Environmental Assessment Act R.S.O. 1990, Subsection 7(1)

This Review is subject to the provisions of Ontario Regulation 616/98 which sets out a deadline for the completion of this document. This paragraph and the giving of the Notice of Completion are the notices required by subsection 7(3) of the Environmental Assessment Act.

The Review documents the ministry’s evaluation of the environmental assessment and takes the comments of the government agencies, the public and Aboriginal communities into consideration.

Executive summary

Who

Taggart Miller Environmental Services, a joint venture of Taggart Investments Incorporated and Miller Waste Systems Incorporated.

What

Ministry Review of an Environmental Assessment (EA) for the proposed undertaking which includes the construction, and operation of the Capital Region Resource Recovery Centre (CRRRC).

Major project components are:

  • a materials recovery and recycling operation for incoming Industrial, Commercial and Institutional (IC&I) and Construction and Demolition (C&D) waste
  • an organics processing facility for the portion of the IC&I waste stream that has high organic content
  • a contaminated soil treatment and management of surplus soil facility
  • a gas management and renewable energy generation facility
  • a leachate pre-treatment facility
  • a residual waste disposal facility using engineered landfill technology with a capacity of up to 10.7 million cubic metres

When

EA submitted: July 25, 2014
Comment period: January 3 – February 20, 2015

Where

Project site is located in the City of Ottawa, east of Boundary Road and southeast of Highway 417/Boundary Road interchange. The total property is about 184 hectares (455 acres) in the Township of Cumberland.

Why

The purpose of the proposed undertaking is to provide facilities for recovery of resources and diversion of materials from disposal for wastes that are generated by the IC&I and C&D sectors in Ottawa and eastern Ontario. It would also provide landfill disposal capacity on the same site for post-diversion residuals and materials. The Project could assist in achieving City and provincial IC&I/C&D diversion objectives.

Conclusions

The EA, supplemental information and addenda were prepared in accordance with the approved Terms of Reference (ToR) and the Environmental Assessment Act, and contained sufficient information to assess the potential environmental effects of the proposed undertaking.

The Review itself is not the EA decision-making mechanism. The Minister of the Environment and Climate Change must decide whether or not to approve the EA.

Environmental assessment process

Environmental Assessment (EA) is a proponent driven planning process designed to incorporate the consideration of the environment into decision-making by assessing the effects of an undertaking on the environment. In Ontario, the Environmental Assessment Act (EAA) sets out the general contents for the preparation of an EA, as well as the Ministry of the Environment and Climate Change’s (MOECC; the ministry) evaluation process. For those proponents and undertakings subject to the EAA, approval under the EAA is required before the undertaking can proceed.

Proponents address a wide range of potential effects on the natural, social, cultural and economic environments to ensure the protection, conservation and wise management of the environment. An EA determines, on the basis of the environmental effects, if an undertaking should proceed, and if so, how environmental effects can be managed.

Environmental assessments may identify a problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the environmental effects of the alternatives and select a preferred undertaking from the alternatives. The proponent must consider actions to avoid, reduce and mitigate potential environmental effects. In preparing the EA, the proponent completes various studies and consults with interested stakeholders including government agencies, the public and affected Aboriginal communities to evaluate the alternatives and determine the preferred undertaking. Once the undertaking is approved, the proponent is required to monitor to demonstrate compliance with standards, regulations and the EAA approval.

1.1 Terms of reference

Completing the EA process involves two separate steps – the Terms of Reference (ToR) and the EA. Both are submitted to the Minister of the Environment and Climate Change (Minister) for approval. The ToR is the work plan or framework for how the EA will be prepared.

On December 17, 2012, the Minister approved Taggart Investments Incorporated and Miller Waste Systems Incorporated (Taggart Miller) ToR. In the ToR, Taggart Miller stated that the EA would be prepared in accordance with section 6(2)(c) and 6.1(3) of the EAA, thus enabling Taggart Miller to ‘focus’ the project on the construction and operation of a Capital Region Resource Recovery Centre (CRRRC) by identifying a preferred site, as well as a preferred site development concept and preferred leachate treatment option for the preferred site. The ToR set out how Taggart Miller would assess alternatives, assess environmental effects and consult with the public during the preparation of the EA.

1.2 Environmental assessment

Once the ToR is approved by the Minister, the proponent can proceed to the second step of the EA process and carry out the EA. The EA must be prepared in accordance with the approved ToR and the requirements of the EAA. Once the proponent has carried out the EA, including consultation, the EA is submitted to the ministry for review and approval by the Minister.

On January 2, 2015, Taggart Miller submitted the EA to the ministry for a decision on the proposed CRRRC, which includes diversion facilities, leachate and landfill gas management systems, and a new landfill to hold between 9.4 million and 10.7 million cubic metres of waste over a 30-year lifespan. The EA comment period ended on February 20, 2015.

1.3 Ministry review

The EA was circulated for review to a Government Review Team (GRT). The GRT, including federal, provincial and local agencies, reviewed the EA to ensure that the information and conclusions of the EA were valid, based on their agencies’ mandates. The public and Aboriginal communities also had an opportunity to review the EA and submit their comments to the ministry. All comments received by the ministry are considered by the Minister before a decision is made about the EA undertaking.

The EAA requires the ministry to prepare a review of the EA, known simply as the Ministry Review (Review). The Review is the ministry’s evaluation of the EA. The purpose of the Review is to determine if the EA has been prepared in accordance with the approved ToR and therefore meets the requirements of the EAA and whether the evaluation in the EA is sufficient to allow the Minister to make a decision about the proposed undertaking.

The Review outlines whether the information contained in the EA supports the recommendations and conclusions for the selection of the proposed undertaking. Ministry staff, with input from the GRT, evaluates the technical merits of the proposed undertaking, including the anticipated environmental effects and the proposed mitigation measures. The Review also provides an overview and analysis of the public, agency and Aboriginal community comments on the EA and the proposed undertaking.

The Minister considers the conclusion of the Review when making a decision; the Review itself is not the EA decision making mechanism. The Minister’s decision will be made following the end of the five-week Review comment period. The Minister’s decision is subject to the approval of the Lieutenant Governor in Council.

The Review comment period allows the GRT, the public and Aboriginal communities to see how their concerns with the EA and the proposed undertaking have been considered. During the Review comment period, anyone can submit comments on the EA, the undertaking and the Review. In addition, anyone can request that the Minister refer the EA, or any matter relating to the EA, to the Environmental Review Tribunal for a hearing if they believe that there are significant outstanding environmental effects that the EA has not addressed. Requests for a hearing can only be made during this comment period. The Minister will consider all requests and determine if a hearing is necessary.

A Notice of Completion of the Review was published in the Ottawa Citizen and Chesterville Record in English and Le Reflet/The News and Le Droit in French indicating that this Review has been completed and is available for a five-week comment period. Copies of the Review have been placed in the same public record locations where the EA was available, and copies have been distributed to the GRT members and potentially affected or interested Aboriginal communities.

The proposed undertaking

2.1 Project site and vicinity

The proposed CRRRC site is located in the City of Ottawa, east of Boundary Road and southeast of Highway 417/Boundary Road interchange. The total property is about 184 hectares (455 acres) in the Township of Cumberland (Figures 1 and 2). The site and the majority of the lands surrounding the site are designated ‘General Rural Area’ in the City of Ottawa’s Official Plan. The majority of the site lands are currently zoned ‘Rural’ in the City of Ottawa’s Zoning By-law; however, a small portion is zoned ‘Rural Heavy Industrial’ and currently permits waste processing and transfer. The implementation of the CRRRC will require approvals under the Planning Act (Official Plan Amendment and Zoning By-law Amendments) because the proposed CRRRC is not recognized in the present Official Plan and parts of the Boundary Road site are not currently zoned for the activities proposed at the CRRRC.

The site is currently vacant, with the exception of three residences (owned by Taggart Miller) and a model aircraft club along Frontier Road and one residence along Boundary Road (also owned by Taggart Miller). The remainder of the site is regenerating vegetative growth on land formerly used for agriculture. Agricultural lands are located to the east of the site along the opposite side of Frontier Road and a vacant, regenerating agricultural area, which is partially treed, is located to the south of the site. Various industrial uses and an industrial subdivision are located immediately to the west of the site along Boundary Road and six residences currently exist immediately to the west of the site mixed in with the industrial and commercial uses along Boundary Road. In total, nine residences are located off the site but within 500 metres of the site. The closest sensitive receptor to the proposed landfill portion of the CRRRC facility is a private residence and is approximately 85 metres from the property boundary. There is a private residence across the street from the site entrance that is about 75 metres from the property boundary. The closest sensitive receptor to the diversion facilities is a residence approximately 400 metres from the property boundary.

A golf course is located to the north of the site, on the opposite side of Highway 417. There is an existing industrial subdivision adjacent to the site and industrial/commercial activities, such as soil management, immediately northwest of the site. An auto wrecker formerly occupied some of the land on which the CRRRC is proposed.

There are currently two applications for site plans in the vicinity of the proposed CRRRC site at Boundary Road. The first application is for a Long Combination Vehicle Truck Transport De-Coupling facility at the southeast corner of the Boundary Road and Highway 417 interchange. The second application is for a Light Industrial Use, including a warehouse and office, within the Industrial Subdivision directly west of the proposed CRRRC lands. Both proposed site developments are considered industrial/commercial in nature and are consistent with the immediate surrounding area.

The CRRRC site is underlain by approximately 32 metres to 40 metres of soil, representing one of the thicker areas of soil deposits within the area. Much of the area is underlain by deposits of offshore marine silts and clays associated with the former Champlain Sea. These marine deposits are underlain by glacial till deposits situated above the bedrock. Because of the naturally poor water quality at depth beneath and in the area of the site, water supply is generally provided by means of shallow dug wells that obtain their water primarily from the surficial silty sand layer. Major surface water features within the vicinity of the site (i.e., the Castor River and Bear Brook Creek) generally drain in an easterly direction following the general topographic slope. Drainage in the vicinity of the site is mainly by means of a network of agricultural ditches and three municipal drains. There are roadside ditches along Boundary, Devine and Frontier Roads that eventually all drain eastward. The site is characterized by a mix of thickets, immature deciduous forests, swamps, agricultural fields and disturbed areas.

2.2 Description of the proposed undertaking

The proposed undertaking involves the construction and operation of the CRRRC. The proponent’s EA states that the purpose of the proposed CRRRC is to provide facilities and capacity for recovery of resources and diversion of materials from disposal for solid non-hazardous wastes that are generated by the IC&I and C&D sectors. Specifically, Taggart Miller is seeking approval for:

  • a materials recovery and recycling operation for incoming IC&I and C&D waste
  • an organics processing facility for the portion of the IC&I waste stream that has high organic content
  • a contaminated soil treatment and management of surplus soil facility
  • a gas management and renewable energy generation facility
  • a leachate pre-treatment facility
  • a residual waste disposal facility using engineered landfill technology with a capacity of between 9.4 and 10.7 million cubic metres

The site layout positions all diversion and support facilities in the northern section of the property while the landfill, associated stormwater management components and perimeter buffers will be located in the southern section of the site. An access road to the site, administration building, parking, and small load drop-off will be developed on the site. Surface water management consists of a system of site grading, ditching and culverts leading to five stormwater ponds.

The landfill component of the CRRRC will require between approximately 9.4 and 10.7 million cubic metres of airspace volume for a period of 30 years. The total landfill footprint is approximately 84 hectares and will receive a maximum of 450,000 tonnes per year. The landfill base will be surrounded with a perimeter containment berm that will accommodate a perimeter road, header piping for leachate and landfill gas (LFG) collection and other service lines, and provide conveyance of runoff to the stormwater management system. The perimeter berm will be constructed with a low permeability hydraulic barrier and the natural low permeability silty clay deposit will provide leachate containment. The leachate will be conveyed through a system of perforated and non-perforated leachate piping and a granular drainage blanket and leachate sumps (manholes) will be provided within the landfill.

Leachate will be pre-treated on-site and trucked off-site to the City of Ottawa wastewater treatment plant, Robert O Pickard Environmental Centre (ROPEC). The on-site pre-treatment facility will include an equalization tank, leachate storage pond, liquor storage tank, boilers and heat exchangers, chemical precipitation contingency to reduce elevated metals toxic to the biological treatment if they occur, Sequencing Batch Reactor (SBR) system, effluent storage pond, truck filling station and sludge management system. It will pre-treat both leachate from the landfill and liquor from the on-site organics processing facility.

The main haul route from Highway 417 would be south along Boundary Road to the site access point off of Boundary Road at the north end of the site (see Figure 1). The secondary site access/exit is proposed at the north end of the site off of Frontier Road.

A petroleum hydrocarbon contaminated (PHC) soil treatment site will be approximately 1.2 hectares and includes the construction and operation of up to eight biopile cells and a PHC soil receiving building. Surplus uncontaminated soil may be temporarily stored in a surplus soil management area.

The two main diversion buildings are the Materials Recovery and Construction and Demolition Processing Facilities. The C&D facility will house mechanical and manual sorting and both buildings will use a fuel oil fired heating system. Both buildings will have a dust collection system that will discharge though a bag house and cyclone with the air vented through the roof. Additional diversion components may be added to the CRRRC over time as technology or end markets develop.

A demonstration scale BioPower facility will be located within the overall organics processing area and will be expanded as required. The demonstration period is intended to be between 24 to 36 months and will accommodate 4,000 tonnes of organic waste per month, not to exceed 23,400 tonnes per year. Development into a full-scale plant will depend on the results of the demonstration phase, market demand and subsequent approvals, if required. The BioPower facility will include the following: organics pre-processing building, biofilter, primary reactor, secondary reactor, negative pressure extraction system, flare, equipment for operations and monitoring and analytical equipment. The organics facility will accept source-separated organics from IC&I sources, pre-process them on-site and transport the resulting organics slurry to an approved off-site farm or other commercially available anaerobic digester for processing.

If EAA approval is granted, the CRRRC will be completed in accordance with the terms and provisions outlined in the EA; any proposed conditions of approval; and will include the details outlined above. In addition, Taggart Miller must still obtain all other approvals it may require for the undertaking.

Figure 1

Site plan showing the location of Capital Region Resource Recovery Centre study area in relation to nearby roads, railways, utility lines, surface water features, water areas and populated areas. Nearby populated areas include Carlsbad Springs (north), Vars (east), North Russell (south) and Edwards (west). The area is bound by Highway 417 to the north, Frontier Road to the east, Devine Road to the south, and Boundary Road to the west.

View a larger version of this map (PDF)

Figure 2

Site development plan showing the layout of the proposed water reclamation centre, including: proposed facility buildings, outdoor diversion areas, roads, property boundaries, vegetation screening, constructed screening features, landfill and perimeter berm contours, and stormwater management ponds. The facility buildings are located on the northeast corner of the property, and the landfill covers most of the southern half of the property. The entire property is surrounded by vegetation screening.

View a larger version of this map (PDF)

Results of the ministry review

The Review provides the analysis of the EA. The Review is not intended to summarize the EA, nor present the information found in the EA. For information on the decision making process, refer to the EA itself. The EA and supporting documentation outlines the EA planning process and demonstrates how the proponent has selected the preferred undertaking and made the final decision.

3.1 Conformance with ToR and EAA

3.1.1 Ministry analysis

The ministry coordinated an analysis of the EA with the GRT that, in part, looked at whether the requirements of the ToR have been met. The ministry has concluded the EA followed the framework outlined in the ToR, and has addressed the commitments made in the ToR. In addition, the EA has satisfied the requirements of the EAA.

Appendix A summarizes this analysis and identifies how the ToR requirements have been addressed in the EA.

3.1.2 Consultation

One of the key requirements of the EAA is consultation completed during the preparation of the EA. This consultation is the responsibility of the proponent and must be taken prior to the submission of the EA and in accordance with the consultation plan outlined in the ToR.

During the preparation of the EA, Taggart Miller carried out a consultation process that allowed for multiple opportunities for the exchange and review of information pertaining to the proposed Project by the GRT, public, and Aboriginal communities and organizations.

In accordance with the consultation commitments that were outlined in the approved ToR, Taggart Miller carried out the following consultation methods during the preparation of the EA:

  • Establishing and maintaining a stakeholder contact list
  • Providing Project related information and updates throughout the EA process by way of a Project web site, the publication of milestones and consultation events in newsletters, written and electronic correspondence, site visits, and holding four open houses
  • Letters and email correspondence distributed to the public (including those who requested to be on the project mailing list), GRT agencies and Aboriginal communities
  • Meetings with interested Aboriginal communities
  • Maintaining a consultation database and Consultation Record documenting all issues or concerns that were raised during the preparation of the EA, and the responses to them
  • The draft EA was made available for GRT, public and Aboriginal community comment prior to finalization and submission to the MOECC. The draft main EA document (excluding the technical appendices) was made available in both French and English

In accordance with the requirements of section 6(3) of the EAA, Taggart Miller documented its consultation process in a Record of Consultation, which provides a summary of the issues and concerns raised during the consultation process on the EA. The Consultation Record was provided in Volume II of the EA.

Once the EA is submitted to the ministry, ministry driven consultation occurs in the form of the EA comment period. The GRT, the public and affected Aboriginal communities are provided with the opportunity to review the EA and to submit comments to the ministry on whether the requirements of the ToR had been met, on the EA itself and on the proposed undertaking. All comments received by the ministry during the EA comment period were forwarded to Taggart Miller for a response. Summaries of comments received along with Taggart Miller’s responses are included in Tables 1 and 2. Copies of the submissions are also available in Appendix B. Please contact the ministry for complete responses to public comments. A summary of key issues raised can be found in sections 3.2.1 and 3.3.1 of this Review.

Government Review Team

Taggart Miller sought input from members of the GRT including provincial ministries, federal departments, municipal agencies, public utilities, private corporations and others. During the preparation of the EA, Taggart Miller engaged members of the GRT to: identify those regulatory and government agencies that may have a potential interest in or mandate related to the proposed undertaking; any approvals or permit requirements administered under their respective jurisdictional authorities; and any potential concerns about the proposed undertaking.

Taggart Miller consulted the GRT through a variety of means including telephone calls, formal meetings and written and electronic correspondence. A summary of the consultation process carried out during the preparation of the EA with members of the GRT is provided in Volume II and Section 3 of the EA.

A draft version of the EA was made available to the GRT for review and comment between June 11, 2014 and July 31, 2014. The comments received from the GRT on the draft EA and Taggart Miller’s responses to them can be found in Appendix K-2 and K-3 of Volume II of the EA. Following formal submission of the EA to the ministry, GRT members from various agencies were provided copies of the EA for their review during the seven-week comment period, which began January 2, 2015 and ended February 20, 2015. Comments from the GRT, as well as Taggart Miller’s responses can be found in Table 1 and Appendix B. A summary of key issues raised can also be found in sections 3.2.1 and 3.3.1 of this Review.

Public consultation

Members of the public, which includes the general public, interest groups, local organizations, property owners and other stakeholders, were provided with several opportunities to participate and provide input during the preparation of the CRRRC Project EA. Taggart Miller carried out consultation during the preparation of the EA with members of the public in a variety of ways, including: holding four open houses; sending written correspondence; publishing newspaper notifications of EA milestones and consultation opportunities; and posting information and materials to a project website.

The objective of the public consultation was to inform and seek input from interested members of the public on the EA process and the proposed undertaking. A detailed summary of the public consultation process carried out during the preparation of the EA can be found in Section 3 of Volume I of the EA.

The draft EA was made available to the public for review and comments for a 45-day comment period between June 11, 2014 and July 31, 2014. Comments received from the public on the draft EA and Taggart Miller’s responses to them can be found in Appendix K-1 in Volume II of the EA. Members of the public were also provided with an opportunity to review and comment on the EA during the seven-week inspection period that commenced with the formal submission of the EA on January 2, 2015. The inspection period was coordinated by the ministry and members of the public were asked to provide any comments directly to the ministry for consideration.

During the formal comment period on the EA, comments from approximately 70 stakeholders or members of the public were received by the ministry. A number of form letters in opposition to the proposed project due to concerns related to water quality, natural environment and traffic. Refer to Section 3.3.1 of this Review for the key issues raised. As with the comments received from the GRT, the ministry forwarded all public comments to Taggart Miller for a response. A summary by issue of the public comments received and Taggart Miller’s responses can be found in Table 2 of this Review.

Aboriginal community consultation

In addition to public consultation, proponents are required to consult with Aboriginal communities that have credibly asserted aboriginal or treaty rights that may be negatively affected by the project. During the preparation of the EA, Taggart Miller contacted the MOECC, the Ministry of Aboriginal Affairs and Aboriginal Affairs and Northern Development Canada for assistance with developing a list of those Aboriginal communities that should be consulted in the EA process. The following Aboriginal communities and organizations were identified as having a potential interest in the proposed undertaking:

  • Métis Nation of Ontario
  • Ottawa Métis Nation Council
  • Algonquins of Ontario Consultation Office
  • Algonquins of Pikwakanagan First Nation
  • Mohawks of Akwesasne
  • Algonquins of Ottawa

The Aboriginal communities were contacted at key milestones during the preparation of the EA, including being provided with the Notice of Commencement, notification of open houses and the Notice of Completion. A summary of the consultation with Aboriginal communities can be found in section 3.6.7 of Volume I and Appendix G of Volume II of the EA. Three communities participated in the preparation of the EA: the Algonquins of Ottawa; the Algonquins of Ontario (AOO); and the Mohawk Council of Akwesasne.

The Chief of the Algonquins of Ottawa attended Open House #3 and indicated that he was satisfied with the information presented and that the sites were to be located on private land. The Chief also indicated that the proposed project did not affect the interests of the Algonquins of Ottawa and advised that the Algonquins of Ontario Consultation Office was reviewing the project on behalf of all Ontario Algonquins. However, the proponent added the Algonquins of Ottawa to the consultation list as they were not previously identified as having potential interest in the undertaking. The Algonquins of Ottawa did not attend any subsequent open houses or provide any comments on the draft or final EA.

The consulting team met with the Algonquins of Ontario (AOO) on two separate occasions. During the first meeting the consulting team gained a better understanding of who was representing the AOO and their interest in the CRRRC. The second meeting was held in regard to the AOO’s review of the draft Stage 1 archeological assessment report, on which the AOO had previously provided comments (See Volume II, Appendix G-3 of the EA), as well as to discuss the AOO’s opinion on site development concepts. The AOO also requested a CRRRC project status report update to present at an upcoming AOO meeting. An update was later provided and included the alternative site development concepts and a summary document.

The Mohawk Council of Akwesasne requested to meet with Taggart Miller representatives following receipt of the draft EA. A presentation outlining the proponent, the project and its evolution, the layout and structure of the draft EA report, a review of some results of the EA and a summary to Aboriginal outreach completed to date was delivered. The meeting was well received and a subsequent meeting was held to discuss opportunities to work together.

In addition to the above, a draft version of the EA was made available to the Aboriginal communities and organizations for review and comments for a 45-day comment period between June 11, 2014 and July 31, 2014. Aboriginal communities and organizations were also provided with an opportunity to review and comment on the final EA during the seven-week inspection period that commenced with the formal submission of the EA on January 2, 2015. The inspection period was coordinated by the ministry and Aboriginal communities and organizations were asked to provide any comments directly to the ministry for consideration.

The ministry followed up with the Aboriginal communities and organizations to confirm receipt of the final EA. The Métis Nation of Ontario, Algonquins of Ontario Consultation Office, Algonquins of Pikwakanagan First Nation and Mohawks of Akwesasne confirmed receipt of the final EA; however, no comments were received. The proponent provided delivery receipts to the ministry showing that the EA documents were delivered to all of the communities and organizations included on the Aboriginal consultation list.

3.1.3 Conclusion

The ministry is satisfied that the consultation carried out by the proponent meets the requirements of the EAA and is in accordance with the approved ToR. Further, the ministry believes that Taggart Miller provided sufficient opportunities for the GRT, the public, interested stakeholders and Aboriginal communities and organizations to be consulted during the preparation of the EA.

The EA documents the consultation methods that were undertaken by the proponent to engage government reviewers, Aboriginal communities and members of the public during the development of the EA. The EA discusses the concerns raised and how they were addressed or will be addressed if the EA is approved.

3.2 EA process

Environmental Assessment is a planning process that requires a proponent to identify a problem or opportunity, consider alternative ways of addressing the problem or opportunity, evaluate the potential effects of those alternatives against select criteria and then select a preferred alternative. In general, Taggart Miller followed a logical and transparent decision making process that was outlined in the EA. Below is a summary of Taggart Miller’s EA methods, including the study areas used and the method for assessing alternatives and environmental effects. Refer to Appendix A of this Review for the ministry’s analysis of how the EA met the requirements of the EAA and the approved ToR.

Focused EA

In the ToR, Taggart Miller identified that it would undertake a focused EA to evaluate the CRRRC. The proponent’s ToR included a screening of the ‘alternatives to’ which analyzed the ability of the alternatives to address the identified opportunity; if the alternative was financially viable; if Taggart Miller was able to implement the alternative; and if the alternative was approvable and likely to use a proven technology. Based on this, Taggart Miller identified that establishing diversion facilities on a Taggart Miller site and managing disposal of residuals material not diverted in a landfill on one site was the only reasonable ‘alternative to’. A summary of the screening was provided in Section 5.0 of the EA.

The EA assessed alternative methods of potential site locations, as well as design concepts including haul routes for the CRRRC, as well as leachate management systems for the preferred site, per the approved ToR.

Study area

The study areas for the EA process comprised the site study area and the site-vicinity study area extending to a 500 metre buffer zone surrounding the site boundary and haul route, which included the main haul/access route(s) to the site from Highway 417. The site-vicinity study area was modified or extended for individual environmental components as appropriate.

The proponent indicated in its EA that the CRRRC is not located within a Source Water Protection Area.

Assessment of alternative methods and environmental effects

Taggart Miller identified nine environmental components to be assessed as part of the EA: atmosphere; geology, hydrogeology and geotechnical; traffic; surface water; biology; agriculture; design and operations; land use and socio-economic; and cultural heritage resources. The effects of each alternative method, haul route and leachate management option on these components was assessed, and were used to develop appropriate mitigation measures.

Assessment of alternative methods

For the identification of the preferred site, Taggart Miller compared two potential sites (Boundary Road site and North Russell Road site) based on a set of criteria and indicators for each environmental component. In-design mitigation measures were considered and the advantages and disadvantages for each alternative site were discussed. Based on this evaluation, the Boundary Road site was selected as the preferred site for the CRRRC. The proponent’s assessment of alternative sites is set out in Section 7.0 and TSD #1 of the EA.

Taggart Miller’s ToR identified five potential haul routes for the North Russell Road site and identified only Boundary Road as the haul route to the Boundary Road site. As indicated in Taggart Miller’s EA, only the haul route to the Boundary Road site was assessed as part of the EA because the North Russell Road site along with its alternative haul routes were removed from consideration during the comparative evaluation of the two sites.

Two alternative development concepts (Concepts A and B) for the Boundary Road site (site layout) were evaluated in Section 9.0 of the EA. The proponent identified the preferred development concept through comments received at an Open House, the project website, and ministry technical reviewers and Aboriginal communities. Based on this, the proponent identified the advantages and disadvantages of each development concept and identified Concept A as the preferred option, which was further refined in the EA (Figure 2 of this Review).

The alternative methods to leachate management for the landfill and organics processing facility were identified and assessed in Section 12.0 of Taggart Miller’s EA. A comparative evaluation of the environmental components for both on-site pre-treatment/off-site treatment and complete on-site treatment was completed. On-site pre-treatment/off-site treatment at the City of Ottawa’s ROPEC was identified to be the preferred alternative for leachate management.

Environmental effects

The assessment of air quality and odour focused on predicting changes in the concentrations of selected indicator compounds, as well as an assessment of greenhouse gases. Taggart Miller assessed noise associated with landfilling operations and ancillary facilities, as well as noise associated with off-site truck traffic along the haul route using sensitive points of reception and comparing modelled results to ministry standards.

The assessment of the hydrogeological component involved using regional groundwater flow and contaminant models to study the potential for the project to affect off-site groundwater levels and supply. The assessment of potential geological effects was based on the review and interpretation of published geologic and seismic information for the area. Geotechnical investigations were also completed. Surface water quality and quantity were assessed by comparing pre-development results with post-development modelling.

The biology component consisted of an evaluation of existing terrestrial ecosystems and aquatic ecosystems. Available literature, data and agency material were identified, obtained and used to assist in describing natural features in the area including past natural feature surveys for the site and site vicinity. A number of site visits were completed to verify and assess published information. Several terrestrial surveys were carried out including avian; mammals/deer yard usage; amphibian; reptile; butterfly and dragonfly; and Species at Risk (SAR). Aquatic surveys included fish and benthic community surveys completed in appropriate seasons.

The assessment of land use and socio-economic environment were broken down into three sub-components: land use, socio-economic and visual. The proponent reviewed the Official Plan, Provincial Policy Statement, 2014, as well as ministry guidelines to determine the compatibility of the proposed project with surrounding land uses. The socioeconomic assessment involved collecting data on employment, tax revenue, goods and services required for construction and effects on businesses. A visual assessment was completed using a 3D model of the proposed site.

The proponent’s EA also included an assessment of on-site and off-site effects to agricultural lands. Traffic effects were assessed by determining the number of site generated trips, and also evaluated operations at the site access at Boundary Road and the intersections in the area of the site.

Cumulative effects assessment

A cumulative effects assessment is not a requirement of the provincial EA process; however, Taggart Miller completed a cumulative effects assessment considering guidance from the federal EA process, as well as other jurisdictions.

This analysis considered the residual effects of the CRRRC and the potential for these residual effects to interact with other projects or activities, which when combined may result in an adverse effect to an environmental component. The proponent identified in its EA the environmental components for analysis, and past, present and/or reasonably foreseeable future projects. The predicted effects of the CRRRC and the potential for the effects of the other identified projects and activities to overlap with those of CRRRC in time, space and type of effect were considered. Finally, the significance of any identified residual cumulative effects was evaluated.

Based on this analysis, the only areas of potentially significant cumulative effects are surface water quality, given the elevated existing concentrations of some parameters (iron and phosphorous) in surface water, and cumulative effects from traffic. The proposed CRRRC stormwater management plan incorporates a number of features to ensure surface water leaving the site meets regulatory requirements, and also includes contingency measures based on ongoing monitoring results. The proponent’s EA indicates that there is some uncertainty regarding the cumulative effects to traffic at Boundary Road/Highway 417. Traffic mitigation measures may be considered in the future by the City when assessing any future project proposals, such as road improvements. Therefore, no additional traffic mitigation measures beyond the left turn lane and road improvements already proposed for the CRRRC access off Boundary Road have been identified as a result of the proponent’s cumulative effects assessment.

Climate change

Section 11.2.2.2 of Volume I of the proponent’s EA provides a life cycle assessment of the potential reduction in greenhouse gas (GHG) emissions assuming landfilling all of the wastes received at the CRRRC compared to the diversion from landfill of a portion of the waste. The proponent’s EA indicates that at the maximum proposed receipt of waste materials of 450,000 tonnes per year at the CRRRC facility, the annual GHG emission reduction is estimated to be between 113,000 and 257,000 tonnes CO2eq (carbon dioxide equivalent), compared to only landfilling.

In addition, the landfill will be provided with an active landfill gas (LFG) collection system, connected to a flare, as well as power generating engines. The proposed LFG collection system will consist of a network of horizontal gas collection piping installed within the landfill, which will result in maximizing the capture of the GHG generated by the landfill before it can be released to the atmosphere.

The City of Ottawa participates in the Federation of Canadian Municipalities Partners for Climate Protection (PCP) Program. The PCP Program outlines five milestones for municipalities to reach, through the activities undertaken by both the municipality and the community, to take action on climate change. In May 2014, the City of Ottawa released its updated Air Quality & Climate Change Management Plan. The goals and objectives of the plan include reducing dependence on fossil fuels by implementing programs that encourage renewable energy and reducing GHG by continued LFG management system enhancements. The proponent indicated that the proposed CRRRC components and activities, as described above, will assist the City in working towards achieving these objectives of the Management Plan.

During the post-closure period, longer term changes in precipitation and temperature could possibly affect the growth of the vegetative cover on the closed landfill and/or runoff of surface water from both the landfill and diversion facility areas of the CRRRC property and the performance of the components that comprise the stormwater management system. For example, an increase in precipitation and/or an increase in storm intensity or duration would increase the amount of runoff, potentially resulting in surface erosion of the vegetated landfill final cover surface and exceedance of the capacity of the stormwater ponds. If such effects were to occur, these would be handled as part of the post-closure monitoring and maintenance activities; for example, by increasing stormwater pond capacity and by re-vegetating eroded areas. The stormwater management system will be designed to handle severe storm events.

3.2.1 Key issues

Key issues regarding the EA process completed by Taggart Miller for the CRRRC were gathered during the pre-submission consultation and the EA review comment period. One issue was raised by a number of members of the public regarding the EA process. The ministry also raised an issue with the EA process. A summary of these issues and proponent responses are provided in subsequent sections. All comments, including Taggart Miller’s responses and MOECC’s level of satisfaction can be found in Tables 1 and 2.

Rationale/need for the project

A number of comments were received about the need for additional landfill capacity in the Ottawa area. These comments indicated that additional capacity is not required because the existing landfill capacity already meets the needs of the area. In response, Taggart Miller directed the commenters to Supporting Document #1 of the approved Terms of Reference (also summarized in Section 4.0 of the EA), which demonstrated the rationale for the project and determined that landfill capacity for the IC&I and C&D waste streams would be needed through the planning period to 2046 for the City of Ottawa and eastern Ontario.

This assessment was based on the selection of a potential service area (City of Ottawa and eastern Ontario), identifying the known diversion and disposal facilities for IC&I and C&D waste, compiling data available to Taggart Miller on waste generation and diversion within the potential service area, and future IC&I and C&D waste generation and materials requiring management by diversion and disposal were estimated. The assessment method included an approach to estimate waste generation volume (for IC&I/C&D) as a direct function of population. The ministry is satisfied that the rationale for the proposed project was provided in the approved ToR.

