HomeMy WebLinkAboutPD-104-99
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THE CORPORATION OF THEMUNICIP ALITY OF CLARlNGTON
REPORT
Meeting:
General Purpose and Administration Committee
File #-:J)fil
Res. ~:rLf1
Date:
Monday, September 20, 1999
Report #:
PD-I04-99
FILE #: PLN 33.5
By-law #
Subj ect:
APPLICATION FOR AMENDMENT TO PROVISIONAL CERTIFICATE
OF APPROVAL. NEWCASTLE RECYCLING LIMITED
PART LOT 12, CONCESSION 3, FORMER TOWNSHIP OF CLARKE
FILE NO.: PLN 33.5
Reconnnendations:
It is respectfully reconnnended that the General Purpose and Administration Connnittee
reconnnend to Council the following:
I. THAT Report PD-I 04-99 be received;
2. THAT the Ministry of the Environment Approvals Branch be advised of the following:
a) THAT the application submitted by Newcastle Recycling Limited to amend
Provisional Certificate of Approval # A390327 to permit the operation of a Waste
Disposal Site (Transfer) does not conform to the Clarington Official Plan or
Comprehensive Zoning By-law 84-63;
b) THAT the Municipality of Clarington objects to the processing of the application
submitted by Newcast1e Recycling Limited until such time as the issue of Official
Plan and Zoning By-law conformity has been resolved; and
c) THAT the Municipality ofC1arington reserves its decision regarding the need for a
hearing under Section 32, Part V of the Environmental Protection Act until such
time as the issue of Official Plan and Zoning By-law conformity has been resolved;
3. THAT the Ministry of the Environment Approvals Branch, the Region of Durham, all
interested parties listed in this report and any delegation be provided with a copy of Report
PD-I04-99 and be advised of Council's decision.
1. BACKGROUND
1.1 The Ministry of the Environment Approvals Branch has advised the Municipality of an
application submitted by Newcastle Recycling Limited to amend their existing Provisional
Certificate of Approval for their site located in Part Lot 12, Concession 3, former Township
623
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REPORT NO.: PD-I04-99
PAGE 2
of Clarke (4349 Concession Road 4). The Ministry has requested the Municipality's
comments with respect to the application.
1.2 The Ministry has also noted that municipalities or affected members of the public have the
right to request the Director of Approvals to hold a hearing with respect to any application
submitted under Part V of the Environmental Protection Act Any such request must be
accompanied by valid reasons and supporting technicaljustification.
1.3 The purpose of this report is to provide the Municipality's comments to the Ministry of the
Environment regarding the application submitted by Newcastle Recycling Limited. A copy
of the Ministry's letter and the application submitted by Newcastle Recycling Limited form
Attachment No. 1 to this report.
2. OVERVIEW OF APPLICATION
2.1 The existing Provisional Certificate of Approval #A390327 in effect for the Newcastle
Recycling site permits the operation of a Waste Disposal Site (Transfer) for the storage of
used tires. The Certificate was issued by the Ministry on November 18, 1993 under the
provisions of Part V of the Environmental Protection Act
2.2 The application recently submitted by Newcastle Recycling seeks to amend the Provisional
Certificate to permit "the use and operation of a waste disposal site with a total area of 10.1
ha, for the transfer of the following waste categories: non-hazardous solid municipal and
commercial waste, at a maximum rate of 250 tonnes per day with a maximum total storage
of250 tonnes at anyone time, to serve the Province of Ontario."
2.3 The application proposes to construct a 713 sq. m. transfer building with two truck loading
docks at the south end of the property. The waste would be dumped by incoming garbage
trucks on the floor of the building and either bulk loaded or compacted into 25-tonne trailers
for shipment to approved waste disposal sites. A maximum of 10 trailers would be filled in
624
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REPORT NO.: PD-I04-99
PAGE 3
a day. The facility would operate from Monday to Friday 7 am. to 6 p.m., and Saturday 7
a.m. to I p.m. (313 days per year).
2.4 The building would be constructed on a slab without any drains. Liquid created from the
compaction of the waste would be collected and directed to a sump where absorbent would
be used to absorb the liquid. The resulting solid waste would be returned to the waste
stream and transferred to an approved disposal site.
2.5 The application indicates September 1999 as the estimated start date for construction, and
November 1999 as the estimated start date for operation of the waste transfer station.
