Brooks Road Landfill 2011 Annual compliance report

Brooks Road Landfill
2011 Compliance Report
April 2012
Prepared for:
Brooks Road Environmental Limited
c/o Romspen Investment Corporation
162 Cumberland Street, Suite 300
Toronto, Ontario M5R 3N5
Prepared by:
GENIVAR Inc.
1425 Cormorant Road, Suite 300
Ancaster, Ontario L9G 4V5
Project No. 111-53338-00
Distribution:
2 c Client
1 c Ministry of the Environment
1 c Public Liaison Committee
1 c Haldimand County
1 c File

A:Projects2011111-53338-00 - Brooks Road Landfill100 2011 Compliance MonitoringWP2011 Annual Compliance Report-F.docx
1425 Cormorant Road, Suite 300, Ancaster, Hamilton, Ontario, CANADA L9G 4V5
Telephone: 289.239.0100  Fax: 289.239.0109  www.genivar.com
Project No.111-53338-00
April 30, 2012
Richard Weldon
2270386 Ontario Limited, T/A
Brooks Road Environmental Limited
c/o Romspen Investment Corporation
Re: Brooks Road Landfill
Dear Mr. Weldon:
GENIVAR Inc. (GENIVAR) is pleased to provide this 2011 Annual Compliance Report for the
Brooks Road Landfill.
This 2011 Annual Compliance Report is prepared in consideration of Condition 94 of Provisional
Certificate of Approval for a Waste Disposal Site No. A110302, dated May 5, 2004, plus
amendments to July 30, 2007, and Condition 7 of Amended Certificate of Approval for Industrial
Sewage Works No. 8371-6X9L6B dated February 20, 2007. This report provides an interpretive
analysis of the 2011 findings for the compliance monitoring undertaken at the landfill site as well
as a summary of the 2011 operations.
The operation of the site has been transferred to the new operators, Brooks Road Environmental
Limited, at the end of April 2012.
Groundwater and surface water monitoring were completed in accordance with the Certificates of
Approval.
In addition, amendments to Conditions of the Certificate of Approval for Waste Disposal Site are
proposed to facilitate achievement of site development objectives.
We trust that this report satisfies your requirements. Please contact us if you have any questions.
Yours truly,
GENIVAR Inc.
Bailey Walters, M.Sc., P.Geo.
Project Geoscientist, Environment

GENIVAR A:Projects2011111-53338-00 - Brooks Road Landfill100 2011 Compliance MonitoringWP2011 Annual Compliance Report-F.docx i
Table of Contents
Transmittal Letter
1 INTRODUCTION ......................................................................................................................... 1
1.1 Location ...................................................................................................................................... 1
1.2 Ownership and Key Personnel ................................................................................................... 1
1.3 Description and Development of the Waste Disposal Site ......................................................... 2
1.4 Monitoring and Reporting Program Objectives and Requirements of Certificate of
Approval for Waste Disposal Site ............................................................................................... 4
1.5 Assumptions and Limitations ...................................................................................................... 4
2 PHYSICAL SETTING................................................................................................................... 4
2.1 Geology and Hydrogeology ........................................................................................................ 5
2.2 Surface Water Features.............................................................................................................. 6
3 DESCRIPTION OF MONITORING PROGRAM........................................................................... 7
3.1 Groundwater Monitors ................................................................................................................ 7
3.1.1 Groundwater Level Monitoring.................................................................................... 7
3.1.2 Groundwater Sampling ............................................................................................... 8
3.2 Leachate ..................................................................................................................................... 8
3.3 Surface Water............................................................................................................................. 9
3.3.1 Waste Certificate of Approval...................................................................................... 9
3.3.2 Sewage Certificate of Approval................................................................................. 10
3.4 Landfill Gas............................................................................................................................... 10
3.5 Field Sampling and Record Keeping ........................................................................................ 11
3.6 Quality Assurance for Sampling and Analysis.......................................................................... 11
3.6.1 Groundwater.............................................................................................................. 11
3.6.2 Leachate.................................................................................................................... 12
3.6.3 Surface Water ........................................................................................................... 12
3.7 Supplemental Monitoring .......................................................................................................... 13
3.8 Operational Monitoring.............................................................................................................. 13
3.8.1 Daily Operations........................................................................................................ 13
3.8.2 Public Complaints...................................................................................................... 14
3.8.3 Public Liaison Committee.......................................................................................... 15
4 OVERVIEW – MONITORING RESULTS................................................................................... 15
4.1 Historical Data........................................................................................................................... 15
4.2 Data Quality Evaluation ............................................................................................................ 15
4.3 Groundwater Flow Monitoring................................................................................................... 15
4.4 Groundwater Quality Monitoring............................................................................................... 16
4.4.1 Shallow Overburden Unit .......................................................................................... 16
4.4.2 Basal Overburden/Shallow Bedrock Unit.................................................................. 17
4.4.3 Bedrock Unit.............................................................................................................. 17
4.5 Leachate Characterisation........................................................................................................ 18
4.6 Surface Water Quantity Monitoring........................................................................................... 19

2011 Compliance Report Table of Contents
GENIVAR A:Projects2011111-53338-00 - Brooks Road Landfill100 2011 Compliance MonitoringWP2011 Annual Compliance Report-F.docx ii
4.7 Surface Water Quality Monitoring............................................................................................. 19
4.7.1 Background Stations ................................................................................................. 20
4.7.2 On-site Station........................................................................................................... 20
4.7.3 Downstream .............................................................................................................. 20
4.8 Gas Pressures and Composition.............................................................................................. 21
4.9 Control Systems Monitoring...................................................................................................... 21
5 ASSESSMENT, INTERPRETATION, AND DISCUSSION ........................................................ 22
5.1 Groundwater Flow Interpretation .............................................................................................. 22
5.1.1 Shallow Overburden Unit .......................................................................................... 22
5.1.2 Basal overburden/shallow Bedrock Unit ................................................................... 23
5.1.3 Bedrock Unit.............................................................................................................. 23
5.2 Groundwater and Surface Water Quality.................................................................................. 23
5.2.1 Groundwater.............................................................................................................. 23
5.2.2 Surface Water ........................................................................................................... 26
5.2.3 Leachate Generation................................................................................................. 28
5.3 Waste Disposal Site Gas Impacts ............................................................................................ 28
5.4 Effectiveness of Engineered Controls....................................................................................... 28
5.5 Adequacy of the Monitoring Program ....................................................................................... 29
5.6 Amendments to the Certificate of Approval for Waste Disposal Site ....................................... 29
5.7 Assessment of the Need for Implementation of Contingency Measures.................................. 30
5.8 HALT Review............................................................................................................................ 30
6 SITE OPERATIONS AND DEVELOPMENT.............................................................................. 32
6.1 Site Development - Work Completed in 2011 .......................................................................... 32
6.2 Waste Volumes and Site Life.................................................................................................... 33
6.3 Work Scheduled for 2012 ......................................................................................................... 33
7 FINANCIAL ASSURANCE......................................................................................................... 34
8 CONCLUSIONS ........................................................................................................................ 34
9 RECOMMENDATIONS.............................................................................................................. 35
10 CLOSURE ................................................................................................................................. 36
11 REFERENCES .......................................................................................................................... 37

GENIVAR A:Projects2011111-53338-00 - Brooks Road Landfill100 2011 Compliance MonitoringWP2011 Annual Compliance Report-F.docx iii
List of Tables
Table 1-1 Key Personnel Contact Details ........................................................................................... 2
Table 3-1 Groundwater Monitoring Wells............................................................................................ 7
Table 3-2 Surface Water Monitoring Stations ..................................................................................... 9
Table 3-3 Summary of Field Sampling Parameters .......................................................................... 11
Table 3-4 QA/QC Exceptions in Groundwater Samples................................................................... 12
Table 3-5 QA/QC Exceptions in Surface Water Samples................................................................. 13
Table 3-6 Summary of Public Complaints......................................................................................... 14
Table 4-1 Shallow Overburden Unit ODWQS Exceedances ............................................................ 16
Table 4-2 Basal Overburden/Shallow Bedrock Unit ODWQS Exceedances.................................... 17
Table 4-3 Bedrock Unit ODWQS Exceedances................................................................................ 18
Table 4-4 Certificate of Approval ODWQS Leachate Exceedances................................................. 18
Table 4-5 Section 53 Certificate of Approval Leachate Exceedances.............................................. 19
Table 4-6 PWQO Exceedances in Surface Water Samples............................................................. 20
Table 4-7 TDS Pond PWQO Exceedances ...................................................................................... 21
Table 5-1 Parameter Trends in the Shallow Overburden Unit.......................................................... 24
Table 5-2 Parameter Trends for Basal Overburden/Shallow Bedrock Unit ...................................... 25
Table 5-3 Parameter Trends in the Bedrock Aquifer ........................................................................ 26
Table 5-4 Parameter Trends in Surface Water ................................................................................. 26
Table 5-5 Surface Water PWQO Exceedances within the Ditch Network ........................................ 27
Table 5-6 Surface Water PWQO Exceedances in Ponded Areas .................................................... 27
Table 5-7 Monthly Leachate Volumes (m3
)....................................................................................... 28
Table 5-8 Responses to HALT Review Comments of 2006 Compliance Report ............................. 30
Table 6-1 Breakdown of Monthly Waste Acceptance (tonnes)......................................................... 33
List of Figures
Figure 1 Site Location Map
Figure 2 Site Plan
Figure 3 Inferred Groundwater Elevation Contours Shallow Overburden Aquifer-May 2011
Figure 4 Inferred Groundwater Elevation Contours Shallow Overburden Aquifer-November 2011
Figure 5 Groundwater Elevations Basal Overburden/Shallow Bedrock Aquifer-May 2011
Figure 6 Groundwater Elevations Basal Overburden/Shallow Bedrock Aquifer-November 2011
Figure 7 Groundwater Elevations Bedrock Aquifer-May 2011
Figure 8 Groundwater Elevations Bedrock Aquifer-November 2011
Figure 9 Shallow Overburden Groundwater ODWQS Exceedances
Figure 10 Basal Overburden/Shallow Bedrock Groundwater ODWQS Exceedances
Figure 11 Deep Bedrock Groundwater ODWQS Exceedances
Figure 12 Surface Water PWQO/Trigger Exceedances

