The controversial disposal of paper-mill sludge at Ontario gun clubs has recently alarmed environmentalists and exposed a policy flip-flop from Ontario’s Ministry of the Environment that reclassified the waste as a “product” — exempt from regulation — when it’s mixed with sand.
New federal firearms regulations recently came into effect that require recreational gun clubs to install earthen berms at outdoor firing ranges (to catch bullets). Harvey “Skip” Ambrose, who operates Ontario Disposal and other companies, saw an opportunity. Ontario Disposal holds large municipal contracts for hauling sewage sludge and applying it to farmland. The company also takes away paper-mill waste from Atlantic Packaging. At plants in Whitby and Scarborough, Atlantic recycles newsprint and other used fibres into cardboard and paper products; the processes for different products generate anywhere from 10 to 50 per cent sludge, and up to 580 wet tonnes per day that require disposal. Mr. Ambrose provided the gun clubs with Atlantic’s paper-mill sludge as a cheap alternative berm-construction material.
Atlantic thought that turning its waste into a useful product closed the recycling loop. However, a citizens’ group called Protect the Ridges (because it’s concerned with the environmentally important Oak Ridges Moraine) and certain activists are concerned that contaminants within the sludge pose a threat to groundwater, and that toxic moulds can form on the wet paper.
Maureen Reilly, water campaign coordinator for the Sierra Club of Canada, says the sludge contains high levels of E. Coli bacteria and other contaminants related to inks and dyes from newsprint or sludge conditioner chemicals; they include petroleum distillates and acrylamide monomer (a genotoxic carcinogen).
“The ministry has never conducted leachate tests on the sludge or scanned for a full range of contaminants,” Ms. Reilly says.
Atlantic’s Todd Kostal responds that the bacteria are non-pathogenic and are killed off anyway in “heat spikes” inside the sludge piles. Other compounds are at low levels below regulated thresholds, he says.
Whether the material poses a threat or not, the environment ministry’s decision to allow the material to be applied to land simply because it’s mixed with sand is unusual, especially in light of previous controversies. Ontario Disposal initially stored Atlantic’s raw sludge in a gravel pit in Durham. Protests from neighbors drew the attention of the Ministry of Natural Resources and the Region of Durham, which ordered the material removed, citing approval certificate and bylaw violations.
Mr. Ambrose also owns the Kawartha Downs horse track in Peterborough. He trucked the paper-mill sludge there to build a sound-attenuation berm around a car speedway that he built inside the horse track. Interestingly, the environment ministry ordered the material removed because it determined that the application of the waste on land violated provisions in Ontario’s Environmental Protection Act.
Ontario Disposal then mixed the sludge with sand and claimed that it was now a “product” (called “Sound-Sorb” because of its function in dampening the roar of racecar engines.) Staff memos obtained under the Freedom of Information Act reveal why the ministry initially rejected this argument. One staff wrote that, “Merely mixing something with a waste cannot be sufficient to change a waste into a non-waste. To be otherwise would create a very simple way to bypass Part V of Regulation 347 controls.”
Yet the ministry eventually reclassified Sound-Sorb as a product around the time that Ontario Disposal began using it to construct berms — some of them enormous — at gun clubs in Peterborough, Madoc, Napanee, Orillia, Guelph, West Lincoln, Niagara and Oshawa.
The activists remain convinced that the Sound-Sorb berms pose a threat and that the exemption sets a terrible precedent. In a letter to the Aylmer Express, Jennifer Weninger, an environmental science student at York University, stated that total petroleum hydrocarbons (TPH) at the East Elgin Sportsman’s Association — a gun club near Aylmer — were reported at ten times the provincial guidelines. She pointed out that the ministry ordered the cleanup of a site in Toronto where TPH was reported at only 1,000 to 2,000 parts per million, but was doing nothing about TPH at the Aylmer gun club at 7,600 to 13,000 ppm — despite the berm being located in a sensitive wetland and groundwater source for an entire community.
Because of ongoing pressure, the ministry recently formed a “bioaerosols committee” to address concerns that mould and fungus could grow on the berms and become airborne. It also initiated a Site Specific Risk Assessment (SSRA) at the Oshawa Skeet & Gun Club. These initiatives are expected to provide a scientific assessment of any risks posed by the berms. The results are expected this fall, but whatever they are, the activists say the environment ministry should have performed such assessments before it exempted the waste from regulation, not after. It will be very expensive to excavate and remove the material if this is deemed necessary, they say, and to treat groundwater if contamination is detected.
Whatever the outcome of the risk assessment, we have no doubt that Mr. Ambrose will find some other end-use for the material, having already devised a number of novel applications. Mixed with sand, it becomes “Sound-Sorb.” Mixed with cement kiln ash, it’s “Fibre-Krete.” And with compost, it becomes “Nitro-Sorb” — a soil supplement. Perhaps Mr. Ambrose will next mix it with gravel for the construction of ski slopes and artificial mountains. Might we suggest, “Alpine-Sorb”?
What will the ministry do then?
Guy Crittenden is editor-in-chief of this magazine. Send your letters to: email@example.com