Report on Macmillan Bloedel's Contaminated Powell River Industrial Waste Dump

During the month of January, 1995, I conducted a document search at the office of the Ministry of the Environment, Land and Parks (MOE) in Surrey relating to the entire operation of MacMillan Bloedel's Powell River pulp mill for the past five years. The following is my initial draft report concerning only MB's hazardous waste dump known as the Wildwood Landfill.

The original MOE Permit for this industrial dump was issued to MB in 1976 and its terms are very vague and general. Significantly, the permit was for a term of 12 years which would take it to 1988, some 7 years ago.

The dump itself is situated in an old gravel pit on a high hill immediately above Powell Lake which is the source of drinking water for the Wildwood residential community, the source of potable water and electrical power for the mill, and which flows by the mill and discharges into Georgia Strait.

DOCUMENTS

1.   The minutes of a December 7, 1989 meeting attended by MB and MOE officials indicate that a complaint had been received from a local citizen's group known as the Ratepayers Association. I assume that it was a group of citizens from the Wildwood residential area which is immediately adjacent to the dump. The complaint was a suggestion that leachate from the dump may have been contaminating a domestic water supply. At this meeting MB indicated that it would establish monitoring wells at the dump. Significantly, after being advised of the possibility of the dump's leachate being a source of contamination of the local drinking water supply, MB then asked MOE for permission to dump about 20,000- 30,000 M3 of PAH contaminated dredgate because Environment Canada would no longer allow them to dump it in the Ocean as had been their previous practice.

In March of 1990 a report from Hardy BBT Limited, a consultant retained by MB, stated that the groundwater under the dump had been contaminated and that the local hydrology indicated that the dissolved constituents in the groundwater would flow into Powell Lake.

2.   A MOE internal memo dated May 21990 referring to the Hardy report states:

[text missing]
…groundwater."  This memo further states that having discovered phenol and AOX contamination in the groundwater, specific analysis should be done for dioxins and furans and that deep wells, "should be introduced between the landfill and Powell Lake in order to assess the impacts on the Lake."

3.   A June 1990 internal MOE memo recognized that dregs and grits from all kraft mills are special wastes (read- hazardous wastes) and were routinely being landfilled without a special waste permit. This memo recognized this as a province- wide problem.

4.   On September 29, 1990, in a letter to the Corporation of the District of Powell River, the Wildwood Heights Ratepayers Association complained about leachate from the dump going into Powell Lake.

5.   A November 9, 1990, MOE internal memo from J. Wiens, head of the contaminated sites unit, states that insufficient monitoring wells had been established by MB. Mr. Wiens recommended that “due to the apparent groundwater contamination due to leachate. efforts at reduction of leachate and/or leachate strength should be considered."  He also suggested that the types and amounts of contaminants of concern in the waste stream coming to the dump be identified. He further suggested that management changes- i.e. reduction/recycling at source and selective redirection of waste streams be considered. Mr. Wiens memo also states that management intervention may be required, i.e.- "containment , pump and treat."

6.   In an internal MOE memo dated November 14, 1990, Mr. M. Gow, head of Environment Section, suggested that if there is a potential for an impact upon Powell Lake, MOE, "should consider leachate and collection and treatment prior to design and construction of the mill's new treatment system.”  This memo further states that, "the other two pulp mills in region 2 collect their leachate and divert it to the effluent treatment system."

7.   At a meeting between MB and MOE officials on December 6, 1990, MOE advised MB that the recent monitoring program had identified contamination of the aquifer in the area of the landfill, MOE advised MB that, "Therefore, the company should make allowances in the design of the secondary treatment system to treat collected leachate from the present and proposed landfill sites."

8.   Apparently MOE sent MB a letter on July 17, 1991 which contained a proposed leachate monitoring schedule for the landfill with a September, 1991 completion date. MB didn't even respond to this letter until October 4, 1991, some three months later and after the September 1991 completion date. In this letter, MB stated that a decline in the economic conditions of the company made it impossible to even start the monitoring program until January of 1992.

