"With so many challenges facing a successful site clean-up
program, it would be easy to overlook something as simple as the
drinking water that comes from your tap. But municipal drinking
water presents such challenges because the chemical composition of
this ubiquitous resource may actually be "contaminating"
based on the Ministry of Environment's new site condition
standards for groundwater.
Municipal drinking water contains trace concentrations of
specific volatile organic compounds known as
"trihalomethanes" that are formed as a result of
chlorination in water treatment plants. Chloroform is the most
common trihalomethane and according to Health Canada, the average
chloroform concentration in Canadian drinking water is 47
µg/L. The new site condition standards for chloroform, which
came into effect on July 1, 2011, varies between 2 and 22
µg/L. This means that a discharge of drinking water to the
subsurface could exceed the site condition standard, implying that
the property where the discharge occurred could be considered
"contaminated". This is particularly relevant for Table 3
(non-potable) sites, where the chloroform standard for groundwater
has become much more stringent.
A common source of chloroform in groundwater is leakage from
municipal water distribution systems and sanitary sewers; however,
in some instances municipal water is used for environmental
drilling and discharged into groundwater. In this circumstance,
straight-forward technical measures can be applied to prevent any
potential for chloroform "contamination", such as
aggressive well development to remove any injected water.
It remains to be seen whether this type of groundwater
"contamination" ever becomes an obstacle to obtaining a
Record of Site Condition. That said, it does raise the awkward
possibility that your average municipal drinking water, while safe
to drink, could potentially derail the success of a site cleanup
Thank you, Eric!
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Ontario's Ministry of the Environment and Climate Change continues to roll out its Climate Change Action Plan with its proposed GHG guide for projects that are subject to the province's Environmental Assessment Act.
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