Contaminated sites Management - Dr Michel Tétreault

Contaminated sites Management within the Department of National Defence

By:Major François Lauzon, M.Eng., CD, Chef-Génie de l'environnement, DGE, QGDN

DND is the largest federal organization, with some 60,000 regular canadian Forces (CF) troops, 30,000 reservists, and about 20,000 civilian employees. Prior to 1986, the Department was responsible for the development and upkeep of approximately 70 bases and stations located throughout the country and overseas. Today, the Department operates 27 bases across the country, which cover a little under 20,000 square kilometers of land.

The associated infrastructure, as well as the operations of the armed forces on the land in question, requires a high level of environmental stewardship. The Department is responsible for the mitigation of the environmental impact of past and current activities. There is a very wide range of environmental issues that are being managed by DND, from the effects of low-level flying in ecologically sensitive corridors to the disposal of harbour dredgeate. Since 1992, contaminated sites have been the most significant single issue in terms of allocated environmental financial resources. This article presents an overview of DND's practices regarding the management of contaminated sites.

A wide range of challenges

By virtue of the size of the Department, covering a very large geographical area and supporting the very diversified activities of the CF, DND must contend with a broad range of contaminant types under an equally wide range of surface and subsurface conditions. With the exception of the petrochemical industry, DND is responsible for the largest stock of fuel hydrocarbons in Canada. Therefore, it should not come as a surprise that 75% of the contaminated sites currently inventoried are related to the storage and conveyance of fuels.

 

Drums with unknown content in a dump, at CFS Alert, NWT

 

Battery dump at CFS Alert, NWT

 

Contaminated site investigation at CFB Suffield , Alberta

 
 
 

The remaining sites, however, cover a wide range of conditions. The Department operates a number of, what may be called, light-to-medium industrial sites and, therefore, has a number of contaminated sites with halogenated solvents and toxic metals, that resulted from poor past practices. Potential lead contamination of surface and subsurface water is of concern in the many firing ranges. The operation of Fire Fighter Training Areas, have created a challenging set of subsurface contamination problems.

These problems are not unique to DND and their management may rely on solutions that have also been tried and tested by other large corporations or municipalities. Among the problems that are unique to DND we find Unexploded Ordnance in artillery and air-to-ground ranges; potential contamination at various Defence Research Establishments, which in the late years of the second world war and the early years of the cold war conducted tests of defenses against chemical and biological warfare agents, and; contamination in remote northern locations with particularly sensitive ecosystems and unique subsurface conditions, especially permafrost.

Regulatory Context

The DND is subject to a number of federal acts which govern routine operations and the environment. The Canadian Environmental Assessment Act entrenches the obligation to conduct environmental assessments. These assessments are aimed at identifying potential impacts of all the activities of DND and the CF and, avoiding the creation of contaminated sites. The Canadian Environmental Protection Act (CEPA) was adopted to address the problem of toxic substances in the environment. Under the CEPA, DND must take reasonable measures to prevent or mitigate the release of regulated toxic substances and Environment Canada is empowered to act as a compliance enforcement agency. The Fisheries Act is the longest standing federal environmental legislation. The Act prohibits the release into streams of substances with the potential to harm fish or their habitat. It is currently the most aggressive of the environmental statutes of Canada.

Decommissioning activities at CFS Moisie, Quebec

In the absence of federal legislation identifying substances relevant to a site and mandating intervention based on specific contaminant concentration criteria, DND has adopted the policy to rely on, when practical, the more stringent of the provincial guidelines or the guidelines developped by the Canadian Council of Ministers of the Environment (CCME). In the case of sites that are currently located on DND bases, a risk management approach can be considered to determine the need for intervention.

The management structure

In 1983, DND created the office of Director Conservation and Environment which was expanded in 1992 to become the office of Director General Environment (DGE), composed of two directorates: Director Environmental Stewardship, responsible for the development and maintenance of DND's sustainable development strategy, environmental management systems and natural resources, and; Director Environmental Protection, responsible for pollution prevention, hazardous materials management and contaminated sites management.

During that period, the positions of Environment Officers were also created on each base and commands. Finally in 1995, Defence Construction Canada, a crown corporation created to provide contract management services for DND's major infrastructure development projects, began to get involved in environmental site remediation projects.

Typically the Base Environment Officer (BEnvO) will prioritize contaminated sites on his or her base armed with a previously conducted base environmental audit and apply for funds from DGE to further characterize a site and, if warranted, remediate. DGE allocates funds in part on the basis of the National Classification System score of the sites. Site characterization and remediation is contracted to consultants and remediation contractors by the BenvO, who manages the projects, often with the support of DCC.

In addition to the aforementionned groups that are involved in the management of contaminated sites under the present care of local DND units, Director General Construction and Property Services (DGCPS) are responsible for contaminated sites found on properties that have been declared surplus and slated for transfer to other public and private interests. DGCPS follows the directives set out by DGE in managing their contaminated sites during decommissioning.

