The proponent’s continued and unacceptable environmental risks

While we are pleased to see that four of the proponent’s six insecticide-treated shipping containers (as reported here) are no longer in Bala, the proponent is still taking unacceptable environmental risks, for example:

1. Two of their six shipping containers are still in the Precambrian Shield parking lot, perhaps because the proponent pumped water into them, so this water may now be contaminated with insecticides and leaking into the Precambrian Shield parking lot.
   We request these remaining shipping containers to be properly disposed of.
    
2. The proponent has still not properly tested whether their proposed excavation site is contaminated with polychlorinated biphenyls (PCBs), so their planned work could release this toxic chemical to the Moon River, causing irreparable environmental damage.
   We request an independent Qualified Person to plan and supervise the proper excavation of this Brownfield site, to ensure that harmful substances are not released to the environment.
    
3. The proponent’s 2013 Environmental Site Assessment (ESA) found the levels of Zinc in the ground water to be 26.6, 12.6, and 1,040 μg/L (millionths of a gram of Zinc per litre of water) for each of the three exploratory boreholes they drilled. As the last value is above the limit allowed by the Ministry of the Environment and Climate Change (MOECC), the ESA suggested retesting. In response to our continued requests for this retesting, the MOECC recently reported that the proponent did retesting in October 2016, and they found that the levels of Zinc in all three boreholes are now “undetectable”, having spontaneously dropped to less than 5 μg/L.
   1. This is extremely unlikely. We have asked the MOECC Director, Central Region (whom we have met) to confirm she has personally seen these test results, but the MOECC refuses to provide this.
   2. As shown in the graphic in this article, the proponent’s testing was inadequate, so would more than likely have greater levels of contaminants, including PCBs.

   We request the laboratory test results be disclosed to the public.
    

4. The proponent would pump water from their proposed excavations through a plastic pipe suspended above the Bala south channel. They joined the many sections of this plastic pipe on-site, and each of these this pipe sections joined required a multi-step procedure to be carefully followed, or there could be leaks. As anyone that does technical work knows, testing is crucial, yet the proponent has not done any pressure testing, which is the accepted method. Other unaddressed concerns are:
   1. This plastic pipe is suspended from a cable, so would flex due to wind. It is not known if this pipe could tolerate flexing in colder weather.
   2. While the pipe has some insulation, to prevent freezing in colder weather, the pipe would need to be drained, but this would dump untreated water onto the Township’s Portage Landing, which is not allowed.

   We request to see:

   1. Drawings sealed by a Professional Engineer licensed to practice in Ontario confirming the installed pipe is suitable for the flexing and temperatures that would be encountered.
   2. Witnessed pressure test results showing there are no leaks in the installed pipe.
   3. Plans confirming the water in the pipe would not be dumped onto Portage Landing when pumping is stopped.
       
5. The proponent has not shown any concern for the environment, instead their priority is working quickly. The workers are on-site six and seven days a week, which means they are too likely to be taking short-cuts, such as creating this mess on November 8, 2017. While they claim this grout and oil are bio-degradable, their silt fence did not prevent it from getting out to the Moon River.
   The company providing environmental liability insurance to the proponent should be notified of the above.