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HomeMy WebLinkAboutPD-115-94THE CORPORATION OF MUNICIPALITY OF L, REPORT Meeting: General Purpose and Administration Committee Cate: Monday, September 19, 1994 Report #: PD -115 -94-� ile #: PLN 17.4.1.1 1 LANDFILL RECLAMATION PROPOSAL Subject: LAIDLAW WASTE SYSTEMS (DURHAM) LTD. FILE: PLN 17.4.1.1 t ile #e >�, IP`� Res. # a R - 2 � -91 Cy -Lave # Heoornmenclailt ris:is respectfully recommended that the General Purpose and Administration Committee recommend to Council the following: 1. THAT Report PD- 115 -94 be received; 2. THAT the reports entitled "Review of Laidlaw's Proposal to Mine their Durham Landfill Site" and the "Review of Landfill Reclamation Projects ", as submitted by Gartner Lee Ltd. and attached to this Report as Attachment Nos. 1 and 2 respectively, be received; 3. THAT a copy of this Staff Report and Council's decision be forwarded to the Ministry of Environment and Energy; 4. THAT the Durham Region Planning Department, and all interested parties listed in this report and any delegation be advised of Council's decision. 1. BACKGROUND 1.1 On March 28, 1994, Council approved the recommendation of Staff Report PD -34 -94 to retain the consulting firm of Gartner Lee to provide technical assistance to the Municipality with respect to the proposal by Laidlaw Waste systems to undertake landfill reclamation at their existing landfill site northwest of Newtonville. Gartner Lee has now submitted their final reports, which form Attachment Nos. 1 and 2 to this Staff Report. 2. OVERVIEW OF GARTNER LEE REPORTS 2.1 As specified in the Terms of Reference, Garnter Lee's review focused on two primary areas: • a Peer Review of technical materials submitted by Laidlaw regarding their landfill reclamation proposal, in particular aPELa H C R nECVCi y{ 5 / 0 A THIS IS PRI DCN RECYCLED PAPER REPORT NO.: PD- 115 -94 PAGE 2 a technical report prepared by Henderson Paddon & Associates Limited (Attachment No. 1); • a review of other landfill mining projects in Canada and the United States (Attachment No. 1). 2.2 In the Peer Review, Gartner Lee made a number of observations and recommendations with respect to Laidlaw's current reclamation proposal for the south mound of their landfill. These observations and recommendations are summarized in Attachment No. 3 to this report. Of particular note is the continuing concern with the adequacy of the existing leachate management system at the site to properly treat not only the leachate currently collected, but also any new leachate which would be collected as a result of the reclamation operation. 2.3 The review of other landfill reclamation projects undertaken by Gartner Lee was intended to provide a basis for comparing the Laidlaw proposal with other such projects. The main points of comparison are summarized on the table which forms Attachment No. 4 to this report. In particular, it is noted that: • materials reclaimed from a number of the other landfill sites could not be recycled because of their dirt content; • recovered fines at other landfills are generally only used within the landfills, for example as daily cover. At the McDougall Township landfill, the recovered fines have been approved for use in sub -grade preparations, but have not been approved for use outside the landfill footprint. 2.4 The information presented in the Gartner Lee reports may be of assistance to the Ministry of Environment and Energy in their review of Laidlaw's application to reclaim the south mound of their landfill. As such, a copy of this staff report will be forwarded to the Ministry for their information. 599 rJ8 REPORT NO.: PD- 115 -94 PAGE 3 3. STATUS OF LAIDLAW'S APPLICATION 3.1 Laidlaw's application to reclaim the south mound was submitted to the Ministry of Environment and Energy in February 1994. Laidlaw has requested the Ministry to approve the operation as a pilot project which would exempt the reclamation project from the requirements of the Environment Assessment Act and from a hearing before the Environmental Assessment Board. 3.2 The Ministry advised Staff earlier this year that they had initiated a review of the necessary procedures for landfill reclamation projects, and that Laidlaw's application would not be considered until such time as a Ministry policy had been developed. The Ministry recently advised that their review of procedures is nearing completion. Staff have requested that a copy of the Ministry's policy be forwarded to the Municipality once approved. 3.3 On December 13, 1994, Council adopted a resolution advising the Ministry of Environment and Energy of the Municipality's concern with Laidlaw's reclamation proposal, and requesting that the Municipality be fully consulted on this matter. 3.4 On March 28, 1994, Council considered Report PD -43 -94 in respect of Laidlaw's reclamation proposal, and adopted a resolution advising Laidlaw that a Rezoning Application to permit the proposed landfill reclamation project was required. The resolution also advised the Ministry that the Municipality requests a hearing before the Environmental Assessment Board in respect of Laidlaw's proposal. Staff note that, to date, Laidlaw has not submitted a rezoning application in respect of the proposed reclamation project. 599 (J9 REPORT NO.: PD- 115 -94 PAGE 4 Respectfully submitted, l Franklin Wu, M.C.I.P. Director of Planning and Development Reviewed by, cr `• W.H. Stockwell Chief Administrative Officer JAS *DC *FW *df 12 September 1994 Attachment No. 1 - Gartner Lee Report on Laidlaw Landfill Mining Proposals Attachment No. 2 - Gartner Lee Report on Landfill Mining Attachment No. 3 - Summary of Peer Review Attachment No. 4 - Summary of Review of Landfill Reclamation Interested parties to be notified of Council and Committee's decision: Mr. A. Dominski Waste Sites and Systems Approvals Ministry of Environment and Energy 250 Davisville Avenue, 3rd Floor Toronto, Ontario. M4S 1 H2 Mr. Normund Berzins Committee of Clarke Constituents P.O. Box 20028 Newcastle, Ontario. L1 B 1M3 Mr. Michael Walters Laidlaw Waste Systems Ltd. 3410 South Service Road P.O. Box 5057, Station A Burlington, Ontario. L7R 3Y8 599 10 140 Renfrew Drive, Suite 102, Markham, Ontario L3R 663 Fax (905) 477 -1456 (905) 477 -8400 Consultants Ei n I h e ' nvironment Expertise Environmental Planning Ecological Science Geosclence Engineering Services Planning implementation Monitoring Remediotion 1979.1993 Y E A R S O F E %C E LL EN CE 11r], Attachment No. May 6, 1994 Municipality of Clafington 40 Temperance Street Bowmanville, Ontario L1C 3A6 Attention: Ms. Janice Szwarz Senior Planner Dear Ms. Szwarz: Re: Review of Laidlaw's Proposal to Mine their Durham Landfill Site GLL 94 -155 We have completed our review of the November 1993 Henderson, Paddon and Associates Limited report entitled " Laidlaw Waste Systems (Durham) Ltd., Design Brief for Landfill Reclamation Operation, Laidlaw Durham Landfill ". This report describes Laidlaw's proposal to mine their Durham Landfill Site. , Our comments deal with approvals considerations followed by technical issues on a chapter by chapter basis. Approvals We talked with Mr. Paul Nieweglowski of the Approvals Branch at the Ministry of Environment and Energy (MOEE) who indicated that there are presently no policies, guidelines or regulations specific to the approval or operation of landfill mining in Ontario. Chapter 2 states the objectives of the mining proposal to be: — "improve protection of both the groundwater and surface water by constructing a lined cell with a leachate collection system within the mined area ", — "recover and recycle scrap metal and white goods from excavated waste ", — "remove and disposal of potential hazardous waste, if present "; and — "reuse the reclaimed air space ". Chapter 3 states the groundwater at the site complies with the Ministry of Environment and Energy Reasonable Use Guidelines and the site has not measurable impact on water, quality of the Graham Creek ". If this is the case, then it would appear that the primary purpose of the proposal is not to improve protection of the ground or surface water, but to create additional landfill space through "mining" rather than expansion of the site's footprint or height. This additional space would be filled with new waste brought to the site. Under present MOEE approval practices, an expansion of this magnitude usually requires an Environmental Protection Act (EPA) Part V approval, more detailed studies in support of the proposals then provided by the Henderson, Paddon report and an EPA hearing. As well, the MOEE could designate this application under the Environmental Approvals Act (EAA). 