Amending procedure

The proponent’s EA included an amending procedure for minor changes to the undertaking. The ministry requested that the amending procedure be removed or revised as changes to the undertaking would need to follow the requirements under Ontario Regulation 101/07 (Waste Regulation) under the EAA. The proponent amended the EA by replacing the original amending procedure with text indicating that minor modifications to the undertaking may be made following consultation with the ministry to confirm requirements under the EAA, if any. The revised text is provided on the proponent’s website. The ministry is satisfied with the revised amending procedure.

3.2.2 Conclusion

Overall, the ministry is satisfied with Taggart Miller’s decision making process, including demonstrating the rationale for the proposed undertaking. The EA contains an explanation of the problem that prompted the EA. Taggart Miller considered a reasonable range of alternative methods to the undertaking and evaluated them in a defined study area that took into consideration the EAA’s broad definition of the environment.

The EA provides a description of the potentially affected environment in the study areas and identifies potential effects of the alternatives. The EA also includes monitoring and contingency plans to ensure that any potential negative impacts of the undertaking are minimized.

The EA adequately describes the advantages and disadvantages of the proposed undertaking to the environment based on the potential environmental effects. Requirements in the EAA for consultation with the public, GRT and Aboriginal communities have been met. The ministry is satisfied that the EA was completed in accordance with the approved ToR and meets the requirements of the EAA.

3.3 Proposed undertaking

3.3.1 Key issues

Key issues regarding the proposed undertaking were gathered during the pre-submission consultation and the EA review comment period. Key issues that were raised are summarized below. All comments, including Taggart Miller’s responses and the ministry’s level of satisfaction can be found in Tables 1 and 2.

Waste diversion

During the seven-week review period, members of the public indicated their concern that Taggart Miller is only proposing a diversion target of 16% for IC&I waste. Taggart Miller clarified that the waste composition expected at the CRRRC includes organics, IC&I (not including organics) soils and C&D materials. As noted in the proponent’s EA, there are different diversion rates proposed for each of these four components. The diversion rates reflect diversion technology/processes and end markets for the diverted materials. For the mixed IC&I component (not including organics), Table 9.1-1 of the EA states that the diversion target is 16% with a range of 11-28%. This may have led to the belief that overall diversion rate targeted at the CRRRC would only be 16% for all materials received. However, the overall diversion range for the CRRRC facility is 43% to 57% as identified in Table 9.1-2 of the EA

The ministry’s waste reviewer commented on the need for Taggart Miller to prioritize waste diversion at the CRRRC facility. The proponent responded by providing a Waste Diversion Protocol on the proposed ways the facility plans to maximize diversion of waste over time (Appendix C to this Review). The proposed CRRRC will focus on integrated waste management services for the IC&I and C&D sectors. The proponent states that an important element to increase waste diversion performance over time will be to work with IC&I and C&D generators and haulers who use the facility by implementing a series of off-site and on-site protocols.

For off-site diversion efforts, Taggart Miller has committed to work with generators on identifying recoverable materials and organics in their waste streams, facilitate documented audits of the customer’s waste stream, provide recommendations on efficient source separation, author guidelines and deliver the appropriate numbers and types of containers, coordinate workshops, and follow-up via workshops and meetings, as required. On-site operational protocols to mitigate disposal are outlined in the Design & Operations (D&O) Report included in Volume IV of the submitted EA.

It is the stated intention of the proponent to implement these initiatives prior to commencing operations at the CRRRC facility, to work with government and industry associations to promote regulations and policies in favour of diversion, and to report annually to the ministry on the progress made on this Waste Diversion Protocol. For more details on the Waste Diversion Protocol, please see Appendix C of this Review.

The ministry is satisfied with the proponent’s responses and has no outstanding concerns regarding waste diversion. If the undertaking is approved under the EAA, a Condition of Approval requiring the proponent to report on the waste diversion initiatives outlined in the Waste Diversion Protocol may be required throughout the operation of the site.

Leachate management

The ministry’s wastewater reviewer expressed concerns that wastewater management at the site would be dependent on approval from the City of Ottawa to accept the pretreated leachate at the ROPEC. If this approval could not be granted from the City of Ottawa, Taggart Miller would be required to revise its comparative evaluation of leachate management alternatives for the selection of a preferred leachate management option. The wastewater reviewer indicated that this revised comparative evaluation, if required, should be completed prior to EA approval.

Taggart Miller responded that in the motions approved by the City of Ottawa Council in the spring of 2015, the City will allow the receipt of the pre-treated leachate from the CRRRC at the ROPEC; therefore, confirming the preferred alternative for leachate management identified in the EA. The ministry is satisfied that the pretreated leachate from the CRRRC will be trucked to the ROPEC, and there are no outstanding issues associated with the leachate management system at the CRRRC.

Landfill design

Many members of the public submitted comments regarding the landfill design, specifically that the landfill design will rely on natural attenuation with a perimeter containment berm and geosynthetic clay liner around the sides of the landfill for leachate management. Members of the public referred to the Leda clay, which is located at the site, and claim that it is structurally weak and would not be able to support a natural attenuating landfill. In addition, many members of the public reference a report completed by a consultant retained by the Region of Ottawa-Carleton (RMOC) in 1984 for a Waste Management Master Plan (WMMP). The WMMP was published in 1987 and identified the Boundary Road site, referred to as Site 10 in the WMMP and the preferred site in the CRRRC EA, as the preferred site for a new landfill. Members of the public indicated that Site 10 was later rejected as a result of the high water table and structurally unsound Leda clay.

In response, the proponent referred to the Frequently Asked Questions (FAQ) page posted on the CRRRC project’s website, which describes the outcome of the WMMP. Taggart Miller explains that the site was not considered for a new landfill following the release of the WMMP because it was determined that decisions made by the RMOC were not properly documented through the development of the WMMP. In the end, it was determined that this may pose a challenge for the approval of the WMMP. Therefore, it was not the site conditions that prevented the implementation of the WMMP. In general, technical experts concluded that there were no significant environmental impacts that could not be mitigated.

The ministry’s hydrogeology and waste engineers reviewed the public comments and are satisfied with the proponent’s responses. The ministry’s waste and hydrogeology engineers are also satisfied that the proposed landfill design, as well as the proposed monitoring and contingency plans will be sufficient for managing leachate and the protection of groundwater.

Natural Resources Canada (NRCan) and the Ontario Geological Survey (OGS) will review Golder’s report, as well as any public comments received related to subsurface structure during the Ministry Review period and the proponent’s responses, prior to a Minister’s decision on the proposed undertaking.

Traffic assessment

The Ministry of Transportation (MTO) had concerns with the assessment completed in Technical Support Document #9 - Traffic Impact Study, namely that the intersection at Boundary Road and Thunder Road was not considered as part of the assessment. Taggart Miller prepared an Addendum in response to MTO’s concerns. The proponent’s Addendum assessed the operation of the Boundary Road and Thunder Road intersection during the AM and PM peak travel hours. The intersection is approximately 600 metres north of the proposed CRRRC site. The operational analysis included in the Addendum of the intersection of Boundary Road and Thunder Road determined that the additional traffic expected from the CRRRC facility would result in a minor impact on the operation of the intersection, thus, no modifications to the intersection are required due to the CRRRC. The full Addendum is posted on the proponent’s website for more information.

Addendum 2 to Technical Support Document #9 – Traffic Impact Study was similarly prepared by the proponent to address a series of MTO comments and concerns:

  • Utilization of more recent traffic counts provided by the City of Ottawa and the MTO when anticipating proposed Plans of Subdivision opposite Thunder Road
  • Updated truck percentage at intersections as provided and documented in the City of Ottawa and MTO traffic counts, as well as percentage of trucks determined in the Dillon Transportation Impact Study for the proposed truck transfer terminal
  • Updated analysis to examine the impact of the CRRRC site at both 5 and 10 years beyond the 2017 opening date
  • Assurance that traffic generation from maintenance and staff is minimal to null due to 6 am to 6 pm operating hours differing from normal AM and PM peak travel hours
  • Assurance that CRRRC site access is sufficient to provide a southbound Boundary Road left turn lane into the site and a northbound Boundary Road left turn lane onto Thunder Road
  • Assurance that the number of truck trips will be recorded as part of the operation and the average number of peak hour trucks will be compared to that assumed in the traffic study, and can be reported annually in the site monitoring report
  • Assurance that a proposed berm and tree screen for the flare and power generation units will effectively hide the view of this equipment from Highway 417

The full Addendum 2 is posted on the project website for more information. The MTO is satisfied that the supplemental addenda provided by Taggart Miller address its concerns.

Air and odour management

Senes, a consulting firm, and the ministry’s air quality analyst had a number of concerns with the proponent’s assessment of air quality in the final EA for the landfill and organics processing facility. Specifically, the ministry’s air quality analyst requested revised modelling for the landfill release height, additional information on potential odour sources related to loading and unloading of the organic processing facility and overall handling of potentially odorous organic material, potential for air quality impacts as a result of wood grinding and chipping, potential for higher emissions of particulate with the use of contaminated soil for daily cover and a revised landfill gas generation rate calculation for use in developing emissions rates used for dispersion modelling. The ministry requested that an Air Assessment Addendum be submitted to the ministry for review to address the ministry’s air analyst’s concerns.

The proponent provided an Air Assessment Addendum that addressed the ministry’s concerns. With regard to potential impacts due to wood chipping, the proponent indicated that this activity would be infrequent and the impacts are not significant. The proponent provided additional information on mitigating the potential impacts of odour from handling of organic slurry. The proponent revised its modelling for the landfill release height and detailed the results in the addendum. Additional detail on best management practices and commitments were also provided for the use of contaminated soil as daily cover and paved road dust control.

The Air Assessment Addendum is posted on the project website for more information. The ministry is satisfied that the supplemental addendum provided by Taggart Miller addressed its concerns on air quality and odour.

Biological studies and assessment

A member of the public had a number of concerns with the studies and assessment provided in Technical Support Document #4 – Biology and the CRRRC EA. The concerns focussed on the inadequacy of the field and desktop studies completed and questioned the resources used to complete the assessment and field surveys.

Taggart Miller responded indicating that the desktop and field studies, as well as the assessment was completed in accordance with the approved ToR and with applicable information sources and guidance materials recognized by the Ministry of Natural Resources and Forestry (MNRF). The MNRF reviewed the comments from the member of the public and the proponent’s responses and provided further comments for the proponent’s consideration. These additional comments focused on the potential for the identification of western chorus frog, a species protected under the federal Species at Risk Act, and snapping turtle, a species protected under Ontario’s Fish and Wildlife Conservation Act, 1997, within the study area. In addition, the MNRF requested recognition of the Invasive Species Act, 2015 (ISA), and noted that a detailed proposal would be required if the salvage and relocation of fish is necessary during potential flooding events at the site.

The proponent committed to following applicable legislation if snapping turtle or western chorus frog are identified at the site during construction or operation. Although the ISA was not in place at the time the EA was completed, the proponent indicated that any applicable requirements of the ISA will be addressed in the development of the site. The proponent committed to obtaining a scientific collection permit from the MNRF prior to fish salvage. These additional commitments were provided to the ministry in an updated EA commitment list. Based on this, the ministry and MNRF are satisfied with the studies and assessment documented in Technical Support Document #4 – Biology and the CRRRC EA.

Seismicity

The draft EA was provided to Natural Resources Canada (NRCan) for their review of bedrock and surficial sediment geology, as well as seismicity. The comments from NRCan on the draft review were provided to the Ontario Geological Survey (OGS) for review and comment. NRCan raised concerns about the interpretation of the silty layer and its relevance to assessing possible fault movement within the site; however, NRCan indicated that the probability of future fault movement resulting in displacements at the surface or shallow subsurface is negligible and of no engineering or environmental significance. NRCan also raised concerns that the borehole data does not fully substantiate the statement about earthquakes not being the cause of the deformation of the silty clay deposit underlying the site. To address this, NRCan requested that the proponent consider the possibility that there has been smaller-scale deformation to the silty clay deposit. In addition, NRCan requested that the proponent consider the potential occurrence of a large-scale sensitive clay landslide and seismic shaking as the triggering mechanism for such a failure.

Taggart Miller addressed NRCan’s concerns as part of the final EA, where appropriate, and the specific comments to NRCan on the draft EA are documented in Appendix K of the Consultation Record. In response to NRCan’s request for the proponent to address the possibility of smaller-scale deformation of the silty clay deposit, Taggart Miller responded that it agreed that it could not eliminate the potential for small scale disturbance features at the CRRRC site; however, due to the vertical and lateral continuity of the marker horizon, there is a lack of tectonic or seismic disturbance. With regard to the potential for a landslide due to seismic shaking, the proponent responded that due to the 2 kilometre distance between the former paleochannel margin and the CRRRC site, the encroachment of a landslide to the CRRRC site is insignificant.

The Capital Region Citizens Coalition for Protection of the Environment (CRCCPE) submitted concerns regarding the assessment of seismicity in the final CRRRC EA. The geologist on behalf of the CRCCPE was critical of the studies undertaken and the information presented in Volumes I and III of the EA package. Their major concerns include the proponent’s interpretation of site and regional geological conditions and the lack of identification of faults or probable faults in the bedrock, the hazards associated with potential earthquakes, including ground shaking and liquefaction and their potential effects on the landfill component of the CRRRC.

The proponent submitted a supplemental report completed by its consultant, Golder Associates (Golder), in response to CRCCPE’s comments on the EA regarding the seismic assessment. This report can be obtained from the proponent’s website.

In summary, the report provides information that discredits the analysis submitted by the geologist for CRCCPE. In addition, the supplemental report claims that CRCCPE’s geologist has provided insufficient evidence to establish the existence and Quaternary activity of the low scarps that the geologist named the North Russell and East Ridge Faults. Golder states that its seismic analysis for the CRRRC landfill footprint considered the historic record of earthquakes in southeastern Canada, potential effects of surface fault rupture, strong earthquake shaking and potential liquefaction of the clay deposit that underlies the CRRRC site.

Golder states that relevant portions of Volume III of the EA were prepared by a team of Canadian licensed professionals from their firm, and independent experts from post-secondary institutions with expertise in structural geology, hydrology, seismicity, seismic hazard assessment, and geotechnical earthquake engineering and analysis. Golder maintains that the method used was from the approved ToR for this EA, and they are of the position that assessment effects on the CRRRC were studied thoroughly and are scientifically defensible.

NRCan and OGS will review Golder’s report, as well as any public comments received related to seismicity during the Ministry Review period and the proponent’s responses, prior to a Minister’s decision on the proposed undertaking.

Monitoring

Taggart Miller’s CRRRC EA did not identify any adverse effects to any of the environmental components assessed. Taggart Miller has proposed a plan for monitoring dust, noise, groundwater, geotechnical monitoring of the landfill design, surface water, benthic and sediment monitoring, as well as implementation of a complaints protocol. The ministry is satisfied with the monitoring program as proposed in the EA, subject to additional approvals that may be required for the CRRRC. If the proposed undertaking is approved under the EAA, a standard Condition of Approval requiring the proponent to conduct and report the results of compliance monitoring will be included as part of the approval.

3.3.2 Conclusion

Taggart Miller has provided responses to all comments received, including those not detailed above. A summary of all comments reviewed and Taggart Miller’s responses are located in Tables 1 and 2 of this Review.

Ministry staff are satisfied that Taggart Miller has met the requirements of the ToR and EAA for the components of the EA raised in Section 3.3.1 above, as well as those raised in Tables 1 and 2.

The ministry is also satisfied that the proposed CRRRC will be designed and operated to comply with the ministry’s standards and that the environmental effects of the proposed undertaking can be managed through the commitments made in the EA, through conditions of approval, or through additional work that must be carried out by Taggart Miller in support of future approval applications, if the EA is approved.

A final review period and a recommendation to the Minister about the undertaking described in the EA will follow the publishing of this Review. If the undertaking is approved by the Minister, conditions specific to the proposed undertaking may be proposed to ensure the environment remains protected.

Summary of the ministry review

The Review has explained the ministry’s analysis of Taggart Miller’s EA for the CRRRC.

This Review concludes that the EA complies with the requirements of the approved ToR and has been prepared in accordance with the EAA. The EA has provided sufficient information to enable a decision to be made about the application to proceed with the undertaking.

The Review concludes that the EA has assessed and evaluated alternative methods to arrive at the preferred undertaking (i.e., site, design concept and leachate management), assessed the potential environmental effects of the alternative methods and the proposed undertaking, and provides a description of mitigation and monitoring measures to address the potential negative environmental effects of the proposed undertaking.

The ministry is satisfied that Taggart Miller provided sufficient opportunities for the GRT, public, stakeholders and Aboriginal communities and organizations to comment during the development of the EA. Concerns raised by the GRT and the public have been addressed by Taggart Miller or a commitment has been made to address them through additional work that will be completed as part of future approval requirements.

If the proposed undertaking is approved under the EAA, there are several standard conditions that are included in an approval such as the requirement to conduct and report the results of compliance monitoring and to develop a protocol for responding to complaints received during all phases of the undertaking. There may also be specific conditions imposed on this proposed undertaking, if warranted.

What happens now

The Review will be made available for a five-week comment period. During this time, all interested parties, including the public, the Government Review Team and Aboriginal communities can submit comments to the ministry about the proposed undertaking, the EA and/or the Ministry Review. At this time, anyone can request that the Minister refer either all or part of the EA to the Environmental Review Tribunal for a hearing if they believe that their concerns have not been addressed.

At the end of the Review comment period, ministry staff will make a recommendation to the Minister concerning whether the EA has been prepared in accordance with the ToR and the requirements of the EAA and whether the proposed undertaking should be approved. When making a decision, the Minister will consider the purpose of the EAA, the ToR, the EA, the Review, the comments submitted during the EA and the Review comment periods and any other matters the Minister may consider relevant.

The Minister will make one of the following decisions:

  • Give approval to proceed with the undertaking;
  • Give approval to proceed with the undertaking subject to conditions; or
  • Refuse to give approval to proceed with the undertaking.

Prior to making that decision, the Minister may also refer either part of or the entire EA to mediation or refer either part of or the entire EA to the Environmental Review Tribunal for a decision.

If the Minister approves, approves with conditions or refuses to give approval to the undertaking, the Lieutenant Governor in Council must concur with the decision.

5.1 Additional approvals required

If EAA approval is granted, Taggart Miller will still require other legislative approvals to design, construct and operate this undertaking. Section 1.7 of Volume I of the EA outlines additional approvals that may be required. These approvals may include:

  • Environmental Compliance Approval (ECA) under Part V of the Environmental Protection Act (EPA) and section 53 of the Ontario Water Resources Act (OWRA)
  • Letter of Concurrence under the Ontario Heritage Act
  • Approvals under the Planning Act for zoning of parts of the Boundary Road site
  • Regulatory approval under the Conservation Authorities Act from South Nation Conservation is anticipated due to required drainage alterations
  • Approval under the Drainage Act due to the presence of a municipal drain

These approvals cannot be issued until approval under the EAA is granted.

5.2 Modifying or amending the proposed undertaking

The EA Code of Practice identifies a process to address minor and major changes to the undertaking if approval is granted. Any proposed change to the undertaking would have to be considered in the context of the EAA and Ontario Regulation 101/07 (Waste Management Projects) and any environmental assessment requirements met before any change to the undertaking can be implemented.

Public record locations

The public record for this environmental assessment can be reviewed during normal business hours at the following ministry office:

Ministry of the Environment and Climate Change
Environmental Approvals Branch
135 St. Clair Avenue West, 1st Floor
Toronto, Ontario
Voice: 416-314-8001 / 1-800-461-6290
Fax: 416-314-8452

The Review and Notice of Completion are also available at the following locations:

Taggart Miller Environmental Services
Taggart Realty
225 Metcalfe Street, Suite 708
Ottawa, Ontario K2P 1P9
613-234-7000 Extension 235

Carlsbad Springs Community Centre
6020 Piperville Road
Carlsbad Springs, Ontario K0A 1K0
See website for hours and contact information.

Township of Russell
Public Library
1053 Concession Street
Russell, Ontario K4R 1E1
613-445-5331

City of Ottawa Public Library
Blackburn Hamlet Branch
199 Glen Park Drive
Ottawa, Ontario K1B 5B8
613-824-6926

United Counties of Prescott-Russell
59 Court Street
L’Orignal, Ontario K0B 1K0

Township of Russell
717 Notre-Dame Street
Embrun, Ontario K0A 1W1
613-443-3066

City of Ottawa
110 Laurier Avenue West
Ottawa, Ontario K1P 1J1
613-580-2424

Ministry of the Environment and Climate Change
Ottawa District Office
2430 Don Reid Drive
Ottawa, Ontario K1H 1E1
613-521-3450

Making a submission

A five-week public review period ending May 20, 2016 will follow publication of this Review. During this time, any interested parties can make submissions about the proposed undertaking, the environmental assessment or this Review. Should you wish to make a submission, please send it to:

Director
Environmental Approvals Branch
Ministry of the Environment and Climate Change
135 St. Clair Avenue West, 1st Floor
Toronto, Ontario M4V 1P5
Fax: 416-314-8452

Re: Capital Region Resource Recovery Centre Environmental Assessment
Attention: Andrew Evers, Special Project Officer

Under the Freedom of Information and Protection of Privacy Act and the Environmental Assessment Act, unless otherwise stated in the submission, any personal information such as name, address, telephone number and property location included in all submissions become part of the public record files for this matter and can be released if requested.

Appendices

Appendix A: Environmental Assessment Act and terms of reference requirements

EA decision making process EAA and ToR requirements Description and characteristics of the requirements
Problem/opportunities Identify an existing problem or opportunity. Purpose of the Undertaking: EAA section 6.1(2)(a) The EA should contain a brief explanation of the problem or opportunity that prompted the proposed activity. If a specific undertaking has been identified provide a brief description.

Analysis of the EA

Proponent undertook an analysis to assess the opportunity to provide an integrated waste management facility focused on resource recovery of Industrial Commercial &Institutional (IC&I) and Construction & Demolition (C&D) wastes in the Capital Region and eastern Ontario.

The purpose of the undertaking is to address shortfalls in the Capital Region in meeting waste material diversion objectives set out by the Province of Ontario and the City of Ottawa and reinforced with the introduction of Bill 91. The undertaking includes:

  • a materials recovery and recycling operation for incoming IC&I and C&D waste;
  • an organics processing facility for the portion of the IC&I waste stream that has high organic content;
  • a contaminated soil treatment and management of surplus soil facility;
  • a gas management and renewable energy generation facility;
  • a leachate pre-treatment facility; and,
  • a residual waste disposal facility using engineered landfill technology with a capacity of up to 10.7 million cubic metres.
EA decision making process EAA and ToR requirements Description and characteristics of the requirements
Alternatives Description and statement of the rationale for the alternatives methods: EAA section 6.1(2)(b)(ii) “Alternative methods” include a description of different ways of implementing the preferred “alternative to”. A reasonable range of “alternative methods” should be identified and outlined.

Analysis of the EA

The alternative methods were two site location options (North Russell Road Site and Boundary Road Site) and two development concept options (identified as concepts A and B in the EA). A comparative evaluation for the alternative sites was clearly documented in Technical Support Document #1 and Section 7.0 of the EA.

The decision making process explains how Taggart Miller evaluated the alternative methods to determine the proposed undertaking. In summary, the environmental effects for each site was compared based on a set of criteria and indicators for each environmental component, in design mitigation measures were considered and the advantages and disadvantages for each alternative site were discussed. Based on this evaluation, the Boundary Road site was selected as the preferred site.

Section 9.0 of the EA evaluated alternative development concepts on the Boundary Road Site (site layout). The proponent identified the preferred development concept through comments received at an Open House, posting the development concept options on the project website to solicit comments, presentation to ministry technical reviewers and Aboriginal communities. Based on this, the proponent identified the advantages and disadvantages of each development concept and identified Concept A as the preferred option.

Section 12.0 of the EA identifies and assesses alternatives methods to leachate management for the landfill and organics processing facility. A comparative evaluation of the environmental components for both on-site pre-treatment/off-site treatment and complete on-site treatment was completed. On-site pre-treatment/off-site treatment at the City of Ottawa’s Robert O. Pickard Environmental Centre (ROPEC) was identified to be the preferred alternative for leachate management.

The ministry is satisfied that a reasonable range of alternative methods were evaluated as part of the EA.

EA decision making process EAA and ToR requirements Description and characteristics of the requirements
Evaluation Description of the environment: EAA section 6.1(2)(c)(i) Proponents must consider the broad definition of the environment including the natural, biophysical, social, economic, built and cultural conditions. The EA must provide a description of the existing environmental conditions in the study area. The EA must identify those elements of the environment that may be reasonably expected to be affected, either directly or indirectly, by the proposed undertaking and/or the alternatives.

Analysis of the EA

A description of the existing environment for the Boundary Road Site (preferred site) is provided in Section 8.0 of the EA. The EA provides a regional overview and identifies the site vicinity and on-site study areas as the basis for describing the existing environment for the identification of potential environmental effects. As described in the EA, the site is mostly covered with vegetation and trees. Other features on the site include swamp, agricultural fields, four residences and a model aircraft club. The residences are all owned by Taggart Miller. Adjacent areas are commercial, industrial, and agricultural.

The proponent carried out studies and research to compile a description of the existing environment for the study areas. This information was used to establish the existing environment for the completion of the comparative evaluation of the alternative sites (Section 7.2 and Table 7.2-1 of the EA) and identification of potential environmental effects of the preferred site (Section 8.0 of the EA).

The EA identified the components of the environment that may be reasonably expected to be affected by the alternatives sites and the preferred site.

EA decision making process EAA and ToR requirements Description and characteristics of the requirements
Evaluation Description of the environment: EAA section 6.1(2)(c)(ii) Both positive and negative environmental effects should be discussed. The EA must identify methods and studies used to analyze the potential environmental effects. The methods used are contingent on the type of project. Impact assessment methods and criteria used during the evaluation should be identified. The methods chosen must be clear, traceable and replicable so that interested parties can understand the analysis and logic used throughout the EA.

Analysis of the EA

Potential environmental effects of the preferred undertaking are identified and assessed in Section 11.0 of the EA. Section 11.0 summarizes the methods and studies completed to analyze potential environmental effects. The proponent provided further detail in appended Technical Support Documents for each environmental component.

The method used for identifying net effects was clearly described in the EA (Section 2.3.3 of the EA). The EA identified the elements of the environment that may be reasonably expected to be affected by the proposed undertaking (Section 11.0 of the EA). The method included identifying proposed in-design mitigation measures to minimize or avoid any potential negative environmental effects of the preferred undertaking being considered as part of the EA process.

A cumulative effects assessment was also completed in Section 13 of the EA. Overall, the only cumulative effect that was identified was to surface water as a result of past and current activities. A surface water monitoring plan is proposed to ensure surface water leaving the site meets regulatory requirements.

No additional technical work is identified as being needed.

EA decision making process EAA and ToR requirements Description and characteristics of the requirements
Evaluation Description of the actions necessary to prevent, change, mitigate or remedy the environmental effects: EAA section 6.1(2)(c)(iii) A description of future commitments, studies and a work plan may be included as part of the actions necessary to prevent, change, mitigate or remedy environmental effects for each alternative for the ultimate purpose of comparing them.

Analysis of the EA

The two site alternatives were compared, and the preferred site was selected in part due to its lower potential for environmental effects. The two design concepts were then evaluated and the concept with the lower potential for environmental impacts was selected. Ongoing effects monitoring will occur across the lifespan of the landfill. Section 11.1 describes the range of in-design mitigation measures and best management practices. These are summarized again in Table 11.10-1, including identification of net effects for the proposed undertaking and the corresponding proposed effects monitoring. Such measures were identified for all of the environmental components assessed in the EA.

A monitoring plan and contingency measures are detailed in Section 14.0 of the EA and the Design and Operations Report. The monitoring plan describes, at a high level, the methods and frequency of monitoring for each of the environmental components. The proponent commits in the EA to finalize the details of the monitoring with the ministry at the time the ECA application is submitted.

EA decision making process EAA and ToR requirements Description and characteristics of the requirements
Evaluation Evaluation of advantages and disadvantages to the environment: EAA section 6.1(2)(d) The preferred alternative should be identified through this evaluation.

Analysis of the EA

The EA documents the advantages and disadvantages of the preferred site, development concept and leachate management alternative in sections 7.3 (Table 7.3-1), 9.4 and 12.5, respectively, of the EA. The proponent’s decision making is clear, traceable, and reproducible. The EA clearly demonstrated why the preferred alternative was selected over the others. Alternatives were assessed in a screening process that included both public input and a comparison of advantages and disadvantages. This analysis is well described in the EA.

EA decision making process EAA and ToR requirements Description and characteristics of the requirements
Evaluation Description of Consultation with Interested Stakeholders: EAA section 6.1(2)(e) A description of stakeholder consultation that occurred during the preparation of the EA needs be documented and should include consultation methods used, frequency of consultation, dates that events occurred, target audience, descriptions of key milestones for which stakeholders are providing input, comments received. The EA must identify any Aboriginal consultation efforts that have been made including methods for identifying potentially interested First Nations, who was consulted, when and how consultation occurred and any comments received from First Nations. The EA should include outline conflict resolution techniques to resolve issues used by the proponent to resolve outstanding issues with any stakeholders. There must be clear documentation as to how issues and concerns have been addressed.

Analysis of the EA

The Consultation Summary is documented in Section 3.0 of the EA and the Consultation Record is documented in Volume II. Consultation methods documented in the EA and the Consultation Record included public open houses (bilingual), newsletters, website, workshops, meetings, site tours and tours of Miller facilities in the Greater Toronto Area. Consultation was conducted with several federal, provincial, and local agencies and the local community. Meetings were held with adjacent property owners, and the two local community associations were engaged. The proponent documented the comments received from the GRT, public and Aboriginal communities during the consultation events and review of the draft EA and how it intended to address comments in the EA and the Consultation Record. The draft EA was circulated to the GRT, Aboriginal communities and members of the public who had requested a copy or had received a copy of the ToR. The comment period for the draft EA was June 11, 2014 to July 31, 2014. Advertisements and notices for noting the availability of the draft EA were provided at the last Open House. Refer to Section 3.3 of this Review for discussion of the issues raised by the GRT and how they were addressed by the proponent.

The following Aboriginal communities and organizations were consulted: Métis Nation of Ontario, Ottawa Metis Nation Council, Algonquins of Ontario Consultation Office, Algonquins of Ottawa, Algonquins of Pikwakanagan First Nation and Mohawks of Akwesasne. This list was developed in consultation with Aboriginal Affairs and Northern Development Canada, Ministry of the Environment and Climate Change and the Ministry of Aboriginal Affairs. The proponent provided them with information on the EA throughout the process.

The EAA requires that the proponent consult with all interested persons during the preparation of the EA and report on the results of that consultation. The ministry is satisfied that the proponent appropriately carried out the consultation plan that was outlined in the approved ToR. Overall, the ministry is satisfied that the proponent provided sufficient opportunities for the public, interested stakeholders and Aboriginal communities to be consulted during the preparation of the EA. The CRRRC EA documents the proposed on-going consultation plan during construction and operation of the proposed undertaking.

EA decision making process EAA and ToR requirements Description and characteristics of the requirements
Selection process Proposed undertaking description and statement of the rationale for the undertaking: EAA section 6.1(2)(b)(i) The description of the undertaking should specify what the proponent is seeking approval for under the EAA. The description should include information on the location, attributes, dimensions, emissions etc. The evaluation process should identify which is the preferred undertaking.

Analysis of the EA

The undertaking includes:

  • a materials recovery and recycling operation for incoming IC&I and C&D waste;
  • an organics processing facility for the portion of the IC&I waste stream that has high organic content;
  • a contaminated soil treatment and management of surplus soil facility;
  • a gas management and renewable energy generation facility;
  • a leachate pre-treatment facility; and,
  • a residual waste disposal facility using engineered landfill technology with a capacity of up to 10.7 million cubic metres.

Alternatives to were clearly evaluated in the ToR and a preferred alternative to was identified. The selection process that led to the proposed undertaken is clearly explained in the EA. Alternative sites and development concepts were clearly evaluated in the EA. The EA also provides an evaluation of leachate management systems. The process for selecting the preferred site, development concept and leachate management system is described in sections 7.0, 9.0 and 12.0 respectively. A description of the undertaking is provided in Section 10.0 of the EA. The phases of implementation (construction and operation) are not defined in the EA. The EA document describes how the undertaking will help the region meet its waste diversion objectives.

EA decision making process EAA and ToR requirements Description and characteristics of the requirements
Next steps & additional commitments Additional ToR commitments Outline any further commitments made by the proponent in the ToR.

Analysis of the EA

This Review concludes that the EA complies with the requirements of the approved amended ToR and has been prepared in accordance with the EAA. The EA has provided sufficient information to enable a decision to be made about the application to proceed with the undertaking. The EA includes a table of commitments made during the preparation of the EA (Table 15-2). The Review concludes that the EA has assessed and evaluated alternative methods to arrive at the preferred undertaking including the advantages and disadvantages of each of the alternative methods, assessed the potential net environmental effects of the proposed undertaking, and provides a description of mitigation and monitoring measures to address the potential net negative environmental effects of the proposed undertaking.

The ministry is satisfied that Taggart Miller provided sufficient opportunities for the GRT, public, stakeholders, and Aboriginal communities to comment during the development of the EA. If the proposed undertaking is approved under the EAA, there are several standard conditions imposed such as the requirement to conduct and report the results of compliance monitoring and to develop a protocol for responding to complaints received during all the phases of the undertaking.

EA decision making process EAA and ToR requirements Description and characteristics of the requirements
Next steps & additional commitments Additional approvals Outline additional approval requirements. Provide sufficient detail about the nature of the approval.

Analysis of the EA

Section 1.7 of the EA outlines additional approvals that may be required. These approvals may include:

  • Letter of Concurrence under the Ontario Heritage Act from the Ministry of Tourism, Culture and Sport;
  • Official Plan Amendment and Zoning By-Law Amendments under the Planning Act;
  • Permit under the Ontario Regulation 170/06, Conservation Authorities Act for potential construction and/or alteration to watercourses;
  • Approval under the Drainage Act; and
  • Environmental Compliance Approval.

Appendix B: Submissions received during initial comment period

Submissions are available in hard copy at the public record locations listed in this ministry review.

