Letter from Dave Harris

David Harris,
5939 Dease Court,
Powell River, B.C., V8A 5L8,
April 22, 2007.

 

Dr. Sarah Barkowski,
Manager, Environment & Quality Systems,
Catalyst Paper, Powell River Division,
6270 Yew Street,
Powell River, B. C., V8A 4K1.

 

Re: Wildwood Landfill

Dear Dr. Barkowski,

Sometimes what appears to be a good idea from afar loses its attraction on closer inspection. Such is the situation with the current application by Catalyst Paper Ltd. for a vertical expansion to its landfill in Wildwood. This proposal as presented to the public at an ‘Open House” by Catalyst Paper on April 18, 2007, does nothing to lessen the deficiencies that already exist at the current landfill in Wildwood, but also serve to magnify the deficiencies of the site. Other, more appropriate, solutions exist for the handling of the fly ash which is produced as a by-product of the heat generation by Power Boiler #19. These solutions will also have economic and other benefits for Catalyst Paper- and not just to Powell River Division alone.

At various times during the Open House, I was publicly credited as the originator of the concept of having a vertical expansion of the existing landfill in Wildwood. The idea was freely given. However it appears that both Catalyst Paper and Golder Associates have not understood the implications of such an expansion of the facility. While extra storage space is available above the existing site, the limitations of the existing site must be addressed and solved before proceeding further. Only once that is done, can any storage above the existing grade be utilized. It carries its own complexities, which must be identified and solved.

The draft report “Environmental Assessment – Wildwood Landfill Expansion-Catalyst Paper Corporation – Wildwood, B.C. [sic]” prepared by Golder Associates, which was distributed at the recent “Open House”, appears to be seriously deficient. There are many omissions, faulty assumptions, inadequate data and errors presented within it. I will go into more detail further in this letter, but one quick example of a deficiency within the report relates directly to a question and answer from an email from you to me on March 9th, 2007. Under “Questions for Follow-Up:…5. How effective is pumping well 99-5 at capturing water in the 29 meter zone? We have asked Colin Wong at Golder to answer this one.” The report is silent.

The technical report is so deficient that I will only make passing reference to it in the discussion of the existing site and its operation-- both in the past and in the present. Due to its location, the residents of Wildwood have an intimate knowledge of the landfill.

The problems associated with the current landfill site are compounded by the very close proximity this site has to the well-established neighbourhood of Wildwood. The only route to and through Wildwood, Highway 101, passes within 100 meters of the landfill and for over ½ kilometre is within 300 meters of the landfill. Everyone must pass through this zone when entering or leaving Wildwood or to the communities beyond. Several thousand people have no choice except to pass this point, often several times each day. Also the very entrance to the landfill itself further complicates this--it is on a blind corner in a very narrow portion of the highway.

The whole community of Wildwood is in close proximity to the landfill. At least 7 houses are within 100 meters, and a further 90 homes are within 300 meters of the landfill. At a distance of approximately 150 meters from the landfill is a gas station/convenience store/ coffee shop/ restaurant / apartment complex. Also, the prevailing wind pattern is such that most of the neighbourhood of Wildwood, including the local elementary school, is directly down wind of this site. All of Wildwood is affected by the dust from the landfill. Water is also escaping from this site- more so now than even in the past. This current landfill has a daily and persistent impact on the local residents and on any who travel past the landfill.

This has never been a good site for a landfill. Adding to the size and changing the design of the landfill complicates this further. A short recounting of the recent history of this landfill will exemplify that this landfill is inappropriately placed, and has several insurmountable deficiencies

When the existing ‘mini-landfill’ was begun in 1996, the practise of the time was to bring the fly ash from the boilers to the landfill and to just dump it out the back of a waste delivery truck. There was a major attendant problem with dust. This problem was often limited to the landfill itself by the fact that over 1200mm of rain falls on the site. During the dry months, the summer months when people are engaged in outdoor activities, the dust would migrate into the community of Wildwood. This became an identifiable problem and was brought to the attention of the B.C. Ministry of Environment and to the operating company of that time. The fly ash was easily identified at a store, which was about 150 meters down wind of the landfill. This company sold an array of photovoltaic panels and each morning the vendor would wipe the black dust which had combined with the morning dew, from the panels. Each day there would be a sizable amount of very fine black dust on the white paper. On days when he did not wipe the panels, there would be a pattern of dried dust circles on the panels. Also, there was a constant presence of the same fine dust on all the surfaces within the store. When this was brought to the attention of the authorities, the presence of the dust on the panels soon stopped when the company began sending the fly ash to Rebanco, in Washington State. [Please note that this same store space now operates as a coffee shop and restaurant and still is about 150 meters from the landfill.]

