Letter 41: Ongoing Concerns About the Wildwood Landfill

Re: Wildwood landfill -  Permit  #PR-04565

Dear Ms  Warriner,  

The minutes of the March 6, 2008 Catalyst Community Stakeholder Committee – Meeting #35, arrived yesterday. The reference on page 2, “Susan indicated she is now re-reading the Golder  EA report, the Hatfield consultants report, and the consultation report…..” with no mention being made of any assessment of the present site and its performance, has prompted me to respond. I have compiled a list of basic concerns about the existing Catalyst Paper –Powell River Division landfill in Wildwood. These are ongoing concerns and questions about the present landfill.

It makes very little sense to extend a permit, if the state of the permitted landfill is so precarious as to call into question its basic performance. Such is the case here.

The ongoing concerns and questions are-

1. Location of the site—too close to people—do people count?

          The site is within 100 meters of 7 residences,

1. 300 meters of 90 residences,
2. 150 meters of a community store and coffee shop,
3. 500 meters of an elementary school,
4. the main transportation route, Highway 101, is within 300 meters of the site for almost a kilometre. Anyone coming to the community, or even passing through is exposed to the landfill,
5. prevailing wind patterns are such that the winds coming to the community of Wildwood must pass over the landfill first,
6. the scope of the amendment application to expand the capacity of the landfill site by a factor of 8 times, places this amendment beyond a simple change to the site, but is in fact has the power of a new application,
7. the unprecedented manner of storage of the industrial waste so that it is above the ground has the effect of making this a new application as well.

This site does not meet the British Columbia Ministry of Environment guidelines to site municipal waste storage sites. Such guidelines should apply to an industrial site. But, in any case, the company has said that it would abide by these guidelines in relation to the landfill if there were a question.

2.  The site is a poor choice for a landfill –is it safe?

          A. The site is situated at a height of land, directly above Powell River with an existing hydroelectric dam also directly below the landfill. The slope of the bank to the river is steep; often at 60 degrees from the horizontal. Much of the soil along this slope is made up of layers of sand and gravel interspersed with clay layers. All of this is over a base of granite rock which contains fractures and fissures.
Water movement from the landfill site is complex. Water moves along the surface. It also flows through the soil. As it follows the various clay layers, it often forms discrete flow patterns. It also flows through cracks in the rock, where it enters the river below the surface of the river.
          Since this site is situated along the coastline of British Columbia, this is within an area known to be prone to earthquakes. Any overburden of material above the river and dam will place whatever is below in jeopardy.
 
          B. The recent revelation by Catalyst Paper Corporation in a prospectus filed in fulfillment of a corporate financing endeavour, indicates that the company may not be carrying enough insurance coverage to pay for the damage done in an earthquake is particularly timely as this may indicate that the landfill may also not be adequately covered if it were left up to the decision of the company. Are there adequate financial mechanisms in place to ensure that full coverage is in effect if damage occurs?

          This information can be found on ---
http://www.catalystpaper.com/investors/investors_financialreports_informationcirculars.xml

                      and accessing the February 29, 2008 ,“Prospectus……”.

3. The use of the site

          A. What is in the old portion of the landfill?
When the landfill was first utilized, it was in an era when the operating principle seemed to be ‘out of sight-out of mind’. As a result there are many things in the landfill which would not be allowed into any landfill today. Such things as barrels of anti-sap stain solutions, paint and paint thinners, lubrication fluids and solvents all were sent to the landfill. Also, the standards of record keeping were rather casual. Catalyst Paper acknowledges this. Never-the-less, as complete an inventory as possible should be attempted. Has this been asked of the company?

          B. Given that the previous records are so poor, has a system of drilling been requested to provide an inventory of what is in the site? If this is deemed to be too precarious, then should not all further use of the site be stopped and the site secured?

          C. We know that there have been at least six transformers, and possibly as many as twenty transformers, that have been buried on the site. We also know that under the regulations of the Federal Government of Canada, that since 1977, anything containing PCBs must be identified, labelled and inventoried. Have you requested that information?
          We have information from a person who says as part of his job at the old landfill, during its construction, he actually buried two transformers, knocking off a corner of one of them, on the site. He says that he saw five or six more transformers being buried. Another person also tells of seeing two separate groups of transformers, totalling eighteen or nineteen transformers, on the old landfill site. He did not see them actually being buried, but he says he never saw them again either on his subsequent trips to the landfill, nor did he see them elsewhere.

          D. What was done with the PCB containing material that was in the transformers? How much of it ended up in the landfill? If it isn’t in the landfill, can its current location be verified? Where is it?

