Received July 11, 2014 by email

Good afternoon Mr. Isaacs,

Thank you for your letter dated May 15, 2014 (received in our office May 27, 2014). The following provides my response to your letter.

For your general information, landfill sites and other waste management activities in Ontario are subject to Part V of the Environmental Protection Act (EPA). Section 27 of the Act requires that an Environmental Compliance Approval (ECA, formerly Certificate of Approval) is obtained from the Ministry of the Environment and Climate Change by the owner of a landfill site. The ECA for each site takes into site-specific requirements for design, operation, and monitoring to reflect the particular setting and conditions at each site.

As described in the document Landfill Standards: A Guideline on the Regulatory and Approval Requirements for New or Expanding Landfilling Sites (MOE, May 1998), landfill site monitoring is necessary to demonstrate that a site is performing as designed. Regulation 232/98 of the EPA requires that a surface water and groundwater monitoring program is carried out a landfill site.

Surface water monitoring is designed to identify any potential impacts on surface water features in the vicinity of the site. Surface water monitoring data is compared to Provincial Water Quality Objectives as provided in the document Water Management Policies, Guidelines, Provincial Quality Objectives of the Ministry of the Environment and Energy (MOE, July 1994). If there are no surface water features present, then the ministry will not require surface water monitoring.

Groundwater monitoring is necessary to demonstrate that the impacts of the leachate from a landfill site are acceptable, particularly as they relate to impacts on neighbouring domestic wells. Groundwater monitoring is conducted to ensure that the requirements of Guideline B-7 are met, as provided in the document Guideline B-7 - Incorporation of the Reasonable Use Concept Into MOEE Groundwater Management Activities (MOE, 1994). If leachate discharges directly to surface water, with no domestic wells between the landfill site and the surface water, then groundwater monitoring may not be required by the ministry.

In summary, while landfill sites do require monitoring, the extent that it is required is site-specific. While some site ECA’s have specific monitoring requirements, some of the older documents do not. At any time, a landfill site owner may request that the ministry, through the local District Office, reconsider monitoring requirements for a particular site. This may be in the form of changes in the frequency, parameters, or locations of monitoring. The District Office will forward such requests to the surface water and groundwater specialists in the Region. These specialists will assess the request, and in some cases are supportive of reductions in monitoring where the scientific data supports it.

In terms of the landfill sites in Addington Highlands, discussions have recently been held with the municipality regarding monitoring requirements at their sites. A meeting was held in our office on May 6, 2014 with representatives of the municipality, the Environmental Officer for the area, and the relevant technical reviewers. The meeting included a discussion of the Denbigh, Weslemekoon, Kaladar and Hartsmere landfill sites. As I was not in attendance at the meeting, I cannot provide details of the discussion, however, I am aware that in some cases, our ministry is open to the suggestions of reduced monitoring requirements.

The Township of Addington Highlands is in possession of annual monitoring reports for each site, as well as all technical review comments from our ministry. These technical reviews include assessments of the adequacy of the monitoring program for each site, and in some cases may make recommendations for reductions in monitoring where warranted.

This information is available to the public, but it must be accessed by submitting a request through the Freedom of Information office. Here is the link to more information about how to make a request:

https://www.ontario.ca/government/how-make-freedom-information-request

It is always most helpful if a request is scoped to include reference to specific sites, time periods, etc.

If you have any further questions about the sites in Addington Highlands, or would like more details on the May 6 meeting with the municipality, your one-window contact is Craig Dobiech (613-540-6895), Senior Environmental Officer, Kingston District Office (copied on this email).

Gillian Dagg-Foster, M.Sc., P.Eng.

Director, Section 34, Ontario Water Resources Act

Supervisor, Water Resources Unit

Eastern Region

Ministry of the Environment and Climate Change

613-540-6875

Gillian.Dagg-Foster@ontario.ca