Another interesting fact noted by residents of Wildwood at that time was that there was often a smudge of dust on the outside of the windows on the houses within the plume of the dust from the landfill. This dust often was thicker on the windows on the downwind side of the house. Several people told stories of having to clean their windows several times per week. Again, this problem disappeared when the fly ash was no longer brought to the landfill site. The local residents know that the dust from the landfill enters our community.

After several years the landfill has become active again. Catalyst now delivers the fly ash to the landfill as a semi-liquid slurry by way of a cement-mixing truck. This has greatly reduced the amount of dust escaping from the landfill, but it has not eliminated it. Recently some equipment was used in the landfill site to reconfigure the deposited ash. When the ash was moved, clouds of dust were formed and people who were walking their dog well beyond the fence line describe seeing a plume of dust and “tasting’’ the fly ash [“bitter and metallic’’]. Dust is also being generated when the surface of the solidified fly ash is abraded, which happens whenever it is driven over.

Dust is also escaping from the delivery vehicles used to carry the mix of water and fly ash to the landfill. Dust is often caught in the housing of the truck and escapes while the truck is driving--ironically, this is more pronounced on rainy days when the truck is wet. Also dust escapes from the mixing chamber of the truck itself. This is probably due to the fact that a cloud of dust often cascades inside the mixing drum, above the mixed slurry, and the dust escapes as part of each revolution of the mixing drum. I have reported at least one such incident to Catalyst Paper [March 9th-in your absence, to Mr. Murray Jones –I have not received a report of what was discovered]. Other people have also noted the dust escaping the truck and this appears to be the result of the truck travelling before the mixing process is complete. These trucks also have spilled some portion of their loads on the road, and also carry the constant danger of being involved in a serious traffic accident. [The recent work at the entrance to the landfill has certainly decreased the chances of such an accident, but the dangers at that juncture still exist.]

Leachate is also escaping the present site—much of it has not been tracked. As you know, all of the “engineered portion’’ of the present site, often called the “mini-landfill” contains a membrane liner which is designed to capture all the water that enters the mini-landfill and to conduct that water to the mill site for treatment. It appears that massive amounts of leachate are escaping the collection system. If one source of water entering the mini-landfill is from rain, then we know that since the mini-landfill is approximately 2 hectares in size and that approximately 1200mm (1.2 meters) of rain falls on the site each year, then 24,000 cubic meters of water enter the site from that source alone-- plus any runoff water as well as introduced water for dust suppression or truck cleaning. For the year 2005, you reported earlier that the amount of leachate that was collected was 2,398 cubic meters. That accounts for about 10% of the water entering the site. Where are the unaccounted 20,000 cubic meters of water going? It appears that the recent wells that were drilled, as part of the technical study cannot answer that question either.

Not only must these 20,000 cubic meters of escaped leachate be accounted for, they need to be captured and conducted to the mill site for treatment-- or the water entering the mini-landfill must be prevented from doing so. The most logical, and economic solution would be to close this landfill and cover it with an impervious layer of asphalt—the sooner the better. When the other deficiencies of the site are factored in, there really is no other option.

What to do with the fly ash? ---Luckily, you have already demonstrated options, which solve this question. In fact, the options open to you can be quite attractive.