GENIVAR A:Projects2011111-53338-00 - Brooks Road Landfill100 2011 Compliance MonitoringWP2011 Annual Compliance Report-F.docx iv
Appendices
Appendix A Certificates of Approval
Appendix B Monitoring Program
Appendix C GENIVAR Field Protocols
Appendix D Borehole/Test Pit Logs
Appendix E Groundwater Elevations and Analytical Results
Appendix F Leachate Analytical Results
Appendix G Surface Water Flow and Analytical Results
Appendix H TDS Pond Analytical Results
Appendix I Supplemental Analytical Results
Appendix J Financial Assurance Plan Update
Appendix K Certificate of Approval Compliance
Appendix L HALT Review Comments

GENIVAR A:Projects2011111-53338-00 - Brooks Road Landfill100 2011 Compliance MonitoringWP2011 Annual Compliance Report-F.docx 1
1 Introduction
GENIVAR Inc. has prepared the following 2011 Annual Compliance Report, on behalf of Brooks Road
Environmental Limited, the operator of the Brooks Road Landfill Site (Site), formerly the Edwards Landfill
Site. The Site is an approved waste disposal facility operating under Provisional Certificate of Approval for
a Waste Disposal Site No. A110302 dated May 5, 2004 (plus amendments to July 30, 2007) and
Amended Certificate of Approval for Industrial Sewage Works No. 8371-6X9L6B dated February 20, 2007
(Sewage Certificate of Approval). Copies of the Certificates of Approval are included in Appendix A.
This report is structured according to the new Ministry of the Environment Monitoring and Reporting for
Waste Disposal Sites, Groundwater and Surface Water Technical Guidance Document (November 2010).
1.1 Location
The Site is located at 160 Brooks Road in Cayuga, Ontario, which is approximately one kilometre north of
Kings Highway No. 3 (Talbot Road). The Site is legally described as Part of Lot 24, Concession I-N.T.R.,
of the former North Cayuga Township, former Regional Municipality of Haldimand-Norfolk, and now
Haldimand County.
The total Site area is approximately 12.4 hectares (ha) (30.6 acres) of which 6 ha (15 acres) is currently
approved for landfilling. The regional Site location is provided on Figure 1. The local Site setting is shown
on Figure 2.
The Site is bounded to the north by the former Canada Southern Railway right-of-way. The section of
right-of-way between Brooks Road and east to Windecker Road was acquired by the former owner of the
landfill, Haldimand-Norfolk Sanitary Landfill Inc. (HNSL), in 2006. To the north of the former rail right-of-
way, a privately-owned rural property consisting of undeveloped fields (i.e., long-term inactive agricultural
crop production lands) and forested areas is present.
To the south and east of the Site is a privately owned undeveloped rural property used primarily for
passive livestock pasture purposes and consisting of a combination of old fields and forested areas.
The Site is bounded to the west by Brooks Road. On the west side of Brooks Road is an undeveloped
rural property owned by the Cayuga Uplands Game Farm. This property is privately owned and is
understood to be stocked for bird hunting purposes. The property itself is characterized primarily by
undeveloped fields with occasional bush lots.
1.2 Ownership and Key Personnel
In 2011, Brooks Road Landfill was in receivership, managed by SF Partners Inc. and operated by
2274462 Ontario Limited. Beginning April 30, 2012 Brooks Road Environmental Limited became the
operator of the Brooks Road Landfill Site. GENIVAR Inc. (GENIVAR) was retained by 2274462 Ontario
Limited and, subsequently, by Brooks Road Environmental Limited to manage the compliance monitoring
and reporting for the Site.
The key personnel and their respective contact details are included in Table 1-1, below.

Table 1-1 Key Personnel Contact Details
Contact Contact Details
Primary contact for Brooks Road Environmental Limited Richard Weldon
Phone: +1-416-928-4810 Fax: +1-416-966-1161
E-mail: RichardWeldon@romspen.com
Primary contact for 2274462 Ontario Inc.
(operator until April 20, 2012)
Jeff Usher
265 Dunwoody Drive
Oakville, Ontario L6J 4G7
Phone: +1-416-428-6863
E-mail: jeff@jmuconsultgroup.com
Brooks Road Landfill Site Manager Reid Robertson
160 Brooks Road
Cayuga, Ontario
Phone: +1-905-772-3040 Fax: +1-905-772-3041
Competent Environmental Practitioner Bailey Walters, M.Sc., P.Geo
GENIVAR Inc.
1425 Cormorant Road
Ancaster, Ontario L9G 4V5
Phone: +1-289-239-0100 Fax: +1-289-239-0109
Email: bailey.walters@genivar.com
1.3 Description and Development of the Waste Disposal Site
Historic records indicate that landfilling operations commenced at the Site in 1959. Waste from various
municipalities in the vicinity of the Site continued to be landfilled of at the Site on an on-going basis
between 1959 and 1977. Subsequent to 1977, waste disposal activities were carried out on an
intermittent basis. The waste stream included metal drums containing resins, which have also been
disposed of at the Site. Prior to the 1990s, waste disposed at the Site was placed in unlined trenches
excavated into the native clayey soils within the Site. Subsequent to landfilling within trenches, waste was
placed directly on the ground surface and covered with a layer of native soil.
In 1992 GENIVAR (formerly Henderson Paddon Environmental Inc.) undertook an environmental
investigation at the Site in order to document, amongst other things, past landfill practices. According to
the Hydrogeologic Assessment, historical landfilling operations were predominantly based on the trench
method. The GENIVAR investigation identified two trenches within the central portion of the Site. These
trenches extend to 6.1 and 10.7 m below the ground surface (mBGS). A third waste disposal area is
located to the south of the existing access road, although waste in this location was placed directly on the
ground surface and not in a trench. In addition, GENIVAR estimated that between 50 and 60 exposed
drums were located along the north bank of the larger pond in the southwestern portion of the Site.
In May 2001, a Phase II Environmental Site Investigation (ESI) was conducted at the Site by Conestoga-
Rovers & Associates (CRA). The Phase II ESI activities included the excavation of 16 test pits to
delineate the limits of historically placed refuse. The results of the test pit excavation program indicated a

relatively thin layer of refuse (0.3 to 3.0 m) over an area of approximately 20,000 m2
and the presence of
numerous exposed and buried drums to the north of the larger pond in the southwestern portion of the
Site. The findings of the Phase II ESI were documented in the report entitled "Phase II Environmental Site
Investigation, Edwards Landfill Site, June 2001", prepared for 2001825 Ontario Limited.
In October 2001, Waste Characterization was undertaken at the Site by CRA. The Waste
Characterization activities included excavation of 66 test pits within the existing limit of refuse and
collection of 32 soil and/or refuse samples for chemical analyses. Available test pit logs are included in
Appendix D.
Based on the field and analytical data generated, it was estimated that approximately 50,000 m3
of waste
material (bottles, cans, scrap metal, newsprint, demolition debris, intact and crushed drums, drum
remnants, liquid and solidified resin material, and visually impacted soil) are located within the Original
Landfill Area (OLA). The findings of the Waste Characterization activities were documented in the CRA
report entitled "Waste Characterization Activities, Edwards Landfill Site, Haldimand County, Ontario,
January 2002".
Between May and June 2004, a Natural Heritage Features Assessment was carried out by Natural
Resource Solutions Inc. of Waterloo, Ontario, a terrestrial biology consulting firm. At the same time in
2004 and in April 2005, a comprehensive soil quality screening program was completed outside of the
OLA. In 2004 and 2005, the Site was cleared and grubbed. A chain link fence was installed at the front
entrance in 2005, and in 2007 the fence was expanded to surround the perimeter of the Site.
Between November 2006 and January 2007, railway ballast was recovered from the former Canada-
Southern Railway (Railway) spur directly north of the Site. The Railway, between Brooks Road and
Windecker Road, an approximate distance of 2600 metres, was acquired by the former owner of the Site
(HNSL). The intent was to reuse the material as a drainage medium in the Stage 1 cell construction of the
leachate collection system (LCS). Further studies indicated the ballast material contained too many fine
particles to meet the design specifications of the LCS and difficulties were encountered while attempting
to screen the material. It was indicated through laboratory analysis that the ballast material contains low-
level concentrations of polycyclic aromatic hydrocarbons (PAHs), but complies with the Ontario
Regulation 153/04 soil quality criteria for industrial/commercial uses in a non-potable groundwater setting.
Stage 1 cell construction of the new, engineering landfill commenced in December 2006 and was
completed in October 2007. Following several attempts, the Site began receiving waste in October 2009.
Decommissioning of the Original Landfill Area was initiated in autumn 2011.
In May 2007, Natural Resource Solutions Inc. (NRS) of Waterloo, Ontario provided a monitoring report
summarizing the first round of ecological monitoring at the Site. The monitoring consisted of amphibian
monitoring, inspection of habitats for Blanding's turtles, and compliance monitoring. The compliance
monitoring identified three action items related to the identification and protection of the black gum trees.
These action items were implemented in 2007.
As part of Condition 29 of the Waste Certificate of Approval regarding potential construction influences on
ecosystems, the Ministry of Natural Resources (MNR) was consulted on July 28, 2009. Any comment or
recommendations received from the MNR should be given due consideration. Documentation regarding
the implementation of any MNR recommendations will be reported to the MOE. In accordance with this, a

