On May 9, 2006, Lafarge Canada Inc. posted a notice to the Environmental Registry declaring its need to amend their Certificate of Approval for the landfill at its Bath plant.
The Bath plant has been operation since 1973. The landfill contains cement kiln dust (CKD), a byproduct of the cement manufacturing process. CKD is a fine, dry dust released from the cement kiln and captured by the kiln's air pollution control system.
In 1998, Lafarge obtained a Certificate of Approval to dispose of CKD in the landfill based on specifications only for the southern portion. In 2003, the company began disposing of CKD in the northern portion of the site. To this day, Lafarge is operating outside of the management plans that form part of the 1998 Certificate of Approval.
Lake Ontario Waterkeeper and co-application Gord Downie will file our preliminary responses to Lafarge's request for amendments later this week by June 8, 2006. We are asking for a three-month extension so the public can have an opportunity to study the significance of this proposal.
Our first concern is the sheer size of Lafarge's landfill. For every hundred tonnes of cement it produces, Lafarge generates four tonnes of CKD. Between 1992 and 2004, Lafarge has dumped an average of 28,521 tonnes of CDK per year into the landfill. By Lafarge's own numbers, this is the equivalent of the domestic waste created yearly by over 94,000 people. The proposed amendment will allow 240 tonnes of CKD to be disposed each day. This maximum allowable amount is the equivalent of the domestic waste of over 289,000 people.
Our second concern is the potential effect on Bath Creek, Lake Ontario, and local groundwater. Lafarge's proposal does not appear to be based on the most up-to-date science or best engineering practices. In fact, leachate from the landfill is released into Bath Creek, which runs through the town of Bath and into Lake Ontario.
Our third concern is the apparent disregard for Ontario's environmental processes. Lafarge has been operating the northern portion of its landfill for three years without a proper management plan, a required component of the existing Certificate of Approval. This plan should have been submitted before Lafarge began disposing of CKD in a new area and the public should have had an opportunity to comment at that time.
Finally, there is a clear relationship between Lafarge's CKD landfill and its Bath Alternate Fuels Project. The proposed addition of tires, plastics, bones and other waste to its process will change the quality and quantity of the CKD. The CKD amendments make no reference to Lafarge's plan to burn these wastes. The CKD amendments and the Alternative Fuels Project need to be examined together.
In light of these concerns, Waterkeeper and Gord Downie are requesting that the public study period be extended until Fall 2006. If the Ministry of the Environment decides to refuse our request for an extension, we are asking that Lafarge's application to be rejected.
The current deadline for public comments is June 8. Comments can be sent to: Application Processor Environmental Assessment and Approvals Branch Floor 12A, 2 St Clair Ave W Toronto, Ontario, M4V 1L5 PHONE: (416) 314-8216 FAX: (416) 314-8452