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HomeMy WebLinkAboutPD-147-83 610 - 4 CORPORATION OF THE TOWN OF NEWCASTLE PLANNING AND DEVELOPMENT DEPARTMENT T.T.EDWARDS,M.C.I.P.,Director HAMPTON,ONTARIO LOB 1JO TEL.(416)263-2231 REPORT TO THE GENERAL PURPOSE AND ADMINISTRATION COMMITTEE MEETING OF OCTOBER 17 , 1983 REPORT NO. : PD-147-83 SUBJECT: REVISED APPLICATION TO AMEND DURHAM REGION OFFICIAL PLAN - REGIONAL RECLAIMERS LTD. PART LOTS 11 12, CONCESSION 3, CLARKE FILE: 83-8/D RECOMMENDATION: It is respectfully recommended that the General Purpose and Administration Committee recommend to Council the following: 1 . That Report PD-147-83 be received; and 2. That the Region of Durham be advised that the Town of Newcastle recommends that revised Official Plan Amendment Application 83-8/D, submitted by Regional Reclaimers Ltd. to permit a Waste Disposal Site on i approximately 40 hectares (99 acres) in Part Lot 11 and 12, Concession 3, former Township of Clarke, be denied ; and 3. That the Region of Durham and the applicant be provided with a copy of Staff Report PD-147-83 and Council 's decision. 4, . . .2/ REPORT NO. : PO-147-83 Page 2 BACKGROUND: On September 8, 1983, the Region of Durham advised the Town of Newcastle that Regional Reclaimers Ltd. had submitted a revised Official Plan Amendment application (File : 83-8/D). The original application, submitted by Regional Reclaimers on March 11 , 1983, proposed redesignating a 129.19 hectare (319.23 acre) parcel of land in Part Lots 11 and 12, Concession 3, Clarke Township, to permit a waste disposal facility. This parcel was also a subject of a rezoning application (File: DEV 82-36) submitted by Regional Reclaimers to the Town of Newcastle on December 9, 1982. As well , on January 31 , 1983, Regional Reclaimers Ltd. submitted an application to the Ministry of the Environment for a Certificate of Approval for a 40 hectare (99 acre) expansion of their landfill operation. A Hydrogeologic Study and a Landfill Design and Operation Study was submitted to the Ministry in support of the application . At its meeting of May 30, 1983, the General Purpose and Administration Committee considered Staff Report PD-74-83 which dealt with both the rezoning and official plan amendment applications submitted by Regional Reclaimers. Report PD-74-83 recommended that the rezoning and official plan amendment applications not be approved at that time as they are considered premature pending the resolutions of a number of concerns related to the proposed waste disposal site. Committee resolved (Resolution ##GPA-479-83) to adopt the recommendations in Staff Report PD-74-83. Subsequently, Council at its meeting of June 13, 1983, resolved (Resolution ##C-413-83) to adopt a slightly amended recommendation; however, the recommendation adopted by Council still indicated the rezoning and official plan amendment applications were premature. . . .3/ i REPORT NO. : PD-147-83 Page 3 In a letter to Regional Reclaimers, dated duly 13, 1983 * (attached), the Ministry of the Environment indicated that the application and supporting documents submitted by Regional Reclaimers for a Certificate of Approval for the proposed expansion of their landfilling operations do not meet the current requirements of the Ministry and as such, Ministry staff would not be prepared at that time to recommend approval to their Director or provide favourable comments. Staff note that Regional Reclaimers , in their application to the Ministry of the Environment, proposed that the expanded landfill operation cover approximately 40 hectares (99 acres). The revised official plan amendment application recently submitted by Regional Reclaimers proposes to redesignate only that area which is proposed for land- * filling (see Key Map attached). COMMENTS Staff note that the recommendations from Report PD-74-83 that the rezoning and official plan amendment applications were premature, were based on the argument that a number of concerns regarding the proposed landfill expansion had yet to be resolved. One of the most serious of these concerns related to the possibility of Graham Creek and/or the groundwater system becoming contaminated by materials leeching out of the landfill . Staff attempted to address this concern in Report PD-74-83. However, it was noted in the report that there are many complex environmental issues that require consideration when accessing the proposal submitted by Regional Reclaimers and on which the Town , out of necessity, . . .4/ i I REPORT NO. : PO-147-83 Page 4 must defer to the Ministry of the Environment or other Authorities for consideration. As noted earlier in this report, the Ministry of the Environment has indicated to Regional Reclaimers that their proposal as submitted to the Ministry does not meet Ministry standards. Therefore, based on the Ministry of the Environment 's decision related to the Regional Reclaimers application for a Certificate of Approval , it is recommended that the Town of Newcastle recommend to the Region of Durham that revised Official Plan Amendment Application 83-8/D be denied. Respect mitted, T.T. Edwards, M.C.I.P. erector of Planning //September AS*TTE*jip 30, 1983 *Attach. Applicant: Regional Reclaimers Limited P.O. Box 358 NEWCASTLE, Ontario LOA 1HO Mr. Richard J. Hassard, Q.C. Suite 2500 Box 105, 401 Bay Street TORONTO, Ontario M5H 2Z6 Smith & Lyon Barristers & Solicitors Box 420 Exchange Tower 2 First Canadian Place TORONTO, Ontario M5X 1J3 ATTENTION: Mr. Douglas Hatch i i July 13, 1963 ---�� ECEIVED Regional Reclaimers Ltd. , JUL 191983 Box 358, Newcastle, Ontario. ry LOA lH0 ATTENTION: MR. J. W. BALE General Manager Dear Sir: Re: Hale Site Expansion Proposal A 390305 ! Regional Reclaimers Limited, Newcastle ! A meeting was held on December 15, 1982 at the Ministry of the Environment office, 135 St. Clair Ave. West, for a presentation of the hydrogeologic report for the I above—mentioned proposal. An application and two reports (as supporting documents ) were submitted