Wetland Site Inspection in advance of Cell 2 construction was undertaken by the MNR in September
2011. During this inspection MNR staff confirmed the presence of Black gum trees and searched the Site
for the presence of Blanding turtles, snakes, and amphibian species. The results of this inspection were
documented in an MNR inspection letter report, dated November 14, 2011.
1.4 Monitoring and Reporting Program Objectives and Requirements
of Certificate of Approval for Waste Disposal Site
The objectives of the 2011 Operations and Monitoring Program are as follows.
 To report compliance with the terms and conditions of the Provisional Certificate of Approval
for a Waste Disposal Site No. A110302 dated October 7, 1980, plus amendments to July 19,
2007, and Amended Certificate of Approval for Industrial Sewage Works No. 8371-6X9L6B,
dated February 20, 2007, for the reporting period of January 1 to December 31, 2011.
 To assess potential effects of the landfill on groundwater and surface water quality.
 To evaluate the landfill site monitoring program on an annual basis and to recommend
improvements as operations at the site mature.
 To determine the need for the implementation of contingency measures.
This report satisfies the annual reporting requirements of Condition 94 of the Waste Certificate of
Approval for the 2011 compliance monitoring and operations period. Reporting involves a data collection
component and a comprehensive analysis and interpretation component. The 2011 data were collected
by Brooks Road Landfill Site personnel and GENIVAR personnel. The waste disposal information was
prepared with the assistance of Brooks Road Landfill personnel. The data were collated and analyzed by
GENIVAR.
1.5 Assumptions and Limitations
Historic data, prior to December 2010, was collected and collated by Conestoga-Rovers and Associates,
and by the MOE, and is assumed to be accurate, as presented. Data for waste acceptance and leachate
generation in 2011 was obtained from Brooks Road Landfill and the annual totals are assumed accurate.
2 Physical Setting
The Site is located within the Haldimand Clay Plain physiographic region, characterised by fine-textured
glaciolacustrine deposits. Soils of this region have characteristically heavy texture and poor drainage.
The Site is located within the Grand River watershed and the Grand River has cut a deep valley in the
clay and silt below Brantford. Consequently there has been much dissection by tributary drainage. To the
south and west of the site, a scattered group of drumlins is partially buried in moderately dissected clay
beds. (Chapman and Putnam, 1984)

2.1 Geology and Hydrogeology
The overburden geology is relatively uniform beneath the Site. In general the Site is characterized by a
thick (14 to 18 m) deposit of glaciolacustrine stratified clayey silt, clayey till and varied clays, underlain by
a thin (1 to 3 m) discontinuous layer of silty sand till with varying concentrations of gravel and clay
overlying bedrock. The bedrock is encountered at depths varying from 15.2 to 20.2 metres below ground
surface (mBGS). A thin surficial deposit of topsoil is generally observed at the surface of the Site, with the
exception of the southwestern portion, where refuse associated with historical waste disposal activities is
observed.
Based on information obtained from previous investigations, it is estimated that the area containing waste
(drums, refuse/debris, and impacted soils) is approximately two hectares in size, as shown on Figure 2. It
is estimated that approximately 50,000 m3
of waste material is currently located within the clayey silt
deposits in the southwestern portion of the Site. The observed thickness of waste generally varies from
0.3 to 3 m, with deeper deposits reported in Trench 1 (10.7 m) and Trench 2 (6.1 m).
The clayey silt deposits are described as being locally fractured (weathered) from the surface down to
depths varying from 3 to 5 mBGS, and are characterized as a very stiff to hard unit with low plasticity. At
depths in excess of 5 m, the clayey silt deposits have little to no fracturing and the consistency of the soils
decrease to stiff to very stiff. Underlying the clayey silt deposits, a thin, discontinuous deposit of silty sand
till with varying concentration of clay and gravel is encountered across the Site. The silty sand till ranges
in thickness from 1 to 3 m and often contains cobbles and/or broken angular bedrock fragments. This
deposit is usually well-graded, with fine- to medium-grained sand, minor silt and trace clay, and is
described as dense to compact, grey and saturated. The silty sand till rests directly on the bedrock.
Bedrock underlying the Site is a fractured shale, dolostone, and gypsum of the Salina Formation. The top
of bedrock elevation ranges from 180.8 to 185.7 m above sea level (mASL) and forms a small buried
bedrock valley feature from northwest to southeast beneath the Site. The small depression is
characterized by the thicker silty sand till deposit. Regionally the bedrock topography dips to the south.
In general, the geologic units identified at the Site may be grouped into four main hydrostratigraphic units,
as follows:
 Shallow, unconfined water table (shallow overburden) unit within the permeable refuse and
the shallow, fractured clayey silt (weathered) unit
 Intermediate, thick (between 9 and 12 m) layer of stratified clayey silt, clayey silt till, and
varved clays, which form an aquitard of low hydraulic conductivity
 Basal overburden (till)/shallow bedrock confined aquifer
 Bedrock confined aquifer
Groundwater level data historically gathered from the shallow overburden unit and basal overburden/
shallow bedrock aquifer indicate that the presence of the clay aquitard results in hydraulic separation of
the two units.

Based on groundwater data historically obtained, the shallow overburden unit is generally encountered at
depths varying from 0.5 mBGS down to 4 mBGS across the Site. The groundwater flow within the shallow
overburden unit has generally been documented as radiating outwards from the existing refuse area,
which forms a groundwater mound. The shallow overburden unit is essentially a shallow water table
resting on the low permeability un-weathered clay units. The large variation in hydraulic conductivity
between the refuse material and the surrounding clayey silt results in the groundwater mounding effect
historically observed in the existing refuse area. The shallow monitoring wells historically located within
the OLA (OW4B-91 and OW6B-92) were abandoned in 2007 in preparation of the OLA decommissioning
activities scheduled for 2011. As such, no OLA monitoring well existed after this date.
Underlying the clayey silt aquitard, a confined basal overburden/shallow bedrock aquifer was observed
within the lower portion of the silty sand till unit and the shallow fractured bedrock. Groundwater quality
and water level data historically gathered from monitoring wells screened within the lower silty sand till
unit exhibited hydrostatic levels and hydrochemical characteristics which are not substantially different
from samples obtained from well nests screened solely within the shallow bedrock. Therefore, these two
geological units have been generally considered to form one aquifer.
Based on the groundwater data obtained to date, the basal overburden/shallow bedrock aquifer is
generally encountered at depths varying from 14 to 17 mBGS. The groundwater flow pattern within this
aquifer is generally characterized by a weak horizontal hydraulic gradient and a south-easterly flow
direction. Based on water levels within the on-Site nested groundwater monitors, vertical hydraulic
gradients are generally downward.
The bedrock consists of inter-bedded dolostones and shales of the Salina Formation. Groundwater found
within the Salina Formation is of naturally poor quality.
2.2 Surface Water Features
The Site is located within the Haldimand Clay Plain which is characterized by level topography and
relatively poor drainage. A Temporary Dewatering Sedimentation (TDS) pond was constructed in 2007
north of the OLA, to manage surface water runoff during stage I Cell construction. The TDS Pond
continued to be in use throughout 2011 to manage the retention of surface water runoff prior to
discharging to the off-Site roadside ditch on the east side of Brooks Road. The TDS pond is illustrated on
Figure 2.
Drainage from the OLA has been contained within the OLA by the clay containment berm that was
constructed around the existing waste limits. The roadside ditch along the east side of Brooks Road,
adjacent to the Site, drains south through a culvert under the CNR rail bed and empties into a small,
apparently natural, stream channel, which is the head waters of Norton Creek. Other drainage from
adjacent lands to the west of Brooks Road also flows in culverts under Brooks Road to provide surface
runoff to Norton Creek. Other surface runoff contributions include ephemeral streams on lands south of
the Site that enter Norton Creek via culverts under the CNR rail bed.

3 Description of Monitoring Program
The Monitoring Program for the Brooks Road Landfill is summarized in Table B-1 of Appendix B, with the
analytical parameters for each sampling component summarized in Table B-2 of Appendix B. Copies of
the Chain of Custody forms for samples submitted to the laboratory for 2011 are available on file if
required. The environmental monitoring program was carried out by GENIVAR staff. A quality assurance
and quality control (QA/QC) program was followed for each of the routine monitoring tasks completed.
This program consists of procedures for the sampling of monitoring wells, the collection of samples, and
ancillary tasks. A copy of the field sampling protocols is provided in Appendix C.
3.1 Groundwater Monitors
As detailed in the 2007-2009 Operations and Monitoring Report by CRA, of the groundwater monitoring
wells listed in Condition 52 of the Waste Certificate of Approval, for various reasons, a total of eighteen
wells can no longer be monitored; while three off-Site residential wells were added to the monitoring
program in 2005 before being removed in 2007 and replaced by exclusive off-Site downgradient
monitoring wells in 2007 and 2009. Monitoring well stratigraphic, instrumentation logs, and abandonment
logs along with test pit logs are provided in Appendix D.
The groundwater monitoring wells at the Site are screened within three different hydrogeological units:
shallow overburden, basal overburden/shallow bedrock, and bedrock. The following table provides a list
of the existing monitoring wells at the Site, with locations shown in Figure 2.
Table 3-1 Groundwater Monitoring Wells
Hydrogeologic Unit Groundwater Monitoring Wells
Shallow Overburden MW1B-07, MW2B-07, MW2C-01, OW1B-06, OW3B-07, OW5B-06, OW8B-06, OW9B-06,
MW1-03, MW2-03, MW3-03, MW5B-09, MW6B-07
Basal Overburden/ Shallow
Bedrock
MW1A-07, MW2A-01, OW1A-06, OW3A-07, OW5A-06, OW8A-06, OW9A-06, MW5A-09,
MW6A-07, MW4A-09
Bedrock MW1S-07, MW1D-07, MW2S-07, MW2D-07, OW8D-07, OW8S-07
Groundwater monitoring wells are required to be sampled in May, July, and November and the
groundwater levels are to be assessed semi-annually.
3.1.1 Groundwater Level Monitoring
Groundwater levels were manually measured at the existing monitoring wells in May (30-31), July (5-7),
and November (14-16) 2011. Manually-collected liquid levels were measured using an electric contact
meter with an accuracy of 1 mm. The meter was decontaminated between monitoring locations in
accordance with established GENIVAR field protocols.

3.1.2 Groundwater Sampling
Groundwater samples were collected from the existing monitoring wells in May (30-31), July (5-7), and
November (14-16), 2011, with the exception of:
 MW5B-09, which was not sampled in July and November because of insufficient water,
 MW2B-07, which was sampled only for VOCs and PAHs in July and November due to
insufficient water for general chemistry sampling, and
 MW2C-01, which was sampled only for PAHs and VOCs in July due to insufficient water for
general chemistry sampling.
Groundwater samples were collected using dedicated inertial lift pumps. The wells were purged of three
standing volumes, or to dryness, prior to sample collection. Samples for soluble metals and dissolved
organic carbon (DOC) were filtered in the field prior to preservation.
The groundwater samples were analyzed for the Groundwater Indicator parameters as listed in
Schedule C (Note 7), of the Waste Certificate of Approval. The results of analysis are compared to the
MOE Ontario Drinking Water Quality Standards, Objectives, and Guidelines (June 2006).
3.2 Leachate
Leachate that is generated within the waste cell collects within the Leachate Collection System and flows
under the influence of gravity to a sump. It is pumped from the sump to tanker truck(s) for off-Site
disposal.
3.2.1 Waste Certificate of Approval
Schedule C of the Waste Certificate of Approval indicates that leachate quality is to be assessed annually
in July, and leachate mounding is to be assessed quarterly. In accordance with the Certificate of
Approval, a leachate sample was obtained on July 4, 2011 and analysed for the Leachate
Comprehensive suite of parameters. Additionally, leachate samples were obtained in May and November
2011 and analyzed for Leachate Indicator parameters.
The leachate samples were analyzed for the parameters outlined in Schedule C of the Certificate of
Approval and compared to the MOE Ontario Drinking Water Quality Standards, Objectives and
Guidelines (ODWQS; June 2003 and updates). The results are summarized in Table F-1 and copies of
the laboratory Certificates of Approval are included within the Appendix.
3.2.2 Sewage Certificate of Approval
In accordance with the Ontario Water Resources Act s53 Certificate of Approval for Industrial Sewage
Works, leachate grab samples are required to be collected from the Leachate Storage Tank on a
quarterly basis upon commencement of operation.

The Leachate Storage Tank was not constructed in 2011; however, leachate samples were collected from
the leachate collection system on March 31, June 10, September 26, and December 12, 2011. The
leachate samples were analyzed for the parameters outlined in Table 2 of the Sewage Certificate of
Approval, and compared to the ODWQS and Leachate Quality Characteristics (after Rowe, 1995). The
results are summarized in Table F-2 and copies of the laboratory Certificates of Analysis are included
within the Appendix.
3.3 Surface Water
The surface water monitoring program is conducted to satisfy the requirements of the Site’s Certificate of
Approval for Waste Disposal Site and the Certificate of Approval for Industrial Sewage Works (related to
off-Site surface water discharge from the TDS/SWM Ponds.
3.3.1 Waste Certificate of Approval
The locations of surface water monitoring stations that were part of the 2011 compliance monitoring
program, in conformance with the amended Waste Certificate of Approval, are described in Table 3-2
below and shown in Figure 2.
Table 3-2 Surface Water Monitoring Stations
Station Name Location Description
SW1
SW1 is located in the drainage ditch on the west side of Brooks Road and represents upstream background
surface water within the ditches in vicinity of the Site.
SW2
SW2 has not been established to date, as the storm water management (SWM) pond has not been constructed;
once the SWM pond has been constructed, SW2 will be established at its outlet.
SW3
SW3 is located in the drainage ditch on the east side of Brooks Road downstream of the southwest corner of the
Site.
SW4
SW4 is located approximately 380 m southeast and downstream of the Site on the north side of a double culvert
located on Highway 3.
SW5 SW5 is located in a pond in the southeast portion of the Site.
SW6 SW6 is located in an off-site pond, approximately 30 m south of the Site adjacent to Station SW5.
SW7
SW7 is located in an off-site pond, approximately 24 m south of the Site and 100 m east of Brooks Road. As
noted in the 2007-2009 Operations and Monitoring report, this pond does not appear to receive surface run off
from the Site.
SW8
SW8 is located in an off-site pond, approximately 230 m south of the Site and approximately 310 m east of Brooks
Road. Previous reports indicate that this pond is not hydraulically connected to the Site and may be considered as
a background location for assessing surface water quality on, and in the vicinity of, the Site.
Surface water flow at the established stations is required to be monitored monthly during the first year of
Site operations and on a quarterly basis in subsequent years, and surface water quality is required to be
assessed quarterly.
Surface water samples were collected from the established monitoring stations on March 31, May 16,
August 26, and November 11, 2011 No samples were obtained from SW1, 5, 6, and 8 on August 26,

2011 due to dry conditions at those locations. The samples were analyzed for inorganic chemistry,
metals, PAH, and VOC, as required by Condition 52, and detailed in Schedule C of the Waste Certificate
of Approval.
The results of the Surface Water sampling at the site are summarised in Table G-1.
3.3.2 Sewage Certificate of Approval
In conformance with the amended Sewage Certificate of Approval, stormwater grab samples are required
to be collected from the Surface Water Management Facility (SWM Pond) and the Temporary Dewatering
Sedimentation Pond (TDS Pond) on a quarterly frequency, upon commencement of operation.
The SWM Pond is not yet constructed and, therefore, no sampling occurred during 2011.
The TDS Pond is constructed and operational; quarterly sampling was done in 2011 for the TDS pond, as
per the amended Sewage Certificate of Approval. Samples were obtained March 4, June 10,
September 26, and December 12, 2011. In addition to the quarterly monitoring program, sampling of the
TDS Pond is required prior to any discharge from the TDS Pond to the roadside ditches, as per the
Sewage Certificate of Approval. Samples for these events were taken on May 16 and July 4, 2011, from
the discharge point along Brooks Road and analyzed for the trigger parameters outlined in Table 3 of the
Sewage Certificate of Approval. Table 3 of the Sewage Certificate of Approval also provides trigger levels
for which to comparison to the analytical results of the TDS Pond sample.
One additional sampling event was carried out for the TDS pond on October 26, 2011. The collected
sample was analysed for VOCs and PAHs only, in order to develop a new list of trigger parameters with
the MOE. The new trigger parameter list was proposed in a memo on October 31, 2011, and
subsequently approved by the MOE. A copy of the memo is included in Appendix A.
3.4 Landfill Gas
As per the Waste Certificate of Approval Condition 34, the Broaks Road Landfill is required to install eight
(8) methane monitoring probes prior to commissioning of the leachate holding tank. As a new leachate
management system, which does not include construction of a leachate-holding tank, has been submitted
for approval, the methane monitoring probes should be installed prior to commissioning of the new
leachate management system.
The landfill gas monitoring program will include monitoring of the percent of lower explosive limit (LEL),
methane concentration, and gas pressure. The landfill gas monitoring network will consist of eight gas
probes installed at four on–site locations (two per location). A brief description of the future landfill gas
monitoring locations is provided below.
 GP1 will be located in the northwest corner of the Site. This on Site location is the closest to
the nearest off-site dwelling/structure.
 GP2 will be located between the western limit of waste and Brooks Road.
 GP3 will be installed in the vicinity of the on-Site office/maintenance building.

 GP4 will be located adjacent to the underground storage tank located in the leachate loading
facility.
Following landfill gas monitor installation, the landfill gas monitoring activities should be conducted
monthly between December 1 and April 30 (i.e., during the ground frost conditions), and on a quarterly
basis between May and November.
3.5 Field Sampling and Record Keeping
Field testing was completed for groundwater, leachate, surface water, and stormwater samples. Analytes
are summarized in the following table.
Table 3-3 Summary of Field Sampling Parameters
Monitoring Field Parameters
Groundwater pH, conductivity, temperature
Leachate pH, conductivity, temperature, dissolved oxygen
Surface Water pH, conductivity, temperature, dissolved oxygen, stream discharge rate
Stormwater (TDS Pond) pH, conductivity, temperature, dissolved oxygen
Field notes are recorded in a dedicated field book that is maintained on file, if required. The results of field
testing are included in the respective water quality tables with the laboratory results.
3.6 Quality Assurance for Sampling and Analysis
The quality assurance and quality control (QA/QC) program included field-prepared duplicate samples,
laboratory-prepared blanks, matrix spikes, duplicates, and percent recovery of analysis and data review.
Analytical results for the field QA/QC sampling completed were evaluated for the relative percent
difference (RPD) of parameter concentrations. For parameters with sample concentrations greater than
five times the reported detection limit (RDL), a concentration difference of less than or equal to 20% was
deemed acceptable. For parameters where the sample and duplicate/replicate concentrations were less
than or equal to five times the RDL, a concentration difference of equal to or less than the RDL was
deemed acceptable.
3.6.1 Groundwater
Three blind field duplicate samples were collected during each monitoring event in 2011. A random
laboratory replicate sample was also analyzed by the laboratory to ensure consistency of results.
Laboratory chemical results are provided in Appendix E.
Blind field duplicates were collected from:

 MW2-03, MW5A-06, and MW6A-07 during the May groundwater sampling event,
 MW2A-01, MW6A-07, and OW5A-06 during the July groundwater sampling event, and:
 MW2A-01, MW6A-07, and OW5A-06 during the November groundwater sampling event.
The blind field duplicate results were generally similar to the original sample results with the exceptions
summarised in the following table.
Table 3-4 QA/QC Exceptions in Groundwater Samples
Sample ID Sampling Event Parameter QA/QC Evaluation
Relative Percent Difference >20% Difference in Concentration greater than MDL
(used where sample concentrations <5 x MDL)
MW5A-06 May Ammonia 
MW6A-07 May Ammonia 
MW2A-01 July Zinc 
MW6A-07 July
Zinc 
COD 
MW5A-06 July
Total Phosphorus 
Zinc 
MW6A-07 November DOC 
None of the laboratory replicates exceeded acceptable limits for quality control, however, the results for
these parameters are interpreted with caution.
3.6.2 Leachate
A laboratory replicate of the July 2011 leachate sampling event was tested by the laboratory to ensure
consistency of results. Laboratory chemical results are provided in Appendix F. None of the laboratory
replicates exceeded acceptable limits for quality control.
3.6.3 Surface Water
A blind field duplicate sample was collected during each of the August 2011 and November 2011 surface
water monitoring events. Also, each sampling event was tested randomly by the laboratory to ensure
consistency of results. Laboratory chemical results are provided in Appendix G.
A blind field duplicate sample was collected during the sampling event from SW4 on August 26, 2011 and
from SW1 during the November 2011 surface water monitoring event.
The blind duplicate results were generally similar to the original sample results with the exceptions noted
in the following table.

