Reach for Unbleached! Foundation
This report contains an e-copy of Reach for Unbleached! Foundation’s (RFU!) Sludge files. The documents contained are for internal research purposes and publication requires redaction of personal or sensitive information.
RFU! has observed and recorded waste management practices at Canadian pulp and paper mills for three decades. The industry was seeking disposal options and were considering all options: as feed for farm animals, as energy from incineration, and as a compost to amend the soils on farm and forest land.
Previously, industry wastes were disposed into public water sources, but environmental contamination provoked new regulations. Canadian mills were required to significantly reduce the disposal of chlorinated organic compounds. BC’s Zero AOX effluent regulation would force process changes to bleached kraft mills, requiring secondary wastewater treatment systems by a December 2002 deadline.
The industry now had a problem with an increased generation of sludge and fly-ash, both of which are highly concentrated with residual organic compounds, dioxins, and heavy metals. Public and private landfills are expensive and represented a regulatory nuisance for industry. Canadian pulp and paper mills urgently required an inexpensive method of disposal.
In 1988, the Natural Resources Defense Council (NRDC) of Maine was part of a multi-stakeholder committee alongside representatives from government, industry, and the environmental sector. The task was to examine International Paper’s (IP) request to land-apply process waste from its kraft mills. The NRDC initially required some baseline testing for the waste material, but IP was never able to provide acceptable results.
Waste sludges, or “pulp and paper mill fibre wastes” (PFW) had been considered for a feed additive for farm animals since the 1950s. Although there is very little data available to the public, the Sludge Files record the millworkers’ efforts to alert the public and work for precaution. By 1988, Agriculture Canada researchers (Croy & Rode 1988) began quietly conducting research to see if they could feed sludge to cattle. Their study, Nutrtive value of pulp mill fiber waste for ruminants, was published in the Canadian Journal of Animal Sciences. To aid this research, the managers at ten BC pulp mills provided Agriculture Canada researchers with samples of their PFW for mineral analysis. IP in Prince George provided the information on pulp production practices. The sludge samples of these mills were reported to have high variability in chemical and mineral content, particularly high levels of Cadmium (Cd) in three of the mills and “extremely high levels of aluminum (Al)” from four mills. (Table 2, Mineral analysis of pulp fibre waste from 10 mills in BC, p. 466). Fifty percent (five) of these mills produced a sludge of suitable mineral content and digestibility for use as animal feed, but researchers found that sludge composition variability meant that each mill’s PFW would have to be analyzed for known toxins before commercial use (p. 469).
In British Columbia, University of BC (UBC) researchers funded by the BC Science Council studied the toxicity and mutagenicity of PFW in a long-term, ruminant-feeding trial. The PFW was supplied by mill managers in both Prince George (Canfor) and Kamloops (Weyerhaeuser). The resulting study, Chemical characterization and toxicological assessment of kraft pulp mill fibre waste as a feed stuff for beef cattle, found that “potentially toxic chemical compounds are present in PFW,” however, no chlorinated phenols were detected in the livers of biopsied experimental beef cattle. The findings, while contrary to previous studies, “raise questions about biological significance of beef animals exposed to this contaminated feed” and suggest that further studies are needed to determine whether contaminants can be accumulated in beef- and dairy-consuming humans (Bilawchuk, Kitts & Owen 1989).
Bilawchuk published a Master’s thesis and evaluation of the research. The research cautioned that “the presence of potentially mutagenic and toxic compounds identified in the PFWs prohibits its use as a feedstuff. Until these chemical contaminants are eliminated, or until the biological significance of such compounds is determined, the use of PFW as a cattle feed cannot be recommended” (p. 4).
In 1990, The Edmonton Journal reported on the UBC and Agriculture Canada research into PFW as cheaper cattle feed. An interview with Bruce Owen, a professor of animal science, and Priya Mir, Agriculture Canada in Kamloops, explained the four-year study (1986–1990). They found that feed silage can be produced from waste pulp sludge instead of hay, providing cows a source of glucose energy and aiding in grain digestion. While the cows did not gain as much weight (palatability was an issue), the farmer’s cost-benefit analysis determined that the savings by using PFW as an alternative feed outweighed the cost of their cattle’s weight loss. The researchers suggested the possibility of siting cattle feedlots next to pulp mills. Owen and Mir stopped the animal feed trials when they realized the pulp fibre sludge contained toxins.
On the international front, Greenpeace was campaigning to end chlorine bleach processes in pulp mills. The Pulp and Paper Workers of Canada (PPWC) pressured the Canadian government to regulate out the chlorine completely and make the mills substitute with ozone, peroxide, and oxygen. The industry’s efforts, however, were to instead reduce dioxin and furan releases by switching to chlorine dioxide, instead of using chlorine, to bleach paper. Chlorine dioxide reduces dioxins released to the environment, but was later found to expose workers to permanent lung damage. A news article in The Vancouver Sun reports on the views of the medical community, how they “did not used to think these gassing incidents caused lasting damage. We thought recovery was complete” (Priest, 1989).
