This amendment is very…

This amendment is very concerning. Please find a list of concerns for each of the proposed amendments as noted in the Design and Operations Report Section 1.1 Executive Summary

1. Update preamble section to include the following: “The Waste Disposal Site is to be used for the screening and bioremediation of non-hazardous petroleum hydrocarbon impacted soils and transfer of non-hazardous impacted soils”

GFL has also requested to remove the condition 3.3 “The site will only accept non-hazardous impacted soil. The removal of condition 3.3 is in direct conflict with the request to update the preamble section. The current preamble is for the operation of a Soil Management Facility to be used only for the receiving and temporary storage of non-hazardous soil.

2. Update Condition 2 (Waste acceptance testing) as per the D&O to conform with the criteria recently released by MOE in the ECA for GFL Moose Creek and Brighton.

The GFL Moose Creek and Brighton facilities are not the same as the Unwin Facility no do the share the same air modeling for the contaminants of concern. The Waste acceptance testing for these facilities must be submitted with this application for approval on the effects of this ECA.

3. Include the transfer ability to receipt, temporarily store at the Site and subsequent transport of non-hazardous contaminated soils off-Site.

How are these soils being managed vs the hydrocarbon impacted soils. What is to prevent these soils from being co-mingled or even blended?

4. Include the ability to receive impacted soils from emergency spills pending analysis results.

The financial assurance is not reflective of these unknown contaminated soils. This would also permit the acceptance of hazardous soils contaminated with any number of constituents. How will these soils be managed? Do these soils require special packing, tarps, containment?

5. Remove Condition 3.3 – The Site will only accept non-hazardous impacted soil.

The removal of Condition 3.3 will allow the facility to receive an unlimited volume of PCB impacted soil. There are no provisions for storage, treatment, transfer, or disposal and there is no Financial Assurance included. PCB soil can cost up to $1,500 per tonne for transportation and disposal.

6. Update Condition 3.4 – “The maximum amount of waste that the site may receive is limited to 5,000 tonnes per day, with a maximum of 950,000 tonnes per year”

This doubles the daily inbound limit from 2,500 tonnes per day. This warrants a traffic study. This facility was originally designed to reduce the carbon foot print by accepting soils for reuse in Toronto and not transferring soil to landfill or clean fill sites. The public consultation that was completed by Water Front Toronto would no longer be valid. GFL should have to complete another round of public consultation for any amendment that changes the original spirit of the purpose of this facility.

7. Remove Condition 3.5(b), - the total amount of Waste and non-contaminated soil that may be stored on the Site shall not exceed 100,000 tonnes at anytime.

GFL has not provided a revised total tonnage. The Design and Operation Report includes a capacity of soil of 100,000 tonnes but does not include a storage limitation of non-contaminated soil. By removing this condition GFL has no limits on the volume of non-contaminated soil it is allowed to have on site. The Financial Assurance only includes 100,000 tonne of soil for disposal. It does not allow for hazardous soil, nor does it allow for non-contaminated soil. Therefore by removing this condition the total amount of non-contaminated soil and hazardous soil that may be stored on site is unlimited. This is also not reflected in the Financial Assurance.

8. Remove Condition 3.7 and 3.14 to conform recent conditions on ECA (Moose Creek, Brighton) recently released by the MOECC Approval Branch.

Condition 3.7 The Company shall ensure that Waste storage piles and non-contaminated soil storage piles are covered with weighted tarps at all time while not in use.

How does GFL propose to control fugitive emissions and dust from the piles of soil? This is an extremely windy location very close to Lake Ontario. How does GFL prevent the wind from blowing the soil off site?

Condition 3.14 The Company must install Site fencing with filter cloth at all Site perimeters.

Removing this condition may have an adverse effect on the environment. How is off site migration controlled when the application also requests that Condition 3.7 is removed so the soil stock piles are not tarped.

9. Update Condition 3.8 – Contaminated Soil storage stock piles shall not exceed 12 metres in height.

Condition 3.8 allows for 8 meters in height for soil stock piles. This would substantially increase the volume on site far exceeding the 100,000 tonnes in the financial assurance. These piles would also be very difficult to tarp unless you remove Condition 3.7 above.

10. Update the Inbound/Outbound soil analysis requirements and procedures for Treated and Outbound Soil transfer to conform to ECA criteria for GFL Moose Creek

The Moose Creek site soil analysis requirements have not been included in this application. They need to be included and the supporting rationale must also be included for review. Waterfront Toronto engaged with the community to build this site. These amendments should be presented to the community in a similar scope as Water Front Toronto presented them.

11. Update Financial Assurance Financial Assurance allows for transportation and disposal of 100,000 tonne of soil (It does not specify if the soil is contaminated or treated or hazardous) for a total fee of $15/tonne. This rate will not cover the transportation to the nearest commercial landfill let alone the disposal fee. GFL should supply multiple disposal quotes to third party facilities that are not owned or operated by GFL. The loading of transportation vehicles does not provide sufficient funds if a third party firm is contracted. GFL should submit multiple quotes for loading from firms not owned or operated by GFL.

Section 4.6 Biocell Monitoring Parameters Table 1.Biocell Monitoring Parameters indicates that the operation of the site allows for Petroleum Hydrocarbon greater than 10,000 ppm will be mixed with less contaminated soil or bulking agent tor uncontaminated soil.

GFL is blending contaminated soil with uncontaminated soil. Blending is not the solution to pollution. Condition 2.8 of the Amended ECA – The Company may not mix or dilute unprocessed Waste with any other waste, soil or materials prior to sampling.

The Certificate of Approval Air No. 9610-84YLE3 is only approved for 2,500 tonnes of soils received per day. The application to amend the ECA for 5,000 tonnes would require an amendment to the Air CofA.

Based on these concerns the amendment application should be rejected.