MY SEPTEMBER 19, 2017 RESPONSE TO GHD (Consultants) REGARDING EXPLOSIVE METHANE LEVELS IN BOLENDER PARK LANDFILL

In fact GHD, consultants to both Lanxess Canada and Woolwich Township, reviewed my August 22, 2017 Delegation to Woolwich Council. Their review was in my opinion rather mealy mouthed. By that what I am saying is that they tried to show disagreement with my Delegation when very little to none actually existed. My Delegation was very factual and focused on technical reports produced for the Township by CRA (Conestoga Rovers) who also were consultants for both Uniroyal Chemical and Woolwich Township. That was/is a gross conflict of interest however Woolwich Township have long had great self-serving abilities to misunderstand what a conflict of interest really is.

Following is the verbatim text of my response to GHD and Woolwich Council:







"MR. MARSHALL’S SEPTEMBER 19, 2017 RESPONSE TO GHD’s REVIEW OF MY AUGUST 22/17
DELEGATION TO WOOLWICH COUNCIL

GHD have written a report on behalf of their client, Woolwich Township, responding to my August 22, 2017 Delegation to this Council .

GHD claim that they had a methane gas collection system operating from 1983 until 2015 on pages 2 and 10 of their Review. 1983 is likely a typo and 2015 is inaccurate. The Collection System was built in 1984. It may very well have been plugged in to its’ power source throughout and the blower may have been working but it wasn’t blowing either soil gas or landfill gas (methane) the whole time. This can be readily ascertained by the gas probe readings along the length of the collection system between 1998 and 2015. It’s not that the methane readings were zero it’s that the readings simply don’t exist. The reasons vary from the probes being flooded, not found (ie. buried), blocked with debris, caps missing allowing air intrusion, to simply not being measured. Totally unsuccessful attempts at readings were made in 2007 and since then no further attempts have been made. Even at the blower pump in the early and mid 1990s there have been readings of zero. As per page 3 of the March 1998 CRA Report “…combustible gas was not detected at the blower, indicating that combustible gas is not being collected by the system at a measureable concentration.” This page is being included in my handout to Council. The other problem GHD have with their claim of ongoing operation is more of their own words back in 1998. I have included in my handout to Council, page 5 of CRA’s March 3, 1998 Report. It states “Due to the high water table at the site, the existing Gas Control System is of limited use. In addition the Gas Control System does not appear to be functioning. It is, therefore, recommended that the existing Gas Control System be abandoned.”. Further to GHD ‘s claims of ongoing operation of the gas collection system is their own next report, nine years later. That would be in 2007. On page 5 they stated “ The Landfill Gas Collection System does not appear to be operating effectively due, primarily to the high water table at the time of monitoring. It is still recommended that the current Landfill Gas Collection System be abandoned.”. While all of these reports and hence quotes are in Woolwich Township hands I am nevertheless including copies of the pages as I seriously doubt Council have read any of them nor will look them up to confirm the quotes. It is my opinion that GHD’s claims today that the system was operating from 1983 until 2015 are wishful thinking. It could also be a loyal attempt to support both their client and their own CRA colleagues, by advising that this inadequate gas collection system worked successfully for thirty-two years. It did not as per both their own text and data.

On page 2 of GHD’s September 14, 2017 Review of my Delegation they state that there have been 28 gas probes installed around the site since 1983. That is correct. Their distribution has been zero on the south side of the landfill, six on the east side, eleven on the north side and eleven on the west side. Over the last twenty-one years, exactly 8 gas probes of the 28 have been successfully monitored. Over the entire 34 years there has been of course zero monitoring attempts to the south (o probes), seventeen successful monitoring attempts to the east (6 probes), fourty-seven successful monitoring attempts to the north (11 probes), and sixty-nine successful monitoring attempts to the west (11 probes). That is an obvious locational bias in both probes installed and in probes successfully monitored. The point I’m making is that regular and ongoing gas probe monitoring for methane gas around the perimeter of the site has not occurred . The bulk of the monitoring has been at the auto recycling yard for some peculiar reason, while diligently avoiding the south into the park and the east into the residential subdivision.