to the Ministry for review. The two reports are Hydrogeologic Study, Proposed Landfill Expansion, by Morrison Beatty Limited, and Landfill Design & Operations by H. Mooij & Associates Limited. The Hydrogeologic Study Report was presented by Mr. B. W. Beatty, and a general discussion followed. Mr. P. S. Isles outlined the Ministry requirements with respect to a review of an application for a waste disposal site. It was during the general discussion period that a discrepancy was noted between the application and the Operations Report. In that situation it was indicated on behalf of the company that the reports rule and the application would be revised accordingly. The revised section of the application was received on January 31, 1983. Application Review The applicant is Regional Reclaimers Limited, located in Newcastle, Ontario. The company is operated by Mr. Walter John Hale as president and Mr. James W. Hale as general manager. The present land use and zoning category is agricultural. Regional Reclaimers Limited intends to service the following municipalities; City of Oshawa, Town of Newcastle, Town of Port Hope, Town of Whitby and Township of Hope, with a total population estimate of 200,000. General Motors Ltd. is the major industry to be served. The toal area to be filled is 40 hectares within a total site area of 170 hectares. The capacity of the site is estimated to be 5 million tonnes with a life expectancy of 18 years. I I ydrogeologic Study Report Review This report has been reviewed by Ministry staff who have commented according to their particular areas of concern. The following is a discussion of all the concerns raised, divided into three major areas : hydrogeology (groundwater protection and monitoring ) , surface water management and its relation to Graham Creek, and leachate handling and treatement. Hydrogeology The following are the major concerns regarding the site hydrogeology. The minor and more detailed concerns are not included herein as they may be discussed in a meeting with the consultant at a later date . 1. The rate of leachate production stated in the report only considers recharge through the top of the landfill. Ground-water seepage from the sides and bottom of the excavation would also contribute a significant amount to the leachate production rate and should be addressed. 2. The effect that the landfill would have on existing ground-water conditions has not been addressed in the report. The direction of ground-water movement and the shape of the water table surrounding the landfill excavation would change as a result of the construction of the landfill. This is because the landfill excavation would be in most places 6 to 8 m below the water table and the-refore the excavation would act as a large drain. One possible consequence of this is that the ground-water on either side of the i landfill would be sufficiently lowered by the excavation such that a rise in leachate levels after landfilling could i cause a reversal of the ground-water gradient. This would result in the radial flow of leachate away from the excavation, including towards the wells to the east. Leachate recirculation would add to this problem. 3, A complete overall picture of the existing ground-water conditions cannot be developed due to the complexity of the drumlin stratigraphy and static water levels not available for some wells. The sand zones in wells 14, 15, 19, 20 and 24 may be continuous . If so, it seems possible that leachate could flow from Well 19 towards Well 24 and from Well 24 offsite to the west as indicated on i CIPnl 11c71 o nrnca-col.1-i i.,-, P-W 1 i i 3 - 4. The cross sections do not provide the equipotential lines that are necessary to draw the flowlines. 5. It is not apparent why the leachate holding basin is sized for 10 cm infiltration and not the expected annual leachate production rate. 6. The possibility that the leachate from the existing site could be less concentrated than that from the new site, should be qualified when assessing the results of the testing program for the suitability of the leachate treatment system for the new site. 7. It is not apparent from the report which wells indicate the presence of a lower flow system (heads below creek level ) . 8. It is not evident how the consultant obtained the estimate for the 25 m depth of the local flow system. The report does not discuss the effect the landfill excavation would have on this local flow system. 9. The static water levels and piezometer construction details for the 1975 series of monitoring wells were not provided. These would be useful in assessing the value of the monitoring data for the existing site. 10. The report states on Page 1-7 that Well 31/81 could not be affected by the existing landfill. However, the water level data from Well 4/75, OW29/81 , OW30/81 and OW31/81 indicate that OW31 is downgradient from the existing landfill. It is not clear, therefore, why it would not be affected. f 4 - 11. The statements made on Page 1-7 regarding the amount of attenuation with distance would only apply if the core of the leachate plume was being sampled. Whether or not the existing ground-water monitors sample the core of the existing leachate plume has not been established in the report. 12. It is not evident from the report whether or not the various pipelines at the north toe of the landfill are below the water table. This information is necessary to help judge their importance, if any, in controlling leachate flow. Surface Water Component and Graham Creek The following are comments and concerns regarding the surface water component of the study and implications �o Graham Creek. 1. Ministry of the Environment 's Provincial Water Quality Monitoring Station (06-0118-001 ) is not located at the first bridge upstream of the Town of Newcastle as stated in the report /. (p.H-1) . This station is located at the first bridge upstream of the mouth of Graham Creek, which is downstream of the Town of Newcastle. Data from the station may not reflect the quality of Graham Creek in the vicinity of the proposal due to inputs from the urbanized 'i area. 2. Ministry of the Environment does not have an ammonia guideline of 0. 