HBT Agra was retained by MB and this consulting firm did sampling and came out with a report on October 14,1992.

9.   Referring to the Agra report in an internal MOE document dated October 20, 1992, Biologist Brent Moore stated as follows:

"I am very concerned about some of the levels reported in this document. At site 89-5. the 2,3.7.8 TCDD TEQ is in excess of 3000 pg/L. while the accepted discharge level for a Special Waste treatment facility is 15 pg/L . Chlorinated phenolics levels are also quite high, with pentachlorophenol and 2.3,5,6 tetrachlorophenol values reaching 12 and 16 pg/L, respectively, at station 89-3. Other parameters, such as total sulphides, copper, iron and even nickel, are of sufficient concern at some to the monitoring stations. Safety levels for all these parameters have been exceeded in the reported data sets. The Industrial Section may wish to consider whether this location is actually a contaminated site."

10.   The Agra report had identified seepage from a spring and from seeps at the base of the hill below the landfill at the edge of Powell Lake. Referring again to the Agra report, another MOE internal memo, dated October 23, 1992 which was a briefing note for MOE officials in Victoria, discussed the situation as follows:

"Although the levels measured at the spring are within standards, the report indicates a complex set of pathways for contaminants to travel from the landfill to the lake, so other sources flowing to the lake could have much higher levels than the spring that was sampled."

11.   An internal MOE memo which discusses a conference call among 6 MOE officials and environmental scientists makes the following comments about concerns with the contamination leaching from this site:

-- the nastier chemicals are starting to be mobile.

-- safe to assume that it is much worse than current data due to stratigraphy.

-- dioxins are probably the biggest concern.

-- even if capped, there could be a spring.

-- a lot of the semi-impermeable barrier has probably been stripped off.

-- one dioxin is 200 times drinking water limit.

-- make sure people don't drink water from streams they could be fishing.

12.   A November 10, 1992 letter from MOE to Environment Canada concerning die contaminants reaching Powell Lake states that MOE "was considering making an Abatement Order regarding the polluted site to ensure a timely response by the company."

13.   An internal MOE memo dated November 13, 1992 makes the following comments:

"The contaminant types and indicated levels are sufficient to cause general concern as well as to require further investigation and remedial action by MacMillan Bloedel"

"As the alkalinity in the vicinity of the landfill is high, probably the result of leaching mill wastes, the ability to solubilize and transport organics is increased. This is perhaps reflected in PAH being detected in all water samples taken. In general PAH is not that soluble and the fact that PAHs are so widely dispersed throughout this system is a cause for alarm”

"As stated by HBT Agra. not all the flow from the landfill area can be accounted for by the volume seeping from the scarp face; there must be a groundwater component from the landfill area directly into Powell River that has not vet been investigated."

This same memo makes the following comments in regard to Dioxin:

"The one water sample collected within the landfill contained 43 pg/L fopa) 2,3,7,8 TCDD- teas. The levels outside the landfill ranged from 26 to 3065 pg/L 2,3,7,8 TCDD-TEQs. The surface spring which feeds into Powell River also had significant levels of contamination, 55 pg/L 2,3,7,8 TCDD-TEQs."

"The fly ash that was being added to the landfill had high levels of dioxins and furans, 14.510 and 28,460 pg/g (ppt) 2.3,7,8 TCDD-TEQs. The fly ash is only one source of the dioxins and furans in the landfill leachate as pulp sludges, PCP treated waste and PCP treated wood chips could also be significant sources. The dioxin and furan contamination in water is extremely variable but all the samples exceed the federal Drinking Water Guideline of 15 pg/g (ppq) 2.3.7.8 TCDD-TEQs The variability of the contamination as seen in well 89-5 (3065 pg/L 2.3.7,8 TCDD-TEQs indicates that we may not have seen the worst case."

"The contamination of the surface spring is also a major area of concern as it shows long distance movement of significant levels of these contaminants and possible impacts on water available for human consumption!'