2.6 Newcastle Recycling apparently does not have operational contracts with approved disposal
sites for the waste to be transferred from their site. The company is seeking to have the
application approved, with the condition that the transfer station could not be used without
such contracts being in effect.
3. OFFICIAL PLAN AND ZONING BY-LAW CONFORMITY
3.1 Durham Regional Official Plan
The land on which the Newcastle Recycling operation is located is designated 'Major Open
Space' in the Regional Official Plan. A waste transfer station is not a permitted use in this
designation, but is permitted in the 'Employment Area' designation.
3.2 Clarington Official Plan
The subj ect site is designated 'Green Space' in the Clarington Official Plan, with the lands
associated with the Graham Creek valley designated 'Environmental Protection Area'. The
operation of a waste transfer station is not a permitted use in either designation.
Section 4.9.3 of the Plan states that waste transfer stations may be permitted in the General
Industrial designation in accordance with Section 11.6.5. However, Section 4.9.3 is subject
to Deferral No. 39 and is therefore not in effect at this time. Staff anticipate bringing
forward a proposed modification to the Official Plan to resolve Deferral 39 in the near
625
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REPORT NO.: PD-I04-99
PAGE 4
future. With or without Section 4.9.3 being in force, the proposed use would not conform
to the Official Plan.
3.3 Comprehensive Zoning By-law 84-63
The subject lands are zoned 'General Industrial Exception M2-5' by By-law 84-63 (see
Attachment No.2). The provisions of this zone permit the lands to only be used for a motor
vehicle wrecking yard. The By-law defines a motor vehicle wrecking yard as "an
establishment where scrap motor vehicles are stored and/or dismantled and where used
motor vehicle parts are sold. Limited sales of road worthy vehicles are considered accessory
to the operation of a Motor Vehicle Wrecking Yard."
3.4 Based on the above, the proposed establishment of a waste transfer station for municipal
and commercial waste on the Newcast1e Recycling lands does not conform to the Durham
Regional Official Plan, the Clarington Official Plan, or Comprehensive Zoning By-law 84-
63.
4. RELATED MATTERS
4.1 Staffreview of aerial photography for the Newcastle Recycling site in 1998 revealed that
the operation had expanded to the west onto lands zoned 'A- Agricultura1'. This matter was
brought to the attention of Newcastle Recycling in July 1998 with a request to submit a
zoning application to bring this situation into compliance. By letter dated August 16, 1999,
Staff advised Newcastle Recycling that a rezoning application to permit the expanded
operation should be submitted by September 30, 1999. Newcast1e Recycling was further
advised that if an application is not received by this date, the use of the lands zoned 'A" for
all uses other than those permitted by By-law 84-63 should cease.
Staff note that, as of the writing of this report, Newcastle Recycling has not submitted a
rezoning application.
626
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REPORT NO.: PD-I04-99
PAGE 5
4.2 In addition to the Official Plan Amendments and the rezoning applications, the proposed
use for a waste transfer station requires site plan approval.
s. CONCLUSION
5.1 As noted above, the application submitted by Newcastle Recycling to permit the operation
of a transfer station for municipal and commercial waste does not comply with the
provisions of the Regional Official Plan, the Clarington Official Plan, or Comprehensive
Zoning By-law 84-63. Accordingly, it is recommended that the Ministry of the
Environment be advised that, until such time as the issue of Official Plan and Zoning By-
law conformity has been satisfactorily resolved, the Municipality objects to the processing
of the application. In addition, the Municipality should reserve making a decision on the
need for a hearing under Part V of the Environmental Protection Act, since additional
information would be required for the evaluation of the planning applications. Furthermore,
Public Meetings would be held for the necessary planning applications.
Respectfully submitted,
Reviewed by,
o~-~
Franklin Wu, M.C.I.P., R.P.P.
Chief Administrative Officer.
David . rome, M.C.I.P., R.P.P.
Director of Planning & Development
JAS*DC*df
9 September 1999
Attachment No. 1 - Application submitted by Newcastle Recycling to Ministry of the Environment
Attachment No.2 - Key Map
627
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Ontario
Mlntstryoi
Envlrorment
and Energy
Application for Approval
of a Waste Disposal SIte
c. Jormutatr. eat dlsponlble en tr.n~l.
