Letter 37: Fatal flaws in the final Golder report

RE: Response to Environmental Assessment, Wildwood Landfill Expansion of Catalyst Paper-Powell River Division.

Dear Ms Warriner,

I have received a copy of the "Environmental Assessment, Wildwood Landfill Expansion, Powell River, B.C." While I have taken this from the electronic media presence of Catalyst Paper, I note the reservations of the authors of the report as they declare, "… electronic media versions of Golder's work product cannot be relied on." [p. 45, Golder Associates, 2007] I have also received a physical copy of this work, and I can detect no differences, so I have continued with the version that first became available to me.

In general, this report is much easier to read than the earlier, draft version, but it maintains many of the previous version's inaccuracies and invents some new ones. Also, many of the omissions of the former version persist.

One of the problems with this report appears to be the result of a misreading of the Environmental Management Act [EMA] and its regulations. For the authors to state that "[t]here are presently no regulatory criteria or standards for the siting [sic] of industrial landfills in British Columbia." [p. 20] is to engage in a rather juvenile form of bravado. There might not be any standards with the explicit title of "Industrial Standards and Criteria", but it is clear that Catalyst must operate with a permit issued under the EMA which states in Section 120(3), that this statute makes it an offence to discharge waste from a prescribed industry or activity without proper authorization. These criteria also clearly apply to this landfill as it is defined in -
"Section 2. Applicability, sub-section 2.1 -New Landfills and Lateral Expansions" as found in "Landfill Criteria for Municipal Solid Waste". Any further question as to applicability is addressed in "Section 3. Landfill Classifications" where it states, in part "The intent of these criteria is to set Sanitary Landfills as the goal for all MSW landfills…"

Whether it is because of this misreading of the EMA by the authors, or for some other reason, many of the provisions which are "mandatory (M)" within the regulations, have not been addressed in this report. If something is mandated, there is no discretion as to what standards must apply. All parties to this application must address and meet the mandated items as a minimum standard. In fact, the Manager, at his or her discretion, may only make "the siting [sic] and operating criteria for these landfills …[to] be made more stringent to reduce impacts on the environment." [3.2 Modified Sanitary Landfills]

I shall closely follow the format of the "Landfill Criteria for Municipal Solid Waste'' as it applies to the application of Catalyst Paper- Powell River Division and to the Golder Associates report which accompanies it.

1) Information in Common-

As part of this report, there are some maps and tables that accompany and are common to the report. There are some mistakes in these documents. Due to the general nature of this information, these inaccuracies are addressed first.

The following figures have inaccurate or misleading information-
A) Figure 2--- MINI-LANDFILL LINING SYSTEM
- the drawing does not represent the conditions as they are currently installed.

B) Figure 5--- SOIL STRATIGRAPHY CROSS-SECTION (A-A)
- Legend should show 'clay'

C) Figure 6----SOIL STRATIGRAPHY CROSS-SECTION (B-B)
- legend should show 'clay'
- no reference is made to the shore of Powell River
- no reference is made to the level of water in Powell River.

D) Figure 8--- SURROUNDING LANDS
- does not show what is situated within the mandated distance of 300 meters in any direction of the landfill site.

E) Figure 9--- CROSS-SECTION THROUGH LANDFILL (SECTION C-C)
- does not identify the Phase 1 landfill
- does not provide any measurement or scale for the Phase 1 landfill.

F) Figure 10--- CONCEPTUAL MODEL OF GROUNDWATER FLOW
- placement of bedrock at edge of Powell River is incorrect.

G) Table 11 C-2 ---" Dissolved Metals Analysis"
- No results for wells PW 95-1 (11 meters), PW 99-2 (19 meters), PW 99-4 (19 meters)), and PW 99-5 (29 meters).

H) Table E II C-3--- "Results of Chlorinated and Non-Chlorinated Phenol Analyses''
- No results for wells PW 95-1 (11 meters), PW 99-1 (19 meters). PW 99-2 (19 meters), PW 99-4 (19 meters), PW 99-5 (29 meters),

I) Table II C-5---"Results of Dioxin and Furan Analyses"
- No results for wells PW 99-1 (11meters), PW 99-2 (19 meters), PW 99-4 919 meters)

2) Performance Criteria (M)

There seem to be two goals intended in these criteria -
--to reduce the amount of waste entering the landfill through practices of the 3 R's, and
--to reduce the likelihood of contaminated dust or water from leaving this site.
These criteria ask that other options be investigated.

