Overview of the Environmental Assessment Process and Study Organization

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1 This Report documents the Environmental Assessment (EA) undertaken by Clean Harbors Canada Inc. (Clean Harbors) to provide additional landfill disposal capacity for hazardous waste at the existing Lambton landfill (referred to as the Project ) in accordance with the Terms of Reference (ToR) (Appendix A). The EA was initiated in March 2011 following approval of the ToR by the Minister of the Environment and Climate Change (December 2010). Chapter 1 Introduction and Background The existing Lambton facility, which includes the landfill site, is located on Lot 9 and part of Lot 8, Concession 10, St. Clair Township, in the County of Lambton. The Lambton facility is located 15 km southeast of Sarnia, Ontario. The landfill operation, including all historical fill areas, has a footprint of 56 hectares (ha) out of the entire 121 ha property. Clean Harbors has identified the need for approximately 4.5 million to 5.0 million cubic metres (m 3 ) of landfill capacity to continue to manage waste over a 25 year period. Two landfill expansion alternatives were identified in the ToR and developed to a preliminary conceptual design level. Alternative 1 Vertical Expansion On-Site involves the vertical expansion of the existing landfill site (i.e., expansion would take place over the previously approved and landfilled areas of the site). Alternative 2 Shallow Entombment Off-Site involves the expansion of the site to the south of the existing landfill on adjacent lands already owned by Clean Harbors. The primary study areas include the lands currently considered part of the facility, as well as potentially affected surrounding areas. For Alternative 1, the on-site study area is the existing site. For Alterative 2, the on-site study area is the land required for the new cell, on-site buffer zones and earth berms. The on-site study area for each alternative is shown in Figure 1-2 of the EA. Chapter 2 Overview of the Environmental Assessment Process and Study Organization The Lambton Landfill Expansion EA was undertaken in compliance with the requirements for a hazardous waste landfill (as identified in Ontario Regulation (O. Reg.) 101/07, Section 6) under the Environmental Assessment Act (EAA). The EA was conducted in accordance with the ToR dated July 2010, and approved by the Minister of the Environment and Climate Change in December 2010 (Appendix A). The ToR was the first step of the twostep EAA approval process for the proposed undertaking, with the second step being the EA. Figure 2-1 of the EA provides an overview of the process for the Lambton Landfill Expansion EA. Chapter 2 also provides an overview of the organization of the EA. EXEC-1

2 Chapter 3 Overview of the Undertaking The purpose of the undertaking is to provide approximately 4.5 to 5.0 million m 3 of additional landfill disposal capacity for hazardous waste at the existing Lambton facility for an approximate period of 25 years. The undertaking will enable Clean Harbors to continue to provide secure disposal services for hazardous waste to their customers in the region once it reaches its currently approved disposal capacity, which, based upon the historical and forecasted filling rate at the landfill, is estimated to occur by the end of 2015 or early As outlined in the ToR, Clean Harbors has focused the preparation of the EA and the consideration of alternatives to the undertaking to address their specific needs and circumstances. The following four alternatives to the undertaking were identified: 1. Do Nothing; 2. Establish a new landfill at another location in Ontario; 3. Export waste to a disposal facility outside of Ontario; and 4. Expansion of the approved capacity of the Lambton landfill. Based upon the screening of the alternatives to, Clean Harbors concluded that Alternative #4 Expansion of the approved capacity of the Lambton landfill was the only reasonable alternative that may be implemented. The other alternatives do nothing, establish a new landfill elsewhere in Ontario, or waste export outside Ontario were all determined to be unreasonable alternatives that were either impractical or would not meet the needs of Clean Harbors or its customers. Lands adjacent to the existing Lambton facility are already owned by Clean Harbors. The existing integrated infrastructure consisting of buildings, services and management would support the expanded landfill capacity. Economic and environmental efficiencies from continued use of the Lambton facility as a regional transfer, storage, treatment and disposal facility would be maintained and hauling costs minimized. Maintenance of secure landfill disposal at this site would allow Clean Harbors to capitalize on recent investments in on-site specialized treatment facilities to ensure compliance with the Land Disposal Restrictions (LDRs). This alternative would allow for continued secure landfill disposal by Clean Harbors of hazardous waste for its customers in Ontario and the Great Lakes region, and assure that this capacity remains available in Ontario. Chapter 4 Description of the Environment Potentially Affected by the Undertaking The Lambton facility provides a range of integrated specialized services including a laboratory for waste testing and analysis, an inorganic waste pre-treatment plant, an acid and alkali pre-treatment plant, a liquid waste injection incinerator, Thermal Desorber Unit (TDU) and landfill. Table 4-2 in the EA summarizes the facilities on the existing site. Figures 4-2 and 4-3 in the EA show the existing Lambton facility and perimeter buildings and Figures 4-4 to 4-6 show more detailed site plans for the North, Southwest and Southeast buildings. EXEC-2

