Loading...
HomeMy WebLinkAboutPD-48-91 I 1111 CORPORATION OF I F1 lF TOWN OF NEWCAS FLI--' DN: LAIDLAW.GPA REPORT 1'-)) Meeting General Purpose and Administration Committee File 6f PUI,(26 P L, Date Monday, February 18, 1991 HeE, /I Cry-Law fif Rel)ort It PD"- 8---_9-1Fde 9 ORA 89-39/D; DEV 89-44 Subject OFFICIAL PLAN AMENDMENT APPLICATION 89-39/D REZONING APPLICATION DEV 89-44 LAIDLAW INFILL PROPOSAL PART LOTS 11 & 12, CONCESSION 3, FORMER TOWNSHIP OF CLARKE Hecomi-nendailons It is respectfully recommended that the General Purpose and Administration Committee recommend to Council the following: 1. THAT Report PD- 48-91 be received for information. 1. PURPOSE 1. 1 The purpose of this report is to advise Committee and Council of the status of the Official Plan Amendment and Rezoning Applications related to Laidlaw's Infill proposal. 2 . AGENCY COMMENTS 2 . 1 The comments of the Ministry of the Environment on the technical reports submitted by Laidlaw in support of their application pursuant to Part V of the Environmental Protection Act were provided to Laidlaw and the Town on December 4, 1990 (Attachment No. 1) . The Ministry, in their covering letter, noted that a number of technical issues must be resolved, particularly with respect to site hydrogeology. 2 .2 The Ministry of the Environment recommended to the Ministry of Municipal Affairs that the application not be forwarded to the Environmental Assessment Board until such time as the outstanding issues are satisfied. By letter dated January 9, 1991 (Attachment No. 2) , the Ministry of Municipal Affairs advised Laidlaw's consultant that they would not be in a position to refer the subject Official Plan Amendment application to the Ontario Municipal Board until such time as they are advised by the Ministry REPORT NO. : PD- 48 -91 PAGE 2 of the Environment that the application under Part V of the Environmental Protection Act may proceed to the Environmental Assessment Board, and the comments of the Town and the Region have been received. 2 . 3 The Regional Department of Health Services has indicated to the Town, that they would be withholding their comments on the Infill proposal until such time as the position of the Ministry of the Environment is made clear. Staff forwarded the comments of the Ministry of the Environment to the Department of Health Services on December 18, 1990. 2 .4 The comments of all the other technical agencies to which the rezoning and official plan amendment applications were circulated have been received. 3 . CORRESPONDENCE FROM LAIDLAW 3 . 1 By letter dated January 4, 1991 to Town Staff (Attachment No. 3) , Laidlaw indicated that it has prepared a response to the comments from the Ministry of the Environment which will be provided to the Town at such time as it has been submitted to the Ministry. The letter also questions the position of Town Staff that site hydrogeology is a matter which needs to be considered by the Town in making a decision with respect to a proposed land use. 3 .2 The Town's response to Laidlaw's letter is attached hereto as Attachment No. 4 . 4 . CAPACITY REMAINING AT EXISTING SITE 4 . 1 By letter dated October 3, 1990 (Attachment No. 5) , Laidlaw submitted a request to the Ministry of the Environment for an Emergency Certificate of Approval on their existing landfill operation. Laidlaw stated in the letter that landfilling operations on the north mound have ceased, and that the active face on the south mound was within three weeks of reaching capacity. REPORT NO. : PD-48 -91 PAGE 3 4 .2 In a telephone conversation with Town Staff on October 19, 1990, Mr. John Bray, the Director of the Approvals Branch within the Ministry of the Environment, indicated that he did not feel an emergency existed as defined by the Environmental Protection Act, and that a verbal denial with respect to the request for the Emergency Certificate of Approval had been issued to Laidlaw. 4 . 3 Council has previously directed Staff and Municipal Counsel to determine the remaining capacity at the existing landfill site and to advise Council on actions that may be taken to ensure that the site is closed immediately upon reaching capacity. Town Staff has requested the Ministry of the Environment to provide information related to remaining site capacity, most recently by letter dated February 5, 1991 (Attachment No. 6) . As of the writing of this report, the Ministry had not responded to the Town's request. Respectfully submitted, Recommended for presentation to the Committee Franklin Wu, M.C. I .P. La ence E. Kotseff Director of Planning Chief A i strative and Development Officer JAS*FW*df *Attach 7 February 1991 Interested parties to be notified of Council and Committee's decision: Mr. John Kennedy, M.C. I .P. Mr. David Scott Marshall Macklin Monaghan Chairman 80 Commerce Valley Drive East Committee of Clarke Constituents Thornhill, Ontario Box 28 L3T 7N4 Newcastle, Ontario. Ms . Dianne Lemieux Mrs . Helen MacDonald Fogler Rubinoff R.R.#1 Barristers and Solicitors, Newtonville, Ontario. Suite 1400, LOA 1J0 150 York Street, Toronto, Ontario. M5H 3T1 r Ministry Mlrnstbre of the de Environment I'Environnement Attachment # 1 Untano 250 Dam,.Itle Avenue 250,avenue Oavisvdle Toronto,Ontano Toronto(Ontano) APPROVALS BRANCH 144S1H2 WSIH2 3rd Floor Tel. (416) 440-3546 Fax (416) 440-6973 December 4, 1990. Laidlaw Waste Systems Limited 3410 Service Road Box 5057 Station "A" � tip Burlington, Ontario. L7R 3Y8 DEC 12 1990 Attention: Mr. M.J. Pullen. P.Eng. TOWN OF i VAKASTLE PLANNING DEPARTMENT Dear Mr. Pullen: _ RE: LAIDLAW WASTE SYSTEMS (DURHAM LTD. C APPLICATION FOR LANDFILL EXPANSION (INFILL) DECEMBER 21, 1989 The above application and supporting documents have been reviewed by Ministry staff. Comments are enclosed in the accompanying Schedule A. As you will see from the comments, a number of technical issues must be resolved. When applying for the expansion of an existing site, it must be demonstrated that the existing site is operating in an environmentally sound manner. A clear definition of the site's subsurface and associated groundwater flow and leachate migration must be provided for the determination of any existing or potential negative off-site effects. Contingency plans must also be proven viable. It must be shown that the leachate can be effectively collected and disposed. It is recommended that the application not be forwarded to the Environmental Assessment Board until such time as the outstanding issues are satisfied. Should you wish to arrange a meeting with Ministry staff to discuss these comments, please contact Mrs. Anne van Warmerdam at 416-440- 3726. Yours truly, Original Signed by I R. Bray J.R. Bray, P.Eng. Director encl. av/ cc: J. Merritt, MOB, Central Region C. Lundy, Clerk, Regional Municipality of Durham P. Barrie, Clerk, Town of Newcastle f D. Jardine, MMA, Plans Administration Branch D. Scott, Committee of Clarke Constituents SCHEDULE A The Ministry of the Environment staff have reviewed the above-noted application and following documentation in support of the submission: 1. "Laidlaw Waste Systems (Durham) Ltd., Infill Project, Hydrogeology- Laidlaw Newcastle Landfill," prepared by Marshall Macklin Monaghan Limited, dated December 19, 1989. 2. "Laidlaw Waste Systems (Durham) Ltd., Infill Project, Development, Operations and Closure Report - Laidlaw Newcastle Landfill," prepared by Marshall Macklin Monaghan Limited, dated December 15, 1989." 3. "Laidlaw Waste Systems (Durham) Ltd., Infill Project, Transportation Impact Assessment - Laidlaw Newcastle Landfill," prepared by Marshall Macklin Monaghan Limited, dated December 18, 1989. 4. "Laidlaw Waste Systems (Durham) Ltd., Infill Project, Visual Impact Assessment and Use Planning- Laidlaw Newcastle Landfill," prepared by Baker, Salamon &Associates Limited, dated December 18, 1989. 5. "Laidlaw Waste Systems (Durham) Ltd., Infill Project, Dust Impact Analysis - Laidlaw Newcastle Landfill," prepared by Concord Scientific Corporation, dated December 19, 1989. 6. "Laidlaw Waste Systems (Durham) Ltd., Infill Project, Noise Impact Assessment- Laidlaw Newcastle Landfill," prepared by J.E. Coulter Associates Engineering, dated December 19, 1989. 7. "Laidlaw Waste Systems (Durham) Ltd., Infill Project, Public Consultation Report - Laidlaw Newcastle Landfill," prepared by Institute of Environmental Research (1985) Inc., dated December 1989. 