Waterkeeper submits second comment regarding Cherry Beach waste disposal site

EXECUTIVE SUMMARY

Waterfront Toronto has proposed the construction and operation of a waste management facility on the shore of Lake Ontario in Toronto’s port lands. The primary purpose of the proposed waste site will be to stockpile soils of varying levels of contamination that have been removed from other areas of the waterfront as part of the revitalization process.

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SUMMARY AND RECOMMENDATIONS

Lake Ontario Waterkeeper recommendations can be summarized as follows:

1. Waterfront Toronto must provide rationale for the selection of contaminants included in the application.

2. If approved, the site should only be licenced for a limited period of time to allow the Ministry to reevaluate the project based on actual data.

3. The dispersion model must be recalculated using the source closest to the property boundary and at ground level.

4. The ESDM must be corrected to reflect that the closest sensitive receptor is the bicycle path 300 metres from the facility.

5. Waterfront Toronto must publish the peak concentrations for the anticipated contaminants.

6. Waterfront Toronto must be required to implement a proper sampling procedure.

7. Waterfront Toronto must develop and implement a “Best Management Plan” for fugitive emissions.

8. Maximum emissions levels of volatile materials must be used in emissions modelling.

9. Waterfront Toronto must explain how it will ensure that no hazardous waste will be accepted at the site.

10. The public should be given the opportunity to comment on the complete application once the Ministry receives the missing information from the proponent.

11. The Ministry should consider all applications associated with this site in conjunction with one another in order to properly assess the site specific and cumulative impacts.

12. The project of this magnitude and duration requires careful review and consideration. The Ministry and/or Waterfront Toronto should consider postponing/ withdrawing this application and resubmitting an application for a pilot project with a shorter duration.

13. Any approvals should include a condition that limits the amount of waste, the quality of the waste, and the duration of the waste site approval pending implementation of a pilot project and final approvals for a treatment facility.

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