The CSRD has expressed their disappointment with the Ministry of Environment in how they handled a recent noncompliance report.
In early August an environmental protection officer identified several areas of concern at the Revelstoke landfill, which he outlined in a letter to the CSRD. He also made requests for improvement, the CSRD had 30 days to respond, or face up to $300,000 in fines.
“The CSRD continues to submit annual reports, groundwater reports, conformance reviews and (Design and Operating Plan) updates, with no feedback from the (Ministry of Environment),” reads the response letter from the CSRD to the ministry. “Within the (ministry), it is abundantly evident that the Compliance Division and the Authorizations Division are not adequately informed of each other’s activities, which is causing a lack of clear direction and expectations for operators of natural attenuating landfills in the CSRD and within the province.”
The CSRD responded to 11 areas of concern outlined in the ministry’s Aug. 2 letter:
1. Adherence to the design and operating plan, including insufficient daily/intermediate cover, no landfill gas monitoring, no geotechnical inspection and land surveys.
According to the letter, the CSRD will be completing litter control work along the northeast corner of the landfill with plans to extend the controls in 2020. They are also exploring options to reestablish landfill gas monitoring at the site. A new cover/compaction and site maintenance and operations agreement will be issued Oct. 1 and CSRD staff will provide training to the new contractors.
2. Lack of surface water diversion works that were supposed to be constructed when Phase 1 closed as well as exceedances in groundwater and surface water parameters.
“It is the CSRD’s intent to request an amendment to Section 2.6 of the Operational Certificate to enable the CSRD to achieve compliance with groundwater quality requirements within the site boundaries, given current conditions,” the letter reads.
3. Waste deposition and compaction meets BC Landfill Criteria.
The CSRD has reviewed the appropriate section of the Design and Operating Plan with the site operator.
4. Ministry noted a large number of birds at the site.
“As you may be aware, landfill sites attract birds,” the letter reads. However, the requirements to supply sufficient cover to the waste and reduction of litter has been reviewed with the site operator.
5. A landfill operator that has the proper BCLQLO training must be present at all times during operating hours.
The current contract expires at the end of September and the prospective bidders for the contract have been notified that this is a requirement. The CSRD also noted that there are limited course offerings and equivalent training will be provided until the course is being offered.
6. Excess litter and lack of litter fencing was identified as a problem.
“The CSRD will be installing litter netting, similar to the netting used at golf driving ranges, in the fall of 2019,” the letter reads. “In addition, additional control measures such as appropriate cover application, and increased frequency of litter clean-up has been reviewed and initiated with the site operator.”
7. Operations and Maintenance Manual not reviewed and updated as required.
The documents are reviewed more than once a year by the site operators as well as CSRD staff involved in solid waste management.
8. The annual report was late and was missing information including details on bear sightings.
“The CSRD has made changes to the format of the annual report over the years and up until receiving the Warning Letter, the CSRD has received no input, no comment and no direction on the annual reports submitted from the years 2010 – 2018,” the response letter reads.
Since they had no feedback, the CSRD assumed the reports were satisfactory, however next years annual report will include an executive summary, details on bear sightings and a summary of new information and changes, as requested.
9. The ministry does not have any Five Year Reports on file from the landfill which means a detailed hydrological assessment and an update on the financial assurance mechanism has not been reported.
The CSRD has hired a contractor to prepare a hydrogeological assessment and will be submitting it as part of a Five Year Report before the end of the year. The CSRD will also be working with the ministry to determine the appropriate value for the landfill liability fund.
10. The CSRD did not review and update the closure plan every five years as required.
The CSRD’s 2019 Design and Operating Plan includes a detailed closure and post closure plan for the Revelstoke Landfill.
11. The CSRD does not have enough money to cover final landfill closure and post closure costs.
“The liabilities for closure are itemized for each phase of the landfill’s development,” the letter reads. In the Five Year Report that will be submitted by the end of the year, the CSRD will include an updated cost report for closure and post-closure.
In closing the CSRD invited the ministry to do a follow up site visit to review the operations.