moe waste presentation for sdg summit oct 2013

Waste Management (Waste Disposal Sites)

October 2013

Lisa Chalmers, Sr. EO, Cornwall

Overview

1. Waste Disposal Sites (landfills and dumps)2. Ministry role3. Legislation

EPA• Approvals and Orders

Regulation 347 • Operations (post 1990 sites)• Defines waste • Waste Handling requirements

3. Operational Considerations4. Resources

Ministry of the Environment – unofficial and for discussion purposes only

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Dumps vs. LandfillsLandfill BMP are incorporated in the Operations and Design (O&D)Plan

Better cover is possible (contributes to better

environmental protection) Cell progression is formalized/planned = foot print adhered

to Environment protection

Reduced odours & vermin water infiltration reduced Can capture leachate & gas Isolate/protect the ground water and reduced impacts to

surface water Lift method employed > allows for compaction, small

surface area is active = better use of capacity and less cover and less odour

Cost (may be higher cost during operations but long term costs mitigated)

Stability of slopes for closure – reduced breakoutMinistry of the Environment – unofficial -

for discussion purposes only3

Dump Method

Ministry of the Environment – unofficial - for discussion purposes only

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can not cover(vermin/ infiltration or run-off/odours) uses excessive amount of

cover poor use of WDS approved

space

Landfilling Method - less cover (if follow best practices and O&D)

- best use of space and less exposed waste - lessened concerns with long-term/short

term environmental impacts

Ministry of the Environment – for discussion only 5

The ministry and you … “one window”

Cornwall Area Office (most offices) assign Environmental Officers based on geographic areas. The local office (EO) should be your first point of contact for questions and discussions.

Environmental Approvals Branch (EAB): review ECA applications and issue approvals. Sometimes they will be in direct contact with the Township or consultants to resolve questions. EAB also contacts the local EO for input (examples – tree coverage, alternative cover, odour issues..)

Technical Support Staff (hydro geologist, surface water specialist, Air Scientist, Pesticide Officer): This group review annual reports and monitoring programs upon request of the EO (reports to go to the District Office and then will be forwarded). If consultation will be beneficial to address significant issues or changes being contemplated – it is arranged through your EO

Ministry of the Environment – for discussion purposes only

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The Ministry and Landfill Owners/Operators

The ministry regulates through legislation and confirms compliance through:

inspection programs Review of Reports Address on complaints

“one window” approach to provide local knowledge Local ministry staff provide feed back for approvals Conduct Inspections Available to answer questions and provide information

The ministry may require work to be done in control documents issued OR as a result of inspection findings. The Owner conducts the work, or retains a consultant (depending on site, work etc.)

Ministry of the Environment – unofficial - for discussion purposes only

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Operating a LandfillInvolves numerous considerations

Legislation - general requirements

Control Documents – specific requirements

Operational and Design Plan (O&D)

common sense (diligence)- rely on staff observations

Communicate with other WDS Operators

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Example

Hazardous Materials: • legislation dictates what wastes are “hazardous” or “subject

waste” • Approval will dictate what can be disposed at a given WDS. • Municipal policy may dictate what they choose to accept

(dead animals, asbestos)

Operational Requirements (Daily Cover/Burning): required in Approval and in legislation but a municipality may look at alternatives because of local issues, costs, materials available.

Ministry of the Environment – Not to be considered official direction - for discussion

purposes only

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Legislation and Control Documents (Instruments)

Legislation:• Environmental Protection Act (EPA) … Part V

• Regulation 347 (General Waste Management)

• Other legislation (recycling 101, 102, 103)

Ministry of the Environment – not to be considered official direction – general

overview only

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>

Environmental Protection Act (EPA) . Authorizes Approvals and Orders

. Act governing Regulation 347(waste) and Regulation 419 (air) and the “3Rs” regulations

Ontario Water Resources Act (OWRA) . Authorizes Approvals for Sewage Works

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Approvals

Ministry of the Environment - CONFIDENTIAL for discussion purposes

only

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Environmental Compliance Approvals (ECA)

formerly Certificates of ApprovalEnvironmental Compliance Approval (ECA)

• For Waste Disposal Site• For Waste Management Systems• For transfer or processing sites• For recycling facility and/or Household Hazardous Waste

facilities (may be under WDS ECA if on-site)

27. (1) No person shall use, operate, establish, alter, enlarge or extend a waste management system * or a waste disposal site except under and in accordance with an environmental compliance approval.