599 Page 2 Municipality of Clarington May 6, 1994 Chapter 2 — Landfill Mining'Operations Our comments on this Chapter relate to the subsections on Health and Safety, Odours and Dust. Comments on the management of ground and surface water are included in our discussion of Chapter 5. Health and Safety When digging into any old landfill there is uncertainty about the types of wastes and health hazards that will be encountered. Therefore, detailed plans for protection of the Health and Safety of both workers and the public are needed. A detailed Health and Safety plan is not provided in the report. On page 2 -6 the report states that a "detailed list of health and safety procedures will be prepared before the start of operation." We recommend that this plan be prepared as part of the approval process so that it may be reviewed by all interested parties. One of the potentially significant health risks posed by landfill mining may come from the release of landfill gases, particularly if these gases contain harmful components. For example, benzene, vinylchoride and chlorinated ethanes are three common constituents of landfill gas that could present a health risk. Therefore, we recommend that the composition of the landfill gases at the site be determined before mining begins, so that the appropriate air monitoring program can be developed and the appropriate level of respiratory protection selected for the workers. Also, the potential for landfill gases to cause off —site air quality impacts should be assessed. If air monitoring in the working area detects elevated levels of potentially harmful compounds, then additional monitoring at the site perimeters should be undertaken to determine if air —borne contaminants are leaving the site at potentially harmful levels to the public at large. Odours Landfill wastes can release odours that may not pose a health risk but can be objectionable to smell. On page 2 -7 the report says that application of a natural organic odour neutralizer such as 'Ecosorb' may be utilized to fog working faces or piles as required ". The need for odour control from the trommel operation and from the spreading of the recovered fines should also be addressed. The need for odour control is very subjective since it varies with weather conditions and some people are more sensitive to odours than others. An approach should be developed in conjunction with the site's neighbours to determine when odour control is needed. Dust Page 2 -9 of the report only discusses dust control for the on —site roads. Dust will be created by the landfill mining operation itself from such activities as stripping of the cover and sorting of waste. Also, dust will come from placement of the fines in the borrow pit area. Dust control procedures for these areas and activities should be developed. This paper is made from recycled fibre 599 12 (94155) Page 3 Municipality of Clarington May 6, 1994 Chapter 3 — Lined Cell After mining, it is proposed that the south landfill will be lined and a leachate collection system installed before replacing the wastes. Liner Gundseal is proposed as the liner material. We have concerns about the adequacy of this material as the sole liner material. Gundseal is comprised of a thin (0.5 mm or 20 mil) high density polyethylene plastic coated with a thin layer (about 5 mm) of sodium bentonite clay. This material has only been available for landfill related uses for a few years and therefore has little proven performance experience. The plastic (at 20 mil) is much thinner than the 80 mil typically used for landfill liners and therefore may be more susceptible to puncturing and other damage during installation. As well, the joints between sheets are not welded together as they would be in a conventional plastic liner. Instead the sheets are overlapped like shingles. The intent is that the clay bagking will seal the joint. However, this may not occur if the sheets buckle due to expansion and contraction of the plastic in varying heat conditions during installation or due to the differential stresses applied by the waste and waste moving equipment during the placement of the first lifts of reclaimed waste. In addition, the sheets may slip apart on the side slopes of the landfill. In addition, while the bentonite clay has a reportedly very low permeability its ability to act as an adequate barrier against leachate leakage through holes in the overlying plastic depends on its thickness and its ability to expand when wetted (which determines its permeability). The clay layer is very thin (only about 5 mm) and therefore does not present much of a thickness against contaminant migration compared to conventional clay liners which are typically 1.5 in thick. As well, such a thin bentonite layer may be susceptible to damage (e.g. some of the bentonite being rubbed off during placement or a puncture of the plastic extending right through the bentonite layer). Less expansion or swelling occurs in these type of clays when they are wetted with leachate compared to pure water. This can give the clay a higher permeability than its technical specifications. The effect of the sites' leachate on the bentonite coating should be assessed. For these reasons, Gundseal would not normally be used as the only liner in a landfill. The documentation provided by Gundle Lining Systems Inc. for the Gundseal product says: " Gundseal is a bentonite clay /polyethylene composite liner for one step deployment (usually as an addition to a conventional single or double liner system)." Leachate Collection System It is unclear from the description of the leachate collection system on page 3 -2 whether it is proposed t to wrap the perforated pipes in geotextile. We would not recommend this because the geotextile will be quickly clogged by biological fouling which will prevent leachate from getting into the collection pipe. 599 1 - (94155) This paper is made from recycled fibre Page 4 Municipality of Clarington May 6, 1994 Chanter 4 — End Use of Recovered Fines "Recovered fines" are mainly the soil materials recovered from the waste during landfill mining operations. This soil was used in the landfill for daily cover and final cover. The economic feasibility of this mining proposal depends upon being able to dispose of most of the recovered Imes outside of the landfill footprint. Less material is then returned to the landfill, leaving landfill space within the original footprint and contour limits. This new space can then be filled with new waste, generating the revenue to pay for the mining operation. The proposal at the Durham site is to use the recovered fines to fill the borrow pit south of the landfill. Based on testing done by Henderson, Paddon and Associates Ltd. on the recovered fines from the McDougall Landfill in Muskoka, it is assumed that the recovered fines from the Durham site will meet the compost guidelines and /or proposed urban industrial fill guidelines and