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Application Number(.) CIlont Number Payment Rece_ Date ,-
3~ 0 -:,;l 7 $ ~/ CjD 0'00 ~.x. ~
Inforrnatioo roquen,d by Ill.. form is collectod un<Iot the -.arily 01 the Envin>I",_. Protection Act. RS D. 1990 (EPA), CMpter E-la, (EPA)
ond lI10 Env~'" Bill of Right.. c.28. StaMoo 01 Ontario. 18113. (EBR) _ wtI bo uoed I<> ev_ appI;cotiona tor __ 01 W_ cIiopooa!
silos llCCO(dlng 10 Ihe roquiroments of Ill. EPA. Q.-tiona ohould bo dIrec1Iod I<> the ApprOYalo Br"""". 250 DllViovilo Avenue, 3<d F1oo<,
Toronto, 0_. 1.445 1 H2. ToIephono No. {4161440-3713 or l-lI()()-ClI1~, or to you' IocoJ MIilIs1ry of Environment and Erwgy DIsIric1 0tIIce.
Instructions
~ When completing Ill.. form. pi...... rele< 10 Ihe '~'ForApplyingIorApprOY1ll 01 Waolo OIspoooJ Sileo. '. Sections 27. 30. 31 and 32. EPA
I (referred 1<>..1he Guido).
I 2. This form must be compIei.od with r06pect to ale 1he requirements of the Guide In order for it Ie be ~idofed as an appMcation for 8ppfoval.
I _INCOMPLETE APPLICATIONS WILL BE RETURNED TO THE APPLICANT OR DENIED APPROVAL.
,
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3. A complete oppIicolion for _oval oonoista 01;
(') 0 oompIetIod and signed O!'I"'eollon form;
(2) all oupportio<,j informotion .. 'oqueolod by this form ond by "'" ~; ond
(3) 0 oer1Ifiod cheque or money orde< tor... __ 1M, M .."" _,
Tho Ministry may require ~ ~ ,100.......... foIcNMg . rWYtew of ht oornpM6 ~eIion.
.. Two (2) oopi.. 0I1he oppIJcallon togeth<< with tho "'-'!>I>Cring InIonndon muo1 bo oubmitlod I<> 1he Ministry of Envifonmen1 one! Erwgy.
One copy 10: Oiroctor 01 Approvals _. Ministry 01 En\,~~.,_. ond Energy,
250 Oovi.vitIo Avonuo. 3<d Floor, Tor"'*'. 0nWl0. M4S 1 H2
OR
Roglonol [);,eclor In the region In wNch 1he silo is IooUod/wiII bo Iocolod
A duplJcalo oopy mus1 bo -.t I<> 1he Dio1rict Otfioo hovIng jurisdk:tion ov<< lhe or.. WI which Ihe works w~1 bo Iocalod.
5. 1_ _ In this oppIIcollon 10 no< oonoldored conlIdentIaI and will bo __ _ I<> lhe public upon ,oquoot. CorIaIn
informotion slJbmitlod .. supporting Inforrnatioo may bo cloKnod .. confidontIaI 001 will bo subject I<> Ihe Fr&8dom ot J~, _ p_
ot PrWecy Act (FOlPOPA) ond EBR. K you do no< doirn 001 ,lido. .liality ol1he limo 01 0<Jbmitting the inforrnatioo. 1he Ministry may moko ...
Informotion _I<> Ihe public: wi1hout fur1her naCIco I<> you.
1. APPlICANT
Name (<<tt6c:h proof of I'WnlI . ~,. '-J_)
Newcastle Recycling Limited
Add_ (WlCludo .treel....-. concaoion.1ot etc.)
R.R.#1
LOB 1 MO
City I Proviflce
Orono, Ontario
Postal Code
I T.do,A__NumI>er
(905) 786 -2046
Oporllllor ~ v.. 0 No
"-r-lo. attach name, .:kIress and cona.nenoe of the appropriate
Oporllllor.
