Letter 43: File: PR-04565 - Hazardous Waste Site

Re:  File: PR-04565 –Hazardous Waste Site

Dear Mr. Fournier,

Thank you for meeting with me today.

1) On rereading “Permit PR-04565”, which governs the functioning of the Wildwood landfill operated by Catalyst Paper Corporation –Powell River Division, I noticed that in paragraph 2.6

"The waste asbestos authorized for discharge in Section 1.1.2 shall be managed in accordance with the Hazardous Waste Regulation."

would have the effect of defining the Wildwood landfill site as a Hazardous Waste Site. If a Hazardous Waste Site is defined as a site in which hazardous waste is stored, then this would indeed apply to the Wildwood landfill site.

2) Waste asbestos is being deposited at this site and it is defined as a hazardous waste in the “Hazardous Waste Regulation. The waste asbestos can be deposited anywhere within the active area of the permitted site under this permit, so the provisions of the “Hazardous Waste Regulation’’ extend to the whole of the site. This is further indicated in the permit by the description of a single site location in the permit.

3) Unfortunately, the requirements of the “Hazardous Waste Regulation’’ seem to have been forgotten, or ignored, in the current assessment process which is being conducted as part of the current application to amend the permit as is being conducted by Catalyst Paper Corporation-Powell River Division. I urge you to reread the “Hazardous Waste Regulation’’ and inform the applicant that the requirements of that regulation indeed apply to the Wildwood landfill.

4) The recent Golder Associates Report, of July 2007, which was submitted as a part of the reassessment process by Catalyst Paper in support of their application to expand the Wildwood landfill, states,

 “Powell River is located about 250 m downslope from the toe of the Phase 1 landfilll and more than 300 m from the toe of the Phase 2 Landfill.” (page23)

Since the “Hazardous Waste Regulation” calls for a minimum of 300 m of separation from a body of water, this is enough to disqualify this site from further consideration. [The proposal to expand the landfill utilizes all of the landfill as it proposes to deposit the wastes over the Phase 1 portion as well.]

5) The 2006 Annual Report of the Wildwood Landfill, also prepared by Golder Associates for Catalyst Paper, describes the hydrogeology of the Wildwood site.

“Regional groundwater flow occurs in a southeast direction within the upper, fractured zone of the bedrock…..Groundwater within bedrock is inferred to discharge as underflow to Powell River.”(page 6)

This would also have the effect of disqualifying the site as the “Hazardous Waste Regulation” prohibits any storage of waste over a zone of fractured bedrock.

6) The history of the older, capped portion, of the Wildwood landfill has many instances of non-compliance with the “Hazardous Waste Regulation”. None of that area has any sort of a liner under it, let alone, a double liner as required under the regulation. Also there were many hazardous materials deposited in that site. Such things as
-asbestos
-paint
-solvents
-bunker C oil
-anti sap stain compounds
-transformers with PCBs
This would also have the effect of disqualifying this site for further expansion.

7) The presence of residences within the 100 m distance from the site as described in the “Hazardous Waste Regulation” also serve to disqualify this site from further expansion.

8) Please inform Catalyst Paper Corporation-Powell River Division their application to expand the Wildwood landfill is denied, as the site does not meet the minimum requirements of a site that contains hazardous wastes.

          Yours truly,

          David Harris.