therefore be acceptable for placement in this area without causing environmental effects or requiring approval as an additional waste area. Consequently, confirmation of the quality of the recovered fines at this site is also critical to determining both the environmental approvals requirements and assessing the potential environmental impacts of this proposal. The conclusions about the quality of the recovered fines is based on data from other sites. No data specific to the fines in the Durham landfill are presented. Since the waste materials and types and levels of contaminants can vary from one landfill to another, we recommend that field studies be conducted at the Durham site, prior to approval, to determine the quality of the fines that will be recovered. The sampling program carried out throughout the landfill mining operations to test the quality of the recovered fines will also be very important. The program proposed by Henderson, Paddon and Associates Ltd. is to sample and test the materials once per week for the parameters listed in the compost guidelines and once every fifth sample (once every five weeks) for the more extensive list of parameters listed in the MOEE's Proposed Policy for Management of Excess Soil, Rock and Like Materials (henceforth called the proposed Excess Soil Policy). We do not feel that this is an adequate sampling program. A December 7, 1993 handout from Laidlaw entitled Durham Landfill Reclamation Project" states that about 2,200 m' of the landfill will be reclaimed per day. At this rate the total landfill volume of 192,000 m' would be mined in about 3 months. Page 5 -3 indicates mining may extend over 6 months. Therefore, at one sample per week there would only be 12 to 24 samples collected for compost analysis and only 3 to 6 samples for the more extensive parameter list. This small number of samples is not adequate to characterize the expected 96,000 m' of recovered fines (i.e., 50% of total landfill volume). 599 1 4 (94155) This paper is made from recycled fibre Page 5 Municipality of Clarington May 6, 1994 A program similar to that outlined in the MOEE's proposed Excess Soil Policy is recommended. This program is as follows: — one sample collected for analysis from every 10 m4 of material for the first 100 m3; — one sample collected for analysis from every 100 m' of material for the next 900 mom; — one sample collected for analysis from every 500 m- of material from then on; and — each sample should be a composite collected over time so that it is considered representative of the entire volume of material. Under such a program about 200 samples would be collected for testing to represent the approximately 96,000 m' of Imes expected to be recovered. It is also recommended that all samples be tested for the more extensive list of parameters in the MOEE's proposed Excess Soil Policy. The compost guideline parameters are not extensive enough to test for many of the contaminants that might be expected in a landfill, particularly organics such as benzenes, xylenes, toluenes and chlorinated ethanes which are known to be present in the leachate at this site. In addition, bacteria should be included in the analyses since historically this landfill has probably received wastes that contain human and animal waste as well as pathogenic wastes from hospitals and medical clinics. The approach proposed in the report is to take the recovered fines directly to the borrow pit as recovered. We recommend that the recovered fines should be stockpiled until the test results from each batch are known. This way material of unacceptable quality does not get placed in the borrow pit. It is also recommended that the potential for the recovered fines to leach contaminants into the ground water and surface runoff in the borrow pit be determined. To a certain extent the potential f6r contaminated fill to leach contaminants is addressed by the guidelines in the proposed Excess Soil Policy (i.e., it is assumed that compliance with the guidelines will not result in contaminants leaching from the materials at concentrations of concern). However, it is our understanding that despite meeting the compost guidelines and the proposed urban industrial fill guidelines, the recovered fines from the McDougall site still produced a contaminated leachate with an elevated Biological Oxygen Demand. Iron might also be another potentially leachable contaminant because the combination of naturally high iron in the soils used for daily cover on the landfill and the anaerobic conditions of the landfill increases the solubility of the iron. A ground water and surface water monitoring program should be established for the borrow pit area to assess whether the recovered fines placed in this area are having any environmental impact. No such program is included or recommended in the Henderson, Paddon and Associates Ltd. report. 599 15 (94155) This paper is made from recycled fibre Page 6 Municipality of Clarington May 6, 1994 On page 2 -2 of the report it also states that some of the recovered fines may be used for subgrade preparations. If it is proposed to use this material under the landfill liner then its geotechnical suitability for such a use should be confirmed. As well, the potential for contaminants to leach from the recovered fines would also be an issue here since this material will be below the liner. Chapter 5 — Leachate Management When the landfill mining operation extends below the water table it is proposed that the leachate will be pumped to the Rapid Infiltration Basins. The report provides estimates of the amount of leachate expected to be pumped to assess whether this will significantly increase the amount of leachate going to the basins compared to present conditions. The report assumes that the amount of leachate to be pumped from the excavation will only be that contained in the pore spaces of the saturated waste. It does not account for additional ground water that will flow into the excavation from the surrounding soils. Given the sandy nature of the soils this volume could be significant and should be estimated. We do not consider the Rapid Infiltration Basins to be an adequate approach to leachate management at this site, for either the present leachate collection volumes,' the leachate captured during landfill mining operations and the leachate that will be captured by the collection system after lining and re- filling. The Rapid Infiltration Basins will eventually cause a bathtub effect where the level of the water table will increase until the system "overflows ". This will occur because all leachate presently pumped to the Rapid Infiltration Basins is recaptured by the extension of the low level collector and pumped back to the basins. This is then being added to new, additional amounts of leachate coming from the remainder of the site's collection system. This concern was also identified by Acres International Ltd. in their 1993 review of the site. They had available to them the April 1992 water level data (after installation of the low level collector extension) and compared it to the November 1991'data (before installation of the low level collector extension). They found that the water table between the Rapid Infiltration Basins and the low level collector extension had increased significantly except in the immediate vicinity of the influence of the low level collector drain. This is illustrated on the attached Figure from Acres review report. The increased water table levels will result in bypass of the low level collector extension. This may occur by a change in ground water flow directions so that some water flows around the end of the collector or it may result in more ground water moving downward and under the collector. Seepage at surface followed by overland flow may also