Performance verification plans
A performance verification plan (PVP) is a stand-alone document that describes the principal risk controls necessary to ensure that risk-based standards under the Contaminated Sites Regulation (CSR) are met at a site. The PVP lays out the actions needed to ensure these risk controls are implemented and maintained.
An example of a risk control is a pavement cover placed over shallow contaminated soil to eliminate the risk to humans and animals coming into contact with that soil.
As a PVP supports the development and compliance with risk controls, it may be required for:
- Certificate of Compliance or Approval in Principle applications, either reviewed by the ministry or recommended by Approved Professionals
- Site reclassification from high risk to risk-managed high risk site under Protocol 12 Site Risk Classification, Reclassification and Reporting (PDF, 647KB)
- Contaminated Soil Relocation Agreements
- As a condition of a Site Release notice
The person responsible for the remediation of a site is also responsible for the implementation of the PVP. A PVP may be modified based upon application to, and at the discretion of, the ministry.
How to determine if a PVP is necessary
To determine whether a PVP is necessary, sites are classified into Type 1 or 2 based on the type of risk control needed to meet CSR risk-based standards.
- Type 1 sites generally do not require a PVP unless specified by the director
- Type 2 sites that implement institutional and/or engineering controls require a PVP
Site type descriptions with examples of risk controls are described below in Table 1.
|Site Type||Examples of Risk Controls|
Site meets risk-based standards under current and future standards without risk controls.
The site has institutional control for limiting the presence of future drinking water wells where the site is serviced by a treated municipal water supply.
The site has engineered control of a paved cap covering soil contamination in a municipal roadway or sidewalk.
No risk controls:
Site meets risk-based standards under current and future uses through use of institutional or engineered risk controls (apart from the risk controls noted in Site Type 1).
The ministry expects a PVP to include the following:
- The necessary risk controls with the rationale for their selection
- The actions required to implement, operate and monitor the identified risk controls
- Detailed specifications on any engineering work to be implemented
- A description of immediate risk of exposure to humans, the aquatic receiving environment and terrestrial non-human receptors to contaminants if there is a sudden failure of risk controls
- Schedules for inspection and maintenance of any operations or engineered works
- Contingency plans related to installed engineered works
- Notification instructions to the director if performance verification actions indicate that there is a failure of risk controls or contingency action is triggered
- Identification and contact information (address and email) of those responsible for the proper operation, maintenance and record-keeping of risk control performance
Records of risk control maintenance and monitoring activities performed on the site should include the following:
- Description of inspection and maintenance works
- Data from the monitoring of environmental media to confirm the efficacy of works
- Construction activities that may have occurred
- Any identified failures in risk control performance along with the measures to restore their efficiency
- Quantity and quality of soil or waste managed or disposed of as part of the engineered works
Records should be submitted to the ministry either upon request or on a scheduled basis as detailed in a Certificate of Compliance, an Approval in Principle or as required in other related documents.
PVPs are developed and signed by qualified professionals. Approved Professionals must review, recommend and/or sign PVPs as detailed in Protocol 6 Approved Professional Recommendations and Preapprovals (PDF, 406KB) and Protocol 12 Site Risk Classification, Reclassification and Reporting (PDF, 647KB).
Please refer to these protocols for more information. Qualified professionals who have contributed to the findings of the risk assessment or the implementation of risk controls should sign the PVP.
To ensure risks to human health and the environment are controlled, a qualified professional preparing and signing a PVP should include a declaration that they are suitably trained and educated and are certified by their professional organization. QPs should not practice beyond their area of expertise.
More information regarding the ministry’s professional reliance on qualified and Approved Professionals, the types of Approved Professionals and their roles can be found on the ministry's professional reliance webpage.