Since there are many problems associated with this site, alternate options for handling the fly ash are imperative. No new problems should add to the deficiencies already at this site.

It is almost unbelievable that since 1995, at least, the management of this pulp and paper operation has made public pronouncements of seeking practical uses for the fly ash they produce, but only three options were mentioned as uses for the fly ash. It seems that Catalyst views the option of the 3 R's as only a matter of convenience to itself. If there are uses for the fly ash, there will not be the need for a landfill. How can this company be so different than almost all other places in the world, that this company uses 0% of its fly ash, while other places utilize up to 100% of the fly ash they produce? Please inform the company that finding a use for the fly ash is a matter of prime importance which must be pursued as a matter of priority.

For instance, even now, as this application for an expansion of the landfill in Wildwood sits before you, a proposal for the use of the fly ash in a manufacturing process has been presented to Catalyst. That proposal also carries the possibility of a research grant along with it. Yet the response of the company to this proposal was to inform the proponents that Catalyst had no interest in pursuing this option until after a new permit was firmly in place and then they might look at the proposal to use the fly ash-a "don't call us, we'll call you" attitude. This indifferent attitude towards finding a solution to the problem of limiting waste, by creating a use for the fly ash, must be challenged and changed.

It is interesting to note that Catalyst Paper is also seeking an expansion of the landfill that is associated with their Elk Falls operation in Campbell River. Why does Catalyst not investigate the option of combining and consolidating the whole of their landfill options? Indeed, one alternative might be that the company could set up a separate facility to also receive fly ash from all the mills on the coast-this would make a profitable option for the company as well as provide options for the local operation. Centralizing a fly ash operation would also provide increased opportunities to find uses and markets for this material. Providing a rational approach to the handling and storage of waste products seems to work to the advantage of the Rebanco operation-This rational approach could also be used to advantage here. There seems to be a "need" to deal with fly ash and its disposal, which extends beyond the boarders of this mill. These combined options need to be fully investigated before any more demands are placed on local operations.

The Golder Associates report, on page 4, seems to imply that the Catalyst Community Stakeholder Committee gave some sort of approval to the option referred to as "Phase 2". As a member of that committee, may I advise you that many reservations were expressed about pursuing that option. The Phase 2 option was discussed, but not given any sort of approval.

The second goal of these criteria seems to have been completely missed. The regulations make mention of utilizing temporary structures and covers to minimize the area exposed to the weathering forces of the sun, the air and the water. The operating procedures proposed for this landfill make no mention of these options at all. The whole question of dust generation and leachate formation could almost be eliminated in its entirety if the landfill were operated so that there would be a very small active disposal area within the landfill. If that active area was entirely under a temporary, moveable structure, which contained the whole of the exposed material being deposited on the site, there would be no occasion for dust to be formed and leachate to be generated. Once the area within the structure or cover is filled to capacity, and before that structure was moved to the next location, a more permanent cover should be placed over the now filled zone. The covering / filling/securing sequence would then be repeated in the next module. -The fly ash should almost never be exposed to the atmosphere. The fly ash would always have either a temporary structure or a permanent covering over it. At no time should the fly ash ever be driven on.

3) Ground and Surface Water Quality Impairment (M)

There are several interconnected issues which surround the whole issue of how the water moves over and through the ground. There is the ongoing issue of what already is happening with the leachate from
- the original landfill, and
-from the mini-landfill and
-from the proposed expansion.

A) The existing landfill

There is contaminated water, which is entering the water of Powell River. This contaminated water must be of a significant nature and quantity for it to show up as consistently as it does in water tested at the Mill Filter house [Table II-C-5]. This also seems to be a long-standing pattern with similar results being reported over many years. This leachate is most probably being conducted as "[g]roundwater within bedrock [and] is inferred to discharge as underflow to Powell River." [p.15] It is known to enter Powell River from the zone of fractured rock beneath the water surface. This zone is often exposed to view when the level of Powell Lake is brought down for electrical generation during extended dry periods. Indeed, it was just such a discovery that led to the original testing and determination of contamination entering Powell River that resulted in the closing of the original landfill. This zone of fractured rock is not always accessible as the water level in Powell River must drop significantly to expose this rock zone. There doesn't seem to be much of a probability of that happening this year due to the amount of water and snow in the Powell River catchment area.