3 In order to generate a more detailed description and understanding of the existing conditions that were presented in the ToR, investigative studies of the following environmental components were carried out: Agriculture; Archaeological and Cultural Heritage; Atmospheric Environment (Air Quality and Odour); Noise; Geology and Hydrogeology; Natural Environment; Socio-Economic; Surface Water; and Technical (Engineering and Design). As a result of comments received during the ToR consultation process, Clean Harbors also conducted studies to establish the existing conditions relating to Human Health and Biomonitoring. The existing conditions were documented in accordance with the work plan developed for each environmental component. The work plans were provided to St. Clair Township, Aboriginal communities and MOECC for review and comment and revised accordingly. Results of the investigative studies are detailed in Section 4.3 of the EA. The existing conditions were updated, as appropriate, during the course of the EA based on comments received. Chapter 5 Alternative Methods of Carrying Out the Undertaking Two alternative methods of expanding the approved capacity of the landfill were identified and are described below. These alternatives were developed to the level of preliminary conceptual designs and were presented at open houses / community meetings as part of the consultation process during the ToR. The conceptual designs of the landfill expansion alternatives were developed in greater detail as part of the EA to ensure feasibility, constructability and approvability under the Environmental Protection Act (EPA). The landfill design and operations concepts summarized in Chapter 5 and presented in the Conceptual Design Report for the two alternatives will be further developed during the detailed technical design stage for the Preferred Alternative (i.e., the Environmental Compliance Approval (ECA)). The concepts presented in the Conceptual Design Report for both alternatives are a minimum requirement and different methods may be applicable to achieve the same or better objective / purpose for the design. During the technical approval of the Preferred Alternative, the detailed design of the Preferred Alternative will be developed to meet or exceed the applicable sections of O. Reg. 232/98. Overview of Alternative 1 This alternative involves the vertical expansion of the existing landfill site. The total disposal area is approximately 56 ha (555,691 m 2 ) and the existing buffer zone around the perimeter of the landfill will be maintained. The volume of the additional waste capacity (including the hydraulic control layer (HCL), waste, interim and final cover) is approximately 4.75 million m 3. EXEC-3

4 The following are the conceptual design constraints for Alternative 1: The waste disposal footprint largely covers previously landfilled areas but does not include the area for Sub-cells 1, 2 and 3 of Cell 18. The peak height of the waste disposal contours is consistent with the peak height of the perimeter berm. For conceptual design purposes, the base grades area are the existing contours for the pre-1986 disposal area, 1 m above the waste disposal surface for Cells 16, 17 and 18 and to a minimum elevation of 182 metres above mean sea level (m AMSL) for the new disposal cell areas. A hydraulic control system including a perimeter leachate collection system (LCS) and HCL is to be incorporated. The existing waste receipt / processing and water management systems are to be maintained as long as possible and amended as required. The following are key features of the surface water management system: Ditching is designed to accommodate runoff from a 1:25 year rain event. Detention of runoff is designed for the 1:100 year storm event. Surface water treatment plant has an approved capacity of 4.5 million litres per day (ML/day). The following are the key changes to the stormwater and process water systems: West surface water pond will be relocated to the west buffer to accommodate the new south process water pond. South process water pond will be relocated to the west surface water pond to accommodate installation of the hydraulic control trench and final cover. Stormwater drainage will be split at the northeast corner to reduce pumping requirements. East surface water pond will be reduced in size to accommodate waste disposal. Perimeter ditches will provide water storage requirements. The monitoring program will be consistent with the current program for the landfill consisting of: Waste receipt; Landfill inspection; Groundwater monitoring; Surface water monitoring; Biomonitoring; and Air quality monitoring. Overview of Alternative 2 This alternative involves the development of a new landfill area south of the existing Lambton facility. The conceptual design for Alternative 2 is based on the entombment method that was used for the existing Lambton landfill. The entombment method consists of a disposal area excavated into the native soil, the installation of a clay key on the perimeter of the cell, and the placement of waste below grade with a 5.1 m clay cover. The total disposal capacity including waste, internal berms, interim and final cover is estimated to be 5.75 million m 3. EXEC-4

