
• Sampling locations for all affected media
• Final wall and base excavation drawings showing confirmatory sample locations
• Cross-sectional diagrams to show geology and vertical and lateral contaminant delineation
• Treatment/monitoring well locations
• Groundwater contours and estimated flow direction
• Borehole logs with monitoring well completion details
• Site photographs

Conceptual site model

Describe the conceptual site model as developed during site investigation and characterization.

Commitments or conditions

Reference any company commitments or CER requirements associated with the site (e.g., requirements from a Remedial Action Plan (RAP) acceptance, or conditions on an Order or Certificate).

Overview of remedial activities

Include the volume of all media removed from site and their disposal method(s), as applicable.

If a RAP was previously accepted by the CER:

Summarize the RAP. Provide a summary of the selected remedial approach(es) and the activities completed. Describe how and why the remedial activities differed from the RAP, as applicable.

If a RAP was not previously accepted by the CER:

Provide a summary of the selected remedial approach(es) and the activities completed.

Contaminants of Concern (COCs)

Present the COCs that were analyzed to determine remediation is complete.

If not previously accepted in a RAP:

Discuss the rationale for both the inclusion and exclusion of potential COCs to ensure that all contamination at the site has been addressed.

Soil texture/grain-size

Summarize soil texture or grain-size analytical results.

If not previously accepted in a RAP:

Provide evidence of laboratory analytical results to support the selection of the Remediation Criteria (e.g., coarse- or fine-grained soils).

Land use

Provide a rationale for selected land use. See Section 11.4 of the 2020 Remediation Process Guide for further information.

Remediation Criteria: Use of generic criteria

If already accepted in a RAP:

• Present the Remediation Criteria, referencing the accepted RAP report
• Were there any changes to the Remediation Criteria accepted in the RAP? If so, provide a rationale for any changes to the accepted Remediation Criteria, as applicable.
• Have provincial and/or federal guidelines been revised in the time between the RAP acceptance and the submission of the Closure Report to the CER? If so, update the Remediation Criteria and highlight the changes.

If not previously accepted in a RAP:

• In a concordance table, present the relevant provincial and federal guidelines, and clearly indicate which Remediation Criteria were applied at the site. See Appendix B, Table 18.1 of the 2020 Remediation Process Guide for an example.
• Have provincial and/or federal guidelines been revised in the time between the remedial activities and the submission of the Closure Report to the CER? If so, update the Remediation Criteria and highlight the changes.

Remediation Criteria: Use of Site-Specific Remediation Objectives (SSROs)

If previously accepted in a RAP:

• During remediation activities, were there observations or findings that changed the assumptions used to create the SSROs (e.g., soil properties)? If so, provide additional support for the updated SSROs.

If not previously accepted in a RAP:

• Follow Section 11.6 of the 2020 Remediation Process Guide. Ensure that SSROs are well supported by providing the rationale for any pathway exclusions, adjustment of generic criteria with site-specific information, the use of risk assessment, as applicable, and sample calculations.

Confirmatory sampling

For all potentially affected media, describe the sampling protocol(s) for confirmatory sampling. Include both spatial and temporal information, as applicable (e.g., sampling frequency, seasonality for groundwater and soil vapour sampling).
Note: Confirmatory sampling protocols should be consistent with provincial and/or federal guidance where available, and referenced in the Closure Report (e.g., Appendix 5-1 in CCME Guidance Manual Volume 1 for Soil Characterization).

Analytical results

Provide summary tables and attach laboratory analytical reports to demonstrate all potentially affected media are remediated. Ensure it is clear which samples represent final conditions.

If generic Remediation Criteria or SSROs have been updated since remedial activities were completed, ensure analytical results are compared to the current Remediation Criteria.

Groundwater consideration

Compare post-remediation groundwater analytical results to current groundwater Remediation Criteria. Seasonality should be considered.

If groundwater was not a component of active remediation, demonstrate groundwater was either:

• Not exposed to or in contact with contamination; or,
• Meets Remediation Criteria for the site.

Background conditions

Do any parameters exceed the Remediation Criteria but are attributed to background conditions? If yes, include the rationale and supporting information to demonstrate background conditions, such as background sample analytical results.  The use of statistics, publications, maps and figures may also be acceptable.

Backfill quality

Demonstrate backfill soil quality is appropriate for the site (e.g., pH, salinity, COCs, soil texture and any other relevant properties such as weed seed content or Clubroot testing for topsoil).

Post-remediation activities

Summarize the post-remediation reclamation activities and objectives for the site. Describe any reclamation related conditions and/or commitments made to potentially affected persons or communities.

Record of engagement with potentially affected persons and communities

Provide an up-to-date record of engagement summarizing who was notified and/or engaged, along with any comments and/or concerns expressed by any potentially affected persons or communities. Include a summary of:

• Measures taken, or to be taken, that address comments and/or concerns, or an explanation of why no further action is required
• Methods and dates that the response was made to the potentially affected persons or communities who raised the concern(s)

See Section 7 of the 2020 Remediation Process Guide and the 2020 Early Engagement Guide for additional guidance on engagement with potentially affected persons and communities.

Record of engagement with other regulators

Provide an up-to-date record of engagement with other regulators that were notified of the contamination and engaged on the plans for Remediation. Include contact information such as name(s), email address(es) and/or telephone number(s), along with a summary of the interactions.

See Section 8 of the 2020 Remediation Process Guide for more information.