02 mg/L as stated in the report (P. H-3) . It has an un-ionized ammonia objective of 0. 02 mg/L. This objective is not exceeded at the Provincial Water Quality Monitoring Station. I - 5 - 3. The report fails to mention that Graham Creek has an annual spring run of rainbow trout. Information currently available from the Ministry of Natural Resources (MNR) indicates that these fish spawn in the tributaries of Graham Creek upstream of the proposal . It is MNR's intention to continue managing Graham Creek as a coldwater fishery. 4. The report, with respect to leachate from the existing site concludes ". . . however, there has been no measurable impact on Graham Creek" (p.3 ) . Only 3 sets of samples have been collected from Graham Creek in the vicinity of the existing site (Nov. 18, 1981 , Oct. 6 & L8, 1982) . The upstream sampling location on the first two sampling dates was located adjacent to the eastern boundary of the site. Based on the groundwater flow direction this station may be within the zone of influence of leachate from the existing site, and thus poorly situated to reflect upstream quality. This station needs to be supplemented with two additional stations, located upstream on the two tributaries , as was done on the third sampling date. The limited available, valid data generally supports the consultants conclusion regarding impacts to Graham Creek from the existing site. However, please note that between November 1981 and October 1982 phenol concentrations at test well OW 6/75, the closest test well to Graham Creek, increased from 150 to 1120 ug/L. The concentration of phenols in Graham Creek increased from less than 0.02 ug/L in the tributaries upstream of the site to 1.2 ug/L downstream of the site in samples collected on October 18, 1982. The Provincial water Quality Objectives for phenol is 1.0 ug/L. This data is insufficient to base conclusions on, and identifies the need for additional monitoring to determine more precisely the impact of the existing site on Graham Creek. i i - 6 - I 5. Based on the limited available water quality data from the hydrogeological report Graham Creek, upstream of the existing site is a Policy I stream according to all of the I Provincial Water Quality Objectives for which the data was provided. The quality of a i Policy I stream must be maintained at or above the objectives . 6. The 7Q20 flow of 40 L/sec still requires to be verified by Ministry Regional Staff. Should this flow be accepted, the available design flow for leachate assimilation in Graham Creel-, is 26 .4 L/sec. A reserve equal to one third of the 7W20 flow is imposed to provide for future downstream uses and a buffer for the existing Coldwater fishery. Leachate Handling and Treatment The report proposes a relatively new method of treating leachate. The proposed system will first be discussed, followed by the concerns raised. The internal landfill drainage is expected to be toward the north, i.e. , the leachate may be collected at the north toe of the berm without placing underdrains. Tile collectors can be installed at this location to intercept the leachate. The leachate is then routed through an aeration/marsh channel and recharged into beach deposits at the north edge of- the landfill area. A storage basin to be installed between the tile collectors and the aeration/marsh channel to regulate flow. The proposed leachate treatment system is comprised of the following: 1. leachate tile collectors from below the north toe of landfill area 2. holding basin within landfill for flow regulation 3. aeration/marsh channel-gravity drainage from basin (north toe) to recharge facility 4. a gravity leachate recharge facility The aeration/marsh channel is to provide the ,pretreatment of the leachate. The dimensions proposed are 200 to 300 metres in length, 2 metres in width and 1 metre in depth , with a 0. 5 percent gradient. The t-`reatment of the leachate will he in the north-central area of the site immediately east of the existing landfill area, where there are dry beach sands at the e I - 7 A number of major concerns have been raised regarding the proposed leachate handling and treatment system and are listed below: i 1. The leachate tile collector system has not been shown on a plan indicating location of the drains and general detail of installation. 2. The location of the holding basin has not been shown and its connections with the tile collector and aeration/marsh channel. 3. The method of pretreating leachate using an aeration/marsh channel has not been used to date. Aeration/marsh channel facilities have been tested and continue to be tested by the Ministry of the Environment for pretreating municipal wastewater only. This wastewater has a BOD in the order of 200 ppm. One such test site, also referred to in the hydrogeological study report, is the Town of Listowel, Ontario. In October, 1981 the Ministry of the Environment made a presentation regarding Sewage Effluent Treat- ment in an Artifical Marshland which specifically described the first full year operation of the Listowel test site. In the discussion of the results , it was pointed out that the results were preliminary in nature and that further, long term studies are required to confirm conclusions drawn. The hydrogeoloic report refers to six existing landfills where information on observed leachate treatment in open ditch was the basis for the aeration/marsh channel proposal . They are: Burlington, Maitland (Dupont site ) , Brockville, Stoney Creek, Listowel, and Cobalt. An investigation conducted in 1978 at the Old Burlington Landfill Site noted outbreaks of leachate along the southern toe of the site. The leachate was being discharged into the swampy headwaters of a small stream. There was an improvement in leachate quality after passing through this swampy area, however