Table 1: Government Review Team comments

Comment #1

It is unclear whether the assessment of Boundary Road adheres to the method as set out in Section 8.3.4.3 and Appendix C-2.9 of the approved ToR:

  1. Frontier Road is identified as a secondary site access point yet it does not appear to have been assessed as a main site access location.
  2. The intersection of Boundary Road and Thunder Road does not appear to have been assessed (impacts, road improvements, intersection improvements, etc.)
Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Frontier Road is not a main access point for the site; it is correctly described as a secondary access point to be used only by some staff and emergency vehicles. The main and predominant site access location is off Boundary Road, conveniently located just south of the Highway 417/Boundary Road intersection. The traffic assessment adhered to the methodology set out in the approved Terms of Reference (ToR). In response to the same comment from the Ministry of Transportation (MTO), Addendum 1 to the Traffic Impact Study Technical Support Document (TSD) #9 was prepared to assess the Boundary Road/Thunder Road intersection. The analysis concluded that the additional site-related CRRRC traffic would have only minor impact on this intersection and there would be no requirement for intersection modifications due to the CRRRC. This addendum was posted on the CRRRC website.

Status

The ministry is satisfied with the response and MTO’s review of the traffic Addendum.

Comment #2

Section 8.3.6 of the approved ToR indicates that net effects will be combined with the predicted effects of other existing and identified certain and probable projects in the area: The cumulative impact assessment in the EA does not appear to include the adjacent proposed business park and vehicle facility.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The assessment considered the existing adjacent business park in detail. The cumulative impact assessment in the Environmental Assessment (EA) also considered the proposed vehicle decoupling (truck terminal) facility in a qualitative manner. At the time this assessment was prepared, information on the amount of traffic related to the vehicle facility was not available. Subsequently, in response to a request from MTO on this same matter, Addendum 2 to the Traffic Impact Study TSD #9 was prepared to examine the combined (or cumulative) traffic effects from the proposed CRRRC and the proposed East Gateway Properties truck terminal in a quantitative manner using the site-related traffic made available by the proponent of that development. This addendum was posted on the CRRRC website.

Status

The ministry is satisfied with the response and MTO’s review of the traffic Addendum.

Comment #3

Section 12.2 of the approved ToR includes a commitment to develop during the EA a conceptual monitoring framework, including both compliance and effects monitoring, for all phases of the proposed undertaking: It is unclear if this commitment has been met as the discussion about monitoring in Section 14 appears to be exclusive to effects monitoring, and does not appear to include all phases of the proposed undertaking.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Section 14.1 of the main EA report summarizes the effects monitoring program (with additional details provided in the Volume IV Design & Operations (D&O) report), which is applicable to the pre-operational baseline period, the operational period and the post-closure period. Section 15.0 of the main EA report provides all commitments made by Taggart Miller during both the ToR and EA study process, and provides the timeframe applicable to each commitment, i.e., pre-construction, construction, operations and post-closure. Together, Sections 14 and 15 of the main EA report completely fulfill the requirements of Section 12.2 of the approved ToR.

Status

The ministry is satisfied that the proponent will implement a monitoring program as committed to in the EA. A standard condition of approval is also being proposed to address this matter.

Comment #4

As was indicated in comments on the draft EA, it would be helpful to set out in a summary table format for the potential impacts to the environment for all components of the undertaking, and the alternative methods of carrying out the undertaking.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The comment on the draft EA on this matter was considered in the preparation of the final EA as described in the response to comment 8 in Table K-3, page 8 of 17 in the Consultation Record Volume II. Summary tables are provided by component in Section 7 of the main EA report (Table 7.3-1 for alternative site comparison), in Section 11 (Table 11.10-1 for impact assessment of the preferred alternative and in Section 12 (Table 12.5-1 for leachate treatment alternatives). The potential impacts for alternative methods (Section 9 of the main EA report) are described, but not in table form by component since the approved approach in the approved ToR is not by component.

Status

The ministry is satisfied with the response.

Comment #5

Procedures proposed for amending the EA should be removed (pages vi, 156, 166, 268, & 297).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Resolved through discussion with the Ministry of the Environment and Climate Change (MOECC).

Status

The ministry is satisfied with the revised pages of the EA as posted on the proponent’s website.

Comment #6

Identify the source for the predicted annual IC&I and C&D waste volume (approximately 1 million tonnes?) for the area to be managed after 2017.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The Executive Summary of the main EA report states that the Industrial, Commercial & Institutional (IC&I) and Construction & Demolition (C&D) waste in the area is approximately 1 million tonnes in 2010, increasing to approximately 1.5 million tonnes in 2046. The summarized details of how this was estimated was provided in Supporting Document #1 to the approved ToR and summarized in Section 4.0 of the approved ToR.

Status

The ministry is satisfied with the response.

Comment #7

A summary of Mer Bleue is missing from biology description in the Executive Summary.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The Mer Bleue is located well beyond the site-vicinity, and is not predicted to be affected in any way by the proposed CRRRC, as described specifically in Section 11.5.3 of the main EA report. It was therefore not considered necessary to mention the Mer Bleue specifically in the Executive Summary. It is noted that the Nature Conservancy of Canada (NCC), who own and manage the Mer Bleue, have indicated that the EA studies fully address their issues of interest.

Status

The ministry is satisfied with the response.

Comment #8

While an overview of contingency measures is presented in Volume IV, in accordance with the work plan a summary should be presented in the EA.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The Contingency Measures are in fact summarized in Section 14.2 of the main EA report, with further details in the Volume IV D&O report.

Status

The ministry is satisfied with the response.

Comment #9

All environmental components should be presented in the summary of net effects and effects monitoring (missing cultural, heritage and archeology, agriculture and traffic).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Because there are no component-specific monitoring programs proposed for those components, they were not presented in the summary.

Status

The ministry is satisfied with the response.

Comment #10

The overview of the assessment of leachate management should include a summary of section 12.2 (estimated wastewater volumes and quality).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

These are technical details that were not considered necessary for the Executive Summary, which was prepared for the reader who wants to gain a general understanding of the project and the results of the assessments. As noted in the comment, this specific information is provided in Section 12.2 of the main EA report, with additional detail in TSD#10.

Status

The ministry is satisfied with the response.

Comment #11

Identify where in the EA the rationale for the alternative sites can be found (section 7).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Table 1.8-1 correctly describes that the rationale for the alternative methods of carrying out the undertaking (in this EA, alternative methods consist of alternative sites, alternative site development concepts and leachate management options) can be found in Sections 7.0, 9.0 and 12.0.

Status

The ministry is satisfied with the response.

Comment #12

Identify where in the EA the rationale for the leachate management options can be found (section 12).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

See above response.

Status

The ministry is satisfied with the response.

Comment #13

In accordance with the ministry’s Code of Practice, Table 1.8-1 should include a summary of other approvals required for the undertaking, including all components of the undertaking.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Table 1.8-1 responds to Section 4.3.3 of the Ministry’s EA Code of Practice. The other approvals required for the undertaking are fully described as it relates to the Boundary Road site in Section 1.7 of the main EA report.

Status

The ministry is satisfied with the response.

Comment #14

The rationale for modification of the study area (to capture additional surrounding potential receptors) for noise assessment has not been included in Table 2.3-1. Provide an explanation; revise accordingly.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The work plan in the approved ToR for noise listed three study areas: site, site-vicinity and haul route. There was no modification made for the noise assessment.

Status

The ministry is satisfied with the response.

Comment #15

It is unclear if the haul route study area was assessed for the atmosphere, noise and land use environmental components. Provide clarification and/or cross-reference where in the EA this assessment has been presented.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

As indicated in Table 2.3-1, the haul route study area (Boundary Road from Highway 417 to the site entrance) was assessed for noise (Section 11.2.1 of the main EA report and Sections 4.5 and 4.6 of TSD #2) and for land use (Section 11.6.1 of the main EA report and Section 4.1 of TSD #5), as per the approved ToR and as shown in Table 2.3-1 of the main EA report.

Status

The ministry is satisfied that noise was assessed in accordance with the approved ToR.

Comment #16

When concerns were raised at meetings a summary of those concerns should be identified. Alternatively, if no concerns were raised that should be indicated as well.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

As noted in the description of each of the four Open House meetings in Sections 3.6.1, 3.6.2, 3.6.5 and 3.6.8, a summary of the comments / concerns received at each event are provided in Sections 3.7.1, 3.7.2, 3.7.4 and 3.7.5, respectively, of the main EA report. Further details are provided in the Consultation Record Volume II.

Status

The ministry is satisfied that details on meetings were provided in the EA Consultation Record.

Comment #17

The consultation undertaken with Aboriginal communities is presented out of order.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Section 3.6 of the main EA report is organized in general chronological order of events.

Status

The ministry is satisfied with the response.

Comment #18

Details have not been provided about consultation undertaken between July - December 2014.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The period between July and December 2014 was the time during which Taggart Miller was considering the comments received on the Draft EA and making changes to the EA document package in preparation for the final EA submission.

Status

The ministry is satisfied with the response.

Comment #19

Identify consultation and steps undertaken with the Francophone community to ensure participation in the process.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Information on the steps taken with the Francophone community to ensure its ability to participate in the process is provided for each of the main consultation activities in Sections 3.2, 3.3 and 3.6.1 through 3.6.9. In summary, the steps taken consisted of the following:

  • The Taggart Miller Project Manager is fully bilingual and attended all Open Houses;
  • Postings on the project website were in French, as well as English;
  • Provision of all notices of public meetings in French, i.e., in newspapers, on the project website and by email;
  • At the Open Houses, the front desk staff were bilingual. All display materials and handouts were provided in French. Bilingual staff from Taggart Miller and the consulting team were distributed throughout the Open House venue and wore clear identification that they were available for discussion in French;
  • At the groundwater workshops, a fully bilingual consultant was present;
  • An Executive Summary of the ToR was prepared in French and posted on the project website;
  • Provision of a bilingual newsletter;
  • The draft of the main EA report was available in French and provided at all public access locations as well as on the project website; and,
  • The final main EA report was also prepared in French and provided at all public access locations as well as on the project website.

The bilingual materials are provided in the Volume II Consultation Record.

Status

The ministry is satisfied that consultation was undertaken with the Francophone community in accordance with the approved ToR.

Comment #20

Provide clarification whether the unique anaerobic digestion process is the same as what is later referred to as ‘BioPower’ (see page 154).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The organics processing facility described in Section 6.3.1.3 of the main EA report is the BioPower process referred to in Section 9.2.2.

Status

The ministry is satisfied with the response.

Comment #21

Provide a summary of proposed treatment process for petroleum hydrocarbon (PHC) contaminated soils.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

A summary of the proposed treatment process for PHC soil is provided in Section 9.2.2 of the main EA report, with some additional details provided in Section 10.6 of the main EA report. A full description of the PHC soil treatment process is provided in Appendix H in the Volume IV D&O report.

Status

The ministry is satisfied with the response.

Comment #22

Identify where in the EA the rationale for selecting the alternative sites can be found.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The rationale for selection of the alternative sites is provided in Section 5.0 of the approved ToR, which is appended to the main EA Report and forms part of the EA pursuant to the EA Act.

Status

The ministry is satisfied that the rationale for the alternative methods is provided in the approved ToR.

Comment #23

Identify the estimated area required for the small load drop-off.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The approximate area required for the small load drop-off is approximately 0.8 hectares, included the vehicle access and bin pickup areas.

Status

The ministry is satisfied with the response.

Comment #24

It is unclear if the level of detail about the BioPower process is needed (if the demonstration scale BioPower facility is proposed to be located in the area proposed for the permanent facility, why discuss here?).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

This level of detail for the BioPower process is required at this alternative site development concept design stage in order to size and allocate adequate space in the site layout planning for the various components of the full scale facility, assuming that the demonstration scale facility performs acceptably.

Status

The ministry is satisfied with the response.

Comment #25

The referenced organics receiving building has not been reflected in the figures.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

This organics receiving building is labelled as the Organics Pre-processing Building on Figures 9.3-1 and 9.3-2; it is described as being used for pre-processing, receiving and storage in the text in Section 9.2.2.

Status

The ministry is satisfied with the response.

Comment #26

The description of the organics processing operations, including the facilities, is unclear and the use of inconsistent terms makes it difficult to understand. It is also unclear whether, and how, full scale and demonstration operations differ. Figure 10-1 does not make clear the structures associated with the organics processing facility area, for example, it is stated that blended material will be removed from the ‘building’ and placed in the primary reactor cells yet both appear in the same image in the figure.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The components of the organics processing are described at an increasing level of detail for the subsequent steps in the approved EA methodology, in Sections 6.3.1.3, 9.2.2 and 10.5. The components of the organics processing facility are shown and clearly labelled on Figure 10-1 as the Organics Pre-processing Building, Primary Reactor Cells, Secondary Digester, Flare & Power Generation, and Compost Processing & Storage Pad. The primary reactor areas are shown on Figure 10-1 as distinct from the pre-processing building and are shown as different colours as well. The demonstration scale facility is described in both Sections 9.2.2 and 10.5; it is described as essentially all the same processes as will be used for the full scale facility to be able to process up to 50,000 tonnes per year, but constructed and operated initially at a smaller scale capable of handling up to 23,400 tonnes per year. An even more complete description is provided in Appendix F of the Volume IV D&O report.

Status

The ministry is satisfied that the proponent provided a description of the undertaking in the EA.

Comment #27

Detailed description of the proposed CRRRC, including a summary of the site construction and operations should be provided. Identify:

  • Any change in location (and rationale for change) from concept A to final site;
  • The role of the component (in the full process), including operation summary;
  • The physical facility details, including approximate size; and,
  • Movement between facilities.
Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

A summary of the main components of the proposed CRRRC is provided in Section 6.0. The main components remain consistent through the EA as the site layout and concept design are further refined in two steps as described in Sections 9.0 and 10.0.

The changes in the site development plan from site Development Concept A in Figure 9.3-2 to what is shown on Figure 10-1 as the site Development Plan are described for each component of the CRRRC in Sections 10.1 through 10.9.

The role of each component within this integrated waste management facility is described in Sections 6.0, 9.0 and 10.0. and a complete operations flow chart is provided in Figure 10.3. In addition, further details on the individual processes and their operations, including relevant process flow charts, are provided in the Appendices of the Volume IV D&O report.

Approximate sizes (dimensions and, where applicable, height) are provided in Sections 10.1 through 10.12, or where they have not been refined from the site Development Concept this information is in Section 9.0. Additional physical information on the facilities is provided at an EPA level of detail in Volume IV.

Movement between facilities is illustrated on Figure 10-3, which should be read in conjunction with the site Development Plan Figure 10-1.

Status

The ministry is satisfied that the proponent provided a description of the undertaking in the EA.

Comment #28

The description of the organics processing operations, including the facilities, is unclear and the use of inconsistent terms makes it difficult to understand. It is also unclear whether, and how, full scale and demonstration operations differ. Figure 10-1 does not make clear the structures associated with the organics processing facility area, for example, it is stated that blended material will be removed from the ‘building’ and placed in the primary reactor cells yet both appear in the same image in the figure.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The components of the organics processing are described at an increasing level of detail for the subsequent steps in the approved EA methodology, in Sections 6.3.1.3, 9.2.2 and 10.5. The components of the organics processing facility are shown and clearly labelled on Figure 10-1 as the Organics Pre-processing Building, Primary Reactor Cells, Secondary Digester, Flare & Power Generation, and Compost Processing & Storage Pad. The primary reactor areas are shown on Figure 10-1 as distinct from the pre-processing building and are shown as different colours as well. The demonstration scale facility is described in both Sections 9.2.2 and 10.5; it is described as essentially all the same processes as will be used for the full scale facility to be able to process up to 50,000 tonnes per year, but constructed and operated initially at a smaller scale capable of handling up to 23,400 tonnes per year. An even more complete description is provided in Appendix F of the Volume IV D&O report.

Status

The ministry is satisfied that the proponent provided a description of the undertaking in the EA.

Comment #29

It is important that names given to facilities in Figure 10-1 correspond to the names used in the descriptions provided in 10.1 to 10.12. Similarly, all components reflected in Figure 10-1 should be discussed and all facilities discussed should be reflected in the figure (e.g., clean load drop-off bunker area, sludge de-watering pad, offices and employee facilities, etc.).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

With minor exception, the names given to facilities as described in Sections 10.1 to 10.12 correspond to those labelled on Figure 10-1. The purpose of Figure 10-1 is to show the overall site layout; it is not possible to show and label the features of every proposed component of the CRRRC on this figure. A greater level of detail on the various diversion processes and leachate pre-treatment (for example, indicating where the office areas will be in the Materials Recovery Facility (MRF) and C&D processing buildings and the sludge de-watering pad will be in the leachate pre-treatment building) is provided in the Volume IV D&O report Appendices D through H and Appendix J. The level of detail provided in Volume IV is appropriate for application for an Environmental Compliance Approval (ECA) subsequent to EA approval.

Status

The ministry is satisfied that the proponent provided a description of the undertaking in the EA.

Comment #30

Various components that make up the CRRRC are inconsistently described.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Without specific examples, we are unable to respond to this. If there are occasional unintended inconsistencies, we have received no comments that this has impeded the understanding of the project by the public or by the Government Review Team (GRT) reviewers.

Status

The ministry is satisfied that the proponent provided a description of the undertaking in the EA.

Comment #31

Identify the proposed entrance and exit locations for vehicles dropping off small loads. (10.3)

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Vehicles dropping off small loads will enter the site via the main access road from Boundary Road over the in-bound scales and they will be directed to the small load drop off area. After dropping off their waste and recyclable materials they will leave the site by the main access road leading to Boundary Road.

Status

The ministry is satisfied with the response.

Comment #32

The processes and facilities associated with BioPower technology have not been articulated. In addition, the principal facilities that comprise the BioPower technology are not clearly reflected in Figure 10-1. As this is a new technology the EA would benefit from a separate figure dedicated specifically to the organics processing facility.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

As noted in the response to comment 23 above, the principal facilities that comprise the BioPower process are all shown and clearly labelled on Figure 10-1. The technical details associated with this technology are described in Sections 9.2.2 and 10.5. Section 9.2.2 states that this process ‘uses well known biological treatment processes, however this combination of processes has not been previously used for full scale operation in Ontario’. As such, it is not “new technology”, but rather a process that uses proven technologies that are arranged in a sequence to be able to handle and process organics received in mixed IC&I waste. If a reader is interested in more technical details, they are available in Appendix F of the Volume IV D&O report, including separate figures showing the general layout, the primary reactor cell details, and an operational flow chart illustrating the steps in the process and their interconnectivity.

Status

The ministry is satisfied that the proponent provided a description of the undertaking in the EA.

Comment #33

The demonstration facility is sized to accommodate up to 4,000 tonnes of organic waste per calendar month, not to exceed 23,400 tonnes per year. What is the anticipated calendar month and annual organic waste volumes anticipated for the full scale facility?

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

As stated in Section 9.2.2, the full scale organics processing facility will be designed to receive up to 50,000 tonnes per year for processing through the primary reactor, with no specified monthly figure required because at full scale the facility will have capacity available to handle large volumes of material received.

Status

The ministry is satisfied with the response.

Comment #34

The processes and facilities associated with BioPower technology have not been articulated. In addition, the principal facilities that comprise the BioPower technology are not clearly reflected in Figure 10-1. As this is a new technology the EA would benefit from a separate figure dedicated specifically to the organics processing facility.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

As noted in the response to comment 23 above, the principal facilities that comprise the BioPower process are all shown and clearly labelled on Figure 10-1. The technical details associated with this technology are described in Sections 9.2.2 and 10.5. Section 9.2.2 states that this process ‘uses well known biological treatment processes, however this combination of processes has not been previously used for full scale operation in Ontario’. As such, it is not “new technology”, but rather a process that uses proven technologies that are arranged in a sequence to be able to handle and process organics received in mixed IC&I waste. If a reader is interested in more technical details, they are available in Appendix F of the Volume IV D&O report, including separate figures showing the general layout, the primary reactor cell details, and an operational flow chart illustrating the steps in the process and their interconnectivity.

Status

The ministry is satisfied that the proponent provided a description of the undertaking in the EA.

Comment #35

Identify all potential approvals required for the demonstration facility, including referenced applicable guidelines (re: composting).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

It is anticipated that the demonstration scale organics processing facility will require approval as a waste processing facility under the ECA issued for the CRRRC site, which is described in Section 1.7 of the main EA report. The applicable regulations and guidelines for composting are described in Appendix G, Section 1.1 in the Volume IV D&O report.

Status

The ministry is satisfied that the proponent has identified all potential approvals for the demonstration facility.

Comment #36

Clarification is needed about providing capacity for source separated organics to ensure organics diversion capability during the demonstration period, including identification of the location of the on-site organics receiving building (Figure 10-1), and how this differs from what is being proposed for the full scale operation.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Section 10.5, page 154 states “The receiving and storage building, which is anticipated to serve for both the pre-processing and the full scale receiving and storage”. For clarification, the organics building to be used initially at the demonstration scale and subsequently at full scale is the same building. As such, there is a single building shown on Figure 10-1.

Status

The ministry is satisfied that the proponent provided a description of the undertaking in the EA.

Comment #37

Identify the location of the slurry storage tank.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Section 10.5, page 155 states “the organics slurry will be pumped to an exterior, closed storage tank….”. The exact location and dimensions of this tank are details that are not appropriate to identify on Figure 10-1, which is an overall site layout plan. Some additional descriptive details are provided in Section 2.6 of Appendix F of the Volume IV D&O report. The slurry storage tank will be located immediately adjacent to the organics pre-processing building.

Status

The ministry is satisfied with the response.

Comment #38

Only primary reactor and secondary digester are in Figure 10-1 but the description of the process indicates a secondary reactor and primary digester. Where are these?

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The terms primary reactor and primary digester refer to the same component, labelled as the Primary Reactor Cell on Figure 10-1. The terms secondary reactor and secondary digester refer to the same component, labelled as the Secondary Digester on Figure 10-1.

Status

The ministry is satisfied with the response.

Comment #39

Figure 10-3, primary scale and secondary scale need to be explained.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The Primary Scale on Figure 10-3 is the same as the In-bound Scale on Figure 10-1; this scale will be used to weigh all vehicles entering the site carrying materials destined for one or more of the receiving locations within the CRRRC, as is conventional practice at any modern waste disposal site. As shown on Figure 10-1, the Secondary Scale will be located along the access road between the diversion and processing activities in the north part of the site and the landfill component in the south part of the site, and will weigh post-diversion residuals (as illustrated on the operations flow chart on Figure 10-3).

Status

The ministry is satisfied that the proponent provided a description of the undertaking in the EA.

Comment #40

Pre-processing of organics has not been reflected in Figure 10-3.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Pre-processing of organics is a step within the box on Figure 10-3 labelled “Organics Processing Facility”.

Status

The ministry is satisfied with the response.

Comment #41

The description of the proposed petroleum hydrocarbon (PHC) contaminated soil treatment component does not align with the facilities reflected in Figure 10-1.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Figure 10-1 shows a green coloured box labelled as “PHC Soil Storage Building” and an adjacent orange coloured area labelled as “Petroleum Hydrocarbon Contaminated Soil Treatment Area”. The former is the building described in the text in Sections 9.2.2 and 10.6; the latter depicts the area within which the biopiles described in the text will be located. The layout of the overall PHC soil treatment process and its components are described and illustrated in greater detail in Appendix H of the Volume IV D&O report, and appropriately summarized in Sections 9.2.2 and 10.6 of the main EA report.

Status

The ministry is satisfied that the proponent provided a description of the undertaking in the EA.

Comment #42

Explain the relevance of a potential future regulatory requirement to the proposed CRRRC site plan.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

A potential future regulatory requirement directed at a mandatory increase in IC&I diversion is not expected to affect the proposed CRRRC site Development Plan in any material way. The facilities have been sized and designed conceptually to accommodate the IC&I and C&D wastes generated within the service area and receiving and processing capability/equipment can be increased as required in response to demand. There is also the option of running a double shift at some or all of the processing facilities. The site layout has been planned to facilitate movement between the CRRRC components up to the maximum allowable annual waste receipt.

Status

The ministry is satisfied with the response.

Comment #43

Identify the area required for surplus soil management.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

As described in Section 9.2.2, an area of about 1.5 hectares was set aside in the northern part of the site as shown on Figure 10-1 for temporary storage of surplus soils.

Status

The ministry is satisfied with the response.

Comment #44

Please provide a summary of the predicted effects for the air, geotechnical and surface water environmental components.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

In response to the comments received on the draft EA from the MOECC Environmental Assessment Services Section (EASS), as per Volume II, Appendix K, Table K-3, page 8 of 17, Taggart Miller provided summaries in Volume I of the final EA report at strategic locations to improve understandability of technical details. Table 11.10-1 provides a very succinct summary of the impact assessments for each component in the “net effects” column. Summaries of the air and geotechnical components of the impact assessments have also been provided in Sections 11.2 and 11.3 as follows:

  • Air- at the end of Section 11.2.2, summary Table 11.2.2-4 provides the results of the assessment for each indicator with a statement preceding the table that “the assessment indicates that the proposed facility will be in compliance with Ontario Regulation (O. Reg.) 419/05”.
  • Geotechnical- The last paragraph of Section 11.3.3 Geotechnical Assessment, following the individual discussions on static stability, seismic stability, and settlement, starts with the words “In summary,……”

There is no overall summary provided for the surface water impact assessment at the end of Section 11.4. However, a summary of the effects in terms of predicted effects on drainage areas, on off-site flows, on on-site runoff flow volume and on surface water quality is provided at or near the end of each of these component topics within Section 11.4. In Table 11.10-1, the net effects for the surface water component are summarized.

Status

The ministry is satisfied that a description of the predicted effects is provided in the EA.

Comment #45

All monitoring commitments, including details about frequency, stages, etc., should be presented in table format (Table 11.10-1 provides a summary only of some commitments).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The approach taken in the EA in Section 11.10 (Table 11.10-1) is to provide a summary of the proposed effects monitoring programs, with additional details provided in the Volume IV D&O reports. Table 11.10-1 provides a summary of all the effects monitoring commitments. The proposed monitoring program is further summarized in Section 14.1. The final details will be determined when the ECA is issued by the MOECC for the CRRRC.

Status

The ministry is satisfied that the proponent will implement a monitoring program as committed to in the EA.

Comment #46

Effects monitoring and compliance monitoring should be described and itemized separately in this section, summarizing the importance and function of each.

Proponent’s response
Reviewer

Special Project Officer (EAB, MOECC)

Effects monitoring is discussed in Section 14.0 and compliance monitoring in Section 15.0. In preparing the final EA, some additional description of function (or purpose) of effects monitoring and compliance monitoring were added as introductory paragraphs in Sections 14.0 and 15.0, respectively.

Status

The ministry is satisfied that the proponent will implement a monitoring program as committed to in the EA.

Comment #47

Ensure all commitments made during the preparation of the EA are captured in Table 15-2 (e.g., the table is missing the commitment to establish a Community Liaison Committee (CLC) discussed in section 11 and 14).

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

We believe that all commitments made during the EA are captured in Table 15-2. The establishment of a community liaison committee is commitment #77 in Table 15-2.

Status

The ministry is satisfied that the final commitment table has been revised to reflect all comments received on the EA and is posted with the EA on the proponent’s website.

Comment #48

Appendix G references two meetings that Taggart Miller had with the Algonquins of Ontario First Nation. These meetings are reported as having occurred on April 9 and October 8, 2013. While a record is provided for the April meeting, the EA does not include any information about the October meeting, such as meeting notes or a meeting summary memo.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

The content of the discussions at the October 8, 2013 meeting, the focus of which was on obtaining comments on the two proposed site Development Concepts, is included in the letter dated October 28, 2013 provided in Appendix G-2 of Volume II.

Status

The ministry is satisfied that the proponent consulted with Aboriginal communities during the preparation of the EA.

Comment #49

Section 3.6.7 of the EA discusses two meetings with the Mohawk Council of Akwesasne; however, the Record of Consultation does not include any records of these meetings.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

There was no record of these meetings prepared. However, an overview is provided in Section 3.6.7 of the topics covered in the presentation that was given by Taggart Miller at the first meeting. As noted in Section 3.6.7, the second meeting was to discuss future opportunities for Taggart Miller and the Mohawks of Akwesasne to work together on commercial opportunities.

Status

The ministry is satisfied that the proponent consulted with Aboriginal communities during the preparation of the EA.

Comment #50

Please identify if there is a commitment to on-going consultation with the Algonquins of Ontario First Nation or the Akwesasne First Nation.

Reviewer

Special Project Officer (EAB, MOECC)

Proponent’s response

Taggart Miller are of course happy to continue consultation with the Algonquins of Ontario First Nation or the Akwesasne First Nation, as appropriate, and we have so indicated to them. Also, Table 15-2, commitment #80 states “if during the process of development any archaeological resources or human remains of potential Aboriginal interest are encountered, the Algonquins of Ontario Consultation Office will be contacted.

Status

The ministry is satisfied that the proponent consulted with Aboriginal communities during the preparation of the EA.

Comment #51

The hydrogeological conceptual model at the Boundary Road (BR) site is primarily groundwater migrating to the east in the surficial silty sand unit and secondarily groundwater migrating to the east in the silty layer within the silty clay unit and the underlying silty clay unit is an aquitard thus restricting the vertical migration of contaminants to the underlying glacial till unit and bedrock unit(s). The data provided supports the consultants’ hydrogeological conceptual model.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

No response.

Status

The ministry is satisfied that the data supports the hydrogeological model.

Comment #52

The geology and hydrogeology information shows that the BR site is understood and can be monitored.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

Agreed.

Status

The ministry is satisfied with the selection of the preferred site, Boundary Road site.

Comment #53

The proposed landfill is not to be lined. The native soils are classified as low permeable, thus a bottom liner is not necessary.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

No response.

Status

The ministry is satisfied the landfill design will meet ministry guidelines.

Comment #54

The proposed landfill site is to be ringed with an engineered containment perimeter berm (geosynthetic clay liner) “keyed” into the underlying silty clay unit. This should reduce the potential of offsite migration of leachate.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

No response.

Status

The ministry is satisfied the landfill design will meet ministry guidelines.

Comment #55

The proposed buffer zones meet the minimum requirements.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

No response.

Status

The ministry is satisfied the landfill design will meet ministry guidelines.

Comment #56

The landfill operation is to be undertaken in a phased approach from hydraulically downgradient to upgradient. This is not the preferred direction of operation from a hydrogeological viewpoint. To compensate, a leachate detection system/containment system is to be installed directly hydraulically downgradient of the barrier berm. This is acceptable.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

No response.

Status

The ministry is satisfied the landfill design will meet ministry guidelines.

Comment #57

The landfill site is to have a leachate collection system. The leachate is to be pre-treated onsite. Excess leachate, above the pre-treatment system capabilities, is to be directed to a lined pond (estimate two months capacity) for holding until it can be pre-treated. Groundwater monitoring is undertaken around the pond for leak detection. The pre-treatment effluent is held onsite and trucked offsite for disposal (ROPEC). The pre-treated effluent has to meet the City of Ottawa’s sewer use bylaws.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

Noted.

Status

The ministry is satisfied with the leachate management system.

Comment #58

The leachate impacts will be primarily restricted to onsite. While the inputs into the models are representative, models are a predictive tool but a groundwater monitoring program is required to support the findings in the models.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

Noted.

Status

The ministry is satisfied that a groundwater monitoring plan will be implemented to confirm EA results.

Comment #59

The proposed leachate monitoring program is acceptable.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

Noted.

Status

The ministry is satisfied with the leachate monitoring program.

Comment #60

The groundwater monitoring program is to be commenced one year prior to operations at the facility to obtain baseline groundwater conditions.

The groundwater monitoring program is acceptable. The volatile organic compound sampling in the monitoring wells is not required unless volatile organic compounds are found at the leachate monitoring locations.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

Noted.

Status

The ministry is satisfied that a groundwater monitoring plan will be implemented to confirm EA results.

Comment #61

The water wells within 500 metres of the site should be sampled, along with a survey. This should be undertaken prior to operations at the facility commencing to obtain baseline water quality results. Golder state that this will be undertaken.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

Agreed.

Status

The ministry is satisfied that the proponent will sample water wells within 500 m of the site prior to operations.

Comment #62

The number of groundwater trigger parameters are sufficient however additional trigger parameters may be required and some trigger parameters may be eliminated based on ongoing results.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

Agreed.

Status

The ministry is satisfied that a groundwater monitoring plan will be implemented to confirm EA results.

Comment #63

The groundwater trigger mechanism is 75 percent of the Reasonable Use Limits at the compliance monitoring wells. An exceedance of the groundwater trigger mechanism is two consecutive exceedances for one or more parameters during regular sampling intervals. This triggers a three step process to determine if contingency measures are required. The proposed groundwater trigger mechanism is acceptable.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

Noted.

Status

The ministry is satisfied that a groundwater monitoring plan will be implemented to confirm EA results.

Comment #64

The proposed potential contingency measures are feasible and can easily be implemented.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

No response.

Status

The ministry is satisfied with the contingency measures.

Comment #65

The proposed final cover meets the minimum thickness requirements and is to be a permeable material. The permeable cover will allow infiltration which in turn will generate leachate. Since there is a leachate collection system, this is acceptable and will reduce the longevity of the contaminating lifespan of the landfill. The final cover should be applied sequentially as the area is closed. A low permeable cover (soil or engineered) could be applied as a contingency measure (to reduce leachate generation).

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

Agreed.

Status

The ministry is satisfied with the method for final cover.

Comment #66

The proposed landfill is acceptable from a hydrogeological viewpoint due to:

  • The geology being favourable
  • The hydrogeology being understood and capable of easily being monitored
  • The proposed monitoring program will evaluate the impacts and potential impacts
  • The contingency measures are feasible
  • The potential for offsite impacts are low

The potential for offsite impacts to an existing water well are negligible.

Reviewer

Hydrogeologist, Technical Support Section (Eastern Region, MOECC)

Proponent’s response

Noted.

Status

The ministry is satisfied with the hydrogeological component of the proposed undertaking.

Comment #67

The site of the proposed undertaking is located within a significant groundwater recharge area and highly vulnerable aquifer in the South Nation source protection area. There are no source protection plan policies that apply to these vulnerable areas. We do not have any comments or concerns regarding this proposal.