BC mills are required to comply with the Zero AOX law of 1992, requiring them to reduce by half the release of thousands of tons of organochlorines currently dumped into rivers and oceans by 2002. Secondary treatment systems were implemented, but contaminants of concern (COC) remained and are concentrated in the waste sludge, lime grit, and fly-ash. A cost-effective and safe disposal solution was urgently required.
The BC Ministry of Environment (MOE) allows for the limited land application of pulp and paper mill sludges, grate ash, and green liquor dregs under an individual mill permitting process (RFU! Foundation. (1997, Nov 24). Table: BC approvals/refusals for the land application of mill sludges. Millwatch).
The Elk Falls mill in Campbell River was producing 600 cubic meters of fly-ash and 50 cubic meters of recausticizing lime wastes per day. Treatment plant sludge was burned in the power boilers, but 200+ cubic metres of fly-ash went to landfill every day. In 1994, the UBC Department of Agriculture analyzed the sludge and reported on its nitrogen, potassium, and phosphorous content in the fly-ash. The dioxins levels were recorded at a composting plant between Campbell River and Courtenay and found to be too high for use in agriculture. But dioxin levels were not so high to prohibit its use in horticulture. So, the Elk Falls mill began experimenting by composting wastes on-site and distributing it without cost to locals. Several sod farmers and Christmas tree farms near Courtenay accepted the product. By 1997, environmental groups were identifying contaminants of concern (COCs) and, by 1998, this disposal method of transforming mill wastes into an agricultural product was shelved. Still, the mills’ management declared future plans to spread its waste on four other sites near Campbell River, including a plan to “reclaim” an abandoned mine near Mt. Washington that was leaching acid and killing the Tsolum River fish (Easton 1999; Hackett 1999; Hackett et al. 1998).
On March 29, Environment Canada and Industry Canada hosted a workshop on combustion of pulp and paper sludges to discuss the critical issue of sludge disposal. Topics for discussion included emerging technologies, current research, and opportunities and concerns with paper mill sludge combustion. The handout package from the seminar included information on sludge characteristics and ash mineral composition, Elk Falls waste sludge burning project findings, pollution control system design, future research and design needs, chlorinated sludges, and dioxin and furan removal.
In January, PGL Organix Ltd. (PGL), a “residual management consultant” for Celgar Pulp Company, released its findings in Beneficial reuse pilot trials – land revegetation and landscape soil production. The “residuals” and fly-ash were combined and tested. The results showed “low concentrations of regulated compounds with the exception of cadmium.” This meant that it could not be used in food production; however, if mixed with sand, the consultant believed it was suitable to distribute as a landscape soil product (p. 2).
By March, mill workers had discovered that waste sludges were being quietly removed from on-site locations at different mills in BC. Upon further investigation, they learned that industry management, along with UBC researchers, had been granted MOE approvals for sludge testing and Ministry of Agriculture approvals to experiment with alternative feeds for cattle.
PGL was contracted by Macmillan Bloedel (MB) Paper Ltd. to provide BC’s MOE with a report on the 1996 field trials with grate ash and waste (from the Sludge Files, MB Paper Ltd., Beneficial reuse pilot trials, 1996 operating plan, PR-14337).
The worker’s union notified the BC Cattlemen’s Association (BCCA) (F. Henton, by fax, March 21, 1996) and the public of their concerns by way of a press release from the Occupational, Health and Safety Office. The BCCA is “both surprised and disturbed” with the exposure. They explained that they had since learned that the experimental heifers were intended for breeding only, and any bio-accumulative contaminants were unlikely to affect the food chain “for at least 10 years”. The BCCA informed the PPWC, Weyerhaeuser and the Ministry of Agriculture, Fisheries and Food that they would do everything they can to stop farmers and government from encouraging the use of “PFW” “as a feed source until such time as extensive research proves…that the health and safety of the consuming public will in no way be compromised” (J. Morrison, by fax, April 3, 1996).
The PPWC informed the MOE of its position that pulp mill sludge “should not be used for agricultural land distribution, additives for cattle food, private or commercial market gardens, or landfill makeup where streams and waterways are directly adjacent to the dumping of this material.” It also informed that “no substantial testing has been carried out. Apart from the known facts that this substance contains heavy metals, chlorine dioxide, bleaching residue, chlorate, residual chemical contaminants, and a real concern for dioxins and furans” (F. Henton, by fax). Weyerhaeuser Canada immediately announced it would discontinue plans to use PFW to feed Kamloops cattle and the PPWC claimed that sludge “poses a long-term health threat to humans” (Rowlands, 1996, Mar 25). The PPWC maintained its position in their Constitution (1999, p. 17) to the present date, that “the waste poses a long-term threat to humans.”
The PPWC emphasized that sludge and fly-ash chemical analysis is critical and informed on its intention to collect and independently sample the PFW for toxins. Its primary focus was to ensure worker safety and “proper scientific data is crucial” (F. Henton, personal communication, April 6, 1996). The PPWC supplied RFU! the lab results from their power boiler ash with hope that they could be interpreted.