8. "Laidlaw Waste Systems (Durham)Ltd, Social Analysis Report," prepared by Institute of Environmental Research (1985) Inc., dated December 1989. ) J - 2 - 9. "Laidlaw Waste Systems (Durham) Ltd., Proposed Leachate Forcemain - Laidlaw Newcastle Landfill," prepared by Henderson, Paddon &Associates Limited, dated August 1989. 10. "Laidlaw Waste Systems (Durham)Ltd., InfiIl Project, Government Consultation Report- Laidlaw Newcastle Landfill," prepared by Marshall Macklin Monaghan Limited, dated December 19, 1989. Comments regarding the report are as follows: - 3 %AIDLAW WASTE SYSTEMS (DURHAM) LEMM ED INFILL PROJECT, NOISE DIPACT ASSESSMENT - LAIDLAW NEWCASTLE LANDFILL." PREPARED BY J.E. COULTER ASSOCIATES ENGINEERING The submission follows procedures described in the Ministry's noise guidelines. The proposed control measures are acceptable provided that the recommendations included in Section 6.0 of the report are properly incorporated into the final design. LAIDLAW WASTE SYSTEMS (DURHAM) LTD. DEVELOPMENT, OPERATIONS AN CLOSURE REPORT NEWCASTLE LAMI AW LANDFILL 1.3 PURPOSE OF THE STUDY Paire 1-3: A list of benefits is provided which is said to only occur if the site is approved. The list includes an improved level of groundwater and gas monitoring, an improved level of leachate collection from the existing landfills due to the new system to be installed beneath the infill and installation of an expanded leachate collection system for the site. Should the site infill not be approved, the Ministry would still have the ability to require an improved groundwater and gas monitoring system. The expanded collection system to the west of the site was required by condition on a previously issued Certificate of Approval. While leachate from the existing site may be collected from the new infill collection system, it is understood that the majority of leachate will be collected from the infill. The additional amount collected from the previous filled areas is not documented. Figure 2 should include the locations of the two additional sedimentation ponds. � f I - 4 - 1 2.0 EXISTING CONDITIONS 2.4 Hydrology Page 2-6: Flow rates are given for the Graham Creek at the entry point to Lake Ontario. According to the reference given, these numbers are at least 25 years old. Are more recent figures available and if not, are the 1965 OWRC figures appropriate? The report A1ao states that sampling analysis to date has not resulted in evidence of leachate presence in Graham Creek. This should be re-stated to say that there has been no evidence of impact on Graham Creek from leachate from the landfill. 2.5 Leachate Characterization -� The sample used to characterize the leachate was collected from the sump of the upper collector. It is described as a blend of leachate and groundwater from the upper and lower collectors. Sample analyses indicate the nature of the leachate collected for treatment, but not pure leachate. The sump sample had a conductivity value of 168 mmhos/cm while material sampled in OW95-4 had a conductivity value of 8,340 mmhos/cm(sampled by MIML). It is recommended that a representative sample of pure leachate be collected for analysis and used for worst case scenario predictions. The values listed in Table 1 should be compared to background values for this site and not necessarily to values at other landfill sites as has been done. While a comparison to other landfill sites may indicate that parameters fall in the "typical" range, it is not indicative of changing conditions at the site. C - 5 - 2.6.1 Groundwater Movement Paste 2-10: The gradients are said to be primarily downward in the infill area and upward near Graham Creek. This does not necessarily follow from the information provided in the Hydrogeology Report (Table 5, Page 3-5). Information suggests that the gradients at OW37-5, OW83-13 and OW78-4 are downward (these wells are just south of the Creek), with only OW78-6 having an upward gradient. These findings are inconsistent with the statement made in the Design and Operation Report. Similarly, it is suggested that the gradients in the infill area are primarily downwards. The information provided indicates a perched water table at OW95, leaving only one monitor showing a downward gradient (OW92-5). Monitor OW93 shows an upward gradient. Pare 2-11: It is indicated that the hydraulic conductivity of the soils �+ underlying the infill area range from 10'cm sec. in the sands and gravels to 10' cm/sec. in the silt soils. These values have been based on sieve analyses. Bail tests conducted in the Hydrogeology Report indicate that the conductivity values of the soils range from 10'cm/sec. to L4 x 10'cm/sec. 2.6.3 Reasonable Use Guidelines Page 2-12: The report states that as the Laidlaw site predates the implementation of this policy, the Reasonable Use Guidelines do not apply to the site. It should be noted that this policy applies to this expansion. .Before the Reasonable Use Policy was implemented, no discharge was permitted beyond site boundaries. The waste disposal site's location presently registered on title is parts of Lot 12, Parts 1 and 3, Concession 3, Town of Newcastle, Regional Municipality of Durham. - 6 l Migration to the south of the landfill must be determined, as should any necessary remedial measures. The site owner must be able to demonstrate that any contaminant migration off-site meets the required levels. The landfill's limit of fill for Phase 2 borders on the southern portion of Part 3, Lot 12. No buffer exists. Pages 2-13, 14: The report assumes that the downgradient use of groundwater from the site is Graham Creek and that the Reasonable Use Guides can be applied using the Provincial Water Quality Objectives. This is inconsistent with the manner in which the policy is to be applied and nullifies the results of any of the calculations. It is acknowledged that there are physical and chemical processes which alter groundwater as it seeps into the surface water environment. For these reasons, the background values are to come from the appropriate monitoring wells and not surface water bodies. A statement is made to the effect that there is no groundwater flow under Graham Creek. Does this mean no groundwater flow perpendicular to the flow direction of the Creek at depth? The Sykes model referred to on Page 2-13 was discouraged by the Ministry of the Environment during a previous meeting, dated March 30, 1988. It is interesting to note that Page 2-16 of the same report reads: "Consideration was given to modelling the site; however, after exam;nAtion of a few of the models available, it was concluded that the site geology and hydrogeology was too complex to realistically model." Leachate was detected in OW37-5. Since the writing of the report, the leachate collection system has been extended along the western boundary, east of the observation well. Parameters (iron and phenol)were found to exceed Reasonable Use Criteria during the sampling period of May 1988. Why has recent sampling not been undertaken to confirm this? If confirmed, what , i - 7 - measures will be taken to rectify this situation before the material migrates off site? Have trends continued since the implementation of the collector system? It is suggested that phenols may occur naturally in the groundwater. Background samples are required to confirm this statement. If geology is found to be too complex to obtain representative samples in unaffected areas, the leachate must be adequately characterized in order to identify parameters and concentrations exclusive to the leachate. 