AECOM

3292 Production Way, Floor 4 604 444 6400 tel

Burnaby, BC, Canada V5A 4R4 604 294 8597 fax
www.aecom.com

Discussion Paper

To Paul Dufault, GVS&DD Page 1 of 10 + Att.

Rick Bitcon, AECOM
Wayne Wong, AECOM
Eduardo Gamez, AECOM
CC Anthony Fuller, Golder

Subject LGSWWTP Soil Management

From Rob Dickin, AECOM

Revised January 12, 2016 after receiving MV
Date comments and discussion with Wayne Wong Project Number 60429019

1. Purpose
The purpose of this discussion paper is to inform the Project Team of the contaminated soil issues
associated with the project property (the “Site”) at 1311, 1321, 1350 West 1st Street, North
1
Vancouver that is being developed for the Lions Gate Sewage Treatment Plant (LGSWWTP).

This discussion paper briefly describes the Areas of Environmental Concern (AECs) and Potential
Contaminants of Concern (PCOC) that have been identified during previous environmental
investigations at the Site by consultants retained by the previous landowner. The paper provides an
overview of project risks and sets out a suggested allocation matrix between Project Co and
GVS&DD for contaminated soil management.

2. Regulatory Framework
Contaminated soil, groundwater, soil vapour, sediment and surface water in BC are regulated under
the Contaminated Site Regulations (CSR) under the Environmental Management Act (EMA). The
CSR and its protocols provide a framework to investigate and remediate contaminated sites in British
Columbia.

The CSR identifies five Schedules applicable to establishment of risk-based cleanup levels for soil,
water and vapour:

 Generic Numerical Soil Standards for various land uses (Schedule 4)

 Matrix Numerical Soil Standards that consider human and ecological exposure pathways
as well as land use (Schedule 5)

1
Note: Development Application notes property as 1131 West 1st Street. Refer to correspondence from Doug Allan
(Community Planner District of North Vancouver) to Paul Dufault (GVS&DD), dated December 10, 2014

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 Generic Numerical Water Standards (Schedule 6)

 Standards Triggering Contaminated Soil Relocation Agreements (Schedule 7)
 Generic Numerical Soil and Water Standards (Schedule 10)
 Generic Numerical Vapour Standards (Schedule 11).

The CSR also specifies notification requirements for responsible parties to provide written Notice of
Independent Remediation (NIR) to the ministry, notification to neighbouring property owners, and
development of a site risk classification report.

Based on the previous environmental reports prepared by others and the Certificate of Compliance
(CoC) (Attachment A) issued to BCR Properties Ltd. (BCR) on March 23, 2011, the following
standards are applicable to this Site:

 industrial land use

 marine aquatic life

Based on the October 6, 2014 Release Request for Development Application to the Ministry of
Environment (MOE) (signed by Rob Dickin of AECOM, Numerical Standards CSAP), Drinking Water
Standards now apply to the Site based on MoE Technical Guidance 6 – Water Use Determination
(TG6). TG6 became effective February 1, 2011, after the BCR CoC application was submitted.

The release letter issued by the MOE to GVS&DD and the District of North Vancouver on October 14,
2014 (the “Release Letter”) is enclosed as Attachment B.

The MOE is completing an “omnibus review” of all the environmental quality standards in the CSR
and is developing a new set of draft standards, which are expected by June 2016 with an effective
date some 6 to 12 months later (exact dates have not been determined). This impending regulatory
change in environmental quality standards induces a risk that the quantities of contaminated soil and
groundwater requiring remediation may increase after the regulatory change comes into effect.

3. Background
The Site was owned by BCR and was used for railway operations for many years including: a
commercial freight shed, the Royal Hudson passenger service, a passenger station, and associated
ancillary facilities. BCR sold the property to GVS&DD for the purposes of building the LGSWWTP.

BCR completed soil and groundwater remediation of the Site between 2008 and 2010 to meet
Contaminated Sites Regulation standards for industrial land soil use and marine aquatic life water
use. Reports that document the results of previous environmental investigations and remedial actions
are referenced at the end of this discussion paper.

A risk-based CoC was issued by the Ministry of Environment for the Site on March 23, 2011. There
was off-site contamination associated with the Site. BCR prepared a Remedial Plan for the impacted
off-site area of the BCR rail right-of-way located at the southeast end of the Site. BCR obtained a risk-
based Approval in Principle (AiP) of a Remediation Plan for the off-site management area in 2011.

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The CoC includes a number of legal Conditions, which must be adhered to. The value of the CoC to
BCR is that they are no longer considered a “responsible person” for remediation under the EMA
(Part 4, Section 46(1) (m). However, the Conditions on the CoC indicate that the CoC is not valid if
the land use changes from a “decommissioned railway yard with potential industrial use of existing
buildings and surface areas”. Therefore, due to the impending land use change, GVS&DD may
become a “responsible person” for remediation.

