Randle Reef Cap
or dredge? What to do with the infamous toxic hot spot
The Hamilton Spectator
Randle Reef is in the way, always has been. The highly toxic
reef, located just off Stelco's boat dock, stands as not
just a natural barrier to shipping, but as a toxic barrier
to a clean harbour. And it stands as a symbolic barrier
to the ultimate success of the Remedial Action Plan (RAP).
The reef is like an open sore. Often called a spill in slow
motion, it is constantly leaking toxic polycyclic aromatic
hydrocarbons (PAHs) into the water, a constant reminder
of RAP's failure to tackle one of its biggest problems.
"This is the motherlode of PAHs in the harbour," says John
Shaw, Burlington-based manager of Environment Canada's Great
Lakes Sustainability Fund.
The contamination is spread around the reef in what he calls
a "marble cheese" pattern that causes huge headaches for
any cleanup. The size of the problem seems to get worse
the more it is studied.
After a decade of false starts, there is again hope the
reef may soon be cleaned up, opening the way for a run to
the finish line that could see RAP goals achieved by 2015.
But it's been this close before only for things to fall
Why it is still not solved is a complicated story that reveals
a great deal about RAP, and its strengths and its weaknesses.
RAP's consensus decision-making-process -- in this case
involving Stelco, Environment Canada, Ontario's environment
ministry and Hamilton Port Authority -- has been unwieldy.
The technical hurdles have been high. Governments have tried
to fund it on the cheap, often making the search one for
a bargain plan, not the best plan.
Stelco, obliged to be part of the solution, has often disappointed
in what it is willing to contribute.
The plan that is poised to bust that log-jam is a major
break with past attempts. It's a plan that is straining
RAP's long-standing reliance on consensus decision-making.
It calls for the contaminated sediments to be buried in
the harbour, instead of being removed.
The $25-million plan is to build a wall around the site,
cover the hot spots with other contaminated material and
top it up with clean fill. A new seven-hectare island or
peninsula will be created.
The infilling creates a chance that contaminated sediments
from other harbour hot spots can be cleaned far faster than
thought possible. It avoids the significant problem and
cost of dealing with the toxic material that is brought
up from the bottom. Previous plans have foundered on that
And it means the city has a place for sediments from the
dredging of Windermere Basin. That will save city taxpayers
"It can be done at a third of the cost of a whole-harbour
cleanup using removal, and in a time frame that we think
would be significantly compressed. Those were the overriding
advantages," Shaw said.
As Stelco's environment manager Andrew Sebestyn said: "The
tag that came up is it's a whole-harbour solution."
It is an ideal solution in so many ways.
"Eyes started to open when people saw the advantages of
it," said Shaw.
But some of those eyes opened wide in surprise and dismay.
Filling in the harbour is a solution that harks back to
the city's past in a way that isn't always comfortable.
It's an echo of a more exploitative relationship with the
harbour that many had hoped Hamilton had left behind: Take
what you can from it and damn the consequences, a convenient
out when confronted with pollution.
Many inlets that dotted the southeast shore were filled
in to cover over sewage and industrial pollution that had
become too acute. Today, a quarter of the harbour is filled
"I don't think we need to fill in the harbour any more,"
says Mark Sproule-Jones, a McMaster University professor
of urban studies who has been involved with RAP since its
"We're always filling in bits and pieces and saying, 'Oh
it's just a small bit, it's just a small bit more.'
"We just can't go on removing bits and precluding the possibility
of restoring the ecosystems. It's a principle thing rather
than an economic analysis."
A former member of the Public Advisory Group searching for
a solution to Randle Reef, he has since resigned from the
group in frustration. He and activist Lynda Lukasik are
challenging the containment plan to the federal and provincial
environment ministers. If the plan goes ahead, it will do
so over the principled objections of two of the city's most
committed and respected environmentalists.
Randle Reef is named after Captain Harvey T. Randle, a long-serving
harbour pilot. The pilots took control of the large ships
coming into the harbour and guided them safely to dock.
The reef is named after Randle because he once ran a ship
aground on it. His fellow pilots never let him forget it
and the name, originally attached in jest, stuck.
The area is contaminated with deposits of coal tar, a dark,
gooey remnant of coking operations, full of polycyclic aromatic
hydrocarbons, or PAHs. Nasty stuff, they are known carcinogens,
toxic to humans and aquatic life. Randle Reef contains concentrations
of PAHs of more than 800 parts per million, sometimes in
the thousands. There is no life of any kind near the reef.
Prior to this, the closest RAP came to a cleanup was in
the late 1990s when the provincial environment ministry,
Environment Canada and Stelco worked out a $8.5-million
plan that would have the sediments used as a fuel in Stelco's
sintering plant. It saved on trucking and disposal costs,
but that plan fell apart under resistance from Stelco workers.
