Ontario's Old Dumps: Patch them Up or Shut them Down
For almost three decades, from 1980 to 2009, the Moscow Landfill in Camden East operated under a Certificate of Approval (C of A) that imposed few requirements. It only stipulated the site’s location, the maximum size of its “working face”, and the need to cover wastes with soil weekly. No monitoring or testing was required. In fact, no testing was conducted until 2003, when an MOE inspection found the site to be out of compliance with current provincial regulations and policies. In general, the early history of the site reads like a litany of bad management:
- wastes were regularly deposited in wetland areas not suitable for landfill;
- wastes were deposited on a neighbour’s land, forcing the Township to buy (and the neighbour to sell) part of the land to mitigate non-compliance with regulations; and
- groundwater under much of the remainder of the neighbour’s land was contaminated by the waste.
Moscow Landfill uses what is called “natural attenuation” to treat the liquid effluent, called “leachate”, which flows out of the waste into the environment. Leachate can contain contaminants, such as metals and toxic organic compounds, which can pollute ground and surface waters. Soil can remediate leachate through natural processes as long as the leachate’s retention time in the soil is sufficient. In this case, however, the site is situated on fractured bedrock and is close to a river and to a sensitive natural feature (i.e., a wetland). Accordingly, the leachate generated at the site poses at least some degree of risk to both the environment and to the local water supply. Overall, there is little doubt that the site would be deemed unsuitable for waste disposal according to current standards.
Nevertheless, in 2008 the Township expropriated most of the adjacent land and applied to MOE for an amended C of A in order to be able to shift the landfill’s footprint away from the wetland, which, without extending its original footprint capacity of 2.8 hectares, extended its life by 39 years. In issuing the requested permit in 2009, MOE required the Township to construct a clay base under the new part of the landfill, conduct local water monitoring, and create a contingency plan with criteria for triggering abatement actions.
The new operating conditions will certainly be an improvement on the site’s historical record. The facts laid out above, however, beg the question: why not close this landfill and haul the waste to a modern, better-situated facility? The ECO does not agree with the implicit MOE policy of relying on amended Cs of A to justify keeping old landfill sites open in unsuitable or environmentally inappropriate locations.
For a more detailed review of this application, please refer to Section 5 of the Supplement to this Annual Report.
| Recommendation 11:
The ECO recommends that the Ministry of the Environment establish and implement a plan to update Certificates of Approval for Ontario landfill sites, with priorities based on environmental risks. |
| Previous section: Aging Landfills: Ontario's Forgotten Polluters |
| Next section: Shedding the Spare Tires: Rolling Out Ontario's Used Tires Program |
| This is an article from the 2009/10 Annual Report to the Legislature from the Environmental Commissioner of Ontario. |
Citing This Article:
Environmental Commissioner of Ontario. 2010. "Ontario's Old Dumps: Patch them Up or Shut them Down." Redefining Conservation, ECO Annual Report, 2009/10. Toronto, ON : Environmental Commissioner of Ontario. 130-131.
