Regional Municipality of…

Regional Municipality of Waterloo (HSW Review):

Re: Zone Change Application 11/19 – Preliminary Comments from Hydrogeology and Source Water Protection
Jackson Harvest Farms Ltd. (Hallman Pit)
1894-1922 Witmer Road, Township of Wilmot

The Region’s Hydrogeology and Source Water Protection (HSW) staff have reviewed the above-captioned zone change application submitted on behalf of Jackson Harvest Farms Ltd. for a proposed above-water table aggregate operation at municipal addresses 1894 to 1922 Witmer Road in the Township of Wilmot. The application is intended to support the applicant’s application to the Ministry of Natural Resources and Forestry (MNRF) for a Category 3, Class ‘A’ License to Excavate Aggregate from Above-Water Table Pit.

HSW staff reviewed the technical reports that were submitted in support of the proposed aggregate pit. The following relevant technical reports were reviewed by HSW staff:

1) Phase I Environmental Site Assessment (CVD, 2017a)
2) Phase II Environmental Site Assessment (CVD, 2017b)
3) Hydrogeological Assessment, Level 1 and 2 (Harden, 2019)

HSW staff reviewed the submission and assessed the technical reports with a focus on potential impacts to drinking water sources from the proposed aggregate pit as well as to ensure consistency of the technical work with the Region’s draft Guidelines for Hydrogeological Assessments for Proposed Mineral Aggregate Resource Extraction Projects.

The hydrogeologic field investigation completed at the subject property is insufficient to
assess potential impacts to surrounding municipal and private groundwater users within the
study area. Further, the data collected and technical assessment does not meet the
minimum requirements as set out in the Region’s aggregate guidelines, which were
provided to the proponent ahead of this submission. Given the above, HSW staff has
outstanding concerns and does not support the proposed zone change application at this
time. Additional investigations and reporting will be required prior to approval of the zone
change application. Specific concerns identified below by HSW will need to be addressed
prior to zone change approval.

Potential On-Site Contamination

The Phase I and II Environmental Site Assessment (ESA) reports identified contaminated
soil at the subject property relating to historical fuel and oil storage. Based on this new
information that identifies historical BTEX/PHC contamination identified in soil at the
property, HSW requests that a Record of Site Condition (RSC) be filed for the subject
property. The implementing zoning by-law should include a Holding zone until such time as
an RSC is filed with the Ministry of the Environment, Conservation and Parks and to the
satisfaction of Regional staff.

Site Water Balance

Additional details and supporting rationale need to be provided for the site water balance
calculations presented in the Hydrogeological Assessment report. There were also some
discrepancies noted between different sections of the report related to the water balance.
Further, the assessment of the during-operations water balance used only one scenario,
where multiple should have been evaluated.

High Water Table Delineation

An inadequate number of groundwater monitoring locations were installed across the site to
delineate the on-site high water table and groundwater flow direction. None of the
monitoring wells were installed within the proposed extraction area, especially near the
topographic divide at the centre of the property and towards the west of the property in the
vicinity of the headwaters of Hunsberger Creek.

Further, the report did not consider potential changes to regional and on-site groundwater
elevations related to climate change. Nearby shallow aquifer groundwater elevations have
varied by over 2 metres throughout the monitoring period and exhibit an overall increasing
elevation trend over time. The report should evaluate high water table elevations in
comparison to the historical high groundwater elevations demonstrated below and consider
potential increases in the high water table as a result of climate change.

Potential Impacts to Nearby Municipal and Private Drinking Water Sources

The presence and thickness of the protective aquitard ATB2 referenced in the report
cannot be confirmed/refuted at the site because groundwater monitoring wells were not
advanced to sufficient depths. Due to the lack of information about the connectivity
between the unconfined aquifer and the municipal supply aquifer, and the lack of analyses
regarding impacts from shallow groundwater pumping for the wash ponds, not enough
information has been collected and analysed to determine whether there may be an impact
to private and/or municipal supply wells in the vicinity of the proposed pit.

The report did not provide sufficient evidence or rationale to confirm that there would be no
impacts to private wells in terms of water quantity and/or water quality as a result of the
operation of the aggregate pit and associated recycling activities proposed at the subject
property.

Surface elevation contours suggest there is a component of on-site runoff that flows to the
west towards Hunsberger Creek; however, the report did not discuss potential impacts to
the headwaters of Hunsberger Creek as a result of altering drainage flowpaths across the
subject property.

The report did not adequately characterize historical groundwater quality in nearby
municipal and private wells. In addition, the report did not adequately assess the potential
impacts to future groundwater quality concentrations (particularly nitrate) as a result of
operations at the proposed aggregate pit.

Groundwater Monitoring Program

Additional groundwater monitoring will be required at additional locations, including
groundwater monitoring in a deep multi-level with one of the screens installed within the
municipal aquifer.

Further, the proposed groundwater monitoring program is insufficient to adequately assess
potential impacts to nearby private wells and nearby municipal wells. The report did not
include any trigger levels or contingency plans for groundwater quality and/or quantity in
on-site monitoring wells and, potentially, off-site private and municipal wells.

Spill Contingency Plan

Additional details should be added to the spill contingency plan to ensure that the plan
identifies and designates key individuals and responsibilities for implementing the plan,
identifies chemical storage areas, and provides information regarding spill prevention
measurements of chemical storage vessels and storage areas.

Summary
Based on the technical information provided, Regional staff do not support the proposed
Jackson Harvest Farms Ltd. aggregate pit at 1894 and 1922 Witmer Road at this time.
Additional investigations and updated reporting as described above is required to address
outstanding concerns. The proponent should contact Regional Hydrogeology and Source
Water staff regarding questions about the scope of the above-noted required technical
studies and information and to arrange discussions on more detailed technical matters.