They worried about dioxins being released through the burning.
While it may seem like a slow process of finding a solution,
it actually isn't, some say. Shaw says a project as complex
as this can't be rushed.
"You can call this a slow project but that is typical. There
is an awful lot of uncertainty when you get into sediment
remediation. To my mind that is the problem in making these
He said Hamilton is not out of line with other Great Lakes
areas trying to clean up similar areas.
The initial years were spent trying to determine where the
deposits were, how high the levels were and what areas needed
to be dealt with. "I think it's taken a long time because
there has been a lot of work that has had to go into defining
just how much needs to be dealt with," said RAP co-ordinator
That marble cheese pattern meant only the worst areas could
be dredged and any removal plan had to accept that significant
deposits would still be left behind. There was always the
question of what to do with the material once removed. And
stirring up the contaminants during dredging was also a
The containment plan now being welcomed is actually an old
one, rejected a decade ago as not in keeping with the direction
and philosophy of the cleanup.
In the 1980s, when it was suggested the sewage problem be
solved by moving the outlet pipes from the bay to Lake Ontario,
RAP activists such as Gil Simmons said no. The point, they
said, was to solve the problem, not move it.
For those such as Sproule-Jones, this plan has the taint
of taking the easy way out.
But time and lack of progress have changed that view for
most of those involved.
What is different now?
Shaw says one of the reasons containment is now more acceptable
is the changing understanding of how much material needs
to be dredged.
In the late 1990s the estimate was that 20,000 cubic metres
of sediment would need to be removed. Those estimates are
now 35,000. And no one can be certain how final that number
is. Every cubic metre of material adds removal, treatment
and disposal costs.
That kind of uncertainty makes it hard to get the different
agencies to sign on to a plan.
"You are looking at trying to estimate what is there, it's
the margin of error, it's the partnerships, multipartnered
projects (that) take a lot of time to resolve," Shaw said.
"You are trying to satisfy the various agencies' interests
and objectives, trying to raise the funds; then you are
going to a public process, you are building consensus. It
just takes time."
Then there is cost. The estimate for tackling the harbour's
three most toxic hot spots is about $90 million.
And what of Stelco?
Stelco has always played a curious role in the Randle Reef
discussions. Stelco is always part of them, always seems
to have a say in what proposals go forward. That involvement
always implies a degree of responsibility for the contamination
that is there.
But no one ever suggests it is directly responsible. Usually
unwilling to put up money, sometimes willing to make "in-kind
contributions" such as burning the sediment in its sintering
plant -- Stelco has always had a virtual veto over what
gets done there.
This plan is going forward with no clear obligation on it
to do anything and no clear commitment.
Sebestyn couldn't say what Stelco would end up contributing.
"Right now I can't comment any further other than we are
involved in the process and eventually it will get down
to where the details are available, what the cost is going
The problem with holding the steel company more directly
accountable is the contaminants can't be clearly tied to
Historically, there were other coking operations that drained
to that area.
And in the 1980s, the MOE signed off on a cleanup of a spill
by Stelco that suggested it had cleaned up what it was responsible
"Common sense would suggest it could only have come from
them," says Sproule-Jones, admitting common sense has no
legal strength in this case.
No one wants to push the point. RAP has always tried to
walk a line between the concept that each agency is responsible
for the pollution it creates, and not playing a public blame
"Stakeholders sit down and define what should be done and
we do that pretty well," said Hall. "The RAP is not in the
business on a day-to-day basis of trying to police activities.
What we're in the business of trying to do is, where it
has been identified that remedial actions need to be carried
out, then we try to put together the appropriate team to
get on with those.
"I don't think it would work very well for us if we didn't
have that distinction."
Hall says he senses a real desire to get the job done now,
even from Stelco.
Shaw says it's just too early to talk about specific contributions
from any agency. That time will come once more detailed
engineering plans are completed.
He speaks well of Stelco's contribution to this process.
His expectation, however, is that Stelco will commit something;
probably in-kind work such as the sheet steel piling for
containing the area.
"All the agencies are really on hold, including ourselves,
in terms of how much dollars, how much resources do we need
for the project and who are the potential partners, whether
it is financial or in-kind."
He said there may be opportunities for bringing in additional
Sproule-Jones, a RAP original, has abandoned the RAP process
when it comes to the reef. He's in the minority, but he
believes Randle Reef is a case where the process, so successful
in other ways, has not worked.
"The devil is in the details. Where you could get the agencies
to work together and pool resources and get things going,
it worked really well.
"Where it hasn't is where you need a lot of money and where
you have a strategy that has given various stakeholders
a veto over what is going to happen."
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