2.6.3.2 Future Results Page 2.16: It is incorrect to propose that since the Reasonable Use Policy Guidelines will come into affect once approval for the infill is granted, the present parameter concentrations could be considered background. To insinuate that present conditions at a site which has been operating since the " early 1970's may represent background is reprehensible. Background concentrations are described in the Ministry of the Environment's 'Reasonable Use Policy" as the "quality of the groundwater prior to any man made contamination". Representative values of a background quality of respective aquifers are to be collected in order to assess any possible degradation of quality. The report concludes that the extrapolation of data indicates that Reasonable Use Guidelines will not be exceeded in the near future. The term "near future" is unacceptable. Predictive monitoring(based on conservative figures) should ` be undertaken to determine when maximum allowable limits may be exceeded. Annual monitoring and reporting will be used to assess and modify the predictions. t a c> t - 8 - 3.0 SITE DEVELOPMENT 3.3 Landfill Design and Phased Development Page 3-2: It is indicated that 17,000 tonnes of soil would be required for site repairs. However, on Page 3-7 in Table 6, 14,000 tonnes are dedicated to site works. For the waste and cover quantity calculations, the figure 14,000 tonnes is used. This discrepancy should be clarified. Table 6 also states that the total volume of waste and cover quantity is 223,694 ma. Were the final contour elevations for the infill project based on placement of this volume within the area. This should be verified by illustrating that the volumes between the final contour and bottom contours are the same. 3.4 Base Preparation The report recommends that 1 m of silt till be placed to form a base for the infill area. The reasoning behind this should be presented (i.e., why only 1 m and will it be compacted to a hydraulic conductivity of less than 1.4 s 10' cm/ sec.?). Predictions of leachate migration through the liner should also be provided. The diagram showing the leachate collector details indicate that the pipe will be 0.65 m below the ground surface. This places it 0.35 m above the base of repaired bed surface. Is this intended to adequately isolate the underlying strata from the collector system? In order to prepare the infM base, the Trans Canada pipe bedding and underlying gravel will be removed to depth of 2 m. Concern exists that the pipe .acted as a conduit for leachate travel. It is, therefore, suspected that leachate may exist in high concentrations within the soil. Will visual inspections be made to ensure that all leachate contaminated soil has been j removed? ! - 9 - It is stated that waste has a hydraulic conductivity of 1 a 10-3 cm/sec. thereby providing a preferential flow along the base which has a permeability of 1.4 s 10-5 cm/sec. Waste studies have found that waste hydraulic conductivities can vary from 10' cm/sec. to 10' cm/sec. depending on the material's density, degree of compactness, and state of degradation. It should be demonstrated that the difference created between 10' cm/sec. and 10' cm/sec. will create enough of a differential flow. What are the bottom contour elevations of the existing two landfilled areas as compared to the proposed infill project? Drawing 1 shows a compacted silt till base up to an elevation of 165 m on the slide slopes. Is there refuse under the new side slope and will the integrity of the new base be affected by settling of old refuse below? What are the locations of detail A) and B) of the leachate collector tiles on the drawing? 3.5 Leachate Collection System Paire 3-3: It is indicated that if one of the leachate collector pipes is blocked, leachate flow would be collected by the second pipe. On Drawing 1, a crown on a the base between the two collector pipes is shown such that the leachate flow is split. In all likelihood, if one collector pipe becomes blocked, leachate would flow along the trench. The drawing also shows a minimum separation distance of 1 m between the base of the liner and water table. Justification for this distance must be provided. A cross-section should be presented showing the elevations of the present and proposed leachate collector systems. The elevations of the creek bed and the sedimentation pond basins should also be documented. - 10 - } Page 3-4: Reasons for the assumption of a long-term infiltration rate of 23 cm/year (9"6rear) should be provided. The report stipulates that 0.3 m of till will be placed over the collector system while no refuse is placed on that section of the site. Should there be truck traffic in the area, an additional 0.6 m will be placed over the trench malting a total thickness of protective covering of 1.6 m. These numbers should be substantiated to the appropriateness of the intended purpose. 3.6 Leachate Disvosal Possible leachate disposal methods discussed include leachate flow routed via the existing leachate collection system to the rapid infiltration basin or the flow routed to a pump station and then to a forcemain to a sewage treatment plant. On March 1, 1990, Laidlaw notified the Environmental Assessment Board that 1 it did not plan to proceed with the forcemain application. Therefore, this is no J longer considered an option for leachate disposal. The rapid infiltration basin has a storage capacity of two months should no infiltration take place. Should this occur, leachate will be trucked away. Assurances or guarantees must be provided to show that disposal of leachate will be done in an environmentally safe and acceptable manner. If trucked the leachate will meet sewer use by-laws if hauled to a municipal sewage treatment plant. The rapid infiltration basin (RIB) is prone to clogging overtime due to the precipitation of metals and the formation of biological films derived from the leachate. How is the performance of the basin assessed? In order to assess the RIB performance, it is recommended that a more frequent sampling interval be undertaken in order to determine the travel time of leachate between the sump and observation wells below the infiltration basin. Change in chemical characteristics shall also be observed. Sampling parameters should include chloride, sulphate and other mobile cations. 3.8 Sedimentation Control The additional ponds and the expansion of the existing pond to accommodate the sediment from the surface runoff will have an affect on the groundwater conditions on site. The large northern pond will be located very close to the collector system along the northwest edge of the filled zone. What are the expected effects of having a large potential recharge zone at this proximity to the leachate collector? What is the elevation of the pond bottom expected to be and how does this compare to the elevation of the leachate collector in this area? By what volume will these capture basins reduce the volume of leachate projected to be collected by the collection system? 4.0 OPERATIONS AND MAINTENANCE Pare 4-1: The report indicates that water for calcium chloride will be utilized for dust control. Will the use of calcium chloride on roadways affect groundwater monitoring results for defining the leachate plume? 4.5 Leachate Collection System Maintenance The leachate pumping stations are proposed to be checked weekly during operations. If the pumping stations do not already have alarm systems with signals such that the pumping station can be attended to immediately, it is recommended that alarm systems be installed to reduce the risk of any breaching of the collection system. The low level leachate pumping station approved did show a high level alarm. Also, in a letter dated March 11, 1988 from Mr. D. Tefft of Laidlaw,it was stated that pumping stations would be inspected daily from Monday to Friday. I 4.6 Gas Control The report suggests that the leachate collection system will prevent migration and allow the venting of landfill gases. It is agreed that there will be some gas 1 i - 12 - 1 venting through a leaching collection system; however, there is no guarantee that it will prevent gas migration. The report fails to provide a contingency for odour control of landfill gases. 4.11 On-site Rec9clin� On-site recycling should be included as part of the application and supporting documentation. For example, the location of the recycling containers should be shown on the drawings. 4.9 Winter Operations It is indicated that an emergency dumping area will be prepared for trucks not being able to access the actual working face. This proposed area should be f shown on a drawing (as part of the supporting information) as an emergency 1 transfer storage area. In this way, emergency facilities would be approved with J the infill project. Perhaps, an alternative would be not to operate the site when trucks cannot access the working face. 5.0 MONITORING AND CONTINGENCY An annual monitoring report is to be submitted in September which would include surface and groundwater, leachate and gas monitoring results. An interpretation of the analysis results and recommendations based on the interpretation are required. 