the ratio of leachate to base flow in the stream was low, and it passed through approximately 400 m of swamp where additional dilution from groundwater inputs was provided in addition to uptake by the swamp vegetation. Maitland (Dupont) is not a landfill site but a test for treatment of wastewater and sludge used for breeding poplar trees. - qq _ V I The report is not clear as to what references i are made regarding the Brockville and Stoney Creek sites. The study in Listowel, as discussed earlier herein, was for marsh channel treatment of f sewage effluent. Northern Ontario Industrial Affairs conducted studies in Cobalt for treatment of sewage effluent. Data or significant information on the operation has not been provided to the Ministry of the Environment. A field study conducted in 1978 on the impact of leachate outbreaks from the Nelson landfill site, Peterborough, on the adjacent swamp noted zones extending approximately 700 m from the SW & NE leachate springs where all swamp vegetation within the main flow channel have been eliminated. Leachate strengths measured near their source varied from 150 to 7000 mg/L BOD. Based on this experience, leachate at or I near "full strength" may be potentially lethal ito marsh vegetation. j The information and results from tests on i aeration/marsh channel treatment of sewage I effluent available to date are still experimental. Further, there is no information which can be used to verify the effectiveness treating leachate with an aeration/marsh channel. It was pointed out at the meeting of December I 15, 1982 that new concepts introduced in landfill sites or any operation to be approved by the Ministry of the Environment requires background supporting pporting information relating to i actual practical applications. The report does not provide the required supporting information. 4. Similar to number 3 above, substantial information and practical application of soil I attenuation as a system for treating leachate is lacking. The information provided in the report on the design or engineering of the proposed system is insufficient to verify the ieffectiveness of leachate attenuation by the beach sands . i I i �i 9 - Design and Operations Report Review This report has also been reviewed by Ministry staff and the following are comments regarding the Landfill Design and Operations Report. 1. There are no plans or cross-sections showing the bottom elevations of the proposed landfill. The description regarding trench depth is not clear as outlined on page 27, 8.2 Trench Sizing. Plans are necessary to help predict what hydrogeologic conditions would be intersected by the excavation and how these conditions would change in response to the landfill. 2. The watertable lies approximately 2.5 metres below existing ground surface at the proposed landfilling area. Based on section 8. 2 of the report, it seems that the trenching operations will be below the groundwater table. This together with the upward gradient which exists at the landfill area may present construction and operation problems. The handling of groundwater during the trenching operations should be discussed. 3. It should be noted that the ground-water flow directions on Plan A and Plan C do not represent the leachate flow directions. i 4. The composition of the paint sludge expected from General Motors as described i Section n 6 .2 of the report constitutes 2. 6% of the total. Information on the remaining 97.4% of the sludge should be provided. i 5. The Township of Percy is presently being served by the existing site. The report does not list the Township of Percy as a municipality to be serviced by Regional Reclaimers Limited. A statement confirming this should be noted. 6. In the event that the leachate attentuation I system proposed does not operate as expected, contingency systems for leachate collection and handling are required. General layout and operation plans for the contingency systems should be provided at this time. I I � i 10 - 7. A plan indicating precisely the location of j the total site area of 170 hectares and the I disposal area of 40 hectares is required . i 8. Plans indicating the incorporation of the existing site with the proposed expansion site I are required for the longterm site development and operation. The plans should include leachate handling and collection systems, site maintenance , and final use proposals . I 9. Funding requirements should be confirmed as requested in Section 12 of the Design and Operations report at this time. - I I i Conclusion f The application and supporting documents for a I Certificate of Approval for the proposed expansion landfilling operations by Regional Reclaimers Limited have been reviewed by the Ministry of the Environment. It is considered that the proposal as presented by the I supporting reports does not meet the current requirements of this Ministry, and as sucYi, staff would not be prepared at this time to recommend an approval ito our Director or provide favourable comments. In particular, the documentation does not adequately substantiate the viability of the proposed leachate I handling and treatment system. There is concern that the information available regarding the proposed handling and treatment system is of an experimental nature and not totally applicable to leachate from landfilling sites . Further, the contingency plans prepared are merely a list of technologies that are available and not an evaluation of whether one or more are technically viable. i i If you wish to discuss possible amendments, alternatives , or any of the above stated concerns , please contact me at 965-6421. Yours truly, P.S . Isles, Supervisor, Waste Sites & Systems Approvals Unit, Environmental Approvals Section. LM/dms c. c. H. Mooij - H. Mooij & Associates Limited B. W. Beatty - Morrison Beatty Limited R. J. Hassard Ministry of Natural Resources Regional Municipality of Durham Town of Newcastle Citizens Group I I KEY MAP FORMER TOWNSHIP OF CLARKE LOT LOT 6T I 15T I LOT I LOT LOT LOT LOT LOT LOT LOT LOT 13 12 1 11 z l 10 I g g I 7 I 6 I I i I I t o # CROOK16 I U 1 CREEK , I ORIGINAL I APPLICATION ATION I . ... REVISED Z APPLICATION I O ... _ - -- -T - - - - - - - x'�r' _ I I I I I I I ( I I I I I I I I i I I I 1 I I I I i I 1 I I i I I 1 I I I I I I I ( I I I I I I 1 0 I t o I I I 1 I I I U I I I 1 NE TON1i ILLI I r 0 250 500 1000m 500 I CORPORATION OF THI TOWN OF NEWCASTLE PLANNING AND DEVELOPMENT DEPARTMEN T.T.EDWARDS,M.C.I.P.,Director HAMPTON,ONTARIO LOB 1J0 TEL.