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HomeMy WebLinkAboutPSD-022-01 '- ~ , Cl!J!Jugton REPORT PLANNING SERVICES DEPARTMENT Meeting: Date: Report #: GENERAL PURPOSE AND ADMINISTRATION COMMITTEE (;1//1- MONDAY OCTOBER 1, 2001 1:-05 Recommendation # lj!tg'.-{) I PSD-022 01 File # PLN 33.12 By-law # Subject: SOIL ENRICHMENT PROGRAM - PAPER FIBRE BIOSOLlDS AMENDMENT TO CERTIFICATE OF APPROVAL NO. H150022900500-03 SUBMITTED BY ATLANTIC PACKAGING PRODUCTS LTD. AND COURTICE AUTO WRECKERS Recommendations: It is respectfully recommended that the General Purpose and Administration Committee recommend to Council the following: 1. THAT Report PSD-022-01 be received; 2. THAT the Ministry of the Environment be requested not to approve the Amendment to Certificate of Approval No. H150022900500-03 submitted by Atlantic Packaging Products Ltd. and Courtice Auto Wreckers Ltd. for a Soil Enrichment Program, until the outstanding issues identified through the Region's Peer Review of the Benefits Study and the testing of "Sound-Sorb" leachate have been properly addressed, and the Bioaerosols Study and groundwater testing have been properly completed; 3. THAT, in the event that the Ministry does not defer making a decision on this matter, the Municipality of Clarington requests a hearing under the Environmental Protection Act for the reasons outlined in this Report; and 613 , , REPORT PSD~22~1 PAGE 2 4. THAT the Ministry of the Environment (York-Durham office), the Region of Durham, the City of Oshawa, the Township of Scugog, Protect the Ridges, interested parties and all delegations be forwarded a copy of this report and be advised of Council's decision on this matter FORTHWITH. \ Submitted by: Reviewed bye ~ ~ Da id J rome, M.C.I.P., RP.P. Franklin Wu Director, Planning Services Department Chief Administrative Officer JAS*BN*DC*sh September 25, 2001 614 , REPORT PSD-022-01 PAGE 3 1.0 BACKGROUND Atlantic Packaging has submitted an application to the Ministry of the Environment (MOE) for an amendment to their Certificate of Approval. The requested amendment would, among other matters, increase the permissible application rate and storage time for paper fibre biosolids (PFB) and renew the Certificate of Approval for an indefinite period. As a condition of their existing Certificate of Approval, Atlantic Packaging is required to undertake a Benefits Study that examines the soil/agronomic benefits and/or detriments resulting from the application of PFB. The Study was originally released in January 2001. The Study was subsequently revised in response to comments provided by MOE. On August 24, 2001, the Ministry forwarded the revised study, entitled Final Report of the Atlantic PackaQinq Products Ltd. Paper Fibre Biosolids Studv. to the Region and area municipalities and requested that comments be submitted by Friday September 28, 2001. The Region has retained consultant to conduct a Peer Review of the revised Benefits Study. The Peer Review report (see Attachment No.1) included the following conclusions: . the analysis and interpretation of the data lacks scientific rigor . the study did not meet, with scientific accuracy, all the requirements of Section 43 (d) of the Certificate of Approval . the study did not indicate with any level of scientific accuracy that soil benefits have been achieved. 2.0 RELATED STUDIES MOE, in conjunction with the Region of Durham Health Department, has also retained a consultant to undertake a study of the health effects of bioaerosols resulting from the manufacture and use of "Sound-Sorb". The study is expected to begin in the fall of 2001 and is tentatively expected to be completed sometime in 2002. 615 '. REPORT PSO..Q22..Q1 PAGE 4 The Health Department retained the consulting firm Gartner Lee Limited to undertake testing of existing stockpiles or berms composed of "SoundSorb" (see Attachment No.2). A key finding of Gartner Lee's report is the presence of high levels of E. coli and fecal coliforms in liquid trickling from the base of a "Sound- Sorb" berm, possibly indicating a strong link to human/animal sewage. The consultants suggested that the source of the bacteria is likely sewage sludge that was disposed of near the base of the berm. The testing also found concentrations of various chemicals in the liquid that were higher than the respective concentrations in the paper sludge leachate. This report is to be considered by the Regional Health and Social Services on September 20, 2001. MOE is also completing hydrogeological mapping of groundwater movement in north Oshawa and Clarington in the area where "Sound-Sorb" has been stockpiled and bermed. MOE has indicated that test wells will be drilled this fall to gather groundwater samples to determine the presence of contamination. The results of this testing should be available by the end of November 2001. 