occur. If the water table rises into the base of the Rapid Infiltration Basins it will also effect the capacity of the basins and the rate of infiltration. Ground water bypassing the low level collector will contain elevated levels of some contaminants which will discharge to Graham Creek. Presently leachate undergoes some renovation in the ground water system between the Rapid Infiltration Basins and the low level collector. This is reportedly due to biodegradation of the organic fraction, adsorption and dilution. However, not all contaminants are reduced to acceptable levels. For example, prior to installation of the low level collector extension, This paper is made from recycled fibre 599 16 (94155) Page 7 Municipality of Clarington May 6, 1994 iron concentrations within about 15 m of the creek were about 5 ppm which is about 17 times higher than the Provincial Water Quality Objective of 0.3 ppm. Also, the capacity of the sandy soils and ground water downgradient of the basins to continue to achieve the present reductions in the future is unknown. We recommend that an alternative leachate management plan be developed for this site. Should you have any questions about our review comments please do not hesitate to call me. Yours very truly, GARTNER LEE LIMITED Glenn W. Reynolds, M.Sc Principal GWR:mm cc: Mr. Bruce Bennett, Gartner Lee Inc. (94155) This paper is made from 599 1 I ry recycled fibre C Gartner Lee 140 Renfrew Drive, Suite 102, Markham, Ontario L3R 6B3 Fax (905) 477 -1456 (905) 477 -8400 Consultants Er < the ' nvironment May 27, 1994 Municipality of Clarington 40 Temperance Street Bowmanville, Ontario L1C 3A6 Attention: Ms. Janice Szwarz Senior Planner Dear Ms. Szwarz: GLL 94-155 „•..,,. i ,r C r,hNOTON Re: Review of Landfill Mining Projects in the U.S.A. and Ontario Attached is a brief review of landfill mining projects ongoing in the U.S.A. and Ontario. La- idfill mir -ig is also commonly referred'to as landfill reclamation. in preparing this review we relied on published information only and therefore may not have identified all of the landfill mining projects. Nor have we been able to collect detailed information on all of the projects. A list of the articles and reports that we reviewed is appended. We have also discussed landfill mining with Mr. David Russell of Collier County, Florida; Mr. Chris Hyde of the Ministry of Environment and Energy (MOEE) in Barrie; and Mr. Paul Nieweglowski of MOEE Approvals Branch. Expertise In the U.S.A., we identified three active landfill mining projects. These are: Collier Environmental Planning County, Florida; Edinburg, New York; and Lancaster County, Pennsylvania. Two Ecological Science Geosclence additional sites may be active in Thompson, Connecticut and Barnstable, Massachusetts, Engineering but little information was available on these sites. We also identified four landfill mining projects in the planning stage. These are: Key West, Florida; Kingston, New Hampshire; Newbury, Massachusetts; and the State of Delaware. Services Planning In Ontario, there are presently four active landfill mining projects. These are: the Implementation McDougall Landfill near Parry Sound; the Flos North Landfill in Simcoe County; the Monitoring Remediafion Elmvale Landfill in Simcoe County; and the Essa Landfill in Simcoe County. We so identified four projects in the planning stages. These are: the Wasaga Beach Landfill in Simcoe County; the Notawasaga Landfill in Simcoe County; Laidlaw's Durham Landfill in Clarington; and the Barrie Landfill. More information on the active reclamation projects is attached. We hope this review meets your needs. Please give me a call if you have any questions. Yours very truly, GARTNER LEE LIMITED 1 1973-1993 Glenn W. Reynolds, Sc. Y E^ R S° F Senior Hydrogeologist E X C E L L E N C E Principal GWR:n m j Attach. 599 18 cc: Mr. Bruce Bennett, Gazfier Lee Inc. v This paper is made from recycled fibre Review of Landfill Mining Projects 599 19 Landfill Reclamation Projects in the U.S.A. This paper Is made from recycled fibre Collier County, Florida Collier County is in rural southwestern Florida. The landfill was opened in the mid 1970s and continues to receive waste today. The site is 300 acres with 165 acres licensed for waste disposal. Landfill mining began in 1988 and is one of the first landfill reclamation projects. Mining is still occurring. The two oldest cells are being mined over an area of about 26 acres. About 25% of these cells have been mined to date. Reasons for Mining In the early 1980s, the County had plans to build an energy from waste facility. At the time there was insufficient waste to supply the plant and wood chips were proposed as supplemental fuel. However, wood chips were costly. Therefore it was proposed to mine the landfill and use the decomposed waste in the old landfill as fuel instead of wood chips. Due to other financial reasons the energy from waste facility did not proceed. However, by this time the concept of landfill reclamation had progressed sufficiently to identify other benefits and therefore it continued. The main benefit was that much of the recovered material was sufficiently decomposed that it could be used for daily cover material in the operational portion of the landfill at'a significant cost saving. The mined material could be recovered for about half the cost of importing daily cover material, saving the County a few hundred thousand dollars a year. A secondary benefit was the opportunity to dig up the older, unlined portions of the landfill and line them, thus preventing future ground water contamination problems and clean—up costs. Mining Methodology The waste is mined using an excavator. It is sorted first through a grizzly screen to remove large objects like tires and white goods (i.e., fridges, stoves, etc.). It is then placed through a trommel screen to separate the fines (dirt and decomposed material) from the waste. The size of the trommel screen has varied over time from 3 inches originally to 0.5 to 1 inches presently. Originally, tires, ferrous metal, aluminum and plastic were also separated from the waste but this. is no longer carried out because a market has not been found for these materials. These materials were not recyclable because they contain large amounts of dirt and sand. Nature and Use of Reclaimed Materials About 65 to 80% of the mined material was recovered as fines useable for landfill daily cover. The remainder was disposed as waste in the operational (lined) portion of the landfill site. Such a large t (u0527gr/94155/94) This paper is made from 599 21 recycled fibre percentage (65 to 80 %) was recovered for daily cover for two reasons. One was because of the large trommel screen size originally used, which allowed a significant proportion of metal, glass, paper and plastic fragments to pass. The second was the well decomposed nature of the waste. Decomposition is enhanced at this site because of the warmer climate and large amount of rainfall (about five feet per year). The recovered fines can only be used for landfill cover. Other uses of the fines would require additional regulatory approval and an extensive testing program. Collier County has done only limited testing on the quality of the recovered fines because they do not have plans to use them for anything but landfill cover. Health and Safety and Environmental Issues Collier County is a rural, mostly tourist area, with very little industry. Therefore except for household hazardous wastes. and asbestos (in demolition debris), hazardous wastes were not expected nor encountered. Specific conditions were established for asbestos in the permit for the mining operation operations. All workers were trained in asbestos identification and random tests for asbestos were conducted twice monthly. If materials