(416)263-2231 REPORT TO THE GENERAL PURPOSE D ADMINISTRATION COMMITTEE MEETING OF OCTOBER 17 , 1983 REPORT NO. : PD-147-83 SUBJECT: REVISED APPLICATION TO AMEND DURHAM REGION OFFICIAL PLAN - REGIONAL RECLAIMERS LTD. PART LOTS 11 & 12, CONCESSION 3, CLARKE FILE: 83-8/D RECOMMENDATION: It is respectfully recommended that the General Purpose and Administration Committee recommend to Council the following : 1 . That Report PD-147-83 be received ; and 2. That the Region of Durham be advised that the Town of Newcastle recommends that revised Official Plan Amendment Application 83-8/D, submitted by Regional Reclaimers Ltd. to permit a Waste Disposal Site on approximately 40 hectares (99 jcres) in Part Lot 11 and 12, Concession 3, former Township Clarke, be denied ; and 3. That the Region Durham and the applicant be provided with a copy of Staff port PD-147-83 and Council 's decision. I i i . . .2/ REPORT NO. : PO-147-83 Page 2 BACKGROUND: On September 8, 1983, the Region of Durham advised the Town of Newcastle that Regional Reclaimers Ltd. had submitted a revised Official Plan Amendment application (File: 83-8/1)). The original application, submitted by Regional Reclaimers on March 11 , 1983, proposed redesignating a 129.19 hectare (319.23 acre) parcel of land in Part Lots 11 and 12, Concession 3, Clarke Township, to permit a waste disposal facility. This parcel was also a subject of a rezoning application (File: DEV 82-36) submitted by Regional Reclaimers to the Town of Newcastle on December 9, 1982. As well , on January 31 , 1983, Regional Reclaimers Ltd. submitted an application to the Ministry of the Environment for a Certificate of Approval for a 40 hectare (99 acre) expansion of their landfill operation. A Hydrogeologic Study and a Landfill Design and Operation Study was submitted to the Ministry in support of the application. I At its meeting of May 30, 1983 the General Purpose and Administration Committee consi : red Staff Report PD-74-83 which dealt with both the rezc -.,ig and official plan amendment applications submitt by Regional Reclaimers. Report PD-74-83 recommended th the rezoning and official plan amendment applications no oe approved at that time as they are considered premature iding the resolutions of a number of concerns related to ! proposed waste disposal site . Committee resolved (Res ition #GPA-479-83) to adopt the recommendations in Staff R )rt PD-74-83. i Subsequently, Council at its in .ing of June 13, 1983, resolved (Resolution #C-412-83 :o adopt a slightly amended recommendation; however, the r )mmendation adopted by Council still indicated the re—ning and official plan amendment applications were premature. REPORT NO. : PD-147-83 _T 3 _a(� In a letter to Regional Recla -ors , dated July 13, 1983 * (attached) , the Ministry of t Environment indicated that the application and supportin locuments submitted by Regional Reclaimers for a Cer ficate of Approval for the proposed expansion of their landfilling operations do not meet the current requirements of the Ministry and as such, Ministry staff would not be prepared at that time to recommend approval to their Director or provide favourable comments . Staff note that Regional Reclaimers , in their application to. the Ministry of the Environment , proposed that the expanded landfill operation cover approximately 40 hectares (99 acres). The revised official plan amendment application recently submitted by Regional Reclaimers proposes to redesignate only that area which is proposed for land- * filling (see Key Map attached) . COMMENTS Staff note that the recommendations from Report PD-74-83 that the rezoning and official plan amendment applications were premature, were based or ne argument that a number of concerns regarding the propos landfill expansion had yet to be resolved. I One of the most serious of the � concerns related to the possibility of Graham Creek a for the groundwater system becoming contaminated by illate - it s leeching out of the landfill . Staff attempted to ldress this concern in Report PD-74-83. However, it was no i in the report that there are many complex environmenta issues that require consideration when accessing I proposal submitted by Regional Reclaimers and on wh i the Town , out of necessity, I . . .4/ REPORT NO. : PO- 147-83 Page 4 must defer to the Ministry of ie Environment or other Authorities for consideration As noted earlier in this repo the Ministry of the Environment has indicated to jional Reclaimers that their proposal as submitted to the k(nistry does not meet Ministry standards . Therefore, based on the Ministry of the Environment ' s decision related to the Regional Reclaimers application for a Certificate of Approval , it is recommended that the Town of Newcastle recommend to the Region of Durham that revised Official Plan Amendment Application 83-8/D be denied. Respect mitted, T.T. Edwards, M.C. I .P. rector of Planning JAS*TTE*j i p September 30, 1983 *Attach. Applicant : Regional Reclaimers Limited P.O. Box 358 NEWCASTLE , Ontar LOA 1HO j Mr. Richard J. E lard , Q.C. Suite 2500 Box 105, 401 Bay -reet TORONTO, Ontario M5H 2Zb Smith 8 Lyon Barristers Y4 S( ci tors Box 420 Exchange Tower 2 First Canadii Place TORONTO, Ontar M5X 1 J3 ATTENTION: Mr ouglas Hatch f July 13 , 19t13 ` 7VE'CIvey ioital Reclairers Ltd. , JUL.Box 3_i8 , Newcastle, Ontario.LOA 1110 4 ^�� • s ATTENTION: MR. J. W. HALE General Manager Dear Sir: Re: Hale Site Expansion Pr6posal A 390305 Regional Reclaimers Limited, Newcastle A meetinq was