5 The following are the conceptual design constraints for Alternative 2: Provide waste disposal capacity consistent with the waste disposal capacity provided by Alternative 1. The peak of the waste disposal contours is to be similar to the existing ground surface and below the perimeter berms. Base contours are approximately m AMSL and limited to an excavation depth of approximately 13 m below the existing ground surface. Maintain a 153 m buffer on the east, west and south sides. Utilize the existing facility site entrance and roadways for vehicle access. The existing waste receipt / waste processing and water management systems at the existing Lambton facility are to be maintained and similar water management systems are to be constructed for Alternative 2 where required. An on-site access road from the existing facility to Alternative 2 is to be constructed. The following are key features of the surface water management system: Ditching designed to accommodate at a minimum runoff from the 1:25 year rain event. Detention of runoff for the 1:100 year storm event (at a minimum). Surface water treatment at a rate of 2 ML/day or use the existing Lambton facility plant that has an approved rate of 4.5 ML/day. Surface water management pond at south end. Process water will be transferred to the south process water pond at the existing facility by a forcemain that will follow the alignment of the access road. The leachate will be transferred to the existing facility, by a forcemain that will be installed along the access road alignment, for disposal in the incinerator. The monitoring program will be consistent with the current program for the facility including: Waste receipt; Landfill inspection; Groundwater monitoring; Surface water monitoring; Biomonitoring; and Air quality monitoring. Chapter 6 Net Effects of the Alternative Methods The potential effects of the landfill expansion alternatives were identified based on the application of evaluation criteria, indicators and using data sources that were identified in the ToR. The net effects analysis was conducted by documenting potential effects associated with each indicator in the future baseline year under a maximum impact stage or worst-case scenario specific to each discipline. Mitigation measures were identified to avoid or minimize potential effects and the net effects were evaluated taking into consideration the application of mitigation measures. Finally, an evaluation of the effects for an extended site life was also conducted. The potential effects, mitigation measures, and net effects associated with the alternatives were documented in stand-alone Net Effects Analysis and Comparative Evaluation Reports. EXEC-5

6 Potential net effects were identified for the following environmental components: Agriculture; Archaeological and Cultural Heritage; Atmospheric Environment (Air Quality and Odour); Noise; Geology and Hydrogeology; Natural Environment; Socio-Economic; Surface Water; and Technical Environment. Agriculture The potential net effects of Alternative 1 and Alternative 2 on agriculture are: Net loss of 1.9 ha of Class 2 lands, 9.7 ha of Class 3 lands and the loss of 2.2 ha of Disturbed Lands if the southern property boundary is required to move south to accommodate setback. Net effects on agricultural operations from fugitive dust emissions will be avoided or minimized through implementation of the Fugitive Dust and Odour Best Management Plan (BMP). Net effects on agricultural operations from fugitive dust emissions and weed growth on the new berms will be avoided or minimized through implementation of the Fugitive Dust and Odour BMP and through covering the new berms with erosion control matting and seeding. Archaeology and Cultural Heritage Resources The potential net effects of Alternative 1 and Alternative 2 on archaeology and cultural heritage resources are: No net effects on known archaeological resources and potential net effects on areas with archaeological potential will be avoided or mitigated through conducting a Stage 2 Archaeological Assessment. One cultural heritage resource, Telfer Road pioneer cemetery, is located in the Alternative 1 study area and one cultural heritage landscape, Telfer Road, is located in the south end of the Alternative 1 study area and includes land immediately adjacent within the study area. No net effects on cultural heritage resources anticipated as the existing entrance to the site will continue to be used thus avoiding the identified cultural heritage resources. No net effects on known archaeological resources and potential net effects on areas with archaeological potential will be avoided or mitigated through conducting a Stage 2 Archaeological Assessment. One cultural heritage landscape, Telfer Road, is located to the immediate west of the study area and the Telfer Road pioneer cemetery is situated in the vicinity within the Alternative 1 study area. Although Telfer Road has been identified as a cultural heritage roadscape due to its narrow right-of-way and shoulders evocative of 19 th century origins, it is not considered a unique resource and is typical in this part of Lambton County. With the implementation of the recommended mitigation measures, effects on the Telfer Road roadscape are not considered significant. EXEC-6