On page 8 of GHD’s Review of my Delegation they comment on very high methane gas readings found twice in 2008 and twice in 2010 at the gas probe a mere 26 metres (85 feet) from the nearest home on High St.. They state that this distance “provides a buffer against landfill gas migrating to the residence.” . That is a shocking claim and I doubt that any other landfill gas expert would ever make such a statement . In fact CRA/GHD in their February 2009 Report in their Conclusions and Recommendations suggested that “…the Township may wish to initiate an indoor air monitoring program with contingencies for basement spaces and other enclosed environments in the closest residence on High St….”. This is the exact same residence but is only referring to the 2008 monitoring results. 2010’s were both higher. Speaking of those results GHD stated that the concentrations were “above the 20% LEL trigger.”. That is correct. They were 80% LEL, 350%, 390% and finally 420% LEL .

Lastly we will mention GHD’s claim that there are no “receptors” south of the currently claimed location of the Bolender Landfill. I did advise Council verbally last Tuesday that the 2016 Geotechnical Investigation for the new Splash Pad had a little surprise in it. While the consultants were discreet in regards to their findings, they were honest about them. “Organics” and “ organic materials” were found and mentioned on page 3 as well as in all six boreholes they drilled. The term is also used in GHD’s September 14 Review we are discussing. It is at the bottom of page 1, in the footnote. Organic materials folks are what you put in your compost. They are foodstuffs and yes eventually they turn into soil but in the anaerobic, bacterial process they release methane gas. Therefore I have provided a map to Council which shows the location of the splashpad relative to George St.. As municipal garbage apparently is present underneath the park then it’s likely right beside the backyards of the George St. residents. There are your receptors GHD and you and CRA have never tested for methane gas in the park area, much less further north at the alleged southern boundary of the Bolender Park Landfill.

There are many other problems with GHD’s Review of my August 22/17 Delegation. These include their nitpicking about industrial wastes not being municipal wastes not being chemical wastes etc.. There are other sources than the two GHD mention (Jackman/MOE & Environmental Audit) that indicate there are chemical wastes from Uniroyal in the Bolender Landfill including NDMA, resins and leftover 2,4-D wastes in filter cloths. The good news is that the Bolender Landfill was rejected as a significant source of NDMA to the Elmira Aquifers although this upgradient from Uniroyal groundwater , in 1991, was above the Ontario Drinking Water Standards for NDMA .

My deepest thanks to GHD for their Review as it has further clarified the gaps in CRA’s reports and they have shown that a proper methane evaluation still needs to be done at the Bolender Park Landfill. Also my thanks to Woolwich Council for authorizing this further expenditure on consultants, all towards the goal of protecting property and lives around this landfill.

Alan Marshall proud CPAC & EH-Team member"


Since that date Woolwich Township have installed another methane gas monitoring probe to the north of the landfill (near Elmira Pet Foods) and finally after 36 years one monitoring probe to the south at the edge of the park itself. I take that as both an admission that my advice was accurate/correct and as a compliment. Nothing of course will "fix" the failures of the last 36 years however if they put in more probes both east and south and monitor ALL of them (N, S, E & W) regularly say monthly then in a couple of years I would feel much more confident that they at least understood the situation. It still likely requires the construction of a new methane collection system for which they should be discussing/negotiating directly with the owner of 86 Auto Recycling, namely Mr. Frank Rattasid. Of course their behaviour and attitude towards Mr. Rattasid and his business need to be radically improved for that to happen. Refusing to negotiate in good faith and forcing local businesses to go to court over black and white issues such as an illegal municipal waterline on their private property and then the Township hiding behind taxpayers money is contemptible and does not serve the public interest.