Problems noted on PTTW…

Problems noted on PTTW Application by Coco/GIP on July 21, 2022

Many required fields on the application form are missing information. (No business number on page 2, most of Pg 4 is blank, pgs 5, 6, 7, 8 are incomplete)

2. The Map requirements in Section 10 are not met. The attached map does not identify all wells, springs, names of property owners or dwellings within 500 meters of water sources. The map should indicate the exact location of every test, monitoring and sampling well.

3. The water source is described differently in different areas of the application. The Environmental registry indicates the source will be a single well. This not accurate, the quarry does not draw from a well, it draws from 2 sump ponds. There is apparently no dug well on the property, and the drilled wells that do exist are very low yield or dry.

4. The location of the north sump (sump 1) is shown on the attached map, but the south sump (Sump 2) is not. Where exactly is sump 2?

5. A new sump has been installed in the southwest corner of the south quarry, where all quarry drainage now exits. Has this sump been used, or will it be used in the future, as a water source for industrial purposes? Has it or any other pond on the site historically been used as a water source? Aerial photos show crushing equipment at different times and locations throughout the quarry, usually near a water source other than the sumps described in the Elginburg PTTW.

6. A portion of the North quarry is leased by a third party for a ReadyMix concrete plant. The plant has no PTTW or Sewage ECA. How are water takings & drainage associated with this plant monitored or reported? The disposal location of contaminated water and sludge from Concrete truck washouts should be specified. Assuming drainage from the Concrete plant mingles with quarry water during rain/flood events and eventually exits in the SW corner as “quarry” drainage, how would responsibility be determined if exceedances were noted in the monitoring reports?

7. There is also an Asphalt plant on the site, currently decommissioned. The application claims water is required for Asphalt and Concrete production, but neither plant currently consumes or needs water under the Elginburg PTTW. (The ready mix plant apparently trucks all required water into the leased area) . This should be clarified in the application.

8. The application relies on a 2012 Hydro-G study by Morrison-Herschfield for background information. The MH study relies on earlier HydroG studies by Gorrell Consultants. The 1991 Gorrell Study indicates the wells drilled at the quarry are not sufficient to meet the needs of the quarry and water will need to be trucked in. However the PTTW application claims all water required by the quarry and asphalt plant arrives by ground or surface infiltration. This is contradictory.

9. In 2019 the water / drainage in the south quarry was radically altered. The original drainage ditch near the eastern boundary was essentially taken out of service, and is now reserved exclusively for overland water from the CRCA watershed. However, until 2019 the overland water (identified on the map as “Main Drainage Ditch”) was mixed with quarry volumes via internal quarry ditches, and separating overland water from quarry volumes was virtually impossible. This was particularly important with respect to monitoring requirements under the PTTW and newly acquired Sewage ECA. As there was no way to distinguish quarry volumes from overland volumes, accurate monitoring of total quarry discharges and contaminants was impossible. To complicate matters further, the main drainage ditch was impounded within the quarry by a previous licensee and used as a settling pond for quarry purposes. The overland water arriving into the quarry obviously provided an additional water source, but how that water was reported remains unclear. Given that overland water is no longer available for quarry use, and the deficits described in the 1991 Gorrell Study regarding insufficient well quantities, the water volumes claimed in the application are difficult to understand. Full clarification should be provided and previous monitoring reports subject to audit.

10. The application makes no mention of drainage/water requirements of an expanded quarry. As the ministry is aware, an application for an adjacent quarry was submitted in 2017 and is currently under appeal at the OLT. The proposal is to merge the existing quarry with a new quarry under separate licenses, while using the existing drainage system to drain the new expansion areas on both sides of the pipeline corridor. The new sump /exit point at the southwest corner of the existing site will be used for expanded quarry operations, as will the culvert underneath the pipeline which currently drains the north quarry into the south quarry.
The SW sump is an unproven dewatering idea, whereby quarry water will accumulate in the sump and drain / percolate randomly through the south escarpment wall onto the adjacent farm property, and when the sump reaches capacity the water/sewage would be pumped onto the proposed expansion area and down the south escarpment via random flows. Strong concern about flooding the adjacent farm has been expressed, but there is no mention of off-site dewatering concerns or public complaints in the application.