Finally, this same November 13,1992 memo makes the following comment

"No further material which may act as future contaminant sources should be deposited at this landfill"

14.   On November 27, 1992 a meeting was held with officials from MB, Ministry of Health, Environment Canada, MOE and the Department of Fisheries and Oceans. At this meeting MB agreed on principle to take certain actions. As a follow up to this meeting, a letter was sent to MB outlining the matters that MB had agreed upon at the meeting. This letter states : “ The company has agreed to identify and assess alternatives for preventing further contamination of the ground water and river. Options considered should include closure and capping of the landfill, pump and treat interception system, barrier walls, siting of a new secure landfill facility, waste elimination and reduction at source or development of alternate uses or recycling wastes. I would expect to receive a written presentation of this assessment by the end of January, 1993.”

Although the Agra report came out October 14, 1992, it was not until after...
[text missing]
…months later that the public was advised that...
[text missing]

15.   A MOE memo dated December 31, 1992 states that, "the Ministry expects the company to implement containment and remediation systems in a timely manner."

16.   On the 17th day of February, 1993 MOE wrote a letter to MB which set out the steps that MB should take with respect to the contaminated site. Among the steps to be taken by the corporation included:

1.  "Determine and delineate the contaminant pathways to Powell River."

2.  "Calculate the contaminant loading from all sources related to the landfill to Powell River (e.g. seeps, groundwater, contaminated sediments, etc.) pathways to Powell River."

3.  “Provide information to formulate appropriate remedial measures to mitigate contaminant migration to Powell River from surface and groundwater, as well as from potentially contaminated sediments in Powell River."

This February 17,1993 letter also stated: "As  agreed at our November 27 meeting. MB will commence and conduct the above investigations in an expedient manner. We expect MB to implement remedial measures derived from this investigation to mitigate any pollution from this site by September 1, 1993."

17.   MB wrote a letter to a citizen on June 24, 1993, in which the company stated: "We intend to have a remedial action plan identified by this August. The plan will provide a solution to the offsite migration of the contaminants. Implementation will begin in the Fall with the completion dependent upon which remediation technology is ultimately chosen. "

18.   An internal MOE memo dated July 8, 1993 discusses the results of certain studies that had been done to determine whether fish were being contaminated by the toxic chemicals being discharged from the landfill. The studies had determined that fish located in a fish hatchery downstream from the contaminated spring and seeps flowing into Powell Lake had been contaminated. This memo from Laurena Hansel, an MOE biologist discusses the contaminated fish in the hatchery as follows: "However, the consistency of elevation in the hatchery fish warrants some consideration. In all cases the hatchery fish samples had the highest levels of 2 3.7.8-fCDD equivalents. It may suggest that the hatchery fish continuously exposed to water from the vicinity of the landfill are bioaccumulating organics, even though the levels are very low." The memo further states: “The suggestion that long-term exposure to the intake water results in accumulation in fish may bear consideration with respect to domestic consumption of the same water supply."

It is significant that bearing in mind that this site was highly contaminated, MB applied for and was given permission to store 6000M3 of hazardous waste at this site in August of 1993. This waste consisted of soil contaminated with hydrocarbons, and MOE allowed MB to store this waste at the landfill site in a manner that was contrary to the B.C. Special Waste Regulation. In other words, an exception was made for MB so that the company could store this waste without complying with the strict terms of the regulation.

19.   The December 20,1993 HBT Agra report entitled "Closure of Wildwood Landfill- Volume 1 makes it clear that this consulting firm retained by MB was very uncertain about the hydrology of the site and the paths of transport of the contaminants. Following are some extracts from this report:

—"The groundwater immediately down-grade from the landfill was found to have the highest levels of contamination, with the levels declining toward Powell Lake. However, some contamination was detected in the major spring that discharges to Powell Lake. Evidence was found that indicates that the spring was used by children for recreation purposes."