Zellstoff Celgar Pulp mill near Castlegar, BC, spread 80 tons of kraft clarifier sludge within 170 feet of a private well. Residents from the rural neighbourhood near Krestova were disturbed to find the BC MOE, which had approved a permit for the sludge use, subsequently suggested their well-water be tested to for safety. The water was tested on May 20, 1997, but the MOE withheld the results from the residents for several months, increasing their distress and inconvenience. To add further insult, the sludge-accepting land owner for a proposed Christmas tree farm never grew any trees and subsequently sold the land (March 1998). The next owners built their residence and drilled two wells over the sludge site (H. Voght, personal communication, October 14, 1998). This incident made obvious the need to inform future property owners of sludge application with a note attached to the land title. If waste application is beneficial, it stands to reason that it should increase the property value (H. Vogt, personal communication, March 24, 1998 and August 12, 1998, p.3); C. Jmio, by fax to the committee members and MOE, August 15, 18, 23, 1997. Finally, in September, BC’s MOE released lab results for the well water safety. Laboratory results for Krestova wells from 1996 and 1997.
Other known land-spreading sites included a Christmas tree farm where 100 tonnes of Celgar sludge was disposed, and the Cominco mine where 500 tonnes was disposed. A further several tonnes of sludge was being used as composting windrows, prepared on-site on the foreshore of the Columbia River (F. Henton, by fax, April 4, 1996).
Celgar marketed its sludge as compost application for home gardens and public use.
It was not until July 1996, that the Celgar mill would share their data on sludge testing for chlorinated phenols. The sampling for the testing occurred in 1992, when the mill was using 30% ClO2 and again in 1993, when the mill increased to 100% ClO2. The Celgar mill also released its quarterly (94-95) chemical analysis of final effluent, EEM (Environmental Effects Monitoring) cycle one.
RFU! does some chemical testing on BC mill sludges. (retrieved from the Sludge Files).
The BC MOE’s Industrial Waste and Hazardous Materials Branch invited key stakeholders to participate in an advisory committee on pulp mill sludge disposal. The PPWC agreed to participate and proposed to pay for all costs for the unbiased, scientific testing and analysis of the toxic components of sludge if the Ministry would agree to collect sludge samples from the Celgar mill. (F. Henton, by fax, August 9, 1996). The MOE agreed to contribute $20,000 in government lab credits for chemical analysis of pulp mill wastes.
By September 1996, as promised, the MOE, under an NDP government, organized the Pulp Mill Sludge Advisory Committee (PMSC) to examine all aspects of pulp mill solid waste, develop stakeholder consensus, to guide the government toward a policy for the responsible management of industrial sludges.
To begin the stakeholder consultation, the committee agreed to flush out the scientific literature that characterized chemical contaminants of pulp mill sludges. Pulp mill sludges include pulp mill primary and secondary effluent treatment sludges, fly-ash, grate ash, and lime dregs.
The Sludge Files bore witness to and documented industry resistance to any independent testing of its waste.
Fifteen reports were tabled by RFU! (D. Broten) from the Sludge Files including:
- Macmillan Bloedel Powell River organic contaminant testing, sludge, grate ash, and green liquor dregs (nd).
- PGL Organix report on MB Powell River sludge (Nov 1995) one scan each on dregs, ash, and primary and secondary sludge, study was not well done, i.e., PAH and dichlorophenol recovery was very low (D. Broten, the Sludge Files).
- PGL Organix report on Celgar sludge (Jan 1996) Beneficial reuse pilot trials-land revegetation and landscape soil production. Prepared by PGL, a “Residual Management” Consultant for Zellstoff Celgar Pulp Co.
- Elk Falls, Campbell River sludge measurements from air emissions testing.
- Quesnel River Pulp Co. sludge disposal permit.
- Alberta Research council sludge utilization project (Nov 1993). This report shows spikes on the mass spectrographs.
- Donnees sur les residus primaires de desencrage, Assn des industries forestieres du Quebec (1996).
- Usable waste products for the farm: An inventory for Maine. (1986).
- (1992). The properties of de-inking sludge, Paperi Ja Puu (Paper and Timber), Finland. 74(2).
- Agricultural utilization of paper mill sludge in the Niagara area – tests to 1989. Thorold de-inking mill.
- Lake Michigan Federation. (1991). Granulation Technologies Ltd. is a health concern. Included results of EOA sampling of sludge from Fort Howard Paper at Green Bay, Wisconsin. Fort Howard is mostly TCF.
- (May 1990). Response of selected pulp and paper industry solid wastes to the RCRA Toxicity Characteristic Leaching Procedure NCASI Technical Bulletin No. 587.
- A few tests from the Thorold, Ontario de-inking plant.
- (1995?). Dioxin and furan in sludge from Maine wastewater treatment plants, including several paper mills.
- Dioxin found in Champion Paper monitoring data, 1995/96 (influent, sludge, effluent, and leachate).
Three reports were tabled by industry (COFI et al.), including:
- O’Connor. (1996). Characterization of pulp & paper mill solid residues: A review. Paprican Miscellaneous Report MR 324. (RFU! published a critique of Paprican report MR 324 which points out the many glaring flaws in statistical method and chemical analysis).