containing asbestos were encountered then mining operations were to cease until the materials were removed and disposed in the lined portion of the site. Combustible gas monitoring was conducted in the excavation. Occasional pockets of combustible gas were encountered but vented in a short time. No other air or vapour monitoring was conducted specific to the mining operation. Odours were not an issue because of the remote nature of the site and because of the well decomposed nature of the recovered waste. Dust also was not an issue because of the moist nature of the recovered materials and the remote nature of the site. Contaminated waters accumulating in the excavation were pumped out to a lined pond. The ultimate fate or treatment of this leachate was not noted in the literature reviewed. Excavation did not proceed below the water table. Future of Mining at the Collier County Landfill Mining will be discontinued in the near future at this site. This is because they are switching to a synthetic daily cover and will not need the cover material recovered from the landfill mining. The switch to daily cover is proposed to save landfill space. The six inches of soil cover presently required at the end of each day takes up a considerable amount of landfill space compared to. synthetic materials like plastic tarps placed over the waste nightly and then removed the next day. 2 (m0527gr/94155/94) 599 2-2 Town of Edinburg Landfill, New York The Town of Edinburg Landfill is in Saratoga County in east central New York State. The landfill was opened in 1969 and stopped receiving waste in 1991. The site covers 5 acres. Landfill mining was conducted in 1990 and 1991 as a demonstration project for the State of New York to assess the feasibility of landfill mining and to conduct a test burn on the combustible materials recovered. About 1 acre of the site (15,000 cubic yards) was mined. Reasons for Mining Landfill mining was conducted at this site solely for demonstration/pilot study purposes. The mining operation was funded by New York state, the U.S. Environmental Protection Agency and the Town of Edinburg. The Town berefitted by having their landfill reduced from 5 acres to 4 acres and thus reducing the costs of landfill closure. This reduction in size, however, required that most of the recovered fines not be returned to the landfill. The objectives of the demonstration project were; (1) to determine the best methodology for excavation and separation of the reclaimed materials; (2) to assess the health and safety aspects of landfill reclamation operations; (3) to determine whether reclaimed materials such as metals and tires could be recycled; (4) to determine potential end uses of the recovered fines materials outside of the landfill footprint; (5) to do a test burn of the reclaimed wastes to determine if they could be used to fuel an energy from waste incinerator. Mining Methodology The waste was exhumed using an excavator. Two approaches were used to screen the recyclables and fines (mainly dirt) from the waste materials. These were a gravity finger screen and a trammel screen. The finger screen had two stages, one with a three inch screen and the second stage with a half inch screen. A one inch�screen was used for the trommel screen. Both methods worked well. Tires and bulky white goods (such as fridges and stoves ) were removed by hand. Mining operations were carried out in both the fall and the spring. Weather was generally not a problem, with operations proceeding through both rain and snow. In good weather and waste excavation conditions, as much as 1,200 cubic yards were mined in one day. In poorer weather and waste excavation conditions about several hundred cubic yards per day were mined. Nature and Use of the Reclaimed Material About 60 to 85% (averaging 75 %) of the mined material was recovered as fines. The remaining 25% was waste. This waste material was re— disposed in the operational portion of the landfill. However, some of the waste material was used for a test burn at an energy— from —waste incinerator. The initial test burning of this material was unsuccessful mainly because of the soil material adhering to the wastes. Additional test burns are proposed. The reclaimed metals, tires and white goods were found 3 croo527g/94155/94> This paper is made from recycled fibre 559 23 to be too dirty for recycling without fast preprocessing to remove the dirt. In some cases this was done at the landfill, but in most cases these materials were re— landfilled. Such a large percentage (60 to 85 %) of the mined material was recovered as fines because a large amount of soil had been used in the landfill as daily cover at this site. Therefore the recovered fines were mainly soil material but did contain pieces of glass, plastic, metal and some decomposed waste. About one third of the recovered fines (4,000 cubic yards) were used as daily cover in the operational portion of the landfill. The remainder (8,000 cubic yards) were initially stockpiled and then were approved for use outside the landfill as general construction fill ( as long as used above the water table) and as cover material for other landfill sites. The recovered fines were tested for compost criteria parameters, asbestos, PCBs, contaminants on the U.S. Target Compound List (previously the Hazardous Substance List) and pathogenic microorganisms. The fines were also subjected to the Toxic Characteristic Leaching Procedure. The recovered fines were found to meet the Class I compost criteria and have acceptable levels of the other contaminants. This is why the recovered fines were approved for use outside the landfill footprint. Health and Safety and Environmental Issues The Edinburg Landfill is located in mainly a tourist area with little industry. As a result, hazardous materials were not expected other than household hazardous wastes and asbestos (from construction debris). Nevertheless, an extensive health and safety program was developed for this mining operation. The Health and Safety plan detailed site entry procedures and control, site characterization, personal protective equipment and monitoring, decontamination, communication procedures and emergency medical protocols. Procedures for dealing with hazardous materials such as asbestos, barrels or compressed gas cylinders were also developed. Hazardous materials were removed from the landfill when encountered and stored safely on —site until disposal could be arranged at a hazardous waste disposal site. All staff were trained irl Hazardous Waste and Emergency Response Operations and were required to wear EPA Level C personal protective equipment, including full face, air— purifying respirators. Air monitoring equipment was used including combustible gas meters, organic vapour photoionization detectors, a radiation survey meter, personal asbestos monitors and personal organic vapour badges. Pockets of combustible gases were occasionally detected in the excavated waste but these vented quickly. No other hazardous vapours were detected except on the few occasions when drums with organic vapours were uncovered. Information was not available on dust and odour aspects. Mining operations were above the water table and therefore did not require ground water control. Surface water was directed away from the mining area by ditches. Rain falling directly on the operation infiltrated rapidly due to the sandy nature of the underlying soils. Future of Mining at the Edinburg Landfill Mining is no longing occurring at this site. The demonstration project was to mine only one of the sites' five acres. This was completed in 1991. The site closed in late 1991 under a regulatory order. j 4 (m0527g/94155/94) 599 24 Frey Farm Landfill, Lancaster County, Pennsylvania Lancaster County is in southeastern