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Monday, 11 January 2016


A significant environmental problem is still present, underground, at the site of the new Virginia Park Elementary School. The issue needs to be exposed to the public, and better understood by everyone, before construction continues; that is if the new school should be built on this site at all. 

This Post is intended to "kick-start" that overdue conversation and release the, until now, secret Report.

Here are the salient facts:

The provincial government has been in possession, since April 2015, of a document entitled “DRAFT FINAL REPORT ON SUPERVISION OF CONTAMINATED SOIL REMOVAL DURING SITE PREPARATION WORK”, New Virginia Park Elementary School Site, St. John’s, NL.

As the title suggests, contaminated material has already been removed from the area where the structure is located. But the Report confirms that heavy metals and other dangerous metals are still present in the soil, at least along the north and northeast boundary of the site. The area of contamination remains undefined. The contaminants have the potential to threaten human health.

The Report, prepared by Pinchin LeBlanc, an Environmental Consultancy, (note: it is a large file 52,405KB. It contains a 3 page Executive Summary at the start.) The entire Report can be accessed here. It was obtained by the Uncle Gnarley Blog from a confidential source.

Cover - Pinchin LeBlanc Report
The Report, as stated, is dated April 2015. That is approximately nine months ago. More than adequate time has elapsed for the public to have been informed, and for additional studies to have been conducted.

Accordingly, one might be excused for assuming the government never intended that the public might be permitted to parse its contents.

The Tender for Phase II of the new school closes on Tuesday, January 12, 2016. This is further evidence the document was never destined for the public domain.    

I suggest no Tender should be awarded until all the facts surrounding the contamination issues have been fully assessed.
If the Premier is serious about his desire to ‘Restore Openness, Transparency, and Accountability” to the Government, he will instruct the Ministers of Transportation and Works (TW) and Education and Early Childhood Development (EECD), and the Minister of Environment and Conservation, to begin the consultation process right away.

While the environmental risks involve complex chemistry, such a hurdle is not a reason for “cover-up”; it merely heightens the need for candor.
Wikipedia defines Toxic Heavy Metals 

A toxic heavy metal is any relatively dense metal or metalloid that is noted for its potential toxicity, especially in environmental contexts.[4] The term has particular application to cadmium, mercury, lead and arsenic,[5] all of which appear in the World Health Organisation's list of 10 chemicals of major public concern.[6]
More information is available on the Link above.

You may well ask: why, at this late date, are we asking such questions? Surely, no stone was left unturned in the original assessment of the property’s safety and suitability?

The evidence does not support such a contention.

The following excerpts are verbatim the Pinchin Leblanc Report’s Executive Summary:

“some metal concentrations in soil samples collected from the north and northeast wall of the excavation (adjacent the Site boundary) exceed  the CSQGs for residential and commercial land use; (Editor’s Note: CSQG – Canadian Soil Quality Guidelines)

Metal concentrations in one soil sample collected from the base of the northwest portion of the excavation exceeds the commercial CSQGs;

Where detected VOCs in soil were below the CSQGs with the exception of TCE in four soil samples (includes a duplicate sample) collected from the north wall of the excavation and benzene in a duplicate soil sample collected from the northeast wall of the excavation. Benzene was not detected in the original sample. This variance is likely related to the heterogeneity of the sample (i.e. collected from the debris layer).”

This may sound like a science lecture but the importance of the issue is compelling enough not paraphrase, but to quote the Pinchin Leblanc Report.

At this point, it is important to point out that contamination on the school site has been tested using commercial standards. Those are more lenient than the contamination standards (often referred to as “exceedences”) used for residential areas.

For example, the Study locates a sandbox on the site of the existing playground. Part 5.4.4 describes nine soil samples taken in this area. Part states that the results did not exceed commercial land use CSQG but does not indicate if the results exceed the residential limits.

On the other hand, results from the north bank are compared to residential criteria due to the presence of residential properties located immediately to the north of the Site.

Part of the Report states: “Some metal concentrations exceeded the residential and commercial land use CSQGs including antimony, arsenic, barium, chromium, copper, lead, nickel, tin and/or zinc in five of the final excavation boundary soil samples (BS21, BS25, BS56 & BS69). These sample locations were not removed during the excavation work and are situated along the north and northeast wall of the excavation.”

Part states the area along the North east wall contains Volatile Organic Compounds (VOCs). The Report does not make clear if they have to be removed.


.....these are organic chemicals that have a high vapor pressure at ordinary room temperature and are potentially dangerous to human health. Click the Link above for more details.

What does the Pinchin LeBlanc Report recommend?

Again, the recommendations are verbatim the Report.

“Based on the results of the work”, it states:

1.         It is recommended that a Risk Management Plan and Safe Work Procedure for on-Site workers be developed to limit exposure to on-Site personnel (i.e. construction workers). Remaining metals in soil at the north and northwest (“northeast” was the direction likely intended by the drafter) portion of the Site do not pose a risk to human health or environmental health provided that the operative exposure pathway (i.e. dermal contact) remains incomplete by maintaining suitable cover.” (Editor’s Note: this line should be understood to mean workers should “suit up” before coming in contact with the material. Underline added.)

