In Ontario, Phase II Investigations often follow the Ontario Ministry of Environment, Conservation and Parks (MECP) Record of Site Condition (Ontario Reg. 153/04 – Phase Two ESAs) regulations. As part of best management practice or in some cases triggered by a regulatory requirement (e.g. Ontario Reg. 153/04), a Sampling and Analysis Plan (SAP) is considered an essential component of a Phase II ESA, and includes detailed information that enables implementation of the field work in a manner that meets with the overall objectives of the project. The SAP is an integral part of the Phase II ESA process and should effectively target areas of potential environmental concern and corresponding contaminants of concern (COCs).
Key Components of a Sampling and Analysis Plan (SAP)
- Standard Operating Procedures (SOPs) to be adopted – these include procedures such as methodology for borehole drilling, installation of groundwater monitoring wells, screening methods, field equipment, methods and procedures to be used to obtain samples. SOPs are an integral part of conducting Phase II ESAs both for due diligence purposes as well as those required in accordance with the Ontario Ministry of Environment, Conservation and Parks (MECP) Record of Site Condition (Ontario Reg. 153/04 – Phase Two ESAs).
- Number of samples and media (soil, groundwater, surface water, sediment) to be collected in each area of potential environmental concern;
- Contaminants of Concern (COCs) for which samples should be analyzed; Details such as laboratory methods, detection limits and regulatory standards against which results will be interpreted should be included;
- Quality procedures to be adopted including equipment calibration and frequency; equipment decontamination procedures; sample containers and preservation; quality control samples including duplicates and trip blanks; transport to the analytical laboratory and chain of custody protocols;
- Data Quality Objectives (DQOs) which describe how the data proposed to be generated will support quantitative and qualitative applicable criteria. According to the MECP guidelines, DQOs outline the overall level of uncertainty that can be accepted in collecting field data in order to develop a Conceptual Site Model (CSM). Additionally, DQOs are set to determine precision, accuracy, reproducibility, representativeness, and completeness for field data (e., relative percent difference (RPD), matrix spikes, matrix spike duplicates, data qualifiers, etc.); and,
- Health and safety procedures to be adopted during the field work – the SAP could reference a site-specific health and safety plan. In addition, environmental management of issues such as air, water, management of investigation derived wastes, and traffic during implementation may also need to be addressed depending upon site specific requirements.
Benefits of a Comprehensive Sampling and Analysis Plan (SAP)
A focused and well-formulated SAP will ensure that the field investigation is implemented in a cost-effective manner whilst ensuring that sufficient and meaningful data is generated. Analysis of the data is used for the preparation of a CSM which then forms the basis for subsequent stages of the environmental due diligence process such as a risk assessment, remediation or formulation of a contaminant management plan. In addition to technical decisions, commercial decisions related to factors such as liability and costs eventually rely on the accuracy of the data generated from a Phase II ESA.
How can VTX help?
A detailed and well-formulated SAP is an essential pre-requisite to implementing any field work for a Phase II ESA. To learn more about VTX’s Environmental Consulting services or to speak with an Environmental Expert, please contact: