Non-Compliance Highlights

With numerous enforcement order amendments and information spanning as far back as 2011, it can be difficult to sift through some of the analytical documentation. Below is a snippet of some of the more concerning issues brought forward by inspectors and consultants.

Most recent major enforcement order (Amendment #9)

  • Material on site was estimated at 73,507.85m3 (51,455.50tonnes) despite there being a maximum of 20,000 tonnes of material permitted.
  • Composting piles are seen as high as 13.4 meters in some places, despite there being a maximum allowable pile height of 4.3m.
  • Stockpiles of compost extend beyond the limit of the perimeter berm in the southern, north-western, and north-eastern limits of the facility, seen as far as 20m past the perimeter berm.
  • The liquid level of the detention pond (used for storing liquid wastes that are accepted) is approximately 3.6m above the design level of the pond.
  • Perimeter berm is no longer visible at the facility. Cleanit Greenit states ‘the road acts as on on-site berm’.
  • AEP requests that Cleanit Greenit notify all impacted landowners that Cleanit Greenit’s materials have crossed the property boundary.
  • AEP consistently requests documentation and photographs which are not submitted by Cleanit Greenit (noted numerous times).
  • As of 2019, Cleanit Greenit submitted the following response of materials and liquids that are accepted: latex paint, biosolids, septic waste, sump, kitchen greases, hydro vac solids, sludge, hydro vac liquid, fertilizer, grease trap, catch basin, wash bay sump, chicken sump, milk waste, car wash, and sewage contaminated water.
  • October 2020: AEP Senior Waste Policy Advisor concluded that CIGI is likely accepting a number of wastes that are not organic material and have no biological/microbial benefit for use in a composting process, including: gypsum wallboard (drywall), hydrovac waste, greywater from cleaning services, municipalities, car wash bays, car service shops, and used activated carbon. The AEP Senior Waste Policy Advisor is of the belief that the practice by Cleanit Greenit to circulate the fluids from the Surface Water Storage Pond and leachate water back onto the composting piles is one of the root causes of offensive odours, and the presence of hydrocarbons, chlorides, and other contaminants in their finished compost.
  • Samples taken by the Canadian Food Inspection Agency that were supplied to AEP show: samples were not compliant with CFIA guidelines, specifically for Ni, Pb, Co, Ni, and Zn. Total Dioxins and furans concentration were more than 400-600X the tier 1 guidelines.
  • An AEP Contaminant Hydrogeologist was brought in to analyse the impact of operations on groundwater and surface contamination. AEPs review concluded that the integrity of Cleanit Greenit’s clay liner could not be confirmed, and that well seals in some wells may be ineffective. Cleanit Greenit’s operations are affecting the shallow groundwater and surface contamination may be entering the subsurface and the groundwater through precipitation and runoff.
  • AEP deployed is Mobile Air Monitoring Unit and Canister samples to measure air quality and found: three exceedances of the HS2 1-hr Alberta Ambient Air Quality Objectives (AAAQO), HS2 and NH3 concentrations were above their corresponding odour thresholds most of the time near the fenceline, and 8 Canister samples targeted up to 121 VOCs and 12 RSCs. HS2 was above its odour threshold and PAH, PM2.5, and CH4 concentrations.
  • AEP is concerned that because the Surface Water Storage Pond does not meet requirements, that it would overfill in a 24 hour duration storm event.
  • An AEP Reclamation Policy Specialist indicated that “The Cleanit Greenit facility should be reclassified as a waste treatment facility, rather than a Class I composting operation, based on the potentially hazardous wastes Cleanit Greenit accepts.” As well as “Hazardous wastes are not acceptable wastes for a composting facility because these materials potentially contain hazardous, long-chained hydrocarbons that are not easily degraded, and chemicals not commonly found in compost.”
  • Cleanit Greenit states they ceased accepting liquid wastes is contrary to their October 2020 Incoming and Outgoing materials report which states they accepted 1.2 tonnes of liquid waste in 2020.

October 2020 Inspection

  • Capacity exceedances and feedstock acceptance issues. Aeration system operational problems, odour complaints, and run-off management issues.
  • Issues with liner/composting pad. CIGI site subsurface is capable of transmitting potentially contaminated liquids downwards.
  • Inadequate run-off control.
  • CIGI site configuration may permit off-site release of leachate and/or surface run-off and based on CIGIs annual surface water analysis results some limits would be exceeded.
  • CIGI annual report notes chloride levels in groundwater monitoring wells continue to be elevated and exhibit an upward trend. CIGI has yet to implement a remediation plan despite these exceedances.
  • Unreported contraventions regarding the non-compliant site run-off management system.
  • Monthly report have been consistently submitted later than the specified deadline.
  • During the inspection it was noted that the aeration system was not connected properly and therefore not aerating the piles properly. As well as 2/4 generators were not in operating mode during the time of the visit.
  • Inspectors noted that the current aeration process did not make sense (forced aeration is run 15 minutes every AM/PM during the weekdays and not on weekends. CIGI site manager said that they do not run aeration once it is under -10 celsius). The oxygen probe was broken for the second time so CIGI is unable to track anaerobic conditions.
  • The 2019 CIGI annual report was reviewed for compliance and was deficient in sections requiring them to report non compliance issues and a summary of complaints received and actions taken.
  • The AEP Directory is of the opinion that the operation of the facility may be causing adverse effects on the environment, including but not limited to air and groundwater, and that steps must be taken to both assess potential impacts and address all those that may have occurred.

The order then goes on to describe at length the requirements imposed on CIGI related to Odours, Air Quality, and Groundwater quality moving forward with due dates for all. Some of these dates have already been amended with extensions in Amendment #10 of the enforcement order.