*NB THERE IS NO PERSONAL…

*NB THERE IS NO PERSONAL INFORMATION IN THIS COMMENT SUBMISSION. PLEASE POST ON-LINE TO THE EBR REGISTRY October 26, 2018 Dear Madam/ Sir, Please accept this submission as Environment Hamilton's formal comments regarding the Revolution Landfilll Acquisition GP Inc. (commonly known as Terrapure) application to launch a pilot project at its 237 Brant Street Facility to transform dewatered biosolids into fertilizer. First, we want to begin by stating that we are confused about why the company is applying to establish this operation at its 237 Brant Street location. In reviewing the application file, we learned that the proponent currently holds an ECA (Waste Management System) that permits it to operate a mobile system for, among other things, the treatment of sewage sludge. ECA No. 6303-4Q9J8G, issued on March 23, 2009, states the following in Condition 2: 2. This Certificate is limited to the use, operation, and transportation of a mobile waste disposal site (processing), specifically mobile dewatering unit and associated equipment, for the treatment of liquid industrial waste, hauled sewage, MUNICIPAL SEWAGE SLUDGE, pulp and paper sludge, and hazardous liquid waste class numbers 122, 123, 146, 148, 149 and 270, as described in the "New Ontario Waste Classes" January 1986. (emphasis added) Further, in its application for approval to operate a mobile unit as part of a pilot project at 237 Brant Street, the proponent references this ECA No. 6303-4Q9J8G, stating that: The pilot project will be conducted using a temporary lime stabilization unit described and approved in Terratec Environmental ECA # 6303-4Q9J8G. To facilitate the pilot study Terratec is requesting an amendment to the Brant Street location approval, ECA # A100143. This will allow the Brant Street facility to receive municipally generated, dewatered biosolids. ECA #6303-4Q9J8G provides for the temporary processing of dewatered biosolids using the Bioset lime stabilization process. The Bioset process uses CaO or quick lime as the primary input for stabilizing biosolids to meet EPA CFR 503 standards for a Class A biosolids material. Our review of the conditions set out in ECA No 6303-4Q9J8G has made us aware of the fact that, while this ECA does permit the operation of a mobile biosolids processing unit, the ECA requires that this unit must be located at least 100 metres from the nearest residential location. Condition 18 in the ECA spells out the details of this requirement: 18. The Mobile Unit shall only be operated at a site which is located at least 100 metres from the nearest residential location, unless written approval is given by the District Manager to operate within the 100 metre limit. Further, in the section of the ECA where justifications are provided for the inclusion of each condition, the following explanation is provided for the need for Condition 18: 13. Condition No. 18 is included to minimize the possibility of any environmental adverse effects caused by the operation of the waste management system. This leads us to raise some questions and concerns. First, we need to point out that the 237 Brant Street facility is located as close as 20 meters to a residence. In contrast, the company's Eastport Drive location is almost 150 meters away from the closest residence. This leaves us wondering several things. First, why does the proponent need to set this operation up at the Brant Street location especially when the 100 meter minimum distance from the mobile processing unit cannot be achieved? Second, unless we had learned about the existing approval for the mobile unit, we would not be aware of Condition 18 and the requirement that the unit be located at least 100 meters from the nearest resident. This also makes us wonder does the proponent not also need to secure an amendment to ECA No 6303-4Q9J8G to allow the mobile unit to be located a distance less than 100 meters from a residence? Finally, why would the proponent not take what would appear to be the obvious step here locate the mobile facility at its 200 Eastport Boulevard location, where, it would seem, the proponent is already approved to operate the unit? Should the MECP decide to approve the amendment to ECA No. A100143 we would argue that the same protection to nearby residents must be upheld. The proponent should be required to locate the mobile unit at least 100 meters from the nearest residence. This will limit where, on the 237 Brant Street site, the unite would need to be located but we believe that there was a reason for the 100 meter requirement in the original approval and it should hold, regardless of the location where the unit is being set up. And, so, if MECP opts to approve the requested ECA amendment, we request that the following conditions be added to the approval: -A condition that the Mobile Unit shall only be operated at a site which is located at least 100 metres from the nearest residential location -A condition setting out a 1 odour unit limit at the fenceline of the 237 Brant Street facility -A condition that makes it clear that the amendment is to approve a pilot project for a 12 month period as the proponent has indicated is its intention. We are also concerned at the existing ECA No. A100143 is very old it was issued in 1990. We are requesting that, should the MECP opt to grant the requested amendment, that it update the ECA so that it reflects the activity that the proponent is requesting it be approved to undertake at the site. We want assurances that there any conditions in this old ECA do not create issues for this current proposal. For instance, the current ECA permits up to 8000 tonnes of waste on site at any given time as well as allowing waste to be stored on-site for up to 180 days! These permissions certainly would not be appropriate for a site handling biosolids. Finally, we also have concerns about the Schwing Bioset process and the generation of ammonia. We want assurances, should this pilot be approved, that there will not be any issues with ammonia odours. We also wonder whether there will be any wastewater generated that contains ammonia. The proponent makes reference to this possibility in their application. Will this happen and how will this wastewater be handled? We want the MECP to clarify requirements for proper handling of any wastewater generated by this mobile unit. We thank you for the opportunity to comment on this application for an amendment to ECA No A100143. To summarize, we are concerned about the location of this facility so close to a residence. Further, we are confused as to why the proponent would not simply apply for approval to run the pilot at its 200 Eastport Boulevard location. It would appear that they are already approved to do so, given that there is more than a 100 meter minimum distance to the closest residence at the 200 Eastport Boulevard location. Thank you Lynda Lukasik, PhD Executive Director Environment Hamilton TEL: (905) 549-0900