Pennsylvania. The landfill age was not noted in the literature reviewed but it is presently an operational site. Landfill mining began in early 1991. The area being mined is an older landfill cell of 18 acres containing about 700,000 cubic yards of waste. By the end of 1992 about 3,150 cubic yards of the landfill had been mined. Reasons for Mining Mining was undertaken at this site for two main reasons. One was to recover the waste as additional fuel for the County's waste -to- energy plant. The other was to reclaim landfill space. The revenue from the energy generated by the waste sent to the waste -to- energy plant, plus the revenue from ferrous recovery and reclaimed landfill volume, amounts to about $30,000 per week. The landfill life will be extended several years. Mining Methodology Waste is mined with an excavator. It is sorted with a trommel screen to separate the waste from the fines (i.e., dirt). The operation is presently sending about 1,600 tons of waste to the waste -to- energy plant each week. Nature and Use of the Reclaimed Materials About 70% (by weight) of the mined material is reclaimed refuse used as fuel for the waste -to- energy plant. About 30% of this (by weight) returns to the operational part of the landfill as ash from the incinerator. Another 2% of this material is recovered from the incinerator ash as ferrous metal and sent for recycling. ' About 5% of the mined material is oversize or non - combustibles which are re- disposed in the operational portion of the landfill. About 25% of the mined material is recovered fines. The recovered fines are used as daily cover in the operational part of the landfill. Health and Safety and Environmental Issues Information was not available on the Health and Safety aspects of the mining operation, nor on dust, odour, surface water or ground water. Future of Landfill Mining at the Frey Farm Landfill Mining is continuing at this site. By 1995 it is anticipated that the entire 18 acres (700,000 cubic yards) will be reclaimed. 5 (reo527gr/94155/94) This paper is made from recycled fibre 5 Ii I This paper is made from recycled fibre Landfill Reclamation Projects in Ontario Simcoe County There are presently three landfill reclamation projects ongoing in Simcoe County. These are at the Flos North Landfill, the Elmvale Landfill and the Essa Landfill. The Flos North and Elmvale sites are side by side and are essentially one site. The Flos North and Elmvale Landfill sites are in the north part of Simcoe, near the community of Elmvale, which is about half way between Barrie and Midland. Each site is about 4 acres in size. The Essa Township Landfill is southwest of Barrie. This is a larger site. J.andfill mining has been ongoing at these sites for almost two years. Reasons for Mining The main reason these sites were mined was to gain capacity and extend the life of the sites. Apparently there are some ground water contamination issues at the sites but these are not being remediated as part of the landfill reclamation process. Before mining began the Flos North and Elmvale sites only had a few years capacity each. Presently ij about 60 to 70% of these sites have been mined extending the combined life by about 10 to 15 years. The Essa Township landfill started receiving waste from additional townships reducing its site life from 10 to 15 years to less than five years.. Presently about one third of the site has been mined extending the site life by about eight years. Approvals All three landfill reclamation projects received approval from the MOEE. These sites were considered pilot studies and did not go through an EPA Part V approval, EAA approval or an environmental hearing. Mining Methodology The waste is exhumed with an excavator. The waste materials are separated from the fines (mainly the dirt used in the landfill as daily cover) using a 1 inch trommel screen. There is no separation of tires or metal, etc., because a market could not be found for these materials due to their dirt content. Nature and Use of Reclaimed Materials Much of the waste recovered was poorly decomposed. However, about 60% of the mined material was recovered as fines. This large percentage of recovered fines was attributed to (1) thick layers of (m0527gry94155/94) This paper Is made from recycled fibre 599 2 7 daily cover used in many places in the landfills, (2) areas where the landfill had not extended to its full approved depth (and therefore was subsequently excavated to this depth, thus removing the native soils) and (3) mining of the oldest portions of the landfills where waste had been burned (and therefore only ash remained). A considerable amount of metal, glass and paper fragments were in the recovered ` fines. The recovered waste materials are relandfilled. It is required by the MOEE that the recovered fines only be used for landfill daily cover. The recovered fines are being used for this purpose in both the operational portions of the sites where mining is occurring and at other operational Simcoe County landfills where cover would otherwise have to be imported. The quality of the recovered fines has been tested as well as leach testing of the fines. However, this information is not publicly available. Health and Safety and Environmental Issues All three of these sites are in rural areas with little industry. Hazardous materials were not anticipated, or encountered, apart from household items like paint cans, etc. Combustible gas monitoring was conducted in the excavation, No other air or vapour monitoring was conducted. The sites are open and well vented. Odours have not been an issue because of the relatively remote nature of the sites. Dust has not been an issue because of the moist nature of the recovered materials and the remote nature of the sites. The reclamation process -has required additional litter control. The excavations are not below the water table and therefore leachate control has not been required. The stockpiles of recovered fines are required to be within the landfill footprint because runoff from these piles is contaminated. Future of Mining in Simcoe County Landfill mining is continuing at these sites. There are also future plans to mine the Wasaga Beach and Notawasaga landfills. The City of Barrie is also considering mining of their landfill. 7 (r&0527g/94155/94) 599 28 McDougall Landrill The McDougall Landfill is in the Township of McDougall about 7 km east of Pang Sound. The site is about 64 ha of which about 7 ha is licensed for waste disposal. About 5.5 ha has been landfilled. Landfill mining commenced in the summer of 1993 and continued until the late fall. Mining will continue again beginning in the summer of this year (1994). About one third of the site has been mined to date. Reasons for Mining The McDougall Landfill has ground water contamination problems. To solve these problems the MOEE ordered exhumation of the site to install a composite liner of clay and plastic and a leachate collection system. Since the site was being dug up it was proposed that the material be mined and screened to recover recyclables and fines for cover material. Approvals Landfill mining at the McDougall site was approved by the Ministry of Environment and Energy. This project is considered a pilot project and did not go through an EPA Part V approval, EAA .. approval or an environmental hearing. Mining Methodology The waste is exhumed with a excavator and passed through a trommel screen with 25 mm (1 inch) openings to separate the waste from the fines. Large objects such as white goods (fridges, stoves) and tires are removed. Nature and Use of Reclaimed Materials About 50% of the mined material was recovered as fines and the remainder as waste. The mining operation proceeded at an average rate of about 82 m3/hour. The reclaimed waste is presently stockpiled