          E. With the presence of transformers in the site, why is this site not classified as a contaminated site?

4. Collection of leachate from the site

          A. There seems to be a consensus that about 50% (or less) of the leachate that is migrating through the soil is captured. Why is the number not nearer 100%? The design of the landfill, when it was capped, was to rely on a system of “recovery wells” to capture any leachate which escaped the site. There has been thirteen years since the cap was installed. Why is there such a low performance rate?

          B. How can you know how much is actually collected? The measurement of these volumes of the leachate collected is largely unknown. The company has claimed that these volumes are of a proprietary nature, and not released the information. Also, it has been recently revealed that the company was collecting information from meters with faulty calibration.

          C. Why are whole systems of water movement from the landfill being missed? There is direct evidence from eyewitnesses that there is a flow to Powell River through the fractures in the rock that lies under the landfill. This enters the river below the normal surface of the water. This feature is also mentioned in the Golder report when it infers such flow through the bedrock. This also is mentioned in a master’s thesis done on this site. Why is it never acted upon?  No mention is made of this in any of the analysis of the site, nor do the permit requirements mention this. Why not?

          D. The amounts of water arriving on the site from rainfall can be estimated from precipitation figures. The asphalt cap was supposed to prevent any water from entering the landfill by conducting the water off the site.  How effective has this been?  What areas of the asphalt cover conduct the water to the mini-landfill? [On periods with high precipitation, when you look down from the top of rock bluff beside the landfill, you can see the water enter the mini-landfill]. What are the more realistic figures?

          E. How much contaminated water is being conducted off the site without any sort of monitoring at all? The design of the landfill has a portion of the run off from the asphalt cap conducting run off water to the south and also to the northwest boundaries of the landfill. The water which flows to the north joins a surface stream that goes behind the houses along Lund Street, and then behind the Italian Hall, and on to join up with Shoenfield Creek and the ocean.  This water is contaminated. That portion of the asphalt cap is often driven over by traffic going into, and out of, the mini-landfill to deposit the wastes. Any substance from the landfill can be tracked out of the landfill and along the paved surface, and is subsequently carried by the water into the environment. Why is there no monitoring of any kind along this portion of the landfill? Why is this even in the design?

5. Treatment of the leachate

          What is being done to effectively treat the contaminants that are now collected in the leachate? The leachate, once it is collected from the landfill, enters the mill wastewater treatment system. Beyond being diluted as it combines with the greater volumes of mill wastewater, there seems to be little attention paid to the constituents of the leachate. How effective are any treatments?

6. Site Monitoring

          A. Why is the frequency of monitoring so inadequate? Since leachate from some parts of the landfill could enter Powell River as quickly as in 17 days, to monitor these flows on a semi-annual basis is woefully inadequate. This is particularly inadequate when the pattern of annual precipitation is considered. The annual precipitation follows a pattern of dry summers and wet winters. The water flow through the soil will also reflect that fact, with the soil drying out during the summer. The following heavy rains would then flush out any more heavily concentrated solutions of leachate. Such inadequate monitoring will likely miss most of what is passing through the soil.

          B. Why are wells, which have shown high levels of contamination in one year, often not sampled again?  There are frequent gaps in monitoring data. Some of these wells are PW95-1, pW99-2, pW99-4, PW 99-5, 89-2, 89-3, 89-5.  [this is not an exhaustive list]

          C. What is being done to monitor and sample the flow of water from the landfill that flows to the river through the fractures in the rocks? This is being completely ignored.

          D. The Hatfield report concluded that there is too little information about the level of dioxins that are entering the environment by being introduced into Powell River, to come to any conclusions about the effects of dioxins and furans in the river. Will you order that the tests recommended in that report be done?  Are you going to request that more frequent and more appropriate testing be done?

          E. Why are there not tests being done for PCBs?  Transformers are known to be in the landfill and they are likely to have, or have had PCB laden oil in them. Also, PCBs were a part of the sample profile in at least 1992 [but the wells that were sampled showed no PCBs, possibly because they were situated outside of the plume that would emanate from the location the transformers were buried].

          F. Why are some springs below the landfill not sampled? The only spring routinely sampled is “Spring S-1”, but it is not the only spring to have water reach the surface along the slope below the landfill. At least one other continuous spring brings water to the surface about ½ way up the slope. This spring brings water to the surface, only to have the water flow for about 3 meters, before the water disappears back into the soil. This spring has had times when there is a distinct smell of a solvent associated with its location. The times that the smell occurs corresponds to a time when a ‘’flushing effect” would occur---early autumn. Why is this spring not recorded? Why is it not monitored?

