P.O. Box 121, Rockwood ON N0B 2K0 Summary of of Issu sues “Hidden Quarry” Application Guelph-Eramosa sa Township For Halton on Region on Planning and Public Works Com ommittee 20 April 2015 Introduct ction on CRC Rockwood Inc. (CRC) is a not-for-profit organization representing the interests of residents of Guelph-Eramosa Township (GET), Halton Hills and Milton with regard to the proposed “Hidden Quarry”. Since the applications for rezoning of the proposed quarry site from Agricultural-Hazard to Industrial- Extractive, and for a Class A Category 2 license under the ARA for extraction below the water table, CRC has actively engaged GET, Halton Hills, Halton Region, Milton, GRCA, and the Provincial Ministries in regard to our concerns about the impact of the proposed quarry. CRC has met previously with planning staff from the Town of Milton and Halton Region to discuss our shared concerns. This paper summarizes the issues that CRC has raised as the application is assessed under the Planning Act and ARA, and accompanies the brief presentation made by CRC to the Halton Region Planning and Public Works Committee on 20 April 2015. CRC has submitted information to GET and other stakeholders providing details of its concerns related to hydrogeology, blasting, haul routes, economic impacts, natural and aquatic habitat, air quality, cultural heritage, and visual impact. As well, CRC has raised concerns about the possibility that approval of the Hidden Quarry will provide an opening for the development of additional quarries in the area. What follows is a summary of the concerns that pertain to issues of most significance to Halton Region. Hydrogeol olog ogy i CRC has retained the services of Hunter and Associates, Environmental and Engineering Consultants (Hunter), to peer review the proponent’s application documents regarding hydrogeology. The summary report (April 2015) describes a number of outstanding issues: 1. Hunter disputes groundwater modelling results submitted by the applicant and the predicted water table drawdown estimates, as well as the allowance for seasonal variability of flow. 2. The applicant has not considered how the Phase 1 extraction area will be dewatered and the requirement to lower the water table to provide for dry staging of subsequent blasting operations. 3. The applicant has deficient groundwater level monitoring and overburden water level monitoring. 4. Hunter asserts the need for private well replacement and the absence of a contingency plan in the event of adjacent springs drying up due to quarry operations. 5. Hunter asserts the need for additional monitoring wells on the quarry site. 6. It is noted that applicant’s site plans in application documents are not consistent. _________________________________________________________________________________________________________________________ facebook: hidden quarry website: hiddenquarry.ca twitter: crcrockwood e-mail: crchiddenquarry@gmail.com
Bl Blasting ii CRC Director William Hill, a mining engineer with 60 years of international mining experience, reviewed blasting impact analysis reports submitted by the proponent, and a review carried out by the proponent of those reports by its consultant Golder Associates. The latter report is identified as a “peer review”, but CRC disputes this designation as the subject reports and the review report were carried out by the proponent’s hired consultants according to terms of reference set by the proponent. Regarding substantive issues, the Hill report raises issues pertaining to the geology and karst weathering of rock on the quarry site, the risks of fly-rock ejection from the site largely due to the unique characteristics of the karstic formation, various drilling and blasting considerations, blasting patterns and powder factor considerations, and the transmission of shockwaves and ground vibrations. Of note are the following points: 1. The proponent asserts the absence of karst geology on this site based on one bore- hole examination that failed to detect large-scale karst weathering; the Ontario Geological Survey maps show either potential or observed karst in a large area to the east of Guelph encompassing the quarry site, and direct observations of sink holes and a disappearing stream on the site as well as evident karst immediately to the south of the site suggest the contrary. 2. The proponent acknowledges the possible ejection of fly-rock in the Blasting Impact Assessment (“Orientation of the aggregate operation will be designed and maintained so that the direction of the overpressure propagation and fly rock from the face will be away from structures as much as possible.”), apparently in the belief that the direction of fly-rock ejection can be controlled. Nothing else provided by the proponent addresses this risk to the adjacent stretch of Highway 7 and the numerous buildings and residences that are within range. 3. The Hill Report questions the proponent’s conclusions that blasting with the indicated quantities of explosives per charge will keep vibration levels within permissible limits. 4. The Hill Report notes that the quantity of explosives used per tonne of rock extracted (powder factor) is significantly higher than typically used in similar mining operations, leading to greater risk of blowouts and fly rock. 5. The proponent’s reports do not acknowledge that 80% of blasting operations will be carried out at distances closer to sensitive receptors for vibration than the distance used to calculate acceptable vibration levels, with the result that vibration at these receptors will exceed permissible levels in most blasting operations. 6. The Hill Report also questions the proponent’s conclusion that a “causeway” carrying the Brydson Creek through the middle of the quarry site will be able to withstand the effects of blasting in the two extraction areas between which it passes. The Brydson Creek passes under Highway 7 and empties into the Blue Springs Creek. 2
Haul Route iii The proponent submitted four iterations of a Traffic Impact Study (TIS), and at the request of Halton Hills, Milton and Halton Region, a Haul Route Study (HRS), all carried out by Cole Engineering. The TIS received comments from MTO and R. J. Burnside & Associates on behalf of Guelph-Eramosa Township. CRC’s review of the HRS has raised a number of issues: 1. As noted by Burnside in response to the TIS, and again by CRC in review of the HRS, the proponent underestimates the number of truck trips by basing the estimate on an average 33 tonne load, roughly the capacity of tractor trailers. Furthermore, while providing time, day-of-week, and seasonal distribution of load transportation data, the use of “average” values creates the impression that truck traffic will be much lower than will actually be the case. Without attempting to cor orrect for the average loa oad size question on, CRC’s estimate of truck trips per hour in the period May through September, 0600 to 1500 hr. ranges from a low of 15 to a high of 32 trips/hr. and an average of 24 truck trips per hour or one every 2 ½ minutes. 2. The proponent uses as a “proxy” its Erin Pit for projecting truck trip frequency without providing any justification. 3. While the TIS indicates that 5% of truck traffic will be northbound and 95% eastbound, the HRS gives a different breakdown as shown below: Haul Route Distribution 4. The question of queuing of trucks for entry to the quarry site is addressed by the proponent’s HRS as follows: “The site plans indicate that the gates will be positioned to allow enough room for a full truck/trailer to pull off the 6th line.” In addition to providing space for one truck on site, the proponent offers assurances that truck arrival to the area before the 6 am start of operations will not be permitted. CRC’s view is that queuing of trucks along Highway 7 and 6 th Line will be a problem, as it most certainly is at other quarries such as those in Milton. 5. The proposed haul routes will put considerable stress on Acton’s Main Street including Highway 7 east towards Georgetown, as well as on RR 25 northbound and southbound from Highway 7. 6. CRC recognizes that the 5 th and 6 th Lines Nassagaweya offer access to RR 25 southbound without the need to pass through Acton. These lines are load limited but enforcement can be expected to be an issue. 3
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