Reviewer

Land Use Planner, Source Protection Planning Branch (Source Protection Programs Branch, MOECC)

Proponent’s response

Noted. Please note that based on a review of the City of Ottawa Official Plan, and the Source Water Protection work completed for the Rideau Valley Source Protection Area and the South Nation Source Protection Area, the CRRRC site is not located within a groundwater protection zone, or within a significant groundwater recharge area.

Status

The ministry is satisfied with the response.

Comment #68

Erosion and sediment control measures will be implemented before landfill construction begins. Best management practices will be used to minimize impacts to the surrounding environment. The reviewer understands that a detailed stormwater control plan during the construction phase is not possible until one of the development plans is chosen. In general CRRRC is committed to using the best management practices for stormwater control during the construction phase.

The reviewer notes that the Ministry’s Guideline B-6 (Guidelines for Evaluating Construction Activities Impacting on Water Resources) is not listed in the reference list.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

The preferred site development concept was selected (Section 9.0) and described (Section 10.0) within the main Volume I EA. However, at present the phasing of construction and site activities are still to be confirmed. A commitment to prepare a Sediment and Erosion Control Plan has been provided in Section 15.0 of Volume I of the EA. Taggart Miller will consider the Ministry’s Guideline B-6 (Guidelines for Evaluating Construction Activities Impacting on Water Resources) during preparation of the Sediment and Erosion Control Plan.

Status

The ministry is satisfied that the proponent will prepare a Sediment and Erosion Control Plan in accordance with ministry guidelines.

Comment #69

The surface water monitoring program has been enhanced with spring, summer and fall sampling and the addition of one sampling event to coincide with a heavy precipitation event. The EA states that surface water monitoring will continue in 2014 to increase baseline data. However no 2014 data is presented in Attachment B, Appendix I, Volume IV. It was noted that previous sampling data indicated a significant variance in the data. In Section 7.2 Volume IV it states that BSW10 and BSW11 will be removed from the program once the landfill becomes operational. The reviewer cannot find any other reference to these two stations and they are not listed in Table 2 of Appendix A, Volume IV or indicated on Figure 1 of Appendix A, Volume IV.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

Ongoing baseline monitoring data (data collected in 2014 and 2015) are not included in the EA. In Table 13-4 in Section 13.3.1 of Volume III, a note states, “Regimbald Drain (upstream of Simpson Drain) and Wilson-Johnston Drain at Devine Road will be sampled during baseline monitoring starting in 2014 provided permission to access the locations can be obtained and they are practically accessible. These locations will be removed from the program once the site becomes operational.” These locations are BSW-10 and BSW-11. Note that this was not as well described in Volume IV and this may explain the reviewer’s uncertainty regarding these sampling locations.

Status

The ministry is satisfied with the response.

Comment #70

Additional stations based on the revised Figure 1 would be required on Regimbald Drain just upstream on its confluence with Simpson Drain and upstream on Wilson-Johnston Drain from Devine Road. These additions were not added in the final EA.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

In Table 13-4 in Section 13.3.1 of Volume III, a note states, “Regimbald Drain (upstream of Simpson Drain) and Wilson-Johnston Drain at Devine Road will be sampled during baseline monitoring starting in 2014 provided permission to access the locations can be obtained and they are practically accessible. These locations will be removed from the program once the site becomes operational.”

These two new locations were added in Fall of 2014 and will continue to be part of the baseline monitoring program. Ongoing baseline monitoring data (data collected in 2014 and 2015) are not included in the EA.

Status

The ministry is satisfied with the response.

Comment #71

The South Nation Watershed is guided by a total phosphorus (TP) monitoring plan that is managed by the South Nation Conservation Authority (SNCA). The plan involves point source contributors of TP off-setting their TP loadings to the South Nation River by funding reductions in other parts of the watershed if additional on-site mitigation is cost prohibitive. If not already done so, CRRRC should have discussions with the SNCA regarding this issue as TP is a common parameter that is elevated in landfill leachate at some sites.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

South Nation Conservation has been consulted as a member of the GRT team. Consultation with South Nation Conservation can be found in Volume II.

In view of the proposed leachate collection system and on-site pretreatment of leachate for conveyance to ROPEC for final treatment and discharge, increased phosphate loadings to surface water in the vicinity of the CRRRC site are not anticipated.

Status

The ministry is satisfied that consultation with SNCA was completed.

Comment #72

The final EA indicates that sampling continued in 2014 but the 2014 data wasn't updated in the surface water data tables of the final EA Previous data has shown water quality at the various locations during pre-development is quite variable. It is in the best interests of CRRRC to have a statistically relevant database for background data purposes so that post-development monitoring water quality can be compared to a competent pre-development database. Additional sampling should reduce the variability and therefore make it easier to determine if downstream water quality is influenced by the landfill or not.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

Sampling continued in 2014 and will continue in 2015 to build the database. This data was not included in the Final EA as, practically speaking, a cut-off point must be selected for these types of reports. Data collected in 2014 and 2015, and possibly in subsequent years prior to commencing site operations, will be used to supplement the baseline data reported in the EA, and provide the pre-development baseline surface water quality.

Status

The ministry is satisfied with the response.

Comment #73

Previous memos dealt with stormwater issues only as the preferred option for managing leachate was pre-treatment and trucking to Robert O. Pickard Environmental Centre (ROPEC) in the City of Ottawa for final treatment before discharge to the Ottawa River. Based on the overwhelming information in the EA submission which focused on stormwater management and discharge to three agricultural drains my assumption was that this option was approved by the City of Ottawa. The EA submission did not provide much detail on other leachate management options especially with discharge to Simpson Drain and potential impacts to downstream biological and physical impacts.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

At the time of preparing the Final EA, the information that Taggart Miller received from the City of Ottawa indicated that the City would allow receipt of the pre-treated leachate from the CRRRC at ROPEC. The motions subsequently approved by the City and submitted to the MOECC with their final comments on the Final EA dated April 29, 2015 acknowledge acceptance of leachate at ROPEC from the CRRRC (pending an Agreement between the City and Taggart Miller) up to 180,000 Lpd, at which point Taggart Miller understand it would be their requirement to find either an alternative method of delivering leachate to ROPEC or an alternative means of providing final treatment. Taggart Miller has no plan other than to pursue final leachate management at ROPEC.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #74

The City of Ottawa has provided draft comments dated February 20, 2015. In these comments the City indicates that while they can deal with the volume of leachate projected to be produced by the Capital Region Resource Recovery Centre (CRRRC) the facility is not able to support the volume of truck traffic (22 tankers per day) at the ROPEC facility. The inferred reference in this statement would indicate that pre-treated leachate from CRRRC would not be accepted at ROPEC and an alternate is required.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

See previous response.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #75

Section 4 of TSD #10 identifies other off-site wastewater treatment plant receivers and problems with each of the other options. ROPEC was determined to be the most realistic off-site receiver.

Section 5 of TSD #10 compares on-site treatment and discharge to Simpson Drain to on-site pre-treatment and leachate management at ROPEC. Both options received a “Ranked 1st” or a tied assessment for surface water. In my opinion the on-site treatment and discharge option would outweigh the stormwater only discharge option. This is because the treated effluent would be at PWQO levels which would be better than the current water quality in Simpson Drain and likely better water quality than stormwater discharged from the site. It is likely that when mixed with stormwater discharge that the effluent discharge would even improve the stormwater quality so that overall water quality of the discharge from the site would likely be better than is currently there and/or if stormwater only was being discharged. This would require some additional modelling assuming dry-ditch conditions to determine what final water quality being discharged from CRRRC would look like.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

Within Section 5 of TSD #10, both on-site wastewater treatment and discharge to Simpson Drain, and on-site wastewater pre-treatment and off-site wastewater management at ROPEC received a “Ranked 1st” in terms of surface water quantity. With regard to surface water quality, Taggart Miller ranked on-site wastewater pre-treatment and off-site wastewater management at ROPEC first and on-site wastewater treatment and discharge to Simpson Drain second. The reviewer’s opinion regarding which option would be preferred is acknowledged, although it would not change the overall outcome of the assessment.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #76

There is no discussion on the potential downstream impacts associated with erosion, flooding or impacts on current aquatic habitat not only in Simpson Drain but to Shaw Creek. The addition of up to 230,000 m3 of treated leachate leaving the site into Simpson Drain on top of the predicted total stormwater runoff of 543,160 m3 means a significant addition of water to the Simpson Drain and Shaw’s Creek. The EA stormwater management design was based on post-development flows being equal to pre-development flows so the effluent discharge would be extra. If the on-site treatment and discharge option is now to be considered as an addition to discharge flows then additional modelling for downstream impacts is required.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

The details regarding on-site wastewater treatment and discharge to the Simpson Drain was completed at a level of detail necessary to compare the leachate management options as described in the Minister approved Terms of Reference. As on-site wastewater treatment and discharge to the Simpson Drain was not determined to be the preferred leachate management option for the CRRRC, further details around this option were not developed nor are they necessary.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #77

Options for leachate discharge could include direct discharge to Simpson Drain separate from stormwater which would require engineered erosion control measures at the discharge point, discharge to the current proposed ponds (ponds might need to be resized to accommodate extra flow and to achieve the 80% TSS removal for stormwater) or a separate pond for both stormwater and leachate discharges so that water is released to Simpson drain in a more controlled manner as well as other possible discharge scenarios need to be assessed and a preferred option proposed.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

On-site wastewater treatment and discharge to the Simpson Drain was not determined to be the preferred leachate management option for the CRRRC; further details around this option were not developed nor are they necessary.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #78

The Municipality needs to be consulted with respect to capacity of the drains to accept the additional discharge or any changes to the previous proposed re-alignment of the current drains through CRRRC. An example would be; during spring freshet can the drains handle the extra effluent discharge or does the effluent have to be stored for discharge during periods of low flow in the drains.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

Taggart Miller and its consulting team have met with and had several discussions with the City of Ottawa Municipal Drainage Superintendent. Should this proposed project receive EA approval, additional discussions with the City Municipal Drainage Superintendent and revisions to the Municipal Drainage Report or the Simpson Drain will be required (as described in Section 1.7 of the Final EA).

Status

The ministry is satisfied that the proponent will do on-going consultation with the City of Ottawa.

Comment #79

It is likely that increased flows and better water quality from the effluent treated to (Provincial Water Quality Objectives (PWQO) would provide better downstream aquatic habitat but re-assessment of potential impacts by the South Nation Conservation (SNC), Fisheries and Oceans Canada (DFO) and Ministry of Natural Resources and Forestry (MNRF) is likely required to confirm.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

On-site wastewater treatment and discharge to the Simpson Drain was not determined to be the preferred leachate management option for the CRRRC; further details around this option were not developed nor are they necessary.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #80

There was no estimate of total phosphorus loadings from stormwater but the addition of 230,000,000 litres of effluent at 0.02 mg/L total phosphorus means an extra 4.6 kilograms of phosphorus per annum into the watershed. SNCA needs to be consulted as to whether this is significant or can be mitigated for.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

On-site wastewater treatment and discharge to the Simpson Drain was not determined to be the preferred leachate management option for the CRRRC; further details around this option were not developed nor are they necessary.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #81

If on-site treatment is now the only option available then the treatment system would require a change in site plan to accommodate treatment facility, potential storage pond etc. Depending on how radical the change in site plan is to accommodate the new facility changes in landfilling design, stormwater management etc. maybe necessary.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

See previous responses regarding the Simpson drain and transport of pre-treated leachate to the ROPEC.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #82

In conclusion, a change in the management of leachate at CRRRC from trucking to ROPEC to on-site treatment and discharge from a Surface Water Technical Support perspective affects only the ECA application. Most of the missing information and consultation noted above would be required as part of the ECA application. Effluent discharge criteria and associated monitoring would be developed through pre-consultation meetings with surface water staff followed by a surface water assessment of the application when that process occurs.

Reviewer

Surface Water Specialist, Water Resources Group (Eastern Region, MOECC)

Proponent’s response

Acknowledged, see responses above.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #83

The proposed facility is a Resource Recovery Centre, so the primary function should be recovery and diversion as opposed to final disposal of waste (landfilling), which is in line with the province’s waste diversion objective. It is stated in the Design and Operations Report that the ultimate diversion rate will be in the range of 43 - 57%. To ensure diversion will be a priority, it is suggested to set a minimum diversion rate, which may be specified in the EPA approval.

Reviewer

Senior Waste Engineer (EAB, MOECC)

Proponent’s response

In a meeting with the MOECC reviewer on June 19, 2015, representatives of Taggart Miller provided a rationale for why setting a minimum diversion rate is not a feasible approach for the CRRRC facility. A memorandum describing a Waste Diversion Protocol for the proposed CRRRC was provided to MOECC to address this comment.

Status

The ministry is satisfied that the proponent will carry out The Waste Diversion Protocol (Appendix C) as part of the operations of the undertaking.

Comment #84

The facility will accept IC&I and C&D waste from the Ottawa region and eastern Ontario. It is not clear in the EA report that whether all of the incoming waste will be processed at the various facilities (MRF, C&D Processing, Organics Processing, Petroleum Hydrocarbon (PHC) Treatment, Composing, etc.) to recover as much useable materials as possible, so that only the residue waste will be disposed at the landfill.

Reviewer

Senior Waste Engineer (EAB, MOECC)

Proponent’s response

Refer to response immediately above. Sections 5.6 and 5.10 of Volume IV indicate that once the CRRRC is operating at its full capacity, all incoming waste to the site will be processed at the various facilities, with the exception of 1) incoming truck loads of IC&I waste received at the MRF that are deemed to not be suitable for diversion based on the contained mixture of waste for processing, and 2) non-hazardous contaminated soil (with the exception of PHC-contaminated soil directed to the treatment facility) that will be directed to the landfill primarily for use as daily cover.

Status

The ministry is satisfied that the proponent will carry out The Waste Diversion Protocol (Appendix C) as part of the operations of the undertaking.

Comment #85

The proposed landfill will not have an engineered base liner (geomembrane or compacted clay) and it will rely on natural attenuation for the leachate impacted groundwater at the landfill. So it is important that there will be adequate contaminant attenuation zone in the downgradient to ensure compliance with the Reasonable Use Guideline at the property boundary. Although the groundwater model suggests that there will not be off-site contamination, it may not represent the real site condition, and need to be verified through monitoring during operation. Therefore it is extremely important that the site design will allow the monitoring of site performance in the first stage and provide adequate contaminant attenuation zone for implementation of contingency measures if required. However, according to the landfill phasing plan, the first stage is on the east side which is in the groundwater downgradient, this is not a preferred site development plan. As a compensate measure, a leachate detection and secondary containment system (LDSCS) is proposed in the downgradient of the site. Although this is considered acceptable, consideration shall be given to move the first stage further from the east boundary in the detailed design stage.

Reviewer

Senior Waste Engineer (EAB, MOECC)

Proponent’s response

The natural clay deposit that underlies the site will provide a substantial natural low permeability liner that is coupled with a leachate collection system and perimeter hydraulic barrier and leachate detection and secondary containment system (LDSCS) to provide an engineered leachate containment and management system.

A monitoring program is outlined in Section14.1.2 of Volume I, Section13.4 of Volume III and Section 7.1 of Volume IV of the EA submission package. The groundwater monitoring program will identify potential leachate impacted groundwater and contingencies can be implemented to ensure compliance with the Reasonable Use Guidelines. The contingency measures are discussed in Section 14.0 of Volume I, and in greater detail in Section 8.0 of Volume IV.

The LDSCS design component will provide both leachate detection and a secondary containment system continuously along the east side of the landfill. This approach was agreed upon by the groundwater technical reviewer from the MOECC in place of altering the filling sequence.

Status

The ministry is satisfied the landfill design will meet ministry guidelines. The ministry is satisfied that a groundwater monitoring plan will be implemented to ensure the protection of groundwater.

Comment #86

According to the proposed landfill design, the LDSCS will be installed in the surficial silty sand layer. However, as there is another silty sand and sandy silt layer just 3 - 4 m below the landfill base, in the absence of an engineered base liner, leachate migration to the lower silty sand layer is also of concern. So installing the LDSCS in the lower silty sand layer should also be considered.

Reviewer

Senior Waste Engineer (EAB, MOECC)

Proponent’s response

The LDSCS was incorporated into the design as a protection/detection measure for the silty sand layer that represents the preferred pathway for lateral migration of leachate-impacted water. The less thick, less permeable silty layer is not a preferred pathway for migration of leachate-impacted water, noting that the leachate constituents would have to first migrate through approximately 3 to 4 metres of low permeability native silty clay to reach the silty layer. The groundwater monitoring well network hydraulically downgradient of the landfill, which includes 19 monitoring well nests along the eastern edge of the landfill, is in place to detect potential leachate-impacted groundwater in the silty layer. Deepening of the LDSCS to the lower silty layer is not considered necessary.

Status

The ministry is satisfied the landfill design will meet ministry guidelines. The ministry is satisfied that a groundwater monitoring plan will be implemented to ensure the protection of groundwater.

Comment #87

As the landfill will be developed in phases, internal temporary berms shall be constructed for diversion of storm water and site access, and the same GCL side barrier system same as the perimeter berm shall also be installed on the temporary berm.

Reviewer
Proponent’s response

It is intended that the applicable portion of the perimeter berm will be constructed as described in the submission prior to any waste placement within a phase, in order to provide the required leachate containment. As such, a GCL in a temporary interior berm (within the landfill footprint) would be redundant and is not proposed.

Status

The ministry is satisfied the landfill design will meet ministry guidelines.

Senior Waste Engineer (EAB, MOECC)

Comment #88

The leachate manhole including the High-density polyethylene (HDPE) chamber, and the clean outs shall be designed with sufficient strength to sustain the anticipated waste stress and landfill settlement, and should properly sized to accommodate the submersible pump and the accessories.

Reviewer

Senior Waste Engineer (EAB, MOECC)

Proponent’s response

Agreed.

Status

The ministry is satisfied the landfill design will meet ministry guidelines.

Comment #89

Besides the landfill, leachate generated from other areas of the site including the organic processing area, compost processing and storage pad, the petroleum hydrocarbon contaminated soil treatment area, the truck wash station, and the material recovery facility shall be collected and directed to the on site treatment facility.

Reviewer

Senior Waste Engineer (EAB, MOECC)

Proponent’s response

As per Section 12.2 of Volume I, liquor from the organics processing will be reused in the process, if possible, and the remaining liquor will be directed to the on-site pre-treatment facility.

Runoff from the compost pad will be directed to stormwater management ponds to be used for compost pile spraying or site irrigation (see Appendix G to Volume IV). Should water quality be such that site irrigation is not possible, it is contemplated that surplus water would be taken to the City of Ottawa wastewater treatment plant with the pre-treated wastewater from the site.

Rainwater runoff and water draining from the PHC soil piles will be collected in a storage tank. The collected water will be mixed back into the piles to increase moisture. Should water quantity be such that re-use in the piles is not possible, it is contemplated that surplus water would be disposed of off-site and/or mixed into the leachate treatment system (See Section 10.6 of Volume I and Appendix H to Volume IV).

Runoff from the vehicle maintenance garage will be run through an oil-water separator before being drained to the stormwater management system. The tire wash station is envisioned to be a recirculating system with a solids interceptor.

Water collected by floor drains in the MRF will accumulate in underground holding tanks. The water will be removed with a vacuum truck for off-site treatment or be delivered to the on-site leachate pre-treatment facility (See Appendix E to Volume IV).

Status

The ministry is satisfied with the proponent’s proposed leachate management system.

Comment #90

As an important part of the public consultation, the Community Liaison Committee (CLC) shall be established as early as possible. Issues discussed and the resolution shall be posted and made available to the public in a timely manner. Records of CLC meetings shall be included in the application for EPA approval.

Reviewer

Senior Waste Engineer (EAB, MOECC)

Proponent’s response

Agreed.

Status

The ministry is satisfied that the proponent will establish a CLC.

Comment #91

A financial assurance evaluation to be prepared in accordance with Regulation 232 and the Financial Assurance Guideline shall be submitted in the EPA application.

Reviewer

Senior Waste Engineer (EAB, MOECC)

Proponent’s response

Understood.

Status

The ministry is satisfied that the proponent will submit a financial assurance evaluation with its EPA application.

Comment #92

The implementation of the retained option for wastewater management depends on the approval of the City of Ottawa.

Reviewer

Senior Wastewater Engineer (EAB, MOECC)

Proponent’s response

Acknowledged. See previous responses regarding this issue.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #93

It is suggested that if an agreement is not reached with the City other alternatives, including the on-site wastewater treatment and discharge to Simpson Drain, will be identified and included in an updated comparative evaluation, to decide on the wastewater treatment option to pursued.

Reviewer

Senior Wastewater Engineer (EAB, MOECC)

Proponent’s response

Acknowledged; however, as discussed above, it is now clear that ROPEC has sufficient treatment capacity.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #94

Knowing that the above change of option might require (a) that the site Development Plan be revised, and (b) a receiver capacity assessment be conducted if necessary, it is my opinion that the said comparative evaluation should be part of and should further be documented in the present EA after consultation with the Ministry Regional Technical Support Section.

Reviewer

Senior Wastewater Engineer (EAB, MOECC)

Proponent’s response

As noted above, no changes in the preferred option (ROPEC) is required or anticipated. As such, further documentation in the EA is not required.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #95

TME has indicated in the Consultation Record (Volume II, Appendix K, Table K-3) that negligibility assessments, additional modelling and impact analyses were performed for contaminants not identified as indicator compounds. At the time of submission, these analyses were not included. Trish Edmond of Golder Associates L. noted this discrepancy and forwarded the missing information on January 23, 2015. I have reviewed the negligibility analysis, and note that several emission thresholds were incorrectly calculated- those with 10 minute limits were calculated using a 30-minute averaging period conversion factor. Correcting this error pushes Dimethyl sulfide into significance, which should be modelled and compared to relevant standards.

Reviewer

Air Quality Analyst (Eastern Region, MOECC)

Proponent’s response

We have reviewed our January 23, 2015 analysis and cannot find any error in that work as described in the reviewer’s comment. We used 10 minute, 30 minute, 1 hour, 24 hour, and annual averaging periods depending on the contaminant and their applicable standards. However, an updated negligibility analysis (significance of contaminants assessment using the same averaging periods) was completed and has been provided to the reviewer to respond to comment #15 from the Environmental Approval Services - Environmental Approvals Branch below.

Status

The ministry is satisfied with the response.

Comment #96

TME has included AERMOD input and output files for indicator contaminants in their entirety, except for Dimethyl sulfide discussed in Concern 1 above.

Reviewer

Air Quality Analyst (Eastern Region, MOECC)

Proponent’s response

Refer to response above.

Status

The ministry is satisfied with the response.

Comment #97

I am satisfied with the treatment of cumulative effects with respect to air quality presented in the submission. Language has been changed in relevant sections (TSD #3, S4.3 and S4.4) to improve clarity.

Reviewer

Air Quality Analyst (Eastern Region, MOECC)

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with the response.

Comment #98

No additional comment. Odour frequency analysis is not expressly required and has not been included in the submission.

Reviewer

Air Quality Analyst (Eastern Region, MOECC)

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with the response.

Comment #99

I accept that detailed equipment specifications are not available at this level of design, and suggest that equipment selected for the CRRRC in the future should meet emission rate estimates used in this assessment or, if higher, demonstrate compliance using a similar or more rigorous approach.

Reviewer

Air Quality Analyst (Eastern Region, MOECC)

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with the response.

Comment #100

The submission predicts air quality impacts and I agree with the majority of the report conclusions with exceptions and concerns noted and discussed above. I am satisfied the submission meets the agreed upon ToR.

Reviewer

Air Quality Analyst (Eastern Region, MOECC)

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with the response.

Comment #101

The EA Report has inconsistent information on the proposed site layout and source location. The site Plan for the preferred alternative described in section 9.4 of the EA Report (Figure 9.3-1) does not match the site Plan described in the TSD #3 (Figure 1-l). The site configuration used in the model could not be confirmed.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

Figure 9.3-1 of the EA Report presented Alternative site Development Concept A, one of the two alternatives considered. Following the selection of the Preferred site Development Concept, the site Plan was revised as described in Section 10 of the Volume I EA Report and is presented in Figure 10-1 of the EA Report. The TSD #3 site Plan (Figure 1-1), which was used in the air quality assessment, corresponds to the Preferred site Development Concept presented in Figure 10-1 of the EA Report.

Status

The ministry is satisfied with the response.

Comment #102

An electronic copy of the model runs has not been provided. A copy of the modelling files should be included to allow the ministry to comment on the findings and conclusions of the EA Report.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The dispersion modelling files were sent to the reviewer on June 24th, 2015.

Status

The ministry is satisfied with the response.

Comment #103

There appears to be an error in the modelling approach. The final EA Report describes the landfill as having a release height of 1.9 metres and not 45.8 metres (see Technical Support Document#3, Appendix B, Table B.6-2). Any inconsistency in the modelling parameters should be corrected, including an updated contaminants significance assessment (Table 1, Appendix K) and predicted compliance assessment (Table 11.2.2-4).

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The landfill has been remodeled with a modelled release height of 10 m (half the maximum peak height). Revised modelling files, significance assessment and TSD tables are provided in the February 2016 Air Quality Addendum.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #104

Odour modelling is carried out using the regional meteorological data set. Frequency analysis has not been considered in the odour assessment. ln addition, it was confirmed that the predicted maximum odour level is 0.96 ou at the sensitive receptor (although the EA Report presented the model prediction of 99.51 percentile of 0.58 ou as per Table 11.2.2-4). In the event that a frequency analysis is carried out in the future, then odour modelling shall be conducted using local meteorological data set approved by the ministry’s Environmental Monitoring and Reporting Branch (EMRB), as indicated in the ministry’s technical bulletin "Methodology for Modelling Assessments of Contaminants with 10-minute Average Standards and Guidelines".

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

Acknowledged. A revised Table 4-4 has been provided in the February 2016 Air Quality Addendum to include the predicted maximum concentration and the 99.5th percentile.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #105

It appears that the Organics Pre-processing Facility is conceptually designed for 2 air changes per hour as per section 9.2.2 of the EA Report and the Technical Support Document #3. Supporting documentation should be provided during the ECA application stage, demonstrating that the ventilation design is sufficient to minimize the fugitive odours from the building.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The biofilter design capacity emission rates presented in the EA are based on emissions from equipment suppliers for similar operations. Following EA approval, if the equipment when finally selected has higher emission rates than those used in the air quality assessment that was supplied as supporting information for the EA application for the project, the emissions will be re-assessed to demonstrate continued compliance with Ontario Regulation 419/05 as required as part of the EPA, Part II Approvals.

Status

The ministry is satisfied with the response.

Comment #106

A description of the odour control approach for the tanker loading operation, which appears to be an outdoor process, should be provided.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The pumping of the organics slurry from the exterior, closed storage tank into tankers for haulage off-site to off-site anaerobic digestion facilities takes place within piping from the storage tank to the tanker. There is little opportunity for odour generation from this process. Air discharged as a result of the filling of the tanker has odours reduced by passing the air through carbon filters attached to the tanker. Additional information on odour is provided in section 2.1 of the February 2016 Air Quality Addendum.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #107

The digested product still requires curing and is potentially odorous. A description of the odour control concept for the opening of the reactor and for the air injection process should be provided.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

To clarify the operating procedure, the process of air injection occurs before, not after the opening of the primary reactor cells. Please refer to the Organics Processing Facility - Odour Management Plan provided to the reviewer in the February 2016 Air Quality Addendum.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #108

The proposal is for the placement of blended source separated organics in the primary reactor cells using front end loader(s. A description of the proposed odour control approach for the outdoor loading of organics into the reactor should be provided.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

Please refer to the Organics Processing Facility - Odour Management Plan provided to the reviewer in the February 2016 Air Quality Addendum.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #109

The EA Report should include a description of the proposed odour control concept for the digested product curing/composting process, which is to occur outdoors.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

Please refer to the Organics Processing Facility - Odour Management Plan provided to the reviewer in the February 2016 Air Quality Addendum. Additional information on odour is provided in section 2.1 of the February 2016 Air Quality Addendum.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #110

Please provide the odour control concept for the leachate treatment facility, including the sources that are to be collected and treated using the scrubber. It is understood that the leachate treatment building will house the liquor/leachate storage tanks, chemical precipitation process, sequencing batch reactor, sludge management system and truck loading station.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

Additional information on the odour control concept is as follows. As noted in the comment, the leachate treatment building will be equipped with a scrubber stack to control all emissions. The main components anticipated that would be served by the scrubber are the reactors. Ventilation hooding routed to the scrubber can be provided as required for the other potential odour sources.

Status

The ministry is satisfied with the response.

Comment #111

The proposed site development plan includes an outdoor equalization pond to hold the leachate from the landfill and the liquor from the organics processing facility. Please describe the odour management approach for this potentially odorous source.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

As discussed in the Design and Operations Report (Volume IV) in Appendix C, Table 1, the potential odour emissions from the leachate holding pond and the treated effluent pond will be mitigated through aeration and use of a misting system. The leachate holding pond is intended to only be used for overflow (collected leachate volumes in excess of the plant’s treatment capacity) prior to pre-treatment.

Status

The ministry is satisfied with the response.

Comment #112

A control efficiency of 85% has been applied to the estimation of the unpaved and paved road dust emissions to represent the dust suppression activities at the site (as per Appendix A of the Technical Support Document #3, sections 4.1.3 and 4.1.4). The EA Report should cite the documentation or references used to support the estimated control efficiency.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The control efficiency of 85% is based on the site’s proposed best management practices to be implemented to mitigate fugitive dust as described in the Design and Operations Report. The control efficiency selected is within the range described in the Western Regional Air Partnership’s (WARP) Fugitive Dust Handbook. Additional information on the 85% control efficiency is provided in Section 2.2 of the February 2016 Air Quality Addendum.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #113

It appears that the particulate emissions from the proposed outdoor wood grinding and chipping operation in the compost storage and processing pad (as described in section 9.2.2) have not been identified and assessed in the EA Report. Please clarify and provide a revised compliance assessment (Table l l.2.2-4), as necessary.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The particulate emissions from the wood grinding and chopping operations were considered to be insignificant. Wood grinding will only occur periodically, and the frequency will depend on the rate and amount of material received. The material to be chipped and ground will have relatively high moisture content and is expected to result in negligible particulate emissions in any event. Given the moisture content of the material, the relatively small processing capacity of the chipper and grinder (estimated at 1 metric tonne per hour), the infrequent nature of the operation and the location on site, inclusion of particulate emissions from this source in the Air Quality Assessment was not considered necessary and would not alter the outcome of the assessment. Additional information on the infrequent wood grinding and chipping operation is provided in section 2.1 of the February 2016 Air Quality Addendum.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #114

As per section 4.1 .6 of Appendix A of the Technical Support Document #3, particulate emissions from the baghouse dust collectors are based on the MOECC Procedure Document (Guideline A-10); an outlet loading of 10 mg/m3 is applied to estimate particulate emissions. Please note that the ministry’s guidance document refers to an emission factor of 20 mg/m3. The ministry can consider deviations from the guidance document based on site-specific situations. Supporting information shall be provided during the ECA application stage.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The baghouse dust collector outlet loading is based on the current recommended outlet values emissions factor of 10 mg/m3 for dust collectors as reflected in the MOECC Procedure Document (Guideline A-10) (Draft Version 4.0). Additional information is provided in section 2.2 of the February 2016 Air Quality Addendum.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #115

The method used for landfill gas assessment using the 30-year averaged landfill gas generation rate is not appropriate for assessing compliance over short-term averaging periods (i.e., compliance assessment is based on the MOECC 10-min, L-hour and 24-hour standards/guidelines for nonmethane organic compounds (NMOC)). Please provide an updated contaminants significance assessment (Table 1, Appendix K) and predicted compliance assessment (Table 11.2.2-4).

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

In our opinion, the method using the 30-year averaged LFG generation rate is appropriate given the estimate of landfill gas generated using the landGEM model assumes that organics will be present in the landfill gas. However, to demonstrate that this method will not alter the outcome of the assessment, we have updated the contaminant significance assessment in conjunction with this response. Revised emission rate calculations, significance assessment ,Table 4-4 and other tables from TSD #3 are provided in the February 2016 Air Quality Addendum.

It should be noted that contaminants presented in the contaminant significance assessment were all assessed against their applicable standard. The results of the updated compliance assessment do not change the predicted compliance.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #116

Landfill gas generation rate is estimated based on a biological decay model (LandGEM). Please note that the ministry can consider the methane generation potential based on site­ specific situations; however, supporting information should be provided for ministry review.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The LandGEM variables recommended by MOECC were used for the assessment, as provided in Attachment A in TSD#3.

Status

The ministry is satisfied with the response.

Comment #117

The EA Report does not appear to have taken into account the much higher levels of NMOC observed from landfills where contaminated soils are used as daily cover (as per the USEPA AP-42 publication). A revised assessment should be submitted accordingly.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The EA report did not assess the potential that use of contaminated soils as daily cover may have higher levels of NMOC emissions since the same documentation cited (United States Environmental Protection Agency (USEPA) AP-42 publication) explains that there is insufficient data to develop a factor or algorithm for estimating NMOC from contaminated soil used as daily cover.

However the CRRRC, unlike other facilities, will include a contaminated soils treatment facility. Heavily impacted soils will be treated prior to application as daily cover. Considering the total soil required for daily cover both annually and daily and the processed contaminated soil available for use as daily cover annually and daily it is estimated that Further, only 10 to 15% of the processed contaminated soil capable of generating NMOC’s will be used as daily cover.

It is noted that the NMOC assessed are well below the MOECC standards. As such, assuming higher NMOC concentrations in a small portion of the daily cover soils would not alter the outcome of the Air Quality Assessment. Therefore, in our opinion a revised assessment is not required. Additional information is provided in section 2.3 of the February 2016 Air Quality Addendum.

Status

The ministry is satisfied that the proponent has committed to only using 10 to 15% contaminated soil for daily cover.

