Letter to the Editor
Re: EBR Application to change EPA to prevent landfilling on fractured bedrock

July 22, 2013

Our region can do its part in solving the waste problem by considering enclosed composting and material recycling facilities; but our home is not suitable for massive landfills such as the new BREC landfill proposed by Waste Management to be located beside the now closed Richmond Landfill. Because of the leaky land from fractured bedrock, the Richmond Landfill site is “arguably one of the worst areas in Ontario to build a landfill” (Gord Miller, Environmental Commissioner of Ontario, 2009).

The over half-a-century old Richmond Landfill was allowed to be built and expanded in a time of little government regulation and scientific oversight. Unfortunately, it still appears to be easier to build a new landfill on an existing site that was never properly vetted for its hydrogeological suitability, than to locate one properly in the first place.

Many hydrogeological experts agree that it is virtually impossible to confidently monitor and clean up contaminated groundwater in fractured bedrock aquifers. New or expanded landfills should be prohibited by law in these kinds of sensitive areas, especially since many people and livestock rely on water drawn from fractured bedrock aquifers. Recently, concerned citizens submitted an Environmental Bill of Rights (EBR) application to tighten up legislation that deals with the locating of landfills.

In 2004 I attended a talk by the renowned hydrogeological scientist, Dr. Allan Freeze, entitled “Some Awkward Truths about Waste Disposal” hosted by Queen’s University. Freeze pointed out that double liners delay early failure but eventually leak, transferring the risk to future generations. He stressed that good siting is critical in order to minimize the risk of eventual leachate leakage and to maximize confidence in detecting and properly mitigating leakage.

Freeze put it succinctly in a presentation he gave in 2001 to the University of Michigan when he wrote,

“Proper siting represents the best possible route to environmental protection, but current socially-driven siting promotes poor sites at the expense of good ones.”He continued, “Wise environmental policy would promote prevention rather than remediation, regional aquifer protection rather than site-scale engineering design, and consideration of long-term risks rather than short-term economics.”

The issue of proper landfill siting takes on an even greater importance when considering the new groundwater source protection plans of the provincial government. A report by the Ministry of Environment’s Committee on Watershed-based Source Protection Planning (2003) stated,

“Protecting Ontario’s drinking water at its source is the first line of defence in what experts refer to as the ‘multi-barrier approach’ to ensuring the safety of drinking water. Each barrier in the system works together to prevent or reduce the risk of contaminants reaching your tap.”

Until our society finds alternatives to landfills, we need to be smart about where we put them. The Lafleche Landfill, north of Cornwall, is one good example of a regional landfill on suitable geology. It is underlaid by 50 feet of impermeable clay that provides a natural barrier to leachate movement. Concerned citizens hope that their EBR application will be accepted by the government as a means of bringing landfill regulations in line with conventional scientific wisdom on the importance of proper landfill siting.

Stephen Medd
Retired Geologist

Tags: Environmental Bill of Rights, Landfill Siting, leachate risks, Leaking landfill, Napanee, Waste Management Corporation