Fox Number
(905) 786 - 2761
Owner 01 Land l2S v.. 0 No
L~~:~ODoch_=~~'" .,.;~'~ olthe _~to owner
2, CONTACT FOR TECHNICAL AHD DESIGN INFORMATION
Nome I TI1lo
Gord Miller, Miller Environmental Services Inc.
jCiiYl Province
26 Riddle Court _ r -------_____L Nort~ Bay, Ontano
Postal Code I Telephone Number I Fax Number
P1B 8S6 . (705) 840 - 6653 (705) 840 - 6673
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Address
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ATTACHMENT NO.1
@ Ontario
Ministry of the Environment
Environmental Assessment and
Approvals Branch
250 Davisville Avenue
3'd Floor
Toronto ON M4S 1H2
MinistGte de I'i:nvironnement
Direction des evaluations
environnementales et des autorisations
250. avenue Oavisville
3- etage
Toronto ON M4S 1H2
AUG 19 12 14 PH '99
(416)314-8320
(416)314-8452
Tel/Tel
T axlT elec
August 16, 1999
Clerk
Municipality of Clarington
40 Temperance Street
Bowmanville, Ontario
LlC 3A6
RE: Newcastle Recycling Limited
Application for an Amendment to Provisional Certificate of Approval #A390327
::
The Approvals Branch Office of the Ministry of the Environment has received an application from the
above company for an amendment to Provisional Certificate of Approval for a Waste Disposal Site
(Transfer) located at Lot 12, Concession 3, Municipality of Clarington, Ontario. The attached
application provides details as to the nature of the operation to be carried out at the site.
It is requested that the Works Department make comments with respect to the application. In lieu of a
Council Resolution, please ensure the report is signed and dated by the Commissioner of Works or
equivalent. Please write directly to Geoff Carpentier, Supervisor, Approvals Branch, Ministry of
Environment, ],d Floor, 250 Davisville, Toronto, Ontario, M4S 1H2 by September 19, 1999.
As you are aware, the Director has the discretion under Section 32, Part V of the Environmental
Protection Act (EPA) to hold a public hearing regarding applications for waste disposal facilities.
Municipalities or affected members of the public have the right to request that the Director consider
calling a hearing with respect to any application submitted under Part V of the EP A. Any submissions
in this regard must be accompanied by valid reasons and supporting technical justification. Please refer
to file number A390327 in all related correspondence.
Should you have any questions, please contact Ellen R. Reed at (416) 314-8320
Yours tml y ,
~ \<mc\
Ellen R.Reed
Senior Approvals Officer
Approvals Branch
cc: D. Beach, District Manager, York-Durham District Office
Attachments
Ot.1
, J. Z:tl ~ I:. !-U~A I toN (CO,f}~~lon. Lol.., Munlclp.llty)
Lot 12, Concession 3, Municipality of Clarington (fromerly town of Newcastle),
Regional Municipality of Durham
I~ the propo:sed waste site located in an area. of development control as defined by the Nlagar9. E.scsrprntmt Pf8.fln/ng 8.fld DBYf1Iopment Act (NEPDA)?
o Y8$ [Xl No \11 Yes, attach copy 01 NEPDA permrt)
4. FACILITY DESCRIPTION - 8ri,!!~scri~~ .)I__~_~atura ~_~U3lnc3S ~ ~y1ty reH8ted to this :site
; (a) PrD6entland use (b) Present Oft'iClal plan de:si9natJon
, YY<3_s~e.9isposal Sit~ \ Transfer) Major open space
i (c) Present zoning category
M2 - General Industrial
. --c;>"_LdJ '::0-== '=:'0'. of all adJO.niOlJ eropertJes to be providod on .
~ (e) Maximum rate at which s;u, can receive wute per day
I' .. . .
Mun~pa1
250 IX]
o
COO"lmardaJ
tonr_
o
o
Proceued Organic Waste
tonn..
[J Litres
cu: metres
cu. metres
11 any of the following waste .cstegoties ate intended to be received at the site, attach a description of each, including Ihetr soorce, to the
!\wllcaton.
Type 01 Waste
Tonnes
Cu. Metres
..-------
Utres
Liquid InduWjaJ
Non-hazardou5 Solid Indus1rial
Hazardous
Other
(q Days ond hours of operation
. Mon -fri 7arYL-g,RlIL.sQt7am-1 pm
I (h) Names of all munK:ipafiti03/major muslries to be servod by this s~~.
(ii) PoPulation served
N/A
L
L___.
I
2.
N/A
,
I 4.
6.
,
..
3.
Area to be Landfilled
--NlA
N/A
o hec1ar~.or 0 acre5
o hoc:tat.. or 0 acr..