Comment #118

The USEPA AP-42 publication describes a large range (0.003 ppmv to 12,000 ppmv) in H2S concentrations at landfills where a majority of the waste is composed of C&D material. Please cite the documentation/reference used in the assumed total reduced sulphur concentration of 39.64 ppmv (as per section 4.1.7 of Appendix A of the Technical Support Document #3) and its applicability to the proposed landfill.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The total reduced sulphur concentration of 39.64 ppmv is calculated following the method described in US EPA AP-42 documentation. A sample calculation for one individual sulfur compound is provided in section 4.1.7 of Appendix A of the TSD #3of the EA. A full sample calculations package completed for all sulfur compounds is provided in conjunction with this response.

Based on the target diversion rates, it is estimated that about 13% of landfilled waste will be comprised of residuals from the C&D processing. The majority of the waste at the CRRRC will not be from C&D waste (or the C&D components that can generate H2S such as drywall). As such we believe it is appropriate to use the emission factor calculated from individual sulfur compounds as presented in section 4.1.7.

Status

The ministry is satisfied with the response.

Comment #119

The EA Report does not appear to have taken into account the odour emissions from the following activities.

  • outdoor tanker loading of organics slurry
  • outdoor operation of the digesters including opening of the reactors and air injection
  • outdoor loading of source separated organics into the reactor
  • outdoor curing/aeration of the digested product from organics processing
Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

An additional primary reactor odour source with an area of 5% of the total landfill size has been added to the odour assessment. Revised modelling files and results of the assessment are provided in in the revised Table 4-4 in Section 2.4 of the February 2016 Air Quality Addendum. Additional details on the odour management are provided in the Final Odour Management Plan in Appendix A of the February 2016 Air Quality Addendum.

Status

The ministry is satisfied that the modeling was revised in the Air Assessment Addendum.

Comment #120

The EA Report has not provided an assessment of the odour-causing contaminants from the proposed organics processing and leachate/liquor treatment process (such as ammonia and total reduced sulphur). A revised assessment should be provided accordingly.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

Odour as a contaminant was assessed from the organics processing and leachate treatment process as documented in TSD #3 of the EA source 5 and source 11, respectively.

It is not expected that ammonia or total reduced sulphur, as a group, would be released in significant amounts from the organics processing. An evaluation of individual sulphur compounds was conducted as part of the EA and most were found to be negligible. An assessment of compounds that were considered, and were predicted to likely to be released in significant amounts, but are not indicator compounds is presented in the supporting material provided in conjunction with this response.

We also note that in the leachate treatment process, the scrubber stack would serve to also reduce emissions and associated odours of ammonia and total reduced sulphur.

Status

The ministry is satisfied with the response.

Comment #121

Please clarify that the emission factor (of 0.56 ou/m2 as described in section 4.1.13 of Appendix A of the Technical Support Document #3) used for estimating odours from the outdoor composting pad is representative of the proposed operation and waste processing activities at the site, including leaf & yard composting and curing of digested source separated organics. Provide a copy of the reference material used in the assessment, and a revised odour assessment if applicable.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

Emission factors used to calculate the odour emissions associated with the proposed composting activities were obtained from a study completed for GORE (Barth & Bitter GmbH, 2006). The maximum annual throughput of compost is 50,000 tonnes/year, roughly 60% of which was assumed to be digested product, and 40% of which will be yard waste. Approximately 32,000 tonnes of the final product was assumed to be produced annually. The average emission rate for all composting activities was calculated following methodology described in the study from GORE.

A copy of the reference document as well as the calculations completed from the composting pad odour emissions is provided in conjunction with this response.

Status

The ministry is satisfied with the response.

Comment #122

It appears that the same emission factor is incorrectly applied to estimate odours from the proposed leachate equalization pond and the effluent pond. It is expected that odours from the equalization pond (holding the leachate from the landfill and the liquor from the organics processing facility) would be much higher than that of the effluent pond. Please provide a revised assessment demonstrating that the proposed outdoor holding/equalization pond would not cause an adverse effect.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The potential for the equalization pond to generate more odours than the effluent pond is noted, however at the CRRRC site the potential odour generated from the leachate should be considerably less than typical landfill leachate because of the high percentage of organics that will be removed and processed prior to disposal. Further, the leachate equalization pond is not expected to be required on a continuous basis. It is designed to be an overflow pond in the event that more leachate is produced than can be processed. The emission factor for both ponds was estimated based on information obtained from the design team and an emission factor of 100 OU for a final clarifier (from Odor Threshold Emission Factors for Common WWTP Processes; St. Croix Sensory Incorporated, 2008). While we are aware of no emission factors for this type of landfill leachate (where organics are removed from the process prior to material going to the landfill), this emission factor was selected based on project team experience and considering the negligible liquor odour generated by the University of Toronto experimental setup that was visited by the reviewer. The flow rates used were provided by the design team based on information available from suppliers obtained as part of the conceptual design. Therefore a revised assessment is not required in our view.

Additionally, conservatism has been included in the assessment by modelling the ponds at their maximum surface area. Since emissions are proportional to the surface area this approach maximizes the potential emissions.

Status

The ministry is satisfied with the response.

Comment #123

According to section 10.9 of the EA Report, Taggart Miller would consider the option of an on-site wastewater treatment facility in case that the City of Ottawa is unable to accept the pre-treated wastewater from CRRRC. The EA Report has not provided an assessment of the on-site wastewater treatment or documentation that supports acceptable odour impact as a result of establishing an on-site wastewater treatment. At this time, the EA Report covers the leachate pre-treatment only.

Reviewer

Senior Air Engineer (EAB, MOECC)

Proponent’s response

The motions approved by City Council in the spring of 2015 and submitted to the MOECC with the City’s final comments on the Final EA dated April 29, 2015 acknowledge that ROPEC has adequate capacity to accept leachate from the CRRRC. Taggart Miller has no plan to pursue full on-site leachate treatment at the CRRRC site.

Status

The ministry is satisfied that pre-treated leachate from the CRRRC will be transported to the ROPEC.

Comment #124

I have no further comments on the EA.

Reviewer

Senior Noise Engineer (EAB, MOECC)

Proponent’s response

Acknowledged.

Status

The ministry is satisfied the proponent will follow applicable ministry noise guidelines for the construction and operation of the CRRRC.

Comment #125

4.0 Rationale for the Proposed CRRRC. Data (page 37, para 2): Clarify source for generation and diversion data.

Reviewer

Climate Change and Environmental Policy Division (CCEPD, MOECC)

Proponent’s response

As noted in the opening sentence in Section 4.0, the analysis undertaken by Taggart Miller was presented in Supporting Document #1 of the approved ToR. As described in Section 3.1.1 of that document:

  • The source of information for IC&I and C&D generation rates were developed using the population multiplied by the waste generation rate per capita. The Waste Management Industry Survey data prepared by Statistics Canada were used to calculate an IC&I and C&D waste generation rate for the City of Ottawa and the remainder of the select eastern Ontario service area.
  • The source of information for IC&I and C&D diversion was: 1) for the City of Ottawa, the City of Ottawa IC&I 3Rs Strategy was used; 2) for the remainder of the select eastern Ontario service area, a diversion rate of 13% in 2008 was calculated using data from the Waste Management Industry Survey prepared by Statistics Canada.
Status

The ministry is satisfied with the response.

Comment #126

6.3.2 Conceptual Level Description of the Proposed CRRRC. Diversion rate (page 42, paragraph 1): Does the stated diversion rate(s) include waste materials that will be sent to an energy from waste facility? Note that the ministry considers energy from waste a form of disposal and not waste diversion.

Reviewer

Climate Change and Environmental Policy Division (CCEPD, MOECC)

Proponent’s response

The stated diversion rate does not include waste material sent to an energy from waste facility. There are none in this area and this is not contemplated. The diversion rate only includes diversion of materials from landfill by the proposed CRRRC diversion facilities, as a percentage of the total amount of waste received at the CRRRC.

Status

The ministry is satisfied with the response.

Comment #127

9.1 Identification of Preferred site Development Concept. Waste streams and Diversion - Absence of enforced diversion regulations (page 129, section 9.1, paragraph 3).Two regulations under the Environmental Protection Act require businesses to undertake waste diversion activities:

  • Ontario Regulation 102/94 requires owners and operators of certain large IC&I establishments to complete waste audits and prepare waste reduction work plans.
  • Ontario Regulation 103/94 requires owners and operators of certain large IC&I establishments to source separate specific wastes and take reasonable effort to reuse and recycle these wastes.
Reviewer

Climate Change and Environmental Policy Division (CCEPD, MOECC)

Proponent’s response

Taggart Miller acknowledges these two regulations. The statement in Section 9.1 page 129 states “in the absence of enforced diversion regulations”, with the emphasis on the enforcement aspect. The current resultant overall diversion rate of IC&I and C&D waste in Ontario is at only about 13% as described previously in Section 4.0.

Status

The ministry is satisfied with the response.

Comment #128

11.2.2.2 Prediction and Assessment of Environmental Effects. Potential greenhouse gas (GHG) effects (diversion vs. no diversion from landfill): Re: landfill gas recovery rates (p.187 last paragraph): Landfill gas collection systems can range in efficiency from 50-75%; would be beneficial to see a range.

Reviewer

Climate Change and Environmental Policy Division (CCEPD, MOECC)

Proponent’s response

A value of 75% was assumed and is considered a representative value for the CRRRC landfill where a horizontal gas collection system is to be installed within the waste as filling is ongoing, and where methane gas generation is expected to be lower than in a typical landfill because of the organics diversion proposed at the CRRRC. In a situation in which landfill gas recovery is lower, the GHG benefit of organics*-+ diversion is correspondingly greater.

Status

See subsequent follow-up comment and response below.

Comment #129

The 75% efficiency rate is likely too high for a landfill that would have lower amounts of methane generated and not using vertical gas collection wells. Higher efficiency rates are typically associated with landfills generating higher amounts of methane. If the landfill gas generation is low because of the nature of the waste, Taggart Miller should calculate the gas collection efficiency using the generation factor that is appropriate for the type of waste being managed.

Reviewer

Climate Change and Environmental Policy Division (CCEPD, MOECC)

Proponent’s response

The collection efficiency is the average value used for the Air Quality Assessment and is based on values from the USEPA AP-42 for various types of collection systems. Considering that two levels of horizontal collectors are to be installed within the waste during landfilling, this efficiency is considered appropriate for predictive modelling purposes at this site. The amount of gas generated was calculated using the Ministry’s approved Landfill Gas Emissions Model (LandGEM) model as per MOECC guidance from the Environmental Approvals Branch requested during the Environmental Assessment of this site regarding the evaluation of emissions from the landfill. The LandGEM variables recommended by the MOECC were used for the assessment, because, as discussed with MOECC, there is insufficient data at this time (or at the time the EA was being prepared and submitted) to support the use of a different model to estimate the amount of gas that will be generated or to modify the LandGEM default variables recommended by the MOECC.

Status

The ministry is satisfied with the response.

Comment #130

Both sites are near Ecole elementaire catholique Saint-Guillaume, which is located at 5750 Buckland Road in Vars (approximately 5.5 km away). CECCE is concerned about the negative impact, in respect of:

  • Dust from the processing and sorting of materials generally (e.g., crushing of cement and concrete);
  • The environmental impact of, and possible soil contamination from, the storage of various metals (heavy metals, lead, etc.);
  • Children are generally more vulnerable to the influence of contaminants.

As a School Board, our primary concern is the well-being of our students. For these reasons, CECCE wishes to inform you of its disagreement with the proximity of the two sites to Ecole elementaire catholique Saint-Guillaume.

Reviewer

Conseildes ecoles catholiques Du Centre-Est (CECCE)

Proponent’s response

In the province of Ontario, MOECC air quality standards must be demonstrated to be achievable at the closest residence to the CRRRC. As such, the air assessment described in Section 11.2.2 of Volume I (the main EA) and TSD #3 are protective of the indicated school since 5.5 kilometres is much further away than the nearest residence to the CRRRC, where MOECC standards have been demonstrated to be met.

Status

The ministry is satisfied with the air assessment completed for the CRRRC EA.

Comment #131

The Ministry of Energy did not have comments on the EA but we note that the plan mentions possible electricity generation at the site which would likely require an additional EA/environmental approvals process.

Reviewer

Ministry of Energy

Proponent’s response

The requirement for a Renewable Energy Approval has been considered by the project team in consultation with the MOECC and based on the details of the proposal for the CRRRC was determined to be not applicable. Also, the Ontario Power Authority is currently understood to be not accepting applications from such sources.

Status

The ministry is satisfied with the response.

Comment #132

In general, MNDM has no concerns with the proposed project.

Reviewer

Ministry of Northern Development and Mines (MNDM)

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with the response.

Comment #133

The MNRF is satisfied that Barn Swallow were identified on site, and that Registration, under the Endangered Species Act, will occur for that particular species prior to disturbance or removal of habitat, and that all requirements outlined in the Registration will be complied with.

Reviewer

Ministry of Natural Resources and Forestry (MNRF)

Proponent’s response

Acknowledged.

Status

The ministry is satisfied that the proponent will comply with the requirements under the Endangered Species Act.

Comment #134

Only three woodlands were surveyed for bats, however additional woodlands, per the Ecological Land Classification mapping were identified; as such more surveys should have been carried out at these locations. Furthermore, the MNRF requires rationale for the presence/absence of bats and their habitat for this site; this could be in the form of photos, greater in-depth explanation of the woodland characteristics and analysis of the suitability of the site. The MNRF recommends the use of the Ministry of Natural Resources and Forestry Bats and Bat habitats: Guidelines for Wind Power Projects (July 2011) to guide survey efforts.

Reviewer

Ministry of Natural Resources and Forestry (MNRF)

Proponent’s response

A habitat assessment, which included a snag assessment, following the protocols in the Ministry of Natural Resources and Forestry Bats and Bat habitats: Guidelines for Wind Power Projects (July 2011) document was conducted on the entire site.

The only areas that met the criteria for suitable habitat for the listed bat species included two buildings on the site. One woodland, although immature and not having the characteristics of good quality habitat, was also surveyed out of an abundance of caution. There were no woodlands on the site that had more than ten snags per hectare, which would signify roosting habitat, as per the MNRF guidelines. All of the woodlands on the site are immature and no suitably sized trees were identified that contained cavities or loose bark suitable for maternity roosting, with the exception of larger shade trees in and amongst the area of the buildings that were surveyed.

Status

The ministry is satisfied with the response.

Comment #135

The Environmental Assessment indicates that Butternut surveys were carried out, however little detail pertaining to these surveys was provided as to the detail and extent of the surveys.

Reviewer

Ministry of Natural Resources and Forestry (MNRF)

Proponent’s response

Botanical surveys were conducted during multiple seasons in 2012 and 2013 by walking through all habitats. Butternut was not observed during any surveys and is not believed to be on the site. Ongoing diligence during the construction phase of the project will be exercised in the unlikely event that any trees were missed. Construction staff will be educated on how to identify and avoid butternut.

Status

The ministry is satisfied that the proponent will monitor for Butternut during the construction of the undertaking.

Comment #136

Nocturnal surveys for Whip-poor-will should have included interior surveys distributed throughout the property, rather than surveys carried out from the roads/rights of way.

Reviewer

Ministry of Natural Resources and Forestry (MNRF)

Proponent’s response

Nocturnal surveys were not specifically designed to target eastern whip-poor-will, but rather were part of general wildlife surveys (taking into account all relevant protocols). As discussed below, there is no habitat for eastern whip-poor-will on the site. Nor are there any records for eastern whip-poor-will on Natural Heritage Information Centre (NHIC), the Ontario breeding bird atlas, or e-bird within the vicinity of the site.

Status

The ministry is satisfied with the response.

Comment #137

The MNRF is satisfied with respect to the determination that there would be no basking or nesting areas on the property and therefore is satisfied that no surveys to this effect were carried out. However, there is a Snapping Turtle observation from 2009 at Devine and Boundary Road, and the site has potential to be used as a travel corridor for turtles as well, particularly as there are suitable wetlands in proximity to the site.

Reviewer

Ministry of Natural Resources and Forestry (MNRF)

Proponent’s response

Movement corridors for wildlife will be maintained along the perimeter of the site following construction. The site is surrounded on three sides by disturbed or developed areas. No snapping turtles were observed on, or near, the site during the field surveys over multiple seasons in 2012 and 2013. Should there be snapping turtles observed in the area, they will be precluded from the site during construction and operation. Preclusion will include using exclusion fencing following MNRF guidelines for reptile and amphibian exclusion fencing (July 2013), as necessary, so individuals are protected.

Status

The ministry is satisfied that the proponent will follow the necessary guidance for the protection of wildlife.

Comment #138

Amphibian surveys should have been carried out in the identified swamp communities. As the road surveys identified a substantial number of amphibians, the MNRF would like to know how this was considered in relation to the Significant Wildlife Habitat (SWH) Technical Guide. Further to this, there is an identified wildlife staging area located on the northern portion of the site, which has not been addressed in the report and addressed in relation to the Significant Wildlife Habitat Technical Guide.

In addition, as there are wet areas identified on the site, there is potential for Flooded Jelly Skin, threatened lichen, grows at the base of trees around vernal ponds and waterways in wet lowland forests flooded every spring, with the main tree species being Black Ash. Low lying wet woodlands and vernal pools should be examined for this species.

Reviewer

Ministry of Natural Resources and Forestry (MNRF)

Proponent’s response

The nocturnal amphibian surveys cover an area of 250 m around each survey station, which Golder felt was sufficient to include enough of the swamp communities to determine the amphibian habitat on the site. Nocturnal access to the swamps was difficult in some cases.

Considering all natural features and functions present in the study area, the only potential SWH identified on the site is an area of potentially suitable woodland amphibian breeding habitat in the southeastern corner of the site and an area in the southwestern corner of the site. Based on our assessment of habitat in the local area, the habitat on the site is not the largest concentration or the most representative of woodland amphibian breeding habitat in the region. In addition, the outcome of the effects assessment concluded that the regional population of amphibians will not be adversely affected by removal of this habitat. During construction, appropriate mitigation measures will be implemented to protect individuals, including, but not limited to, restricting disturbance during the breeding season.

Although the wildlife staging area is identified on Land Information Ontario (LIO) mapping, it is a circle that encompasses a large area that includes Highway 417 and the golf course north of Highway 417, neither of which could be considered a wildlife (waterfowl) staging area. The MNRF also confirmed that the staging area was identified at a desktop level using NTS (National Topographic System) mapping and then transferred into NRVIS (Natural Resources and Values Information System) mapping at some point in the 1990s. These data were never field verified. Through the field assessment, surveys were conducted on the site at the appropriate times to observe a waterfowl staging area, if it was present. In addition, based on the draft Significant Wildlife Habitat Ecoregion Criteria for Ecoregion 6E (MNR 2012), agricultural fields with waste grains are commonly used by waterfowl, but would not be considered SWH, which is the case at CRRRC. In any event, a wildlife staging feature was not identified on the site and it was determined that no further analysis was warranted. No other SWH were identified on the site using the Draft SWH criteria.

A botanical inventory was completed on the entire site over multiple seasons in 2012 and 2013. Although swamp habitats were identified on the site, there were no vernal pools identified, and the soil conditions are not suitable for vernal pools. The swamp communities are primarily dominated by thickets and immature trees, and black ash is a rare component. It was determined through the habitat assessment on the site that there is no suitable habitat for flooded jellyskin. Furthermore, flooded jellyskin was not identified during any of the botanical inventories, nor was it identified by MNRF in the letter dated June 20, 2013. We also note that, as of March 31, 2015, flooded jellyskin is no longer listed under the Endangered Species Act.

Status

The ministry is satisfied that adequate surveys were completed and mitigation measures will be implemented to protect wildlife, if required.

Comment #139

At this time, the MNRF does not require that additional surveys be carried out; however the MNRF would like to be provided with additional detailed information related to survey techniques, rationale for survey methodologies employed, and additional information and rationale to support the determination of presence/absence of species at risk and their habitat on the site. As well as additional more detailed mitigation measures are developed to MNRF's satisfaction.

Reviewer

Ministry of Natural Resources and Forestry (MNRF)

Proponent’s response

Acknowledged. Appropriate mitigation measures such as a worker awareness program for Species at Risk (SAR), which will include identification of SAR, daily sweeps and steps to take if one is encountered, will be implemented. This program will include specifics for all SAR that may reasonably be found in the area of the site. Specific details of the program will be discussed with the MNRF prior to construction.

Status

The ministry is satisfied that the proponent will consult with MNRF on mitigation measures to protect wildlife prior to construction.

Comment #140

The Natural Heritage Reference Manual (MNRF, 2010) identifies adjacent lands to natural heritage features or areas as 120 meters. While this may not encompass all large range wildlife species, 500 meters as selected by the proponent encompasses larger area sensitive receptor adjacency as identified by MOECC’s D-Series Guidelines.

Reviewer

Ministry of Natural Resources and Forestry (MNRF), December 10, 2015. Follow-up comments based on the review of public comments and responses.

Proponent’s response

N/A

Status

The ministry is satisfied with the study area selected and described in the EA.

Comment #141

The Natural Heritage Reference Manual and the Significant Wildlife Habitat Technical Guide (MNRF 2000) do not speak specifically to survey methodology specific to “…fungi, lichens, bryophytes, terrestrial mollusca etc…”. The MNRF notes that there are some species such as Flooded Jelly Skin, which (at the time of MNRF’s previous comments) were identified as Threatened under the Endangered Species Act, however as per the consultants surveys, no such species were identified.

Reviewer

Ministry of Natural Resources and Forestry (MNRF), December 10, 2015. Follow-up comments based on the review of public comments and responses.

Proponent’s response

N/A

Status

The ministry is satisfied that adequate surveys were completed and mitigation measures will be implemented to protect wildlife, if required.

Comment #142

The MNRF would like to take this opportunity to identify Chorus Frog as a species protected under the federal Species at Risk Act. If, as per the objector’s comments, there are known Chorus Frogs observed in the area, this should be addressed appropriately per Federal legislation and requirements.

The Significant Wildlife Habitat Technical Guide (SWHTG) notes general timing windows for amphibian surveys; specifically “…warm spring evenings in April are good times to listen for calling frogs to determine their relative abundance. For later-calling species such as green frog and bullfrog, late May and early June is more optimum timing.” (SWHTG, page 47). Furthermore, the SWHTG notes that Canadian Wildlife Service has amphibian-monitoring programs as well as Bird Studies Canada has marsh-monitoring protocols. Such protocols should have been identified and followed, as per the ToR.

Reviewer

Ministry of Natural Resources and Forestry (MNRF), December 10, 2015. Follow-up comments based on the review of public comments and responses.

Proponent’s response

Calling amphibians (frog and toads) were surveyed, as part of this project, using the standard Marsh Monitoring protocols (Konze and McLaren 1997; MMP 2008). The surveys were conducted on April 21, May 22, and June 20, 2013, which are the appropriate times to detect frogs and toads in Ontario. The April 21, 2013 date, in particular, is appropriate timing to detect western chorus frog.

If during project activities or operations, western chorus frog is observed on the site, it will be addressed per federal legislation and requirements. This will be added to the CRRRC EA commitment table.

Status

The ministry is satisfied with the response and that the proponent’s EA commitments table was updated to reflect this commitment.

Comment #143

Snapping Turtles are protected under the Fish and Wildlife Conservation Act (FWCA), throughout the project development the proponent must ensure compliance with the Act.

The SWHTG provides some general direction with respect to surveying specifically for Turtle Nesting habitat (SWHTG pg. 47, S. 5.4.2.6). Furthermore, MNRF has specific survey protocols for nesting basking surveys for other species of turtle, that are identified as endangered and threatened as per the Endangered Species Act. Visual Encounter Surveys were carried out as were other methodologically approved surveys, and MNRF agreed that no suitable habitat was identified on site for turtles and as such no surveys to this effect were carried out.

Reviewer

Ministry of Natural Resources and Forestry (MNRF), December 10, 2015. Follow-up comments based on the review of public comments and responses.

Proponent’s response

The mitigation measures described in the EA include the use of exclusion fencing to prevent turtles from entering work areas. A revision to the CRRRC EA commitment table will be made to reference the Fish and Wildlife Conservation Act if snapping turtles are encountered.

Status

The ministry is satisfied with the response and that the proponent’s EA commitments table was updated to reflect this commitment.

Comment #144

It appears that collection was carried out in accordance with standard protocols.

Reviewer

Ministry of Natural Resources and Forestry (MNRF), December 10, 2015. Follow-up comments based on the review of public comments and responses.

Proponent’s response

N/A

Status

The ministry is satisfied with the response and that the proponent’s EA commitments table was updated to reflect this commitment.

Comment #145

The MNRF would like to note that the new Ontario Invasive Species Act (2015) has recently received Royal Assent, and as such, invasive species should be considered in light of this new Act.

Reviewer

Ministry of Natural Resources and Forestry (MNRF), December 10, 2015. Follow-up comments based on the review of public comments and responses.

Proponent’s response

Although the Invasive Species Act was not in place at the time of writing the EA, with the implementation of the mitigation measures recommended in the EA, the project will be in compliance with this Act. This will be specified in the revised CRRRC EA commitments table.

Status

The ministry is satisfied with the response and that the proponent’s EA commitments table was updated to reflect this commitment.

Comment #146

The proponent’s response: “Fish may need to be relocated again, should flooding occur on the site.” This potentially raises concerns should the proponent be conducting isolated work within the In-Water Work Timing Restriction period (i.e. March 15 – June 30). Should any fish enter the isolated work location during flooding events, during the timing restriction period the timing restrictions would immediately apply to the entire flooded work site. Furthermore, as it relates to DD3, the salvage and relocation of fish will require a more detailed proposal, with special considerations given to the prevention of potential fish pathogens (i.e. testing) or the suitability of receiving waterbody (i.e. isolated).

The MNRF is willing to work with the proponent to discuss these matters and a more detailed proposal in due course.

Reviewer

Ministry of Natural Resources and Forestry (MNRF), December 10, 2015. Follow-up comments based on the review of public comments and responses.

Proponent’s response

A scientific collection permit, prior to the fish salvage, will be obtained from the MNRF. Any requirements in the permit application will be addressed at that time. This will be added to the revised CRRRC EA commitments table.

Status

The ministry is satisfied with the response and that the proponent’s EA commitments table was updated to reflect this commitment.

Comment #147

I recommend removing the following statement: "…and are therefore not eligible for designation under the Ontario Heritage Act." wherever it occurs in the documents.

Reviewer

Ministry of Tourism, Culture and Sport (MTCS)

Proponent’s response

We acknowledge that wherever the statement “…and are therefore not eligible for designation under the Ontario Heritage Act.” is located, it can be considered removed. Should this EA receive approval, the heritage report will need to be re-submitted in support of City of Ottawa approvals and this wording will be removed from the report at that time.

Status

The ministry is satisfied with this response.

Comment #148

The following documentation is being submitted for your assessment and consideration in view of the impending decision pertaining to the approval or rejection of the proposed ToR:

  1. Appendix “A”; certified true copy of Council resolution 263-2012 dated October 29, 2012
  2. Appendix “B”; certified true copy of Council resolution 2015-64 dated February 17, 2015
  3. Appendix “C”; copy of the letter sent by the Office of the Mayor dated October 31, 2012
  4. Appendix “D”; copy of excerpt from the technical review comments submitted by XCG Consultants on behalf of the Township of Russell in October 2012 indicating that our comments reflected both the original North Russell Road location and the current Boundary road location.
  5. And finally, Appendix “E”, report from XCG Consulting, a nonpartisan firm whose mandate was to provide our EAC subcommittee and Council with an independent assessment of the CRRRC ToR back in 2012.
Reviewer

Municipalitié de Russell Township

Proponent’s response

The Terms of Reference on the proposed CRRRC were approved by the Minister of the Environment on December 17, 2012. The document package submitted on January 2, 2015 was the Final EA of the proposed CRRRC.

With respect to Appendices A, C, D and E, these submissions were already commented on in full during the MOECC’s review of the ToR in the fall of 2012. The comments from Appendices A, C, D and E have not be reduplicated in this document however a summary of the responses to issues within these documents is provided below:

Requests were made for clarification on details regarding the ToR related to the surface water, agriculture and groundwater work plans. In the response Taggart Miller provided guidance on where to find information in the ToR for groundwater, surface water and agriculture.

Modifications to the biology work plan were suggested. The response by Taggart Miller was that generally the modifications were either already included in the study or a rationale why that study method or species was not included was provided. In some instances agency pre-consultation was suggested as a rationale of whether to include a species or not. It was acknowledged that if the project was to proceed an effective monitoring program will be required.

Methods and requirements for consultation were recommended. Taggart Miller responded that the recommendations were already included in the ToR and the Township was referred to the appropriate parts of the ToR where consultation plans were outlined.

The Township suggested the archeological and built heritage work plans be reworded to use terminology more in line with the PPS. This was not deemed necessary in the ToR but if a Heritage Impact Statement was to be completed it would use terminology from the PPS and follow provincial requirements. Taggart Miller also indicated in their response a Heritage Resource Assessment is not required unless the screening checklist indicates the potential is present.

The traffic work plan as presented in the ToR generated a Traffic Impact Study. The haul routes described in the ToR were determined from Taggart Miller’s expected origin of the waste and the shortest and most convenient route to the facility. As per the request from the Township the nature of potential receptors along the main haul routes was considered in comparing the two potential sites. As described in the Atmospheric work plan in Appendix C of the ToR, the potential impacts from the preferred haul route were also evaluated to ensure there were no material constraints to its use as a haul route. In general Taggart Miller provided guidance on where to find information related to traffic in the ToR.

Changes to the socio-economic assessment were suggested. Taggart Miller did not include the changes considering the following rationale. Measurable changes to population, if any, are not expected to result from the project, and therefore ‘population’ was excluded from the evaluation. Accordingly, potential effects related to population change on access to and capacity of services and infrastructure were also not included. Effects on residents and communities would be associated with effects due to air quality, noise, water quality, biology, land use, economics and visual aesthetics, which were all considered in the EA.

The Township suggested that a human health risk assessment (HHRA) was required. Taggart Miller does not agree with the need for a HHRA, for which as the Township noted there is no legal requirement. The standards against which the expected performance of the proposed CRRRC were assessed and against which the results of operational monitoring were subsequently compared, are designed to be protective of human health and the environment. The premise for a HHRA is that the regulatory standards are inadequate, which we do not believe has been demonstrated.

The Township thought that the ToR should be translated. Taggart Miller indicated that an Executive Summary of the Terms of Reference was posted in French on the project website. It provides a good overview of the ToR. All background information in the project website is in both languages. The open house materials were all in both French and English. The Taggart Miller project manager remains available to answer questions in French or English. Taggart Miller made a commitment to translate the main EA document to French when the ToR is approved.

Status

The ministry is satisfied with this response.

Comment #149

Boundary Road location is not within our municipal boundaries, it is located at the very entrance of our Municipality. Council feels its proximity to our municipal borders raises serious concerns in regards to the following three items.

  • Groundwater pollutants
  • Air pollutants
  • Traffic congestion at the 417 Boundary Rd. exit (a major artery into our Municipality)
Reviewer

Municipalitié de Russell Township

Proponent’s response

The potential impacts from the proposed CRRRC related to groundwater, air and traffic have been carefully considered and described in the EA document package in Sections 1.3, 11.2 and 11.9 of Volume I, respectively.

Status

The ministry is satisfied that potential effects to groundwater, air and traffic are assessed in the CRRRC EA and supplemental documentation.

Comment #150

The existing watercourses appear to be acting as headwater drainage features. As this proposal moves forward, an assessment will need to be completed on these features using the “Evaluation, Classification and Management of Headwater Drainage Features Guideline. Toronto and Region Conservation Authority (TRCA) and Credit Valley Conservation (CVC), TRCA Approval July 2013 (Finalized January 2014)”. If such evaluation is deemed unnecessary, a rationale should be provided.

Reviewer

South Nation Conservation (SNC)

Proponent’s response

This will be discussed further with SNC in future as part of subsequent approvals/permits for the proposed project.

Status

The ministry is satisfied that the proponent will continue to consult with SNC for subsequent permits/approvals.

Comment #151

Additional fish sampling should be done in spring. This would be consistent with the above Guideline.

Reviewer

South Nation Conservation (SNC)

Proponent’s response

Acknowledged.

Status

The ministry is satisfied that the proponent will continue to consult with SNC for subsequent permits/approvals.

Comment #152

The potential impacts due to the changes in surface water regime should be evaluated and properly documented.

Reviewer

South Nation Conservation (SNC)

Proponent’s response

The stormwater ponds will be designed such that the surface water leaving the site will be controlled and the hydrologic regime post-construction will meet the pre-construction conditions, through the design of the hydraulic outlet controls for post-development flow to meet peak flow conditions for the 1 in 2, 5, 25 and 100 year design storms. As described in the surface water assessment, it is anticipated that because under existing conditions the site is prone to flooding and the groundwater levels areclose to the surface, by meeting the pre- and post-construction peak flows in DD1 and DD2, the post-development base flow will be similar to pre-development conditions. In addition, a surface water monitoring program (quality and quantity) will be implemented to confirm predictions regarding the surface water regime post-development, and to make adjustments to the operation of the stormwater control system, as necessary. As such, it was determined that there will be no material effects to downstream aquatic habitat as a result of the project. Additional information on the proposed surface water monitoring program will be shared with SNC at the permitting stage.

Status

The ministry is satisfied that the proponent will implement a surface water monitoring plan.

Comment #153

The volume per unit area used in the Report appears to be lower than what is required. For example, a wet pond treating 80% Total Suspended Solid removal with an area of 70% imperviousness requires 225 m3/ha (MOE Stormwater Design Guidelines, 2003); however, the report uses 185 m3/ha. This should be clarified or revised as required.

Reviewer

South Nation Conservation (SNC)

Proponent’s response

Table 9 of the report summarizes that the proposed ponds exceed the required permanent pool volumes for each pond, not the total storage volume. As per Table 9, Note 1, an additional 40 m3/ha is provided as extended detention during an event. As the SNC has noted, the requirement per the MOECC based on 70% imperviousness for ponds 5a and 5b is 225 m3/ha; this has been provided as 185 m3/ha permanent pool and 40 m3/ha extended detention volume. This is consistent with Section 3.3.2 of the MOECC Stormwater Design Guidelines, 2003. Note 2 for Table 9 of the EA provides the % imperviousness assumed for each of the other ponds.