3.0 MUNICIPAL COMMENTS Committee and Council have previously provided comments to MOE on the Benefits Study and the requested amendment to the Certificate of Approval. On June 11, 2001, Council, through its consideration of Staff Report PD-055-01, resolved to recommend to MOE that the requested amendment to the Certificate of Approval not be approved until the Region's Peer Review and the Bioaerosol Study have been completed, and the Municipality has had an opportunity to determine whether a hearing is required under the Environmental Protection Act. Committee further resolved to request a hearing in the event MOE is not willing to wait for the results of the studies. On September 18, 2001, Regional Planning Committee considered a staff report that presented the conclusions of the Peer Review. Planning Committee resolved 616 " REPORT PSD-022-()1 PAGE 5 to request MOE not to approve the requested amendment to the Certificate of Approval until the outstanding issues identified through the Region's peer review of the Benefits Study have been addressed and the Bioaerosol Study has been completed. Planning Committee further resolved to request a hearing under the Environmental Protection Act for the reasons outlined in the report should MOE not wish to defer its decision. 4.0 CONCLUSIONS The conclusions of the Benefits Study Peer Review and the results of the testing on the leachate from "Sound-Sorb" indicate that there are many unanswered questions related to the land application of PFB and the production and use of "Sound-Sorb". As well, the results of the Bioaerosol Study and groundwater testing are not yet available. Accordingly, there does not appear to be any compelling reason for the Municipality to revise its previously stated position that it is premature for MOE to approve the requested amendment to the Certificate of Approval held by Atlantic Packaging and Courtice Auto Wreckers. Attachments: Attachment 1 - Peer Scientific Review of: "Paper Fibre Biosolids (PFB) Benefits Study" Attachment 2 - Letter to Mr. Mr. A. C. Wong, Regional Health Department Interested parties to be notified of Council's decision: District Supervisor Protect the Ridges Ministry of the Environment C/o Ms. Deb Vice York Durham District Office 4220 Townline Road N. 230 Westney Road S. RR #2 5111 Floor BLACKSTOCK, Ontario AJAX, Ontario LOB 1 BO L 1S 7J5 CORPORATION OF THE MUNICIPALITY OF CLARINGTON 40 TEMPERANCE STREET, 80WMANVILLE, ONTARIO L 1 C 3A6 T(905)623-3379 F (905)623-6506 617 \ ATTACHMENT 1 Peer Scientific Review of: "Paper Fibre Biosolids (PFB) Benefits Study" Durham Region File No. 012-000027 Prepared by the Soil Resource Group September 13,2001 SRG ;ft SOIL RESOURCE GROUP 503 Imperial Rd. N., Unit I Guelph, Ontario NlH 6T9 618 ,. SRG;{t SOIL RESOURCE GROUP TABLE OF CONTENTS Executive Summary Background 3 Study Objectives 3 Results A) Certificate of Approval Criteria 3 I. Results and conclusions related to soil/agronomic benefits 3 2. Agronomic effects of biosolids on plant growth and yield and soil properties 4 a) Soil properties b) Agronomic effects on plant growth and yield 3. Soil and farm management practice recommendations to prevent adverse 7 environmental impacts 4. Recommendations for the timing of biosolid application and suitable crops 7 5. Recommendations for improving fertilizer program 7 6. Additional measures to maintain and protect environmental quality 8 7. Assessment of the specification of organisms present 8 B) Evaluation of the scope of the study to assess benefits of soil quality and .::rop growth 9 Conclusions 9 Appendix 10 11 619 SRG;ft SOIL RESOURCE GROUP Peer Scientific Review of: "Paper Fibre Biosolids (PFB) Benefits Study" Durham Region File No. 012-000027 Executive Summary: The Soil Resource Group (SRG) established a study team of senior scientists with experience in agronomy, soil science, microbiology and hydrology to conduct a science-based peer review of the paper fiber biosolids (PFB) benefits study. The objectives of the peer review were: a) to determine whether section 43 (d) of the Certificate of Approval has been satisfactorily addressed and b) to assess whether the scope of the study was sufficient to determine the benefits of paper sludge on soil quality and crop growth. The Benefits Study as submitted would not satisfy all the criteria set out in Sections 43 (d) of the Certificate of Approval. The results and conclusions reported by the authors with respect to soil benefits and soil management recommendations are often not supported by the data in the report. The study concludes that PFB enhanced soil and biological properties with no detrimental effects on chemical properties. However, when the conclusions were evaluated against the data, many of the claims are not supported by the data reported. At the same time, management recommendations are made for PMB storage, spreading, soil texture, weed control and timing of application. Conclusions drawn for soil texture, timing of application and weed control are not supported by data in the report while conclusions on topics such as storage and spreading equipment were not based on any data. . Recommendations on management practices that would reduce adverse environmental effects associated with PFB were either not addressed (eg. trace metal contamination) or not based on any data (eg. storage). Management practices investigated related to the timing (spring vs fall) and method of application (surface vs incorporated) are difficult to make credible recommendations for when only a single year of data were available for analysis. The requirement