- Reid, I.D. (1996, March). Solid residues generation and management by Canadian pulp and paper mills in 1994. Paprican Miscellaneous Report. MR 326 (Retrieved from the Sludge Files).
- Reid, I.D. (1998). Solid residues generation and management at Canadian pulp and paper mills in 1994 and 1995 national survey. Pulp & Paper Canada, 99(4), 49.
RFU!, PPWC, and West Coast Environmental Law (WCEL) repeatedly demanded that the waste material undergo characterization through testing before handling and release to the environment. Toward this goal, Natural Resource Development Canada (NRDC) staff scientists helped formulate the test requirements. In addition, MOE set aside $20,000 for pulp mill sludge laboratory analytical work for appropriate sampling, testing, analysis, and interpretation of data (soil chemicals, micro-fauna, soil microbes, fungi phthalates, bacteria). Three drafts of the Land Application Guideline would be prepared by the MOE because of the “magnitude and complexity of the comments that were received during the comment review period” (Vogt, memo MOE 1998).
Committee attendees included representatives from:
- Industry – UBC Forest Products Research (Chair), Canadian Council of Forest Industries (COFI), MacMillan Bloedel Limited, and Fibreco Pulp
- Government – BC Ministry of Environment (MOE), Environment Canada (EC)
- Legal – West Coast Environmental Law (WCEL)
- Environment – Reach for Unbleached! Foundation (RFU!)
- Workers Unions – Pulp, Paper & Woodworkers of Canada (PPWC), Communications, Energy & Paperworkers Union of Canada (CEP)
- Concerned Citizens
July 11, in response the MOE’s request of May 1, 1997, Fibreco Pulp provides some pulp mill sludge characterization data from non-COFI mills – Western Pulp (Port Alice) and Fibreco Pulp (Taylor) were the only two non-COFI mills to submit data.
All COFI mills submitted their data only to PGL. There were discussions about the uncertainty of quality and comparability of the data, as well as lack of data, risk assessment, site considerations, exposure routes. COFI is looking and leaning toward municipal waste parameters for allowable concentrations of contaminants (J. Ritchlin, personal communication, September 19, 1997).
PGL Organix Ltd. (March 1995). Prefeasibility assessment waste management options. Report prepared for MB Powell River (from the Sludge Files).
PGL Organix Ltd. (November 1995). Documentation to support an application for a permit under the provisions of the Waste Management Act (Refuse), MB Powell River Division. Report prepared for MB Powell River for submission to the MOE (from the Sludge Files).
RFU! letter to MOE expressed concerns about MB Powell River Pulp Mill’s application to spread pulp mill waste consisting of primary and secondary sludge, grate ash (1996 May 25).
MacMillan Bloedel Limited is granted permit PR-14337 under the Waste Management Act to discharge mill residuals to Powell River land August 21, 1996.
The Powell River/MB Appeal to permit Environmental Appeal Board s.44(1) under the Waste Management Act. In 1997, “beneficial reuse” is an unproven concept. The appeal was upheld substantively because the permit failed to protect the environment because of “insufficient data to support the benign nature of the waste,” “less than adequate testing of the current waste disposal system,” “the design of experimental project is flawed,” and there is “a potential for waste materials to end up in surface water” (D. Broten, Powell River Grate Ash/Lime Dregs Appeal: Substantive Victory; Cameron, Goggins & RFU! v. Regional Waste Manager, from the Sludge Files.
PGL Organix Ltd. Summary Brief Re: Permit PR-14337 Appeal April 1997, prepared for MB Powell River. (from the Sludge Files).
PGL Organix Ltd. report, MB Paper Ltd. Beneficial Reuse Pilot Trials 1996 Operating Plan PR-14337, prepared for BC MOE, Environmental Protection, Waste Management Branch. October 1996. (from the Sludge Files).
Powell River mill applies for an approval (temporary permit) to “experiment” using grate ash as roadbed material and lime dregs as a soil amendment. An environmental appeal is filed by Anne Cameron, Paddy Goggins, and RFU! against the MOE’s decision. RFU! contracts Bitterroot Consultants from Corvallis, Montana to peer-assess the application. Assessment Part 1 and Assessment Part 2.
Although the Appeal is denied, the tribunal substantively upheld in the matter of further testing as requested by RFU! The Powell River mill drops their application for permit rather than do the required testing.
“From an analysis of available data on the chemical composition of sludge, ash, and green liquor residues from pulp and paper mills” (Broten, D. 1997, Nov 25. RFU! Pulp Mill Sludge Draft – see What we know about sludge).
And Paprican’s response (O’Connor, B. 1998, Jan 14. Critique of Broten’s research). Brian O’Connor of Pulp and Paper Research in Canada (Paprican) comments on RFU!’s memo concerning the chemical characterization of pulp and paper mill sludges.
PGL Organix Waste Solutions Inc. was hired to prepare a report on characterization of pulp mill sludges and contaminants present.
The committee presented a list of possible pulp mill sludge contaminants that warrant further investigation. Also at this meeting came a request for a moratorium on land spreading, which was denied until more data became available. There was also a request for maximum possible community notification (J. Ritchlin, personal communication, September 19, 1997).
