Comments on GFL proposed…

Comments on GFL proposed Amendment ECA Air & Noise No. 9610-84YLE3: GFL’s application for amendment states: “At the Facility, GFL operates a soil remediation site for the treatment of petroleum hydrocarbon impacted soils.” This statement is also included in the best management practices dated October 2016. The current Certificate of Approval Air issued June 18, 2010 by the MOECC permits: “A soil management facility (SMF) for the following processes and support units: •Receiving of Soils at the SMF; and •Stockpiling of Soils at the SMF; Including the Equipment and any other ancillary and support processes and activities, operating at Facility Production Limits of up to 2,500 tonnes of Soils received per day and up to 100,000 cubic metres of Soils stored on site, exhausting to the atmosphere as described in the ESDM report.” Additionally “Equipment” as defined in Section 13 of the CofA includes equipment or processes described in the ESDM Report, the CofA and in the Supporting Documentation. The original CofA issued to Waterfront Toronto only included equipment for the screening of soils. Therefore this facility is only permitted to receive and stockpile soils. There are no conditions permitting bioremediation of petroleum hydrocarbon impacted soil. Although DEME Environmental Contractors Canada Ltd. and Stryvesent Environmental Contracting Inc. were issued Certificates of Approval to pilot soil washing plants at the Unwin site, these owned by DEME and Stryvesent cannot be utilized by GFL for the processing of soil at the Unwin site. These permits are also for soil washing exclusively and do not include bio-remediation. This site has been operating as a Bio-remediation Soil Treatment Facility since Green Soils was awarded the contract to manage the site in July 2012. The bioremediation process is not approved in the existing Certificate of Approval and therefore the site has been illegally processing soil. In addition, the Environmental Compliance Approval No. 4410-85LJ85 is only approved for the receiving and temporary storage of soils contaminated with either hydrocarbons, PAHs, heavy metals, PCBs (limited to less than 0.3 ppm.) and soils containing construction demolition debris. It also does not include the bio-remediation of soil. An amendment application made to the MOECC February 21, 2017 and posted on the EBR April 19, 2017 suggests/infers that the ECA actually allows for bio-remediation of soil, but this is just not true. This application for amendment should also be denied and a full investigation should ensue. It is clear that Green For Life is attempting to mislead the MOECC to believing that the site is currently approved for bio-remediation, which it absolutely in not approved to do. Additional Comments: •The ESDM report states that the site may receive soils from Ontario. The original COA issued to Waterfront Toronto was for soils generated only in Toronto as requested by WFT. Therefore all soils received from outside Toronto should be returned to the generator site. •The ESDM report included in the application for Amendment states the site currently operates a soil remediation site for the treatment of petroleum hydrocarbon impacted soils. It goes on to confirm that soil is screened and wetted with a microbial solution. Low impacted soils are then placed in biopiles and high impacted soils (equal to or greater than 0.146ppm) are remediated using biocell technology. The process includes 2 microbe tanks with a capacity of 2,000 litres. The site does not have, nor did it ever have, a permit for these operations. •The ESDM report assumes 650ppm for soil contaminated with gasoline and 2,500ppm for soil contaminated with fuel oil. These concentrations are not reflective of most projects. Concentrations can exceed 50,000ppm. •The AirZOne Soil Emission Rates allows for 2 tonnes per m3. This is very generous and not normally the case. Soil is denser and is typically 1.7 tonnes/m3. Therefore the calculations reduce the level of organics in the soil. The rates need to be updated. •The Soil Remediation Best Management Practices Plan states the maximum height of soil is 12 metres but in fact the maximum height is only 8 metres. •The Soil Remediation Best Management Practices Plan states that water misting or spraying will be employed to minimize dust and that the placement of tarps can also be used. Conditions 3.7 of the ECA mandates that all piles are to be tarped. It does not appear that GFL is in compliance with this condition. •Per Schedule A, Condition 1 - Application for a Provision Certificate of Approval, all soil leaving the site are to be re-used in the Designated Waterfront Area (DWA). However, soils have been shipped outside of the DWA. •All soil received at the SMF must exceed Table 3. The ECA No. 4410-85JL85 defines “Contaminated soil” as soil that contains one or more parameters at a concentration that exceeds Table 3 lists in the Soil, Ground Water and Sediment Standards for Use Under part XV.1 of the EPA. As there was no treatment on site, how was the soil reused in the DWA? All soils that have been received at the site and shipped off site must be located and either tested to confirm compliance with all regulations or excavated and returned to the Soil Management Facility and/or Generator. There is no possible reason to trust the operations at the site the soil was actually treated by any method as there was never a CofA or ECA to bio-remediate soil. Is it possible that GFL has only been blending soil? A full investigation must be completed of the operations on this site.