Table 3-5 QA/QC Exceptions in Surface Water Samples
Sample ID Sampling Event Parameter
QA/QC Evaluation
Relative Percent Difference >20%
Difference in Concentration greater than MDL
(used where sample concentrations
<5 x MDL)
SW4 August
Ammonia 
TSS 
SW1 November COD 
While concentrations of these parameters in the field duplicates differed from the original samples, these
concentrations were within the historic ranges for the respective sample location. None of the laboratory
replicates exceeded acceptable limits for quality control, however, the results for these parameters are
interpreted with caution.
3.7 Supplemental Monitoring
Additional sampling of ponded areas and leachate seeps was undertaken throughout 2011, as necessary.
Additional samples were obtained from ponded areas under the section 53 Certificate of Approval in July,
August, and September 2011. Samples were tested according to section 53 stormwater parameters.
Additional samples of leachate seeps were taken in November 2011 under the Certificate of Approval.
These were tested for the complete leachate parameter suite. Water quality results, as well as the
laboratory certificates of analysis, can be found in Appendix I.
3.8 Operational Monitoring
Operational monitoring, which includes daily inspection of the facilities and equipment, addressing public
inquiries and complaints, and participation in the Public Liaison Committee was undertaken in 2011 by
the Brooks Road Landfill Site personnel.
3.8.1 Daily Operations
Daily inspections include assessments of the condition of site fencing, gates, access and haul roads,
litter, scale & control equipment, site equipment, and dust control.
Completed Daily Inspection and Log Reports are maintained on-site and available for inspection.
Figure 3-1, below, is an example of the Daily Inspection & Log Report. Weather conditions and the
disposal area used are noted for each day. In addition, daily records of any rejected waste load(s), the
volume of leachate that is trucked off-site for disposal, and any public complaints lodged are recorded.
Corrective action(s) arising from the inspection are recorded.

Figure 3-1 Example of Daily Inspection & Log Report
3.8.2 Public Complaints
In 2011, five public complaints were received by Landfill Site staff. A summary of the complaints and
corrective action(s) is provided in the table below.
Table 3-6 Summary of Public Complaints
Date and Time
Operations
at the time
of Complaint
Wind at the time
of incident
and/or weather
Complaints
Leachate Smell at
the time complaint
was received
Investigation results and
corrective actions
04 April 2011
Time:
Landfill
Operations
Light rain. Overcast Odour Not noticeable None
10 May 2011
Time:
Landfill closed Partly cloudy, 14
Degrees
Road covered with
mud on Sunday.
The road was fine
on Monday.
N/A None
31 May 2011
Time:
Landfill
Operations
21 Degrees Odour. Not noticeable Made sure everything was covered
03 October 2011
Time:
Landfill
Operations
Heavy rain, above 0 Odour.
Dirt on road.
N/A Throughout the day roads are cleaned
regularly with bobcat sweeper
03 November 2011
Time:
Landfill
Operations
Rain, Overcast 0 Litter on the road.
Strong odour
Strong Litter was picked up and road checked.
All drivers were told to make sure truck
was clean before leaving

3.8.3 Public Liaison Committee
As required by the Certificate of Approval, a Public Liaison Committee (PLC) was established in 2004 to
serve as a forum for the dissemination of information, consultation, review, and exchange of information
regarding the operation of the Site.
Due to delays in Site development, legal challenges to the Site Certificate of Approval, and temporary
closures of the Site while in Receivership, the PLC ceased to function between 2005 and 2010.
The Public Liaison Committee was re-established in 2011 with meetings held on 11 January, 12 April,
12 July, and 11 October.
4 Overview – Monitoring Results
This section provides the results of monitoring program activities undertaken during 2011. Monitoring
activities undertaken at the Brooks Road Landfill included monitoring and sampling of leachate,
groundwater, surface water, gas (future), and engineered control works (e.g., TDS pond).
4.1 Historical Data
Available historical data for groundwater and surface water, including the TDS Pond, are presented in
Appendix tables along with the 2011 monitoring data. Groundwater and surface water monitoring data is
available since 2004 and TDS Pond monitoring data is available since 2006.
4.2 Data Quality Evaluation
As discussed in Section 3.6, QA/QC measures using field-prepared blind duplicate samples, laboratory-
prepared replicate samples, laboratory blanks, and percent recoveries, as well as a Data Quality Review
(DQR) conducted by the laboratory, suggest that the groundwater chemical results presented are
representative of actual conditions and may be interpreted with confidence. Variations in concentration
are attributed to the natural heterogeneity of the Site and the volatility of select chemicals of concern.
Where the results of comparisons of groundwater and surface water field duplicates indicated several
parameters did not meet QA/QC acceptance criteria, the results for these parameters should be
interpreted with caution.
4.3 Groundwater Flow Monitoring
Groundwater elevations measured for the 2011 sampling events are presented in Table E-1, Appendix E,
along with historic data. Hydrographs covering the period between 2004 and 2011 are presented for the
shallow overburden aquifer, basal overburden/shallow bedrock aquifer, and bedrock aquifer in
Appendix E—Figures E-1, E-2, and E-3, respectively. Groundwater elevations and/or inferred elevation
contours are presented graphically in Figures 3 through 8.

4.4 Groundwater Quality Monitoring
Laboratory chemical results for the May, July, and November 2011 sampling events are presented in
Tables E-2 through E-4. Historic data are provided for comparison. Laboratory reports of analysis and
QA/QC documentation are included in Appendix E.
We acknowledge that the Ministry provided additional historic groundwater quality data for two sampling
events conducted by the MOE in April and December 2009. This data has been included in the historic
groundwater quality table data.
The following provides a brief summary of the results including exceedances of the MOE criteria listed in
the Ontario Drinking Water Quality Standards (ODWQS), published by the MOE in August 2000, and
revised in 2001 and June2006.
4.4.1 Shallow Overburden Unit
Groundwater quality in the shallow overburden unit in 2011 generally complied with the ODWQS for the
parameters tested, with the following exceptions:
Table 4-1 Shallow Overburden Unit ODWQS Exceedances
DOC Sulphates TDS Iron Manganese Sodium
MW1-03  
MW1B-06   
MW2-03  
MW2B-07   
MW2C-01    
MW3-03   
MW5B-09    
MW6B-07   
OW1B-07     
OW3B-07    
OW5B-06  
OW8B-06  
OW9B-06 
 - May 2011;  - July 2011;  - November 2011.
The above-noted exceedances are for non-health-related parameters. Groundwater parameter
concentrations in the shallow overburden unit during the sampling events in 2011 were generally within
their historic ranges, with the exception of DOC concentrations which were generally higher than the
historic maxima of the sampled wells. Comparison of pre-2011 historic DOC concentrations to more
recent results should be undertaken with caution as DOC sampling from January 2011 onwards was
completed according to the updated sampling protocol, which requires field-filtration and preservation of
DOC samples. Previous sampling for DOC did not include filtration or preservation.

ODWQS exceedances in the Shallow Overburden are presented graphically on Figure 9.
4.4.2 Basal Overburden/Shallow Bedrock Unit
Groundwater quality in the basal overburden/shallow bedrock unit in 2011 generally complied with the
ODWQS for the parameters tested, with the exceptions indicated in the following table:
Table 4-2 Basal Overburden/Shallow Bedrock Unit ODWQS Exceedances
DOC pH Sulphates TDS Iron Manganese
MW1A-07 
MW2A-01   
MW4A-09    
MW5A-09    
MW6A-07 ()
1
   
OW1A-06    
OW3A-07    
OW5A-06     
OW8A-06     
O
9A-06    
1. The November 2011 field duplicate for MW6A-07 had an exceedance for Dissolved Organic Carbon (27.6 mg/L); however, the
original sample had a value of 3.1 mg/L. The field sample is considered anomalous and is mentioned as an exceedance to be
conservative in reporting.
The above-noted exceedances are for non-health-related parameters, which have aesthetic objectives or
operational guidelines. Groundwater parameter concentrations in the basal overburden/shallow bedrock
were generally within their historic ranges for the sampling event in 2011. ODWQS exceedances in the
basal overburden/shallow bedrock unit are presented graphically on Figure 10.
As noted for the shallow overburden unit, DOC concentrations in groundwater samples during 2011 were
generally greater than the historic maxima of the sampled wells. However, monitors MW4A-09,
MW5A-09, and MW6A-07 had anomalously high DOC readings in November 2011. These results should
be interpreted with caution.
The water quality at monitor MW1A-07 is generally anomalous in comparison to the water quality of the
remaining wells within this unit. This monitoring well should be examined in further detail to determine if a
well replacement or refurbishment is required.
4.4.3 Bedrock Unit
Groundwater quality in the bedrock unit during the sampling event in 2011 generally complied with the
ODWQS for the parameters tested, with the following exceptions:

Table 4-3 Bedrock Unit ODWQS Exceedances
DOC Sulphates TDS Boron Iron Manganese
MW1D-07    
MW1S-07   
MW2D
07     
MW2S-07    
OW8D-07     
OW8S-07     
The above-noted exceedances are for non-health-related parameters, which have aesthetic objectives or
operational guidelines, with the exception of boron, which has an interim maximum acceptable
concentration (IMAC). ODWQS exceedances in the bedrock unit are presented graphically on Figure 11.
Based on historic groundwater quality data, boron concentrations in samples from bedrock monitoring
wells MW1D-07 and OW8D-07 typically exceed the ODWQS criterion. Groundwater parameter
concentrations in the bedrock unit for the samples obtained in 2011 were generally within their historic
ranges. As noted previously, DOC concentrations in groundwater samples were generally greater than
the historic maxima of the sampled wells during 2011, but comparison to historic ranges should be
interpreted with caution due to changes in the DOC sample preparation protocol.
4.5 Leachate Characterisation
Laboratory chemical results for the leachate monitoring events in 2011 are presented in Table F-1.
Historic data are provided for comparison. Due to the transition in ownership/operator in 2010, only one
sampling result is available for that year. Laboratory reports of analysis and QA/QC documentation are
included in Appendix F.
The leachate quality for the grab samples obtained in 2011 under the Certificate of Approval generally
met the ODWQS standards with the following exceptions.
Table 4-4 Certificate of Approval ODWQS Leachate Exceedances
Parameter ODWQS Unit
ODWQS
type
May 31, 2011 July 4, 2011 November 11, 2011
Alkalinity 30 – 500 mg/L OG 2610 3700
Boron 5000 µg/L IMAC 6730 9820 16100
Chloride 250 mg/L AO 1060 1190 1440
Chromium 50 µg/L MAC 58
Dissolved Organic Carbon 5 mg/L AO 211 304 555
Hardness 80 - 100 mg/L OG 1860
Iron 300 µg/L AO 1200 7510 2210
Toluene 24 µg/L AO 41
Total Dissolved Solids 500 mg/L AO 4210 4560 5800

Note that the exceedances were for operational guidelines or aesthetic objectives for the parameters
except for boron and chromium, which are health-related.
The leachate quality for the 2011 samples obtained under the Section 53 Certificate of Approval were
compared to PWQO criteria. In general, the leachate samples complied with PWQO criteria with the
following exceptions:
Table 4-5 Section 53 Certificate of Approval Leachate Exceedances
Parameter PWQO Unit March 31, 2011 June 10, 2011
Ammonia, un-ionised 20 µg/L 1570 3650
Arsenic (5) µg/L 15 29
Boron (200) µg/L 2510 7710
Copper 5 µg/L 6 7.1
Iron 300 µg/L 7550 6400
Lead (5) µg/L 8.8
Phenols (1) µg/L 130 354
Toluene (0.8) µg/L 4.4 37
Total Phosphorus (30) µg/L 1350 4060
Zinc (20) µg/L 87 172
(0.5) indicates an interim PWQO
As shown in Tables F-1 and F-2, the leachate quality exceeded the ODWQS standard for boron and
chromium, and exceeded the aesthetic objectives/operational guidelines for alkalinity, chloride, dissolved
organic carbon, hardness, phenols, total dissolved solids, arsenic, boron, chromium, copper, iron, zinc,
and toluene.
The leachate parameter concentrations were also compared to characteristic leachate ranges, calculated
from leachate concentrations published by Rowe (1995). The leachate samples results were generally
below the characteristic ranges.
4.6 Surface Water Quantity Monitoring
Surface water flow monitoring was completed during the March, May, August, and November 2011
monitoring events for all stations except SW1, SW5, SW6, and SW8 which were dry during the August
2011 monitoring event. Surface water discharge rate data for the 2011 monitoring events are presented in
Table G-1.
4.7 Surface Water Quality Monitoring
Laboratory chemical results for the surface water monitoring events carried out in 2011 are presented in
Table G-1. Historic data are provided for comparison. Laboratory reports of analysis and QA/QC
documentation are included as Table G-1, Appendix G.

The results of analysis indicate that the surface water quality samples generally complied with the PWQO
criteria, at the time of sampling. Parameter concentrations that exceeded the PWQO criteria are
summarized in the table below and presented graphically on Figure 12.
Table 4-6 PWQO Exceedances in Surface Water Samples
Parameter Units
PWQO
(IPWQO)
SW1 SW3 SW4 SW5 SW6 SW7 SW8
Background,
immediately
upstream
Downstream at
southwest site
perimeter
380 m
downstream
of site
SE
corner
of Site
Off-site
ephemeral
pond 30 m
South of SW5
Off-site pond,
unconnected
Background off-
site pond,
unconnected
Phenols µg/L 1   
Total
Phosphorus
µg/L 30       
Boron µg/L (200) 
Cobalt µg/L 0.9     
Copper µg/L 5   
Iron µg/L 300       
Lead µg/L 25 (5) () ()
Zinc µg/L 30     
Toluene μg/L 0.8 
 - March 2011,  - May 2011.  - August 2011,  - November 2011
PWQO for lead varies with [alkalinity]; IPWQO for lead varies with [hardness]; () indicates that concentration exceeded the
interim PWQO (IPWQO) but not the PWQO
4.7.1 Background Stations
Surface water background stations SW1 and SW8 generally complied with the PWQO criteria, at the time
of sampling. Exceptions for SW1 include total phosphorus, cobalt, iron, and zinc. Exceptions for SW8
include phenols, total phosphorus, cobalt, copper, iron, and zinc. Organic and PAH parameter
concentrations were below the respective laboratory method detection limits for both background
samples.
4.7.2 On-site Station
The on-site surface water monitoring station SW5 generally complied with the PWQO criteria at the time
of sampling. Exceptions for SW5 include total phosphorus, cobalt, copper, iron, and zinc. The
concentration of lead at SW5 exceeded the IPWQO criterion in May and November. Organic and PAH
parameter concentrations were below the respective laboratory method detection limits for the on-site
samples.
4.7.3 Downstream
Surface water stations located downgradient of the Site including SW3, SW4, SW6, and SW7 generally
complied with the PWQO criteria, at the time of sampling. Exceptions for SW3 include total phosphorus,

boron, iron, and zinc. Exceptions for SW4 include total phosphorus and iron. Exceptions for SW6 include
phenols, total phosphorus, cobalt, iron, and toluene. Exceptions for SW7 include phenols, total
phosphorus, cobalt, copper, iron, lead (IPWQO), and zinc. Organic and PAH parameter concentrations
were generally below the respective laboratory method detection limits for the samples, with the
exception of toluene at SW6.
4.8 Gas Pressures and Composition
As discussed in Section 3.4, the landfill gas monitoring program will commence following installation of
the gas probes, as per the Waste Certificate of Approval.
4.9 Control Systems Monitoring
Laboratory chemical results for stormwater monitoring of the TDS Pond during 2011 are presented in
Table H-1. Historic data are provided for comparison. Laboratory reports of analysis and QA/QC
documentation are included in Appendix H. The results of analysis were compared to PWQO criteria and
the trigger criteria specified in the site s53 Certificate of Approval for Industrial Sewage Works.
TDS Pond sampling and analysis for s53 Stormwater parameters was undertaken in March, June,
September, and December. Additional sampling for the s53 Trigger Parameters is required prior to off-site
discharge from the TDS Pond (if discharge did not coincide with the quarterly sampling event).
In addition to scheduled sampling, TDS Pond sampling was conducted (prior to discharge events) on
May 16 and July 4, 2011 and analyzed for the trigger parameters outlined in the Certificate of Approval
(pH and TSS). If a trigger parameter(s) was exceeded, no discharge was permitted until a resample
confirmed that parameter concentrations were below the trigger criteria.
At the request of the MOE, additional Trigger Parameters for TDS discharge were developed in October
2011 and approved by the MOE in November 2011. The additional trigger parameters, applied after
November 2011, are un-ionised ammonia, total phosphorus, boron, iron, zinc, toluene, fluorene, and
naphthalene.
The water quality in the TDS Pond samples obtained in 2011 generally complied with the PWQO for
parameters tested, with exceptions noted in the following table.
Table 4-7 TDS Pond PWQO Exceedances
Parameter PWQO Units March May June July September December
Total Phosphorus (30) µg/L 31 37 80 34
Boron (200) µg/L 214 255 303 346 370
Zinc (20) µg/L 65.3
Phenanthrene (0.03) µg/L 0.13
(30) indicates interim PWQO criterion
The TDS trigger criterion for TSS was exceeded in the May and September 2011 samples. No discharge
occurred following these sampling events.

5 Assessment, Interpretation, and Discussion
This section provides an assessment of the potential impact from the Brooks Road Landfill on local
groundwater and surface water features, using the results and analysis of the 2011 and historic
monitoring data.
5.1 Groundwater Flow Interpretation
Spring and autumn groundwater flow in the shallow overburden, basal overburden/shallow bedrock, and
the bedrock units was determined from inferred water table/piezometric surface contours shown on
Figures 3 through 8 and discussed in the following sections. Hydrographs are provided in Figures E-1 to
E-4, Appendix E.
5.1.1 Shallow Overburden Unit
Groundwater contours for the shallow overburden unit measured in May and November 2011 are
presented in Figures 3 and 4, respectively. The shallow overburden unit represents a shallow
groundwater flow system whereby precipitation infiltrates into soil fractures, root casts, and other
weathering features and moves in a dominantly lateral direction. The low permeability of the surrounding
and underlying clayey silt matrix restricts the volume of groundwater movement through the shallow
aquitard. Evidence of the low hydraulic conductivity within the shallow aquitard may be observed in the
slow recovery of monitoring wells following purging and sampling.
Based on the groundwater elevation data gathered in May and November, it is concluded that the
groundwater within the local shallow overburden unit flows in a generally easterly direction. Previous
interpretation of groundwater flow within the shallow overburden unit indicated radial flow away from the
OLA. As the shallow overburden monitoring wells, which were previously located in the OLA (OW4B-91
and OW6B-92), have been decommissioned, it cannot be confirmed whether this conditions continues to
exist.
Based on the water levels obtained in 2011, on-site groundwater flow within the shallow overburden
aquifer is toward the open Cell 2 excavation, which is dewatered to permit construction. (Water is pumped
into the TDS pond following confirmatory quality analysis.)
Surficial features such as ditches, waste cells, excavations, ponds, berms, and the leachate management
systems, as well as precipitation amounts, will locally influence the groundwater flow direction.
Groundwater mounding within the OLA may be reduced as ponded areas within the OLA have been
drained, with the water either discharged off-site or into the leachate collection system, as directed by the
results of water quality analysis.
In the long term, groundwater elevations within the shallow aquifer will continue to fluctuate because of
seasonal effects from precipitation and snowmelt, as well as irregular periods of prolonged precipitation or
lower than normal precipitation, as was observed during the summer of 2010.