5.1 Surface Water Monitorinz The report indicates that Graham Greek is sampled four times a year between May and September. It is recommended that the sampling period be extended to at least into November or late fall. Sampling between May and September is too compressed and would not reflect seasonal fluctuations. t ) /� - 13 5.2 Groundwater Monitorin¢ The monitor wells to be sampled semi-annually should be listed. The report has stipulated that 20 wells are to be sampled as listed on Fig. 5. There are more than 20 wells shown as monitoring wells. The contingency measures stated should be elaborated with specific details provided. If purge wells are to be placed, where would they be positioned and to what depths will they extend? What kind of leachate is likely to be utilized? 5.3 Leachate Collection Syjdem Monitoring In order to assume all leachate is collected by the existing collection system, it Cis requested that a site water balance be conducted It is stated that all pipes will be flushed and cleaned annually in addition to any cleaning for emergency purposes. How will cleaning of collector tiles be implemented without clean-outs at specific and reasonable distances? It also indicates that system monitoring will be conducted monthly with pumping stations and inspected more frequently. In a letter dated May 11, 1988 from Laidlaw to the Ministry, it is indicated that leachate pumping systems will be inspected on a daily basis from Monday to Friday. Standby pipes have been ordered and a vacuum tank truck has been obtained on a standby basis. Also, this system will be disassembled bi- annually for inspection and maintenance, not annually as proposed. It is understood that an alarm system was installed in a low level ! � P�P� i station. It is recommended that alarm systems with signals to a 24-hour man station, if possible, are installed at all pumping facilities. I i - 14- 1 5.4 Gas Monitorin¢ The locations and depths of the six gas monitoring probes should be clearly presented. The rationale for six monitors should be provided. 5.5 Contin¢ency Action It may be difficult to pinpoint the source of leachate migration impacting Graham Creek. It is recommended that while contingencies are being carried out io loc to and correct the problem, immediate haulage of leachate be implemented in lieu of recycling the leachate back,to the site. An off-site treatment plant is recommended as one of the options available in dealing with the problems of excessive leachate generation. Has there been an allocation at the treatment plant for volumes of leachate from this site? Are there any estimates of the volumes which may be of concern? Where is the plant which will be taking excess volume? One of the considerations in implementing contingency plans is the increase in leachate head such that it is considered detrimental to the underlying groundwater. Table 8 indicates that this level is to be 3 m above the liner. Reasons for this height stipulation should be documented. Is it to be 3 m in the base of a liner or from the top of the liner? What is the elevation of leachate head in Phases 1 and 2? Pare 5-5: It should be clarified that although Laidlaw is committed to a leachate forcemain, Durham Region has not provided an allocation of capacity for the £orcemain in the extension of the Graham Creek Water Pollution Control Plant. As stated earlier, Laidlaw withdrew its forcemAin application from the Environmental Assessment Board. Table 8: In the column pertaining to the surface water Graham Creek contingency plan, reference to the Reasonable Use Guidelines should not be used. ) d J - 15 - Two uses for purge wells are proposed for contingency methods. The first is to use the wells to create a flow boundary, thereby preventing leachate migration. In order to demonstrate their effectiveness, it is recommended that pump tests be conducted in order to determine the radius of influence. The impact of the purge well system on groundwater levels and stream base flow must also be assessed. The second proposed use is the direct withdrawal of leachate from the waste area. The ultimate disposal of the leachate for both methods must be determined. 6.0 SrM CLOSURE 6.1 Post-Closure Monitoring and Contingency Plan After site closure, it is proposed that the proponent undertake dust and noise monitoring only if there are complaints from surrounding residents. It is the responsibility of the site owner to ensure that such problems are not created. The annual monitoring report should not only indicate the monitoring results but also an interpretation with recommendations as required. Page 6.2: A discrepancy e3dsts in the report with respect to the monitoring of the landfill gas. A post-closure monitoring frequency of four times a year is proposed. However, in Section 5.4, continuation of sampling if the LEL is less than 10 percent is discussed. Clarification is required. 6.3 Maintenance After Site Closure It is suggested that annual inspections remain after the establishment of vegetation. It is recommended that inspections be made twice a year, preferably, during the spring and fall. t - 16 - 1 7.0 HYDROGEOLOGY 7.1.2 Groundwater Calculations should be used to support the anticipated reduction in the infiltration volumes and leachate volumes. 7.1.3 Sedimentation The volumes of pond storage and of anticipated runoff should be stated in the report as well as the methods used for these calculations. 7.1.4 Landfill Gas The report indicates that the leachate collector mitigates gas migration problems anticipated with increased fill. There is further mentioned made of the placement of gas vents. The number and location of these should be shown on the site diagrams along with construction details. Are these gas vents the same as the six proposed monitors? Landfilled gas odour control contingencies should be addressed. 7.3 Social Environment It is implied that the life expectancy of the site is seven years. This has changed to two years. Paste B-2: Wells OW79-4 and OW81-3 are noted as being outside the collector system on site. Well OW39-4 would also give some indication of the presence of leachate beyond the collector and should be incorporated in the sampling program- j �� j - 17 - Page B-3: A statement is made that only pH, alkalinity, ammonium, phenols and iron have been present at measurable levels over the period of record. It would seem that these were the only parameters measured and were, therefore, the only ones measurable. In most cases, for the time period covered, between 60 and 75 percent of the data is listed as "na". (Data were not available.) It appears that the projection of the trends on the graphs B-1 to B-8 are at best on two previous data points. Two points hardly constitute a trend on which concentrations can be projected. The graphs would be more useful if all parameters for a particular monitor were plotted on the same graph instead of the current configuration. This would facilitate comparison of trends at each monitor instead of a comparison of trends between monitors. It is noted that the historical chloride levels for the values listed in Table B-4, Extrapolated Groundwater Chemistry are not found in the parameters listed in CTable 13-3. Where are the values used to arrive at these projections? The parameters listed in Table B-6 are not consistent with those found in the monitoring report and leachate indicators. Since the values used as background for this site are incorrect, the values presented in this table are meaningless as are the conclusions drawn from the values on the table. Pate B-5: A statement is made that concentrations of ammonia, beryllium, chromium, nickel and silver in the monitor wells and the leachate collector system are below calculated Reasonable Use Policy levels. It has been noted that these levels are incorrect if inappropriate background levels have been used. Why are these parameters used to illustrate this point and not those on the list of critical conteminen{,sy The development operation and closure report should include a drawing showing the general cross-section of the site to include bottom contour elevations of the existing fill area and proposed area, leachate collector Celevations, creek bottom groundwater table and leachate plume delineation. There should also be a cross-section of the leachate pond, observation well, creek bottom and water table including plume delineations from the rapid 1 - 18 - l infiltration basis. The drawing showing the cross-section of the bottom of the infill area should also include the actual plan of the bottom contour area to be used for the infill. There should also be a cell developmental plan outlining the typical refuse fill and cover and direction of the sequential fill development and a number of lifts, etc. 