Appendix A Linda J Rogers Dec.12, 2014
Environmental Review Tribunal Case No. 14-09652
Section I – The Smithville Phase IV Bedrock Remediation Program
The Smithville Phase IV Bedrock Remediation Program (2002)
Background: The small municipality of Smithville (now West Lincoln) gained notoriety in 1985 when PCBs and other contaminants were discovered leaking from a waste transfer facility into the environment… The intended use of the site was to receive and transfer PCB wastes. CWML operated the facility from 1978, when the MOE granted a Certificate of Approval, until 1985, when PCBs were discovered leaking into the environment. During its operational life the facility handled several hundred thousand litres of liquid wastes. Approximately half of the wastes received were reported to have been PCB waste. In 1989, the MOE assumed ownership of the former CWML site and continues, to this day, to be responsible for the site (Report 10, p. 1).
Objectives of the Phase IV Program: The Phase IV Bedrock Remediation Program (the “Program”) was established in 1993 with the goal of protecting public health and safety and the environment and allowing the intended beneficial use of the affected lands. The main stakeholders in the remediation of the Smithville site are the MOE (regulator and site owner), the Corporation of the Township of West Lincoln (the municipality in which the site is located) and the public-at-large (Ibid, pp. 1 – 2).
Source: The lateral extent of the source of contamination was identified as an oval-shaped area approximately 200m by 240m roughly centered on the lagoon area of the former CWWL site…In terms of vertical extent, the bulk of the Dense Nonaqueous Phase Liquids (DNAPL) is found in a layer of rock about 7m thick, known as the Upper Eramosa. The Upper Eramosa extends from about 6 m to 13 m below ground surface at the site… Some DNAPL may have penetrated into the Lower Eramosa and upper Vinemount between 13m and 25m below ground surface. Monitoring results indicate that no significant amount of DNAPL contamination has penetrated below the lower Vinemount, at a depth of about 25m below ground surface.
The DNAPL consists primarily of Polychlorinated Biphenyls (PCBs) (47%), Trichlorobenzene (TCB) and Trichloroethylene (TCE). It is estimated that between 20,000 and 40,000 litres of liquid waste leaked into the environment between 1978 and 1985 (Report 5_1 pp. viii – ix).
Challenges: …[F]ew technologies are available for treating recalcitrant contaminants in complex geologic formations. This conclusion is summarized graphically in Figure 4… (taken from Innovations in Ground Water and Soil Cleanup, National Academy Press, 1997). (Report 4 – Alternatives Report, pp. 57- 58, See Figure 4 below). [Highlights added to tables for ease of viewing].
Sites such as Smithville, with PCB contaminants in fractured rock settings…, are the most difficult to deal with (Report 10, p.3, Refer to Figure 3 Treatability of Contaminated Sites – adapted from National Academy Press, 1997: see table 1 of graphic below].