Principal Contaminated Sites Initiatives

National funding programs for contaminated sites management began in the late eighties and early nineties with the fairly systematic performance of environmental baseline investigations, to which approximately $6 M was allocated. These baselines gave rise in 1992 to the creation of the Corporate Environmental Program (CEP) that DGE is mandated to manage. The Contaminated Sites Remediation Program (CSRP) is the most significant component of the CEP. The CSRP was created to allow bases to characterize and, if required, clean up sites that resulted from activities predating 1992. These sites are referred to as legacy sites. Contaminated sites created after 1992 are the responsibility of the bases and are to be managed from the bases' operations budgets.

Since 1992, approximately $250 M has been allocated to the Contaminated Sites Remediation Program. In addition to the CSRP, which is intended to manage most legacy sites, DGE has managed a number of very large special projects, such as PCB contamination in Saglek, Labrador; the DEW line clean up ($300 M); hydrocarbon contamination in Goose Bay, Labrador ($12 M), and; decontamination of lead in Longue-Pointe, Montreal ($31 M). Finally, to date DGCPS has allocated approximately $34 M for contaminated sites related to facility decommissioning.

DGE has developped and implemented the use of a contaminated sites database, Aladdin. The database was created initially from an inventory conducted by DGE, but it is now the responsibility of individual bases to update the database. It is also a requirement of the Treasury Board for all federal departments including DND, to maintain an up-to-date inventory of all of their environmental liabilities. This will eventually allow the TB to include those liabilities in the compilation of the national debt. Contaminated sites are by far the most significant environmental liability of DND.

In an effort to rationalize the prioritization of contaminated sites, DGE has also developped the Contaminated Sites Remediation Framework, which outlines the process that bases are to follow.

DND Contaminated Sites Remediation Framework The Framework primarily applies to contaminated sites on active bases. Although the procedures followed during site decommissioning are similar in principle to those of the Framework, the additional factors that must be considered when dealing with property transactions are considered in a separate document used by DGCPS.

The purpose of the Framework is to act as a management tool so that proper steps are taken to characterize, classify, and prioritize contaminated sites and to ensure that remediation takes place in a cost-effective manner. This document only serves as a guideline when dealing with contaminated sites. It is recognized that different approaches and/or techniques may be used to characterize and remediate contaminated sites based on site specific conditions or criteria.

The Framework consists of an enumeration and description of the recommended steps to be followed, which are essentially based on classic approaches adopted in the industry. In addition, templates are provided for scopes of work required in the procurement of consulting and contractor services at the different stages of the process. The Framework has been recognized by the authors of an independent internal audit as significant progress towards achieving "value for money" in environmental projects. High praise from auditors !

Remediation Technologies

A fairly broad array of technologies have been used over the years to remediate DND's contaminated sites. The selection of remediation technologies is now guided, to some extent, by the Framework, but consultants play a key role in evaluating the suitability of technologies to site specific conditions. DND has, in the process, acquired valuable corporate experience in the selection and application of remediation technologies. While the tendency has been to opt for proven technologies, the department has been open-minded about investigating emerging technologies.

The many technologies used or investigated are too numerous to fully enumerate here, but the following list provides a broad overview:

In-situ approaches

  • CFB Borden: Funnel-and-GateTM with Biocurtain, where groundwater was funneled in-situ with sheet piles through a gate where bioremediation was enhanced;
  • CFB Borden: Biocell, where fuel contaminated soil was excavated, bioaugmented and replaced in the original excavation, with the addition of an air injection system;
  • CFB Petawawa: A series of technologies was used to remediate the site of a decommissoned gas station. For the fuel-contaminated soil zone, soil vapour extraction along with biofiltering of the extracted vapours was followed by bioventing. For the groundwater plume that was already developed, groundwater pumping and activated carbon treatment;
  • Phytoremediation is also being field-tested at CFB Chilliwack while Monitored Natural Attenuation has been adopted at the former CFB Uplands' fire training area and is being investigated for a decommissioned gas station at CFB Borden.

Ex-situ approaches

Biocell in operation at CFS Chatham, Québec

Among the ex-situ approaches adopted, we find:

  • Low Temperature Thermal Desorption at CFB Cold Lake;
  • incineration at CFB Goose Bay;
  • Landfarming at CFB Borden and CFB Edmonton.

Technical Partnerships and scientific payoff

DND has become a leader in the development of a federal contaminated sites management approach, while co-chairing the interdepartmental Contaminated Sites Management Working Group. The department is also working actively with other government and private agencies towards the development of solutions to contaminated sites.

The current practices established by DND were developed over many years, in many cases through collaborations with a number of universities. Among these partners, are the University of Waterloo, the University of Alberta and Carleton University. By virtue of its status as a integral unit of DND, the Royal Military College of Canada in Kingston, has established a close working relationship with DND environmental managers at all levels. The most significant contribution of RMC to contaminated sites management is provided by the Environmental Sciences Group, which has taken a lead role in managing contaminated sites in the Arctic. The Environmental Engineering Research Group and the Groundwater Research Group, also make significant contributions to the development of protocols and solutions.

In all cases, a mutually beneficial relationship was developed where the university provides technical expertise in the investigation of problems and development of solutions, while gaining valuable research data. In this way, DND issues are used for the advancement of scientific knowledge. The university partners, in particular RMC, also play a key role in the education and on-going professional development of DND environmental managers.

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