The PPWC, in considering the variability in mill processes, expected the group’s first task would be to determine which were the most critical toxins to test. It also pushed for testing, funding, and monitoring programs for any disposal solutions. There were concerns raised over persistent, bio-accumulative nonylphenol ethoxylates. Until these testing and monitoring programs are in place, PPWC insists on disposal in industry landfills (F. Henton, personal communication, November 28, 1997).
COFI presents Background and frame work—guidelines for management and composting. The premise was that biosolids can be used beneficially and guidelines should specify: uses for different chemical load rates, set-back allowances, and for monitoring and compliance.
RFU! insists that industry pay for testing in order to first determine suitability of their waste for land spreading. It suggests an industry-funded research group.
The MOE and EC want the committee to achieve consensus on key issues, and to protect the environment through sludge characterization, soil characterization and evaluation standards (H. Vogt, personal communication, December 16, 1997).
Celgar disputes the findings and provides alternate tests.
RFU! discovers that both COFI and PGL are unable to supply any mass spec analysis results and that there are only three that have been done. One for Newstech, Scott Paper (poplar plantations), and the MB Powell River tests that were flushed out during the Cameron, Goggins, & RFU! environmental appeal process (D. Broten, personal communication, the Sludge Files, nd).
RFU! creates a Sludge Research Proposal based upon the 1988 research panel reporting the Maine Board of Environmental Protection.
PGL report prepared for Council of Forest Industries (COFI) is released, Draft – The guideline for use of pulp mill combined biosolids in land application – Part 1 and Part 2. (from the Sludge Files). Industry’s draft framework proposed three classes of sludge to be sampled for different standards and uses. Class 1 would require no reporting/ approval/permit and unrestricted use (Organix claimed that 95% of pulp mill sludge would fall within Class 1). Class 2 and 3 would be monitored use by a “qualified professional,” but only Class 3 would require permit. Ideally, the contaminant level parameters would be sourced from the Organic Matter Recycling Regulation (OMRR), Canadian Council of Ministers of Environment (CCME), and Contaminated Sites Regulation (CSR).
RFU! highlighted a key concern from the Organix report. Even if the receiving environment is already loaded beyond the 80% trigger of a contaminated site, the MOE may overrule these chemical load restrictions on “scientific grounds and be well documented to show minimal environmental and human health risk” (p.12). RFU! stressed that chemical characterization through testing each mill’s waste must happen before any decisions on classifying the waste. RFU! is given permission to publicly circulate the draft guidelines by COFI (H. Voght, personal communication, March 24, 1998).
PPWC, worried about worker’s health when working with the waste, stressed the need to identify compounds of concern. It does not support the risk-assessment approaches because they do not consider synergistic and cumulative effects of chemical contaminants.
MOE advocates sampling and offers the committee $20,000 of lab credits for independent analysis.
Spring Issue, The BC Environmental Report: Toxics – Who Says Toxic Sludge is Good for You? By Delores Broten.
Milburn Lake residents, near Quesnel, BC were shocked to find 100 tandem truckloads of sludge from Quesnel River Pulp Mill dumped on a local farm. The dump site was atop frozen land that sloped toward creeks and a local lake. There was no public consultation process, which was required by the MOE, until after the sludge was dumped on March 9, 1999. It was at this public meeting, hosted by MOE, a soil specialist, a farmer, and a nursery owner, that Quesnel River Pulp’s soil amendment program was discussed (Quesnel River Pulp presentation materials). The mill subsequently removed the sludge because of citizen outrage (Horner, N. 1998, Mar 14. Slingin’ Sludge. Quesnel Cariboo Observer) and documented by Delores Broten, Democracy Discovered in Sludge Dump in a Millwatch article.
PGL submitted a proposal for a $13,140 MOE contract to collect waste samples and review lab results for draft 2. MOE wants COFI to pay Organix and for MOE to pay for lab analytical work.
The problem of undefined compounds in the wastes still exists. RFU! is not happy with the sludge characterization data. Furthermore, now the MOE claims that a literature review of pulp mill sludge characterization may suffice so that sludge sampling and analysis may be unnecessary. They have prepared data spreadsheets on sludge characterization based on a literature review. COFI acknowledges RFU! has concerns about phthalates, and so it should be included in any sampling and analysis program. The committee discusses soil trials that need to be conducted to examine effects on soil chemicals, micro fauna, soil microbes, bacteria, and fungi. But it is still waiting for COFI to supply the three open scan characterization data so it can be interpreted.
RFU! sent a sample of an interior mill’s sludge to Alberta for an open scan analysis testing to try to find out what is in it. The mill that was sampled uses 100% chlorine dioxide bleaching with highly efficient effluent treatment.
