Proposed Landfill Site

Proposed Landfill Site

The following is the complete text of the Letter from Chairman, Marcel Golec, addressing the concerns of the Friends of the Spanish River with regard to the new proposed Landfill site.

'Friends' Critical of Espanola Landfill Expansion

The Friends of the Spanish River is a not-for-profit environmental organization that evolved from the Public Advisory Committee for the Spanish River Remedial Action Plan (RAP). The group’s primary goal is to increase public education, awareness and appreciation of the Spanish River. The Friends are currently the primary public interest group overseeing the implementation of the Stage 2 recommendations for the RAP. Their primary project to date is a six-year re-stocking and assessment program of muskellunge at the mouth of the Spanish River. Total expenditures to date on this project have been $210,000.00.

The Friends have endorsed and adopted a watershed-based management strategy for the Spanish River. In that your proposed landfill is within the watershed, the following review comments have been prepared by an ad hoc sub-committee of the Friends of the Spanish River. The Group is neither for or against your project provided it has no off-property impacts and it meets or exceeds Provincial regulatory requirements.

The project, as we understand it, is to expand the current landfill so as to service the Districts of Algoma, Manitoulin and Sudbury, increasing annual tonnages from 20,000 tonnes to a maximum 50,000 tonnes. Approximately 70% of these wastes are to be C&D wastes, the balance MSW and ICI wastes. The total waste volume to be deposited at the site is 1,670,000 m³. The total area of the landfill is 119.6 ha.

The proposed landfill is a quasi-engineered (lined) natural attenuation design consisting of 3 cells for MSW coupled with general infilling with construction and demolition wastes to the west and south. Groundwater flow from the site is to two wetlands at the north end of the site. These wetlands form part of the Darkie Creek wetland continuum.

Given the proposed waste volumes to be disposed of at this expanded landfill, the site must comply with Ontario Regulation 239/98. That said, the document fails to meet the detailed requirements for the design, operation, closure and post-closure care of a municipal waste landfilling site. A partial list of these deficiencies, focusing on groundwater/surface water interactions and potential off-property impacts follows.

The wetland evaluation completed to date has only addressed the on-site wetlands. Although we agree these wetlands are not Provincially significant, the assessment does not address the Provincial significance of the Darkie Creek wetland or the potential impacts of the proposed project on this ecological continuum. In that this wetland is a public resource, Provincial Water Quality Objectives (PWQO), as well as the Province’s Groundwater Protection Policy, must be met at the property line. The use of the Darkie Creek wetland as part of the treatment wetland is unacceptable.

Per our earlier comments, the design would appear to be quasi-engineered, although no specifics are provided other than a liner will be provided under the fill area for the MSW. We fully expect the final design to meet or exceed Ontario Regulation 232/98 under Part V of the Environmental Protection Act.

This entire section is poorly written, lacks detail, contains no maps or cross-sections and is technically unacceptable. At best it is a hodge-podge of boreholes logs, and a mix of collated and simply copied laboratory sheets. The section fundamentally fails to address the hydrogeology of the site, including travel times and leachate attenuation mechanisms, including potential compliance with the Ministry’s Reasonable Use Guideline. It also fails to address and predict the volume of leachate that will be produced by the site, including contingency measures to control leachate in a quantity greater than expected or with a quality worse than expected.

This section is little more than a presentation of a) where the on-site sub-watersheds are and b) what the general quality of the drainage is and fundamentally fails to demonstrate that the surface water leaving the landfill property will meet PWQO. The design premise is simply that the on-site wetlands will attenuate the leachate from the site, which clearly reports to them, and thus PWQO will be met at the control point.

In summary, this environmental assessment document fails to prove that the leachate from this site can and will be managed on-site such that PWQO and groundwater protection guidelines are met at the property boundary. To that end, the report also fails to address the impact of these discharges on Darkie Creek nor does it adequately assess and score the potential Provincial significance of this wetland.

A copy of these review comments has been forwarded to the Ministry of the Environment as part of the public record for the application. Please ensure that we are circulated on what we hope to be a much improved environmental assessment report for the site.