There are significant…

There are significant discrepancies in the well records submitted to the Ontario Ministry of Environment by York 1 for the proposed site outside Dresden Ontario were York 1 proposes to amend the current Environmental Compliance Assessment given to the previous Waste Wood Disposal for York 1 to operate a recycling center and dig a new landfill at this site.

A review of York 1 monitoring well records on the site clearly shows a significant discrepancy between York 1 well records and the surrounding private well records of private wells nearest the site.

Consistently York 1 has failed to observe and properly record the yellow and/or blue clay layers in their own monitoring well records that are consistently found in the private well records. This is a significant Ommission as the presence of both yellow and blue layers are observed and recorded in the surrounding private well records.

The presence of yellow and blue clay layers in the well records indicate that both of these layers have been oxidized at some time and indicates that water has permeated thru both layers. This calls into question the hydraulic conductivity of the site in general for landfill purposes.

Direct comparison of York 1 monitoring well records with Well tag #s; 7431540, 7431544, 7431542, 7431541, 7451195, 7451196, 7451165, 7451197, 7431539, 7431538, 7451164, 7451167, 7451194, 7451193, 7431545, 7431543, 7451199 and 7451200

To Private well records with Well tag #s; 3305886, 330329, 3300175, 3300176, 3300177, 3300332, 3300279, 3300326, 3300325, 3305017, 3304582, 3300320, 3300313, 3300318, 3300319, 3300275, 3300272 and 3300274

As noted in the following paper; Effect of Solid Waste landfill Leachate contaminates on hydraulic conductivity of landfill liners; Water Sci Technology: 2022 March 85 (5) : 1581-1599 by Metmet Sukru Ozcoban, Seren Acarer, Nese Tufekci

From the abstract of this paper;" .. however as a result of various interactions between leachate-clay liners, changes occur in the hydraulic conductivity of the liner.."

Because York 1 failed to report accurately the clay layers in the immediate area and at the site properly thru Ommission of the yellow and blue clay layers; concerns are valid that interactions unknown and unexpected could occur with the leachate-clay liner.

Given the very shallow depth of only 40-47 ft to the aquifer layer at this site the time taken for leachate movement is likely to be rapid.

Review of the Ontario Hydrologic database shows a very high presence of naturally occuring dissolved methane in the groundwater at this location, indicating the presence of micro fracture networks in the site's underlying Kettle Point Black Shale Bedrock. This additionally raises concerns of the site's suitability due to hydraulic conductivity being enhanced by micro fracture networks in the underlying bedrock.

How high levels of dissolved methane in the groundwater will react with leachate contaminates and add to leachate enhanced hydraulic conductivity are unknown and must be factored into before allowing York 1 to proceed.

This site sits over top a contact type aquifer with direct surface drainage via the wooded Molly's Creek running immediately adjacent the site and drains directly into the Sydenham river of which downstream from the site is the water intake for the town of Wallaceburg with a population of 10,000. A leachate leak due to poorly understood hydraulic conductivity places the town population of Wallaceburg at risk.

It is unknown at this site how the yellow and blue clay layers will be affected by leachate contaminates without further comprehensive studies, as noted in the below study:

Hydraulic conductivity and leachate removal rate of genetically different compacted clays: State of the Art paper, Innovative Infrastructure Solutions: July 17, 2017 Volume 2, Article number 46, (2017) by Ibrahim Adewuyi Oyediram, David Ayodek Olalusi

" ... however, the influence on the structure of the genetically different soils played a contributing role in the alternation of their mineralogy and hence their hydraulic conductivity...".

Also the extent of fractures in the site are unknown and pose a risk for enhanced hydraulic conductivity.

From the following study: Fracture effects in the shallow groundwater zone in weathered Sarnia-area clay, Canadian Geotechnical Journal Feb 1989 by A.Y, D'Astous, W.W. Rutland, J.R.C. Bruce

This paper describes how fracture networks can enhance hydraulic conductivity.

Given that Molly's Creek is wooded on both sides and that wooded zone extends directly to the bank of the Sydenham river the concerns that hydraulic conductivity is enhanced by root holes and cracks from tree roots is valid.

As discussed in the following paper: Distribution, origin, and hydraulic influence of fractures in a clay-rich glacial deposit, January 2011 Canadian Geotechnical Journal 32 (6) 957-975 by L.D. McKay, J. Fredericia

It is for the above stated reasons that York 1 should be denied approval given the hydraulic conductivity of the site is questionable and a risk to the downstream population of Wallaceburg cannot be addressed or ascertained with respect to the site's hydraulic conductivity because of the significance of York 1 's well records Ommissions.