A separate signed and stamped grading plan will be required at the permitting stage, prior to construction.

Status

The ministry is satisfied that the proponent will submit a grading plan prior to construction.

Comment #154

The Report states that there is a leachate collection system. How will surface spills/leachate be intercepted before reaching the stormwater management (SWM) ponds and ultimately being released to the municipal drains?

Reviewer

South Nation Conservation (SNC)

Proponent’s response

The leachate collection system is a drainage system located underneath the landfill component of the CRRRC. The leachate collected in the leachate collection system will be directed to the on-site leachate pre-treatment facility via a forcemain. Leachate spills are therefore quite improbable. Stormwater ponds in the vicinity of the landfill will not become impacted by landfill leachate. The landfill is to be surrounded, above ground, by a perimeter berm which is 36 metres wide at the top. The base of the landfill is situated primarily on or within native silty clay, or on a thin remaining layer of surficial silty sand underlain by native silty clay. In addition, a geosynthetic clay liner (GCL) hydraulic barrier is proposed for the sideslope liner system to prevent leachate from entering the surficial silty sand/weathered crust zone or overlying perimeter berm fill; a leachate detection and secondary collection system is also proposed along the east side. The combination of these natural features and the engineered containment features associated with the landfill located between the landfill and the two nearby stormwater ponds will protect the two nearby ponds from potential leachate effects.

In addition to leachate from the landfill, there will be liquor generated from organics processing. The liquor will be contained within lined engineered cells, and liquor not re-used in the process stored in a secure tank. Liquor spills are therefore quite improbable.

With respect to accidental spills, the EA discusses in Section 11.10, Volume I a best management practice whereby operation, storage and maintenance of equipment and associated materials should occur in areas away from surface water features to minimize the potential for the entry of any deleterious substance into a water body. The site will not deal with liquid or hazardous wastes and, therefore, any accidental spill will likely be related to fuel or oil from equipment. Section 15.0 of Volume I of the EA makes a commitment to develop a site-specific Spill Response Plan to further outline actions to prevent, contain and mitigate spills should they occur.

Status

The ministry is satisfied the landfill design will meet ministry guidelines. The ministry is satisfied that the proponent will submit a Spill Response Plan.

Comment #155

A Sediment and Erosion Control Plan should be provided. The plan will:

  1. Identify who is responsible to install inspect, maintain and remove the control measures
  2. Identify the inspection and maintenance record (how, when, how often i.e. daily/weekly)
  3. Indicate which control measures are proposed, their location and corresponding number
  4. Indicate that it is to be considered a “Living Document” which may be modified in the event the control measures are insufficient.

It is understood that the plan will be provided at the site Plan control stage and/or during the application for a Conservation Authority permit. However, SNC still recommends that a plan be provided as part of the EA package.

Reviewer

South Nation Conservation (SNC)

Proponent’s response

A separate signed and stamped Erosion and Sediment Control Plan will be required at the permitting stage, prior to construction. Section 6.0 of Appendix A, Volume IV outlines the suggested frequency of inspections and items to be observed during the inspections. Taggart Miller feel that this is sufficient for EA level approval. Typical best management practices would not only include engineering controls such as silt fences and check dams but strategies for re-vegetation and minimizing disturbance. The actual plan will be dependent on phasing of construction and site activities, which are still to be confirmed. Without these details a plan would be very generic. A commitment to prepare a Sediment and Erosion Control Plan has been provided in Section 15.0 of Volume I of the EA.

Status

The ministry is satisfied that the proponent will complete and submit a Sediment Control Plan.

Comment #156

Section 8.2: Residential Well Program (Dug Wells): The Report states that “Most residents/businesses in the vicinity of the site use shallow dug wells to provide their water supply.” Section 8.2 identifies two residential dug wells and one commercial dug well along Frontier Road and Boundary Road. Appendix M identifies six dug wells on or nearby the site.

Section 8.2 should be rectified with Appendix M to identify the extent of the dug well assessment. In addition, the Report should provide a map showing the location of all private wells in operation on or near the site. Note that the MOECC database may not include the location of all wells near the site (although required by Ontario Regulation 903, under the Ontario Water Resources Act); a visual survey of the surrounding properties could be completed, with the assumption that each residence/business requires a water supply.

Comment on the potential impact to all dug wells near the site, taking into account groundwater flow direction, (likely) depth of wells, and other hydrogeological considerations.

Reviewer

South Nation Conservation (SNC)

Proponent’s response

Section 8.2 of the report identifies the three dug wells that were selected for inclusion in the residential well sampling program (Frontier-1, Frontier-2 and Boundary-1). Appendix M identifies the six dug wells that are on, or are in the immediate vicinity of the site potentially available for assessing the hydraulic properties of dug wells (Frontier-1 through Frontier-3 and Boundary-1 through Boundary-3). The dug wells discussed in Section 8.2 included in the residential well sampling program are a sub-set of the available dug wells on, or in the immediate vicinity of the site. It should be noted that the term ‘assessment’ in regards to the Dug Well Assessment presented in Appendix M refers to an assessment of hydraulic properties.

Figure 3-5 in Volume III shows the location of water supply wells included in the MOECC Water Well Information System (WWIS) database in the vicinity of the site. The WWIS database does not include dug wells. Once the on-site dug wells have been decommissioned, there will be no dug wells located in the vicinity of the site, except within the industrial park and sparse residential development along Boundary Road. It is agreed that most of these businesses/residences would likely have a dug well. Figure 8.4.1-1 in Volume I shows the location of residences in the vicinity of the site (identified as ‘Point of Reception Locations’). The locations of the properties in the industrial park can also be seen on the air photo underlying Figure 8.4.1-1. Some of the locations in the industrial park are not expected to have dug wells (i.e., some locations are just used for soil storage, or have just a trailer on the property).

The dug wells in the vicinity of the site obtain water from the surficial silty sand, with minor contribution from the weathered clay zone. The groundwater flow direction in these units is towards the east (see Figure 7-1 in Volume III). The dug wells that are currently located on the east side of the site (Frontier-1 through Frontier-3) will be decommissioned prior to start of operations at the site (dug wells Boundary-2 and Boundary-3 will also be decommissioned). There are no dug wells located further to the east of the site. The next potential well location is over 2.5 kilometres east of the site, and based on the geology in that area, the well at that location would not likely be a dug well. As such, potential contamination of existing dug wells is not anticipated or predicted. In addition, an extensive proactive groundwater monitoring program has been proposed to identify any contaminants that may be migrating in the groundwater prior to reaching the site boundary. If issues are identified, they would be addressed well before off-site impacts occur.

As indicated in the dug well pump test assessment in Appendix M, the dug wells are interpreted to be recharged locally (i.e., within 10 to 20 metres around the well). The results of the 3D numerical groundwater flow model used for the CRRRC site (Section 12 of Volume III) show that reduction in groundwater levels at the site are primarily contained to the landfill footprint. The closest dug well located within the vicinity of the site is located on the west side of Boundary Road across from the southwestern corner of the site (approximately 135 metres from the edge of the landfill footprint). As such, the construction of the CRRRC will not have an impact on the available water quantity for dug wells.

Status

The ministry is satisfied that a groundwater monitoring plan will be implemented to ensure the protection of groundwater.

Comment #157

Section 8.2 and Appendix M identify several wells located on the proposed site; comment on the fate of those wells (i.e. continued use as water supply wells, monitoring wells, decommission, etc.)

Reviewer

South Nation Conservation (SNC)

Proponent’s response

All on-site dug wells (Frontier-1 through Frontier-3, Boundary-2 and Boundary-3) will be decommissioned.

Status

The ministry is satisfied with the response.

Comment #158

Appendix M, Technical Memorandum – Dug Well Assessment: The Report states that six dug wells on or near the site were identified as potential locations for the dug well assessment. Well depths ranged from 3.6 to 5.9 m (identified in Appendix M), or 3.7 to 6.1 m (identified in Section 8.2). Two wells (Boundary-2 and Frontier-1) were selected for the assessment; which are the shallowest wells (3.6 and 3.7 m respectively) and do not extend to the silt layer. What was the rationale for the selection of dug wells for the assessment?

Reviewer

South Nation Conservation (SNC)

Proponent’s response

There are two components of the dug well assessment: groundwater level monitoring of typical dug well use, and groundwater level monitoring during a dug well pumping test. The pumping test component of the dug well assessment required that the dug well not be in-service at the time of the testing (i.e., to allow the installation of a pump and subsequent constant rate testing). All dug wells on, or in the immediate vicinity of the site were in service at the time the dug well assessment was undertaken, except for Boundary-2. As such, Boundary-2 was the only option available for the pumping test portion of the dug well assessment.

The typical use component of the dug well assessment required that the dug well be in-service. The dug well options available for this portion of the assessment included Frontier-1 through Frontier-3, Boundary-1 and Boundary-3. The location of Frontier-2 was unknown by the home owner, so this location was eliminated. Meetings were held with the home owner at Boundary-3, but permission was not granted for drilling observation wells in the vicinity of their dug well. Discussions were held with the business owner at Boundary-1 and the tenants at Frontier-3, and permission was not granted for completing the dug well assessment. As such, the only remaining option was Frontier-1, where permission was granted for the proposed assessment.

Status

The ministry is satisfied with the response.

Comment #159

Comment on the how the dug well assessment is expected to relate to dug wells that extend deeper into the silt layer. (i.e. is there preferential flow within the silt layer, what is the expected zone of influence?)

Reviewer

South Nation Conservation (SNC)

Proponent’s response

Based on the results of the groundwater flow modelling completed for the site, it was determined that the silty layer does not convey a significant amount of water due to its relatively low hydraulic conductivity (geometric mean of 8x10-7 m/sec), and because it is a relatively thin layer (i.e., less than 0.6 metres thick). Dug wells that are completed deeper and intersect the silty layer would have additional storage because of the increase of depth, but the formation supplying the water to the well would still be the surficial silty sand (with minor contribution from the weathered clay). As such, the radius of influence for the wells completed into the silty layer would be expected to be consistent with those observed during the completed dug well assessment.

Status

The ministry is satisfied with the response.

Comment #160

The Report notes that the upper clay zone is weathered (up to 1.3 m, Section 6.3); was weathered clay identified at the two sites studied as part of the dug well assessment? Comment on the expected impact to wells within a more extensive weathered clay zone than the two sites studied.

Reviewer

South Nation Conservation (SNC)

Proponent’s response

Weathered clay is interpreted to be present at both dug well locations included in the dug well assessment. Weathered clay was not identified in the two monitoring wells installed adjacent to Frontier-1 because the monitoring wells are installed within the area excavated for the dug well. Weathered clay was identified in most boreholes completed at the CRRRC site, and varied in thickness between 0.1 and 1.3 metres. The thickness of the weathered clay would be expected to fall within this range at the Frontier-1 dug well location. The thickness of the weathered clay in the vicinity of Boundary-2 is approximately 0.66 metres (BH13-5).

As indicated in Section 12.1.2 of Volume III, the thickness of the weathered clay unit was found to be inversely proportional to the thickness of the overlying surficial sand unit. It is expected that a dug well completed in an area with a more extensive weathered clay zone would have less surficial sand contributing water to the well. As a result, it would be expected that the sustainable pumping rate would be lower, and the well would be more likely to go dry during dry years or during periods of heavy pumping.

Status

The ministry is satisfied with the response.

Comment #161

Appendix M identifies a local radius of influence (10 to 20 m) based on water level monitoring at Frontier-1 and the pump test at Boundary-2. Comment on groundwater flow and the approximate capture zone for the wells proximal to the site (i.e. although the radius of influence may be local for the shallow dug wells, the capture zone will extend beyond the radius of influence due to natural groundwater flow).

Reviewer

South Nation Conservation (SNC)

Proponent’s response

As discussed in Section 7.2 of Volume III, the gradient for groundwater flow is very low in all formations present at the site. In the surficial silty sand layer, which is the primary source of water for dug wells in the area, the average horizontal gradient is 0.0008 (measured between borehole locations 13-18-2 and 13-17-2). Using the measured gradient, the measured range in hydraulic conductivity and a reasonable estimate of porosity, the range of average linear groundwater velocity in the surficial silty sand is estimated to be between <0.01 metres per year and 1.8 metres per year. Given the low gradient and low groundwater velocity, it would be expected that the capture zone for the dug well would be nearly circular (i.e., there would be limited extension of the capture zone in the direction groundwater flow is from), and would not differ significantly from the radius of influence observed during the dug well assessment. The majority of water captured by the dug well comes from recharge to the surficial silty sand in close proximity to the well (i.e., within 10 to 20 metres).

Status

The ministry is satisfied with the response.

Comment #162

The dug well assessment was conducted in November 2013 which was an “average year” for precipitation. Comment on the potential extent of the radius of influence and capture zones for the dug wells in a wet or dry year.

Reviewer

South Nation Conservation (SNC)

Proponent’s response

During a drier year, we would expect the water level in the surficial silty sand (primary source of water for the dug well) to be lower. As the well is operated within a thinner contributing aquifer (i.e., decreased saturated thickness of silty sand), the radius of influence may increase slightly to try to supply the water demand. Because the surficial sand is only found in the upper 2 to 3 metres or less of the well (range in surficial silty sand found in the boreholes at the site was 0 metres to 2.7 metres), the extent of the radius of influence is limited by the gradient that can be induced at the well head within the surficial silty sand. As a result of this limit, the well may go dry during extended operation during dry conditions. It is not uncommon for dug wells to go dry during dry years if the rate of water taking is not reduced. As discussed above, because of the low horizontal gradients at the site, the capture zone would be similar to the radius of influence for the well. The overall capture zone for a dug well would approximately equal to the worst-case radius of influence that can be induced by drawing the water level down to the base of the surficial silty sand. During dry years, the radius of influence would approach this capture zone extent (i.e., likely closer to the 20-metre extent estimated during the dug well assessment).

During a wetter year, the saturated thickness of the surficial silty sand would increase, and the radius of influence around the well would decrease. As such, during wetter years, the area supplying water to the well would be somewhere inside the worst-case capture zone (i.e., likely closer to the 10-metre extent estimated during the dug well assessment).

Status

The ministry is satisfied with the response.

Comment #163

The original Environmental Assessment document discussed the proposed access to the Capital Region Resource Recovery Centre. In that discussion details were provided related to the improvements required to accommodate trucks entering the site. The consultant recommended that a southbound left turn lane be constructed that included 50 metres of storage, 60 metres parallel and a 145 metre taper. Since the first report did not include information on the Thunder Road / Subdivision Access intersection, there was no comment on whether such improvements could be accommodated on Boundary Road.

Reviewer

Ministry of Transportation (MTO)

Proponent’s response

As per telephone conversations with the MTO on March 25, 2015 and a letter provided March 26, 2015 (Traffic Addendum 1), improvements on Boundary Road related to the CRRRC project can be readily accommodated, taking into account improvements required for the East Gateway project proposal. Addendum 1 is available on the project website.

The proposed site access onto Boundary Road would be located approximately 600 m south of the Thunder Road intersection and approximately 700 m north of the Mitch Owens Road intersection. The traffic assessment in the EA document recommended a southbound Boundary Road left turn lane into the site for a posted speed limit of 80 km/h and a design speed of 90 km/h To assume the worst case, we examined the lane configuration for a 100 km/h design speed. The southbound left turn lane would comprise the following configuration:

  • 60 m vehicular storage
  • 70 m parallel lane
  • 160 m taper
  • 290 m total lane length

If we are to assume that the Thunder/Boundary intersection will in the future be controlled by traffic signals with a northbound left turn lane to accommodate the East Gateway project proposal, the northbound Boundary Road left turn lane onto Thunder Road would have the following lane configuration for a 100 km/h design speed:

  • 40 m vehicular storage (City’s minimum length for a signalized intersection)
  • 70 m parallel lane
  • 160 m taper
  • 270 m total lane length

Both the CRRRC southbound left turn lane into the access and northbound left turn lane onto Thunder Road would total 560 m and can be accommodated in back-to-back left turn lanes into the approximately 600 m (centerline-to-centreline) separation between the CRRRC site access and Thunder Road.

The Petro-Canada service station at the southwest corner of Boundary Road and Thunder Road has an access directly onto both Thunder Road and Boundary Road. The Boundary Road access is located approximately 55 m south of Thunder Road (centerline-to-centreline). Northbound left turning vehicles into the Petro-Canada site can be accommodated in the 110 m portion of the storage plus parallel lane at the proposed northbound approach to the Thunder/Boundary intersection. The CRRRC site access onto Boundary Road can be accommodated without interfering with the future lane configuration at Thunder Road and the Boundary Road access into the Petro-Canada service centre.

Status

The ministry is satisfied that MTO has reviewed Addendum 1 and is satisfied with the response.

Comment #164

The Traffic Impact Study for the Plan of Subdivision recommends that the intersection of Boundary Road and Thunder Road be signalized due to background traffic growth and development traffic, a Northbound Left turn lane would be required. Furthermore, since there is an existing fuel station on the south west corner of the Thunder Road / Subdivision access, such a northbound left turn lane' s storage, parallel and taper will likely extend far enough south to conflict with the proposed southbound left turn lane for the Capital Region Resource Recovery Centre. We expected that there would be some discussion regarding such improvements. The only discussion provided was a statement saying that in 2022 signals would not be warranted at the Thunder Road / Subdivision access intersection. This determination was made without the benefit of studying the impact of the traffic from the Plan of Subdivision at that location. Likewise, the traffic impact study for the Plan of Subdivision used the 2026 year horizon; which is the correct forecast year required for traffic studies of Ministry facilities, 2022 as provided in the Environmental Assessment is not. As stated in the Ministry of Transportation’s Traffic Impact Study Guidelines -Section 2.16 -Evaluation of lmpacts "…Forecast and analyze traffic for the opening day of the development, 5 year and 10 years beyond the opening date."

Reviewer

Ministry of Transportation (MTO)

Proponent’s response

See responses above. Taggart Miller’s assessment year of 2022 represents an analysis of traffic 5 years from the assumed opening day of the CRRRC development. Addendum 2 to the Traffic Impact Assessment (TSD #9) has been prepared that also includes an assessment of traffic at year 10 (2027). Addendum 2 can be accessed on the project website.

Status

The ministry is satisfied that MTO has reviewed Addenda 1 and 2 and is satisfied with the response.

Comment #165

Since there will likely be conflicts with the improvements on Boundary Road between the left turn lanes for the Thunder Road intersection and the site access, we recommend that the access for trucks entering and exiting the site be relocated to either Devine Road or Frontier Road.

Reviewer

Ministry of Transportation (MTO)

Proponent’s response

See response above. There is no conflict with the improvements on Boundary Road between the left turn lanes for the Thunder Road intersection and the CRRRC site access location, and hence no requirement to consider moving the site access location.

Status

The ministry is satisfied that MTO has reviewed Addenda 1 and 2 and is satisfied with the response.

Comment #166

The Environmental Assessment makes no recommendations with respect to improvements required at the Eastbound (South Side) ramp terminal to address the traffic, and traffic signal warrant calculations have not been provided. Notwithstanding the assumption that traffic generated by this site will only account for 5% of the total intersection traffic, the absence of recommendations to address the total traffic is not acceptable. We recognize that the Capital Region Resource Recovery Centre will apply a small percentage of new traffic to Boundary Road. However, that entire percentage is made up completely of trucks. Trucks by nature take up more space on the roadway, accelerate and decelerate slower and therefore can reduce the carrying capacity of a roadway more so than a car.

Reviewer

Ministry of Transportation (MTO)

Proponent’s response

An assessment of the Eastbound (South Side) ramp terminal has been provided in Addendum 2 to the Traffic Impact Assessment and recommendations are provided. Addendum 2 can be accessed on the project website.

Status

The ministry is satisfied that MTO has reviewed Addenda 1 and 2 and is satisfied with the response.

Comment #167

With respect to the traffic analysis provided in the report, we have serious concerns with Exhibit 14 and 15. The truck percentage fields are exceptionally low considering the land uses and what is being proposed. If we zero in specifically on the right turn from the Eastbound right turn, in the 2011 morning peak hour (Ministry Turning Movement Count), there are 71 vehicles turning right with a 10% truck volume. Considering that the plan of subdivision consists almost exclusively of land uses intended to serve trucks (see image below of Table 4 from the Plan of Subdivision’s Traffic Impact Study) and further that this operation expects to add 43 truck trips into and out of the facility during the morning and afternoon peak hour, we question how a 5% truck volume on right turning vehicles as shown in Exhibit 14 would be justified.

Reviewer

Ministry of Transportation (MTO)

Proponent’s response

Exhibits 14 and have been updated and are Exhibits 20 and 21 in Addendum 2. Addendum 2 can be accessed on the project website.

Status

The ministry is satisfied that MTO has reviewed Addenda 1 and 2 and is satisfied with the response.

Comment #168

Furthermore, considering that the truck traffic for both developments needs to be applied to much of the movements for both ramp terminal intersections as well as the Thunder Road / Subdivision Access, it is disappointing to find that in most cases, the truck percentage has been left blank. We are pleased that the proponent was able to get the truck percentage correct for the site access which is shown in Exhibit 21 as 100%. As stated in the Ministry of Transportation’s Traffic Impact Study Guideline Section 2.10 "…Heavy/Commercial vehicles should be accounted for in the traffic analysis.

Reviewer

Ministry of Transportation (MTO)

Proponent’s response

Addendum 2 to the Traffic Impact Assessment includes truck traffic from both the East Gateway project and the CRRRC.

Status

The ministry is satisfied that MTO has reviewed Addenda 1 and 2 and is satisfied with the response.

Comment #169

The report only details the truck traffic entering into and leaving the site. We feel that it is likely that there will be other employees and maintenance workers also entering and exiting the site.

Reviewer

Ministry of Transportation (MTO)

Proponent’s response

There will be other employees and maintenance workers entering and exiting the site. As stated in Section 6.0 of TSD #9, employees will be required to use the Frontier Road access to the site; maintenance workers will also be requested to use this entrance. As stated in Section 3.1 of TSD #9 and confirmed in Addendum 2, because employees of the facility arrive and depart outside the peak hours of the adjacent roads it was therefore considered appropriate to not assign worker-related traffic using the Frontier Road access in the peak hour traffic analysis.

Status

The ministry is satisfied that MTO has reviewed Addenda 1 and 2 and is satisfied with the response.

Comment #170

Section 14 of the Environmental Assessment deals with monitoring after the opening of the facility. We have concerns that there appears to be no plans to monitor traffic conditions after the opening of the facility.

Reviewer

Ministry of Transportation (MTO)

Proponent’s response

The number of truck trips will be recorded as part of the operation of the facility and the average number of peak hour trucks can be compared to that assumed in the traffic study, and reported annually in the site monitoring report.

Status

The ministry is satisfied that the proponent will make a record of truck trips for the annual monitoring report.

Comment #171

The proximity of the proposed "Secondary Digester Flare Power Generation " may pose a visual distraction to drivers who are not accustomed to seeing a flare near to Highway 417. How will this visual distraction be mitigated?

Reviewer

Ministry of Transportation (MTO)

Proponent’s response

The viewpoint projection from Highway 417 of the flare and power generation units (there is no Secondary Digester Flare) is shown on Figure 11.6.3-2 of Volume I. The proposed berm and tree screen for the flare and power generation will provide an effective screen of the units from Highway 417.

Status

The ministry is satisfied that mitigation measures will be implemented for potential visual effects.

Comment #172

We are in agreement in principal to the methods used for the storm water management component of the Environmental Assessment. However, approval will take place during the site plan control stage of the development.

Reviewer

Ministry of Transportation (MTO)

Proponent’s response

Acknowledged.

Status

The ministry is satisfied that the proponent will get the necessary approvals required for the CRRRC.

Comment #173

Figure 8.4.1-1- all noise monitoring is focused near Hwy 417 or immediately adjacent to the site boundary. This would generate background noise levels significantly higher than residences along Frontier Road and Blackcreek Road - add a noise monitoring location on the quiet side of the landfill near these residents.

Reviewer

City of Ottawa

Proponent’s response

The assessed points of reception (PORs) are within 500 m from the site boundary. Residences to the north along Boundary Road (close to Hwy 417) have been included for the assessment of off-site haul route traffic noise as the primary haul route is along Boundary Road from Hwy 417. Noise monitoring location #3 is on the “quiet side” of the CRRRC and approximately 2 km from Highway 417, and is representative of background noise levels away from Highway 417. At POR03, the predicted noise levels from landfill and ancillary operations comply with MOECC guidelines. The residences along Frontier Road north of Devine Road are owned by Taggart Miller and will be removed. Residences along Frontier Road south of Devine Road, which are further away from the site, would experience lower sound levels and so will comply with MOECC guidelines.

Status

The ministry is satisfied that the proponent shall meet ministry noise guidelines.

Comment #174

According to Table 8, page 10 of Technical Support Document #2 - leachate truck movements will occur 24 hours per day.

Reviewer

City of Ottawa

Proponent’s response

Table 8, page 10 of Technical Support Document #2 is incorrect in that leachate truck movements cannot occur 24 hours per day as the off-site receiver of leachate (ROPEC) is only open between approximately 8 a.m. and 3:30 p.m. Assessing the truck noise in this way is therefore conservative, but it does not reflect what is expected to actually occur.

Status

The ministry is satisfied that the proponent shall meet ministry noise guidelines.

Comment #175

In addition to other volatile organic compounds (VOC), methane should be included in the Air Quality monitoring program.

It is stated that the monitoring program is focused on indicator compounds predicted to occur at other than de minimus levels. That makes sense for other VOC's in landfill gas, however methane is likely a significant percentage, by volume, of the gas and should be included in the Air Quality monitoring program.

Reviewer

City of Ottawa

Proponent’s response

The monitoring program is focused on air quality in relation to the compounds that were predicted in the air quality assessment to occur at other than de minimus levels in relation to their respective MOECC criteria. Unlike a typical landfill, at the proposed CRRRC a significant portion of the organic containing materials will be removed from the waste stream for processing, which will reduce the amount of methane produced from the landfill. In any event, being a colourless, odourless gas, methane dispersed in air is viewed neither as a health concern nor to cause aesthetic issues. If it accumulates in an enclosed space, methane can be an explosion hazard and should be monitored in enclosed spaces to evaluate explosion hazards, which is an operational issue for the site. It is noted that with the proposed layout of components on the CRRRC site, the enclosed spaces, i.e., buildings, are not located in proximity to the landfill component. Further, the MOECC has not requested this monitoring.

Status

The ministry is satisfied that the proponent shall meet ministry air quality guidelines.

Comment #176

The GHG's from leachate tankers hauling to ROPEC are not considered in the emissions summary. This should be included as a site impact. Volume 1 Technical Support Document #3, page 8 - leachate hauling is not included as a specific activity. Leachate tankers will weigh 60 tonnes.

Reviewer

City of Ottawa

Proponent’s response

The leachate tankers emission source were included in the emission summary in Section 11.2.2.2 of Volume I and Section5 of TSD #3.

Status

The ministry is satisfied that the proponent shall meet ministry air quality guidelines.

Comment #177

Odour modelling results should be depicted in a contour drawing in odour units on an aerial photo of the affected area.

Reviewer

City of Ottawa

Proponent’s response

The odour assessment indicated that provincial standards would be met at the nearest off-site receptor, therefore modelled odour concentrations further off-site were not required. The MOECC has not requested such a contour drawing.

Status

The ministry is satisfied that the proponent shall meet ministry air quality guidelines.

Comment #178

Technical Support Document #10 Table 5.1- Atmosphere - Air Quality - ranks off-site wastewater treatment first. Does this ranking consider the GHG's generated by hauling 230,000 m3 of leachate per year? This is equivalent to 287,500 km of leachate being hauled by tanker (50 km round trip multiplied by 5,750 tanker loads per year). It is difficult to imagine how the GHG generated by trucking this distance does not offset the gases generated by the pre-treatment system. Please explain how this ranking was achieved.

Reviewer

City of Ottawa

Proponent’s response

In the evaluation of leachate treatment alternatives, the approved ToR included criteria and indicators for both air quality and leachate haulage. Leachate truck traffic was captured under the leachate haulage criterion: off-site treatment ranked less favourably than on-site treatment for this criterion. Considering GHG from leachate trucks within the air quality criteria would be double counting the effect of leachate haulage already captured under the leachate haulage criterion.

Status

The ministry is satisfied that the evaluation of alternative methods was completed in accordance with the approved ToR.

Comment #179

In subsection 2.4, reference is made to performing a laboratory oedometer consolidation test on soil samples to determine consolidation characteristics of the soils. Please indicate what test methodology was followed in performing this test. This is clarified in Volume II on Pages 941-942. However, this information should be incorporated into the body of the report for clarification.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. This comment was responded to in the draft EA comment table within Volume II.

Status

The ministry is satisfied with the response.

Comment #180

Subsection 2.7.2 discusses using Slug Testing to determine hydraulic conductivity based on Bouwer and Rice Method. Please discuss any methods used to correct for the high percentage of clay in the soil profile. This is clarified in Volume II on Pages 941-942. However, this information should be incorporated into the body of the report for clarification.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. This comment was responded to in the draft EA comment table within Volume II.

Status

The ministry is satisfied with the response.

Comment #181

The map information in Figure 9.1, as discussed is subsection 9.3, should be extended to the south to include the proposed site in the map. This is clarified in Volume II on Pages 941-942. However, this information should be incorporated into the body of the report for clarification.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. This comment was responded to in the draft EA comment table within Volume II.

Status

The ministry is satisfied with the response.

Comment #182

When the report (Volume III Geology, Hydrogeology & Geotechnical Report", report number 12-1125-0045/4500/volume III, by Golder Associates, dated December 2014) is finalized and submitted for site Plan Approval, it must be signed and sealed by the engineer of record. The report is signed but not sealed by the engineer of record. Professional Engineers Ontario (PEO) requires Seal of Engineering based reports. Please provide appropriate sealing and signing of the report per PEO Guidelines.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. As the final EA package of documents is meant to support the EA and are not for any construction or technical approvals, they were intentionally not stamped. Documents submitted for site Plan Approval to the City of Ottawa will be signed and sealed as appropriate.

Status

The ministry is satisfied with the response.

Comment #183

In its current form, the report can be received as a preliminary investigation of the subject site. The primary three concerns are as follows:

  1. The field investigation and laboratory methodologies are not clearly indicated in the report, as such, there is no accepted frame of reference to consider the findings and index test results provided in the report.
  2. The test pit investigation does not substantively assess the degree of compaction nor cohesiveness of the soil strata to a minimum 6 metres below base of proposed footing elevation to address expected loadings.The soil strata should be investigated to a depth at where a maximum 10% of net applied load (5% of net applied effective stress) is imparted on the soil strata at that elevation and the greater of either the 2:1 or Boussinesq stress formulae.
  3. The site Classification for Seismic loading requires substantiation from boreholes with appropriate testing, drilled a minimum 30 m below base of footing elevation for soil materials or an acceptable shear wave testing program.
Reviewer

City of Ottawa

Proponent’s response
  1. The field investigation and laboratory testing program is summarized in EA Volume III, Section 2.0. The field investigation methodologies mentioned in Sections 2.1 and 2.2 describe the Cone Penetration testing, Nilcon Vane testing and Standard Penetration testing that were carried out in the field, and these were conducted in general conformance to ASTM Standards D5778, D2573 and D1586, respectively. Similarly, water content determinations, Atterberg limit testing, grain size distribution testing and consolidation testing were carried out on select soil sampled in general conformance with ASTM Standards D2216, D4318, D422 and D2435, respectively.
  2. No test pits were carried out as part of this investigation. However, investigation of the full overburden thickness and into the underlying bedrock was completed at 7 locations (i.e., locations 12-1 to 12-4 and 13-5 to 13-7) across the site as described in EA Volume 3, Section 2.1 and 2.2). One borehole at each of these locations extended into the underlying bedrock at depths between about 33 and 40 m below the existing ground surface. In addition, the bedrock was cored for at least 4 m. Furthermore, 25 Cone Penetration Tests (CPT) were carried out across the site to depths up to 38 m with continuous measurement of tip resistance, local side friction and porewater pressure. A complete stratigraphic profile together with engineering properties, such as strength, stress history and density, can be interpreted from the results of the CPT. Further geotechnical investigation will be carried out for the proposed building/facility areas, as reasonably required in consultation with the City of Ottawa for Building Permits.
  3. Geophysical Vertical Seismic Profile (VSP) testing was carried out within boreholes 12-2-3 and 12-3-3 as described in Section 6.6 of EA Volume III and the accompanying memorandum in Appendix K to support the selection of a seismic site Class. The results of the testing indicate that a site Class of E should be used for the site.
Status

The ministry is satisfied with the response.

Comment #184

230,000 m3/year = 5,750 tanker loads of leachate delivered annually to ROPEC, or 22 loads per day over a standard 5 day work week. The greenhouse gas generated by this trucking operation was not considered in the Atmosphere - Air Quality Environmental Component.

Technical Support Document #10 - treating wastewater at its source and directing the treated water back into the local environment is an accepted environmental best management practice. It is noted that the Trail Waste Facility is currently hauling leachate to ROPEC, however this practice will be discontinued once the full scale treatment facility is operational. It is understood that other Ottawa landfills discharging leachate do not haul for off-site treatment and/or disposal. Pre-treating leachate and discharging it to ROPEC is not a best management practice. CRRRC should be required to install full on-site treatment. Why was the social effect not evaluated?

Reviewer

City of Ottawa

Proponent’s response

The GHG emissions from the tailpipes of the maximum potential number of leachate trucks are included in the GHG emission source called Tailpipe (Hauling Trucks) presented in the TSD #3 - Atmosphere - Air Quality Environmental Component.