The flow of leachate is into the zone of fractured rock beneath the various layers of perched water contained in the soil below the landfill. This is consistent with the pattern of "Concentrations of leachate indicator parameters generally tend to decrease with depth and with increasing distance along the flow path away from the Phase 1 landfill." [p.17] The water is flowing down into the zone of fractured rock and not laterally through the soil. A further indication of this is evident in comparing the sampling analyses of wells #89-5 (11 meters) and #AH-6L (29 meters). Both wells show elevated levels of contaminants [Table II-C- 2, Table II-C-3, Table II-C-5]. Both wells appear to be in the same 'plume', which is not sampled again before it reaches and discharges into Powell River.

Unfortunately there are no volume measurements or flow rates provided for any discharges from the landfill stated anywhere in this report. We can only guess as to the impact and volumes of water that is moving.

Please note that in a previous freedom of information request, the following quotes were found from an Aggra Report from 1992.
"Although the levels measured at the spring are within standards, the report indicates a complex set of pathways for contaminants to travel from the landfill to the lake so other sources flowing to the lake could have much higher levels than the spring that was sampled."
"As stated by HBT Aggra, not all the flow from the landfill area can be accounted for by the volume seeping from the scarp face: there must be a groundwater component from the landfill directly into Powell River that has not been investigated."
These reports are available to your office.

The information presented on Figure 10-CONCEPTUAL MODEL OF GROUNDWATER FLOW is seriously challenged by the occurrence of the contaminants entering Powell River. For one thing, no provision is made in the conceptual model to show the presence of a zone of fractured rock between the landfill and Powell River. Also, this figure shows that there is a very significant zone in which no sampling of any manner is happening beneath the 29-meter zone, which shows contamination in effect. The limits of contaminants in the soil have not been established.

B) Mini-landfill

There are problems associated with the mini-landfill. The information presented in Figure 2-MINI-LANDFILL LINING SYSTEM exist only as a design criteria. The reports that have been given me by people who actually worked on the construction of the site consistently challenge the information in that figure.

Beginning at the uppermost layer, the geotextile exists mainly as shredded cloth within and beneath the compacted soil cover "above" it. During the construction process, the cloth would often catch on the blade of the soil moving equipment, and rip into shreds. After repeated attempts to spread and cover the cloth failed, the focus became just to contain the cloth within the compacted soil. This had the effect of adding the compacted soil to the leachate collection system gravel below this layer. The result was to have a single layer of compacted soil with a course aggregate above the HDPE Geomembrane.

When the Geomembrane was installed, care was taken to ensure there was complete coverage and that all seams were sealed. However, when it came to distributing the "leachate collection system - gravel" above the membrane, problems arose in distributing and compacting this gravel up the incline. At least one of the operators of the caterpillars that were distributing the gravel recounts getting his blade caught in the membrane, but being told to just continue on. Also, there were problems with the compactor going up the slope-at least one of the compactors had difficulty climbing the slope over the loose aggregate. A different compactor was brought in-one with spikes on its rear wheel. Each time it mounted the slope, it perforated the membrane below the gravel.

When the "leak detection system" was put in place, pipes were placed in a matrix of gravel. Here again there were problems covering that layer with the geotextile. When the cloth was placed over the gravel below, and the Bentonite clay soil was being distributed over the pipes that were placed in the area, the grader operator was directed by the person on the transit to keep lowering his blade as he distributed the bentonite soil. He was directed to do this until he had exposed each pipe and also had "pealed off a strip along most of the length of the pipe. Once the pipes were open, he was directed to keep on distributing the soil with the result that the pipes were filled with compacted soil. So when the Golder Associates report states, "According to Catalyst, the sump below the mini-landfill is checked weekly for leachate and this is reported annually. Catalyst has never detected leachate in the leak detection sump of the mini-landfill." [p.14]---no wonder.