in the unmined portion of the site. Once the liner is placed in the mined out portion, the waste will be placed back in the lined landfill. About 40 samples were collected during the mining operation in 1993 to determine the quality of the recovered fines. The materials generally met the compost guidelines for chemical quality (i.e., metals, etc.), although the occasional sample exceeded these guidelines. The material does not meet the compost guidelines for non — biodegradable components due to the presence of plastic, glass, metal, wood, textiles, ceramics and stones. The recovered fines do not meet the proposed MOEE guidelines 8 (r0527gr/94155%94) This paper is made from 599 2 9 recycled fibre for Inert Fill or Urban Residential Fill. On, average the materials meet the proposed guidelines for Urban Industrial Fill, although occasional samples had higher concentrations classifying them as Controlled Fill. The primary uses of the recovered fines are: (1) as fill for subgrade preparation below the liner, (2) as daily cover in the landfill, and; (3) as a sublayer of the final cover. More Imes are expected to be recovered than needed for the primary uses. To gain landfill capacity the Township has expressed interest in secondary uses of the recovered fines outside of the footprint of the landfill. The main secondary use proposed is to fill an area where waste is presently outside the approved limits of landfilling. This waste will be removed by mining so that the ultimate limits of the landfill conform to that approved. Removal of this waste will leave a hole outside the footprint which is where it is proposed to place most of the recovered fines. Recovered fines have also already been used to partially fill an old pond on the site. The other secondary use proposed is to use the recovered fines as daily cover on other landfills. The MOEE have approved the primary uses of the recovered fines. The secondary uses have not yet been approved. The recovered fines are presently being stockpiled until the issue of secondary uses is resolved. Not having to return the recovered fines to the landfill could extend the life of the landfill to the year 2002. Health and Safety and Environmental Issues Information was not available on the Health and Safety aspects of the mining operation, nor on dust and odour. Mining operations were above the water table and therefore did not require ground water control. Surface water was directed away from the mining area by ditches. Rain falling directly on the operation infiltrated rapidly due to the sandy nature of the underlying soils. Future of Mining; at the McDougall Landfill It is proposed that landfill mining will continue at this site this year (1994) and in 1995 until all of the site has been exhumed. Whether through mining or just straight excavation, the site must be exhumed to place a liner below the waste to resolve the ground water contamination issues. 9 (nos27v)94155/94> 599 30 Bibliography 1. Aquino, John, 1994. Reclaiming Landfills: Amazing Interest. Waste Age. February 1994. Pages 55 to 57. 2. Hagy, James, 1990. There's Gold in That County Landfill.. Governing. October 1990. Pages 36 to 37. 3. Henderson, Paddon Environmental Inc., 1993. Containment Cell and Landfill Remediation. Township of McDougall Landfill Site. Project #92706A. A report prepared for the Township of McDougall. November 1993. 4. Henderson, Paddon Environmental Inc., 1994. 1993 Annual Report on Landfill Development. Operation and Monitoring. McDougall Township Landfill. Project #193809. A report prepared for the Township of McDougall. February 1994. 5. Kelly, Robert, 1990. Buried Treasure. Civil Engineering. April 1990. Pages 52 to 54. 6. Kelly, Robert, 1990. More Precious then Gold: Mining Old Landfills. World Wastes. June 1990. Pages 44 to 45. 7. Langsford, John, 1993. Landfill Site Remediation. Recycling Product News. November/December 1993. Page 15. 8. Morelli, John, 1990. Landfill Reuse Strategies. BioCycle. March 1990. Pages 40 to 43 and 62. 9. Naber, Thomas, 1987. Mining the Landfill: The Ultimate in Resource Recovery. Waste Age. November 1987. Pages 196 to 197. 10. New York State Energy Research and Development Authority, 1992. Town of Edinburg Landfill Reclamation Demonstration Project. A report prepared by Schillinger, Salerni and Boyd, Inc. under contract #1355- ERER- MSW -90. Q 11. 12. 13. 14. 15. 16. 17. This paper is made from recycled fibre Savage, George, Clarence Golueke and Edward von Stein, 1993. Landfill Mining: Past and Present. BioCycle. May 1993. Pages 58 to 62. Spencer, Robert, 1990. Landfill Space Reuse. BioCycle. February 1990. Pages 30 to 33. Spencer, Robert, 1991. Mining_ Landfills for Recyclables. BioCycle. February 1991. Vasuki, N.C., 1988. Why Not Recycle the Landfill. Waste Age. November 1988. Pages 165 to 170. Walters, Michael, 1994. Landfill Reclamation. Hazardous Materials Management. April 1994. Pages 24 and 25. Watson, Tom, 1988. Recycling the Landfill: The Mining of f Disposal Sites. Resource Recycling. September /October 1988. Pages 20, 21 and 58, 59. World Action for Recycling Materials and Energy from Rubbish (WARMER), 1993. Feature: Landfill Minins. Warmer Bulletin No. 38. Pages 8 and 9. 10 (rao527v/94155/94) Attachment No. 3 G110,TAER LEE REPORT PEER REVIEW OF LAIDLAW RECLA14ATION PROPOSAL V-V.; Operational Procedures Gartner Lee recommended the following changes to the operational plan for the landfill reclamation operation to more adequately address concerns regarding health and safety, odours and dust. 1. A detailed Health and Safety Plan for the protection of both workers and the public should be prepared as part of the approval process. 2. The composition of landfill gases at the site should be determined to allow an appropriate air monitoring program to be developed and appropriate respiratory protection to be provided for workers. 3. In the event elevated levels of potentially harmful gases are detected in the working area, air monitoring at the site's perimeter should be undertaken to determine if air -borne contaminants are leaving the site at levels potentially harmful to the public. 4. The need for odour control from the trommel (ie. waste screening) operation and from the spreading of the recovered fines should be addressed. 5. The approach to odour control should be developed in conjunction with the landfill site's neighbours to determine when odour control will be needed. 6. Dust control procedures for landfill mining activities such as stripping of the cover, sorting of waste and the placement of fines in the borrow pit area should be developed. 599 32 Landfill Liner The plastic /clay material which Laidlaw proposes to use as the sole landfill liner may not provide adequate protection against contaminant migration. For a number of reasons, including the thinness of the liner and the potential for product failure, this liner material is intended to be used as an addition to other liner systems, and not as the only liner in a landfill. End Use of Recovered Fines Gartner Lee made the following observations and recommendations regarding Laidlaw's proposal to use the fines recovered through screening of the waste to fill the borrow pit south of the landfill. 1. Field studies should be undertaken at the Laidlaw site prior to approval to determine whether the recovered fines are of a suitable quality to be placed in the borrow area without causing environmental effects or requiring approval as an additional waste area. 2. Sampling to test the quality of the recovered fines during reclamation operations should be more frequent and include a more extensive list of parameters than proposed by Laidlaw. 3. The recovered fines should be stockpiled until the test results from each batch are known, rather than being taken directly to the borrow pit as proposed by Laidlaw. 