Galibier Materials Inc. - Environmental Compliance Approval (sewage)

ERO Comment One

We have not received any supporting documentation from the Ministry so our comments do not take this potentially available information into consideration. Having said this, we do have several concerns with this ECA request ERO 019-7705 submitted by Galibier Materials. The first issue is that the ECA request is for an INDUSTRIAL SEWAGE system at the Lewis Pit. What kind of industrial sewage are we talking about, and will this be running constantly?

Response

The Environmental Compliance Approval (ECA) application is for the treatment of process water related to washing fine-grained material (i.e. silt and clay) from the aggregate resource to meet gradation specifications for construction projects. The ECA is required to permit the collection, transmission, treatment and reuse of wash water from aggregate washing operations located at the existing Galibier Lewis Pit. Since the process water used in the wash plant system is being treated using settling ponds, which allow the fine-grained material to settle out, the wash water falls under the definition of “sewage” as defined by the Ontario Water Resources Act (OWRA):

• “sewage” includes drainage, storm water, commercial wastes and industrial wastes and such other matter or substance as is specified by the regulations;
• “sewage works” means any works for the collection, transmission, treatment and disposal of sewage or any part of such works, but does not include plumbing to which the Building Code Act, 1992 applies.

ERO Comment One (continued)

We are already getting significant dust (with potentially higher than acceptable silica levels) from the existing pit lot, the contamination that will occur with a new industrial sewage system is just not acceptable given all the protected species of wildlife and flora in the immediate area. Furthermore, the submission indicates that there will be a source water pond and three settling basins located on the pit floor, which is a mere 1.5 metres from the water table. This facility is directly on top of a recognized Significant pure water recharge area for Simcoe County and the natural filtering abilities provided by layers of rock and stone has already been severely compromised by the pit mining over the years.

Response

The existing Galibier Lewis Pit has been approved by the Ministry of Natural Resources and Forestry (MNRF) to extract aggregate to a depth of 1.5 metres above the established water table as per license No. 3560. Since aggregate wash plants are common pieces of processing equipment, it is appropriate to locate the closed loop wash plant ponding system on the pit floor.

The 1.5 metres buffer must be maintained as per section 0.1(2)(a) of Ontario Regulation 244/97 of the Aggregate Resources Act. This buffer is mandated as suitable buffer to maintain the natural filtering abilities of the deposit.

ERO Comment One (continued)

The contaminated water in these settling basins will easily, quickly and regularly leak into this significant pure water recharge area. It will also naturally run downhill into the Significant Minesing Wetlands given that the existing pit is located near the top of a hill. How will Galibier guarantee there is no leaching of contaminants into the ground and how will this be monitored to ensure this does not happen?

Response

The water in the settling ponds is not contaminated. The water used by the wash plant will be clean groundwater. This water will be taken as per the conditions written in Permit to Take Water No.1036-C85QXZ, which is an MECP approval instrument. The water will be reused through the closed loop system.

The closed loop wash plant ponding system is a physical process, not a chemical process. No chemicals are added to the process. Fine grained material (i.e silt and clay that is contained with the excavated sand) will accumulate in the settling ponds after using the wash water, while this fine-grained material is native to the site. No new materials are introduced to the ground nor added to the natural groundwater system. Since there are no contaminants of concern, there is no potential for leaching of contaminants down into the shallow groundwater system.

As per consultant’s technical memorandum dated August 16, 2023, which was submitted in support of the ECA application, the consultant recommended routine maintenance and cleanout of the basins to maintain their function. This routine maintenance will ensure the efficacy of the overall system and reduce the buildup of sediment within the basins.

ERO Comment two

I am concerned about contaminants leaching into the land and destroying the pure water in our water recharge area under the pit. There will be a source water pond and three settling basins on the floor of the pit which is only 1.5 metres from the water table. The pit sits at the top of a hill that overlooks a significant pure water recharge area for the region We all know water runs downhill. What are the sewage and contaminants that the existing nearby residents and wetland environment need protection from? What are the potential risks that should be disclosed?

Response

There are no contaminants. The “sewage” (as defined by the OWRA) is merely process water related to washing fine-grained material (i.e. silt and clay) from the aggregate resource to meet gradation specifications for construction projects. The closed loop wash plant ponding system is a physical process, not a chemical process. No chemicals are added to the process. Fine grained material (i.e. silt and clay excavated with the sand) will accumulate in the settling ponds after the wash water has been used, but this fine-grained material is native to the site. No new materials are introduced to the ground, nor added to the natural groundwater system. Since there are no contaminants of concern, there is no potential for leaching of contaminants down into the shallow groundwater system. The use of settling ponds to remove fines from the aggregate is a common practice and has been successfully used by aggregate producers in the Province of Ontario for decades.