Further information from the people who were building the landfill also challenges the 'official' version of how the mini-landfill operates. At one point, early in the site preparation stage for the mini-landfill, the excavation was being prepared to come down to the intended depth. A spot of very wet soil was uncovered on the bottom of the excavation near where the intended exit was to have been installed. This area was dug out with an excavator and it almost immediately filled with water. This water had several pumps placed in it to attempt to empty the water. Despite several weeks of effort, and the addition of several more pumps, this showed no sign of diminishing the water level. The decision was made to extend the excavation further south-east, into a zone which had already received deposited waste, but which was dry. The "underground lake" was filled in and a compactor was sent over the area. When the compactor would pass over the portion of the landfill that was between the wet zone and the extended excavation, a strange thing began to occur. Each time the compactor would go over that one spot, the water in a toilet in a house trailer which was across Highway 101 from the landfill, and easily over 200 meters distance, would begin to form standing wave patterns. After several days of this, it began to become a part of the expected results. Since this occurred only when a compactor was on that one spot, the assumption was that this corresponded to a firm rock saddle, which extended in that direction. This also provided a significant explanation as to why the water above that point remained in that one spot as an 'underground lake'. What is unclear is where that water is coming from and where it is going. It probably is leaving the site along a pathway that has not been identified at all.

At the new location for the leachate collection system pump, a hole was quickly excavated, and filled with large, clean and round rocks. A system of 5 pipes were quickly run into this 'sump" and the whole was covered with the membrane. The consensus is that this 'sump', which is in a dry zone, functions as a water dispersal point (a 'dry well') and the leachate pump acts more as an overflow pump than as primary extraction pump.

The presence of the leachate entering the soil as if it were a 'deep point injection system', is given further support when the flow from just such a spot would occur as a plume, is encountered at well #89-5 (11 meters) and #AH6L (29 meters). ---These wells appear to be in or near the plume from just such a point source of water. Further, the pattern of contaminants found at these two spots would suggest that the water would have been migrating through the soil for some considerable distance. We know that there is a significant volume of leachate captured at these wells, but we have no way of assessing how much water passes this point and proceeds to Powell River. We just know that it must be significant to show up as consistently as it does in the Powell River water which is tested in the Mill Filter house.

I have no confidence at all in any of the "official" explanations as to how the mini-landfill operates. Catalyst has not released the volumes of water/leachate which it pumps at the mini-landfill. If these volumes were known and an accurate assessment made of just how much water enters the mini-landfill from the asphalt apron which surrounds it,--which are alluded to in, "Surface water near the site consists of ephemeral water courses (including those on the asphalt final cover) that flow during rainfall events."[p. 23], a realistic assessment can be made as to how much water escapes from the mini-landfill. Another method, and by far the simplest method to determine the degree of leakage from the landfill, is to close the entrance to the pump (and the exit from the min-landfill) and see how long it takes for water to accumulate. If the system is secure, water should immediately rise and should be visible within the landfill after only a few days or a week. If there were leaks, no such volume of water would accumulate. Until the security of the landfill is fully demonstrated, it is more reasonable, and more consistent with the known contaminant plume, which exists, and the known fact that contamination is entering Powell River, to assume that the mini-landfill is leaking.

Further, we know that beneath the miini-landfill there is the presence of a rock zone which has high integrity and which is bordered by a 'dry' zone which is adjacent to the firm rock and which is very near the base of the 'sump'. This would have the effect of conducting a large portion of the water, directly into the zone of fractured rock and then into Powell River. Much the same result is alluded to by Andrew (Drew) H. Kilback in his 2001 master's thesis, "Assessment of Groundwater Remediation at an Industrial Landfill Site", when he states "Groundwater within bedrock is inferred to discharge as underflow to Powell River."[p.4]----once he states this as a factor, he does not return to this explanation, however it is also supported by Mr. Kilback's reasoning.

C) The proposed expansion-
Parts of the proposed water management system proposed to handle any water which falls onto the site and enters the ground, only makes sense if you also assume that everything works as it is designed-a very tenuous assumption. But there are three glaring exceptions.

i) Large volumes of leachate are needlessly formed if this plan is followed. Large areas of fly ash are proposed to be deposited on the site, All of which is open for action from the weather. In the section on operational procedures, it has as a design criteria, that exposure to the open environment be limited. To follow that criteria would be the more prudent approach as it would minimize and cover the area that are receiving fly ash so that no rain or wind would have the chance to meet any stored fly ash. When the temporary cover is removed, the fly ash should receive its permanent cover. Any water that falls on the site would just be surface run off water. The fly ash should not have the chance of making leachate which in turn must be processed.