5.1.2 Basal overburden/shallow Bedrock Unit
Groundwater elevations for the basal overburden/shallow bedrock unit measured in May and November
2011 are presented in Figures 5 and 6, respectively. Based on the groundwater elevation data gathered
in May and November, it is concluded that groundwater in the basal overburden/shallow bedrock unit
generally flows in a north-westerly direction.
5.1.3 Bedrock Unit
The groundwater elevation data gathered in May and November 2011 are provided on Figures 7 and 8,
respectively. The water levels at each borehole location in this unit are similar, being approximately 184.3
to 184.5 mASL. This pattern indicates a flat hydraulic gradient within the deeper bedrock unit, with no
discernible flow direction.
5.2 Groundwater and Surface Water Quality
The assessment of groundwater and surface water quality was developed through analysis of regulatory
criterion exceedances and trends in the 2011 and historic water quality data.
5.2.1 Groundwater
The Reasonable Use Criteria (RUC) criteria used for the 2011 assessment were established using
background water quality data collected from monitoring wells located up-gradient of the historic OLA.
The RUC established for the shallow overburden unit was derived from background groundwater quality
data gathered at monitors MW1B-07, OW3B-07, and OW9B-06 as summarized in Table E-5, Appendix E.
The RUC established for the basal overburden/shallow bedrock unit were derived from background
groundwater quality data gathered at monitors MW1A-07, OW3A-07, and OW9A-06, as summarized in
Table E-8, Appendix E. The revised calculated RUCs are based on the average median concentration
reported in the background/up-gradient monitoring wells.
Groundwater chemistry in each unit was also examined for trends over time.
5.2.1.1 Shallow Overburden Unit
Although groundwater in the shallow overburden on-site is inferred to flow toward the open Cell 2
excavation in 2011, the impact assessment, including calculation of RUCs is undertaken as an academic
exercise and for the purpose of consistency with previous and future reports.
The groundwater impact assessment undertaken for the 2011 monitoring period for the Site is based on
the 2011 chemistry data and focuses on select shallow overburden wells located downgradient of the
OLA, including the western boundary of the Site (MW1-03, MW2-03, MW3-03), the eastern portion of the
Site (MW2C-01), along the southern boundaries of the Site (OW8B-06, OW1B-06, OW5B-06) and south
of the Site boundary (MW5B-09, MW6B-07). Exceedances of the RUCs for the shallow overburden unit
are presented in Table E-6 for the up-gradient/background monitoring wells and in Table E-7 for the
boundary and downgradient monitoring wells.

The groundwater trigger parameters were generally in compliance with their RUCs with the exception of
sulphate for monitor OW1B-06, OW5B-06 (southern border), MW5B-09 and MW6B-07 (south of Site),
MW2B-07 and MW2C-01 (eastern border); iron for monitors OW1B-06 (southern border) and MW3-03
(western border), and boron for monitor OW8B-06 (southern border).
It should be noted that the RUC groundwater quality analysis for up-gradient/background stations also
reported exceedances for sulphate (OW9B-06) and iron (MW1B-07). These parameters are elevated in
monitoring wells across the site and within the basal overburden/shallow bedrock unit.
Exceedances of ODWQS were plotted on Figure 9 for the shallow overburden unit to examine potential
spatial trends. Exceedances for DOC and TDS are found at a majority of the overburden wells. Sulphate
exceedances are found within the western boundary monitors (MW2C-01 and MW2B-07), southern
boundary monitoring well (OW1B-06), and south of the site monitors (MW5B-09 and MW6B-07).
Exceedances of iron occur at monitors within the site, but not at all monitoring wells. Manganese
exceedances were only found north of the Site (MW1B-07 and MW3B-07). Only one exceedance of
sodium was recorded at MW5B-09 (south of the Site) in 2011.
Parameters were also examined for any prevailing trends over time within the shallow overburden unit.
The following table summarises the notable trends.
Table 5-1 Parameter Trends in the Shallow Overburden Unit
Parameter Observed Trend
Chemical Oxygen Demand Overall downward trend within the shallow overburden unit
Chloride Upward trend at monitor MW1-03, MW2-03, and OW8B-06, possibly from road salt use
Dissolved Organic Carbon Upward trend; however sampling/analysis methodologies have changed sincethe end of 2010
Sulphate Upward trend at MW2C-01, at the east side of the landfill
Barium Upward trend in OW3B-07, at the north side of the landfill.
5.2.1.2 Basal Overburden/Shallow Bedrock Unit
The basal overburden/shallow bedrock unit beneath the OLA is overlain by a clay aquitard of low
hydraulic conductivity, and thus the potential for water quality impact in this unit is low. Results from the
2005 and 2006 monitoring program, however, indicated that some inadvertent vertical contaminant
migration may have occurred in the vicinity of OW6A/6B, located to the south of the site on the west side
of Brooks Road. The vertical contaminant migration at this location is due to possible compromised well
integrity as a result of nearby construction activities.
For the 2011 monitoring period, basal overburden/ shallow bedrock wells targeted for assessment
included monitoring wells located in the southern portion of the Site (OW1A-06, OW5A-06, and
OW8A-06), the eastern portion of the Site (MW2A-01), immediately west of the Site (MW4A-09), and
downgradient of the Site (MW5A-09 and MW6A-07). Exceedances of the RUCs for the basal
overburden/shallow bedrock unit are presented in Table E-9 for the up-gradient/background monitoring
wells and in Table E-10 for the boundary and downgradient monitoring wells.
As presented in Table E-10, exceedances of the RUC were observed at all of the targeted wells. Sulphate
exceedances occurred at each location. Iron exceeded at monitors along the southern portion of the

(OW1A-06, OW5A-06, and OW8A-06) and at the downgradient monitoring wells (MW5A-09 and
MW6A-07). The remaining groundwater trigger parameters complied with the RUCs.
It is noted that the groundwater quality analysis for the up-gradient/background locations also exhibited
exceedances of the RUCs for sulphate (OW3A-07 and OW9A-06) and iron (OW9A-06). These results
indicate that the sulphate and iron RUC exceedances within the basal overburden/shallow bedrock
monitoring wells are likely naturally-occurring and are not attributed to landfill-related activities. Since the
bedrock is part of the Salina Formation, naturally poor water quality is expected.
Exceedances of the ODWQS were plotted on Figure 10 for the basal overburden/shallow bedrock unit to
examine potential spatial trends. Exceedances of sulphates were noted at eachmonitoring well except
MW1A-07. DOC, TDS, iron, and manganese exceedances were also noted across the site. Overall, there
is no noticeable spatial trend for the exceedances withn the basal overburden/shallow bedrock unit.
Parameters were also examined for any prevailing trends over time. The following table summarises the
notable trends.
Table 5-2 Parameter Trends for Basal Overburden/Shallow Bedrock Unit
Ammonia Downward trend overall in the basal overburden/shallow bedrock unit
Sulphates Slight upward trend overall in the basal overburden/shallow bedrock unit
Barium Upward trend at OW3A-07 which correlates with the noted upward trend at OW3B-07
Iron Downward trend overall for the basal overburden/shallow bedrock unit
Magnesium Downward trend overall for the basal overburden/shallow bedrock unit
Sodium Downward trend overall for the basal overburden/shallow bedrock unit
It is noted that historical current water quality samples from monitor MW1A-07 have results consistently
different than the chemistry results for the remaining monitoring wells within the unit. It is recommended
that the monitoring well should be examined for refurbishment or replacement.
5.2.1.3 Bedrock Aquifer
The RUC analysis was not performed on the Bedrock Aquifer as groundwater elevations indicated
minimal groundwater movement within this unit.
Exceedances of the ODWQS were plotted on Figure 11 for the Bedrock Aquifer to examine spatial trends.
Sulphates, TDS, boron, iron, and manganese exceedances occurred across the site at various monitoring
wells. Overall, there is no noticeable spatial trend within the bedrock aquifer. Parameters were also
examined for potential prevailing trends over time. The following table summarises the notable trends.

Table 5-3 Parameter Trends in the Bedrock Aquifer
Chloride Downward trend at MW1D-07 and OW8D-07
Dissolved Organic Carbon Upward trend; however sampling/analysis methodologies have changed since the end of 2010
Boron Downward trend at MW2D-07
Iron Minor downward trend overall
Sodium Downward trend overall
5.2.2 Surface Water
PWQO exceedances for surface water stations were plotted in Figure 12 to examine potential spatial
trends. Total phosphorus, iron and zinc exceedances occur across the site at each surface water station.
Copper exceedances occur at surface water stations in the southern portion of the site, and cobalt
exceedances occur at various stations across the site. There are no clear spatial trends for exceedances
with the exception of copper, which only occurs in the southern portion of the site.
Figure 12 also shows the TDS exceedance. When surface water station exceedances are compared with
TDS values, there is little correlation between the two. However, it is noted that the background station
SW1 has exceedances for total phosphorus, cobalt, iron, and zinc.
Parameters were also examined for potential prevailing trends in the surface water over time. The
following table summarises the notable trends:
Table 5-4 Parameter Trends in Surface Water
Chloride Upward trend at SW3 and SW4
DOC Upward trend at SW6 and SW7
Nitrate Downward trend at SW4
Sulphates Upward trend overall
TDS Upward trend at SW3, SW4, and SW5
TKN Upward trend at SW7
It is noted that several high concentrations of COD at station SW7 and phenols at SW6 and SW7 have
occurred during the sampling events during 2010 and 2011 but continued monitoring is necessary to
establish a trend.
To further assess the surface water collected at the Site during the 2011 monitoring events, the
parameters that exceeded the PWQO were compared to the station location and the type of surface
water feature (ditch or pond).
5.2.2.1 Ditch Network
The analytical results reported within the ditches, in proximity to the Site, are summarized in the following
table for the parameters that reported PWQO exceedances in 2011.