ERO Comment Three

Living nearby, exposed for years to high levels of PM10 and PM2.5, with zero remediation or even acknowledgement of responsibility, I have become very skeptical of anything this applicant proposes. Even with a “closed loop system” how is the water in the “settlement ponds” going to be prevented from leeching into the groundwater, our water source, only five feet below the extraction limit? Surely, our drinking water will be adversely affected, as will the nearby Minesing Wetlands. Obviously, my neighbours and I are strongly opposed to the granting of this application unless and until an application for Certificate of Approval for Air Emissions and approval from Simcoe Muskoka District Health Unit.

Response

The closed loop wash plant ponding system will be perched above the water table (at least 1.5 metres) as the fine-grained material (i.e. silt and clay) from the aggregate washing process will line the base of the settling pond. This natural liner provides separation from the shallow groundwater system and prevents sediment from leaching downward to the water table. To further protect shallow groundwater from sediment loading, the consultant has recommended routine maintenance and cleanout of the basins. This routine maintenance will ensure the efficacy of the overall system and reduce the buildup of sediment within the basins.

ERO Comment Four

I am writing to express my strong opposition to the proposed installation of three settling basins and a source water pond at your gravel pit site. As a concerned member of the community, I believe that this development poses significant environmental risks and raises serious questions about the impact on our local ecosystem. First and foremost, the construction of settling basins and a source water pond has the potential to disrupt the delicate balance of our natural surroundings. The introduction of these structures may lead to the disturbance of wildlife habitats, jeopardizing the diverse flora and fauna that call this area home.

Response

The closed loop wash plant ponding system will be constructed on the pit floor of the existing Galibier Lewis Pit. Since this area is already disturbed, due to the extraction of aggregate, there will be no additional disturbance to existing wildlife habitats, flora and fauna due to the construction of the ponding system.

ERO Comment Four (continued)

The discharge of gravel wash water into a settling pond carries the inherent risk of contaminating the water table and groundwater in the vicinity. This poses a direct threat to the quality and safety of our local water supply, which is a critical resource for both the community and the surrounding ecosystem. Given the potential impact on water table wells, there is a legitimate fear that harmful substances from the gravel wash water may infiltrate the groundwater, leading to contamination that could have severe repercussions for residents and the environment. This is especially alarming considering the importance of clean and safe drinking water to the well-being of our community.

Response

The closed loop wash plant ponding system does not involve the use of chemicals. The closed loop wash plant ponding system is a physical process, not a chemical process. No chemicals are added to the process. Fine grained material (i.e silt and clay) will accumulate in the settling ponds after the water has been used to wash the aggregate, and this fine-grained material is native to the site. No new materials are introduced to the ground nor added to the natural groundwater system. Since there are no contaminants of concern, there is no potential for leaching of contaminants down into the shallow groundwater system.

ERO Comment Four (continued)

Furthermore, the increased risk of water contamination is a major concern. Settling basins, if not managed and maintained properly, can become sources of sediment runoff, potentially contaminating nearby water sources. The potential negative consequences for both surface and groundwater quality are alarming, with far-reaching implications for the health of our community and the environment.

Response

The closed loop wash plant ponding system will have no direct discharge to surface water features. Since the ponding system will be constructed on the pit floor, runoff from the pit will be contained by the grade of the pit floor and by berms. Sediment runoff will not leave the portion of the site where the ponds will be constructed. To ensure the settling basins are managed and maintained properly, the consultant has recommended routine cleanout of the basins to maintain their function. This routine maintenance will ensure the efficacy of the overall system and reduce the buildup of sediment within the basins.

ERO​​​​​​​ Comment Four (continued)

This applicant has already shown their inability to manage processes on their site with the extreme release of dust and high levels of silica to the surrounding homes for close to four years. This has been an illegal discharge that the MNRF nor any other governing body has dealt with as my claim is still open two years later.

Response

The construction of a closed loop wash plant ponding system on the east portion of the existing Galibier Lewis Pit will likely reduce the generation of dust from this portion of the pit because the stockpiles of aggregate will be wet after being rinsed with wash water, thereby less susceptible to production of fugitive dust. The dust sized particles are effectively removed by the washing process.

ERO​​​​​​​ Comment Four (continued)

I have minimal confidence that this operator can effectively manage and maintain a source water pond and three settling basins. This raises serious concerns about potential Environmental consequences specifically to the Minesing Wetlands that are considered per the NVCA to have international significance.