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Environmental Compliance Approvals (ECA)

Environmental Compliance Approval (ECA)• Air emission (ex. Gas collection/venting)

Section 9 - Approval, plant or production process No person shall, except under and in accordance with an environmental

compliance approval (a) use, operate, construct, alter, extend or replace any plant, structure, equipment, apparatus, mechanism or thing that may discharge or from which may be discharged a contaminant into any part of the natural environment other than water


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Environmental Compliance Approval (ECA)

Everyone is aware of the ECA – but surprising how often no one has read it! Conditions in the ECA are legal requirements.

Generic conditions Daily and interim cover Register on tittle Compaction Reporting (incl. Annual reports) and record keeping Inspections Follow O&D Plan (cover, progression, compaction) Required to submit closure plan


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Approvals

Site Specific Conditions Ground water and surface water monitoring (wording allows

changes to the program with local approval) Installation of leachate collection or gas collection systems Additional reporting requirements (ex. failure of a specific

piece of equipment or part of abatement program) Special cover considerations (sludge, tree cover) Allowance for burning of CLEAN wood Area serviced

Approval conditions are LEGAL requirements. Ensure staff are aware of the condition and a copy of ECA available. If Contract staff used, the responsibility remains with the Owner of the site .


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Approvals must be amended before implementing changes at a

WDS

Some examples of when approval must be amended:

• New cover material• Changing closure plans• Fill Beyond Approved Limit (FBAL)• Increase in size or different footprint• Adding Buffer area to the ECA• Increasing gas capture system• To submit closure plan (2 years before )


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ECAs are documents that are accessible to the public. ECAs for Landfill Sites are posted on the ministry web site www.ene.gov.on.ca)

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Orders

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Orders

EPA - Authorization to issue OrdersUsually issued to ensure a specific issue is complied with example: make a change in operations, apply for an Approval,

conduct a study, submit information or Work Plan May be preventative or compliance driven Often issued if voluntary abatement was not effective

Orders (Provincial Officers or Director’s)• Site and situation specific.• Used to address potential concerns or a violation with time requirement

enforced.


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Regulation 347 General Waste Management

. Defines waste . Categorizes waste . . Provides direction for handling, transporting and disposal . Includes generic operational requirements


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Regulation 419 Local Air Quality

Defines what information is needed for application for air approval Standards for Contaminants


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Regulation 347 - General Waste Management

• Solid non-hazardous* – to municipal WDS

• Liquid Industrial – onsite treatment, to sewers, to disposal sites, to recycling sites

• Hazardous Waste (scheduled chemicals, ignitable, corrosive, reactive, pathological, PCB waste, schedule 4 Leachate Toxic Waste*) - to specialized receivers

• Other – Asbestos Waste – to municipal landfills

*Toxicity Characteristic Leaching Procedure – used for contaminated soils etc.

Ministry of the Environment - for discussion purposes only

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Regulation 347 – some waste may be exempted from Part V


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Regulation 347 – When is waste exempted from Part V?

The regulation lists what wastes can be exempted – and under what circumstance. For example: agricultural waste; inert fill; recovered wire/metal (but no combustion allowed); clean wood intended for mulch; e-waste with conditions; asphalt; compost (where it meets ECA or Regulation criteria).

Municipalities may generate some waste (or become aware of waste handling by private sector) that might be exempt form Part V of the EPA. Inert material, asphalt, and asphalt shingles are examples of “construction type wastes” that might be exempt and can be diverted from landfill.

“recyclable” waste is also addressed through this exemption section: municipal waste, consisting solely of waste from a single category of waste set out in Schedule 1, 2 or 3 of Ontario Regulation etc……

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Asbestos Waste

o Asbestos is “domestic waste”

o Section 17 “Management of Asbestos Waste”. No person shall manage asbestos waste except in accordance with the following (see section 17 for full responsibilities) :>>>• Pre notification• contained• covered immediately• PPE and material to address spill• Precautions to ensure not airborne

o Different requirements for “residential Small quantity and

bulk shipments”


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Regulation 347 Standards for Waste Disposal Sites (1990) in the Reg.Regulation 347 contains a section that provides minimum standards and

operational requirements.

