On July 13, Lake Ontario Waterkeeper and Gord Downie filed a comment with the Ministry of the Environment under the Environmental Bill of Rights, asking for a public hearing to scrutinize Lafarge's request for a revised permit for its cement kiln dust landfill in Bath, Ontario.
Lafarge opened the cement kiln dust (CKD) landfill on its property in 1975. CKD is the dust captured from the cement kiln's exhaust gas by the air pollution control system. It is made up mostly of raw feed materials, fuel ash, and minerals/salts, and it is a corrosive, toxic substance. Exposure to wet kiln dust can cause serious, potentially irreversible tissue damage to the skin, eye, or respiratory tract due to chemical burns, including third degree burns.
Each year, Lafarge dumps an average of 28,521 tonnes of cement kiln dust into its landfill. That's the equivalent of the domestic waste created by 94,000 people annually. The company has a certificate of approval for the landfill, but it has been operating the northern portion of the site for three years without an approved management plan. The plan is a â€œrequired componentâ€? of the existing Certificate of Approval and the focus of the EBR comment process.
Lafarge's application went through a public comment process in May, but Waterkeeper asked for more time to review the proposal. We didn't get the three months we asked for, but with 30 days and more documents to study, we uncovered a number of serious issues with the cement kiln dust landfill.
Our biggest concern is the potential impact on local waters. Leachate from the landfill is released untreated into the Bath Creek, which runs from the landfill through the town of Bath and into Lake Ontario. Lafarge is allowed to continuously discharge into the creek as long as monthly monitoring does not indicate greater than 50% mortality to fish. In 2001, Lafarge reported two of these mortality tests where all organisms died at 100% concentration.
Sample results reveal a number of contaminants found above Ontario's Provincial Water Quality Objectives in the past, including: Silver, Aluminium, Cadmium, Iron, Molybdenum, Nickel, Strontium, Zinc, Phosphate, and Phenols. Where the Bath Creek exits Lafarge's property, the highest levels were cadmium (560 times PWQO) and molybdenum (500 times PWQO). Strontium was found at 19,285 times PWQO levels on Lafarge's property just downstream from the Landfill area.
Concerns about local water quality are amplified by reports of dust falling on neighbouring property and potential impacts of the Alternative Fuels project on the makeup of the cement kiln dust. The Ministry of the Environment has warned Lafarge that dust from its plant found on neighbouring property in 2005 is a violation of the Environmental Protection Act, but no enforcement action has ever been taken.
Meanwhile, the both Lafarge and the Ministry remain silent on the potential impacts of the Alternative Fuels project on Lafarge's landfill. The Project will allow the company to burn â€œAlternative Fuelsâ€? such as pellets, tires, plastics, and other materials to help reduce its fuel costs. If Lafarge receives a certificate of approval to incorporate alternative fuels into its process, the composition of the CKD will change; thus, the composition of the landfill will also change and the monitoring and mitigation needs of the Landfill could be impacted.
What's more, many of the contaminants found in alternative fuels imported from other regions (such as tires) will end up in the CKD landfill in Bath. But Lafarge's CKD landfill application makes no reference to alternative fuels or the potential changes in the levels/types of contaminants in the CKD resulting from the use of alternative fuels. Similarly, Lafarge's recent applications to the Ministry of the Environment regarding its Alternative Fuels Project make no reference to the effects on the CKD landfill.
With all of these concerns â€“ water, air, missing information, and so on â€“ there is clear reason to hold a hearing under the Environmental Protection Act. This is the process that helps us make sure the site is engineered properly, waterways and area residents are protected, and environmental impacts are prevented. This is the process we need.
You can read more about our arguments in our official submission, which is available on our web site: www.waterkeeper.ca.