7 Atmospheric Environment (Air Quality and Odour) The potential net effects of Alternative 1 and Alternative 2 on the atmospheric environment are: Slightly higher potential off-site Point-of-Impingement (POI) concentrations at the northern receptors although these receptors are already in the vicinity of the existing landfill, and the net change in effects between the existing conditions at these receptors is not considered significant. All potential off-site air quality impacts from the facility comply with the MOECC health and risk based air quality standards. Fugitive dust emissions will be mitigated through the implementation of the Fugitive Dust and Odour BMP. The total number of receptors potentially affected by off-site POI concentrations is higher for Alternative 1 although the net change in effects between the existing conditions and Alternative 1 at these receptors is not considered significant. Under normal operations, there are currently no off-site odour impacts from the facility and no net effects from odour are anticipated. Under normal operations, there are currently no off-site odour impacts from the facility; however, under an upset scenario in the future, potential off-site odour concentrations would be the same for either alternative. The potential impacts at the six southern residential receptors are higher and the net change in effects between the existing conditions and Alternative 2 at these receptors is considered significant. All potential off-site air quality impacts from the facility comply with the MOECC health and risk based air quality standards and fugitive dust emissions will be mitigated through the implementation of the Fugitive Dust and Odour BMP. The southern receptors that are closest to the proposed landfill are not currently in the vicinity of the existing landfill, and the net change in effects between the existing conditions and Alternative 2 at these receptors is considered more significant than the net change in effects at the northern receptors. Under normal operations, there are currently no off-site odour impacts from the facility and no net effects from odour are anticipated. Under normal operations, there are currently no off-site odour impacts from the facility; however, under an upset scenario in the future, potential off-site odour concentrations would be the same for either alternative. Noise The potential net effects of Alternative 1 and Alternative 2 on noise are: All receptors will remain below the MOECC noise limits for landfill operations. The most affected receptor, Point of Reception 1 (POR1), will experience a net increase of 1 decibel (dba) which is considered acoustically insignificant. As such, no net effects from noise are anticipated. All receptors will remain below the MOECC noise limits for landfill operations. The off-site environmental noise impact is limited to the eight existing residential dwellings to the north. All receptors will remain below the MOECC noise limits for landfill operations. The five residents to the south of the study area would experience a noise increase of more than 10 dba. A greater than 10 dba change in sound is perceived as twice as loud. All receptors will remain below the MOECC noise limits for landfill operations. The off-site environmental noise impact is limited to the five existing residential dwellings to the south, although these residents would experience a noise increase of more than 10 dba. EXEC-7

8 Geology and Hydrogeology The potential net effects of Alternative 1 and Alternative 2 on geology and hydrogeology are: It is projected that 3,256.4 m 3 /year of impacted water will the recovered by the perimeter LCS and extracted from the Sub-cell 3 HCL. An additional 3,486.9 m 3 /year of impacted groundwater will be purged from the Interface Aquifer. The total (6,743.3 m 3 /year) will need to be managed as leachate. This represents an increase of 2,880.7 m 3 /year over the volume of impacted water (3,862.6 m 3 /year) that would need to be managed under the future baseline condition. The volume of impacted groundwater to be extracted from the Interface Aquifer under this alternative (3,486.9 m 3 /year) is marginally larger than that projected for the future baseline condition (3,152.6 m 3 /year). The infrastructure (i.e., purge wells and piping) required is fundamentally similar to that for the future baseline condition. The perimeter LCS will prevent discharge of impacted water to surface water. This represents a reduction in discharge of 5,656.9 m 3 /year. It is projected that the water recovered by the LCS and extracted from the Sub-cell 3 HCL will contain 107,802 kg/year of chloride. The groundwater to be purged from the Interface Aquifer will contain an additional 27,753 kg/year of chloride. The impacted water with a total chloride mass of 135,555 kg/year is to be managed as leachate. This represents an increase of 94,401 kg/year over the chloride mass (41,154 kg/year) that would need to be managed under the future baseline condition. There is no expected chloride mass discharge to surface water. This represents a 206,135 kg/year reduction in the chloride discharge predicted for the future baseline condition. It is projected that the volume (710 m 3 /year) of impacted water recovered by the LCS and extracted from the Sub-cell 3 HCL will not change because the design does not include a LCS. The volume of impacted groundwater to be purged from the Interface Aquifer is predicted to be 5,439.8 m 3 /year. The recovered leachate / water (total volume 6,149.8 m 3 /year) will be managed as leachate. This represents an increase of 2,287.2 m 3 /year over the volume of impacted water (3,862.6 m 3 /year) that would need to be managed under the future baseline condition. The volume of impacted groundwater to be extracted from the Interface Aquifer (5,439.8 m 3 /year) is 2,287.2 m 3 /year greater than that projected for the future baseline condition (3,152.6 m 3 /year). Alternative 2 will require additional infrastructure (i.e., purge wells and piping) to extract and manage the water in comparison with the future baseline condition. The volume of impacted water that will discharge to surface water (36,602.3 m 3 /year) is 30,945.4 m 3 /year greater than what is predicted for the future baseline condition. It is projected that 8,909 kg/year of chloride will be recovered by the perimeter LCS at the pre-1986 landfill and extracted from the Sub-cell 3 HCL. An additional 79,977 kg/year of chloride will be purged from the Interface Aquifer. The chloride mass (90,254 kg/year) will need to be managed as leachate. This represents an increase of 49,100 kg/year over the chloride mass (41,154 kg/year) that would need to be managed under the future baseline condition. The chloride mass to be extracted from the Interface Aquifer (81,345 kg/year) is substantially larger than that projected for the future baseline condition (32,245 kg/year). Additional infrastructure (i.e., purge wells and piping) is required in comparison with the future baseline condition. The chloride mass in the discharge to surface water will be substantially larger at 1,385,154 kg/year in comparison with the future baseline condition (206,135 kg/year). EXEC-8

