Letter 40: Consultant's Report

Re: Consultant's Report on Catalyst Landfill in Wildwood

Dear Ms Warriner,

The authors of the recently released "Data Review and Compliance Assessment Report, Wildwood Landfill, Powell River", have a very significant last sentence in their report. In that last sentence, they quote a letter by Dr. Paul Martiquet "…the Ministry of Health also views this process [to decommission the existing industrial landfill] as an important means of protecting the area groundwater from further degradation and looks forward to the completion of the closure." There is little ambiguity in that statement.

For the most part, this recently released report seems to have a thorough grasp of the complexities of the Wildwood Landfill. It is also encouraging to see acknowledged the presence of fissures within the underlying rock structure beneath the landfill which provide passage for liquids from within the landfill (p. 40).

However, there are a few minor errors-----the Wildwood Landfill is in the City of Powell River, and not "….located north-east of the town of Powell River" (p vii); and on page 24, the fish will be found in Haslam Lake, not in "Hasman Lake".

Another inaccuracy is found in Figure 4.4, and the surrounding discussion, by using the title "MONITORING WELLS IN THE BEDROCK FLOW ZONE" to describe the flow which is next to the bedrock itself. In fact there is no monitoring of the flow "IN" the bedrock itself. This is a particularly important distinction to make. There is a flow within and through the fractures in the underlying bedrock, and this has not been previously addressed. The liquid that is being sampled is at the boundary of the rock and the soil.

A continuing deficiency of the whole discussion and analysis is also called into question by addressing the subsurface water flow Figure 4.4 ([NEXT TO] BEDROCK FLOW ZONE) and Figure 4.3 (REGIONAL FLOW ZONE). In all the topographic representations of the landfill, the topography of the surrounding area is not fully given. Please note that the topographic figures leave the area to the north east of the landfill as a complete blank. It is completely ignored. This implies that the area ignored is of no consequence. That area also has a topography that is above the level of the landfill. This will influence the flow of water by adding more water to flow to and through the landfill as well as directing the actual route the water will take. This deficiency also applies to all of the Golder Report as well. There is more liquid being introduced into this system which remains unaccounted for.

The discussion surrounding the performance of the mini-landfill can best be described as a case where not all "HELP" is a help. The authors of this report seem to reluctantly accept the use of the Hydrological Evaluation of Landfill Performance (HELP) model as used by Golder and Associates, in ascribing the amount of water lost to evaporation in the mini-landfill. The 19% annual evaporation rate is for losses from open water. Since the design of the landfill is such that during times of precipitation, any water arriving on the site is collected and conducted away from the surface, this leaves very little moisture to be evaporated during times of low humidity. Also, since much of the surface of the mini-landfill is also covered, there is a much smaller area that is open for evaporation to take place than the area that is functioning as the collection area. I expect that the reference to Dr. Ilja Tromp-van Meerveld expecting a rate closer to 10% to 15% from exposed soils (p. 39) would be a more accurate approximation of what actual losses take place. Even then, the lower figure might also still be too high. If the water is not there, it can't be lost to evaporation.

In the analysis of the performance of the mini-landfill, the authors of this report are correct when they say "….the results of any modeling to date must be viewed with some degree of scepticism." (p.40) The amounts of water being introduced into the mini-landfill must be reassessed as the catchment area is increased due to a "…portion of the phase 1 landfill adjacent to the mini-landfill which has settled and now appears to be contributing water to the mini-landfill"(p. 39). As recently as last Thursday, I looked down onto the landfill and the area contributing water to the mini-landfill appears to include a significant portion of the asphalt covered phase 1 landfill. The authors of this report also should apply the same "…degree of scepticism" (p.40) to the conclusion when they say "… there appear to be no significant impacts as a result of the leak"(p. 40)" A very real probability is that any extra water is migrating down and into fractures within the bedrock below the landfill. This water will be conducted off the site with no monitoring taking place at all. In fact, due to the nature of the fractured rock, there is a very real probability that this water is being introduced into Powell River through the fissures in the rock which is below the normal surface of the water in the river.