4. A ground water and surface water monitoring program should be established for the borrow pit area to assess the environmental impacts, if any, of the recovered fines placed in this area. 5. Prior to using some of the recovered fines for sub -grade (below liner) preparations in the excavated landfill cell as Laidlaw proposes, the potential for contaminants to leach from the fines, as well as the geotechnical suitability of the fines for such a use, should be assessed. 599 33 Leachate Management 1. Laidlaw's estimates of the amount of leachate expected to be pumped from the excavation should also account for the additional ground water that will flow into the excavation from the surrounding soils. 2. The addition of the additional leachate to the Rapid Infiltration Basins will increase the level of the water table down- gradient of the basins. This will result in contaminated groundwater by- passing the low level leachate collector system and discharging to Graham Creek. 3. The Rapid Infiltration Basins are not an adequate approach to leachate management at this site, for either the present leachate collection system, the leachate captured during landfill mining operations, or the leachate that will be captured by the collection system after the landfill is lined and refilled. An alternative leachate management plan for this site should be developed. 599 34 wkff r` OVERVIEW OF LANDFILL MINING PROJECTS COMPARED TO THE LAIDLAW PROPOSAL F Collier County, Florida Edinburg, New York Lancaster County, Penn. Sirnooe County, Ontario McDougall Township, Ont. Laidlaw Proposal 3 sites Reasons for Mining —to save costs by using recovered —as demonstration project —to fuel a waste —to— energy —to regain landfill space — to put liner under landfill — 'reuse the reclaimed air space' fines for daily cover in rest of site —to regain landfill space incinerator causing groundwater — 'improve protection of both —to fuel a waste —to— energy —to regain landfill space contamination the groundwater and surface incinerator —as demonstration project waterby constructing a lined cell — to put liner under old part of with a leas hate collection system landfill causing groundwater within the mined area' contamination — 'recoverand recycle scrap metal and white goods from excavated waste" — 'remove and dispose of hazardous waste, if present' Approvals — approved by state regulatory — approved by state regulatory — approved by state regulatory — approved by MOEE — approved by MOEE — requesting MOEE approval agency agency agency — considered pilot projects and — considered a pilot project and — requesting pilot project status therefore did not require an EPA therefore did not require an EPA and therefore requesting MOEE Part V approval, EAA or a hearing Part V approval, EAA or a hearing approval with no EAA or hearing Mining Methodology —mined with excavator —mined with excavator —mined with excavator —mined with excavator —mined with excavator —to be mined with excavator —large items like tires and white —large items removed by hand — trammel screen used to —large items not separated —large items removed by hand —large items to be removed goods removed by grizzly screen — trommel screen used to separate fines from the waste — trammel screen used to —tro nmel screen used to by hand — trammel screen used to separate fines from the waste separate fines from the waste separate fines from the waste — trommei screen to be used to separate fines (mainly dirt) from no excavation into the water table —no excavation into the water table —no excavation into the water table separate fines from waste the oversized waste (waste overs) — stockpiles of recovered fines to — excavation into the water —no excavation into the water table remain within the landfill footprint table may occur to prevent contaminated runoff —waste overs to be stockpiled in mined area Nature and Use of — originally tires, white goods, — reclaimed metals, tires and —no separation of recycieables —no separation of recycleables — recycleables are removed but —white goods and scrap metal Reclaimed Materials: ferrous metal, aluminum and white goods were found to be too undertaken because no market could be their fate was not determined in to be removed and sold to scrap Recycleables plastic were separated for dirty for recycling without found this review metal dealer for recycling recycling — this was discontinued preprocessing to remove the dirt because the material was too dirty to be marketable F U'B OVERVIEW OF LANDFILL MINING PROJECTS COMPARED TO THE LAIDLAW PROPOSAL — continued Collier County, Florida Edinburg, New York Lancaster County, Penn. Sinooe County, Ontario 3 sites McDougall Township, Ont. Ladlaw Proposal Nature and Use of —65 to 80% of the mined material —60 to 851A of the mined material —251/. of the mined material —60% of the mined material —50% of the mined material —50% of the mined material Reclaimed Materials: was recovered as fines was recovered as fines was recovered as fines was recovered as fines was recovered as fines is expected as recovered fines Recovered Fines —the remainder (the waste overs) —the remainder (the waste ovens) —the remainder (except oversize —the remainder (the waste overs) —the remainder (the waste overs) —the remainder (the waste overs) were relandfilled were relandfilled materials) is used as fuel for a were relandfilled are presently stockpiled on the will be landfilled — recovered fines can only be used —a trial burn of the waste overs waste —to— energy incinerator — required by the MOEE that the unmined landfill until the liner —the fines are proposed to be for daily cover in other parts of the was unsuoessful due to the high —the recovered fines are used as fines be used as daily cover is completed — then they will disposed outside the waste landfill dirt content daily cover in the active part of within active portions of the be landfilled footprint in an adjacent borrow pit —some of the recovered fines the landfill mined sites as well as at other — approved uses of the fines are: —fines quality similar to used as daily cover in active part landfills within the County as fill for subgrade preparation, the McDougall site is a )petted of landfill daily cover in the active landfill, —some of the fines used as daily and sublayer of the final cover cover on other landfills — approval being sought, but not —some of the fines used as yet received, to fill areas outside construction fill above the the waste and as daily cover on watertable other landfills — recovered fines met compost —the fines meet the compost guidelines except for pieces guidelines except for plastic, of glass, plastic and metal glass etc. content —the fines do not meet the proposed MOEE guidelines for Inert Fill or Urban Residential Fill, the fines generally meet the Urban Industrial Fill guidelines Health and Safety — nature of area (rural and tourist — nature of area (rural and tourist — information on Health and —all 3 sites in rural area with — information on Health and — detailed Health and Safety only) with low chance of hazardous only) with low chance of hazardous Safety not determined in this low chance of hazardous Safety not determined in this plan not yet prepared wastes except household items wastes except household items review wastes except household items review — development of this plan — testing for asbestos and — detailed health and safety — combustible gas monitoring only proposed combustble gas only plan developed —EPA Level C personal protective equipment required — organic vapour and combustible gas monitoring — radiation monitoring — asbestos monitoring and handling procedures —entry and decontamination protocols — emergency protocols — procedures for hazardous materials identification, handling and disposal