'LAMI AW WASTE SYSTEMS (DI;RI LOD LEMMD. HYDROGEOLOGY- NEWCASTLE LAIDLAW LANDFILL" 2.0 EXISTING CONDITIONS 2.2.2 Surficial Geolocy Pace 2-2: It is stated that "site boreholes only partially penetrated the 1 surficial sediment sequence...only the upper portion of the surficial sediment J sequence has been interpreted with any degree of certainty". While migration of the leachate has been determined through the upper sequences of the soils, uncertainty still exists as to the migration of leachate from below the previously filled phases. A partial understanding of the site's subsurface is inadequate for the determination of groundwater and leachate migration. Contingency plans cannot be made with any degree of confidence. The Consultant should elaborate on the term "morainic land.form'. Pace 2-3: The report indicates that seismic measurements conducted at the site were unable to distinguish between the various strata known to exist from borehole data. The report also notes that increasing size velocity with depth is a requirement for the survey to reveal information at depth. The cross-sections enclosed show stratigraphic changes in layering in the subsurface (dashed lines). Was this information derived from the size of the surveys or from the borehole samples? - 19 - 3.0 HYDROGEOLOGY 3.1 Hydraulic Conductivity Comparisons are made of the soil's hydraulic conductivity values based on results from grain-size analyses and bail tests on Table 2. The two values cannot be compared (with the exception of OW35-11) as the sample depths are obtained from different lithological units. The bail test results are preferred as they represent in-situ scenarios. Therefore, the statement that the hydraulic conductivity values of the soils range from 10' cm/sec to 1.4 x 10' cm/sec is acceptable. The range given on Page 2-11 of the Development, Operations and Closure Report of 10' cm/sec to 10' cm/sec is unacceptable as the values are based on sieve analyses. It is not felt that the classification of on-site sediments as permeable or relatively impermeable can be based on the above-noted values. 3.2 Groundwater Flow Directions The shallow groundwater flow under the property is said to be radially away from the landfill. This implies movement to the south as well as to the northeast and northwest. The southerly direction of flow has not been documented in the report. Water table contours and associated groundwater flow to the south of the site must be determined and illustrated. In addition, reasonable use calculations must be made relative to movement towards the southern site boundary. Fig. 9 presents water table contours for the infill area and parts of the site. The contour lines end as they meet the fill boundary within the site. This represents an incomplete picture and is incorrect in that an isopleth cannot simply end as is the case in this diagram. Water table contours and associated groundwater flow to the south of the site must also be shown. - 20 - Table 6 presents gradient directions and hydraulic gradient calculations for selected wells on-site. The method used for the calculations of these gradients should be provided. 4.0 GEO-CHEAHSTRY 4.1 Landfill Leachate 4.1.1 Leachate Control ThA locations of the upper and lower collector pipes are described relative to the location of Graham Creek. They are not, however, described as any reference to their elevations. Elevations of the creek bed and collector pipes should be clearly presented in sectional or planned diagrams. 42 Extent of Leachate J Some leachate indicator parameters are listed and chloride levels are plotted on Fig. 11. The chloride levels plotted are not all from the same sampling run and, therefore, do not represent conditions at any one time. Maps of parameter values placed beside the well of concern are appropriate for this type of report; however, the well number should be presented on the map along with the value for the parameter being detected. The date on which the sample is collected should be presented along with the data. There are two abandoned wells indicated on Fig. 9. Is there any information on these wells such as depths, formations finished in, and time of abandonment/destruction? Leachate parameters for OW39-4 show trends of increasing concentration since 1986. The report recommends further testing before any firm conclusions may be drawn as to whether or not there was any impact from leachate. The same projection exercise performed in the Development, Operations and Closure d `) - 21 - Report for certain wells and parameters should also he performed for this well. There are more data points on which to base a projection than there were for any of the well studies in the Development, Operations and Closure Report. Page 43: The findings of the sample analyses are summarized by noting that 20 of the 41 piezometers sampled in 1988 indicate the presence of leachate. This provides enough data to allow the drawing of leachate plumes or zones of contamination in both plan and cross-sectional diagrams. Such information should be included. Table 10 compares shallow and deeper observation wells for levels of contamination with respect to certain leachate indicators. There should be another comparison made with background levels at these sites. These should be compared to present conditions to determine if there is any change of depth over time and not just changes between the shallow and deep wells. C 5.0 HYDROLOGY Flow rates from Graham Creek near the site are said to range from 30 to 2,000 Usec. The Development, Operations and Closure Report indicated a slightly different range for flow rates (Page 2-6). Which range is correct? What effect does this have on the calculations presented in determining the dilution levels provided by the creek? Fig. 13 shows the sedimentation pond which is not present on other figures in this volume. The report does not indicate what effect this pond will have on flow patterns both surficial and through the subsurface. Table 11: The reported surface water quality parameters included the most essential parameters for identifying potential water problems. The parameters included chlorides, ammonia, nitrate, total phosphorus, phenols, DOC, BOD5, iron and manganese. - 22 - The majority of results obtained from five sampling periods throughout 1988 reported satisfactory concentrations within Blue Book Objectives and Guidelines. Only the BODE parameter indicated slightly elevated concentrations with levels of 5.0 mg/L (November 4) at station SS1 and 20.0 mg/L(November 4)at station SSS. The results could be due to either improper sampling techniques and/or due to a rainfall event which could produce an inordinate amount of solids into the Graham Creek water column. Several queries resulted during the data interpretation of the surface water material that was presented including. (a) L^,,--Qt?on of SS6 was described as a ditch by Stapleton Road but was not shown on the surface water sampling locations map. (b) In Section 5.1, under Graham Creek sampling, results in Appendix "E" is mentioned as containing organochlorine concentrations. No such Appendix "E" existed in the report. 1 The surface water quality data as presented in Table 11 indicated general acceptable water quality in Graham Creek. The downstream surface water quality was comparable to upstream quality and in some instances (mean chloride concentrations), the surface water quality was improved downstream compared with upstream concentrations. 