One route for water to leave the landfill is in fact through the fractures within the bedrock. The whole issue of measurable pollution entering Powell River was publicly introduced when, during a time of low water level in the summer months, a "black ooz" was seen emerging from the rocks in an area that normally was below water level. At that time, this was brought to the attention of the management of the local mill. The "black ooz" was analysed and soon the mill was placed on bottled drinking water. Another, ultimate, result was the capping of the original landfill and the creation of the mini-landfill. But what has always intrigued me is just how the whole issue of pollution being within the fractured rock has been kept out of the formal analysis of the landfill. The fact that pollution was first found to be entering Powell River from the rocks seems to have been ignored. Was this fact "forgotten" or was it hidden? Also, when the original landfill was being capped, there was a time when some of the rock below the landfill was blasted in order to use a rock crusher to create aggregate for the completion of the job. Such blasting would have had the effect of increasing any fractures, which already was known to exist in the rock below the landfill.

The most commonly referred to location for the pollution entering the River from the rock face is in a zone of rock which only becomes visible when the level of Powell River falls during times of low rainfall. This zone of rock is roughly positioned along the 'up-hill side' where the 'old bridge' used to be. This is near the current location where the electric high voltage lines cross Powell River, but also towards the dam from that. The rocks form a ledge which is between 10'-17' below the normal water level. On this ledge, there is a fissure which is filled with sand. At times of low water, it takes about a week till the "black ooz" begins to emerge. This 'sand bar' is about 40 feet long. There are several local residents who can place the location with a high degree of precision [I have permission from these people to give you their names, at your request].

Despite the contention by Golder and Associates, on behalf of Catalyst Paper, that the levels of dioxins and furans found in the samples from the mill Filter house are of no significance, there is every likelihood that there are pollutants entering the environment. For them to contend this is to ignore the "certificate of assurance" that there is a 99% Confidence interval in the laboratory work. Such a "certificate of assurance" is presented as part of the Golder report. Also, if there is doubt cast on the figures from the mill filter house, then the same doubt must also be applied to all other figures from the sampling of the wells.

Incidentally, in the discussion on levels of dioxins and furans, the report states that "[t]he Wildwood landfill data has been reported primarily using the NATO approach and therefore the TEQs derived following the NATO approach were assessed in this report (p. 25)". This is in contrast with information given by Ms Cindy Walsh, a member of the B. C. Ministry of Environment, at the July 18, 2007 Catalyst Community Stakeholder Committee meeting, that the Ministry of Environment uses the WHO approach in preference. Is this in fact the case?

Also, in the discussion of on the various weights of the dioxin and furan molecules, the "…higher weight dioxin/furan molecules indicates the source is primarily from combustion (Bright 1999) (p.31)''. Isn't the ash in the landfill also a product of combustion?

I concur that additional investigations need to be done to determine how, where and in what amounts pollution is entering Powell River. Until now, the presence of pollution travelling through the fractures in the underlying rock has been ignored. The proposed SPMD and/or XAD sampling would begin to address this oversight. The sampling profile described on page 41 of the report would be a good beginning. This would provide a generalized matrix to identify pollutants in Powell River. In addition to the distribution of sampling stations which is described to find a non-specific source of pollution entering the river, a further array of sampling stations should be positioned by the identified sources. It is very probable that pollution is entering the river at more points than have been identified by local residents.

Another issue that must be considered is that when the analysis is done on the various sampling stations, it seems there is a consistent pattern that forms over the yearly cycle. There seems to be a higher level of pollutants in samples taken in late November and early December, and lower levels found in the dry months. It appears there is a flushing effect in the yearly variation of levels.

It is also a good idea that sediment toxicity sampling takes place. As well, an analysis of the micro-organisms that are normally found in these waters should be done. This analysis should also extend to the invertebrates and other marine dwellers. Maybe, we will discover why there never appears to be any presence of mergansers and ducks on Powell River-they are present further up on Powell Lake, but not near the dam.

Thank you for asking that this independent analysis be done on the information which is within the current files associated with this landfill. The questions that are raised by some of the information that curiously is not included in this information must now be addressed. The performance of this landfill must be assessed to assure that it is not in anyway damaging the environment, before any further consideration can be given to any expansion of its capacity-and more particularly, in such an expansion as is proposed. A vertical "landfill" defies logic as it like filling a "vertical hole".

The last sentence of this report does indeed provide the most useful direction "…to decommission the existing industrial landfill…[is] an important means of protecting the area groundwater from further degradation and [we] look forward to the completion of the closure."

Yours truly,

David Harris