Table 5-5 Surface Water PWQO Exceedances within the Ditch Network
Parameter
SW1 SW3 SW4
Background Immediately Downstream 380 m Downstream of Site
Total Phosphorus   
Boron 
Cobalt 
Iron   
Zinc  
 - March 2011,  - May 2011,  - August 2011,  - November 2011
The parameters with reported PWQO exceedances for downstream stations SW3 and SW4 were
generally detected at similar or lower concentrations compared to the concentration at the background
station, SW1. An exception was noted for boron where the detected concentrations at station SW3 and,
to a lesser degree, at SW4 were elevated over background levels. However, the noted boron
concentration at SW3 during 2011 were generally lower than all available historic boron concentrations
reported for this station.
The water quality reported in the ditch network during 2011 was within the historic range with the
exception of sodium for station SW3, and sodium, calcium, chloride, and magnesium for SW4.
5.2.2.2 Ponded Areas
The analytical results reported within the ponds, in proximity to the Site, are summarised in the following
table for the parameters that reported PWQO exceedances in 2011.
Table 5-6 Surface Water PWQO Exceedances in Ponded Areas
Parameter
SW8 SW6 SW7
Background Immediately Downstream Immediately Downstream
March May November March May November March May August November
Phenols 2 40 2 4
Total
Phosphorus
270 867 535 210 274 833 570 3170 4150 177
Cobalt 1.67 1.29 1.14 0.98 1.64 2.19
Copper 6.02 5.15 6.35
Iron 1960 3550 2410 1290 2540 2600 2840 5480 8650 5110
Zinc 29.1 64 22
Toluene 1.1

The parameter concentration exceedances for surface water samples at SW6 in 2011 were generally
lower than the concentrations detected at background station SW8, with the exception of phenols and
toluene, which were not detected at SW8 in 2011.
The parameters with reported PWQO exceedances for SW7 were detected at higher concentrations
compared to the background station SW8, with the exception of phenols, cobalt, and copper. The surface
water quality at SW7 appears to have degraded in comparison to historic results, with most parameter
concentrations reaching historic highs in January 2011 and returning to the historic range for the
remainder of 2011. The poor surface water quality noted at SW7 during January 2011 is likely due to
construction activities undertaken at the Site. Poor surface water quality results may be attributed to
sampling of the pond under conditions of no flow. It is recommended that the surface water stations only
be sampled when flowing conditions exist.
5.2.3 Leachate Generation
During 2011, leachate was transported off-site by an approved liquid waste hauler for disposal. The
monthly leachate disposal is presented in the following table.
Table 5-7 Monthly Leachate Volumes (m
3
)
January February March April May June July August September October November December Total
0 0 0 0 4574 0 0 137 483 1755 1171 674 8795
A Leachate Management Plan report was prepared by GENIVAR that proposed the use of Aqua
Treatment Technologies Wetland System (AWS) for pretreatment of leachate on-site with eventual
discharge onto a poplar plantation located on the Cell 1 cap and the north buffer area. An application
package has been prepared and submitted to the MOE Environmental Assessment and Approvals
Branch (EAAB) for approval of this plan. Following initial consultation and MOE review, copies of the
application package were circulated to various stakeholders for comment.
5.3 Waste Disposal Site Gas Impacts
As discussed in Section 3.4, the landfill gas monitoring program will commence following installation of
the gas probes, as per the Waste Certificate of Approval.
5.4 Effectiveness of Engineered Controls
As Site development, including installation of engineered controls to minimize off-Site contaminant
migration, is only partially completed, the effectiveness of the controls cannot be adequately assessed at
this time. A proper assessment of the engineered controls implemented at the site can be conducted
once the landfill liner, surface water management (SWM) pond, and leachate collection systems have
been installed, and proper site grading is complete.
Currently, surface water is collected in the Temporary Dewatering Sedimentation (TDS) pond, which
provides some settlement capacity only prior to discharge from the site. The TDS pond may be used until
landfill cell construction is complete and the SWM pond is installed. However, since the TDS pond has
been in use longer than intended, a review of the trigger parameters was completed in October 2011 at

the request of the MOE. The trigger parameters were revised to reflect the manner in which the TDS
pond is used.
The portions of the landfill liner and leachate collection system installed in Cell 1 are functioning at an
initial level; leachate levels are maintained at elevations below the natural water table. The leachate
produced is pumped from the leachate collection system and shipped off-Site for disposal, as outlined in
Section 5.2. Once there is a system in place to better track leachate generation, a correlation between the
Site water balance and leachate generation may be developed.
5.5 Adequacy of the Monitoring Program
Table K-1 provides a summary of Certificate of Approval conditions applicable to the Site during the 2011
reporting period and the compliance status.
5.6 Amendments to the Certificate of Approval for Waste Disposal
Site
Based on review of the monitoring data, site operations, and site development, the Certificate of Approval
for Waste Disposal Site is recommended to be amended as follows:
 The Design & Operations (D & O) plan should be updated, including an updated site plan
(with modified 4:1 slope contours, and revisions to the surface water management, leachate
management and the financial assurance sections). The Certificate of Approval should be
amended to acknowledge the updated D & O plan. As a minimum, this will necessitate
amending the Site capacity cited in the Certificate of Approval Site and Conditions 1, 20, 21,
22, 30, 33, 50, and 78-85.
 A Construction & Demolition material recycling centre should be established, sited east of
the scale house in order to remove recyclable or reusable materials prior to landfilling.
Depending on the scale of the operation, this activity may be permitted under Condition 70 of
the Certificate of Approval, without the need for amendment. Condition 70 states that
“controlled removal of recyclable/reusable material from the Site may occur in a designated
paved area on the Site, and shall be supervised”. However, consultation with MOE should be
sought to confirm that a separate Certificate of Approval or additional Condition to the
existing one is not required.
 Condition 19 should be amended to remove the “daily” tonnage limit in favour of an annual
tonnage limit of 250 000 tonnes. This requested change is to acknowledge the seasonality of
waste acceptance and to allow the Site to accept more waste on those days when it
operates for a longer period of time.
 Note 4 of Schedule C, which lists PAH parameter suite for analyses should be amended to
remove benzo(j)fluoranthene as an individual parameter as it co-elutes with
benzo(b)fluoranthene and benzo(k)fluoranthene and can only be reported indirectly.
 Condition 19 should be amended to exclude contaminated, non-hazardous soil received at
the site for use as daily cover from the annual tonnage limit of waste that can be accepted.

 Condition 63 should be amended to extend the Site hours of operation to facilitate better use
of seasonal daylight hours. Alternately, under Condition 64, the hours may be amended in
consultation with the Public Liaison Committee and concurrence from the District Manager.
 The Leachate Management Report included plans for improved leachate treatment and
management including treatment via constructed wetland and irrigation of poplar
plantation(s) (phytoremediation). Application for approval of the plan has been submitted to
EAAB.
5.7 Assessment of the Need for Implementation of Contingency
Measures
Implementation of contingency measures is not required following review of the 2011 environmental
monitoring and quality data. Continued routine monitoring will assist in establishing potential trends.
However, a soil and shallow groundwater quality assessment plan has been implemented following the
release of leachate into the unlined Cell 2 excavation from the Cell 1 leachate trench, and from on-going
leachate seepage from the OLA.
5.8 HALT Review
At the request of Haldimand Against Landfill Transfers (HALT), Wilf Ruland undertook a Review of the
2006 Compliance Monitoring Report for Brooks Road Landfill, then known as the Edwards Landfill. He
provided comments and recommendations to HALT in a letter dated June 3, 2007. A copy of this letter is
attached in Appendix L.
Below is the text of the recommendations and our response to the comments and recommendations in
the letter.
Table 5-8 Responses to HALT Review Comments of 2006 Compliance Report
Item Comments or Response
a) Introduction
GENIVAR
Comment
The HALT Reviewer, Wilf Ruland, discussed water quality from monitoring well OW4B-91. To clarify, shallow
monitoring well OW4B-91 was located within the waste of the Original Landfill Area and, as such, liquid
samples from this monitoring well are considered leachate samples. The results of analysis on samples from
OW4B-91 do not represent shallow overburden aquifer water quality. Decommissioning of the Original
Landfill Area was initiated in autumn 2010 and will progress concurrent with cell construction of the new,
engineered landfill.
The description of the basal aquifer, as presented in the Review letter to HALT, is incomplete based on
review of the borehole logs for the site. Underlying the silt/clay is a basal aquifer comprised of a thin,
discontinuous silty sand till deposit overlying fractured dolostone and shale bedrock.
b) Shallow Groundwater Quality
Recommendation 1 Two shallow monitoring wells should be installed along the south property boundary (south of the historic
waste areas) to determine if significant southward contaminant migration is occurring from the Edwards
Landfill property.
Recommendation 2 The frequency of sampling the shallow monitoring wells west of the historic waste areas (MW 1-03, MW 2-
03, and MW 3-03) should be increased to at least twice yearly to determine if significant westward
contaminant migration is occurring from the Edwards Landfill property.
GENIVAR
Response
Groundwater flow within fractures, where present, may be horizontal but the primary flow direction within
clay (aquitard) units tends to be downward.
As the open excavation for cell 2 construction has been dewatered since 2010, the inferred flow direction for

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