held on December 15, 1982 at the Ministry of the Environment office , 135 St . Clair Ave. West, for a presentation of the hydrogeologic report for the above—mentioned proposal . An application and two reports (as supporting documents ). were submitted to the Ministry for review. The two reports are Hydrogeologic Stud,, Proposed Landfill Expansion, by Morrison Beatty Limited, and Landfill Design & Operations by H. Mooij & Associates Limited. The Hydrogeologic Study Report was presented by Mr. B. W. Beatty, and a general discussion followed. Mr. P. S . Isles outlined the Ministry requirements with respect to a review of an application for a waste disposal site. It was during the general discussion period that a discrepancy was noted between the application and the Operations Report. In th .' situation it was indicated on behalf of the company at the reports rule and the application would be revi d accordingly. The revised section of the applicatic was received on January 31 , 1983. Application Review The applicant is Regional eclaimers Limited, located in Newcastle, Ontario. T company is operated by ,Mr. halter John Hale as p sident and Mr. James W. Hale as general manager. The esent land use and zoning category is agricultural. Regional Reclaimers Limited intends to service the fo owing municipalities; City of Oshawa, Town of Newcas e, Town of Port Hope, Town of Whithy and Township of tope, with a total population estimate of 200,000. Gen al "Motors Ltd. is the major industry to be served. Th toal area to be filled is 40 hectares within a total s e area of 170 hectares. The capacity of the site is e inated to be 5 million tonnes with a life expect icy of 18 years. l Hydrogeologic Study Report Review This report has been reviewed by Ministry staff who have commented accordinq to their particular areas of concern. The following is a discussion of all the concerns raised, divided into three major areas : hydrogeology ( groundwater protection and monitoring ) , i surface water management and its relation to Graham Creek, and leachate handling and treatement. Hydrogeology The following are the major concerns regarding the site hydrogeology. The minor and more detailed concerns are not included herein as they may be discussed in a meeting with the consultant at a later date . 1 . The rate of leachate production stated in the report only considers recharge through 1 the top of the landfill. Ground-water seepage from the sides and bottom of the excavation -.uld also contribute a significant mount to the leachate production to and should be addressed. 2. The effect :at the landfill would have on existing gr 1d-water conditions has not been address: A in the report. The direction ol: lround-water movement and the I shape of th( cater table surrounding the landfill ex( cation would change as a result of ti. construction of the landfill . T1 . 3 is because the landfill excavation % ild be in most places 6 to 8 m below the ater table and the-refore the excavation � ild act as a large drain. One possibl( ;onsequence of this is that the ground-c :er on either side of the landfill woi i he sufficiently lowered by the excavat. i such that a rise in leachate le\ Ls after landfilling could cause a revs sal of the ground-water gradient. This would result in the radial t flow of leachate away from the excavation, including towards the wells to the east. Leachate recirculation would add to this } problem. 31 A complete overall picture of the existing ground-water conditions cannot be developed due to the complexity of the drumlin stratig.raphy and static water levels not available for some wells. The sand zones in wells 14, 15, 19, 20 and 24 may be continuous . If so, it seems f)ossihle that leachate could flow from Well 1.9 towards Well 24 and from Well 24 v, a( 3 - 4 . `1'he cross :sections do not provide the equipotential lines that are necessary to draw the f:lowlines. 5. It is not .,parent why the leachate holding ha - n is sized for 10 cm i infiltrati :<; and not the expected annual leachate r duction rate. 6 . 1'he possik: ity that the leachate from the existing s e could be less concentrated than that om the new site, should be qualified +en assessing the results of the testin program for the suitability of the leacha , treatment system for the new site. 7 . It is not - parent from the report which wells indi -te the presence of a lower flow syste (heads below creek level ) . 8 . It is not 'vident how the consultant obtained t`.,, estimate for the 25 m depth of the loc flow system. The report does not discusL the effect the landfill excavation would have on this local flow system. I9. The static water levels and pieszometer construction details for the 1975 series of monitoring wells were not provided. These would be useful in assessing the value of the monitoring data for the existing site . 10. The report states on Page 1-7 that well 31/81 could not he affected by the existing landfill. However, the water level data from Heil 4/75, OW29/81 , OW30/81 and OW31/81 indicate that 01131 is downgradient from the existing landfill . It is not clear, therefore, why it would i not be affected. i I I I 4 - i 11, The statemej . ; made on Page 1-7 regarding the amount ( attenuation with distance would only � )ly if the core of the leachate plL was being sampled. Whether or not the c .—sting ground-water monitors sample the < -e of the existing leachate plume has nc been established in the report . 12. It is not eN lent from the report whether ' or not the •:ious pipelines at the north toe of the ! . idfill are below the water table . Thi: _nformation is necessary to help judge t , sir importance, if any, in controlling lachate flow. Surface Water Component and Graham Creek The following are comments and concerns regarding the surface water component of the study and implications i to Graham Creek. 