Taggart Miller agrees that treating wastewater at its source and directing the treated water back into the local environment is an accepted practice; however, based on approvals of other waste management leachate-generating facilities in Ontario (and elsewhere) we do not agree with the statement in the City’s comments that this is a “best management practice”. No one at the City made such a suggestion during consultation on the proposed ToR for the EA, during preparation of the EA, nor during review of and comment on the draft EA. For those landfills in Ontario that collect leachate, the majority convey the collected leachate to a municipal sewage plant (with or without pre-treatment). There are very few landfills in Ontario that have full on-site treatment for direct discharge to the natural environment. For some time, this has also been the practice for the three landfills within the City that collect leachate. The concept of full on-site treatment at the Trail Road landfill is very recent, and its design is just being initiated by the City. Both the privately owned BFI Navan Landfill and the Waste Management Carp Landfill convey their leachate to ROPEC for treatment and discharge, under individual agreements with the City. This was accepted by the City as appropriate during the 2006 EA for the BFI Navan Landfill. It is also noted that the more recent Carp Landfill expansion EA also evaluated leachate management alternatives as per their approved ToR and concluded that continued conveyance of leachate to ROPEC for final treatment was the preferred option. The City did not disagree with that conclusion nor suggest that full on-site treatment at Carp was a best management practice in its comments on that EA. The City comments on the Carp Landfill expansion EA regarding leachate management were simply that: “The City requires that Waste Management (WM) take steps to minimize the generation of leachate and that leachate be properly treated at WM’s cost. A new Leachate Agreement with the City will be required to address changes to the property description and better define leachate quantity and quality parameters.”

The CRRRC assessment of leachate treatment options was completed using the criteria and indicators in Appendix B of the approved ToR as required under the EA Act. The approved methodology considered atmosphere, geology & hydrogeology, surface water, biology, land use, traffic, technical effectiveness, regulatory approvability, and capital and operating costs. The City of Ottawa reviewed the proposed ToR and provided comments. The City did not in its comments on the draft ToR suggest that social impact should be added to the proposed criteria for the evaluation of leachate treatment options. Nor did the City make this comment in its review of the draft EA in 2014. The assessment completed in the EA was in accordance with the methodology approved by the Minister in the ToR. The EA concluded that on-site pre-treatment with off-site final treatment at ROPEC is clearly the preferred option.

Pursuant to the final staff report concerning the CRRRC to and the motions approved at the City Environment Committee and City Council meetings in the spring of 2015, it is understood that the City agrees that ROPEC has adequate capacity for CRRRC leachate, and that the optimal options for conveyance of such leachate to ROPEC in the future will be determined in consultation with City staff.

Status

The ministry is satisfied that the proponent shall meet ministry air quality guidelines. The ministry is satisfied that the proponent will transport pre-treated leachate to the ROPEC under agreement with the City of Ottawa.

Comment #185

Volume 1 Technical Support Document #3, Appendix A, Section 4.2.6 Exhaust Emissions - it is stated only on-site leachate vehicle emissions are included in the calculations. 60 tonne vehicles (a full leachate tanker) travelling 287,500 km each year will generate a significant amount of greenhouse gases. Vehicle emissions from leachate tankers need to be included in the exhaust emission estimates, as hauling leachate to ROPEC is the identified leachate management technique. These vehicle emissions would not occur if your facility did not exist.

Reviewer

City of Ottawa

Proponent’s response

As noted above, the leachate trucks emissions are included in the calculations and air quality assessment for on-site emissions. For the evaluation of leachate treatment alternatives, the approved ToR included the separate criteria air quality and leachate haulage. In the evaluation, the EA team considered air quality related specifically to the actual on-site treatment processes and facilities. Leachate truck related traffic was captured under the leachate haulage criterion. As noted above, considering GHG from leachate trucks within the air quality criteria would be double counting the effect of leachate haulage already captured under the leachate haulage criterion.

Status

The ministry is satisfied that the proponent shall meet ministry air quality guidelines. The ministry is satisfied that the evaluation of alternative methods was completed in accordance with the approved ToR.

Comment #186

Based on the number of potential loads/day identified, ROPEC can support the volume of leachate, but not the volume of truck traffic on-site, as access for regulated waste is 8 am - 3:30 p.m. Monday to Friday. The facility would not be able to process 22 trucks during this time period when considering the other hauled waste that is brought to ROPEC.

Reviewer

City of Ottawa

Proponent’s response

Based on consultation with the City of Ottawa during preparation of the EA and as documented in Section 12.4.3 of Volume I, it is understood that if treatment at ROPEC was selected as the preferred leachate management option (which it was) the City would prefer the wastewater from CRRRC to ROPEC to be trucked, at least initially, so that information and assurance on leachate quantity and especially leachate quality could be obtained. In view of the City’s understood preference, the preferred method of conveyance is by tanker truck at this time.

The identified 22 potential loads per day represent the worst case scenario (largest leachate generation), which is expected to occur around year 27 of landfill operation. As indicated in Section 12.2.1 of Volume I initially the landfill will generate only about 20,000 m3 per year, increasing to about 88,000 m3 per year by year 10. These landfill leachate quantities would be the equivalent of 2 trucks a day initially, up to 6 trucks a day at year 5 and up to 8 trucks a day at year 10. Considering the CRRRC has not yet even been approved or built, there are therefore perhaps 30 years approximately before tanker truck traffic would be up to 22 trucks per day. Subsequent discussions with the City of Ottawa following receipt of these comments confirmed that the ROPEC facility could currently accommodate up to 6 trucks per day, or approximately 180,000 L of pre-treated leachate per day from the CRRRC, provided a Leachate Agreement is arranged with the City describing the necessary quality. In accordance with the direction from City Environment Committee and Council in 2015, the possibility of forcemain conveyance in the future will be reconsidered in consultation with the City, after leachate quality from the CRRRC is established and the success of pretreatment to meet City Sewer Use By-law requirements is confirmed, and an updated assessment of ROPEC`s truck receiving capability is undertaken as appropriate.

Status

The ministry is satisfied that the proponent will transport pre-treated leachate to the ROPEC under agreement with the City of Ottawa.

Comment #187

Since leachate must be pumped immediately - what is the maximum design head on the leachate liner? What is the storage volume of the collection system?

Reviewer

City of Ottawa

Proponent’s response

Under drained conditions the average leachate head within the leachate collection system is 0.3 metres above the base of the landfill (i.e. above the clay liner). It is considered, that for temporary, short-term storage, that another 0.2 metres of leachate within the leachate collection system could be achieved without adverse effects on the performance of the leachate collection system. This additional short-term storage capacity equates to approximately 50,400 cubic metres of leachate.

Status

The ministry is satisfied that the proponent will transport pre-treated leachate to the ROPEC under agreement with the City of Ottawa.

Comment #188

All stormwater run-off entering a ditch or municipal drain is required to meet the City of Ottawa’s Storm Limits.

Reviewer

City of Ottawa

Proponent’s response

This comment was provided on the draft EA, and the response was as follows: Acknowledged. It should be noted that the existing surface water quality within these ditches was found to exceed City storm sewer limits for phenols and biochemical oxygen demand (BOD) on one occasion. However, most of the existing conditions data show the surface water at the site is in compliance with the City of Ottawa storm sewer limits. The proposed undertaking is predicted to have no impact on existing surface water quality.

Status

The ministry is satisfied with this response.

Comment #189
  1. Need to meet a TKN limit of 100 mg/L.
  2. Need proper sampling ports - raw leachate (not mixed with other waste streams), treated leachate, liquid stream from organics processing facility (prior to mixing with other waste streams).
  3. Leachate water is to be brought on its own to ROPEC. Any storm water that needs to be trucked to ROPEC cannot be mixed with the final effluent of the leachate treatment system.
  4. A contingency plan will be required if liquid waste does not meet City of Ottawa By-law limits and cannot be brought to ROPEC for further treatment.
  5. Discharge Agreement for Leachate will have monitoring requirements, in addition to the provincial requirements already identified in the report.
  6. Hours of access to ROPEC for Regulated Waste are 8:00 a.m. to 3:30 p.m. Monday to Friday, excluding statutory holidays.
Reviewer

City of Ottawa

Proponent’s response
  1. Acknowledged. The leachate pre-treatment facility has been designed to meet this requirement.
  2. Proper sampling ports for raw leachate, treated leachate and liquid stream from the organics processing facility will be provided.
  3. Acknowledged
  4. Contingencies related to disruption of leachate transport to ROPEC are described in Section 8.3 of Volume IV.
  5. Acknowledged.
  6. Acknowledged.
Status

The ministry is satisfied with this response.

Comment #190

4 out of the 5 surface water features had fish. These will require DFO self assessment and a CA review. As well, fish sampling should be conducted in snow melt/early spring season (freshet).

Further fish community data collection should follow the direction of the "Evaluation, Classification and Management of Headwaters Drainage Feature Guidelines" (TRCA & CVC Jan 2014), which recommends sampling during spring freshet.

Reviewer

City of Ottawa

Proponent’s response

There are 4 surface water features on the site, 3 of which contained fish as observed during field surveys. As described in Section 1.7 of Volume I, South Nation Conservation is responsible for issuing permits for any construction in or alternation of water courses regulated under the Conservation Authorities Act. A Fisheries and Oceans Canada (DFO) self-assessment will be done if required by SNC during permitting. Given that the drainage features on the site are warm water, any fish in these systems would be spawning in spring, and would not be found in the on-site drainage features. If additional data regarding the fish community is deemed necessary, it should be collected during the summer, which is after the MNRF restricted period (March 15 to June 30).

Status

The ministry is satisfied that the proponent will obtain the necessary permits from SNC, DFO and MNRF as required.

Comment #191

Migratory Bird Nests (page 202): on the basis of new and improved information from Environment Canada regarding the migratory bird breeding season, we recommend that there be no vegetation clearing between April 15 and August 15 unless a qualified biologist has checked for nests first. Update section 11.5.1 to reflect the new breeding season time frame (page 215).

Reviewer

City of Ottawa

Proponent’s response

The applicable migratory bird breeding season for the region in which the site is located will be observed in relation to any vegetation clearing.

Status

The ministry is satisfied with this response.

Comment #192

We disagree with statements (page 203) regarding fish habitat. If fish were found in drain DD1 and this drain is scheduled for removal, how can it be concluded that this "will not result in direct loss of fish habitat on site"? Please clarify which sections of DD1 are scheduled to be removed in a map.

Reviewer

City of Ottawa

Proponent’s response

Construction of the diversion facilities in the northern part of the CRRRC will require the complete removal of DD1. DD1 is a man-made channel in an agricultural field. The feature originates and is entirely within the site (i.e., there is no upstream channel beyond the site) and does not receive flows from connecting off-site tributaries. Based on our field assessment this feature serves to collect surface runoff from a portion of the site during limited periods (i.e., following storm events and spring freshet). Our assessment includes direct observations from a 2012 survey where DD1 was dry along its entire length and a 2013 survey where there was an approximately five metre section with pooled water, but the remainder was dry. The sole observation of fish in DD1 was in 2013 - three small bodied fish in an isolated shallow refuge pool created as water in DD1 dried up.

Our assessment is that DD1 contains limited and marginal quality fish habitat that is subject to ongoing disturbance due to seasonally dry conditions. Access to DD1 by fish from adjacent waterbodies is limited by hydrology and for much of the year DD1 is not accessible to local fish populations. Indirect contributions of nutrients from the site to off-site areas through DD1 are limited by the ephemeral/intermittent conditions. The removal of the channel is not anticipated to affect regional fish populations or distribution in any discernible or biologically meaningful way. Because of the limited functions in this ditch, it is Golder’s opinion that removal of this feature will not result in direct loss of fish habitat on the site.

A headwater drainage feature assessment will be discussed further with SNC in future as part of subsequent approvals/permits for the proposed project.

Status

The ministry is satisfied that the proponent will obtain the necessary permits from SNC.

Comment #193

What are the mitigation measures for direct fish habitat loss in DD3? Although fish will be "salvaged and relocated", this does not compensate for fish habitat loss. Please elaborate why DD3 is does not qualify for the Fisheries Act's definition of fish habitat?

Reviewer

City of Ottawa

Proponent’s response

DD3 does not meet the criteria for fish habitat under the Fisheries Act, and therefore compensation is not required under that Act. Under the Fisheries Act, only CRA (Commercial, Recreational and Aboriginal) fisheries, and those waterbodies that contribute to CRA fisheries, are regulated. DD3 is located on private land with restricted access and is not a CRA fishery. Also, because DD3 is artificial and is not connected to fish habitat downstream, a review by DFO for removal is not required. Although the habitat will be removed, implementation of mitigation measures to avoid causing serious harm to fish will be implemented. The mitigation will be to salvage and relocate the fish from DD3. Prior to any work associated with DD3, a fish collection permit will be obtained from the MNRF. The fish will be salvaged and relocated to a nearby surface water feature. Any non-native species encountered during the fish salvage will be euthanized and disposed of using appropriate methods.

Status

The ministry is satisfied that the proponent will obtain the necessary permits from SNC, DFO and MNRF as required.

Comment #194

Please provide the source of information for "NCC has hypothesized the existence of a wildlife movement corridor from Cumberland Forest through the Vars Forest…" (page 204). Please provide written correspondence of NCC's agreement that their interests were addressed.

Reviewer

City of Ottawa

Proponent’s response

The approximate location of the potential wildlife corridor was noted in the following source: National Capital Commission. 2013. Canada’s Capital Greenbelt Master Plan. A copy of the correspondence with the NCC can be found in Volume II, Appendix F, page 517 of the EA submission package.

Status

The ministry is satisfied with this response.

Comment #195

The entire section "Alteration of Surface Water Regime" requires furtherattention (page 206 & 207). The section begins by acknowledging potential impacts on downstream sections of aquatic systems but does not presenttheir reasoning in a sequence to justify or substantiate their conclusion of flow regime changes not being ecologically important. Please clarify and elaborate.

States that: "Although it is expected that these changes in flow will be minimal and not ecologically important, a surface water monitoring program as outlined in Section 14.1.3 will be implemented post-development."Given that the program outlined in that section comprises only of the collection of water quality samples and estimated flows where appropriate, it is unclear as to how this will measure changes to fish habitat. Please advise.

Reviewer

City of Ottawa

Proponent’s response

The Alteration of Surface Water Regime section of the report was updated and clarified in the Final EA. Because the flow regimes of the drainage features will not be changing materially, any changes to downstream aquatic habitat are anticipated to be minor. Any downstream change in aquatic habitat (including fish habitat) that does occur will be within a relatively small geographic extent, and the magnitude of any change will be low. The overall importance of any such change to the ecology was also therefore judged to be low.

Flow and water quality monitoring will determine if a change has occurred, that is not predicted, that could reduce the fish habitat, increase the deposition of fines, or decrease the amount of in-stream vegetation.

Status

The ministry is satisfied that a monitoring plan will be implemented.

Comment #196

As noted above, the groundwater monitoring program should include on-site and off-site monitoring, including the monitoring of private wells within 3 kilometres of the landfill. Only one sample from residential wells is planned prior to the commencement of the operations at the site. Ottawa Public Health (OPH) would like to see annual tests of private wells within 3 kilometres of the landfill.

Reviewer

City of Ottawa

Proponent’s response

Within the Environmental Committee Report dated April 29, 2015, OPH provided an update to this comment. The update noted that staff had initially raised concerns related to the lack of off-site groundwater monitoring proposed in the EA. However, the MOECC requires groundwater monitoring to ensure no migration of contaminants along the perimeter of the site, per the Reasonable Use Guideline. We understand that this requirement addresses Public Health’s initial comment regarding off-site private well monitoring.

Status

The ministry is satisfied that a monitoring plan will be implemented.

Comment #197

The right of way (ROW) protection for Boundary Road is 30m per the City’s Official Plan, so 15m from the centreline of existing pavement to the property line. Ensure that the road widening is conveyed to the City.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with this response.

Comment #198

Please note that the proposed roadway modifications will require the delegated authority approval of the manager of Development Review, Suburban Services.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with this response.

Comment #199

Noteworthy is intersection at Boundary and Highway 417 is subject to study involving 400 series interchanges which will form part of the Employment Lands study. The selection process for consultant is underway and the study is expected late 2015. The result of this study may inform or recommend changes to Official Plan with respect to land use at interchanges.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with this response.

Comment #200

The proponent is proposing to alter drainage boundaries for three municipal drains within the property, which would necessitate revisions to the Municipal Drain Engineering Reports under the Drainage Act. The proponent is advised to consult with the Municipal Drainage Superintendent to confirm all requirements under the Drainage Act.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. Taggart Miller and its consulting team have met with and had several discussions with the Municipal Drainage Superintendent. These consultation activities are documented in Volume I, Section 3.6.6.

Status

The ministry is satisfied with this response.

Comment #201

Taggart should note that revisions to Municipal Drain Engineering Reports can take 1-2 years and may be subject to the appeals process as detailed in the Drainage Act. Sufficient program allowance should be made to ensure that Drainage Act approvals do not delay the other project elements.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with this response.

Comment #202

It appears that the proponent’s analysis of potential environmental impacts was based solely on the 2006 WEPP document – “Water Quality in Ottawa’s Rivers and Streams”. This document does not contain sample results; only a very simplified characterization. It is suggested that the proponent complete their analysis based on the actual data collected by WEPP from 2008 to the present in order to assess the potential impacts of the discharge.

Although the proponent has indicated that data from 2008 to present was obtained for Bear Brook Creek, it appears that only a rudimentary analysis was performed on four out of forty three parameters (phosphorus, E.coli, copper and zinc), and the mechanism for reporting results lack clarity.

Regarding in-field monitoring undertaken by the proponent, it also appears that a limited number of parameters were considered during the analysis of potential environmental impacts.

Based on the very limited information contained in the report, it is still our opinion that the analysis undertaken does not adequately assess the potential impacts of the facility on natural watercourses.

It is unclear why Technical Supporting Documents for the analysis were not made available, as they were for the impact analysis of other factors. (The two paragraphs contained in Technical Support Document #4 – Biology are insufficient.) This would lend clarity as to the parameters considered and how the conclusion that there would not be an adverse impact was reached.

Reviewer

City of Ottawa

Proponent’s response

WEPP data from 2008 to present for the Bear Brook Creek were in fact obtained from the City. The concentrations of key water quality indicators (phosphorus, E. coli, copper and zinc) were compared to the provincial water quality objectives and the Canadian Water Quality Guidelines. At the time of the review of the draft EA this reviewer did not indicate that there was an issue with evaluating only the four key parameters. It should be noted that this data was not used in the analysis of potential environmental impacts, but was used only to describe existing conditions of the surrounding Bear Brook Creek as described in Section 8.6 of Volume I. Water quality of on-site surface water features was determined from on-site sampling events.

The list of parameters monitored for the “in-field monitoring” represent the comprehensive list from Schedule 5 of the MOECC Landfill Standards (1998 revised 2012). This list includes 23 laboratory parameters and 4 field parameters including general chemistry, metal and volatile organic parameters. This is the long list of parameters that has been carefully developed by the MOECC to evaluate potential impact from waste disposal facilities.

Drainage from the CRRRC can and will be directed appropriately as impacted or not impacted. As described in Section 11.4 of Volume I, during operational phases of the CRRRC, drainage features will be implemented to keep potentially impacted runoff separate. Drainage that is known or anticipated to be impacted includes the drainage around the active face of the landfill that will be directed to the landfill leachate collection system. As well, drainage from the compost processing and storage pad will be directed to Pond 4a. The plan for management of this surface water is described in Section 11.4 of Volume I and includes re-use within the composting area and/or spray irrigation. Stormwater ponds adjacent to the landfill will not become impacted because the landfill is to be surrounded, above ground, by a perimeter berm which is 36 metres wide at the top. The base of the landfill is situated primarily on or within native silty clay, or on a thin remaining layer of surficial silty sand underlain by native silty clay. In addition, a geosynthetic clay liner (GCL) hydraulic barrier is planned for the sideslope liner system to prevent leachate from entering the surficial silty sand/weathered crust zone or overlying perimeter berm fill. Further, a leachate detection and secondary collection system is also proposed along the east side. The combination of these natural and engineered containment features within the landfill protect the two adjacent ponds from potential leachate effects.

Volume IV Appendix A includes more detailed information with regard to the surface water impact assessment. Surface water quantity and quality were carefully examined in the assessment. This information was placed within the Design and Operations Report, Volume IV in lieu of a separate TSD as it would only have to be repeated again within Volume IV.

Status

The ministry is satisfied with this response.

Comment #203

Taggart should note that revisions to Municipal Drain Engineering Reports can take 1-2 years and may be subject to the appeals process as detailed in the Drainage Act. Sufficient program allowance should be made to ensure that Drainage Act approvals do not delay the other project elements.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with this response.

Comment #204

4.2.1 of Appendix A, Volume IV states that "During operational phases of the northern diversion facilities or the landfill, drainage features will be implemented to keep potentially contaminated runoff separate. Drainage around the active face of the landfill will be directed to the landfill leachate collection system." Further clarification is needed to indicate how this runoff will be collected and conveyed to Pond 4a. Primarily, this would detail how the temporary collection system will be sized and the maximum event contained before contaminated runoff enters the main stormwater system.

Reviewer

City of Ottawa

Proponent’s response

See response above. Pond 4a is receiving drainage from the compost processing and storage pad only; other leachate-impacted water generated at or near the landfill will be directed to the leachate collection system and the on-site leachate pre-treatment facility. Drainage on the compost pad will be contained and directed to a series of catchbasins in the pad area. These will be connected by a sewer network that will convey the runoff to Pond 4a. In accordance with the Guideline for the Production of Compost in Ontario (MOE, 2012), the retention pond has been sized to contain a minimum of 110% of the runoff from a 1:25 year, 24 hour event.

Status

The ministry is satisfied with this response.

Comment #205

The proponent must develop a comprehensive program to ensure that there are no future groundwater and surface water impacts on and around the site.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. The program described in the Final EA will ensure that groundwater and surface water are adequately monitored and fully protected.

Status

The ministry is satisfied that a monitoring plan will be implemented.

Comment #206

An annual report should be provided to the Mayor, Councillors of Wards 19 and 20 and the General Manager of Environmental Services that ensures there are no environmental impacts resulting from the operations at the facility.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

The ministry is satisfied with this response.

Comment #207

Request the Ontario Ministry of the Environment and Climate Change to restrict the proposed service area for the CRRRC to the municipal boundary of the City of Ottawa and that of the United Counties of Prescott and Russell and the United Counties of Stormont Glengarry, provided that loads containing mainly recyclable materials may be received from the broader “secondary service area” described in the CRRRC EA.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. Such a restriction on the service area would not in any way affect the environmental impact assessment of the CRRRC. It will be up to the MOECC to determine if such a restriction is warranted.

Status

The ministry is satisfied with the service area defined in the EA.

Comment #208

Approve that contaminated soils brought to the site should also be restricted to those generated within the same territorial limits of the proposed service area.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. See response above.

Status

The ministry is satisfied with the service area defined in the EA.

Comment #209

Request that the Ministry put in place programs and policies necessary to move the IC&I and C&D sector from its current 17 percent diversion rate to the Ministry’s and City’s target of 60 percent diversion before considering future landfills to dispose of IC&I and C&D wastes where all reasonable efforts have not been made to first divert the waste.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. Taggart Miller believe that the diversion components of the CRRRC are a very important investment by the private sector to help increase the current very low commercial diversion rate in the community.

Status

The ministry is satisfied with this response.

Comment #210

Request that, if the Ontario Minister of the Environment and Climate Change chooses to approve the CRRRC, the City of Ottawa urges the Minister require the company to build recycling facilities at the same time as landfill facilities.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. Taggart Miller have stated in the EA that the initial phase of the diversion facilities will be constructed at the same time as the initial cell of the landfill component.

Status

The ministry is satisfied with this response.

Comment #211

Request that, if the Ontario Minister of the Environment and Climate Change chooses to approve the CRRRC, the annual maximum tonnage capacity approved for the recycling and composting facilities be in alignment with the province’s IC&I and C&D diversion target.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. The EA proposes the maximum annual tonnage to be received as 450,000 tonnes, and describes the anticipated diversion to be achieved over time from the various components of the waste stream.

Status

The ministry is satisfied with this response.

Comment #212

Request that, if the Ontario Minister of the Environment and Climate Change chooses to approve the CRRRC, to not count contaminated soils used for daily/interim/final cover or other uses on the property at the Capital Region Resource Recovery Centre towards the facility’s diversion rate.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. This is a beneficial use of such soils.

Status

The ministry is satisfied that this will be considered at the ECA stage.

Comment #213

Request that, if the Ontario Minister of the Environment and Climate Change chooses to approve the CRRRC, the proponent be barred from charging less for waste loads going directly to landfill disposal than it does for loads processed through the onsite diversion facilities.

Reviewer

City of Ottawa

Proponent’s response

Some types of recyclables are very expensive to deal with and therefore Taggart Miller cannot commit to always charging more for waste loads going directly to landfill disposal than it does for loads processed through the onsite diversion facilities. Taggart Miller is making a very significant upfront investment in the CRRRC diversion facilities. Taggart Miller’s Waste Diversion Protocol developed in consultation with the MOECC and on which Taggart Miller will be reporting annually to the MOECC will ensure that waste that can reasonably be diverted from disposal will be.

Status

The ministry is satisfied that the proponent will implement a waste diversion protocol to enhance diversion at the site.

Comment #214

Require that Taggart Miller initiate a Public Liaison Committee (PLC).

Reviewer

City of Ottawa

Proponent’s response

Acknowledged. We have already proposed this.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #215

Require Taggart Miller to invite the two East-end Councillors (Cumberland and Osgoode) to participate on the PLC.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #216

Require that City staff and the MOECC be invited to attend all PLC meetings.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #217

Require that Taggart Miller advertise in the local community papers and through the East-end Councillors to solicit participation in the PLC.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #218

Require that the PLC membership consist of a minimum of six (6) members of the public and two (2) members of the local business community.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #219

Require that a Terms of Reference be developed and approved by the participants on the PLC.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #220

Require that Taggart Miller holds at least four PLC meetings each year.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #221

Require that the PLC monitor and make recommendations on Taggart Miller’s operational issues, complaints and environmental issues and that Taggart Miller formally responds to the PLC on these recommendations and provides timelines for action plans.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #222

Require that Taggart Miller provide an agenda at a minimum of one week in advance of the PLC meeting that includes a summary of the complaints, operational issues and issues of non-compliance for discussion at the meeting.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #223

Require that Taggart Miller provide written minutes to the members of the PLC within one week of the meeting.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #224

Require that Taggart Miller provide to the PLC annual tonnage reports that contain the following information:

  1. The source of materials (recyclables, organics, contaminated soils, residual waste, etc.) processed and disposed (inside/outside City limits);
  2. The residual rate for materials processed at all recycling and composting facilities on site;
  3. The methane generated, collected and burned, and fugitive emissions from the site.
Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #225

Require that Taggart Miller host the PLC meetings.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

A condition of Approval will be proposed for the establishment of a PLC.

Comment #226

Request that, should the Ontario Minister of the Environment and Climate Change approve the proposed CRRRC, the daily maximum volume of leachate allowed to be trucked to ROPEC from this site be limited to 180,000 litres (equivalent of 6 trucks) per day, five days per week, pending either:

  1. determination of alternate means to convey additional leachate to ROPEC; or
  2. identification of alternate means of final treatment consistent with the Environmental Assessment for the CRRRC, and
  3. subject to the terms and conditions of a suitable agreement between the City and the site operator of the CRRRC.
Reviewer

City of Ottawa

Proponent’s response

Acknowledged. While the CRRRC is not anticipated to hit this figure until approximately 2025 and perhaps later, consultation with City staff per item 22 below will continue.

Status

The ministry is satisfied that the proponent will transport pre-treated leachate to the ROPEC under agreement with the City of Ottawa.

Comment #227

Direct staff to engage in discussions with the proponent to assist in the process contemplated by item 21 above.

Reviewer

City of Ottawa

Proponent’s response

Acknowledged.

Status

The ministry is satisfied that the proponent will transport pre-treated leachate to the ROPEC under agreement with the City of Ottawa.

Table 2: Summary of comments from the public

Comment #1
  1. The CRRRC EA Report is not technically sufficient. The report lacks detail and skims over critical facts, contains many generalizations that are not substantiated by any hard facts, and contains errors, omissions, falsehoods, misleading statements, or what appears to be falsified data. The EA Report is too vague with respect to plans for various components of the Site.
  2. The EA does not adequately take into account previous technical studies done on the project Site regarding fault lines, geology, hydrogeology, historical reports, maps and borehole records.
  3. The final EA Report was deliberately written to be too long to thoroughly evaluate within the seven week comment period. There are flaws in the methodology of the EA.
Proponent’s response

Approximate number of times comment received – Forms:190 Individuals:12 Groups footnote 1 :2

  1. The Environmental Assessment (EA) was done in accordance with a specific methodology approved by the Minister of Environment and Climate Change as required pursuant to the Ontario Environmental Assessment Act. The EA was prepared using the criteria, indicators and data sources in the approved Terms of Reference (ToR) by a team of qualified, licensed professionals.
  2. In preparing the EA, Taggart Miller reviewed and considered relevant information available from previous preliminary technical studies, and undertook extensive additional studies, all in accordance with the approved ToR.
  3. The draft EA was circulated to review agencies and the public for review and comment. The seven week review period is established by regulation and is the same for every individual EA in Ontario.
Status

The ministry is satisfied that the EA was completed in accordance with the approved ToR.

Comment #2
  1. The proposed location of the CRRRC is not appropriate considering it was rejected for a landfill and abandoned in the 1980s (referred to as “Site 10”).
  2. The zoning of the Site does not currently permit this facility.
  3. Local elected representatives are opposed to the CRRRC.
Proponent’s response

Approximate number of times comment received – Forms:6 Individuals:24 Groups:3

  1. Taggart Miller prepared Frequently Asked Questions (FAQ), which is posted on the project website, regarding the identification of the Boundary Road Site as the preferred site for a new regional landfill in a previous Region of Ottawa-Carleton (RMOC) waste management study. The Boundary Road Site was not previously rejected as unsuitable by the RMOC; in fact comments of regulatory agencies at the time were generally very supportive of Site 10, as it was called. Rather, the Region determined that its Master Plan process was not adequately documented and was unlikely to be approved by the Environmental Assessment Board. We believe that the Site is very well suited for the proposed CRRRC facility.
  2. As described in the EA, the implementation of the CRRRC will require approvals under the Planning Act. Planning Act approvals would be sought after EA approval is received. It is noted that a portion of the Site is already zoned for “rural heavy industrial” uses and that certain waste-related uses are already permitted by this zoning.
  3. The proposal has been reviewed by the Environmental Committee and full Council of Ottawa. The staff report and the motions passed by the Committee and Ottawa Council are overall supportive of the project.
Status

The ministry is satisfied with the assessment of alternative methods in the EA. The ministry is satisfied that the proponent has identified additional approvals required for the CRRRC. The ministry is satisfied with the proponent’s consultation with the City of Ottawa.

Comment #3
  1. There was inadequate (or no) consultation with local farmers, Aboriginals, local natural history groups and the National Farmers Union-Ontario (NFU-O).
  2. The Environmental Assessment Report is only partially available in French.
  3. The documents were not available in print and the size of some electronic files deterred receipt via e-mail.
Proponent’s response

Approximate number of times comment received – Forms:129 Individuals:8 Groups:4

  1. The consultation process for this EA has been undertaken in accordance with the approved ToR and is described in Volume II of the EA package.

    As per the approved ToR, the Ontario Federation of Agriculture and the Christian Farmers Federation were contacted. Neither of these organizations nor the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA) identified the NFU-O during the ToR or EA as an organization to contact. All Aboriginal groups identified in the ToR were consulted during the EA.
  2. In accordance with the commitment made during the approval process for the ToR, the entire main EA report (Volume I), which summarizes the EA, has been fully translated into French. It is a stand-alone document that describes the EA process and findings in their entirety for the CRRRC proposed waste management facility. The translated EA Volume I completely satisfies the requirements of the approved ToR with respect to translation. In addition, all six Open Houses were in both English and French, and French capability was provided at both workshops. The FAQs on the project website are in English and French. If specific French questions were or are asked, the Taggart Miller Project Manager is fully bilingual.
  3. Hard copies of all volumes of the EA are available at nine public locations (libraries, Ministry of the Environment and Climate Change (MOECC) office, municipal offices and at Taggart Realty Management) in accordance with the arrangements discussed with the MOECC. The documents are also available for anyone to download from the website www.crrrc.ca.
Status

The ministry is satisfied that consultation was completed in accordance with the approved ToR.

Comment #4
  1. The proposed CRRRC landfill is not needed for IC&I waste from our area. Other sites in the area can handle the waste.
  2. The CRRRC will not promote increased recycling because the excess landfill space will reduce recycling and there are no diversion targets.
  3. Waste will be imported from the Greater Toronto Area.
  4. Different options for the disposal of waste should be considered.
Proponent’s response

Approximate number of times comment received – Forms:3 Individuals:21 Groups:4

  1. The opportunity for the proposed CRRRC is discussed in Supporting Document #1 to the approved ToR. The location, permitted waste acceptance and estimated currently approved remaining site capacity and life for each of the landfills in the Capital Region were described in the ToR for this EA.
  2. Primary components of the CRRRC are diversion facilities, all of which will divert material from the landfill portion. The Waste Diversion Protocol, Proposed, which has been developed in consultation with the MOECC is designed to ensure that waste that can reasonably be directed from disposal, will be.
  3. The waste generated by the Industrial, Commercial & Institutional (IC&I) sector includes mixed materials, organics and soils, as well as Construction & Demolition (C&D) materials. The overall ultimate anticipated diversion rate for the CRRRC is 43 – 57%, as stated in the EA, which is a significant improvement over the current 12- 14 % IC&I diversion rate. The CRRRC will contribute positively to the provincial and City of Ottawa objectives for IC&I waste diversion.
  4. The service area for the proposed CRRRC was clearly defined in the approved ToR and is repeated in the EA. That service area does not extend to the Greater Toronto Area.
  5. An assessment of alternatives to landfilling was provided in Supporting Document #1 to the approved ToR. The CRRRC is an innovative proposal and will be among the first of its kind anywhere in Canada.
Status

The ministry is satisfied that the proponent provided the rationale for the undertaking in the EA. The ministry is satisfied that the proponent’s assessment of alternatives was consistent with the approved ToR.

Comment #5

Property values will be impacted in the area surrounding the CRRRC. The PVPP should be extended to businesses, recreational and institutional land uses.

