government of nunavut department of environment environmental protection division intervention to...
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![Page 1: Government of Nunavut Department of Environment Environmental Protection Division Intervention to the Nunavut Water Board City of Iqaluit Water License](https://reader035.vdocuments.us/reader035/viewer/2022062517/56649e7a5503460f94b7b27c/html5/thumbnails/1.jpg)
Government of Nunavut
Department of Environment
Environmental Protection Division
Intervention to the Nunavut Water Board
City of Iqaluit Water License Renewal Application
March 2006
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Legislative Authority
• DOE derives its regulatory authority from the Environmental Protection Act (EPA).
• EPA Prohibits the discharge of a contaminant into the environment.
• Does not apply if the discharge is authorized by Federal or Territorial Legislation.
• EPA, its regulations and guidelines are the standard against which development projects are gauged in determining if they should proceed.
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Opening Comments
• DOE avoided providing prescriptive, detailed recommendations for Terms and Conditions.
• Most DOE comments and suggestions are intended for the City of Iqaluit’s consideration and to assist them with coming into compliance with EPA.
• Comments intended to be included in the TAC are specifically noted as such.
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Topics of Discussion
• Water Source & Treatment
• Waste Disposal – Solid Waste
• Lower Base Contamination
• Spill/Emergency Response
• Abandonment and Restoration
• Waste Disposal – Sewage
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Water Source and Treatment
• DOE accepts the City’s plan as presented.
• Only real concern is the proximity of the new plateau sub-division to the City’s potable water source.
• This is a health issue, therefore outside of DOE’s regulatory jurisdiction.
• It is assumed that Health officials have examined this.
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Waste Disposal – Solid Waste
• DOE will comment on the following aspects:
I. Hazardous waste management.II. Runoff/Leachate Monitoring.III. Expansion of current site.IV. Long-term solid waste. management plan.V. Lower Base ContaminationVI. Abandonment and RestorationVII. Spill/Emergency Response Plans
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Hazardous Waste Management
• City has made many improvements to their domestic hazardous waste management plan as compared with 10 years ago.
• City appears to be exercising more control over what enters the landfill*.
• City will be required to register with DOE as a HW storage facility if they intend to store HW for > 180 days.
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Runoff/Leachate Control
• Leachate may contain substances which can have a detrimental effect on the sewage lagoon.
• Leachate from the landfill must be collected, contained and treated in an appropriate manner.
• A leachate and runoff management plan should be submitted to the NWB for review and approval.
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Expansion of Existing West 40 Site
• Current site is approaching capacity.
• City proposes to expand to a pre-prepared site adjacent to the current site.
• Proposed site is underlain by a military dump.
• Limited characterization of this site (“Site 3”) was undertaken in 1995.
• Land ownership undetermined.
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Expansion of Existing West 40 Site
• City would like to use 1995 study results as their baseline.
• 1995 study did not include all possible parameters of concern.
• City should, for their own protection, attempt to characterize this site in greater detail.
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Expansion of Existing West 40 Site
• The terms and conditions of the Water License should include a requirement for leachate and runoff control and treatment for the proposed expanded West 40 landfill.
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Long-Term Solid Waste Management Plan
• DOE recommends that the City of Iqaluit be required to provide a long-term, detailed solid waste management plan for review and approval within four years of the issuance/renewal of their Water Licence.
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Lower Base Contamination
• Anecdotal and physical evidence suggest that Lower Base is underlain by hydrocarbon-contaminated soil, the full extent of which is unknown.
• First documented in 1990.
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Lower Base Contamination
• Contamination of Lower Base became a public issue in July 2005 with the excavation of trenches for water/sewer lines.
• DOE believes that this issue is relevant to the Water License.
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Lower Base Contamination
Environmental Engineering tenet: If you are digging a trench and you find evidence of contamination, the first thing to do is stop digging.
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Lower Base Contamination• City can not and should not be held
responsible for historic contamination, nevertheless:
• The City of Iqaluit should develop and implement a management plan for contaminated soil and water if they intend to excavate in areas that are suspected to be, or confirmed, contaminated.
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Abandonment and Restoration Plans
• Under “A&R” Plans, City of Iqaluit submitted a 1995 report: Environmental Study of a Military Installation and Six Waste Disposal Sites at Iqaluit, NWT.
• DOE suggests the City put more effort into developing A&R Plans.
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Abandonment and Restoration Plans
• The City should be required to submit up to date Abandonment and Restoration Plans for those facilities over which they have control; which were, or are, part of their day to day operations; and which have already or are intended to be decommissioned.
• A&R plans for these facilities should be submitted within four years of the issuance/renewal of the Water Licence or within a time frame acceptable to the NWB.
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Spill/Emergency Response
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Spill/Emergency Response
• DOE finds the spill contingency plans to be, for the most part, complete and acceptable.
• Minor suggestions have been made for improvements.
• The City of Iqaluit should be fully prepared to manage the hazardous materials under their control; including during emergency situations.
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Waste Disposal - Sewage
• DOE has posed a number of questions and offered comments pertaining to the new Waste Water Treatment Plant.
• The City is advised to address these questions and to take the comments into consideration.
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Waste Disposal – Sludge Management
• City should re-review estimated quantities of bio-solids production using conservative figures for sludge management plan.
• Evaluation ratings for screened technologies appears to be skewed in favour of air drying. City should explain how they arrived at their ratings.
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Waste Disposal – Sludge Management
• City is advised to review other options such as “trench composting” in an enclosed building.
• DOE strongly recommends that the City determine with reasonable exactitude, how much land they will require for drying beds, vs. how much land is available.
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Waste Disposal – Sludge Management
• Appendix A of the Sludge Disposal Plan references a similar installation in Sweden.
• Temperature graph for Swedish city = 7 months above freezing.
• Iqaluit experiences 4 months of above-freezing temperatures.
• Has the City determined how Iqaluit conditions will impact this technology?
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Waste Disposal – Sewage Lagoon
• The City of Iqaluit should be required to draft a plan, for review and approval, to manage the existing lagoon, including, but not restricted to:– Measures to be taken in the event of an
accidental release (Contingency measures).– Plan for repairs/upgrades to the lagoon (as
identified in the various lagoon reports).– Abandonment and decommissioning plan,
including provisions on how to manage lagoon sludge.
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Summary
• DOE does not have any “show stopper” concerns with this application.
• Major concern relates to the paucity of information pertaining to the short and long term management of the current sewage lagoon.
• City’s proposed sewage treatment system appears to be sound, proven technology.
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Summary
• City should develop A&R plans for those facilities which are under their control/management and which are intended to be closed in the near future.
• Long-term solid waste management plan.
• Lower Base Soil & Water Management Plan.
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Summary• City of Iqaluit is facing problems unlike
those faced by any other City in Canada:
– historic contaminated sites– aging infrastructure– population boom (2 x since 1991)*– High turnover of engineering staff
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Summary
• Despite these hurdles, the City has progressed in many areas.
• Room for improvement, however City is to be commended for their continuing efforts.
• DOE is willing to provide assistance when and where possible.
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DOE Priorities
• Leachate and Runoff Monitoring Plan – June 2006• Leachate and Runoff Control Implementation – Upon
commissioning of the new (old) site.• Management Plan for Contaminated Soils – June 2006• Lagoon Plan – Within 1 year of issuance of licence• Long-Term SWM plan – within 4 years after the issuance
of the licence.• Abandonment and Restoration Plans – within 4 years of
the issuance of the licence or at a time mutually agreed upon by the NWB, the City and other interested parties.