Subsequent to the granting of the CoC, there have been no new commercial or industrial site
operations on Site, other than the deconstruction of buildings to clear the site in preparation for
construction of LGSWWTP. Confirmatory soil sampling was conducted below the building footprint as
part of the deconstruction work. No new soil contamination was identified.

GVS&DD submitted a Site Profile to the District of North Vancouver along with an application for a
development permit for the subject Site. GVS&DD submitted an NIR to the Director along with a
Release Request. The Release request was approved with respect to the site for: Scenario 5:
Proposed change in parcel activity and redevelopment, as set out in the Release Letter.

4. Extent of Remaining Soil and Groundwater Contamination on the

Site
Attachment C (Figure 14 (Revised) “Extent of Remaining Soil and Groundwater Contamination (Post-
Remediation)” from Piteau Associates Engineering Ltd.'s (Piteau) (2010) Confirmation of Remediation
Report) shows estimated areas of soil contamination labelled as AECs with associated PCOCs. This
figure also shows the anticipated limits of excavation for the project (to property boundaries in all
directions).

Attachment D (COR – Table 14 (Revised) Summary of AEC Status (Post Remediation) from an
addendum to the Piteau, 2010 Confirmation of Remediation Report) presents the AECs and
associated contaminants of concern in soil and groundwater which remain at the Site post
remediation. This table also provides Piteau’s estimate of areas/volumes of impacted soil and
groundwater that remain to be remediated on the Site. These estimates are not suitable for design,
construction or costing and are subject to the third party use disclaimers in the Piteau report.

5. Off-Site Contamination
Based on the Piteau (2010) Remediation Plan there is a legally defined off-site management area
located on the BCR right-of way south of the property (AEC1), as shown on Figure 1. Non Aqueous
Phase Liquid (NAPL) petroleum is present in the off-site management area (AEC1) but is not
considered by BCR to be mobile. The contamination in this area is addressed by the AiP, which was
issued in 2011. Remediation of this off-site area remains the responsibility of BCR, who is the off-site
property owner, and responsible for the release of contamination when it occurred and migrated onto
the right-of-way.

A subsurface cut-off wall was installed by BCR along the property boundary adjacent to the off-site
management area. The cut off wall is designed to prevent reversal of the ambient groundwater flow
direction and potential northward flow of contaminants in the groundwater flow system. However, the
Piteau Remediation Plan states that a reversal of groundwater flow (i.e., from southward to

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northward) could occur as a result of excessive or prolonged removal of groundwater, or other

activities at the Site and that prevention of this condition is the responsibility of the Site owner
(i.e., GVS&DD) to “ensure that this plan is properly implemented”. Piteau (2010) also indicates that
there is a small area of LEPH contaminated soil above the industrial standard along the south side of
West First Street that should be remediated when the rest of the site is excavated.

In addition to AEC1 and AEC 2, there are other AECs identified by Piteau (2010) that are shown
extending to the property boundary including AECs 11A, 11B, 11C, 11D, 11E and 11I. The CoC
delineation is based on this contamination being due to random historical fill placement. Therefore,
each property owner is responsible for addressing only the fill on their own property. Based on this
interpretation, there is no requirement for off-site delineation or remediation of off-site historical fill
areas as part of the current project.

According to the Purchase Agreement and Environmental Indemnity Agreement between GVS&DD
and BCR, GVS&DD is not responsible for off-site contamination originating from the site, if that
contamination was in place prior to the date the COC was issued.

6. RFP Soil Management and Remediation Recommendation

The RFP should require that Proponents accept full responsibility for the safe remediation and
management of contaminated soil and groundwater on the property, including any impacts on project
costs and schedule.

Suggested contaminated soil management/ remediation requirements for the Project Agreement are
outlined below in Table 1. Recommended roles and responsibilities of Project Co and GVS&DD are
also provided.