Proponent’s response

Approximate number of times comment received – Individuals:7 Groups:1

Generally, for other similar projects, Property Value Protection Plan (PVPP) zones have been limited to a relatively close area - 1 to 2 kilometres (km) - from the Site. Taggart Miller has voluntarily proposed a much larger PVPP zone – 5 km. The CRRRC PVPP sets a new standard for geographic scope of such programs for similar facilities. It is typical for such programs to apply only to residential properties. Further, there is little evidence of modern waste management facilities adversely affecting property values.

Status

The ministry is satisfied that the proponent will implement the PVPP.

Comment #6

The EA downplays the documented risks of impact on this Site from seismic events in Eastern Ontario. The EA does not address all the known faults and earthquakes that have been recorded in the general vicinity of the Site and that demonstrate that some local faults are active.

Proponent’s response

Approximate number of times comment received – Forms:205 Individuals:23 Groups:4

The potential presence and activity of faults and the seismic stability of the proposed CRRRC have been fully considered in the EA by highly qualified experts. Further, the analysis of the landfill under seismic loading demonstrates that the landfill component will be stable should there be significant seismic activity.

Status

The ministry is satisfied with the response.

Comment #7

The document, titled “Critical Review of Geoscientific Component of TMES EA, Final Version” (Wallach, 2015) contests the interpretation in the EA of Site and regional geological conditions and the lack of identification of faults or probable faults in the bedrock in the area of the Site.

Proponent’s response

Approximate number of times comment received – Groups:1

A detailed review of Wallach (2014) identified that: (i) Wallach (2014) contained significant errors in the data used in his analysis. The data consisted primarily of information obtained from the MOECC Water Well Information System (WWIS) that, even without the significant errors, is not suitable for purposes of geological and structural interpretation; (ii) only part of the available data was used in the interpretation; (iii) structural geological interpretations (i.e., presence of faults) were based more on speculation than evaluation of reliable data; and (iv) once systematic errors in Wallach (2014) associated with the data are eliminated, and other available high quality data are included, the faults hypothesized by Wallach in proximity to the Boundary Road Site is unsupported. The geological interpretations presented in the EA submission accurately portray the geological conditions underlying the 15 by 20 kilometre study area within which the Site is located.

Status

The ministry is satisfied that the proponent posted the supplemental report on its website and that there is an opportunity to comment.

Comment #8

The same document contests the interpretation in the EA of hazards associated with potential earthquakes, including ground shaking and liquefaction, and their potential effects on the landfill component of the proposed CRRRC.

Proponent’s response

Approximate number of times comment received – Groups:1

The seismic analysis for the CRRRC landfill considered the historic record of earthquakes in southeastern Canada, potential effects of surface fault rupture, strong earthquake shaking and potential liquefaction of the underlying clay deposit. The potential effects of future strong earthquake shaking on the proposed CRRRC landfill component considered the approach used for assessment of earthquake life safety for buildings in Canada as well as for seismic protection of landfills in the United States, and followed the state of practice in earthquake engineering design in North America. The analysis showed that under design seismic loading conditions the landfill is stable and both the landfill mass itself and the proposed leachate containment and collection system (and its components) are very capable of withstanding significant vertical and horizontal movements and continuing to perform as expected.

Status

The ministry is satisfied that the proponent posted the supplemental report on its website and that there is an opportunity to comment.

Comment #9

The stability analysis and settlement calculations used characteristics of the closed landfill as the worst case scenario. During the operation of the landfill differential settlement may occur and phasing of the cells may affect stability.

Proponent’s response

Approximate number of times comment received – Groups:1

Differential settlement would not impact the stability of the landfill, provided the interim waste slopes are maintained at 14H:1V during construction as discussed in the EA and shown on Figure 11-3. In fact, differential settlement would only result in flattening of the interim waste slopes. In addition, the analysis was carried out for essentially instantaneous loading (i.e., fully undrained conditions), whereas in actuality the clay layer would be consolidating and gaining in strength over time, which would result in a higher factor of safety than what has been reported.

Status

The ministry is satisfied with the response.

Comment #10

Clarification regarding landfill settlement and stability calculations related to the stability berm, factor of safety, unit weight of waste, stability analysis approach, possible effects of settlement beyond the landfill footprint and strength gain of the clay over time was requested.

Proponent’s response

Approximate number of times comment received – Groups:1

Settlement of the perimeter berm was not specifically assessed. However, the expected settlements for the 3.5 m high perimeter berm could be conservatively estimated from Figure 11-6 of Volume III by correcting for the difference between the unit weights of the berm fill and waste. This settlement would correspond to the conditions at the approximate centre of the berm.

The factor of safety of 1.5 referred to in the comment and which is specified in the “Slope Stability Guidelines for Development Applications in the City of Ottawa” is applicable to natural slopes along river valleys. The Guideline states that the document is not applicable to the construction of embankments (and, by analogy, is also not applicable to landfill waste slopes). The selection of the 1.4 target factor of safety was made based on past experience with landfill design under similar geological conditions. The Ministry of Transportation uses a factor of safety of 1.3 for the construction of earth embankments, which is arguably the most comparable standard to the construction of the slopes for the CRRRC project.

The range of unit weights of waste provided in published data represents the broad range of waste types and types of soil materials that could be used for daily cover. For this analysis, the unit weight of the waste was selected based on calculations of actual in place unit weight of combined waste and daily cover soil at landfill sites in the Ottawa area, determined from the weight of waste and cover soil received and the volume of air space consumed during the same period of time.

As outlined in EA Volume III, Section 11.1, in terms of the approach to stability analysis, the critical design condition is considered to be undrained conditions (i.e., where the full excess porewater pressures are generated in the silty clay due to the conservative modelling of the instantaneous application of the stress from the ultimate height of the waste). In reality, the filling will be progressive, and analogous to a ‘staged construction’ sequence of an embankment. Carrying out fully ‘drained’ analyses would be a less conservative condition and would not safely reflect the actual progressive loading condition. Such ‘drained’ analyses are applicable to natural valley slopes and deep excavations, and not for cases of applied ‘embankment-type’ loading.

The effects of landfill settlements will not extend further than a distance equivalent to the clay thickness (i.e., about 30 m) from the edge of the landfill footprint. No settlement intolerant structures are proposed within this distance. Strength gain of the clay due to consolidation was conservatively not included in the stability analyses.

Status

The ministry is satisfied with the response.

Comment #11

What happens to the design and to the operations if the settlement is worse than expected?

Proponent’s response

Approximate number of times comment received – Individuals: 1 Groups:1

Increased settlement would mean an increased flux of porewater from the silty clay into the landfill (where it would be removed by the leachate collection system together with the leachate). There would also be increased consolidation of the clay, reducing the hydraulic conductivity of the clay, and therefore further improving the performance of the clay deposit as a barrier to contaminant transport flow. As discussed in the EA,settlement is highest where the waste is thickest, and decreases towards the toe of the perimeter berm. Due to this differential settlement, the stratigraphic layers will deform towards a ‘bowl’ shape. This differential deformation will act as a structural trap for leachate generated at the Site. Additional settlement would accentuate the bowl structure. The sumps for leachate collection were strategically placed in the areas where waste is thickest and the most settlement will occur. Increased settlement would result in additional deflection and/or elongation of the leachate collection pipes, but this has been considered in the design and is not expected to be a concern.

Status

The ministry is satisfied with the response.

Comment #12

What are the impacts of a geotechnical failure and what is the plan if there is a failure?

Proponent’s response

Approximate number of times comment received – Groups:1

The exit point of critical deep seated slope failure surfaces, as indicated by the modelling, extend to the perimeter berm and adjacent drainage ditch as shown on Figures 11-1B and 11-2B, of EA Volume III. There are no proposed structures or off-Site receptors within this area.

Based on the stability analyses, slope failures are not anticipated, and as such leachate is not expected to be released to the environment. In the event that waste or leachate moves beyond the waste footprint, there are contingency plans to contain any potential impacts on-Site.

Status

The ministry is satisfied with the response.

Comment #13

The clay soil underlying the landfill (described by commenters as very weak, highly compressible, and sensitive Leda Clay) under the weight of the waste will cause the landfill to sink into the ground and this settlement will compromise the performance of the natural clay liner, the perimeter hydraulic barrier and the leachate and landfill gas collection systems.

Proponent’s response

Approximate number of times comment received – Forms:368 Individuals:23 Groups:4

The physical properties, including the strength and compressibility of the silty clay present at the CRRRC Site, are clearly described and assessed in the EA. The potential effects of settlement on the performance of the landfill and its engineered components have been fully considered in the design of these components.

Status

The ministry is satisfied with the response.

Comment #14

The proposed landfill design does not incorporate a bottom liner and only includes a liner around the perimeter. The design does not adequately address the risk of groundwater contamination from the landfill.

Proponent’s response

Approximate number of times comment received – Forms:398 Individuals:24 Groups:4

The very thick natural low permeability silty clay deposit at the Site will provide an effective and robust low permeability bottom liner for the landfill component of the CRRRC. The perimeter berm and perimeter geosynthetic clay liner will protect against lateral migration of leachate.

Groundwater protection measures associated with the CRRRC are described in the EA, in terms of design, operations, monitoring and contingency measures. The studies and assessments demonstrate that the abundant natural protection, which, together with the engineered design features and the monitoring program, will ensure that the CRRRC will not have adverse effects on off-Site groundwater during the contaminating lifespan of the landfill component of the CRRRC.

Status

The ministry is satisfied that contingency measures and a monitoring plan will be implemented to confirm groundwater protection measures.

Comment #15

The EA relies on assumptions about groundwater flow which were not tested in field work by the proponents, and which contradict other reports for the area.

Proponent’s response

Approximate number of times comment received – Forms:338 Individuals:7 Groups:1

Determination of groundwater flow at the Site did not “rely on assumptions”. Direction of groundwater flow was assessed using groundwater elevations measured from groundwater monitoring wells installed on the Site. Other data pertaining to groundwater were obtained following a rigorous program to ensure it was reliable.

Status

The ministry is satisfied with the assessment of groundwater included in the EA.

Comment #16

The comparative analysis of the alternative sites from a hydrogeological perspective was subjective.

Proponent’s response

Approximate number of times comment received – Groups:1

The North Russell Road Site and the Boundary Road Site were compared using the components, criteria, indicators and data sources developed, consulted about, approved and presented in the ToR. The groundwater assessment criterion was: Which site is preferred for protection of groundwater? The approved indicators included: geological setting, type and thickness of any natural on-Site attenuation layer, presence and quality of groundwater resources on-Site and in Site-vicinity, and interpreted direction of vertical groundwater flow on-Site and in Site-vicinity, i.e., area of groundwater recharge, transitional flow, or groundwater discharge. The analysis clearly demonstrated the superiority of the Boundary Road Site from a groundwater protection perspective.

Status

The ministry is satisfied with the assessment of alternative methods completed in the EA.

Comment #17

The geological interpretation is highly oversimplified and the hydrogeological investigation is weak, has too many assumptions, does not use appropriate values for parameters (total versus effective porosity) and does not consider fracture flow.

Proponent’s response

Approximate number of times comment received – Groups:1

The geology at the CRRRC Site is not considered to be complex. The information gathered from the on-Site investigations was more than sufficient to characterize the Site geology. The conservative nature of the assumptions and parameter values used in the assessment are clearly described. Where contaminant transport is controlled by diffusion in saturated or near-saturated clayey barriers of low activity clays, as is the case for the Boundary Road Site it is reasonable to use total porosity in lieu of an assumed effective porosity. In any event, utilizing an effective porosity does not change the results appreciably (this was checked by re-running the model using an estimated effective porosity and the re-run modelling results were provided to the MOECC).

Based on the modelling completed in support of the EA, contaminants from the Site will not even reach the bedrock during its contaminating lifespan and therefore fracture flow is not relevant to the analysis.

Status

The ministry is satisfied with the response.

Comment #18

A water budget was not completed. The quality of the modelling was weak, the documentation/description was inadequate and the model used for contaminant transport is questionable.

Proponent’s response

Approximate number of times comment received – Groups:1

The water budget, which includes groundwater flow directions to/from the Site and the groundwater flux across the Site is discussed in the Volume III of the EA. The model was documented fully and in a manner that allows for replication. Volume III documents the modelling approach, conceptual model development, discretization, material properties, boundary conditions, and calibration. Based on review comments provided by the MOECC the quality of the modelling, the documentation/description and the type of model used were not considered weak, inadequate or questionable.

Status

The ministry is satisfied with the response.

Comment #19

The presence of VOCs in the groundwater was not explained and indicates that the hydrogeology of the Site is not really understood.

Proponent’s response

Approximate number of times comment received – Groups:1

The reporting of low-level Volatile Organic Compounds (VOCs) in selected monitors at the Site is not representative of the groundwater quality. The low-level VOCs were detected, with only one exception, during a single monitoring session and may be due to sample or lab interferences. In each case, the levels detected were below the Ontario Drinking Water Quality Standards (where drinking water standards exist). In 2014, groundwater quality monitoring additional to that included in the draft and final EA was conducted. The groundwater quality monitoring program included 14 locations in total. VOCs were not detected at any location in 2014, with the exception of benzene at one single well.

Status

The ministry is satisfied with the response.

Comment #20

The levels of chloride in the groundwater are high. The proponent should demonstrate the CRRRC will not increase them.

Proponent’s response

Approximate number of times comment received – Groups:1

The method used for the contaminant transport model conservatively estimated the predicted peak chloride concentration that could potentially migrate from the landfill to the silty layer over time. The method is conservative in that it doesn’t account for: 1) removal of chloride mass via advection from the silty layer to the leachate collection system while the leachate collection system is operating, and 2) diffusion of chloride mass from the silty layer to the leachate collection system after the source concentration in the landfill reduces below the median concentration in the silty layer (890 mg/L). Golder has re-run the model incorporating the background concentrations of chloride in the silty layer and glacial till. The modelling results indicate no chloride impact to the silty layer from the landfill. The original model and the re-run of the model was peer reviewed by Dr. Kerry Rowe, the author of the Pollute model, who was in agreement with the method and the conclusions. The re-run modelling results were provided to the MOECC.

Status

The ministry is satisfied with the response.

Comment #21
  1. The EA did not identify numerous wildlife and plant communities believed to be living within the Site.
  2. The proponent excluded independent observers from the Site.
  3. The EA does not project what ecological communities will develop on the Site during and after the excavation or covering of the landfill, and does not discuss the threat of invasive species, already present on the Site, spreading onto and dominating disturbed ground.
  4. The CRRRC will have negative impacts on wildlife and vegetation, including species at risk. Impacts include habitat loss, destruction of diverse vegetation communities (with ecological degradation extending beyond the exact area of the Site), contamination of groundwater and contamination of Bear Brook Creek.
Proponent’s response

Approximate number of times comment received – Forms:197 Individuals:12 Groups:3

  1. Wildlife and wildlife habitat were thoroughly assessed in accordance with the approved ToR using both a desktop review of existing data and data collected through multiple field surveys by experienced biologists and technicians.
  2. Taggart Miller did not exclude independent observers from the Site. During the winter of 2013 several e-mails were shared via City Councilor Blais’ office where Taggart-Miller offered to permit the Capital Region Citizens Coalition for the Protection of the Environment (CRCCPE) scientists on the CRRRC Boundary Road Site to study the biology on the Site. The CRCCPE never responded to this offer.
  3. As part of the closure plan, a rehabilitation plan will be developed and implemented to re-establish vegetation communities in the project footprint, subject to determination of the final end use plan for the Site.
  4. The biological assessment concludes that the CRRRC will not result in any adverse effects to wildlife and that any changes to and/or effects on wildlife and wildlife habitat that may occur are not considered to be ecologically important.

The potential impacts from the proposed CRRRC, including surface water and groundwater, have been carefully considered in accordance with the approved ToR and are described in the EA document package. No off-Site contamination of groundwater or of Bear Brook is predicted and a comprehensive monitoring program is proposed to ensure this is the case.

Status

The ministry is satisfied that Ministry of Natural resources and Forestry’s (MNRF) review of the EA considered these matters and there are no outstanding issues.

Comment #22

Standard sources of knowledge about biota and natural history were neglected and no experts are cited as having reviewed the assessments of particular taxa.

Proponent’s response

Approximate number of times comment received – Groups:2

Standard databases were used for background information on the Site, in accordance with the approved ToR. As described in Section 3.1 of TSD #4, all references used are those accepted by the relevant agencies, including the MNRF.

All field surveys were conducted by senior biologists and biology field technicians with a minimum of 16 years of experience and all field surveys are documented with the names of the biologists involved.

Status

The ministry is satisfied that an assessment of the biology relevant to the area was included in the EA and was reviewed by MNRF.

Comment #22

Biological surveys were completed at inappropriate times, some of the surveys were not adequately described and adequate information from the surveys was not provided.

Proponent’s response

Approximate number of times comment received – Groups:1

Surveys were conducted by senior biologists and biology technicians, who are recognized by MNRF, using approved methods, during the appropriate timeframes and during the appropriate weather conditions and in accordance with the approved ToR. All species observed (including signs of the species) or heard were recorded, and all conditions at the time of the surveys were recorded and mapped to an appropriate level of detail for technical review by the MNRF and the public.

Status

The ministry is satisfied with MNRF’s review of the EA.

Comment #23

There is no discussion of the importance of the Site in providing ecological connectivity.

Proponent’s response

Approximate number of times comment received – Groups:1

The biological assessment considers not only the Site, but also the Site in context of the region. Using air photo interpretation and review of existing reports such as those from South Nation Conservation (SNC), the City and the Nature Conservancy of Canada (NCC), as well as field surveys, the function of the Site in the regional context was assessed including the connectivity of the habitats in the region and the role of the Site. The wildlife habitat in the Site-vicinity is patchy, disturbed and fragmented. Further, the NCC also identifies a wildlife corridor north of both the Site and Highway417 from the Vars Forest, directly across Boundary Road to a natural area connected to the Mer Bleue further to the west/northwest; thiscorridor, which provides direct linkage from the Forests to natural areas further northwest without having to cross Highway 417, remains available to allow wildlife movement in the area. To the extent there may be wildlife movement across Highway 417, the vegetation to the south of Devine Road would provide a continued movement corridor to the area west of Boundary Road. Based on the data collected during the field surveys on the Site, there were no signs of an existing wildlife movement corridor on the Site such as heavily used game trails or high numbers of wildlife.

Status

The ministry is satisfied with MNRF’s review of the EA.

Comment #24

The conclusions regarding the effects of the proposed CRRRC on the biological environment have not considered all factors such as the cumulative impact of this project with others in the area, the difficulty of on-Site species relocating to nearby areas, decreased availability of food, increased wildlife vehicle collisions and compromising the flood buffering capabilities of the Site.

Proponent’s response

Approximate number of times comment received – Groups:1

The cumulative impact assessment in the EA found no biologically significant cumulative impacts of the CRRRC and neighbouring existing or probable projects.

The biology assessment concluded that there will be no effects to the regional populations of wildlife that currently use the Site. Available forage habitat in the surrounding region is not expected to decline. Although it is possible that there may be a modest increase in road kill of amphibians and reptiles during operations, the increase will not be material or ecologically important. Boundary Road and Highway 417 are already heavily travelled routes.

Although there will be more runoff from the Site post-construction, as there will be more areas with steeper slopes and hard surfaces, the proposed Stormwater Management (SWM) controls will reduce the peak flow rate to existing levels.

Status

The ministry is satisfied with MNRF’s review of the EA.

Comment #25

The CRRRC will impact local surface water features, such as Shaw Creek and Bearbrook Creek either from contaminant migration in surface water or if processed leachate is discharged into local drainages rather than accepted at the City of Ottawa ROPEC facility.

Proponent’s response

Approximate number of times comment received – Individuals:3 Groups:4

The CRRRC and its surface water control features are predicted to result in surface water quality and quantity conditions that are comparable to existing conditions. Post-closure, the SWM ponds will continue to operate, to ensure surface water quantity downstream of the Site remains comparable to existing conditions. There are no plans to discharge Site leachate to local drainage features.

Status

The ministry is satisfied with the response.

Comment #26

The EA does not account for the combined traffic impacts from major development/industrial projects proposed in the area of the Site. The EA underestimates the number of trucks and staff vehicles going to and from the Site. Roads will deteriorate and additional infrastructure will be needed to accommodate the increased traffic volume. There will be congestion of nearby roadways, the potential for accidents will increase, and ground vibrations caused by the heavy trucks will impact the residences and other buildings (exacerbated by the presence of “Leda Clay”).

Proponent’s response

Approximate number of times comment received – Forms:225 Individuals:21 Groups:2

The EA describes the traffic assessment, which accounts for the expected Site-related commercial traffic and assesses the potential worst case traffic impacts in the area of the Site at the peak a.m. and p.m. hour as is the accepted approach for this type of study. Staff vehicle traffic will not generally overlap with the peak hour commercial traffic. The assessment concludes that traffic associated with the CRRRC can be readily handled by the road network with the addition of a left turn lane on Boundary Road into the Site.

A cumulative impact assessment of existing and probable developments was competed and is described in the EA. That assessment plus the addendum to the traffic study posted on the project website address, to the satisfaction of the Ministry of Transportation (MTO), potential cumulative traffic impacts.

The relatively low volume of additional Site-related traffic associated with the proposed CRRRC on Boundary Road is unlikely to increase the magnitude of the vibrations felt (which if in fact experienced are due to a combination of various factors, the most important of which is the condition/smoothness of the road surface).

Status

The ministry is satisfied with the response and MTO’s review of the EA.

Comment #27
  1. The EA does not properly assess the potential harmful effects of the proposed project on adjacent high-quality farm land.
  2. Farm crops will absorb airborne toxins. The effects of air quality to biology and agriculture do not meet the standards for an EA level assessment.
Proponent’s response

Approximate number of times comment received – Forms:236 Individuals:11 Groups:3

  1. The agricultural assessment is described in the EA. The assessment considered potential effects of the CRRRC on on-Site and off-Site agricultural land and land uses in accordance with the approved ToR. The conclusion of the assessment is that the CRRRC development is compatible and no adverse off-Site agricultural impacts of any significance are predicted.
  2. The results of the air quality assessment indicate that the predicted emissions comply with MOECC air requirements. The MOECC air quality guidelines are developed to consider both human and ecological risk, where applicable. It is common practice in EAs to use them to determine if there will be an adverse effect on the natural environment, including agricultural plant species. The findings of the air quality assessment were used in the assessment of potential impacts on agricultural activities (i.e., agricultural productive potential, livestock, farming practices) as described in the EA.
Status

The ministry is satisfied that the proponent completed an assessment of potential effects to agricultural land in the EA.

Comment #28

The odour and the noise related to daily operations and truck traffic will be offensive. The air quality will be impacted and unsafe due to the significant emissions and odours. The air quality impacts from increased traffic along Boundary Road were not included.

Proponent’s response

Approximate number of times comment received – Individuals:20 Groups:3

The potential effects of the proposed CRRRC on air quality were assessed as reported in the EA and demonstrate compliance with MOECC standards.

The acoustic assessment is documented in the EA and also demonstrates compliance with MOECC noise guidelines.

The approved ToR did not contemplate assessment of off-Site traffic air emissions on Boundary Road or Highway 417 or anywhere else. These trucks are already on the road managing existing waste. Site-related traffic will not be material in comparison to existing background traffic on Boundary Road and Highway 417, and would not materially affect existing air quality.

Status

The ministry is satisfied with the response.

Comment #29

The air quality/odour assessment did not follow a standard EA methodology, did not provide rationale for not assessing the construction and closure phases and did not include potentially significant sources of fugitive dust.

Proponent’s response

Approximate number of times comment received – Groups:1

As indicated in the Air Technical Support Document (TSD) #3, the operational phase was quantitatively assessed against the MOECC standards as it would represent the worst case air quality impacts.

The significant fugitive dust emissions sources from the CRRRC are included in the Air Quality Assessment. Fugitive dust best management practices will be implemented to mitigate potential wind erosion emissions.

Status

The ministry is satisfied with the response.

Comment #30

Change to baseline conditions should have been used in the cumulative effects assessment.

Proponent’s response

Approximate number of times comment received – Groups:1

Taggart Miller assessed cumulative effects in accordance with the Minister approved ToR. Canadian Environmental Assessment Agency (CEAA) guidance was considered as well as cumulative impact assessment practice in the United States.

Predicted effects have been described relative to selected standards, but have also been described numerically, where applicable, in an absolute sense.

Status

The ministry is satisfied that a cumulative effects assessment was included in the EA in accordance with the approved ToR.

Comment #31

Site specific atmospheric monitoring that was referenced in the ToR was not completed.

Proponent’s response

Site-specific noise studies to assess existing background levels were completed. During preparation of the EA it was determined that Site-specific background measurements for air quality and meteorological data would not have been of sufficient data quantity or quality to substitute for the government datasets used. The approach used is considered acceptable.

Status

The ministry is satisfied with the response.

Comment #32

The landfill will be visually unappealing.

Proponent’s response

Approximate number of times comment received – Individuals:4

The visual assessment of the CRRRC is described in the EA. The landfill component is well removed from Highway 417 and the Site will be effectively screened.

Status

The ministry is satisfied that a visual assessment was completed as part of the EA.

Comment #33

There are concerns over the impact on human health to the community. There are concerns that waste will release hazardous/toxic contaminants into the air or groundwater or surface water. A Human Health Risk Assessment should have been completed. Pests (rodents and insects) and dangerous wildlife will be attracted by the landfill and will be a potential health or safety hazard.

Proponent’s response

Approximate number of times comment received – Individuals:7 Groups:1

The potential impacts from the proposed CRRRC, including surface water, groundwater and air emissions, have been carefully considered in accordance with the approved ToR using MOECC standards, as described in the EA document package.

Taggart Miller does not believe a formal human health risk assessment is necessary or appropriate. The studies completed adequately evaluate potential effects in terms of risks, since the standards against which expected performance have been compared are mainly risk based and are generally set by the MOECC to protect human health and the environment. A formal human health risk assessment was not a requirement of the approved Terms of Reference for this EA.

With the implementation of standard mitigation measures, use of the Site by nuisance wildlife and pests is not anticipated to be of concern.

Status

The ministry is satisfied that the assessment of potential effects was completed in accordance with the approved ToR.

Comment #34

The CRRRC will negatively impact the social atmosphere or character of the nearby communities. No Social Impact Assessment (SIA) was performed as part of the EA.

Proponent’s response

Approximate number of times comment received – Individuals:5 Groups:2

Socio-economic impacts were assessed in accordance with the approved ToR and are documented in the EA. The ToR did not contemplate a formal SIA. With respect to the need for an SIA, Taggart Miller commented as follows in responding to similar input received at the ToR stage:

“Measurable changes to population, if any, are not expected to result from the project, and therefore ‘population’ is excluded from the evaluation. Accordingly, potential effects related to population change on access to and capacity of services and infrastructure are also not included.

Economics will be considered in the assessment with respect to employment opportunities, municipal tax revenue, and beneficial and adverse effects on local businesses.

Effects on residents and communities would be associated with effects due to air quality, noise, water quality, biology, land use, economics and visual aesthetics, which are all to be considered in the EA”.

Status

The ministry is satisfied that the assessment of potential socio-economic impacts was completed in accordance with the approved ToR.

Comment #35

The proposed engineering controls are temporary and cannot prevent impacts to the environment. The proponent will not safely maintain the Site after its life is complete. Who is responsible for inspecting the Site, monitoring water control during and after the Site’s life? Who is accountable?

Proponent’s response

Approximate number of times comment received – Individuals:3

The owner of a waste management facility is required to file and have approved a closure plan. The plan will require Taggart Miller to inspect the Site and continue monitoring programs after closure of the Site. The MOECC also requires that privately owned waste management facilities set aside a sum of money (referred to as Financial Assurance) to be used for the closure of the Site, post-closure care and monitoring of the Site and for implementation of contingency plans if required. Having this money set aside ensures that post closure care of the Site will occur if the owner abandons the Site. The money that is set aside is deposited with the MOECC.

Status

The ministry is satisfied with the response.

Comment #36

The cumulative effects assessment is too generalized and vague and VECs were not assessed.

Proponent’s response

Approximate number of times comment received – Groups:1

Taggart Miller assessed cumulative effects in accordance with the Minister approved ToR. CEAA guidance was considered as well as cumulative impact assessment practice in the U.S. As clearly stated in Section 13.2.1 of Volume I: “Valued Ecosystem Components“ (VECs) for this analysis were taken from the list of components used in the assessment of environmental effects of the CRRRC…”

Status

The ministry is satisfied that a cumulative effects assessment was included in the EA in accordance with the approved ToR.

Comment #37

The monitoring programs need to be more comprehensive.

Proponent’s response

Approximate number of times comment received – Groups:1

The monitoring programs proposed by Taggart Miller are comprehensive, cover the issues identified in the EA studies that warrant monitoring, and satisfy the expectations of MOECC and other regulatory agencies.

Status

The ministry is satisfied that a monitoring plan will be implemented for the proposed undertaking.

Comment #38

The best management practices do not clearly show up in the assessment of effects.

Proponent’s response

Approximate number of times comment received – Groups:1

Table 11.10-1 summarizes the in-design mitigation measures and best practices proposed for the CRRRC, together with the predicted net effects for each environmental component assessed. The in-design mitigation measures and best management practices have been assumed in carrying out the effects assessment as described in Section 11.1 of Volume I.

Status

The ministry is satisfied that the proponent will implemented the Best Management Practices (BMPs) as committed to in the EA.

Comment #39

On page 22 in Response to Wallach – Critical Review of Geoscientific Component of TMES EA Final Version, February 2, 2015, Taggart Miller/Golder wrote: "Lastly, Wallach (2015, page 16) states that "the clay foundation is liquefiable". Marine clays are not generally liquefiable because they are cohesive and too fine grained to develop sufficient pore pressures during strong shaking. Wallach presents no evidence to the contrary."

Leda clay, a particular type of marine clay, is the exact opposite of what is claimed by the proponent. It is, in fact, generally liquefiable due to the salt in its structure. When moistened by fresh water the sodium ions in the salt are attracted to the clay particles, and its crystalline structure is suddenly reduced into randomized sliding flakes. A number of articles were provided on this topic.

Proponent’s response

Approximate number of times comment received – Individuals:1

The articles provided on landslides of sensitive clay slopes adjacent to water courses, where after the landslide was initiated the clay soil behind and adjacent to the failure area is left in an over-steepened unstable condition and continues to fail through what is termed a ‘flow slide’ and can result in a relatively large total landslide area. This is due to the well-known ‘sensitivity’ of the marine clay soil, which is different than ‘liquefaction’.

Sensitivity refers to the ratio of the undisturbed strength of the silty clay soil to its ‘remoulded’ strength after it has been disturbed/sheared. In marine silty clay soils, the sensitivity is typically fairly high, meaning that these soils retain only a small portion of their original undisturbed strength after they have been disturbed/sheared. The ‘flow slides’ described in the articles are the movement of disturbed, weakened clay soils after they have undergone movement associated with an initial slope instability.

The Canadian Foundation Engineering Manual (CFEM) is a good reference to explain the topic of liquefaction (which is a distinctly different phenomenon). Section 6 of the manual is on Earthquake-Resistant Design. Subsection 6.6 is on liquefaction associated with seismic loading conditions and key relevant points are as follows:

  • Seismic liquefaction refers to a sudden loss in soil strength and stiffness due to the cyclic loading effects of an earthquake;
  • The response of the soil to an earthquake depends on the mechanical properties of the soil layers, the depth to the water table and the duration and intensity of the earthquake;
  • Liquefaction is restricted primarily to more recently deposited sands and silts with a high water table;
  • Two of the factors that influence the liquefaction potential of a site are the soil type (saturated granular soils, especially fine loose sands with poor drainage conditions are susceptible to liquefaction) and the relative density of the soil (loose soils are more susceptible to liquefaction that more dense soils, noting that the terms loose and dense refer to granular soils and not more fine grained silty clay soils); and,
  • The susceptibility of cohesive (clayey) soils to liquefaction is variable and depends largely on their plasticity, with cohesive soils having a plasticity index of greater than 20% being classified as ‘not susceptible’ (Figure 6.15 in the CFEM).

Based on the laboratory testing carried out on the unweathered silty clay soils obtained from investigations at the Boundary Road site, the plasticity index values generally range from about 27% to 58%, indicating a relatively high plasticity soil (and therefore, based on Table 6.15 of the CFEM, not susceptible to liquefaction).

What is key to understand is that, as described above, liquefaction-susceptible soils are loose granular soils or cohesive soils of low plasticity. In contrast, the Boundary Road site and surrounding area are underlain by relatively high plasticity cohesive marine silty clay soils. Therefore, The statement by Golder Associates in the response to Mr. Wallach’s comments is an accurate description of the liquefaction potential of the Boundary Road site under seismic loading.

Status

The ministry is satisfied with the response. Natural Resources Canada (NRCan) and the Ontario Geological Survey will review Golder’s report, as well as any public comments received related to subsurface structure during the Ministry Review period and the proponent’s responses, prior to a Minister’s decision on the proposed undertaking.

Comment #40

From Response to Wallach – Critical Review of Geoscientific Component of TMES EA Final Version, February 2, 2015

For the water well with coordinates 470331, 5020572, the elevation of the Carlsbad is at 55 m. In checking the Excel Files for the published paper, I had changed the elevation from 55 m to 72 m, because of a unit labeled "Red Limestone" in the driller’s record. I suspected that unit was a red-coated limestone, with the red color having coated the Carlsbad from the overlying Queenston, a common feature of rock in the area, particularly on Cholowski Hill. In addition I believed the rock described as limestone belonged to the Carlsbad because there are no thick red limestone units within the Queenston in this area. Most likely the red unit, identified by the driller as limestone, was probably shale or mudrock, thus I fell for a driller’s error. The gray limestone, which would be Carlsbad, is at an elevation of from 55 to 57 m. I would really appreciate it if Golder Associates would confirm my suspicion of the red rock.

Proponent’s response

Approximate number of times comment received – Individuals:1

Based on the description on the driller’s log, the upper portion of the bedrock (described as ‘red limestone’ between 15 and 65 foot depth) was previously interpreted by Golder as being Queenston shale because of the reported red colour, consistent with commenter’s revised interpretation.

Status

The ministry is satisfied with the response.

Appendix C: Supplemental information

Contents are available in hard copy at the public record locations listed in this ministry review.