November 30, 2006 Mr. Steve Burns District Manager Ontario Ministry of the Environment 2430 Don Reid Dr. Ottawa, ON K1H 1E1 Dear Mr. Burns:
Thank you for your letter of November 27 as follow up to the October 13, 2006 letter from Ms. Gayla Campney, Regional Director, Eastern Region, Ontario Ministry of the Environment (MoE). We would also like to express our gratitude for the opportunity to meet with you and other representatives from the MoE on November 21, 2006. At that meeting, the Coalition provided a thorough technical presentation on our analysis, finding and conclusions regarding offsite contamination at the Carp Rd. Landfill based on the report that we submitted to the MoE on September 28, 2006. In the discussions that followed, there were some points where the Coalition and the MoE were in agreement. There were also a number of issues on which we agreed to disagree; the interpretation of the data, what conclusions can be drawn and what measures are necessary to provide the community with assurances that the environment and the health and well being of local residents are protected. We remain committed to working with the MoE to identify and address, in a collaborative way, the numerous issues with the dump. We do wish however, to express our disappointment in part of the process. At that meeting we were informed that the MoE had on November 10, 2006, already issued an amended Certificate of Approval to WM and that the company was now in compliance with Ontario’s groundwater policies. You provided us with clarification and details on how WM was able to purchase additional land across the Carp Rd. to expand its contaminant attenuation zone (CAZ) and thereby become compliant. To better understand our disappointment in the process, it is worthwhile to review the sequence of events: • 2000 Provincial Officer Order issued to Waste Management to address offsite groundwater contamination • Spring 2006 – The Coalition obtains, via the Freedom of Information and Protection of Privacy Act, a copy of WM’s 2005 groundwater monitoring report • September 28, 2006 – The Coalition submits its detailed analysis, concerns and recommendations based on the data contained in the 2005 groundwater
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monitoring report. The Coalition’s analysis of the data clearly points to the presence of offsite contamination. October 13, 2006 - The Coalition received a response from the MoE acknowledging that Waste Management is not in compliance with Ontario groundwater policies and under a Provincial Officer Order as a result. The Coalition was promised a response in writing in 45 days November 10, 2006 – MoE approves an updated CofA for WM. November 21, 2006 – The MoE meets with the Coalition to discuss its analysis and informs those at the meeting that WM is now in compliance.
Based on the content of Ms. Campney’s October 13th letter, it was our earnest understanding that the MoE would be open to our concerns and recommendations before making any decisions regarding WM with regards to offsite groundwater contamination. The timely approval of the CofA and the lack of communication to the Coalition of that important decision in advance of our meeting are, in our opinion, not conducive to forging a fruitful and mutually cooperative working relationship that the Coalition seeks with the MoE. Meanwhile, now that WM is in full compliance, we have been informed that the company is days away from submitting its Terms of Reference for an environmental assessment regarding the proposed expansion of the landfill. As we indicated at the start, the Coalition is sincere in its efforts to work with the MoE to identify and address the numerous issues with the Carp Rd. landfill that affect both the environment and the quality of life of those who live near the dump. With regard to the discussions on the Coalition’s analysis, findings and recommendation, we would like to highlight some of the more significant areas of disagreement. We draw from points made in the October 31, 2006 MoE Memorandum to G. Davis from F. Crossley regarding the Coalition of Citizen Groups, Ottawa (Carp) Waste Disposal Site: The Ministry has determined that leachate has migrated offsite as the extent of the leachate impacts is reasonably determined as the horizontal extent is probably 400 meters from the site licensed boundary in an east, north east direction. The Coalition is in agreement with the Ministry’s assessment that there is “offsite” contamination in the form of a leachate plume that extends 400 meters from the site’s boundary to the east, north east of the landfill. The Coalition disagrees with the MoE that both the size and the direction of the leachate plume is limited to this characterization and that further study is imperative to fully understand its full extent. In addition, we are still not in agreement with the interpretations of the groundwater monitoring data and leachate impact put forward by WM and agreed to by the MoE. This is a compliance issue with Guideline B-7. To this end, WM has purchased additional lands for the purpose of a contaminant attenuation zone (CAZ). The Coalition does not have confidence in a remediation and abatement strategy that simply expands the land on which WM is allowed to contaminate. An expanded CAZ