          G. Is there a correlation between the time that any samples are taken and when the actual analysis is done for the levels of dioxins and furans? I notice that the results seem to show lower levels of dioxins and furans found whenever the interval between the collection and the analysis of the sample increases. Is this possible that time is a factor? Is this time sensitive?  Would exposure to light or to sunlight have any effect on the dioxins within the water sample?

          H. The presence of dioxins and furans found in at least two samples of water from the Mill Filter House is particularly important. When the factors of dilution are taken into account with the amount of water that passes that point each day, for there to be any measurable amount of dioxins is very disturbing. This would point to a source that is delivering these pollutants on a consistent basis. Where is it and how does it work? For the mill to assert “…it indicates that with respect to dioxins/furans, the river water is about as clean as the laboratory water used in running method blanks.” (page 10, Catalyst Community Stakeholder Committee Meeting 35 Notes 080306.doc) is sad.

          I. There seems to be at least two separate patterns of water flow in and through the landfill. The readings of the leachate from below the capped portion tends to show spikes and variable concentrations from one reading to the next. The sampled leachate that is further to the east, in line from the mini-landfill, tend to be more consistent from one reading to the next. The volumes there also are much greater than from the area beneath the capped portion itself. Also, when you look at the levels the leachate is found, it indicates a source which is introducing the liquid into the system, well below the surface. This would be consistent with water coming into the system from near the bottom of the mini-landfill. Can you account for this in any other way than that this indicates that there are leaks from the mini-landfill?

7. The mini-landfill Leaks

        A. How can you know that the volumes of leachate that are collected from the mini-landfill are accurate when you have not requested this information? Also, when it was given by the company, how can you have any confidence in its accuracy --the company, by its own admission, had not calibrated its meters correctly?

         B. How much water is actually introduced into the mini-landfill? There is water from the surrounding asphalt area which is conducted to the mini-landfill, plus water that is used to wash off the trucks, plus there is water which is discharged from the fly ash/water slurry when it begins to set up?

         C. The pattern of leachate collection from the collection wells is consistent with a source of water being introduced into the system at a point which would correspond with the bottom of the mini-landfill. Also, the presence of a membrane has shown to dry out a portion of what is beneath it, This is shown by the area below the asphalt cap being dry until water is introduced again at a level that would correspond with the bottom of the mini-landfill. If the liner in the mini-landfill were doing its job, it would also be dry beneath the mini-landfill, and the surrounding areas. But it is not dry. This is from the leaks in the mini-landfill. There is a well established subsurface flow in line from the mini-landfill and towards Powell River. Further, only a portion of this flow is being intercepted by the recovery wells. Where else would this liquid be coming from if not from leaks in the mini-landfill?
       There are lots of stories that during construction of the mini-landfill there were a great many holes placed in the liner. Some of the equipment operators were more prone than others to tear the liner. Also, the use of compactors with spikes on the wheels served to perforate the liner, and the use of a vibrating compactor also put holes in the liner when the compactor passed over metal that was buried in the fill below the liner (the operator could hear metal to metal contact on his machine).

         D. The leak detection system is compromised. The company claims that every week they check the leak detection system and they never find any liquid. This may be true. But it doesn’t mean that there are no leaks in the liner. There are stories of how the pipes in the leak detection system were compromised during the installation of the system. In an effort to lower and profile the grade at the bottom of the mini-landfill, the grader scraped open the pipes, and the pipes filled with soil. A more likely explanation of why there never is any water is that there is no functional leak detection system.
          A simple test of this whole system would be to stop the exit pump and see how long it takes to fill the mini-landfill with water. If there are no leaks, then the landfill would quickly fill up. If there are leaks, then it would take a long time indeed. Until this is done, there can be no confidence in any of the claimed performance levels of the mini-landfill and the leak detection system.

        There are so many ongoing concerns, deficiencies and unanswered questions about the existing landfill that any further use of this site is questionable. This site is certainly not appropriate for expansion. At the present time, there probably isn’t enough direct evidence to force a site remediation, but there is more than enough to close the landfill.

              When Catalyst Paper began their application to expand the landfill, the performance of the existing landfill went largely unquestioned. As attention became directed to the landfill, more problems and more questions arose. This process will likely continue. The problems with the existing landfill must be completely solved before any further use is made of the site.

           In some ways, the Catalyst Paper application can be described as building a hole from which they are attempting to dig their way out. The problems keep getting larger.

         I hope this is of some help. Please remember that you speak for the environment for all of us.

         Yours truly,

       David Harris