At the October 14 committee meeting, COFI agreed to “lend its support to a chemical characterization study.” “Due to various process changes at their mills, they need new open scan GC/MS chemical characterization data.” The Draft 2 Guideline for the land application of pulp and paper sludge was discussed and the following issues were raised. Industry stakeholders complained that the new guidelines’ intent was to make land application easier, but Draft 2 required more testing that was too restrictive and time consuming (COFI, Pulp mill sludge guidelines – Draft 2 – required changes, November 5, 1998). WCEL and PPWC (comments) are concerned that industry’s sludge needs to be regulated not just self-regulating guidelines. Neighbours of sludged sites are concerned with sludge application over water tables. All groups except industry agreed that Draft 2 was closer to ideal than Draft 1. The MOE suggests that “pulp and paper mill sludge is, in some cases, an order of magnitude less contaminated than municipal biosolids” and that industry will just incinerate the sludge if the land spreading option is too onerous. (H. Voght, personal communication, October 14, 1998, p. 3). RFU! notes that worker health and safety issues remain unaddressed, fly-ash should not be included with the definition of sludge. The regulation should be transparent, enforceable (Ritchlin & Broten, Comments of draft 2 sludge regulations, November 1, 1998). The next step for the committee is the independent testing, sampling, and monitoring to characterize the wastes.
November 5, The Council of Forest Industries (COFI) resigns from the committee.
They are “simply unwilling to invest further time and resources to this process.” Industry would like to discuss with government the “problems with the current stakeholder involvement model” and “present a different consultation model that we feel provides science-based results in a more efficient and equitable [emphasis added] manner” (I. May, personal communication).
The problem with COFI’s preferred consultation model is that it is not equitable. Limited public participation at the design phase of policy means that the most important stakeholder is shielded/excluded from the process. That the public is the most important stakeholder may be proven in any case study on pulp mill pollution legacies. (CBC Radio. (20 March 2015). http://www.cbc.ca/news/canada/thunder-bay/lake-superior-toxic-sludge-cleanup-options-require-millions-1.2579836
For example, it will cost between $30-$100 million dollars to “clean up” 22 hectares of mercury and other contaminants in sediment in Thunder Bay’s harbour. In theory, these costs would be equally shared by Environment Canada, the provincial government, and responsible industry. However, in practice, either industry no longer exists or various owners have created the mess, and liability is difficult to establish.
The rest of the committee was not informed that COFI had formally checked out of the committee for three more months.
MOE explains that COFI withdrew because after 2.5 years they are still working from a draft document that was more onerous than the current permit process. MOE declares the committee adjourned and the information generated to date would form draft 3 for comment.
And that is how the budget was lost for independent lab testing.
March 9: the Quesnel River Pulp Mill hosts a community meeting.
April 15: RFU! responds to Fletcher Challenge, Crofton mills’ proposal to land-spread lime grits, dregs, and “waste” on a 100-acre dairy cow pasture on Evansdale Farm. Among concerns raised are the variability in contaminant composition found in the waste, long-term impacts on agricultural soil, and short-term exposure to airborne toxins. Cadmium, residual caustics, and sulphides are noted.
West Coast Environmental Law (WCEL) provides its comments for Draft 2. They agree with RFU!: “There has been no independent testing of the effects of pulp mill sludge on wildlife, the environment, or workers to date.” They want to know the status of the proposed testing. Where permits and regulations have legal authority, a guideline is not legally enforceable. “Qualified professional” designation is vague; liability should rest with the generator/users; public notification; copies of land-spreading records should be kept at our MOE office and be open for public to view (K. Campbell, personal communication, March 17, 1999).
PPWC urges the Premier to “declare a moratorium” on spreading sludge, claiming it “has the potential to spread toxins that may threaten our communities, workers, and the environment” (F. Henton, personal communication, contaminated sludge, February 3, 1999); to which the BC Premier responded 1999 April 7, Glen Clark, Premier response.
April 3: RFU! Media Advisory on Environment Ontario annual report which criticizes the way government has handled pulp mill wastes. RFU! also reports on the pulp mill sludge committee’s requests for testing and how industry walked away from the stakeholder consultation process to avoid independent testing.
October 12: The BC MOE produces Draft 3 Guideline for the Land Application of Pulp and Paper Mill Sludge (the Sludge Files). These documents combine the Pulp Mill Sludge Regulation with proposed guidelines specifying government expectations of industry that “sets out basic, legally enforceable requirements for the management of pulp and paper mill sludge” (p.4). It is MOE’s expectation that no environmental degradation will occur “if conducted in accordance with” these documents. They are intended “to provide a framework for the environmentally safe and beneficial reuse of pulp and paper mill sludge in the Province of British Columbia” (p. ii, 4), regarding sludge storage and pre-treatment, handling, transportation, soil monitoring, classification, sampling method, soil pre-application monitoring, sludge Class 1 application, Class 2 Sludge Management Plans, application, site characteristics, separation distances, buffer zones, ALR reserve areas, notification requirements, agronomic monitoring parameters and application rates, method and timing, public access, ecological impact assessment, record keeping, monitoring and reporting, substance and toxin requirements, sludge management reports. This draft of the regulation required significantly more testing than the current regulation. Draft 3 would have required that 50 compounds listed in the Contaminated Sites Act be tested. The current code of practice only requires testing for 11 compounds.
January 21: RFU! provides a brief critique of Draft 3 Guideline and regulation for the application of pulp and paper mill sludge, October 12, 1999.