I have consistently mentioned that the solution to the whole question of the fly ash is to treat it as a product. It is in thinking of it as such, that the solution lies. In the past, when the fly ash was sent to Rebanco, the ash had to meet technical specifications for it to travel to and be accepted by Rebanco. The fly ash was put into containers, sealed and secured and then shipped according to specifications. This worked for years, and only ceased to be attractive because of rising costs. Even if in the short term, Catalyst Paper- Powell River Division must now use Rebanco again, it can now utilize the whole concept of mixing water with the fly ash to form a solid. In forming a solid “product” for shipment, handling and transportation costs are significantly lower than using empty canisters that must be handled both when empty and full, and have a unit cost of their own.
Also, once the fly ash is solid, it is acceptable to other, more localized, facilities than just Rebanco. If the fly ash was cast into moulds that formed units of a size and shape which could be handled by the existing mechanical loaders now used to handle paper rolls, great efficiencies could be achieved in loading and offloading rail cars or barges.

While reading the Golder Associates technical report, despite its inadequacies, the discussion regarding the Crofton leachate, introduced the commonality of the fly ash from all the hog fuelled boilers along the coast. If in solving the riddle of what to do with the fly ash generated in Powell River; Catalyst Paper-Powell River Division could then also offer its solution to the other Catalyst Paper mills on this coast. Not only would Catalyst Paper gain a competitive advantage among other paper companies, it would give Powell River Division an advantage within Catalyst Paper itself. All the other mills along this coast are facing, or soon will face, the question of their own waste disposal. The first one to find a solution that can be offered to others within the industry would benefit immensely. Catalyst Paper – Powell River Division is in a strategic position now as it solves this conundrum.

A rational solution would be for Catalyst Paper- Powell River Division to recognize the reality that the landfill in Wildwood does not contain the answers to the waste question. Catalyst Paper- Powell River Division should elect to decommission the landfill as an attempt to solve its deficiencies and to limit the liabilities of the site. A new and separate business entity would probably need to be created to handle the storage of the fly ash solids, and other contracted items to be received. A rational search for an appropriate site, large enough for the entire industry to utilize need not take long. –after all, how many abandoned open pit mine sites are there? Nor should they be overly expensive. Even sites, as close as on Texada Island, offer significant advantages over Powell River due to a much-reduced rainfall.

A further attractive feature of this proposal is that there is a built in incentive for the producers of the ash to find some sort of use for even small portions of the ash being handled. As part of the process, the sending facility that produces the ash would be in a position to easily implement reductions of volumes to be sent out for storage. The sending facility would be able to receive a benefit to itself by already beginning to process the fly ash. And the company in business to receive the solid wastes would be in a position to utilize the raw resource as it is being handled within the storage process itself.

None of the factors that define the present site as unsuitable for use as a landfill are dealt within the technical report prepared by Golder Associates. This report is incomplete, and unreliable. It does not seem to recognize what already exists on the site, nor can it conceptualize the extra areas of impingement that will be the result of increasing the height and volume of the mass to be stored there. The report is so deficient that it has a very limited credibility in any part of the report.

LANDFILL SITE

One of the defining features of the present landfill is its location within the City of Powell River and in adjacent proximity to the neighbourhood of Wildwood. The very picture on the cover of the report serves to remove context from the placement of this landfill. If the picture would have the landfill in the centre of the page, and have a distance equal to the size of the landfill around it, the picture would show several hundred homes. As it is now, there is already one house shown in the picture in the upper left hand corner, and one other house is clipped out of the picture on the copy that I have by the hole for the plastic rings. The picture on the cover implies that the landfill is alone in its placement, rather than to show it as being adjacent to people.

A similar attempt at misdirection occurs in “Figure 1- KEY PLAN”. The neighbourhood of Wildwood is identified with a dot next to it, presumably meant to indicate the centre of Wildwood, on the very edge of Wildwood along Taku Street, a one block long dead-end street. If the dot is to indicate anything like the centre of Wildwood, it should be placed adjacent to the intersection that is nearest the landfill—that is the location of the only convenience store/coffee shop/restaurant in Wildwood. The whole of the Townsite is ignored.