9 Surface Water The potential net effects of Alternative 1 and Alternative 2 on surface water are: There is no expected chloride mass discharge to surface water. This represents a 206,135 kg/yr reduction in the chloride mass discharge predicted for future baseline conditions. Chloride concentrations in treated effluent are expected to continue to be within Canadian Council of Ministers of the Environment (CCME) guidelines for the protection of aquatic life. Results in an improvement in surface water quantity volume and peak flow over the future baseline condition at the North Outlet. Results in similar surface water quantity volume and peak flow as the future baseline condition at the South Outlet. Maximum mass discharge of chloride from the waste to surface waters is estimated to be 1,385,154 kg/year. The net effect to surface water under will result in an overall increase in chloride loadings of 1,179,021 kg/yr or 672% in comparison to that predicted for the future baseline (206,135 kg/yr). If the Surface Water Treatment Plant (SWTP) cannot be designed, maintained and operated in such a way that chloride is effectively removed from surface waters in treated effluent, then it is anticipated that the increased chloride loadings may result in an exceedance of CCME guidelines for the long-term protection of aquatic life. Results in no change in surface water quantity volume and peak flow over the future baseline condition at the North Outlet. Results in a notable increase in surface water quantity volume over the future baseline condition at the South Outlet. Peak flow rate is improved through the implementation of the south surface water reservoir. Natural Environment (Terrestrial and Aquatic Ecosystems) The potential net effects of Alternative 1 and Alternative 2 on the natural environment are: With the implementation of the mitigation measures, such as restoration of swamp and forest areas, no net loss of vegetation communities are anticipated; however, there will be a longer term loss of 0.2 ha of mature swamp and 1.51 ha of mature forest as these areas will take many decades to mature. The 450 m of new forest edge will grow in naturally after several years, minimizing edge effects. There will be a net loss of 1.07 ha of other, natural vegetation from the southwest and southeast woodlot; however, effects are considered minor due to the lower quality of the vegetation. With the compensation of Prickly-ash, no net loss of habitat of provincially rare Giant Swallowtail is anticipated. There will be wildlife avoidance along 250 m of forest edge along southeast woodlot. With the implementation of the mitigation measures, such as restoration of forest areas, no net loss of vegetation communities are anticipated; however, there will be a longer term loss of 0.4 ha of mature forest as these areas will take many decades to mature. The 400 m of new forest edge will grow in naturally after several years minimizing edge effects. There will be a net loss of 1.97 ha of other, natural vegetation; however, effects are considered minor due to the lower quality of the vegetation. Although vehicle use through the wildlife corridor will be minimized at night, where possible, some net effects on wildlife passage will occur. The chain link security fencing along east and west sides of the site will create additional wildlife barriers for large and medium sized mammals. EXEC-9

10 With the creation of wetland areas, there will be a shift in amphibian breeding location; however, no net loss is anticipated. With the compensation planting for Butternut removal and the survival of the seedlings, no net effects on Butternut trees is anticipated. Potential effects from changes in sedimentation will be mitigated through the design and operation of the SWTP, as such, no net effects are anticipated. Potential effects from changes in surface water flow will be mitigated through the operation of the SWTP, as such, no net effects are anticipated. Surface water quality conditions contribute to the overall suitability of fish habitat for fish use. There is no expected chloride mass discharge from groundwater to surface water under Alternative 1. This represents a 206,135 kg/yr reduction in the chloride mass discharge predicted for future baseline conditions. This will result in no net effects to fish habitat off-site in the downstream receivers. No net effects on known or identified Species at Risk (SARs) and their habitats. With the compensation of Prickly-ash, no net loss of habitat of provincially rare Giant Swallowtail is anticipated. There will be wildlife avoidance along 940 m of forest edge along south woodlot and the southwest woodlot. With the creation of wetland areas, there will be a shift in amphibian breeding location; however, no net loss is anticipated. Potential effects from changes in sedimentation will be mitigated SWTP, as such, no net effects are anticipated. Potential effects from changes in surface water flow will be mitigated through the operation of the SWTP, as such, no net effects are anticipated. Surface water quality conditions contribute to the overall suitability of fish habitat for fish use. Maximum mass discharge of chloride from groundwater to surface waters is estimated to be at 1,385,154 kg/year. The net effect to surface water will result in an overall increase in chloride loadings of 1,179,021 kg/yr or 672% in comparison to that predicted for the future baseline (206,135 kg/yr). This will likely impact the suitability of fish habitat for fish use. No net effects on known or identified SARs and their habitats. Socio-Economic The potential net effects of Alternative 1 and Alternative 2 on the socio-economic environment are: Some positive net effects are anticipated through increased business opportunities with vendors with the ongoing need for goods and services at the site. No net effects from change in the municipal tax base are anticipated from a minimal increase in property taxes from the landfill operation. Positive net effects are anticipated with some temporary jobs created at the facility during construction and increased staffing opportunities among suppliers that are created / sustained during construction and operations. Some positive net effects are anticipated with construction and operations of the project contributing to the local economy through potential contracts with local firms. No net effects are anticipated as no businesses will be displaced. No net effects are anticipated as no additional services will be required. Some positive net effects on opportunities to provide goods and services are anticipated through increased business opportunities with vendors. A positive net effect from re-designating the land use for three parcels is estimated to result in increased tax revenues to the municipality of approximately $4,800 per year. Positive net effects are anticipated with some temporary jobs created at the facility during construction and increased staffing opportunities among suppliers that are created / sustained during construction and operations. Some positive net effects are anticipated with construction and operations of the project contributing to the local economy through potential contracts with local firms. No net effects are anticipated as no businesses will be displaced. EXEC-10