Maximum e~t1mated site storage Cap8Crty or storage capacity (if i'"ltonded
lo..to'ago). 250
!Xl tonne~ 0 cu. metres 0 LitJes
(i) Total Area of Site
(j) Typo of lacilily/operollon
o landfill
X transfo,
o pr0C8SSltlQ
Ootho<. specify
(k) List all dispclGalsrtel9 and site Certificato Numbers (for final di5p06al)
1.
To be negociated
4.
2.
6.
3.
..
5. TYPE OF APPLICATION
!
LJ New Ceftificale 01 Appfoval
ex: ATll!Indment to a C;Jrrent Certificate of Approva.
Cwen! Cert,ficote Numbe' A390327
D.,. oll"u. Nov..J8, 1993
'6'1(11i\l"'1f'~:.!<lj",
,
U)i
.: PRO~ECTi~PUCAnciN DESCRIPTION _
EBR Abatr-.ct (Brt.! o...er\p1aon of tt... propos.aI)
The use and operation of a waste disposal site with a total area of 10.1 ha,
for the transfer of the following waste categories: non-hazardous solid
municipal and commercial waste, at a maximum rate of 250 tonnes per day
with a maximum total storage of 250 tonnes at anyone time, to serve the
Province of Ontario. for Q ten year period.
<:7
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7. EBR REQUIREMENTS
Is 111.. Pr..cribed Instrument undet EBR?
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[XJ V.., Ctass of Instrument? 2
0 y-
O El'TlWuency
0 EM or Tribunal Decision
o N.
IZI N.
o
o
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t1 . Pre5Cribed Insb'uffient, i$ !t eKoep1od hom public notific:.tion?
tf rt" axce.p1ed from EBR, provWde r...on
I
.. PUBUC CONSULTATION,1/0TIFlCATlON_
i
- -. ~__ __~---.J
Specify oJl pub4lc can,uIIodIan,/na1ifIcatian (such.. pub4ic mMling., na1lfic...... of Fnt Nllli..,. e1c.)
Vlat he beer! comptel&d or ill in 'fle process of Deing completed.
Equiv...ne Public
P oriciplllian
Environmentally
Insiclnfbnt
II1Mndment or
re\c "'1.
tf ex<<npt frOO1 publicl'lOtiftcation, docum."tatton in lupport 01 v... noWod .r~rplitl'll must be prov~.
Notice through news media
- ~-_._----
.. OTHER APPROVAlSJPERMrTS - List all odloc .nvironmeo1llJ app-ov..lpermi1a appti-u for r.'MId to flit pt'0feC1 or recerv.a und... .,. EPA
(diaeh"'gN to air, was. rnanag.m.tlt, sew. IYS""., e1c) and fl. Ontario Water AMourOM Act
(OW'RA) (wa1or works. permit 10 Ial<. w....., etc.).
N/A
1.. PROJECT SCHEDULE
!.E-.ti~ted D~~'~ Sf...... O'.Con3.uction
I September 1999
I E,tima-.d Date for- StIIr1 01 Operdon
. November 1999
..'J..'.....'..IoliI.}O.4
LJ)~
. ,-- -- .....-...... - - ,.... .........., I,U U30U 10 ft$t1mQte tile 11Ht Incll...dfJS all equipment and c:onstrucUon costs but does not include C':~_:::.i fOlland, IIIngillol!tef'_
. ,- . lnd'setVices and costs of fadlitles for whk:h the permit ot approval Is &ppled for under other Sections of the EPA or the b'wVRA fot
which appropriate fees have or will be pakt 'TI-Ie 1M shall not be less than $50.00 or more than $100.000.00. (For more infofrnation
refer to the GuMie)
,---
I (1) T'he fee payable upon $ubmis-sioo of an application under Sec:::tion 27 Of the EPA where Ihe applicabon ,ela.tc3 to a wate disposal site other than 8
lancffillingsiteis:
(oj 2% 01 "'" cost 0I1he equipment and construction r._ to the opplication, los,
(b) an amount equal to the proportion of tho wa&te that it reoeNed a1 the site and willie..... the slt8 for recydlng or rouse 10 the 1CtaJ amount of
w.... received at the silo, calculoted by weight '" by \'OIume, multipliod by 1110 omount l81errod to In cloUso (oj.
(e) whew. lIdditiotNd apprcv... ate required IJl"lder ether SedIons of the Act, separate feel; _. also required.