ii) The calculation of pipe diameter size for the handling of leachate generated is inadequate---in the extreme. The presence, condition and performance of the leachate delivery pipe is theoretical and even at this level, it is unreasonable to assume that because of its already designed inadequacies, a receiving pond, or "active pond" would need to be built to overcome the already acknowledged inadequacies of the pipe. A much safer solution would entail the principle of 3.C.i above. If leachate is not formed, it doesn't need to be handled. If the pipe diameter is inadequate, then a new system of pipes must be installed.

iii) The very thought of adding an "active pond" to accept the surge effects of handling the leachate because an inadequate delivery system exists as the need for such a pond, borders on the bizarre. This is patently absurd. Something along the lines of, "let's build in an inadequacy because we can, then build in another inadequacy" There are no design criteria mentioned for the "active pond", and as such, the "active pond" should have no status in this plan. The presence of having such a 'pond' would also add significant factors of danger in the event of an earthquake occurring while the pond contained water. The pond could be easily compromised and the contained water would add lubrication to any shaking that was happening with the result that the factors of liquefaction would greatly increase. Again, the solution is in changing the handling practises so that no leachate is ever formed as the result of rain falling on the deposited fly ash.

4) Landfill Gas Management and odour Nuisance (M)
This is one section that seems to be well covered in the report, by its omission.

5) Public Health, Safety and Nuisance (M)
A) Traffic -
The presence of at least two cement trucks going up and down the Wildwood hill and crossing the highway over a double painted line on Highway 101 will undoubtedly result in some sort of traffic accident. By the virtue of the size of the trucks in respect to that of an automobile, this will result in injuries to someone from the public. I imagine that the incidence of mishap will result in an accident every five years or so. Redesigning the truck entrance to the landfill would affect the simplest increase in safety-it should be at a spot where increased visibility is available. Although a new 'automatic gate' has been installed, the entrance to the landfill is still very unsafe.

B) Noise -
The sounds from the new site will convey the sounds of trucks backing up; the sound of brakes and the sound of hydraulic systems at work into the neighbourhood. This will become a factor especially if a shift system of delivery to the landfill were established. Since most of the mill operates on a full week, round the clock schedule, there will be a time when these sounds will intrude themselves into the neighbourhood. This site is not appropriate for further use as an industrial purpose. -This is omitted from the Golder Report.

C) Sight -
This site is already above the level of the highway which passes close beside the site. The activity at the landfill is now fully visible from the highway. When the hours of darkness increase and the trucks and equipment utilize lights, this intrusion into the neighbourhood is unavoidable. Again, this site is not in an appropriate location. The issue of sight of the site is out of sight in the report as it is omitted.

D) Dust
The issue of dust generation at the landfill is of great concern. The dust studies done at the site are consistently not reassuring in any capacity. Not only was the most recent dust study, the Golder study in September to October, 2006, done at the site conducted
-during a time of damp /foggy weather,
-over a too short period to provide an accurate picture,
-utilized a collection system which did not capture a full spectrum of particles from the landfill,
-the canisters were placed in quiet zones which had large trees as a background with the result that air was diverted away from the canisters (the canisters were placed in a 'null' zone).

Also, such statements as "dustfall (generally particles greater than 10 um) is not considered to be a health issue because according to MOE "only particles that are smaller than 10 micrometers in diameter (10 um) can be breathed into our lungs to any extent." [p. 9] while strictly true, are not reassuring. This reflects the bias of the authors that dust is something they wish to trivialize. It has been a very real problem in the past, and continues to carry that potential.

It might be more accurate to refer to the particles smaller than 100 um as Total Suspended Particulate (Tsp). These TSP are of health concern and have not been addressed in any of the "dust" studies. Since the proposed landfill will be entirely above ground level, this has the effect of increasing both the possibility and the efficiency of gathering TSP and dust into the air. Also since this increased probability and opportunity also correspond to an increase of distance that the TSP are distributed, a corresponding increase in a zone of safety around the landfill should be established.

May I propose that for the safety of people, that a landfill of this sort should not be closer than at least 500 meters from any people at the same elevation of the landfill, and from 1000 meters from any people who are below the elevation of the landfill. This would effectively prevent this landfill to be located and operated at the present site as almost all of Wildwood and also almost all of the Townsite of Powell River are within that range. Even using the current distances of 50 meters and 300 meters, this landfill should no longer be there as significant numbers of residences are within those distances. Also, there is an elementary school within Wildwood, which is directly downwind from the landfill at a distance of 575 meters. [ If distance of 1000 meters were to be considered, a second elementary school, in the Townsite, would be identified.]