Response

There will be no direct discharge of water from the closed loop wash plant ponding system to the Minesing Wetland, which is located more than 500 meters to the North of the existing Galibier Lewis Pit. Since it will be located in the base of the existing Galibier Lewis Pit, all water containing sediment will be confined by the grade of the pit floor and by berms.

ERO​​​​​​​ Comment Four (continued)

It is crucial that your company conducts a comprehensive environmental impact assessment, engages with the community to address concerns, and implements measures to safeguard the integrity of our groundwater. Open communication and transparency in this matter are essential for building trust and ensuring that the well-being of the community is prioritized.

Response

The ECA application process involves a comprehensive assessment that includes a review of the application and design details by a licensed professional wastewater engineer and surface water quality expert employed by the MECP. The application process is transparent and allows for public input through the Environmental Registry of Ontario.

ERO​​​​​​​ Comment Four (continued)

In conclusion, I firmly oppose the installation of settling basins and a source water pond at your gravel pit site. I believe that preserving the integrity of our environment should be a top priority, and I encourage your company to seek alternative solutions that prioritize both economic interests and the well-being of our community. I oppose the discharge of gravel wash water to a settling pond due to the associated risks to water table wells and groundwater. I implore your company to act responsibly and seek alternative solutions that prioritize environmental conservation and community health.

Response

It is the consultant’s opinion that the discharge of gravel wash water to a settling pond will not impose a risk to water table wells and groundwater as the ponds will receive clean groundwater from a water well located on-site as per Permit to Take Water No. 1036-C85QXZ. Further, the settling ponds will be perched above the water table by fine-grained material (i.e silt and clay excavated with the sand at the site) that will be naturally lined and isolated from the shallow groundwater system. If the routine maintenance recommendations made by the consultant’s in the technical memorandum dated August 16, 2023, are implemented, then the efficacy of the overall system will be maintained.

ERO​​​​​​​ Comment Five

I am writing to express my strong opposition to the proposed installation of a pond and three settling basins at your gravel pit site for aggregate wash water management. My concerns center around the potential environmental impact, water quality risks, and the long-term consequences for our local community. The construction of a pond and settling basins raises alarms regarding the management of aggregate wash water. Improper handling of this water poses a serious threat to our ecosystem, and the potential for sediment runoff into nearby water sources could have detrimental effects on both surface and groundwater quality.

Response

With respect to threats to our ecosystem, the closed loop wash plant ponding system will be constructed on the pit floor of the existing Galibier Lewis Pit. Since this area is already disturbed, due to the extraction of aggregate, there will be no additional disturbance to ecosystems related to the construction of the ponding system.

With respect to the potential for sediment runoff into nearby water sources, the closed loop wash plant ponding system will have no direct discharge to surface water features. Since the ponding system will be constructed on the pit floor, runoff from the pit will be contained by the grade of the pit floor and by berms. Sediment runoff will not leave the portion of the site where the ponds will be constructed.

With respect to groundwater quality, the settling ponds will be perched above the water table by fine-grained material (i.e silt and clay) that will be naturally lined and isolated from the shallow groundwater system. The consultant has recommended routine cleanout of the basins to maintain their function. This routine maintenance will ensure the efficacy of the overall system and reduce the buildup of sediment within the basins.

ERO​​​​​​​ Comment Five (continued)

Moreover, the introduction of these structures may disrupt the delicate balance of our local environment, affecting wildlife habitats and potentially leading to irreversible damage to the natural ecosystem. As a member of this community, I urge your company to consider alternative and more environmentally sustainable solutions that prioritize the preservation of our surroundings.

Response

The closed loop wash plant ponding system will be constructed on the pit floor of the existing Galibier Lewis Pit, which is already disturbed by the extraction of aggregate. There will be no additional disturbance to wildlife habitats nor additional damage to natural ecosystems due to the construction of the ponding system.

ERO​​​​​​​ Comment Five (continued)

In conclusion, I strongly oppose the installation of a pond and three settling basins for aggregate wash water at your gravel pit site. I urge your company to explore alternative methods that prioritize environmental conservation and community well-being. Transparent and open dialogue with the community will be crucial in addressing our shared concerns.

Response

The ECA application process is a transparent and open process that facilitates concerns from the public via the Environmental Registry of Ontario. The use of settling ponds to remove fines from the aggregate is a common practice and has been used by aggregate producers in the Province of Ontario for decades with no documented harm to community well-being.