Province’s environmental assessment process ‘a paper exercise’

A review of a risk assessment on the former Imperial Oil fuel storage facility in Charlottetown raises red flags for UPEI toxicologist.

This article appeared on page A6 in the Saturday April 2, 2011 edition of The Guardian

The province requires the bare minimum when it comes to reviewing contaminated land, says a toxicologist from UPEI.
After reviewing a risk assessment prepared for Imperial Oil on one of its Charlottetown properties, Michael Van Den Heuvel called the process a paper exercise.
“Risk assessments are what has been pushed by consultants all across North America, particularly in the U.S. as the prime way of doing these things,” he said. “The reality is any risk assessment is a paper exercise and there’s no certainty of these estimates.”
Risk assessments compare data from soil tests to a standard model to determine the level of human and environmental health effects.
Van Den Heuvel reviewed the risk assessment on the former Imperial Oil fuel storage facility on the Charlottetown waterfront.
The land, which is where a proposed outdoor events site could be constructed as earlier as this spring, is full of contaminants left behind from the fuel storage facility.
The risk assessment outlines areas of the land where contaminants exceed acceptable guidelines under the Atlantic Risk-Based Corrective Action (ARBCA), a risk assessment standard adopted by the four Atlantic provinces in 1999.
“It has a criteria, there’s numbers that they sample soils and groundwater and they’re cleaned up to those standards,” said Glenda MacKinnon-Peters, a chemical engineer with the environment department.
“If there is a case where there is contamination on groundwater and if there is concern for vapours coming up into buildings, or it is was a potable water site, all those things are taken into consideration (under ARBCA).”
Groundwater under the land in question is not used for drinking water, said MacKinnon-Peters.
All groundwater under the Island eventually discharges into a stream, river or coastal area, including the groundwater at risk of the site’s contaimination, said Van Den Heuvel.
Even with the Atlantic standard, which is based on Health Canada guidelines for human health, Van Den Heuvel said more research should have been done based on the red flags he found in the report.
“Where indications of risk exist, the risk assessment should be followed up with an environmental impact assessment that examines the real exposure and impacts to biota in the receiving environment,” he said.
MacKinnon-Peters reviewed the same risk assessment of the site as Van Den Heuvel.
She also had access to more research of the site than Van Den Heuvel, who read the risk assessment on The Guardian’s behalf.
“There were other studies done, it was a long process,” she said. “Imperial Oil had done years of documentation and studies of that site before we issued closure. The work that was done there (was) done by a highly recognized environmental firm and we agreed with their outcome in their report.”
Closure is given when the file has been closed and the department will not order any further testing.
“We feel that the contamination has been delineated, which mean it’s been well studied and documented and we feel that everything is in a stable condition there,” said MacKinnon-Peters.
Van Den Heuvel said, based on what he took from the risk assessment, that contaminats in the ground are moving, but he could not tell how quickly they are moving or if they pose a threat to organisms in the environment.
“If they found absolutely no risk on this site in any category then that means it probably doesn’t need further (studies) and maybe could leave it then and it would be safe but that’s not the case here,” he said.
The application reviewed by the province was for an outdoor event centre built on a clean soil cap or pavement.
“We gave closure for that land use, it’s only for that site being used as an open-air venue,” said MacKinnon-Peters.
If the proposal was to construct buildings, for example, then the province would take a different approach in its review.
Van Den Heuvel agreed the report was well written and addresses many human health concerns but he would like to see more research done on plant and animals – biota data.
MacKinnon-Peters did not have all the documentation with her when The Guardian interviewed her, but she could not recall if any biota research was done.
“My perspective as a toxicologist is that a risk assessment is a good approach and should be an initial approach,” said Van Den Heuvel. “It’s called the precautionary principle. When you read a risk assessment and you see red flags, then the precautionary approach should be to protect the people and the environment, not to leave it and say we can ‘minimize the hazard.’”

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