6.0 CONCLUSION The report concludes that leachate is diluted by anywhere from 20 to 300 percent as it seeps into the ground. This statement should be explained. It is unclear whether dilution is the only process by which leachate concentrations are reduced in this environment. With permeability decreasing with depth as the report indicates, how does this increase in dilution take place? - 23 - ADDENDUM A Page A-2: Samples of groundwater collector from OW102-26 indicate that there "is little or no leachate" present. The parameters were compared to other wells on-site which are not screened within the same stratigraphic unit. In order to detect any contamination, the sample should be compared to a similar non-contaminated source. If the certainty of contamination cannot be determined, the Ministry will assume the worst case. Should it be confirmed that leachate was not found at a depth of approximately 16.8 m (the elevation of OW102-26 has not been reported), it should be kept in mind that leachate has been detected between Phases 1 and 2 within observation wells OW91-5, OW93-9, OW94-9, OW95-4, OW95-13 and OW100-15 at elevations ranging from approximately 148 m to 154 m above sea level. This information should be used to determine the rate of migration through the soil. Calculations should also be made to predict further migration and changes in concentration. Observations regarding the extent of leachate staining should be included with the well logs for wells OW101, OW102 and OW103. Cross-sections incorporating the new wells should also be included. It is concluded on Page A-3 that groundwater does not appear to flow under Graham Creek to its northern side. Boreholes should be drilled to confirm this. In addition, it is (and was by the MOE previously in 1988) recommended that groundwater monitoring be considered for the area to the north of Graham Creek. This would rom ize any confusion with respect to the source of contaminants should Graham Creek be measurably impacted. There is a concern that the automobile shredder waste located at the Newcastle Recycling Limited yard to the north of Graham Creek may represent a potential contamination source. r t - 24- As discussed previously,the Sykes groundwater flow model was discredited by the MOE during a previous meeting dated March 30, 1988. It is concluded that the site overlies a compact till. No wells to the south confirm the lateral extent. Have any hydraulic conductivity values for this unit been determined? Observation well 98-21, which is partially screened in the sandy till has hydraulic conductivity of K= 4.9 z 10' (bale test). This cannot be considered impermeable. Leachate discharge has been observed below leachate collectors since their installation. The dates of sampling undertaken in 1989 must be provided for Tables 8, 9 and Appendix D. Borehole logs for all existing wells along with historical sampling data should be submitted in support of this document. 1 'TVFILL PROJECT, DUST IMPACT ANALYSIS - L AEDLAW, NEWCASTLE LANDFILL,'AS PREPARED BY CONCORD SCIENTIFIC CORPORATION (DECEMBER 19, 1989) 1. Dispersion Calculation Dispersion calculations were used to determine the dust concentrations resulting from the existing operations, and both from the existing operations plus the effects from the infill construction phase, and finally, the operation and maintenance of the infill area All results were compared with the Ontario criterion of 120 ugl&, based on a 24-hour average. These comparisons were given in Tables 3.3, 3.4 and 4.2. (a) Because the current Reg. 308, point of impingement standard (half an hour average)is still valid, and appears in Schedule 1, Reg. 308, with the value of 100 uglms, under the item No. 88 [Suspended Particulate Matter (particulate less than 44 microns in size)) all the referenced '1 J 1 - 25 - 1 tables showing the dust concentrations under the column heading "Maximum 1 hour concentration (ug/m'Y should be given quite different interpretation than the current"N/A". Note that the 1/2 hour concentrations are 15% to 20% higher than their 1 hour average equivalents (Tables: 3.3, 3.4, 4.2). (b) Based on 1(a),the worst case meteorological conditions should be extended to a broader set of conditions, including all stability classes under which the concentrations are surpassing POI standard for each individual source separately as well as for their combined effects. The calculations should be carried out on the set of points of impingement in order to show the spatial extent of the impact higher than the POI standard. 2. Emission Rates and Emission Factors All the formulas reported in Section 2.3 and 4.3.1 should be more carefully reviewed as to the accuracy. For instance: (a) The formula 4.1 EAG=49*(s)^.6 kg/hectare for estimating the emission factor for Agricultural tilling could not be found in the literature as quoted in the report. However, in the AP-42, Supplement B, September 1988, Compilation of Air Pollutant Emission Factors, Section 11.2.2.3, the following empirical expression (1)is found for agricultural tilling E=k(5.38)*(S)^.6 kg/hectare, where Aerodynamic Particle Size Multiplier, K, should be taken as 1.0 for the Total Particulate and S is silt content of surface soil W. Dr. Robert Bloxam from ARB also confirmed the validity of formula (1) from 11.2.23 EPA. Consequently, the whole Section 4.3.1 cannot be accepted as valid and accurate until it is proved contrary. 6 /1 - 26 - (b) In Table 3.1, Section 3.3.2 where the formulas for the emissions factors from Section 2.3 are related to emission rates, which are the essential input values to any dispersion model, there are some inconsistencies in referring to the appropriate equations. It is of interest, to the Consultant to carefully document the "source extent" calculations prior to converting the emissions factors to emission rates. When the results are checked, many numeric values are not completely the same as reported. The assumptions for some parameters must have been made which were not probably the same as Consultant's because they were not clearly defined. (c) Reference to the equations in the Table 3.1 should be corrected and reviewed for accuracy also.- To our understanding, equation reference 2.3 under column heading "Condition" and "Activity" item No. 1 should read 2.4 The emission rate entry for"Activity item No. 1 should be, according to Consultant's calculation 0.252 g/sec. from the "Activity", item No. 2. For "Activity" item No. 2,the emission rate value of 0.11 g/sec. from "Activity" item No. 1 should be used. Instead of equation reference 2.4, under the "Activity"item No. 2,2.5 should be entered. Further, instead of reference 2.5, 2.6 should be entered, and finally equation 2.6 should be 2.7 or its substitute Ewe = 0.04 g/ha/sec. (d) The following information should be included in the report, for better understanding of the results: (i) Under what conditions the equation 2.7 was evaluated to yield the result 0.04 g/ha/sec. Is the value of 30%, for f, the percentage of time the wind speed exceeds 19 km/hr, based on search of Trenton or Peterborough wind data. Why"Storage Pile Erosion"was not also included in the wind erosion impact assessment? (ii) Under what conditions, the value 1,543 g/vkt, "Activity" item No. 4 and No. 5, Table 3.1 is obtained when evaluating equation 2.1. (iii) Fig. 3.6, mentioned on Page 29 is not available in the report. - 27 - 1 3. Meteorology On Page 21, the Consultant came to the conclusion, after comparing Trenton and Peterborough data, that the infill site meteorology is better represented by Trenton data, because of its nearness to the lake. It should be noted that wind data from Port Hope and Oshawa are available from 1980-1989, and the wind roses for both sites are enclosed in this review, together with the Trenton wind rose, which was plotted based on the data provided by the Consultant for comparison sake. (NOTE: The enclosed wind roses are all centred in the "Origin" from the modelling grid, as given in Fig. 2.1 in the report. The wind roses have been rotated by the angle of 18 Deg. needed for Map North (direction parallel to the vertical grid lines) to go clockwise to Real North. In this case, all wind directions are real directions. Also, the plotted and tabulated frequencies show the percentage included property boundary, plotted*according to Fig. 2.1 \ from the report, serves as a reference for the comparisons of changes of impacts caused by three different wind roses on the same boundary.) "INFILL PROJECT, SOCIAL ANALYSIS REPORT- LAIDLAW NEWCASTLE LANDFILL,"PREPARED BY THE INSTUUTE