Risk Analysis

CSC Environment and SDS Programs are fundamentally composed of two main portfolios: Environmental Compliance and Environmental Performance.  Both environmental portfolios fall under the strategic corporate priority “Efficient and effective management practices that reflect values-based leadership”.

Environmental Compliance

The Environmental Compliance portfolio relates to aspects that are federally legislated and where the most significant risk level is situated.  Risk level is evaluated based on the likelihood of non-compliance events and the potential environmental impacts associated with such events.  In order to assess the level of risk from an environmental compliance perspective, the following environmental acts/regulations that impact CSC's operations were considered:

• Canadian Environmental Protection Act, 1999 (CEPA)
  • Petroleum and Allied Petroleum Products Storage Tanks Regulations, 2008
  • Federal Halocarbon Regulations, 2003
• Canadian Environmental Assessment Act, 2012 (CEAA)
• Fisheries Act, 1985 (Section 36)
  • Wastewater Systems Effluent Regulations, 2012
• Species at Risk Act, 2002 (SARA)

It should be noted that the potential environmental impacts (and potential violations of the CEPA and/or the Fisheries Act) associated with the presence of contaminated sites, potentially contaminated areas or areas of environmental concerns on CSC sites, are risk managed separately, case by case, as per the approach established by the Federal Contaminated Site Action Plan (FCSAP).

Environmental Performance

The Environmental Performance portfolio relates to aspects that are not legislated and consequently, the risk level is typically less significant.  In CSC, environmental performance generally refers to SDS commitments/targets that mostly involve objectives in the area of energy efficiency (greenhouse gases reduction), water conservation and solid waste reduction.  Risk level is evaluated based on the likelihood of not meeting corporate commitments and the potential environmental impact associated with such results. 

The following chart evaluates the risk ranking for each environmental compliance and performance aspect, in terms of likelihood and impact.

Description of Environmental Impacts

Based on the above risk assessment, the impacts relating to the environmental compliance aspects (regulated issues) are typically more significant than those linked to environmental performance aspects (SDS commitments). In particular, the operation of petroleum storage tanks and wastewater treatment systems on CSC sites represent the highest level of risks in terms of likelihood (highly possible to certainty) and impacts (medium to significant). 

Depending on the volume and the type of product involved (diesel, heating oil, used oil, gasoline, ethanol 85), the environmental risks associated with leaks, spills or overflows from petroleum storage tanks can be significant in terms of potential negative impacts on surface or underground water bodies, soil, real property assets (land use) and infrastructures such as water/sewage distribution networks and wastewater treatment plants.  Accordingly, contamination incurred from uncontained hydrocarbon spills will generate most likely an environmental liability (contaminated site) that will need to be remediated or risk managed at one point in time.  In the worst case scenarios, petroleum products may directly contaminate a water source (lake, river, aquifer, etc.) that is used for drinking water purposes, or end up at a wastewater treatment plant and affect the biological processes involved which could result in the discharge of untreated sewage into water bodies (fish habitat).  However, the risk interactions between petroleum storage tanks and wastewater treatment facilities or water sources are overall relatively low, and even less when considering the mitigation strategies that are described below. 

Regarding the environmental impacts associated with the other regulated aspects (Halocarbons, CEAA, SARA), they are considered to be “negligible to low”.  Halocarbon releases are rated as “low” because today's halocarbons have little to no impact on the ozone layer (although these are considered greenhouse gases) compared to the previous and more potent chemical compounds that were used as refrigerants.  As for the physical repercussions linked with non adherence to CEAA and SARA, they are generally negligible given that CSC (often via PWGSC) conducts as required, Environmental Effect Evaluations (EEE) of its major construction/renovation projects which include provisions regarding Species at Risk.

As for the ecological impacts relating to the environmental performance aspects (SDS commitments), typically these are significantly less impactful than those associated with compliance aspects.  Accordingly, the likelihood and potential environmental impacts of SDS aspects (energy efficiency, water conservation, solid waste reduction) range from “unlikely to occur” to “somewhat possible”, and in all cases, represent a low impact. 

The rationale behind this assessment is based on the risks attributed to environmental performance issues consist namely of the possibility of not meeting some corporate engagements (SDS targets) or not achieving these as per the committed timelines.  The reasons for under achievements in this area are usually because of insufficient resources (namely human), lack of available funding (competing priorities) and/or contingencies that were not forecasted.  

Consequently, in the worst case scenarios, the environmental impacts associated with performance issues, would translate into more solid waste being sent to landfills, or more water and/or energy being used, i.e. more greenhouse gases emitted.  Nevertheless, besides the budgetary consequences associated with inefficient use of utilities (energy, water, and waste diversion), these types of environmental impacts are typically linked to normal operating practices in an organization such as CSC.

Furthermore, given that CSC is not bound by the Federal Sustainable Development Act (FSDA) and the Federal Sustainable Development Strategy (FSDS), all of its SDS commitments/targets should be considered as “self-imposed” under a “volunteered approach”.  Consequently, the risk level for not meeting SDS commitments is evaluated as being not significant.

Controls to Mitigate Environmental Risks and Impacts

To manage and mitigate the environmental compliance risk aspects of its operations and facilities, CSC has published and enforced Guidelines and Internal Services Directives (ISDs) per regulated aspect under the CD 318 on Environmental Programs (2003).  The Environmental Policy documents currently in place are:

• ISD 318-4 – Environmental Management of Halocarbons
• Guidelines 318-6 – Management of Wastewater Treatment Systems^[1]
• ISD 318-8 – Environmental Management of Petroleum Storage Tank Systems
• ISD 318-11 – Federal Environmental Assessment of Projects

In addition, regular inspections, capital investments (upgrade/replacement projects), monitoring and internal compliance review activities (such as the Compliance & Operational Risk Report, i.e. CORR) are regularly conducted on site in an effort to constantly control and maintain the risk at an acceptable level.  These mitigation measures have been relatively efficient to alleviate direct ecological impacts associated with the environmental compliance aspects of CSC's operations.  However, there are still some challenges to be addressed regarding administrative issues (such as record keeping and preventive maintenance practices) linked to the environmental compliance aspects.

As for the risks interactions between petroleum storage tanks and wastewater treatment plants or water sources that may result in direct environmental repercussions (namely negative impacts on fish habitats or contamination of a water source) as well as violations of federal environmental Acts and Regulations (CEPA and Fisheries Act), specific risk factors have been included in the petroleum storage tank risk analysis template so that all storage tank emergency plans have appropriate measures and controls in place to mitigate any potential impacts.

To manage and mitigate the risks and impacts of the environmental performance aspects of its operations and facilities, CSC has published Environmental Guidelines and ISDs for its main performance aspects under the CD 318 on Environmental Programs (2003).  The Environmental Policy documents currently in place are:

• Guidelines 318-1 – Environmental Management System^[2]
• Guidelines 318-2 – Energy Measurement and Conservation^[3]
• Guidelines 318-3 – Environmental Emergency Plan
• ISD 318-7 – Environmental Management of Waste^[4]
• Guidelines 318-9 – Water Measurement and Conservation

Finally, in order to mitigate risks associated with the SDS, CSC conducts regular internal consultations to identify needs, plans for the required funding (based on a 3-year cycle) and schedules timelines for the implementation of approved environmental initiatives/projects.  Over the last decade, this process has proven to be efficient to reduce the risk of not meeting SDS commitments while enhancing the possibilities of achieving or surpassing CSC's environmental performance objectives in line with its strategic corporate priority “Efficient and effective management practices that reflect values-based leadership”.