11 No net effects on existing off-site businesses are anticipated. No net effects on petroleum resources are anticipated as the one known petroleum resource will not be affected by Alternative 1. No net effects on aggregate resources are anticipated as there are no known aggregate sites within 1,500 m of the existing site. No effects on the use and enjoyment of residences are anticipated. Maintaining the vegetation on the existing berm will continue to provide a visual screen at the site; however, there will be a few locations where the landfill will be visible from off-site when it reaches final height. No net effects are anticipated as no additional services will be required. No net effects on existing off-site businesses are anticipated. No net effects on petroleum resources are anticipated as the one known petroleum resource will not be affected by Alternative 2. No net effects on aggregate resources are anticipated as there are no known aggregate sites within 1,500 m of the study area. Five Rokeby Line receptors will experience significantly elevated noise due to the operation of the facility potentially affecting the use and enjoyment of residences. The proposed berm will mitigate visual effects of the landfill and associated operations. Vegetation and plantings, in conjunction with the configuration of the berm, will minimize the visual effects of the berm itself. There will be a residual visual effect to the landscape and views. Technical Environment The potential net effects of Alternative 1 and Alternative 2 on the technical environment are: Complexity of site infrastructure changes will be low given the effectiveness and limited maintenance requirements for the new active leachate management system and the continued use (with or without modification) of other components and systems associated with the existing landfill. Complexity of engineered components will be moderate in part due to the number of engineered components and the requirement for maintenance of the new active leachate management system to maintain the effectiveness, as well as the effectiveness and ability to repair isolated or significant areas of failure of the final cover. Operational flexibility maximized. High interaction and integration with existing site infrastructure. Complexity of site infrastructure changes will be low given that: passive leachate management will remain for the existing landfill except for the pre-1986 area; some of the existing site infrastructure (e.g., incinerator, laboratory, pre-treatment facilities) will continue to be utilized; some new site infrastructure (i.e., new SWTP, perimeter berms, process water and leachate management ponds, etc.) will be required; and the routing of the internal access road through the incineration area will result in some disruption to the existing facility operations. The complexity of engineered components will be moderate given the passive leachate management via installation of the clay key (the effectiveness of which will span the entire life of the landfill), the simplicity of the final cover and its effectiveness for the life span of the facility, and the implementation of appropriate construction management, oversight, and operational monitoring. However, the existing landfill must be accounted for and that will require the installation of a LCS for the pre-1986 area, as well as the potential for twice the number of purge wells. Operational flexibility maximized. Low interaction and integration with existing site infrastructure. EXEC-11