of specification of organisms present in PFB during storage and land spreading was met by an independent study which concluded that, although bioaerosolization cannot be determined directly from bulk samples, the results suggest that nuisance bioaerosolization during land application will not be significant. The scope of the study was sufficient to evaluate the soil and crop benefits. However, questions arise over the validity of the conclusions and recommendations when the duration and experimental design of the experiments are considered. A single years data was collected for I of the 4 sites in the PFB x N study and for 2 of the 3 management experiments. Failure to describe experimental design and field methodologies in a comprehensive manner also made it difficult to evaluate the results. In the PFB x N experiment the amount of N applied appears inconsistent and sometimes inadequate preventing valid treatment effect comparisons. Further, 620 .. the inconsistent and sometimes inappropriate use of statistical measures with the presentation of the data did not provide credence to the reported results Generally, the benefit study has much favorable information with regard to the justification for the application of PFB on agricultural land. However, the manner in which the data is presented and interpreted distracts severely from the potential value of the data. Study methods are often not well documented to the point that it becomes difficult to confidently interpret associated results. The proposed experimental design and analytical methods for conducting soil quality measurements was especially weak. The analysis and interpretation of the data lacks scientific rigor. For example, while much soil quality data is presented and conclusions drawn, there is inadequate statistical analysis of the data reported to support the study recommendations on soil benefits derived from the application of the biosolids. Measurement of soil quality data was inconsistent in timing or crop type. In the management studies, changes in yields were to be based on PFB rates and the interaction with N applied as compared to the control (PFB 0, NO). It is difficult to interpret the statistical design and the treatment response when based on an unbalanced application of N. The statistical analysis of the data is inconsistent throughout the report. While some data tables have no statistical data, other tables have one or a combination of standard deviation and 90% confidence interval data. None of the tables provide the simple ANOV A data required for the basic understanding of the data presented. The SRG study team concluded that the benefits study did not meet, with scientific accuracy, all the requirements of Section 43 (d) of the Certificate of Approval. The study, as reviewed did not indicate with any level of scientific accuracy that soil benefits have been achieved. If this report is to demonstrate a benefit on soil quality parameters, then the method of presentation of the data must be improved. The benefit data would be credible and be more striking to a reviewer if it were presented in graphical format including the resulting linear regression equation and the . statistical parameters of the regression equation. A table of the simple relevant ANOV A data should accompany the presentation of the data. 2 621 Background: The Soil Resource Group (SRG) was retained by the Regional Municipality of Durham to undertake a peer review of a study submitted to satisfy a requirement of the Provisional Certificate of Approval issued by the Ministry of Environment to Atlantic Packaging and Courtice Auto Wreckers. The Soil Resource Group established a study team with research experience in agronomy, soil science, microbiology and hydrology to conduct a science-based peer review of a study on the benefits of land applied paper fiber biosolids. The study team met prior to the review, to plan key review considerations of the team members. Each study team member reviewed the entire benefits study while focusing their analysis on topics related to their area of specialty. Subsequent to the individual reviews, the study team met to consolidate their observations and make recommendations on the report. Study Objective: To conduct a science-based peer review of a report entitled" Atlantic Packaging Products Ltd., Final Report, Paper Fibre Biosolids Benefits Study August 200 I" to determine: a) whether Section 43 (d) ofthe Certificate of Approval has been satisfactorily addressed and with scientific accuracy b) whether the scope of the study and associated parameters are sufficient to assess the benefits/detriments of the application of paper sludge on soil quality and crop growth and c) if other conclusions may be derived from the study results that could assist in evaluating net benefits Study Results: A) Certificate of Approval (Section 43d) Criteria 1. Results and conclusion related to Soil/agronomic benefits The data may support the overall conclusion that applications of PFBs, along with sufficient nitrogen, to agricultural land has either positive or no net negative soil/agronomic benefits. However, individual conclusions as stated in the Executive Summary and Sections II (Summary) and 12 (Management Recommendations) are often not supported by the data reported. Detailed examples of such inconsistencies are given in Section #2, below. It is acknowledged that the 2 year time constraint put on the study, and the fact that those two years were both atypical and opposite in terms of weather, makes statistical year to year and site to site comparisons difficult. However, the results should be discussed in the context of these differences. In that context, since 1999 was a very dry year and 2000 a wet year, and in both years most of the parameters measured showed either positive or no negative effects, it would seem logical to conclude that in "average" 3 622 years, these parameters would also show positive or no negative effects. This is significant from a management perspective. It has not been explicitly stated whether the treatment applications were conducted on the same plots in year 2000 as they were in the year 1999. It was reported that the soil quality parameters were based on applications of PFB over a two year period. Due to the cumulative effect of PFB applications, the resulting management recommendations as outlined may be invalid. The chronology of PFB treatments of individual plots is very unclear and this makes interpretation of the results difficult. A specific example of this is the Fall/Spring PFB Application study. The reviewers have assumed that the "Spring" plots received PFB treatments in Spring'99 and Spring' 00, i.e. two PFB treatments in total. However, it is unclear whether the "Fall" plots received only PFB applications in Fall'99, or in Fall'99 and again in Spring'OO. If "Fall" plots received onlv Fall' 99 applications, then what are being compared are plots with 2 PFB applications ("Spring") and plots with 1 PFB application ("Fall"). Also in the field management experiments, the application of nitrogen between treatments and sites is inconsistent, and does not correspond to the methodology provided. The impact on yield results is, therefore, difficult to interpret. 2. Agronomic effects of biosolids on plant growth and yield, and soil properties. a.) Soil properties The soil physical properties examined were bulk density, surface water infiltration rates, surface soil moisture, and soil aggregation. It was concluded that, application of PFBs decreased the soil bulk density, and this conclusion seems to be (statistics not shown) supported by the data presented. It was concluded that, surface water infiltration rates were significantly increased with the 150 Uha PFB rate. While the averaged data appears to support this conclusion, the standard deviations ranged from approximately 50% to 200% of the means. Block variability often appears to have overshadowed the treatment effects. At best, it can be stated that an overall trend of increasing infiltration rates was observed with PFB application of 150 t1ha. It was also concluded that, significant increases were shown in surface soil moisture content with increasing PFB application. However, while the data generally appears to support this (Tables 20-23), there is lengthy discussion on block to block variation which, again, clouds the overall conclusion. 4 623 It was not possible for the researchers to draw conclusions with respect to soil aggregation, due to the lack of suitable methodology. The soil chemical properties measured were soil total carbon and nitrogen contents, soil pH and electrical conductivity, and soil concentrations of the 11 elemental contaminants regulated under MaE guidelines. The timing and methodologies for these measurements are not given, and only the data for the NA = 1 nitrogen application rate is shown (p63). The researches concluded in their Executive summary, that there was a trend of increasing soil total carbon and nitrogen contents with increasing PFB application. However, the data show that there was no significant difference between the treatments and the controls, and the trend was observed for only 2 of the 4 sites (p64). Without knowing when these measurements were taken, it is difficult to comment on the conclusion. It is likely that a two year (or one year for Campden) study is insufficient to observe a cumulative effect. It is concluded that, soil pH and electrical conductivity (EC) were not affected by PFB application. For pH, the data presented (Table 32) indicate a slight increase at two of three sites and little change at the other two sites. For EC, Table 32 shows a slight increase at two sites, and no change or variability at the remaining two sites. It was stated (p64) that all measurements were within the normal range for Ontario soils. Without the benefit of information on numbers of replicates, or variation, a more appropriate conclusion might be that no negative effects were observed on pH and E.C with PFB applications. It was also concluded in the Executive Summary that, soil concentrations of the 11 elemental contaminants regulated under the 1996 MaE guideline were unchanged by PFB application. Soil concentrations were not reported. What was reported were the concentrations of the metals in the PFB delivered to the site for both years. Only one set of data is presented. The metal of most concern appears to be copper. Using the data presented in Section 9, p65, the calculation of copper load (g/ha) added to a site at the 150T PFB/ha is as follows: 150 T (ww)/ha is approximately 75T (dry wt)/ha at approximately 50% TS (Tables 4 & 5) 75T PFB/ha x 94.1gCurr PFB = 7056 g Cu/ha for one application If the same rate of PFB is applied over two years, the copper load is 14,112g Cu/ha, which exceeds the 5year MaE guideline. (Note: zinc at the concentration reported, would just meet the guideline.) 