11. There is no calculation for water / drainage requirements for an expanded quarry in the application. This is crucial with respect to water requirements, as the current water source is essentially rainfall, arriving via limited ground and surface sources within a high risk aquifer area. Climatic possibilities such as drought or flooding are not considered in the application

12. Given the scarcity of water across the Elginburg region, one would assume conservation would be a top priority. However water conservation and Best Management practices (Schedule 1) are barely addressed in the application.

13. Encroachment of drainage feautures into legal setbacks (pipeline corridor and adjacent property) are not addressed. As mentioned, overland water still travels through the quarry via the “Main Drainage Ditch”, but the critical entrance and exit points are not at ground level: they are channels blasted into the legal 15 M excavation setback, where excavation is not permitted.

14. The drainage culvert under the pipeline (draining the north quarry into the south) is situated within a legal setback and is apparently nonconforming. (Excavations are not permitted within setbacks). The carrying capacity of the culvert has not been demonstrated and the situation is inherently problematic for the adjoining landowner. The culvert is a crucial site feature but is not shown on the existing MNRF site plan.

15. The map shows the “eventual route of tributary to Collins Creek” as a dotted line within the 15 M legal setback of the south quarry. This is not a workable idea. First, large berms of unidentified material now reside along this 15 M setback and are required for noise mitigation. Second, water will not flow naturally in a straight line at ground level down a legal setback, and then take a sharp right-angle turn in the southeast corner as shown. An excavated ditch or channel would be required, but no excavation is permitted within legal setbacks.

16. The Daily Discharge Rates as reported in Table A at the end of the application do not seem plausible. To take one example, the tables on pages 4 to 8 claim pumping occurred 24 hours a day for more than a year. It’s not clear if the discharges/takings occurred from Sump 1, Sump 2 or the sump in the SW corner of the south quarry. Assuming the table applies to total quarry discharge from the SW corner (the only location where discharge from the entire site could be calculated) this is an enormous amount of discharge. Yet for a similar time period across 2018, the tables claim only 1 hour pumping per day on average, with dramatically different discharge totals.

The application also indicates maintenance “dewatering” may not be dewatering at all, but alternate uses such as manufacturing and dust control. This underlines public concern about accurate reporting of volumes at this site. It undermines the reporting requirements for each sump, and makes monitoring difficult to track and understand. How can total volumes exiting the quarry be calculated, if reported “dewatering” volumes have actually been used internally, for different industrial purposes? Such discrepancies should be explained.

Similarly, the discharge rates reported in table A for 2016 show regular discharges occurring in 2016, but that data is contradicted by a record obtained under FIPPA for the same time period. The FIPPA record indicates zero discharges occurred. Which is correct? It should also be noted the application provides no record of discharges/dewaterings for 2019 and the record for 2018 is incomplete. This is the time period when quarry use of the original drainage ditch ended, the ditch was reserved for overland CRCA water and south quarry ditches were re-designed. Pumping by hose began from the SW corner onto adjacent lands at that time. The local ministry office claimed all discharges were being monitored and reported, but why is 2019 data missing from Table A? Of particular interest is the discharge record for Dec. 4, 2018 and mid-May, 2019.

17. On pgs 2&3 of the Morrison Herschfield letter (contained in the application) reference is made to a discrepancy between the groundwater monitoring data provided by the applicant and the quarterly reporting requirements under the PTTW. The discrepancy can probably be explained by the different requirements under the PTTW (quarterly) and the Sewage ECA (tri-annually) but there is a fundamental difference between the two: the PTTW applies to volumes, while the Sewage ECA applies to contaminants and quality. The application should acknowledge the difference.