12 Chapter 7 Comparative Evaluation of Net Effects and Selection of the Preferred Alternative The results of the comparative evaluation of net effects, as detailed in Chapter 7 are provided below. This Chapter also details the cumulative effects assessment, the results of the Stage 2 Archaeological Assessment and the Screening Level Land Use Assessment, in addition to an addendum to the September 2009 Transportation Assessment Report. The results of these studies can be found in Chapter 7 of the EA. Comparative Evaluation of the Alternatives A comparison of Alternative 1 and Alternative 2 was conducted to identify a Preferred Alternative for the undertaking. The comparison analysed the net effects for each criteria within the environmental components. The assessment took into consideration the importance ranking of each criterion as established during the preparation of the ToR. As demonstrated in Table 1, a total of eight out of 15 criteria under Alternative 1 are preferred, while two criteria are preferred under Alternative 2. The Archaeological and Cultural Heritage Resources, Geology and Hydrogeology, and Technical criteria indicate No Substantial Difference between net effects for either alternative. Table 1. Clean Harbors Net Effects Preferred Alternative Summary Environmental Component Criteria Criteria Rank Agricultural Resources Important Agriculture Agricultural Operations Very Important No Substantial Difference Preferred Alternative (Agriculture - Environmental Component Level) Archaeological and Cultural Heritage Resources Archaeological Resources Important No Substantial Difference Above Ground Cultural Important No Substantial Heritage Resources Difference Preferred Alternative (Archaeological and Cultural Heritage Resources Environmental Component Level) Atmospheric Environment Air Emissions Very Important (Air Quality and Odour) Odour Very Important Preferred Alternative (Atmospheric Environment Environmental Component Level) Noise Noise Important Preferred Alternative (Noise Environmental Component Level) Groundwater Quantity Very Important No Substantial Difference Geology & Hydrogeology Groundwater Quality Very Important No Substantial Difference Preferred Alternative (Geology and Hydrogeology Environmental Component Level) Preferred Alternative No Substantial Difference No Substantial Difference No Substantial Difference No Substantial Difference No Substantial Difference No Substantial Difference No Substantial Difference EXEC-12

13 Table 1. Clean Harbors Net Effects Preferred Alternative Summary Environmental Component Criteria Criteria Rank Surface Water Quality Very Important Surface Water Surface Water Quantity Very Important Preferred Alternative (Surface Water Environmental Component Level) Preferred Alternative Terrestrial Ecosystems Very Important Natural Environment Aquatic Ecosystems Very Important Preferred Alternative (Natural Environment Environmental Component Level) Economic Important Socio-Economic Disruption to Use 1 (Social ) Very Important Preferred Alternative (Socio-Economic - Environmental Component Level) Site Development and Important Technical Operating Requirements 1 (Facility Characteristics) Preferred Alternative (Technical - Environmental Component Level) No Substantial Difference PREFERRED ALTERNATIVE No Substantial Difference No Substantial Difference Alternative 1 is preferred over Alternative 2 for a total of 7 criteria that are ranked as Very Important and one criteria ranked as Important. Alternative 2 is preferred over Alternative 1 for one criteria ranked as Very Important and one criteria ranked as Important. With regard to the remaining criteria, two ranked as Very Important and three ranked as Important, there is no substantial difference between the alternatives. As a result, the overall Preferred Alternative was identified as Alternative 1. Chapter 8 Consultation Summary In accordance with the MOECC s Code of Practice for Preparing and Reviewing Environmental Assessments in Ontario (January 2014) and Consultation in Ontario s Environmental Assessment Process (January 2014), Clean Harbors undertook a consultation program throughout the EA process. As required by Section 5.1 of the EAA, Clean Harbors consulted with review agencies, Aboriginal communities and the public. Consultation was undertaken at key milestones in the process, as well as on an ongoing basis, as described below. The key milestones included the following: Milestone #1:... Prior to finalizing the Work Plans for the EA studies including Work Plans for the review of Existing Conditions; Milestone #2:... Following completion of the review of Existing Conditions; Milestone #3:... Following completion of effects assessment and the evaluation of alternatives but prior to final decision on the Preferred Alternative; and Milestone #4:... Prior to finalizing the EA Document. 1. When ranking the importance of criteria during the Terms of Reference development, the Social and Facility Characteristics criteria were referred to as Disruption to Use and Site Development and Operating Requirements, respectively. EXEC-13

14 Four broad participant groups were identified from which to obtain input: 1. Various governmental departments, ministries and agencies with an interest in the Project, otherwise known as the Government Review Team (GRT); 2. St. Clair Township, the host municipality; 3. Aboriginal communities in the vicinity of the study area or with an interest in the Project; and 4. General public which includes residents, landowners and businesses and other stakeholders having an interest in the outcome of the EA. Government Review Team Consultation was initiated with governmental departments, together referred to as the GRT, during the preparation of the ToR and continued throughout the duration of the Clean Harbors EA process. Specific consultation activities included direct correspondence via letters / electronic mail ( s) to the appropriate agencies, two web conferences to which all GRT members were invited (March 27, 2013 and January 29, 2014), as well as meetings held with individual agencies or groups of agencies, as appropriate. Review agencies were also invited to attend Open House events throughout the Project. St. Clair Township For the purpose of reviewing the EA documentation, St. Clair Township formed a PRT to conduct the technical reviews and develop comments on behalf of the Township. The PRT was comprised of a number of consultants, each with a specific technical focus. Clean Harbors consulted with the Township throughout the planning process. Aboriginal Communities During the preparation of the ToR, the following Aboriginal communities were identified as having a potential interest in the Project: Walpole Island First Nation; Aamjiwnaang First Nation; Kettle Point First Nation; Moravian of the Thames First Nation; Oneida of the Thames; Chippewas of the Thames First Nation; Munsee-Delaware First Nation; and Caldwell First Nation. Of these Aboriginal communities, the Walpole Island First Nation and Aamjiwnaang First Nation expressed an ongoing interest in the EA. Both of these communities retained the services of a technical consultant to review EA documentation and develop comments on their behalf. Several consultation events were undertaken between April 2011 and October 2014 with the Walpole Island First Nation and the Aamjiwnaang First Nation, including meetings, community information sessions and an Open House. EXEC-14

