Dear Madam/ Sir, Please…

Dear Madam/ Sir,
Please accept this submission as Environment Hamilton’s formal comments regarding the Revolution
Landfilll Acquisition GP Inc. (commonly known as Terrapure) application to secure an amendment to
its ECA (Waste Disposal Site) No A 100140 for its facility at 152 Imperial Street in Hamilton.  
The company is requesting that a long list of new waste classes be approved for them to receive at
their facility.   Our immediate response is one of concern.  We are seeking assurances that, should
the MECP approve this amendment request that it take steps to ensure that the proponent carefully
manages any new waste classes in order to avoid a repeat of problems that emerged in 2016 and 2017.
  Details of these problems are described in a media article included as Appendix A – and the
problems resulted in charges from the MECP totaling over $180,000.00.   

We had the opportunity to speak with the company about their plans at a community open house
requested by residents living near the site.    We wondered how much of the waste processed at  52
Imperial Street ends up at the Terrapure Stoney Creek Landfill site.  The staff at that meeting
could not provide specific details in response to this question.  But we raise it for a very
specific reason.    Terrapure is currently seeking approval to expand the capacity at its Stoney
Creek industrial landfill site.   We know that waste is received and then processed at 52 Imperial
Street in order to render it non-hazardous and at least some of it is sent to the Stoney Creek
landfill site.   The Stoney Creek landfill is only permitted to accept waste generated in Hamilton.
 However, our understanding is that a waste class can be received and, if processed further in
Ontario to render it non-hazardous, is then considered to be waste generated in Ontario.  We are
concerned about the addition of waste classes to the Imperial Street ECA for this reason.  The
Imperial Street facility is permitted to accept waste from anywhere in Canada and the United
States.  If that waste is then processed here – it can be disposed of at the Stoney Creek facility.
 We do not support amendments to this ECA that might facilitate the proponent’s ability to accept
more waste from outside of Ontario for treatment at 52 Imperial Street and ultimate disposal at the
Stoney Creek Landfill.  We do not support the idea of Hamilton being the potential ‘end point’ for
treated hazardous waste from across North America and we worry that this request is linked to the
request to expand the Stoney Creek Landfill

We have also reviewed what we believe is the current ECA (Waste Disposal Site) for this facility
dated November 14, 2014.  The ECA is still in the name of the previous operator, Newalta
Corporation.   Condition 13 – Waste Storage – sets out significant quantities of materials that are
permitted to be stored at the site.   We are concluding that the company was able to provide the
financial assurance required to accept/process/store the highest waste stream scenario set out in
the ECA – as confirmed by them at a community open house.  We suggest that the ECA should be
updated to reflect this reality so that any community member who accesses the ECA will understand
that this is the approved situation at the site.   We are surprised by the quantities of waste that
are permitted to be stored on site and wonder why these amounts are so high.   We also wonder, in
light of the problems in 2016 and 2017, whether the MECP has done an inspection of this facility
recently and whether the public can access the inspection report so that we have some sense of
whether everything is in compliance at the facility currently.  

We also understand that this amendment includes adding new pieces of equipment for use at the site.
 One of those items is a hammermill which raises questions about noise impacts.   We are requesting
that MECP ensure that any new equipment will not generate unacceptable noise impacts in the
surrounding area.  

We thank you for the opportunity to comment on this application for an amendment to ECA No. A
100140.

Yours truly

Lynda Lukasik, PhD
Executive Director
Environment Hamilton
TEL: (905) 549-0900

APPENDIX A:
Terrapure plant fined for emitting harmful gases
Imperial Street wastes in question not sent to Taro, company says
COMMUNITY Dec 14, 2017 by Richard Leitner  Stoney Creek News

The owner of the Taro industrial dump has been fined $145,000 for two incidents at its Imperial
Street waste processing plant in Hamilton that emitted harmful gases to neighbouring businesses.
Revolution Environmental Solutions Acquisition GP Inc. — known publicly as Terrapure Environmental
— was convicted of three offences under the province’s Environmental Protection Act.
The Ministry of the Environment and Climate Change said the first incident on Jan. 20 of last year
occurred when the plant accepted a lugger bin of mixed hazardous wastes.
Problems arose when workers mixed the bin with 31 other loads of hazardous waste received over the
previous 10 months.
We regret that these incidents occurred and we have rectified the situation to ensure they do not
happen again.
The latter included two wastes not permitted by the plant’s licence and the mixture caused a
discharge of chlorine and/or bromine gas, the ministry said in a Dec. 6 press release announcing
the convictions.
Terrapure didn’t notify the ministry as required by its licence and the incident only came to light
when a neighbouring business complained its employees and contractors were experiencing adverse
health effects.
The second incident took place on Aug. 12 of last year when the plant accepted a shipment of 13,000
litres of glycerin pitch waste, a byproduct of making biodiesel fuel.
The waste was mixed with cement kiln dust and left to cool overnight.
But Terrapure received a call from the Hamilton fire department at 9 p.m. that a neighbouring
business had evacuated its plant because the mixture had created acrolein gas, a highly toxic
substance that can cause acute and chronic health effects.
The odour was contained by 3 a.m. the following day and a subsequent investigation found the waste
had a greater concentration of raw glycerin and possibly a higher temperature than previous loads.
 

Fourteen people suffered burning and irritation to their eyes, noses and throats, including
employees at two businesses, firefighters and ministry staff.
The plant is no longer accepting glycerin pitch waste, the ministry said.
Terrapure vice-president Todd Smith, who oversees the Imperial Street plant, said none of the
wastes in question were shipped to Taro.
He said the violations are the first in the plant’s 30-year history and the company takes full
responsibility for both incidents.
“We regret that these incidents occurred and we have rectified the situation to ensure they do not
happen again,” Smith said.
Besides the $145,000 in fines, Terrapure must also pay $36,250 in victim surcharges.
Incorrect information appeared in a previous version of this story.
by Richard Leitner
Richard Leitner is a Regional Reporter for Hamilton Community News (Ancaster News, Dundas Star
News, Mountain News and Stoney Creek News). He can be reached at rleitner@hamiltonnews.com
Email: rleitner@hamiltonnews.com Facebook Twitter