(2) For the purpose of clause 1 (8), roc:yclod or reused w._ does not incfude waste Intended to b& used as a dust suppressant or as . fuel or
intended to be disposed at at alandfilling site or incinoflltDr.
(3) Tho fee payoble upon opp''''~ under Sectlon 27 011110 EPA whoro 111. application r._ to alandfilllng OM is 4 corns per cubic metro 011110
cap.city 0I1he landfilljng silo.
-0
Estimated F.. ($50.00 minimum. 5100.000.00 maximum) 5
cheque '" Money Ordof A_ 0 Y., 0 No
'M>en an 'PP'- Is submiaed to Ihe Ministry lor _Ihe fee muo1 be In Iho form 01 a cer1itIod c:lleque '" money "'der payable to
"The 1.1_ 01 FInance".
DO NOT SEND CASH
12.SUPPORTlNQ INFORMATION CHECKLIST - This is a ist 01 "'upponIng InIormatlon _ '" 1hi, OW"ation ond Is ,utjec1 '" Iho FOIPOPA
ond EBR.
-,--
! ATTACHED?
INFORMATION
REFERENCE
-l
CAN BE
DISCLOSED
GENERAL
V",_ of Lego/ Name 01 AppIiaInt
Copy 01 NEPDA
0 v.. [ZJ No 0 v..
0 v.. ~ No 0 v..
__!'U
0 !XI No I 0 v..
v..
--
0 v.. []I '" 0 v..
Verification 01 EBA Pubic NollficalIoo, Exempllon
Proof 01 Public No1ificatIon C<lns_
; IXI v..
iO Yoo
Design & Operations Report i
- ~
!BUilding & Compaction Unit specsL
13. STATEMENT OF APPLICANT
/1. "'" ~~Igned he~- decloro -lhal . to Ihe bas1 01 my knowledge. Ihe information c:ontair1ed herem and Ihe ~formalion .ubm/11Iod In support of 111..
application is compl.... and occur'" In OV1Iry way and 1haI1he contact for lochnleal and design Information ,dentltled In item 2 of II1Is form IS
authoc'lZod to .a on my behalf for 1he purpose of obtaining IIpproval under Section 27 of the EPA for the waste dIsposal stte IdentHled herein
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Slgnotur. v ~. !Dato ~ / L;; 11ft--
OJ)
Attachment A
Attachment B
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A TT ACHMENT A
Desil!n and Operations Report
Site Description
The following information is in support to the attached application for amendment to
Certificate of Approval A390327.
A location map depicting adjacent land uses is shown in Figure I.
A scaled site plan is attached as Figure 2. The building would be located 120 feet from
the nearest property boundary to the west, and 13 0 feet from the nearest property
boundary to the east. An access road will be required to circle the facility, in order to
provide adequate access to transport trucks. The-municipal zoning of the property is M2
- (general industrial).
Operations
The site in question is currently operating under Certificate of Approval as a waste
transfer station. The proposed amendment would add non-hazardous solid municipal and
commercial waste as wastes being transferred. The maximum rate of transfer will be 250
tonnes per day with a maximum storage of250 tonnes at anyone time.
The solid wastes will be received in collection trucks (from approved waste management
systems) serving municipalities within the region. The waste wil be dumped on the floor
of the building and either bulk loaded or compacted into 25-tonne trailers for shipment to
approved waste disposal sites. A maximum of 10 trailers would be filled in a day. The
facility would operate from Monday to Saturday, from 7 am to 7 pm.
The operations would take place within a building (Attachment B). The building will be
constructed on a slab, without any drains. As the solid waste is compacted, any liquids
formed would be collected and directed to a sump. At this point, an absorbant will be
used to absorb the liquid, and the resulting solid returned to the solid waste stream and
transferred to an approved disposal site.
The proposed facility would be entirely contained, with no liquid wastes or drainage off
the property. There would be no liquids stored, transferred, drained, or treated at this
facility. There would be no storm water, run-off water, surface water, or groundwater
drainage.
The approval of this application without operational contracts with approved disposal
sites is proposed, with the condition that the transfer station cannot be used without such
contracts in effect.
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ROAD ALLOWANCE BE1WEEN CON. 3 & 4
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CONCESSION 3
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/ 120'
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Proposed
transfer
building
130'
200 feet
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Figure 2: Scaled site plan of subject property
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ATTACHMENT NO.2
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