Critique of Golder's "Environmental Assessment"

The draft report “Environmental Assessment – Wildwood Landfill Expansion-Catalyst Paper Corporation – Wildwood, B.C. [sic]” prepared by Golder Associates, which was distributed at the April 18th “Open House”, contains 189 pages, three appendices,  and various photos, tables and illustrations.

None of the factors that define the present site as unsuitable for use as a landfill are dealt with in the technical report prepared by Golder Associates. The report is incomplete and unreliable. It does not seem to recognize what already exists on the site, nor does 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.

The following critique of the Environmental Assessment can be characterized by means these four categories:

• Omissions
• Faulty Assumptions
• Inadequate Data
• Errors

Proximity

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 by the hole for the plastic rings. The picture on the cover implies that the landfill is alone in its placement, rather than adjacent to people.

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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. (see overhead images here) The only route to and through Wildwood and other communities North, 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.

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 Townsite is ignored.

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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.

No graphical or verbal data exists about the siting of the landfall site and its proximity to significant populations exists except for an acknowledgement that some residences and a convenience store are between 100 & 300 metres from the site. This convenience store also has a food preparation/restaurant included which is overlooked in the prior paragraph of the report and stated otherwise.

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. (Highlighted below in red)

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This manipulation of information is again displayed on “FIGURE 4- ORTHOPHOTO”, however three of the homes near the landfill are still visible. (Highlighted again in red below)

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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.

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 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 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 are 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 whatsoever.

• The definition of what is to be acceptable for disposal is far too general and borders on the meaningless. Only flyash from Boiler #19 should be specified.  As the proposal is currently worded, the mill could burn anything, no matter how dangerous, and dump any type of toxic residue they want.

• Rules for the landfilling should specify that no more than 100 square meters of uncovered flyash 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 flyash ever be driven on.

• 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 flyash.

Conceptual Closure Plan

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.

• Data input for climate modeling is also insufficient as there is no discussion of the trends due to climate change where we experience the same rainfall in shorter more intense downpours as well as longer, hotter dry spells. What are the impacts of these effects which are expected to intensify over time to slumping of the earth cover over the ash and survival of plants growing in that cover?

• No reference is made to the weather of the period in question. How many days did it rain?

In appendix 1 of the assessment report (I-6) it states:
“Dustfall measurements occurred during the relatively dry summer months and as a result, observed dustfall rates are expected to represent a worst case scenario.”

In fact, the study was not made in the “hot dry summer months”.  The bulk of the testing took place in what would be considered autumn, when the average precipitation is considerably greater that the driest month of July. To truly be considered a “worst case scenario”, testing would have to have been  undertaken in July. The data was collected for a week between August 15 and August 21, then stopped for 16 days, then resumed again on September  7 through October 3. It rained for 1 hour during the time that the canisters were closed to collection. It rained for 32  hours during the time the canisters were re-opened in the fall. The conditions were wet during the dustfall collection and not “hot and dry” as the assessment asserts.  The dust kicked up during the time of testing was mitigated by the fact that it was raining much of the time.

• 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.

Canister placement – Dust section

• 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 parameters of the dustfall survey are incomplete since it states that it regards only "nuisance dust" and disregards any health effects. This dust blows into a populated area zoned RA1 where residents grow food gardens and have livestock.

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 flyash. 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.

Long term low levels of fly ash dust exposure are also correlated with silicosis, increased incidences of autoimmune disease, and silica dust is classified as a known human carcinogen. One of the three types of silicosis mentioned in the MSDS includes simple chronic silicosis- which results from long term exposure (more than 20 years) to low amounts of respirable crystalline silica. Nodules of chronic inflammation form in the lungs and chest lymph nodes. This disease may feature breathlessness and may resemble chronic obstructive pulmonary disease.

All samples in the dustfall study had detectable silicon levels.

Throughout the assessment, rather than taking the real health concerns of the public into account, the authors are dismissive of the dust as being a mere nuisance or irritant.

The dust deposition study analyzed total dustfall, fixed (inorganic) dustfall and metals. Given that flyash slurry is known to contain dioxins and furans, it would be reasonable to assume that dust from the ash would also contain dioxins and furans.  There was no mention in the report that dustfall samples had been analyzed for dioxin and furan content. There are no recognized safe limits for these chemicals individually and they are recognized as a major cause of all cancers. Catalyst should undertake to remove these from the slurry, thereby taking responsibility for its waste, reducing the risk of residents, and rendering the waste safer for some as yet unidentified use in the future.

• The report minimizes the problems inherent in the original landfill and is full of assumptions as to the viability of the original landfill regarding its ability to support the new intended waste and maintain its current integrity which is itself contentious. There are problems there which have as yet to be addressed.

 

It is stated in the report that the operational lifespan will be up to 37 years and that the yearly savings to the company are, in today’s dollars, $1.5 - $2 million. In today’s dollars that would be up to $74 Million and likely in dollar values at the time of closure many times that amount. It is also stated that there will be monitoring for 25 years beyond the projected closure of the site. Residents living close to the site have been told that the site was to be closed permanently by representatives of the company in the past. That trust has obviously been broken and we therefore request that a significant bond be posted for the costs of monitoring and future clean up of this site. Also that Catalyst undertake for the removal of all dioxins & furans from further waste produced and deposited.

• No plan has been shown regarding the proposed filling of the new landfill or discussion regarding dust suppression as it is being filled except for the possibility of water trucks driving on the ash. This can only kick up more dust and should not be allowed. This lack of a plan is very disturbing.

Most telling in the paragraph “Prediction Confidence” is the statement: “ No other warranty, expressed or implied, is made.”