There are also serious errors and omissions in the section dealing with the site of the landfill. The nearest property to the landfill is in fact Highway 101, but no mention is made to the fact that it is the only way to, from and through Wildwood and comes within 100 meters of the landfill and extends to a distance of about ½ kilometre within the distance of 300 meters from the landfill. Also, no mention is made that the next closest boundary to the landfill is only a matter of centimetres beyond the distance to the highway, and that is a home. In fact there are at least 7 homes within a 100 meter distance from the landfill. A further 90 homes are within a 300 meter range of the landfill. At about a range of 150 meters from the landfill is the convenience store/restaurant already alluded to. The attempt to misdirect is also evident on “Figure #3- TOPOGRAPHY”—for unexplained reasons, a portion of the topographic map at the left of the page is left blank. This blank spot would show several of the houses within the 100 meter range. This manipulation of information is again displayed on “FIGURE 4- ORTHOPHOTO”, however three of the homes near the landfill are still visible.

Further, since the pattern of winds is such that the air first passes over the landfill site on its way to where the people live in Wildwood, the historical experience is that any dust from the landfill goes directly to the neighbourhood. This is already happening with the current operation of the landfill. But the proposal is to expand the landfill vertically. The effect of this will be that there will be increased opportunities for the wind to find the dust within the landfill AND that there will be an increase efficiency of the dust becoming airborne [the wind will be able to pick it off a vertical face as well as a horizontal surface] AND the resultant plume will be distributed over a wider and longer area down wind. If a factor of 10 units of horizontal distance are affected by one unit of vertical distance [this is very conservative as in landscaping books the effects of a windbreak are considered to be from 12 to 15 times the vertical height], then the proposed increase in height of 20 meters would add another zone of 200 meters beyond the 300 meter zone already identified, creating 3 zonal areas. This would have the effect of having about 170 homes affected in Wildwood and adding another 40 homes in the Townsite. The elementary school in Wildwood is about 575 meters from the landfill—directly down wind.

Further, the vertical expanded landfill would be visible to people in the Townsite. They would be able to monitor any activity at the site.

The fact that the expansion will extend into space which is above the existing surface, and that will form a new physical and visible presence, has been omitted, and its presence ignored.

EARTHQUAKE SECURITY

This is something that seems to be full of convenient assumptions. Until the actual shape, placement, and characterization of all subsurface bedrock is known, the most limiting figures should be applied so as to minimize future risk.

LEACHATE

The fact that, with nothing to support it, leachate from the landfill in Crofton was used and no reference was made to the leachate from the existing landfill makes this whole section next to useless. If it was desirable to utilize Crofton’s leachate, this could have been done as a parallel set of figures and analysis to what already comes from this power boiler (which we are told is ‘the best’ in North America). To exclude the leachate that is generated from existing conditions, and generated by the same group of people who will operate the proposed landfill expansion, and is generated under a license which is more restrictive than the one being proposed for the new operation, is totally mindless. All analysis using the figures from Crofton is totally irrelevant.

DESIGN CONCEPT

The idea of having a single HDPE liner within a layer of sand to overlay the full area of asphalt is totally inadequate. The lifespan of the proposed expansion is anywhere up to 37 years. If an orderly sequence of filling the landfill is adopted so as to minimize the active zone of addition, it is not inconceivable that parts of this HDPE liner will lay with only a shallow protection of sand for a period of up to the 37 years. If a single HDPE liner is in fact installed, significant efforts will need to be made to assure that the whole of the area is not compromised by vegetation, or excursions of vehicles over the area. A more reasonable strategy would be to cover only the area to be included within the next year or two.

CONCEPTUAL OPERATIONS PLAN

The whole of this section appears not to address any of the issues which will effect a long lived, highly exposed, very vulnerable and highly visible system of depositing waste. The whole of this is of no use what-so-ever.

• The definition of what is to be acceptable for disposal is far too general and borders on the meaningless. Only fly ash from Boiler #19 should be acceptable.
• Rules for the land filling should specify that no more than 100 square meters of uncovered fly ash should be available to the open atmosphere at any one time. This would include both vertical and horizontal surfaces. This would acknowledge that any surface above a surrounding grade is more easily weathered than a smooth flat surface.
• At no time should the fly ash ever be driven on. A system of moveable mats might be needed, but since the solid fly ash is easily abraded, it must be protected from physical weathering.
• A sequence of filling the landfill will be adopted so as to provide a permanent cover over the contents at the earliest possible time. Recognition of the fragile nature of the fly ash can be given by having an increased depth of covering material over any portion of the landfill which is used for access to the rest of the landfill.
• The leachate and surface water control appear to be adequate.
• If at any time there is any airborne dust, changes to the operating procedures, consistent with the above, will be adopted to fully eliminate the dust. At no time should a truck carrying water go over the fly ash.

