Long-term monitoring: step 10 of federal contaminated sites decision-making framework

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Step 10: long term monitoring (LTM) (if required)

The objective of Step 10 is to implement a long-term monitoring (LTM) strategy at sites where the remediation/risk management (R/RM) objectives have been met but where conditions are such that the site could not be closed. For example, a risk management site would likely require long term monitoring. Long-term monitoring (LTM) may not be required at all sites. According to the 10-step Approach, LTM is meant to confirm that the nature and extent of the remediation activities have been carried out as per the site management goals, and that the objectives of the remediation or risk management strategy continue to be met over time to protect human health and the environment. Sustainable methods for site monitoring and contracting should be implemented as part of the LTM. Climate change effects should be considered during the development and assessment of the monitoring program in order to take potential changes in site conditions and exposure pathways into account. Stakeholders should be consulted as appropriate.

LTM objectives must be achieved and verified before a site can be closed, indicating that no further action is required. However, at some sites, perpetual monitoring may be required.

Once the LTM Strategy has been completed satisfactorily and the site can be closed, a closure tool should be completed, or updated. For FCSAP funded sites (R/RM activities) the Site Closure Tool (SCT) (FCSAP, 2012) must be completed and submitted to the FCSAP Secretariat.

If LTM objectives have not been met (e.g. monitoring results indicate exceedance of objectives), the exceedances should be reported to the appropriate level of management and custodians should re-evaluate the LTM Strategy and/or the Remedial Action Plan (RAP)/Risk Management Plan (RMP) (see Step 7).

Key decision(s):

• Decide whether the LTM plan, developed in Step 7, is still applicable.
  • Is the remedy functioning as intended by the R/RM plan?
  • Are the exposure assumptions, toxicity data, cleanup levels, and Remediation Action Plan/Risk Management Plan objectives used during Step 7 still valid?
  • Has any other information come to light that could call into question the protectiveness of the remedy?
• Decide when LTM is no longer required.
• Consider climate change effects during LTM planning, including possible permafrost loss or increases and decreases in infiltration rates, and
• Plan and implement sustainable LTM techniques, where feasible, that minimize energy usage and waste production.

How Fisheries and Oceans Canada (DFO) expert support can assist

• Provide advice during the design and development of a LTM program (e.g., selecting monitoring targets/endpoints and monitoring plans).
• Provide support for public engagement activities (e.g., help with the interpretation and communication of results).
• Assist with interpreting LTM results and reports.
• Provide advice on adaptive management and possible modifications to the monitoring plan.
• Provide assistance in applying the Framework for Addressing and Managing Aquatic Contaminated Sites under the Federal Contaminated Sites Action Plan (FCSAP, 2011).
• Provide assistance with interpreting LTM results and reports.

How Environment and Climate Change Canada (ECCC) expert support can assist

• Provide advice during the design and development of a LTM plan.
• Provide advice on establishing procedures for identifying decision criteria prior to LTM data collection.
• Provide assistance with interpreting LTM results and reports.
• Provide advice on the need to continue monitoring.

How Health Canada (HC) expert support can assist

• Provide advice on the need for LTM and on the design of the monitoring plans, including the need for risk communication with stakeholders and those affected, for the duration of the monitoring program (if necessary).

How Public Services and Procurement Canada (PSPC) expert support can assist

• Assist with the update of the LTM plan and with continual monitoring and the Site Closure Tool (SCT) (FCSAP, 2012) when applicable.

How the FCSAP Secretariat can assist

• Provide clarification on the application of the Eligible Cost Guidance document, v. 5.0 (FCSAP, update in progress) as required.

Supporting documents and tools

Please also refer to the list of “Supporting documents and tools useful throughout the 10-step process” at the beginning of the document.

Guidance

• Site Closure Tool (SCT), including the Tool for Risk Assessment Validation (TRAV) (FCSAP, 2012)
• FCSAP Long Term Monitoring (LTM) Planning Guidance (FCSAP, 2013)