This criterion alone is enough to reject the application to utilize this site as a landfill.

Incidentally, the inclusion of
Figure 6: Particulate Matter (PM 10) in Wildwood [p. I-12] and
Figure 7: Particulate Matter (PM 2.5) in Wildwood [p. I-13]
serve only to cast doubt as to the effectiveness of the monitoring device itself. By just looking at the results displayed, just what is it that is being measured? It is impossible to even tell what season of the year is being recorded in either chart. There is no seasonal variation evident. So, what is it that is being measured?

6) Siting Criteria (M)
This is a factor that cannot be ignored just because a landfill has been deposited at this site. An appraisal of this site shows that according to Schedule 1,Table 1 -Composite-all of the following apply.

-A- Water Contamination --#1 & #2,
-B-Site Air Contamination -#1, #4, #5,
-C-Wild life Conflicts- #1 [this is on the Pacific flyway]
-D- Transportation -#1, #2, #3,
-E- Social- #1, #2,
-F- Economic - #1, #2, #3, #4, #5, #6

For this to be somehow exempted from consideration because a pre-existing use has been attached to it is to overlook the obvious. This site would not qualify as a new site. Also, no such assessment has ever been done on this site, and as such, the site has not been granted clear status.
If this were a brand new proposal, this site would not be given even the briefest of considerations. This application for a permit amendment in many ways defines this as a new site. The volume is proposed to increase to hold 8 times the current capacity-a massive increase. The proposal also changes the very definition of what is at issue. This is no longer a landfill but rather a construction above ground, It is "an environmental protection structure (i.e. a structure with the purpose of protecting the environment)" [p. 9]. This also is without precedence. Normally such industrial functions are kept at a discrete distance from people, but this proposal is to have a large, totally visible structure adjacent to, and above an established neighbourhood. Again, if this were a new application, this site would not be considered suitable. This is a mandated criterion, and it must be considered. As such, this application should be rejected.

The history of this site is that this land was first used as a landfill without any authorization or permit. It began as an illegal dump. The first permit was granted to this operation without any land use assessment being done. Over the years, no land use assessment has been done whenever a permit amendment has been issued. For a permit to be granted now without a complete land use assessment would be to perpetuate a situation where one party benefits from a crime. This landfill was begun as an illegal operation, and to continue it further will be similar to someone benefiting from the use of stolen property.

7) Property boundary (M) and 8) Other Facilities (M)

As stated earlier, Figure 8 SURROUNDING LANDS is inaccurate. This figure should show what is located within a distance of 50 meters and 300 meters, at the very least. If a rational assessment of risks to the local community were assessed for TSP, this also should show what is located up to 1000 meters from the site.

As it is now, a public highway which is the only access route for anyone travelling to or from Wildwood, or any point beyond, travels within a distance of 300 meters of the landfill for over ½ kilometre distance. This is the only route to, through and past the community and any traveller must transit this section of highway. If a public park within a distance of 300 meters can exclude the site from consideration as a landfill, surely a highway should share the same status.

Within a distance of 50 meters, there are at least 7 residences. Within a distance of 300 meters from the landfill are a further 80 residences. At a distance of about 150 meters, there is a small restaurant/ coffee bar and neighbourhood store. Most of these residences have been built before the landfill began its illegal beginning.

9) Airports (M)
Please note that there is now a proposal to build an airport almost adjacent to the landfill. And, what is also strange is that Catalyst Paper-Powell River is a party to both applications.

I am including a plan presented to the B.C. Agricultural Land Commission, which shows this information.

10) Surface Water (M) and

11) Floodplain (M)
Neither appear to be at issue.

12) Unstable Area (M)
Here again, the proposal does not meet ministry guidelines. The Phase 2 landfill is to be situated over both the mini-landfill and the Phase 1 landfill.