CONCEPTUAL CLOSUR PLAN

The overlay of soil should probably be increased to over a meter in thickness. After an initial seeding of grasses, the whole of the area should be allowed to follow a natural progression. The soil depth should be adequate to support a fully grown forest.

DUST FALL

Dust is a product of air carrying fine particles of material. The very source of fly ash is from the air. The placement of a source of fine particles within an air stream is an invitation for dust to become airborne and to disperse. The existing landfill already provides dust to be dispersed beyond the boundaries of the landfill. By raising the source of the dust to be dispersed so that it is more central to any air passage, there will be even more dust which is airborne, and this dust will be distributed over a greater area.

The whole of the dust fall study and the conclusions drawn from it are totally inadequate.

• If dust is to be measured, then it is logical that the measurements should coincide with the time most likely to produce dust. The driest time locally is in July, so that should be the time most targeted.
• if a yearly pattern of dust generation is to be interpreted for over a 37 year period, a full year of data would be the minimum time of monitoring. Any interpretation of data which is gathered over a shorter period of time becomes that much more unreliable.
• No reference is made to the weather of the period in question. How many days did it rain?
• What were the wind directions at the site itself? The direction of the wind at the Powell River airport, which is over 6 km away, is a rough guide at best. Also, there are rock outcrops and terrain differences as well as vegetation to be considered locally.
• When dust is generated in the landfill, one source of dust is from the point of the disturbance and another is from the general passing of the wind over the whole site. These dust clouds behave somewhat differently, with a plume formation as a consequence of a point source, hence the placement of the sampling device is of crucial importance. It is easy for a plume to miss a sampling station entirely.
• There is no mention of where in the landfill the activities were taking place.
• There were far too few sampling devices to ensure that all of the exit routes for the air were sampled.
• The sampling stations were placed along and below a line of trees. This tends to be an area of lessened air movement. What would be the measurements if taken from a zone of active air passage?
• The sampling stations were closed during times of dust generation as drill holes were made nearby. One can only assume that these were during days with no rain, this would tend to skew any measurements.
• The sampling stations were placed on the ground, and the source of the dust is from the ground level, yet inferences are being made to apply to a source of dust which is 20 meters above the present level. At the very least, a matrix of sampling stations that would form a grid, both vertically and horizontally should have been utilized.
• No assessment was made as to how far any dust is carried. A second, third or fourth layer of sampling stations should have been utilized.

To come to the conclusion that dust will not be an issue is total conjecture. This has not been the case in the operation of the landfill up till now. In fact, dust from the landfill continues to be a concern.

The statement “The dustfall measured and reported in this report is not linked to health effects, rather it is nuisance dust that is generally considered an irritant.’’ (page I-20 ) is amazing. This ignores the fact that the source of this dust is from fly ash. These are very fine particles and once airborne, travel great distances and once breathed in the body become lodged in the lungs. There is a great co-relation between such dust and all manner of illness—from emphysema to heart disease. Also such dust serves as an insult to people with compromised health.

Unfortunately the statement about dust being of no health concern, serves as a good summary of the whole technical report---people don’t count-their place of residence ignored--their health trivialized—their concerns be ignored. Beyond what has been proposed, nothing is addressed.

Quite frankly, I find this report to be an insult. It adds nothing of substance to the discussion. I also feel sorry for Catalyst Paper who commissioned this study. You didn’t get your money’s worth. But it does highlight the necessity for Catalyst Paper to solve the fly ash issue with some degree of both logic and vision.

I look forward to helping you decommission the present landfill in Wildwood.

Yours truly,

David Harris.

Cc: Brian Baarda, Vice-president, Operations, Catalyst Paper- Powell River Division Susan Woodbine, Environmental Protection Officer, Surrey ,B.C. Ministry of Environment Nicholas Simons, MLA Powell River-Sunshine Coast Honourable Barry Penner, Minister of Environment, for British Columbia

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