18. The water table indicated on the “existing features” page of the Elginburg quarry site plan appears to be incorrect. The north quarry water table is described at 116.9 MASL, while the south quarry is indicated at approximately 112.5 MASL at the south end. The north quarry information appears to be inaccurate. The Gorrell HydroG study (on which the MNRF site plan is based) indicates the north quarry water table is nearly 10 meters higher, at approx. 125 MASL near the pipeline corridor, and over 130 MASL further north near Unity road. These numbers are corroborated by Morrison-Herschfield’s subsequent HydroG study and are shown on the site plans for the proposed quarry expansion. The estimated level of 112.5 MASL in the south quarry seems accurate based on the Gorrell and MH studies. It’s unclear how the north quarry water table was incorrectly noted on the site plan, but the error has implications for north quarry operations such as asphalt production and RAP storage. The entire floor of the north quarry is approximately 125 MASL, and RAP stockpiles must be 2 meters above the water table. Until recently a huge RAP stockpile existed near Sump 1 in the north quarry. In other words, the RAP stockpile was apparently not 2 meters above the water table. There has been public concern over this situation for years, and it should be addressed in some way in the application and any PTTW /Sewage ECA monitoring requirements.

19. A follow-up concern regarding asphalt production: the onsite plant has been shut down since 2018 and plans for future production are unknown. The recent removal of the RAP stockpile suggests production is unlikely to resume any time soon. Given that the water table near the pipeline is 125 MASL (not 116.9 MASL as claimed on the site plan) and the floor of the north quarry averages 125 MASL, this precludes future stockpiling of RAP on the quarry floor, as it must be 2 M above the water table. Without a nearby source of RAP, asphalt production is even less likely to resume, which would alter the PTTW requirements in the application.

20. The “proposal details” posted on the ERO do not match the details contained in the application. The ERO posting indicates 4 categories for each sump with designated water takings per day. However the application includes 6 categories, not four. By themselves the additional amounts total more than 20 million liters per day, which is more than entire allowable takings (19 million LPD) under the 2018 PTTW.

If one adds the total amounts allowed under the 2018 PTTW, the maximum takings total 73 million LPD, not 19 million LPD as stated by the current permit. The discrepancy is hard to understand. If there is a connection between the dramatic increase in total requirements and the proposed quarry expansion, this is not an appropriate way to do it.

21. Given that an adjacent quarry has not been approved and the application is under OLT appeal, the need for an entirely new PTTW remains a possibility. Renewing the existing permit for 10 years - without clear explanation for all volumes requested - seems inappropriate on many levels. A safer option would be to renew the permit annually until things get ironed out.

22. The groundwater inflow stated in the application is 1,362 Cu. Meters per day, and one would assume this applies to the entire quarry. The calculation is apparently based on a third party equation/formula which includes the difference between the water table elevation and the quarry floor elevation. A difference in elevation of 29 meters is claimed in the application, but the current difference - in the north quarry at least - appears to be much less, between 7 and 10 meters. This should be clarified.

The 2016 MH HydroG study confirms the site contains very few water bearing fractures, and this finding is supported by the earlier Gorrell Studies and dry wells across the quarry region. This leaves the site highly dependent on rainfall, a situation that would become critical during drought conditions which often coincide with intense summer activity at the quarry. Despite this, a generic industry equation was apparently used to calculate quarry inflows. Curiously, the inflow amount of 1,362 Cu. M per day (mentioned above) is exactly the same amount estimated for the north quarry alone at full extraction in the 2016 HydroG study by Morrison Herschfield. The inflows to the south quarry at full extraction were estimated at 2,622 Cu Meters per day in the same study. This would total close to 4,000 Cu Meters per day for the entire quarry - a completely different amount.

Discrepancies like this suggest the application contains unreliable data and should be reviewed very carefully.

This concludes my comments on the application.