Government of Nunavut Department of Environment Environmental Protection Division Intervention to the Nunavut Water Board City of Iqaluit Water License Renewal Application March 2006

Legislative Authority DOE derives its regulatory authority from the Environmental Protection Act (EPA). EPA Prohibits the discharge of a contaminant into the environment. Does not apply if the discharge is authorized by Federal or Territorial Legislation. EPA, its regulations and guidelines are the standard against which development projects are gauged in determining if they should proceed.

Opening Comments DOE avoided providing prescriptive, detailed recommendations for Terms and Conditions. Most DOE comments and suggestions are intended for the City of Iqaluit’s consideration and to assist them with coming into compliance with EPA. Comments intended to be included in the TAC are specifically noted as such.

Topics of Discussion Water Source & Treatment Waste Disposal – Solid Waste Lower Base Contamination Spill/Emergency Response Abandonment and Restoration Waste Disposal – Sewage

Water Source and Treatment DOE accepts the City’s plan as presented. Only real concern is the proximity of the new plateau sub-division to the City’s potable water source. This is a health issue, therefore outside of DOE’s regulatory jurisdiction. It is assumed that Health officials have examined this.

Waste Disposal – Solid Waste DOE will comment on the following aspects: I.Hazardous waste management. II.Runoff/Leachate Monitoring. III.Expansion of current site. IV.Long-term solid waste. management plan. V.Lower Base Contamination VI.Abandonment and Restoration VII.Spill/Emergency Response Plans

Hazardous Waste Management City has made many improvements to their domestic hazardous waste management plan as compared with 10 years ago. City appears to be exercising more control over what enters the landfill*. City will be required to register with DOE as a HW storage facility if they intend to store HW for > 180 days.

Runoff/Leachate Control Leachate may contain substances which can have a detrimental effect on the sewage lagoon. Leachate from the landfill must be collected, contained and treated in an appropriate manner. A leachate and runoff management plan should be submitted to the NWB for review and approval.

Expansion of Existing West 40 Site Current site is approaching capacity. City proposes to expand to a pre-prepared site adjacent to the current site. Proposed site is underlain by a military dump. Limited characterization of this site (“Site 3”) was undertaken in Land ownership undetermined.

Expansion of Existing West 40 Site City would like to use 1995 study results as their baseline study did not include all possible parameters of concern. City should, for their own protection, attempt to characterize this site in greater detail.

Expansion of Existing West 40 Site The terms and conditions of the Water License should include a requirement for leachate and runoff control and treatment for the proposed expanded West 40 landfill.

Long-Term Solid Waste Management Plan DOE recommends that the City of Iqaluit be required to provide a long- term, detailed solid waste management plan for review and approval within four years of the issuance/renewal of their Water Licence.

Lower Base Contamination Anecdotal and physical evidence suggest that Lower Base is underlain by hydrocarbon- contaminated soil, the full extent of which is unknown. First documented in 1990.

Lower Base Contamination Contamination of Lower Base became a public issue in July 2005 with the excavation of trenches for water/sewer lines. DOE believes that this issue is relevant to the Water License.

Lower Base Contamination Environmental Engineering tenet: If you are digging a trench and you find evidence of contamination, the first thing to do is stop digging.

Lower Base Contamination City can not and should not be held responsible for historic contamination, nevertheless: The City of Iqaluit should develop and implement a management plan for contaminated soil and water if they intend to excavate in areas that are suspected to be, or confirmed, contaminated.

Abandonment and Restoration Plans Under “A&R” Plans, City of Iqaluit submitted a 1995 report: Environmental Study of a Military Installation and Six Waste Disposal Sites at Iqaluit, NWT. DOE suggests the City put more effort into developing A&R Plans.

Abandonment and Restoration Plans The City should be required to submit up to date Abandonment and Restoration Plans for those facilities over which they have control; which were, or are, part of their day to day operations; and which have already or are intended to be decommissioned. A&R plans for these facilities should be submitted within four years of the issuance/renewal of the Water Licence or within a time frame acceptable to the NWB.

Spill/Emergency Response

DOE finds the spill contingency plans to be, for the most part, complete and acceptable. Minor suggestions have been made for improvements. The City of Iqaluit should be fully prepared to manage the hazardous materials under their control; including during emergency situations.

Waste Disposal - Sewage DOE has posed a number of questions and offered comments pertaining to the new Waste Water Treatment Plant. The City is advised to address these questions and to take the comments into consideration.

Waste Disposal – Sludge Management City should re-review estimated quantities of bio-solids production using conservative figures for sludge management plan. Evaluation ratings for screened technologies appears to be skewed in favour of air drying. City should explain how they arrived at their ratings.

Waste Disposal – Sludge Management City is advised to review other options such as “trench composting” in an enclosed building. DOE strongly recommends that the City determine with reasonable exactitude, how much land they will require for drying beds, vs. how much land is available.

Waste Disposal – Sludge Management Appendix A of the Sludge Disposal Plan references a similar installation in Sweden. Temperature graph for Swedish city = 7 months above freezing. Iqaluit experiences 4 months of above- freezing temperatures. Has the City determined how Iqaluit conditions will impact this technology?

Waste Disposal – Sewage Lagoon The City of Iqaluit should be required to draft a plan, for review and approval, to manage the existing lagoon, including, but not restricted to: –Measures to be taken in the event of an accidental release (Contingency measures). –Plan for repairs/upgrades to the lagoon (as identified in the various lagoon reports). –Abandonment and decommissioning plan, including provisions on how to manage lagoon sludge.

Summary DOE does not have any “show stopper” concerns with this application. Major concern relates to the paucity of information pertaining to the short and long term management of the current sewage lagoon. City’s proposed sewage treatment system appears to be sound, proven technology.

Summary City should develop A&R plans for those facilities which are under their control/management and which are intended to be closed in the near future. Long-term solid waste management plan. Lower Base Soil & Water Management Plan.

Summary City of Iqaluit is facing problems unlike those faced by any other City in Canada: –historic contaminated sites –aging infrastructure –population boom (2 x since 1991)* –High turnover of engineering staff

Summary Despite these hurdles, the City has progressed in many areas. Room for improvement, however City is to be commended for their continuing efforts. DOE is willing to provide assistance when and where possible.

DOE Priorities Leachate and Runoff Monitoring Plan – June 2006 Leachate and Runoff Control Implementation – Upon commissioning of the new (old) site. Management Plan for Contaminated Soils – June 2006 Lagoon Plan – Within 1 year of issuance of licence Long-Term SWM plan – within 4 years after the issuance of the licence. Abandonment and Restoration Plans – within 4 years of the issuance of the licence or at a time mutually agreed upon by the NWB, the City and other interested parties.