OF ENVIRONMENTAL RESEARCH; DATED DECEMBER 1989 Scope of Social Analysis The scope of the analysis appears to be adequate for an application made under the Environmental Protection Act (EPA). Scope of Economic Analysis While the document is entitled "social analysis", there are several references to "economic analysis". The economic environment is not equivalent to the social environment, under either the EPA or the Environmental Assessment Act J () - 28 - The economic environment should not be limited to "employment opportunities and requirements for local goods and services" (ref. p. iv). As with the social impact analysis, an assessment of the baseline economic environment would be useful. What is spent, or what revenue to the Community is generated, by reliance on the local goods and services noted in Section 6.0? Is Laidlaw the only customer? What is the economic growth potential of the region? Impacts on the natural environment may also have impacts on the economic environment in terms of the quality of the local environment, the value of produce and livestock, the value of other economic enterprises,property values, eta as well as employment. The interest of the Ministry is the valuation of environmental impacts from the proposed undertaking and its alternatives. What is the support for the contention that if the "Infill Project not proceed, eight existing jobs would be lost and goods and services from the local area would no longer be required" (ref. P. v). Also,what is the basis for the assumption that "an increase of up to 10% in requirements for the purchase of local goods and services is expected" (ref. Page 21). Elaboration on the conclusion that "municipal, commercial and industrial customers using the landfill site, as well as prospective users,would have to dispose of their waste on another location, potentially incurring increased cost and inconvenience" if the project is not approved (ref. Page 17) is required. What are the comparative costs? Data Collection and Conclusion The choice not to include an assessment of individual-based impacts is problematic. The Consultant has identified 551 potentially impacted residents yet none of these residents were specifically studied to determine the impacts of this infill project and the significance of extending the life of the site, especially in terms of impacts on health and safety. - 29 - One important issue that appears to have been cursory mention is the fact that the Community was prepared to contend with a landfill site for a specified period of time - until 1990 and now the facility could potentially be expanded. The social impacts then occur as a result of doing nothing(letting the landfill close in 1990) compared with continued landfilling for two more years. By arguing that infill operations would not be marginally more than existing operations, the Consultant has not adequately taken into account the alternative of not expanding the site. For example, infill traffic may only represent a 10% increase over existing traffic flow, yet the Community would not have to entertain,the existing level or the 10% increase should the facility be closed in 1990. Therefore, the impacts of the infM opar tion should be a comparison against the null alternative not the existing use of the site. The data on which the conclusion: "...disruption of activities and use and enjoyment of residential property is anticipated to be minimal" (Page 12, Section {.1.6) should be clearly stated. The data preceding this conclusion are essentially generic descriptive } accounts of landfill sites and experiences associated with them. It is recognized and J accepted that this is not a complete social impact assessment as required under the EA Act; nonetheless, the social impact assessment should be specific to this site. 1 0 Attachment 2 January 9, 1991 Mr. John D. McDermott, M.C. 16P. Principal planner McDermott & Associates Limited Pickering Corporate Centre 1305 Pickering Parkway Suite 406 Pickering, Ontario LIV 3P2 Dear Mr. McDermott: Having received your letter of November 91 1990, I would like to take this opportunity to update you on the position of the Ministry of Municipal Affairs with respect to the request by Laidlaw Waste Systems Ltd. to refer a proposed official plan amendment to the Ontario i Municipal Hoard. I recall, in previous correspondence you were advised that comments w0cre still outstanding from the Ministry of the Environment, the Region of Durham and the Town of Newcastle. We have now received comments from the Approvals branch of the Ministry of the Environment regarding Laidlaw's technical reports submitted in support of the Part v application made pursuant to the Environmental Protection Act. In a letter to Mr. M.J. Pullen of Laidlaw Waste Systems Limited dated December 41 1990, Mr. J. R. Bray, Director of the Approvals Branch of the Ministry of the Environment, concluded by recommending that the (Part V) "application not be forwarded to the Environmental Assessment Board until such time as the outstanding issues are satisfied". on the basis of Mr. Bray's letter, it would appear there are a number of outstanding issues which must be satisfied if the Part V application is to be recommended for referral to the Environmental Assessment Board. (! /2 �l_ °Z- Mr. John 12erwtt. As a result, until such time as we are advised by the Ministry of the Environment that the Part V application may proceed to the Envirornmental Assessment Board and we are in receipt of comments from the Town and Region, we will not be in a position to refer Laidlaw's proposed official plan amendment to the Ontario Municipal Board. In closing, it is my understanding that both the Environmental Assessment Board and the Ontario Municipal Board have beef► notified of your application for a consdlidated hearing pursuant to the Consolidated Hearings Act. Howaver, we have also been advised that tha Consolidated Hearings Board will not be in a position to schedule a hearing at which the Part V application and the official plan amendment application may be considered until such time as these two matters are referred to the Environmental Assessment Board and the Ontario Municipal, Board respectively. f, If you would like: to discuss this matter, please call my office so that we may arrange a meeting. Yours truly, Brian D. Riddell VV ,r Assistant Deputy Minister a.o. Mr. J. p. Bray, Ministry of the Environment z Victor Doyle/mf (PAS G & SW) ki seq. R0075 'j INISTRY OF MUNICIPAL AFFW PC' JAN ASSISiA,�, Licr.1, h'JWIPAL OPERATIONS , I Attachment # 3 WASTE SYSTEMS LTD f` 3410 South Service Road LPrLI P O Box 5057, Station A �rol(`;� ��,���"-���-�,T Burlington Ontario L7R 3Y8 Burlington 416 333-5011 Toronto �416� 826-3200 Fax (416) 333-5027 January 4, 1991 Corporation of the Town of Newcastle', 40 Temperance Street, Bowmanville, Ontario, L1C 3A6 Attention: Janice Auger Szwarz, Senior Planner Dear Ms. Szwarz, Re: Laidlaw Landfill, Newcastle, Ontario Infill Project, E. P. A. Part V The Ministry of the Environment has submitted its comments on the submitted document to us and our consultants have prepared a response to the comments. The comments are being held up at present by the delay in setting up a meeting with the Regional Hydrogeologist to clarify his comments. The documents will be submitted to you in the very near future after they have been submitted to the Ministry of the Environment. As you are aware the comments are largely to do with the hydrogeology of the site and have been addressed by the work that has been going on, on the site in the last year. These matters will be reviewed with the Ministry of the Environment in due course. You may wish to attend those meetings with a view to tabling your comments on hydrogeology. -/2 1 - 2 - Jan1ce Auger Szwarz January 4, 1991 At a meeting with the Ministry of the Environment on Dec 11, 1990 no land use planning issues were noted that would prevent a vacated pipeline easement from being used as landfill footprint. Neither Mr Frank Wu, of your office, or yourself were prepared to comment, pro or con, on Land Use issues to our consultants on Oct. 16, 1990. It is Laidiaw's understanding that Mr. Wu and yourself concur with the Ministry as to the Land Use issues on this project. Laidlaw is requesting clarification of Mr. Wu's contention that Hydrogeology has to do with land use in this instance. His letter of Sept. 11, 1990 to Mr. John Kennedy, is not explicit enough for our consultants to address the matter to your satisfaction. In addition, you could be most cooperative by releasing a copy of the the Acres review report and staff comments on the Hydrogeology Report and implied Land Use Planning concerns. It would also be helpful if Laidlaws' consultants could talk directly with Acres, acting on your behalf, to clarify a number of issues. Finally Laidlaw wishes to be copied on all correspondence, meeting notes, and reports that concern our landfill. It is evident that copying Laidlaw used to occur but that for some reason it has ceased. Please rectify this matter. Yours sincerely, LAIDLAW WASTE SYSTEMS LTD. M. J. Pullen P.Eng. Regional Engineer CC. D. Hefferon, Municipal Counsel A. Van Warmerdam, Ministry of the Environment J. Sharpe, Region of Durham, Planning Department B. Bennett, Acres International J. McDermott W. Pinkerton D. Lemieux .. .