York1 landfill proposal…

York1 landfill proposal comments

The former Dresden disposal site now owned by York 1 requires a Full Risk Comprehensive site investigation including soil analysis at different depths and testing of ALL adjacent private water wells to investigate for the presence, nature of and severity of a leachate plume in the local groundwater. Molly's Creek that runs adjacent to the site should also be investigated for any prior contaminants leaching into the Creek. The site should not be considered for further construction for a new landfill cell on the property as York 1 indicated they've wanted to construct; as the local hydrogeology of the site is at high risk for leachate containment failure. The underlying aquifer at the site is a contact type aquifer with shallow water wells in the surrounding area. Shallow water wells are particularly vulnerable to leachate from landfills as noted in the following studies;

Effect of Dumpsite on Water Quality of Shallow Wells; a Case Study of Nasarawa Town, Nasarawa State, Nigeria Chika Magnus Anumiri,I. Onaiwu, E.A. Obajula, Yushai Aliyu, September 2019, Asian Journal of Environment and Ecology

https://www.researchgate.net/publication/336124113_Effect_of_Dumpsite_o…

Assessment of Shallow Groundwater Contamination Resulting from a Municipal Solid Waste Landfill -a Case Study in Lianyungang China, Ge Chin, Yajun Sun, Zhimin Xu, Xusekai Shan,Zengliang Chen, Water MDPI

https://www.mdpi.com/2073-4441/11/12/2496

Isolation distance between municipal solid waste landfills and drinking water wells for bacterial attenuation and safe drinking, Rui Xiang,Ya Xu, Nature Scientific Reports

https://www.nature.com/articles/s41598-019-54506-2

The Precautionary Principle must be applied in this situation. Failure to do so would put human health and the Environment at jeopardy. A proper Full Risk Comprehensive Assessment to determine the prior history of contaminants on site and in the local groundwater surrounding the Dresden disposal site has not been conducted by the Ontario Ministry of Environment to date.

The Ontario Ministry of the Environment is fully aware as indicated in the article below that the previous operator of the Dresden disposal site was fined by the Ministry for improper leachate handling from waste on the site and additionally, the operator failed to comply with any of requirements the Ministry imposed on the operator to address the leachate spills.

Aerial photography from January 2020 allowed the Ontario Ministry of Environment to determine that at least 8,613 tonnes of waste was present at the site, far beyond the 75 tonne approval limit issued to Waste Wood Disposal Ltd.

There is no clear understanding of what has been disposed of at the site by the prior operator before York 1 purchased the site.

There is no idea of how hazardous any of the materials brought to the site are nor any sense of the amount, this poses an unaccountability to Public Health the Ontario Ministry of Environment has allowed.

The groundwater supplying the adjacent private wells beside the Dresden disposal site are at risk for a pre-existing leachate plume that the Ontario Ministry of Environment has not adequately investigated nor has held any parties responsible for.

Please see web-link article below for reference for Ontario Ministry of Environment’s culpability for failure to adequately investigate and hold parties accountable;

https://esemag.com/solid-waste/two-ontario-companies-fined-for-improper…

Because the site is not adequately investigated, the potential for leachate to seep into the local groundwater and into Molly's Creek which runs along the site and from Molly's Creek which flows into the Sydenham river must be considered. In addition, the site in the past operated a gun range for the Chatham-Kent Police Association, therefore an investigation for lead contamination must be conducted both on site for soil analysis and in ALL adjacent private water wells.

A Full Risk Comprehensive risk assessment to the watershed must be conducted, as knowledge gaps are apparent at the Dresden disposal site in how the site was operated in the past.

The below web-link article describes in detail the range of knowledge gaps from landfill leachate risks to the Environment and Human health;

Risk Assessment of landfill disposal sites- State of the Art, Talib E.Butt, Elaine Lockley, Kehinde O. K.Oduyemi, Waste Management 28 (2008) 952-964

https://www.researchgate.net/profile/Talib-E-Butt/publication/5868282_R…

From the conclusion of this paper it is important the Ministry of Environment recognizes;

“ Therefore risk assessment is required as a tool to identify and define landfill hazards for the environment. The risk assessment is a most important factor of an effective risk control,as the degree of success of the latter is based on the former. The other side of the coin is that there does not exist such a holistic risk assessment methodology for landfill leachate, which counts help to perform the process of risk assessment from the start (i.e., baseline study ) through to the end (I.e. Hazard indices and is quantification). Main examples of features that are either wholly or partly absent in the “state of the art” of landfill risk assessment approaches are statistical descriptions; significance and uncertainty assessments; temporal and spatial variations of various landfill characteristics;risk quantifications for carcinogenic as well non-carcinogenic hazards; aggregation of risks; hazard identification and categorization; consideration of background concentrations of pollutants in exposure media and receptors;and the means to assist derive risks in the categories of most likely and worst case scenarios. This research allows the authors to recognize the necessity, identify knowledge gaps and establish bases for developing a more holistic framework of an algorithmic and quantitative methodology of risk analysis for landfill leachate in an integrated manner.”

Given the Ontario Ministry of Environment has fined the previous operator of the Dresden disposal site for leachate spills which the operator did not correct and given the Ministry to date has no clear understanding of the types of wastes disposed at the site or the level of toxicity of those materials, it would be prudent the Ministry does not allow York 1 to construct a new landfill cell on the site as a leachate leak failure on the underlying contact type aquifer with adjacent shallow water wells is a unacceptable Risk. If York 1 is to remediate the site from the previous operator then removal of the waste material and transfer to a already established hazardous waste landfill would be in accordance with the Precautionary Principle.