1 . Ministry of the Environment 's Provincial Water Quality Monitoring Station ( 06-0118-001 ) is not located at the first bridge upstream of the Town of Newcastle as stated in the report I (p.H-1 ) . This station is located at the first bridge upstream of the mouth of Graham Creek, which is downstream of the Town of Newcastle. Data from the station may not reflect the quality of Graham Creek in the vicinity of the proposal due to inputs from the urbanized area. 2. Ministry of the Environment does not have an ammonia guideline of 0 . 02 mg/L as stated in the report (P. H-3 ) , It has an un-ionized ammonia objective of 0 . 02 mg/L. This objective is not exceeded at the Provincial hater Quality Monitoring Station. i I I 1 I i 5 - 3 . The report fail to mention that Graham Creek has an annual s -inq run of rainbow trout. Information cur. .-ntly available from the Ministry of Nat -al Resources (MNR) indicates ! that these fish spawn in the tributaries of Graham Creek upstream of the proposal . It is j MfIR 's intention to continue managing Graham Creek as a Coldwater fishery. 4 . The report, with respect to leachate from the ! existing site concludes ". . . however, there has been no measurable impact on Graham Creek" (p .3 ) . Only 3 sets of samples have been I collected from Graham Creek in the vicinity of the existing site (Nov. 18, 1981 , Oct. 6 & L80P 1982 ) , The upstream sampling location on the first two sampling dates was located adjacent to the eastern boundary of the site . Based on i the groundwater flow direction this station may be within the zone of influence of leachate from the existing site, and thus i poorly situated to reflect upstream quality. This station needs to be supplemented with two additional stations, located upstream on the two tributaries , as was done on the third sampling date. The limited available, valid data generally supports the consultants conclusion regarding impacts to Graham Creek from the existing site. However, please note that between November 1981 a-d October 1982 phenol concentrations test well OW 6/75, the closest test wE to Graham Creek, increased Ifrom 150 to 112 ug/L. The concentration of phenols in Grab i Creek increased from less than 0. 02 ug/L the tributaries upstream of the site to 1 . 2 g/L downstream of the site in samples collect on October 18 , 1982. The ' Provincial iodate Quality Objectives for phenol is 1 < 0 ug/L, T s data is insufficient to base conclusion on, and identifies the need t i for additional nitoring to determine more precisely the i act of the existing site on Graham Creek . 5 . Based on the limited available water quality data from the hydrogeological report Graham Creek, upstream of the existing site is a Policy I stream according to all of the Provincial Water (duality Objectives for which the data was provided. The quality of a Policy I stream ,must be maintained at or above the objectives . 6 . The 7Q20 flow of 40 L/sec still requires to be verified by Ministry Regional Staff . Should this flow be accepted, the available design flow for leachate assimilation in Graham Creek is 26 .4 L/sec. A reserve equal to one third of the 76420 flow is imposed to provide for future downstream uses and a buffer for the existing coldwater fishery. I Leachate Handling and Treatment ! The report proposes a relatively new method of treating leachi The proposed first be discus :d, followed bythesconcerns raised. The internal I& ; 'fill drainage is expected to be .toward the n -th , i .e. , the leachate may be collected at th north toe of the berm without Placing underdr ns . Tile collectors can be installed at th location to intercept the leachate. The achate is then routed through an aeration/mar channel and recharged into beach deposits the north edge of' the landfill area. storage basin to be I installed betwe. the tile collectors and the aeration/marsh annel to regulate 'flow. The proposed leacha treatment system is comprised of thr Following: 1 . leachate tile cr Lectors from below the north toe of landfill cea holding basin wichin landfill for flow regulation I i 3 . aeration/marsh channel-gravity drainage from basin (north toe ) to recharge facility i 4 , a gravity leachate recharge facility The aeration/marsh channel is to provide the pretreatment of the leachate . The dimensions proposed are 200 to 300 metres in length, 2 metres in width and 1 metre in depth , with a 0 . 5 percent gradient. The treatment of the leachate will he in the north-central area of the site immediately east of the existing larv) fi11 a,-�n t,,,r„ 4 i, ,, , C _ 7 - a A number of major concerns have been raised regarding the proposed leachate handling and treatment system and are listed below: 1. The leachate tile collector system has not been shown on a plan indicating location of the drains and general detail of installation. 2. The location of the holding basin has not been shown and its connections with the tile collector and aeration/marsh channel . 3. The method of pretr ting leachate using an aeration/marsh chan 1 has not been used to date. Aeration/mar channel facilities have been tested and con nue to be tested by the Ministry of the Env onment for pretreating municipal wastewate only. This wastewater has a BOD in the or r of 200 ppm. One such test site, also ref -.