--,r own Of Attachment # 4 CONiARO January 18, 1991 Mr. MJ. Pullen, P. Eng. Regional Engineer Laidlaw Waste Systems Ltd. 3410 South Service Road P.O. Bog 5057, Station A Burlington, Ontario L7R 3Y8 Dear Sir. RE: Official Plan Amendment Applies -File: 89-39/D Rezoning Application -File: DEV 89-44 Laidlaw IaSII Proposal i I C This is in response to your letter of January 4, 1991 to Ms. Janice Szwarz in respect of the above - J referenced application. In your letter,you indicate that your consultants have prepared a response to the Ministry of the Envi onmenVs comments on the Infill proposal. It would be appreciated if the documents referenced in your letter could be submitted to the Town concurrent with their submission to the M'in'istry of the Environment to avoid any unnecessary delay in our review of your application. For the present,Town Staff have not planned to attend any meetings between yourself and the Ministry of the Environment to discuss site hydrogeology. However, it is requested that the Town be given adequate notice of any meetings with Ministry staff and be provided with the meeting notes. I read with interest,your statement that Ms. Szwarz and I"concur with the Ministry (of the Environment) as to the Land Use issues on this Project".We were.not in attendance at the meeting with the Ministry on December 11, 1990, nor were we copied with the meeting notes. Therefore, we have no knowledge of the specific issues discussed at that meeting. It would be helpful if you would provide us with any meeting notes for this meeting that you may have. With respect to your request for clarification of our position that the hydrogeology of the Laidlaw site is relevant to the question of land use, we think it is self-evident that, in assessing the appropriateness of any proposed development, the potential negative effects on the natural environment must be identified and evaluated. I note that our position on this matter was indicated to Mr. John Kennedy and Mr. John McDermott at our meeting of October 16, 1990. C CORPORATION OF THE TOWN OF NEWCASTLE 40 TEMPERANCE STREET • BOWMAI,. LLE • ONTARIO - L1C3A6 - (416) 623-3379 • i-AX623-4169 -C.0 P'rcn Page 2. We are surprised to now hear from you that your consultants do not understand what information was requested in my letter of September 11, 1990. I note that my request was further clarified by Ms. Szwarz in a letter to your consultant dated October 25, 1990. Your letter of January 4, 1991 is the first indication we have had that your consultants require even further clarification with respect to our very explicit request. Could you have your consultants contact either myself or Ms. Szwarz as soon as possible to identify the precise problems that they are having in responding to my request. You also make reference to the "Acres Review Report". As we have indicated to you previously, Acres cannot complete their work evaluating your consultant's studies until you or yew consultants provide the information requested in my letter of September 11, 1990. Sincerely, Franklin Wu, M.C.LP. Director of Planning and Development r JAS*FW*df l cc: L. KotseA C.A.O. D. Hefferon, Municipal Counsel A. van Warmerdam, Ministry of the Environment J. Sharpe, Regional Phannin o B. Bennett,Acres International J. McDermott, McDermott & Associates W. Pinkerton, Marshall Macklin Monaghan D. Lemieux, Fogler Rubinoff ) o I Attachment # 5 AMW a 1 WASTE SYSTEMS LTD 3410 South SFrvice Road P 0 Box 5057, Station A eurtirtgton, Ontario t_7R 3Y8 Guriington (416) 333-5011 Toronto (416) 826-3200 Fay (416) 333-5027 j October 3 , 1990 Ministry of the Envirgnment, Approvals Branch 1 250 bavisville AVe. , Toronto, Ontario I M4 S 1H2 Attention : Mr Jahn Bray, P.Eng, Director I 1 Dear Sir, Re; Laidlaw Lendf�lll Newcastle, Ontario Request for an Emergency certificate of Approval Certificate of Approval Number A390305 Laidlaw thanks yoit for the opportunity of discussing withlyou the request for an Emergency Certificate of Approval on the I above noted Landfill Site. The document prepared by Henderson and Paddon entitled Proyosed TTandfi11� Slope Modifications is the intent of th� application and r4resents the final contours that would result for a further 53 to- 56 weeks of life For the site of the presently licensed tonnages. It is anticipatedithat given a timely submission of comments on the pending Part V E.P.A. application that this would dive Laidlaw sufficient time to get to a hearing for a further (two years of life on he site. Please feel free to contact Mr. Frank Ford of Henderson j Paddon if there i,I s further information that you require. Laidlaw is presently checking the survey that was carried out on 1990 10 01 to verify that the remaining capacity is within three weeks of completion. The north mound is complete with final cover topsoil and is seeded. The active face is on the south mound and is very close to completion. � � I - 2 - ' � I Mr. John Bray October 3 , 1940 r I you have any estions, please contact the undersigned i or Mr. Ron Poland ( 16-336-5151) or Mr. Michael Walters, r District Landfil Manager (416-333-5011) Yours sincerely, LAIDLAW WASTE S+EMS LTD. f ' M. J, Pullen P.E fig. II Regional Engineer cc. R.J. Poland, vice President of Environmental mangemenrt Bruce Cook, Acting Regional Vice President I Frank Ford, Henderson Paddon and Associates Limited Jack Marsh, egional Landfill Manager Michael Walt Irs, District Landfill Engineer Don Tefft, Division Manager DUR 07 f r I c i i I I I E I t t f E ` - + i ' I I � I - I i Attachment 6 T�wastfi E TO�I N OF e ONTARIO February 5, 1991 Mr. Gary K Boretski Abatement East Section Central Region Ministry of the Environment 7 Overlea Boulevard, 4th Floor Toronto, Ontario M4H 1A8 Dear Sir: RE: LAIDLAW LANDFILL.SITE- TOWN OF NEWCASTLE PROVISIONAL C8RTIFICAT$OF APPROVAL NO. A39M As you are aware, Laidlaw Waste Systems has been claiming for some time now that their existing landfill operation in the Town of Newcastle is very dose to reaching its approved final contours. Most recently, Mr. M. Pullen of Laidlaw, in his letter of October 3, 1990 (copy attached) to Mr. John Bray of your Ministry regarding Laidlaw's request for an Emergency Certificate of Approval, stated that the south mound on the site is within three weeks of capacity. However, as of today's date, the site is still open and receiving waste. By letter dated August 24, 1990 (copy attached), I requested confirmation from your Ministry as to the operational status of the north and south mounds of the Laidlaw site, the existing elevation on the south mound, the maximum allowable elevation permitted for the south mound under the existing Certificate of Approval, and the tonnes of capacity available on the south mound. I note that the information requested in my letter has not been provided to date. The Town of Newcastle is most anxious to ensure that the Isidlaw site is closed once its maximum allowable contours have been achieved. Therefore,please provide the information requested in my letter of August 24, 1990 as soon as possible. Sincerely, ,danice uge zwar , or Planne ,Strategic Branch *ff D. Hefferon, Municipal Counsel J. Sharpe, Region of Durham Planning Department CORPORATION OF THE TOWN OF NEWCASTLE 40 TEWPERANCE STREET • BOWMANVILLE • 0hTAR10 • L1C 3A6 • (416) 623-3379 FAX 623-4169 �cvci®rya