15 No other Aboriginal community has submitted comments up to the current time except the Chippewas of the Thames First Nation who submitted a letter following the Notice of Commencement stating that they would like to be involved during the EA process. They later submitted a statement of no concern. Caldwell First Nation also requested hard copies of various reports; however, they have not commented on the EA. Open Houses Two Open Houses were held on January 21, 2014 and April 10, The purpose of the Open House events was to provide an opportunity for the public to learn about, and provide comments on, the proposed Lambton landfill expansion. Study team members were in attendance at both Open House sessions to facilitate discussions and answer questions. Comments Received At each milestone, the GRT, St. Clair Township, Aboriginal communities and the public were notified and given the opportunity to provide feedback on the EA. Comments from the GRT, St. Clair Township and Aboriginal communities, and how the comments were addressed by Clean Harbors were documented in Comment Response Tables. Comments that did not specifically relate to these milestones were documented separately. Other Consultation Activities Clean Harbors employed other methods to engage the participant groups on an ongoing basis, including: Project-specific website; Project dedicated address; and Project information hotline. Chapter 9 Monitoring Plans and Commitments for the Undertaking Monitoring strategies were developed so that any respective environmental effects can be monitored during construction, operation and maintenance of the landfill. Monitoring strategies were developed for the Preferred Alternative to ensure that: Predicted net effects are not exceeded; Unexpected negative effects are addressed; and Implemented mitigation measures are effective. Specific monitoring details and commitments relating to each environmental component are outlined in Chapter 9. Clean Harbors will also develop a Compliance Monitoring Program to detail how Clean Harbors will report annually on their compliance with the commitments made in the EA report. EXEC-15

16 As described in Section 8.3.8, through consultation with the Walpole Island First Nation, Aamjiwnaang First Nation and the St. Clair Township, Clean Harbors submitted a series of commitments to address their comments received on the Draft EA which were related to the detailed design of the Preferred Alternative. Clean Harbors will continue to consult with the Walpole Island First Nation, Aamjiwnaang First Nation and the St. Clair Township on these commitments. Chapter 10 Approvals The proposed undertaking will require other environmental and land use approvals, aside from the EA approval. The undertaking will require either an application for an amendment to the current ECA (Waste) for the existing Lambton landfill (Certificate of Approval (C of A) No. A031806), or application for a new ECA. This must occur before construction and operation of the undertaking. The information required to support this ECA (Waste) application includes a Design and Operations Report and a Hydrogeological Assessment Report. Table 2 lists the approvals required and conditions to be fulfilled for the undertaking for the applicable environmental disciplines as considered in the EA. Table 2. Approvals Required and Conditions to Be Fulfilled Environmental Discipline Approval / Condition Archaeology Atmospheric Environment (Air Quality, Odour and Noise) Geology and Hydrogeology Surface Water Natural Environment Land Use Acceptance of the Stage 2 Archaeological Assessment into the provincial register of archaeological reports. ECA Application under Section 9 of the EPA to address potential air and noise emissions from the landfill may be required. Updated Groundwater Monitoring Plan as part of the ECA (Waste). Description of the proposed stormwater conveyance system and ponds in the Design and Operations Report and approval as part of the ECA (Waste). Updated Surface Water Quality Monitoring Plan as part of the ECA (Waste). Amendment to the existing ECA (Industrial Sewage), under the Ontario Water Resources Act. Compliance with the Lambton County By-Law and the St. Clair Township Official Plan will be addressed in the Habitat Compensation Plan prepared in conjunction with the ECA (Waste) and land use approval process, as appropriate. Submission of a Notice of Activity Form and Butternut Compensation Plan to the Ministry of Natural Resources and Forestry (MNRF). St. Clair Township Official Plan amendments, zoning by-law amendments and site plan approvals. EXEC-16