Many WDSs that were started before 1990 had similar conditions in the Approval (although very old Approvals had minimal conditions)

Standards for Waste Disposal Sites – section 1111. The following are prescribed as standards for the location, maintenance

and operation of a landfilling site:• Access roads and on-site roads• Access limited to when attendant is on duty • Drainage passing over or through the site shall not adversely affect

adjoining property. Drainage that may cause pollution shall not, without adequate treatment,

be discharged into watercourses.


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Standards for Waste Disposal Sites (Section 11)

continued• Waste above or isolated from the maximum water table so impairment of

groundwater in aquifers is prevented• • Waste sufficiently distant from sources of potable water supplies so as to

prevent contamination of the water, unless adequate provision is made for the collection and treatment of leachate.

• Where there is a possibility of water pollution resulting from the operation of a landfilling site, samples shall be taken …

• located a reasonable distance from any cemetery Adequate and proper equipment shall be provided for the compaction … and covering of the cells with cover material

• .• All waste disposal operations adequately and continually supervised..

Ministry of the Environment – for discussion only

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Standards for Waste Disposal Sites (Section 11) continued • Procedures shall be established for the control of rodents or other

animals and insects at the site

• the waste disposal area shall be enclosed to prevent entry by unauthorized persons and access to the property shall be by roadway closed by a gate capable of being locked.

• A green belt or neutral zone around the site and site shall be adequately screened from public view.

• Whenever any part of a fill area has reached its limit of fill, a final cover of cover material … and inspected at regular intervals over two years …

• Scavenging shall not be permitted.


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Burning Is it allowed? (ECA)

Must be clean wood (separate) proper location

For discussion purposes ONLY31

Other EPA Regulations (101, 102, & 103)


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Regulation 101RECYCLING AND COMPOSTING OF MUNICIPAL WASTE

PART I : GENERAL

PART II: SYSTEMS REQUIRED IN MUNICIPALITIES Blue Box Waste Management SystemsLeaf and Yard Waste SystemsExemptions

PART III: MUNICIPAL WASTE RECYCLING DEPOTS

PART IV: MUNICIPAL WASTE RECYCLING SITES

PART V: LEAF AND YARD WASTE COMPOSTING SITES

Regulation 102 WASTE AUDITS AND WASTE REDUCTION WORK PLANS(including for construction and demolition projects)

Regulation 103 INDUSTRIAL, COMMERCIAL AND INSTITUTIONAL SOURCE SEPARATION PROGRAMS

Day to Day Operations


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Operational and Design Plan

• where is waste to be deposited and transition/progression to new cells

• ensuring adequate cover material available and applied• conducting inspections to ensure no drainage or concerns with

surface water interference, odour and litter • For sites with leachate collection or gas collection then inspection

and maintenance • Collect required samples• Proper Supervision

• Supervise waste brought in• amount of cover used• interim cells use

• Plan ahead (prepare cells, roads…) & road preparation for all season use

• Is burning allowed – arrange for it

• Ministry of the Environment – for discussion

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Inspections

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Follow (and/or change) the Operations Plan: • progression of cells

• Practical aspect of how to mark use area, elevation limits and foot print limits. How do you direct contractors and public to use areas

• Supervise waste brought in• amount of cover used• interim cells use• Plan ahead (prepare cells, roads…)• Road preparation for all season use• Is burning allowed – arrange for it


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Staff must be informed and trained and roles must be defined• Courses are avaialable; review at staff meetings; highlight legal

responsibilities around waste acceptance, asbestos etc.; mentoring and knowledge transfer etc

• Outline the role of staff involved in WDS operations

• Where contract staff are used, ensure the contract outlines expectations

• Document and record as per the ECA – but also for what is needed for Owners assessment of the site


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At Closure

ECA amended for closure Plan• Inspections• Monitoring• Capping and vegetation

Use after 25 years• Regulation 153 – will apply for change in land use. • Must meet standards or• Risk Assessment shows no issues

Speak to the local MOE staff to discuss particulars


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Resources

Local District Office Environmental Officer The EO for your area should be your first point of contact

for questions and discussions. Cornwall Area Office: 613-933-7402 Spill Action Center: 1-800-268-6060

Ministry public web site (www.ene.gov.on.ca)

E-laws Consultants

http://www.ene.gov.on.ca/

moe waste presentation for sdg summit oct 2013

Business

discussion purposes

environment protection

environment unofficial

subject waste approval

general waste management

waste management systems

environment confidential

environmental officers