—"The viscous contaminant encountered in monitoring well 89-5 must be better understood. Due to the viscosity of the substance the rate of migration should be relatively low. However, due to the high concentrations of contaminants in the material, the issue should be addressed as soon as possible. There are, however, significant risks associated with a number of the conventional approaches that are used to investigate sites. The levels of dioxins and furans in particular, are so high that drilling could result in significant contamination of the regional aquifer. All work in and around the site will pose considerable health risks. It is proposed that a combination of geophysical methods be employed first to outline the probable extent of the viscous contaminant"(emphasis added)

20.  In a series of internal MOE memos during the month of January, 1994 the following comments are made by MOE officials concerning this contaminated site and MB's responsibilities:

[text missing]
…treatment of intercepted groundwater…
[text missing]

--"Given that there is some contamination in the sediments in the immediate vicinity of the seep, which Agra recommends should not be disturbed, should there be consideration to planned remediation (removal or covering) to prevent inadvertent disturbing and release of contaminants?”

-- "After all the investigation that has taken place, can they continue to claim that their "understanding of the hydrology of the site is still limited" and continue to propose more testing? Each time we expect some concrete action, they come back with more questions, and propose more testing."

—"Tony has raised the question of whether we are being consistent with our treatment of Macblo versus Woodfibre. As I understand it Woodfibre has capped their old landfill, diverted upgradient runoff and possibly groundwater around the landfill, and is intercepting leachate/groundwater from the landfill and directing it to their effluent treatment plant. I think the analogous of this for Wildwood would be collecting leachate above the clay layer for treatment, capping and surface/groundwater diversion."

—"Ray, as I understand your note, we would want to prevent discharge of waste to the regional aquifer. This means capping. It could also mean interim pumping and treating of leachate above the clay liner to prevent further discharge. Ray and Roger, how do you feel about that, which is not something we considered I would imagine that provided they could demonstrate that the impact of capping will be relatively fast (say 1-2 years) that we would not likely insist on interim collection of leachate."

—"Again, if we were to be convinced that the capping would result in meeting these levels quickly, then we may be prepared to wait rather than force an interim pump and treat installation that could quickly become unnecessary. I am personally rather skeptical about quick response and recovery, and therefore applying your rationale, expect that we should force pump and treat of the regional aquifer if it exceeds standards." (emphasis added)

—"One thing I forgot to mention in my other note after the conference call, was that Tony asked if excavation and removal of the fill and contamination had been considered  We had never really addressed this before, and we agreed that it was probably feasible, very expensive (probably more than the slurry wall) and not justified at present. However, we may want to let them know that we could not rule this out as an eventual possibility."

21.   In a January 25, 1994 internal MOE memo the following comments are made by Roger Ord, Soils and Hydrogeology Specialist with the Contaminated Sites Unit:

—"In addition to defining and modeling the groundwater plume and further investigations and actions proposed at our meeting of January 12, 1994, MB/Agra will collect information during this investigative phase specific to the design and implementation of an effective groundwater collection and treatment (pump and treat) facility adequate to control contamination emanating directly from the landfill."

—"The pump and treat facility will be designed and implemented to intercept both the impacted regional aquifer groundwater and the perched groundwater as close as practically possible to the contaminant source so as to increase collection effectiveness and minimize dilution"

—"At some future time when the landfill environment stabilizes chemically, should collected groundwater and monitoring information indicate that no significant contamination emanates from the landfill then groundwater collection may cease, provided on-going monitoring indicates that no impact of the regional aquifer occurs after shutdown"

—"I realize that there may be a public perception problem with allowing the continued operation of a landfill where we have serious concerns about the environment; fortunately, this has not occurred so far." (emphasis added)

22. On February 17, 1994, MOE wrote a letter to MB in regard to MB's proposals for closure of the landfill. Apparently MB had not addressed the leachate problem in their proposal. The following are excerpts from this MOE letter:

—"However, the issue of leachate pollution has not been adequately addressed and resolved in your proposal. Having consulted with our Victoria office and Nanaimo Regional office, we wish to advise you that, to curb further pollution of the regional aquifer,  the leachate contaminated perched groundwater and the...
[text missing]
...points as close to the contaminant source as practical treated and disposed of in an acceptable manner as soon as possible, in addition to capping the landfill and other works mentioned above. Leachate collection and treatment may cease in the future when monitoring results indicate that the regional aquifer is no longer affected."