So this places the landfill
---in an area defined as being unstable and subject to earthquakes
+ high on a steep slope with alternating layers of sand and clay
+ over a body of water
+ above a hydro-electric dam
+ over an old landfill site which is non-homogenous
+ over a landfill which has waste deposits of over 20 meters depth
+ over a landfill which has included within it old barrels and storage tanks (not all of which are collapsed)
+ the landfill has compacted fill often with a high moisture content
+ over a landfill with unknown concentrations of organic matter such as contaminated hog fuel
+ a rock outcropping which could anchor the site was removed by blasting to provide crushed rock fill during the construction of the landfill
+ an " active pond' to store water is being proposed to be placed where its rupture during an earthquake would greatly increase the lubricant needed in any soil which will "liquefy''
+ there are signs that the slope is already beginning to move as trees are all leaning in one direction.
=insanity.

Can they be serious?

13) Other Excluded Areas (M)
This appears to be one of the few which do not automatically disqualify this site.

14) Landfill Design Approach (M)
This can use some serious attention. If the goal is to minimize environmental impact, then a system which keeps all of the fly ash away from exposure to abrasion, sunlight, air passage and water erosion. Any discharge onto the landfill should be within temporary structures so as to prevent erosion factors from applying. The site should be quickly and continuously be covered by a secure fill which can be allowed to support vegetation to also minimize excursions into the surrounding environment. There should never be any occasion for a truck to drive on the fly ash-not only will that abrade the fly ash, it will introduce fly ash onto the truck and its tires, with the effect of distributing the ash throughout the neighbourhood.

15) Water (M)
This seems to be adequately covered in this report.

16) Final Cover (M)
The placement of a final cover should be an ongoing process of the site. The cover should be placed over the fly ash at the earliest possible opportunity.

17) Access Road (M)
This seems to be adequately covered in the report.

18) Design by Qualified Persons (M)
I hope the authors of this report are so qualified.

19) Prohibited Wastes- (M)
Does this permit amendment application include provisions to accept the demolition material from the old kraft mill in Powell River?
This is an unnecessary concession to the company and only serves to complicate matters.

Any addition to this site should be clearly limited to fly ash from # 19 Power Boiler only.

20) Signs (M)
This is not an issue.

21) Scavenging (M)
We can only hope that fly ash becomes so valuable that it becomes the target for scavenging. If that happens, there won't be a need for this landfill.

22) Dust Control (M)
This appears to be directed towards the nuisance dust from the site. Please refer to my earlier comments.

23) Waste Compaction and Covering (M) & 24) Litter Control (M) & 25)Vectors (M), & 26) Wildlife (M) & 26) Open Burning (M)
These do not appear to be an issue.

27) Monitoring (M)
While there is a recent history of monitoring and reporting some activities from the landfill, not all important information is being given to the Ministry of Environment. For instance, the volumes of leachate from the mini-landfill are not given to the Ministry. This places the Ministry, and by extension, the whole public at a significant disadvantage as this information is unobtainable. There should be no information that is considered to be proprietary in nature.

28) Record Keeping (M) & 29) Annual Report (M)
Neither appear to be an issue, with the exception noted above.

30) Closure Plans (M)
The closure of this operation should be almost seamless and be a function of the standard operating procedure of adding a final secure cover to the fly ash at the earliest possible time so as to prevent any fly ash being exposed to the atmosphere.

31) Financial
This is the one area that is within the scope of discretion of the manager.

There are several issues involved here; all of which suggest that the company should offer a significant financial security as it applies to this landfill. The whole of Catalyst Paper appears to be in a state of financial jeopardy. If anything were to happen that would require a clean up, it is an open question if there are enough funds in the company to finance such an order. This applies to what is already in the existing and mini-landfill as well as to the proposed expansion.

Finally, please go further than to just reject this application. Please declare this site a contaminated site. Please order a site remediation or at the very least, a Pollution Abatement Order. It is clear that pollution is still entering Powell River and that the terms of a previous Pollution Abatement Order (#13462) have not been met.

By examining the mandated criteria, you must reject this application, There are many reasons to easily justify such a decision. One of these reasons might just be a simple matter of not exposing your ministry, your department and yourself to the embarrassment which will result when the source of pollution which enters Powell River is exposed for public view which will inevitably happen when the water level drops in the lake.

But, a more persuasive reason to reject this application exists because it is the ''right thing to do''.

Yours truly,
David Harris.

Cc: Dr. Sarah Barkowski- Manager, Environment & Quality Systems, Catalyst Paper-Powell River Division.
www.Prlegacy.org