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Table 1. Summary of Soil Management/Remediation Tasks and Responsibilities

Task
Remedial Task Description Project Co GVS&DD
No.
1 Approved Professional. Retain a Contaminated Site Approved Responsible Review
Professional (CSAP) to review existing environmental reports, CSR
legal documents and associated Conditions.
2 Environmental Investigations. Conduct any additional environmental Responsible Review
investigations required to delineate the lateral extent, vertical extent
and volume of soil and groundwater contamination for remediation/
construction cost estimates. This includes determining any remedial
volume changes due to the impending regulatory changes or quality
standards resulting from the MoE Omnibus Review, which is scheduled
to be complete in the spring of 2016.
3 Soil Disposal Plan. Identify permitted soil disposal facilities for various Responsible Review
contaminated material types. Identify waste concentration categories
and volumes for landfill disposal approval. Negotiate disposal
agreements and determine costs. Assume legal ownership of all soil
and fill removed from the Site
4 Water Management Plan. Design necessary facilities and obtain Responsible Review - Issuance of
necessary permits and approvals for surface and groundwater water GVS&DD water discharge
collection, treatment and disposal. permits, if requested
5 Remediation Plan. Design excavation, including sequence, schedule, Responsible Review
geotechnical stability, dewatering and contaminated soil/ groundwater
management and remediation.
6 Implement Remediation Plan. Excavate and dispose of all accessible Responsible Review
contaminated soil, groundwater or soil vapour. Accept ownership of
any soil leaving the Site. Load and transport the contaminated soil
safely to approved disposal locations. Provide all required trucking
manifests, waybills, analyses, and disposal approval documentation.
7 Confirmation of Remediation Sampling. Conduct “confirmation of Responsible Review
remediation” sampling and testing in conformance with requirements of
CSR and associated CSR Technical Guidance documents including:
soil sampling of excavation sides and bottom; groundwater sampling;
and soil vapour sampling if warranted.
8 Risk Management. If there is any residual contamination that cannot Responsible Review and approval of
be safely removed then use risk assessment/ risk management in any areas of residual
conformance with requirements of CSR and associated Technical contamination that cannot
Guidance. be removed.
9 Confirmation of Remediation report. Prepare a Confirmation of Responsible Review and approval of
Remediation report that meets the requirements of the CSR and is any Conditions proposed
suitable for obtaining a CoC. Prepare any other required forms or for CoC.
reports that are required under the CSR
10 Obtain Certificate of Compliance. Obtain a CoC that names Responsible Review and approval of
GVS&DD as the property owner, so that GVS&DD is no longer a CoC and any Conditions
“responsible person” for residual contamination on the Site under the proposed on the CoC
Environmental Management Act (EMA).

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7. References
Associated Engineering. 2013. Project Closure Report – Passenger Station Lands Deconstruction, for
GVS&DD. May 2013.

MOE (BC Ministry of Environment). 2010. Summary of Site Condition, Site ID 9769, signed by Reidar
Zapf-Gilje, CSAP. December 16, 2010.

MOE. 2014. Site Risk Classification report and Exposure Pathway Questionnaire for Site 9769
December 16, 2010, Summary of Site Condition Site ID 9769, signed by Reidar Zapf-Gilje,
CSAP. October 10, 2014.

MOE. 2014. Release Request – Development Permit Application, Letter to GVS&DD (P. Default) and
District of North Vancouver (D. Allan). October 14, 2014.

Piteau (Piteau Associates Engineering Ltd.). 2010. Combined Stage 2 Preliminary Site Investigation
and Detailed Site Investigation – Former North Vancouver Freight Shed and Passenger
st
Station – 1311, 1321 and 1350 West 1 Street, North Vancouver, BC., for BCR Properties
Ltd. February 2010.

Piteau. 2010. Confirmation of Remediation – Former North Vancouver Freight Shed and Passenger
st
Station – 1311, 1321 and 1350 West 1 Street, North Vancouver, BC., for BCR Properties
Ltd. February 2010.

Piteau. 2010. Technical Memorandum, Addendum to Remediation Plan for Railway right-of Way
st
Adjacent to 1311, 1321 and 1350 West 1 Street, North Vancouver, BC., for BCR Properties
Ltd. September 15, 2010.

Piteau. 2010. Technical Memorandum, On Site Performance Monitoring Requirements for Cut-off
st
Wall at 1311, 1321 and 1350 West 1 Street, North Vancouver, BC., (Site 9769), for BCR
Properties Ltd. September 21, 2010.

Piteau. 2010. Technical Memorandum, Final Addendum for Former North Vancouver Freight Shed
st
and Passenger Station – 1311, 1321 and 1350 West 1 Street, North Vancouver, BC., for
BCR Properties Ltd. December 16, 2010.

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 Attachment A
Certificate of Compliance – 1311,
1321, 1350 West 1st Street, North
Vancouver
(SITE ID #9769) March 23, 2011

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 Attachment B
Release Letter Issued by MOE,
dated October 14, 2014

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 Attachment C
Figure 14 (Revised) “Extent of
Remaining Soil and
Groundwater Contamination
(Post-Remediation)” from
Piteau's Confirmation of
Remediation Report (2010) dated
October 14, 2014

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 Attachment D
COR – Table 14 (Revised)
Summary of AEC Status (Post
Remediation) – from addendum
to Piteau's Confirmation of
Remediation Report (2010)

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