— "You are therefore requested to submit no later than July 31, 1994, a program of leachate collection, treatment and disposal for our review. The program should include the basic design and operation with implementation schedule. As discussed in the meeting, a closure plan for the completed portions of the landfill an operating plan for the active part of the landfill to minimize rain infiltration and better manage the refuse discharge, a contingency plan and security (financial)  for both the old and new landfills should be forwarded to us for review as soon as possible.”  (emphasis added)

23.  MB replied to this letter a month later on March 16, 1994 and the following are excerpts from this letter:

—"As further information becomes available (i.e. groundwater contaminant levels, flows, cover effectiveness, etc.) we will modify our closure plan to suit the results. It would be premature at this time to begin planning for leachate collection and treatment given the current information gaps." (emphasis added)

—"Since we are actively remediating the existing landfill and the new site will be designed to prevent similar problems, we do not see any need for financial security." (emphasis added)

24.    HBT Agra Limited prepared a report entitled "Wildwood Landfill Closure Meeting" on March 31,1994. In this report, the following is stated:

—"Mr. Les Gittens of MacMillan Bloedel Limited initiated a review of possible sources of dense non-aqueous phase liquids (DNAPL) in material disposed of in Wildwood Landfill. Potential sources of DNAPL included creosote and possibly other coal tars, PCBs and other waste oil and chlorinated solvents (inducting methylene chloride* carbon tetrachloride and chloroform). Other potentially problematic compounds noted included lead chromate and other lead pigments and mercury. Given that the landfill was started over 20 years ago, before the potential hazards associated with many DNAPLs were recognized, some of these materials may have been disposed of in the landfill.” (emphasis added)

25.  An internal MOE memo dated April 4,1994 states as fellow's:

— "I am faxing you Drew Kilback's April 4, 1994 letter confirming that they will submit a closure plan for the Wildwood landfill site by July 31. 1994. However, there is no mention of commitment to leachate collection and treatment that they promised in the March 31, 1994 meeting.  As Ray suggested, a Pollution Abatement Order should be issued to formalize the process."

26.  An internal memo dated April 20,1994 makes the following comments:

—“My understanding was that at the meeting the company verbally agreed to submit a plan to collect and treat the leachate by July 31. Consequently, we saw no need to order that they submit a leachate collection/treatment plan. However, the company's follow up letter to the meeting did not contain that commitment and subsequent conversation with mill technical staff suggests that the July 31 closure plan may not include collection and treatment of the leachate."

— "If we believe that they (the company) are doing everything reasonable, then we may not need to issue an order, but I got the impression from technical staff reviewing their efforts that we did not believe that their efforts were sufficient in that the company was not proposing to collect/treat leachate (leachate which is at special waste levels) How many years has it been since Mac Blo found out that they were discharging special waste to the environment upgradient from a drinking water supply and how much has the company done to actually reduce the quantity of contaminants being released to the environment (I am aware that they have studied it extensively but I am not aware of any efforts to reduce the impact)?(emphasis added)

27. By letter dated May 6, 1994 MOE wrote MB a letter which included the following:

—"Your letter is not clear to us if a program to collect and treat the leachate would be included in the closure plan. The leachate issue must be adequately addressed to curb groundwater pollution that has been occurring unabated. We have serious concerns with the high degree of contamination, which has reached the Special Waste levels, as revealed by your groundwater sampling and monitoring. I...
[text missing]
...However, in the meantime, the ongoing groundwater pollution must be stopped as soon as possible." (emphasis added)

You are therefore requested to submit a program to collect and treat the leachate by July 31, 1994, either as part of the closure plan or as a separate document."

On November 9, 1994,  MOE found it necessary to issue a Pollution Abatement Order to MB under the provisions of the Waste Management Act.  However this Order only required the company to install a groundwater monitoring system, and to design a surface water diversion/collection system, a gas collection system and a surface barrier system. The site is to be capped. There is nothing in this Order that requires MB to collect and treat the toxic leachate now and so the leachate continues to flow into Powell Lake and will continue to do so in the fixture.