2.         It is recommended that a Quantitative Risk Assessment (QRA) for the site to further assess the TCE and benzene exceedances identified in the soil. The critical exposure pathway, in this case, is the volatilization of these COCs to indoor air. Depending on the final results of the QRA, engineering controls such as soil venting or the installation of a sub-slap vapour extraction system may be needed to mitigate the risk to building occupants. (Editor’s Note: though remediation work was conducted below the new foundation, a sub-slap vapour extraction system has still been designed into the plans for the new school.)

3.         The extent of metals, benzene and TCE impacts identified in soil have not been fully delineated towards the residential properties located north of the Site. Further delineation is typically required in this case. However, since the Site and surrounding properties were reportedly used as a military landfill, it is unclear who would be required to complete the work. It is recommended that the Newfoundland Department of Environment and Conservation be advised of the results to determine a course of action.

"A recent analysis of available epidemiological studies reports trichloroethylene exposure to be associated with several types of cancers in humans, especially kidney, liver, cervix, and lymphatic system…."

Assessing and managing chemicals/Fact Sheet on Trichloroethylene (TCE)  

New Virginia Park Elementary School
As the third recommendation states, the area was a military landfill; that is to say it was a dump site for the American base at Pleasantville. While, possibly, residential and school construction went ahead at a time when there was a lot less knowledge of the environmental impacts of heavy metals and VOCs, we can no longer make that case.

When they are found on a school site, their potential harmful implications are sufficient to affirm the issue should not be left to the secrecy of a handful of bureaucrats.

Given the history of secrecy within TW (supported by officials in the Department of Education and NLESD) , the school council of VPES should look for some independent technical and scientific advice on how it might obtain certainty that the site is suitable, before construction proceeds.  

The public needs reliable information as to the full extent of the contamination, its health implications, how long it will take to make the site “clean”, and the estimated cost.

Proof needs to be shown that the site can be fully remediated at a cost that justifies keeping the school in its present location.  

Quite rightly, some would argue the dump ought to have stayed ‘green space’ or that, based upon environmental assessments conducted prior to the start of the new school, a decision ought to have been taken to relocate the dump in its entirety. (One confidential source suggests that approach might have been far less costly than the piecemeal way it is being dealt with now.)

If the Department of TW ignores those issues, it will not just earn the contempt of the public; the government will have set itself up, again, for very large additional costs. It will have learned nothing from the last financial debacle which occurred on this very site.

Finally, the full extent of the area requiring remediation is unknown. The volume of contaminated materials and the boundaries of the old dump are not fully understood, either.

The Government may have to extend soil testing and analysis beyond the school boundaries. 

The Departments of Environment and Conservation and TW have a public duty to commence additional studies to delineate the full area of the old dump site.

The Consultant recommends “soil venting”.  Parents should still be told why a sub slab ventilation system, which has been designed into the foundation of the new school, is actually necessary, given the remediation work that has been conducted below the foundation. (It is not as if schools, and most government buildings, have a history of diligent maintenance practices, either. The system proposed is not a passive, or maintenance-free system.) 

From several points of view, continued work on the new Virginia Park Elementary School demands an open and honest sharing of information.

In particular, the Department of Education and Early Childhood Development has an obligation to ensure that the school site contains zero doubts as to whether it is “fit for purpose”.

The reason government officials have been sitting on this Report, for nine months, is not apparent.

There have been far too many cover-ups involving the TW Department, the Department of Education, and NLESD.

The Uncle Gnarley Blog revealed the “cover-up” of the Roncalli concrete wall collapse and the “cover-up” of the structural deficiencies at Waterford Valley High School, too, on which more information is forthcoming.

Then, this Blog uncovered a breakdown in oversight of the remediation work on this very site.

Construction on this new elementary school has already cost over $7 million. ; That sum is supposed to get a lot more than the stage of completion evident in the photo above. In case you did not read that Post, the first Tender was awarded in the amount of $2.95 million (for the foundation, structural steel, and removal of contaminated soil). But the Government received a bill for $7.8 million – which, for reasons undisclosed got negotiated down to $4.8 million. (Perhaps the new Minister of TW will also be able to explain how the other $3 million was paid.)

What are we to make of this latest example of "cover-up"? What are those officials not getting, I wonder? 

It will be interesting to know if this issue was found in the briefing notes of the three Ministries where this Report is being discussed. 

If the new Government is serious about transparency, it will advise those officials of the commitments contained in the Premier's mandate letters. In particular, the Ministers of TW and Education will inform them the time for the hand-wringing is over!

Today, the three relevant Ministers and the Premier will be sent a Link to this Post. After today, none of those authorities can say they weren't informed.

To those whose concern is that this disclosure may slow down the completion of a long anticipated project, I would simply say: no public issue deserves a place in the corridors of secrecy, especially not one as important as public safety around a school.