-red to in the hydrogeological stu to report, is the Town of Listowel, Ontario. n October, 1981 the Ministry of the Env onment made a presentation regard g Sewage Effluent Treat- ment in an Artifica Marshland which specifically descri d the first full year operation of the Li -. owel test site. In the discussion of the r, : ults , it was pointed out that the results wee . preliminary in nature and that further, 1 g term studies are required to confirm onclusions drawn. The hydrogeoloic rel. .,rt refers to six existing landfills where information on observed leachate treatment in open ditch was the basis for the aeration/marsh channel proposal . They are: Burlington, Maitland (Dupont site ) , Brockville , Stoney Creek, Listowel , and Cobalt. An investigation conducted in 1978 at the Old Burlington Landfill Site noted outbreaks of leachate along the southern toe of the site. The leachate was being discharged into the swampy headwaters of a small stream. There was an improvement in leachate quality after passing through this swampy area, however the ratio of leachate to base flow in the stream was low, and it passed through approximately 400 m of swamp where additional dilution from groundwater inputs was provided in addition to uptake by the swamp vegetation . Maitland ( h.ipont) is not a landfill site but a test for treatment of wastewater and sludge used for breeding poplar trees. The report is nc clear as to what references are made re(lard: 1 the Brockville and Stoney Creek sites . The study in Li: )wel, as discussed earlier herein, was for irsh channel treatment of sewage effluent, Northern Ontaric Industrial Affairs conducted I studies in Coha] for treatment of sewage effluent. Data significant information on the operation hz not been provided to the Ministry of the ivironment. i A field study conducted in 1978 on the impact of leachate outbreaks from the Nelson landfill site, Peterborough, on the adjacent swamp noted zones extending approximately 700 m from the Sod & NE leachate springs where all swamp vegetation within the main flow channel have been eliminated. Leachate strengths measured near their source varied from 150 to 7000 mg/L BOD. Based on this experience, leachate at or near "full strength " may be potentially lethal to marsh vegetation. The information and results from tests on aeration/marsh channel treatment of sewage effluent available to date are still experimental. Further, there is no information which can be used to verify the effectiveness treating leachate with an aeration/marsh channel. . It was pointed out at the meeting of December 15, 1982 that new concepts introduced in landfill sites or any operation to be approved by the Ministry of the Environment requires background supporting information relating to actual practical applications . The report does not provide the required supporting information. 4 . Similar to numhe 3 above, substantial information and actical application of soil attenuation as a stem for treating leachate is lackin<j . The lformation provided in the report on the de, jn or engineering of the proposed system insufficient to verify the effectiveness of 2achate attenuation by the heath sands . C Design and Oprrritions Rep, r Review This report has also been eviewed by Ministry staff and the following are comn. _nts regarding the Landfill Design and Operations Report. 1 . There are no plan3 or cross-sections showing the bottom elevations of the proposed landfill. The description regarding trench depth is not clear as outlined on page 27, 8. 2 Trench Sizing. Plans are necessary to help predict what hydrogeologic conditions would be intersected by the excavation and how these conditions would change in response to the landfill. i 2 . The watertable lies approximately 2. 5 metres below existing ground surface at the proposed landfilling area. Based on section 8 . 2 of the report , it seems that the trenching operations i will be below the groundwater table. This together with the upward gradient which exists at the landfill area may present construction and operation problems. The handling of groundwater during the trenching operations should be discussed. 3. It should be noted that the ground-water flow directions on Plan A and Plan C do not represent the leachate flow directions. 4 . The composition ( the paint sludge expected from General Mot( 3 as described in- Section 6 . 2 of the report ;onstitutes 2. 6% of the total . Informat: i on the remaining 97. 4% of the sludge shoulc >e provided. S. The Township of 1 -cy is presently being served by the exi :ing site. The report does not list the Town ip of Percy as a municipality to k serviced by Regional Reclaimers Limit( A statement confirming this should he n( d . 6. In the event that -.he leachate attentuation system proposed ( :s not operate as expected, contingency systc for leachate collection and handling are quired . General layout and operation plans f the contingency systems should be provide at this time . 10 - 1 . A pl -in Lndicatinq Precisely the location of the total site area of 170 hectares and the disposal area of 40 hectares is required . 8. Plans indicati.nd the incorporation of the existing site with the proposed expansion site are required for the longterm site development and operation . The plans should include leachate handling and collection systems, site maintenance , and final use proposals . 9. Fundinq requirements should bel confirmed as requested in Section 12 of the Design and Operations report at this time. i i Conclusion The application and supp ting documents for a Certificate of Approval r the proposed expansion landfilling operations b Regional Reclaimers Limited have been reviewed by th Ministry of the Environment. It is considered that th proposal as presented by the supporting reports does "t meet the current requirements of this Min try, and as such, staff would not he prepared at this me to recommend an approval to our Director• or provi favourable comments . In particular, the document ion does not adequately substantiate the viabili of the proposed leachate i handling and treatment s• tem. There is concern that the information availabl regarding the proposed handling and treatment s tem is of an experimental nature and not totally a licable to leachate from landfilling sites . Fur. th2r, the contingency plans prepared are merely a list of technologies that are available and not an evaluation of whether one or more are technically viable. i I i L1 you c� i::,h to discus: ents , iltc�rn'-itiveS or ally o,. t <iliovr pleas ;c.• c�ontcWt r.�e sit c)t,`,- tatc.c, con rer_ns , 1. Your; truly, I'•S - ISI(es , Stwervisor , Waste Sites h Systr.m App ial, Unit , Environmc:�ntal Airpr.oWIls S, ion . LM/dms c. c. H . Mooij - H. P-9ooi- x Associates Limited B. W. Beatty - Mori Son Beatty Limited R. J. 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