Re: GIP Properties Corp…

Re: GIP Properties Corp. Proposal for Permit To Take Water, ERO no. 019-5959, Ministry Ref No. 8727-CHUMTY
We have concerns with the application for a renewal and name change for PTTW No. 8125-BGRT3U for GIP Properties Corp. Our concerns are as follows:
1. The Site Location Map is inadequate. The attached map is a simple Google Map image of the general location and does not identify water sources (such as surface water/drainage channels and exact location of all wells including test wells, monitoring wells, or sampling wells. It does not identify properties within 500 metres of water sources.
2. The Proposal Details opening paragraph indicates “water will be taken from one well related to dewatering, aggregate washing, dust control and manufacturing activities located in the City of Kingston, County of Frontenac, Ontario.” This single well is not identified, or location indicated. However, the Details of water taking then references various sources (South Quarry Sump and North Quarry Sump) for different purposes (e.g. Industrial manufacturing, construction road building aggregate washing, etc.) with different daily max volumes. In each of the activities described the source type is given as “well-drilled” and none identify a draw of water from sump pits yet the arial image of the quarry demonstrates at least 2-3 ponds. As the names “North Quarry Sump” and “South Quarry Sump” imply, water must be pumped from sump pits for some of the activities proposed.
3. The proposal does not identify a water source located in the southwest area of the south quarry where the applicant now pumps drainage to the applicant’s owned lands to the west of the quarry. Is water collected in the southwest sump pit not used for operations and if so, should be indicated in the Proposal Details.
4. A portion of the quarry site is leased to a third party which operates a concrete plant. The third party does not have a PTTW or Sewage ECA for the site. How is the water taking requirements for this operation monitored and reported as well as associated drainage (volume and any contaminants)?
5. There is also an asphalt plant on the site. Although the asphalt plant is currently not used, the application indicates water is required for purpose of asphalt and concrete production. How are third party operator’s water taking activities covered?
6. Most concerning, the maximum daily volumes for each of the sources and purposes are mind-boggling large (ranging from 6.2 Million to 13 Million litres per day per activity). A single drilled well source including any surface water collection could not provide the volumes requested and not detrimentally all neighbouring properties wells. The maximum daily volumes are very confusing. Are the volumes from all sources/purposes to be summed in total?
7. The 2012 Hydro-G study from Morrison-Herschfield supporting document relies on an earlier Hydro-G study by Gorrell Consultants in 1991. The Gorrell study suggests the drilled wells on the site are insufficient to meet the needs of the quarry and that water would need to be delivered by truck.
8. The application does not provide any reference to water taking or drainage needs of an expanded quarry. The applicant currently has an application for an adjacent quarry which is under appeal to the OLT. As an adjacent quarry would be essentially merged with the existing quarry, the water taking and discharge for an expanded overall quarry should be detailed.
9. How are the data and information submitted verified for accuracy? How does the applicant monitor and report on its water taking activities and who verifies the accuracy?
10. Is it appropriate that given a pending decision from the OLT with respect to an adjacent quarry application the PTTW be for a 10 year period?