WCEL provides a brief critique of Draft 3. They were not able to provide comments because independent testing program and sludge analysis were not done. Their participation in the committee was on the understanding that there would be chemical analysis done on the sludge to be land-spread.
BC MOE releases their Minister’s Progress Report Highlights for July 1999 –July 2000, with claims that under the NDP “The toughest pollution standards in Canada for pulp mill discharges…and contaminated sites were announced” and that the “Canada-wide standards for dioxins and furans from coastal pulp mills and waste incinerators were tabled by BC and approved in principle at the Canadian Council of Ministers for the Environment (CCME) meeting in June 2000” (p. 6).
The information in the Sludge Files indicates a difference between the BC NDP and BC Liberals strategies for stakeholder engagement in policy creation. At least the federal government and the BC NDP were willing to discuss the issue. But the BC Liberals have closed any discussion and simply allowed industry to make all the rules.
Final Report—Pulp Mill Residual Chemistry and Options for Regulation is produced by British Columbia Pulp and Paper Association, prepared by Organix Waste Solutions Inc., and filed with MOE. Organix’ sludge analysis aimed to “prove” mills would meet Class 1 standards. The report “concludes that the recommended options, based on a chemical survey of residuals from a cross-section of mill types and processes, will allow for beneficial reuse of pulp and paper mill types and processes, will allow for beneficial reuse of pulp and paper mill residual as much-needed organic soil amendments.” It included information on methodology and sampling, residual characterization of toxins, microbial indicators, agronomic parameters, options analyses, recommended options, review of Acts and Regulations. It was based on an overview of residual quality for six BC mills.
Limited spreading of pulp and paper sludge in BC had previously occurred under special approvals. These include the mill sludge that is mixed with Greater Vancouver Regional District (GVRD) municipal sludge and land-spread on Scott Paper poplar plantations on islands in the Fraser River. Quesnel River Pulp Mill spreads some of its sludge on farmland in the Quesnel area. Celgar kraft sludge has been spread on some orchards and agricultural land.
RFU! along with 33 other organizations, sends a letter to Minister of Environment Joan Sawicki. Reach for Unbleached! and the Georgia Strait Alliance gather public signatures on “Stop Sludge” postcards; the Minister herself signs one at an event in Vancouver.
2001 article, On the sludge trail (Broten & Reilly, Millwatch).
Delores Broten wrote: “This regulation throws the doors wide open for over 50,000 truckloads of sludge per year to be spread in BC communities, with virtually no government oversight and no independent monitoring”. RFU! leads a campaign with dozens of other environmental groups targeting media and government.
November, MOE releases the Code of Practice for Soil Amendments to allow widespread and self-regulated land-spreading. Delores Broten, Rob Wiltzen, Tammy Morris, and Michael Cooke campaign to alert the public; this generates numerous letters from citizens. These efforts resulted in a few weeks extension of the comment period; implementation of the Code was delayed.
The Tyee author, Heather Ramsay, publishes an article Pulp mills aim to spread sludge on crops: Toxic waste use fast-tracked with little public input.
Paprican sludge reduction study, A review of secondary sludge reduction technologies for the pulp and paper industry finds that “although it is technically feasible to eliminate the need for sludge disposal, it is unlikely feasible at this time” (p. 2093).
June 21: The Minister of Health, Doug Abbott, finalizes the Code of Practice for Soil Amendments and announces the Code will come into effect September 2007. It also posts the Summary of Consultation Comments which is no longer available online. The MOE received over 150 responses in the extended four-week web-based consultation period signifying that this is an issue of interest.
August – October, the Crofton Airshed Citizen’s Group releases Toxic Sludge Alert, generates more letters to the Minster, leaflets the Union of BC Municipalities’ (UBCM) annual meeting.
July 9– Zellstoff Celgar pulp mill in Krestova, BC, is again the target of a neighbour’s distress over three properties that have accepted its sludge mix. While the mill claims it “does not think there is a biological risk to this material,” says it is not intended for use on “land where food is grown” (Perkins, 2012).
RFU! wanted to understand the gap between Draft 3 of the Pulp Mill Sludge Committee recommendations and the current Code of Practice for Soil Amendments. We wanted to know what we can know about pulp mill waste management in BC and the status of the remaining 16 BC pulp mills. So, each mills’ environment manager was contacted and asked how they manage their waste. Most of the pulp mills were unhelpful, except for Catalyst Crofton and Harmac Nanaimo. These mills openly offered the information along with mill tours.
The lack of transparency among the majority of the mills, when it comes to its waste management, limit the public’s ability to trust the industry. The relationship between the farmer, the food industry, and customers is crucial for acceptance of sludge use in agriculture. The public is worried about toxic and “potentially bio-accumulative substances that require regulatory assessment to prevent possible ecosystem and human health consequences” (Kelly et al., 2007. Food web-specific biomagnification of persistent organic pollutants, p. 236).
From what we can know about pulp mill waste management in BC, RFU! found that the Crofton mill is not land-spreading any wastes; sludges from primary and secondary sludges are incinerated as biomass fuels. Its boiler ash and recaust waste are landfilled.
Prince George Northwood Pulp Mills’ Sustainability Report 2014 says they are looking at fly-ash utilization initiative operational trials.
