Revolution Landfill Acquisition GP Inc. - Environmental Compliance Approval (waste)

Many of the comments we received shared similar concerns, specifically:

1. The potential for impact from nuisances such as odour, noise and dust; many of the concerns being related to odour impacts.
2. The proximity of the pilot program to places like residential areas, parks, schools, and businesses.
3. The environmental stress this pilot would contribute to the area.

We share the concerns raised in the comments.  We reviewed the application and supporting documentation submitted by Revolution and, where applicable, have imposed conditions in the existing Environmental Compliance Approval (ECA) to address these concerns.

Regarding concerns raised over the potential impact from nuisances such as odour, noise and dust. Revolution was requested by the ministry to develop Best Management Practices (BMPs) for Odour, Noise and Dust during the 12-month demonstration. These BMPs have been reviewed and added as a condition of approval.

In addition, a condition has also been imposed to require the company to establish a Complaint Response Procedure to ensure that action is taken in the event of any substantiated complaints, including ceasing operations if it is determined that the pilot program is the source of any nuisances. If complaints are received by Terrapure for odour, noise or dust, and it is determined that the demonstration is the source, operations at the facility will cease until corrective actions are undertaken. Response to the complainants will be provided noting actions undertaken.

Regarding the concerns raised with the effect this pilot would lend to the cumulative impact from odour in the area, many of the comments spoke of odours from the City of Hamilton's composting operation at their Resource Recovery facility located at 1572 Burlington Street, 3.6 km away from the Brant Street facility where the City of Hamilton temporarily ceased operations at the Resource Recovery facility after a high number of complaints and resumed operation after removing all waste from the facility and power-washing the entire facility. The BMPs for odour developed by the company will aim to minimize the potential for fugitive odour impacts near the Brant St. Site. Should fugitive odour emissions occur because of the pilot program, operations will cease until the source is determined and the issue addressed. Repeated odour emissions and/or complaints from operations will result in the company ceasing the demonstration.

A couple comments raised concerns regarding the generation of ammonia from the process and its contribution to potential odour impacts. The equipment contains a wet scrubber used to capture ammonia emissions from the process. The resulting wastewater will be contained and shipped off-site by Revolution. There is no anticipated impact from ammonia odours. Any unexpected fugitive ammonia odours would be dealt with the BMPs and Complaint Response Procedure detailed above.

Regarding the concerns were raised with the proximity of this location to residential areas, parks, schools and a business district, the City of Hamilton was consulted regarding the site zoning and the uses permitted. As a result, the company was required to obtain a Certificate of Zoning Confirmation from the City. The Certificate was issued on May 2, 2019 verifying that the proposed use was permitted on the property. As part of ECA No. 6303-4Q9J8G for a mobile waste management system, the owner of the mobile unit will be required to obtain approval from the Ministry of Environment, Conservation and Parks, Hamilton District Manager prior to use of the mobile equipment if a resident is located within 100 metres of the Site.  Comments were submitted noting that residents are located as close as 20 metres to the site.  Revolution will be required to verify the need for Hamilton District Manager approval should non-conforming residents be located within the 100 meter radius. An MECP Environmental Officer visited the site and could not verify any residents within twenty metres of any part of the property boundary. The City of Hamilton's Planning and Economic Development Department stated in a November 28^th, 2018 memo that no residential zone exists within 300 m of the site.

Concerns were raised regarding the impacts to traffic this demonstration will have. With only two incoming trucks of waste material per day, no impact to traffic is anticipated.