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provides little assurance to the community that the contamination will be remediated and/or contained to that area. Also, the CAZ does not include all of the properties where significant VOCs were found. We continue to strongly believe that the MoE needs to determine the extent and the origin of these VOCs. Volatile organic compounds are monitored at this landfill operation. VOCs are present onsite. VOCs are not present above Drinking Water Standards offsite. The present monitoring program is currently effective to evaluate the VOC impacts. We note that the off-site well W54-1 has shown consistently high benzene levels in all of the years recorded in the report that was made available to us. Even in 2004, benzene was recorded at the level of 2.5 ppb. Given that the ODWS for benzene is 5 ppb, the fact that it is a medical criterion and that the detection limit is 1.3 ppb, then all of the data for this off-site well has exceeded the RUG limit of 2.2 ppb. Similarly, the off-site well W53-2 reported trichloroethylene in 2001 and 2002 at levels of 4.3 and 4.8 ppb respectively. With an ODWS of 5 ppb and a detection limit of 1.9 ppb, both of these readings clearly exceed the RUG level of 2.7 ppb. Based on the verbal descriptions of the lands purchased by WM provided by MoE officials at the November 21st meeting, it is our understanding that neither of these monitoring wells, W54 norW53, is encompassed within the new CAZ. While there is no indication of a VOC problem at this landfill the detection limits will be discussed with WM, especially vinyl chloride limits. There has been a consistently high level of vinyl chloride in the purge well at the north east corner of the landfill site, peaking at a level 12 times the ODWS limits in 2001. Domestic water supplies on the adjoining properties have also reported issues with vinyl chloride over the ODWS. It is our understanding that these properties have since been made part of the CAZ. These facts and the clear exceedances listed above, indicate to us that VOCs are problems with this site. We seek to understand why the ministry thinks otherwise. While we appreciate the MoE’s commitment to pursue this point with WM on the presence of offsite VOCs, we remain unconvinced that the present monitoring program is adequate. Detection limits are too close and in some cases are above the Drinking Water Standards. The expanded CAZ does not include areas in which VOCs were found. As a result and given that VOCs are not found in nature and include known carcinogens, immediate steps should be taken to determine the full extent of VOC contamination as well as the source. The purge well system is operating as designed and approved. The effectiveness of the system requires ongoing evaluation over time. The purpose of the purge well is to eliminate/reduce the egress of leachate offsite however it will not capture leachate that has already migrated offsite.
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We respectfully continue to disagree that the purge well system is an effective leachate control mechanism. Also, there is an absence of definitive parameters upon which the MoE plans to measure the system’s effectiveness. In the meeting, MoE officials were quite frank in expressing that only time would tell and that a 5 – 10 year window was required to determine if the system was indeed eliminating/reducing offsite leachate migration. This, in our opinion, is not adequate. In summary, the MoE and the Coalition agreed to continue to discuss the concerns and recommendations raised by the Coalition as well as address the list of related concerns that the Coalition provided to you in advance of November 21. It cannot be overstated that the aquifer around the Carp Rd. dump is used by hundreds of people as a source of drinking water. Despite a now expanded CAZ, the Coalition continues to believe that the environment is still very much at risk. To that end, we welcome the opportunity to meet with you in the late afternoon on December 14th to further discuss the situation. In addition, we look forward to a separate meeting with the MoE to address the ongoing and serious issue of odour related to the present landfill. It is our sincere hope that this meeting be organized very soon as we are aware that the MoE intends to release the air CofA for WM in the coming days. The Coalition is not confident that a second flare makes the site compliant until sufficient measurements/observations are obtained and analysed. Sincerely,
Vincent Lavoie, President, Richardson Corridor Community Association On behalf of the Coalition of Citizen Groups opposing the expansion of the Carp Rd. Landfill. c.c.: Laurel Broten, Minister of the Environment Gordon O’Connor – MP (Carleton – Mississippi Mills) Norm Sterling – MPP (Lanark – Carleton) Lisa McLeod – MPP (Nepean – Carleton) Bob Chiarelli – Mayor, City of Ottawa Larry O’Brien – Mayor, (Elect) City of Ottawa Peggy Feltmate – Councillor, Ward 23 Eli El-Chantiry – Councillor, Ward 5 Janet Stavinga – Councillor (Outgoing), Ward 6 Shad Qadri – Councillor (Elect) Ward 6 Marianne Wilkinson, Councillor Ward 4 Gayla Campney – Ontario Ministry of the Environment No Dump Ottawa Landfill Watch Stittsville Village Association
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