In Howe Sound (Port Mellon) Pulp and Paper Corp, the last wastewater treatment review report was in 2013 and it did not contain the info requested.
Quesnel River Pulp Co. says in their 2015 Sustainability Report “we also regularly haul our sludge, a by-product from our effluent ponds at our BCTMP mills and our joint-venture newsprint mill, to local farms to be spread as a soil enhancer” (p. 16). City of Quesnel discharges sewage to Mill WWTP for $200k/year for over 3 decades (Dayton & Knight., p. 10).
An ad in Quesnel Cariboo Observer (21 March 2012) stated a “Notice of Intent to Apply soil amendment material to agricultural land – Class B 104 hectares.” The ad said that 100% of all ash (boiler and fly ash), lime mud, and sludge from aerated lagoon/settling basins (when they are cleaned out) are disposed of in their fully lined landfill on their site. When asked if they had ever land-spread as Class A or B, the manager of environment first said never, but then when asked about the notice from 2012, he said it may have been but that was before his time. This mill was unwilling to answer questions from RFU!
Nanaimo Harmac burns all of its sludge. The PPWC at Harmac say they have not changed their position that pulp mill waste should be landfilled.
The BC Liberals’ opinion on biosolids. North Shore News Letter to Editor from Mary Polak, BC MOE, May 8:
I would like to take the opportunity to clear up some misconceptions around biosolids and how they are used throughout BC. In BC, biosolids can only be applied to the land when there is a benefit. Companies cannot apply biosolids to the land as simply a means of disposal. Biosolids are used as compost or fertilizer on land. The nutrients in the biosolids make soils healthier, similar to animal manure.
In BC, ‘biosolids’ and ‘sludge’ do not mean the same thing, as regulations do not allow the land application of sludge. Sludge is material generated during the wastewater treatment process before any beneficial use is met. Biosolids are sufficiently treated to reduce odours and harmful substances, stabilized, and tested to ensure treatment requirements and quality criteria are met. Biosolids not used as fertilizer are sent to a landfill, contributing to methane production, increased greenhouse gases, and increased costs to landfills.
Regulation of biosolids falls under the Organic Matter Recycling Regulation, which is designed to protect human health and the environment. Biosolids have been applied safely to a variety of locations in the Nicola Valley – and around the province – for more than a decade.
BC’s approach to land-spreading biosolids is described in Biosolids are wicked to manage: Land application regulations in Sweden and Canada, describes BC’s approach to land-spreading biosolids. It notes that there are risks and benefits to society, however they are distributed unequally amongst the stakeholders (Oberg & Morales).
The BC Cattlemen’s Association (BCCA) and the Kamloops Stockmen Association joined with SYLVIS Environmental to host the Economic & Environmental Advantages of Residuals in Forage Production. This workshop taught local cattle and hay producers, TNRD Agricultural Society, and the Skeetchestn Indian Band to have a profitable operation by using “residuals such as biosolids, wood ash, recycled paper fibre, pulp mill and water treatment residuals” (March 31).
A study from Ireland’s Environmental Protection Agency, Health and Water Quality Impacts Arising from Land Spreading of Biosolids Report No. 200, emphasizes:
A matter of concern is that unlegislated metals and PPCPs, which were found to be present in biosolids originating from a selection of the WWTPs examined in this study, may be inadvertently applied to land. With multiple applications over several years, these may build up in the soil and may enter the food chain; this gives rise to concerns over the continued application of biosolids to land in Ireland”. (Healy et al, 2017).
Since the 1996 Pulp Mill Sludge Committee, the BC MOE has failed to recognize knowledge gaps in the persistent, bio-accumulative, and toxic potential of wastes that are being applied to land. Industry is free to land-spread/apply its wastes without legislation or regulatory nuisances. There are no guidelines, or even codes of practice, for the unacknowledged contaminants in the pulp and paper making process, let alone the emerging contaminants of concern.
The risks/benefits in society are unfairly distributed and much resource potential wasted fighting the industry from our backyards, often distraught and disturbed. Cities and groups with higher social economic status are mostly insulated from land-spreading wastes often far afield, but their understanding of the issue is crucial.
Future studies should calculate the costs in risks and in benefits, identify the areas and people/communities at risk, and identify the areas and people/communities that benefit from land-spreading wastes, including quantifying the risks and benefits through an unequal distribution.
It must be required that the land title notes land-spreading activity. Even money lenders are more often requiring this information.
The waste management industry has not evolved. Perhaps this is because COFI was wrong, and multi-stakeholder engagement is not only ethical, it is fundamental in advancing technology. The Code of Practice for Soil Amendments, was narrowly informed by industry interests.
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Priest, A. (1989, Nov 30). Mill workers’ lungs hit: Chlorine gas a health risk, scientists say. The Vancouver Sun.
Polak, M. (2015, May 8). Biosolids used safely as fertilizer. North Shore News. Retrieved from http://www.nsnews.com/opinion/letters/letter-biosolids- used-safely-as-fertilizer-1.1928758#sthash.YGR9nXWy.dpuf on March 30, 2017.
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