RE: “Meet the Spartans” (Editorial, June/July 2009 edition)
We are legal counsel for Atlantic Paper Products. Atlantic has regretfully come to the conclusion that your June/July editorial concerning paper fibre biosolids was misleading and contained significant inaccuracies, including the following:
1. Atlantic had nothing to do with the Pelham site referred to in your editorial. The paper fibre biosolids used in that site were significantly different from those generated by Atlantic.
2. The statement “In several locations, contaminated leachate from the berms has forced the ministry to order the excavation and removal of material, at great expense” is untrue. While there are two locations where berms containing Atlantic PFBs were redesigned, within the same site, this was due to Conservation Authority rules against all kinds of fill in a floodplain and not to evidence of “contaminated leachate.” The SoundSorb was originally placed as directed by the respective property owners; in one case, it replaced an existing 40-year-old berm that predated conservation Authority rules.
3. Atlantic was not using landfill as a method to deal with PFBs when the SoundSorb berm program was developed, and does not intend to use it now. The berm program is a beneficial use program that is not a low-cost option.
4. Atlantic and the ministry signed a binding Agreement, not merely a Memorandum of Understanding. This Agreement is a legally enforceable control instrument which provides equal or better protection for human health and the environment, as recommended by the Experts Panel. In particular, it provides for careful selection of all berm sites, and regular monitoring of potential impacts.
5. The province has substantially implemented the Expert Panel’s other recommendations. In particular, surface and groundwater near existing berms at gun clubs are monitored regularly. In no case have contaminants in excess of the Ontario drinking water quality standards been found in groundwater leaving a site, nor have significant risks to human or environmental health been caused by any berm containing Atlantic PFBs.
6. Your editorial suggests that the ministry is negligent in failing to require Atlantic to compost its PFBs. The Agreement does not require composting of Atlantic’s PFBs, because scientific evidence suggests that this may do more harm than good. Composting could potentially destroy harmful bacteria, if the specific types of e.coli and other bacteria found in Atlantic’s PFBs were harmful to human health or the natural environment. To date, this has not occurred. On the other hand, composting increases the bioavailability of metals, such as copper, as confirmed in a recent English study. Whether composting is desirable depends upon the particular characteristics of the PFBs from each mill.
7. The “recent” call from ALPHA was issued in 2005, before the signing of the Agreement which implemented the Expert Panel recommendations.
8. PFBs contain extremely low levels of lead until they are placed at a gun club. To the best of Atlantics knowledge, all ministry “evidence” that SoundSorb contains elevated levels of lead is based on samples taken after the SoundSorb was contaminated with lead from bullets and other gun club sources.
The beneficial use of paper fibre biosolids is an indispensable element of paper recycling in this province. SoundSorb berms, in particular, provide substantial public benefits. They protect gun club members and neighboring residents against gun club noise as well as against stray bullets. SoundSorb berms are softer, quieter, more uniform and safer than equivalent earth berms, which may contain stones that deflect bullet fragments in unpredictable ways. Public safety officers, such as police, are major users of gun club sites equipped with SoundSorb berms, and access to such facilities allows them to improve their firearms skills, maintain their qualifications, and thus serve and protect all of us.
Atlantic recognizes that the use of SoundSorb remains a legitimate subject of public debate. However, such debate is badly served by inaccurate media, such as your June/July editorial. Thank you for agreeing to publish an appropriate correction in your next issue.
Yours very truly,
Barrister and Solicitor, Ph.D. in Law
RE: “Waste Pellets for Energy” (April/May 2009)
I read with interest your article on Dongara. I noted that the article was silent, however, on end usage issues of the Dongara pellets.
In contrast to the article preceding yours (in which Mr. Zafar identifies cement kilns as one of the more important applications of RDF pellets — from the India perspective) Ontario-based cement manufacturers face considerable challenges in utilizing the Dongara pellets within their own operations. The issues are not technical, but relate more to Ontario waste and air policies, standards and approvals issues.
I wonder if this is an aspect you might consider exploring in a future article on the Dongara pellets. If so, you may wish to gain information from an interview with Martin Vroegh of St Marys Cement.
Bob Masterson, Director of Policy
Cement Association of Canada