5 624 For sequential applications over 5 years, and assuming the copper concentration is similar in other lots of PFB, the maximum annual PFB application rate would be 57.8T/ha. Based on the above calculation, the statement that the soil elemental contaminants were unchanged (if they had been measured) cannot be supported. The soil biological properties measured were earthworm populations and soil microbial biomass. It was concluded that in the Executive summary, a significant increase in earthworm populations occurred [with increasing PFB additions] at Cambridge, with no measurable effect at the other sites. However, Figures 4 indicates that there are some "out of line" data points for Cambridge in Fall 1999, and the corresponding discussion also indicate extreme variability in statistical contrasts. The Fall 2000 data (Fig. 5) indicates a trend of increasing earthworm numbers with increasing PFB applications. However, again the trend is not always consistent. A more appropriate conclusion would be that "There is no indication that the application of PFB had a negative effect on the earthworm populations at [any of the] sites". It was also concluded that, there was a significant increase in microbial biomass. carbon at 3 of the 4 sites in response to high PFB application rates. This parameter was not reported for soybeans. This section ofthe report (6.6) is glossed over without the benefit of presented data or figures. The plot size is not given and the source cited for the methodology is missing in the Reference section. From the "highlights" given in Section 6.6 of the Report, for the Fall application, there was a decrease in microbial biomass C at two sites and no change at one site. For the spring application, there was a decrease at one site, no change at one site and an increase at two sites. Microbial biomass N, however, did indicate some soil improvement with no significant change at all sites for fall application, and an increase at all sites for spring application. It is likely that an examination of changes in microbial biomass over the course of the experiment would be more appropriate. b.) Agronomic effects on plant growth and yield Grain yields for com and soybeans were determined for 3 sites for both years. At the Campden site, soybean grain and corn stover were assessed for one year only (2000). Plant germination and growth was reportedly not significantly effected in a negative manner, but there was no data to support this statement. - It was concluded that, for corn, yields can be maintained or enhanced with PFB additions as long as nitrogen is supplied at a rate of NA = 1. The data generally supports this conclusion, though in some cases (eg. Table 39, Campden), a NA rate of 1.5 appeared to be required. Application of PFB without additional N resulted in decreasing corn yields with increasing PFB application. 6 625 It was concluded that, for soybeans, there is a general trend towards increased yields with increased PFB application rates. Because of the high variability in the yield data, this effect was not statistically significant. However, it does show that there was no adverse effect of applying PFB on soybean yield. 3. Soil and farm management practice recommendations to prevent adverse environmental impacts. No management recommendations are reported in the study, other than for storage, Section l2.l.l( p84) which states that the material should be located away from water courses or residences. This is a reasonable general principal,. but is not based on any data, and should be discussed as such.. From the preceding discussion regarding copper concentrations, it is clear that close monitoring of the elemental contaminants is necessary. No recommendations were made The erosion study referred to (p7) was not included in the benefits study package received, and cannot be commented on in this review. The report on the microbiology of the PFBs was included in the benefits study package. It is stated in the report (p7) that it is for information purposes only. However, the report does indicate that the stockpiled PFB' s would not pose a serious bioaerosol threat. This will be further discussed in #7, below. Again, no recommendations or comments were made. 4. Recommendations for the timing of biosolid application and suitable crops A study was conducted to compare fall and spring applications of PFBs. It was concluded that, applications of PFB in fall resulted in significantly higher corn yields the following year compared with spring PFB applications. The limited data (l year, very wet, and NA = 0, 0.5) seem to support this conclusion at two out of the three sites. However, only a low nitrogen rate was used (i.e., NA = 0, 0.5), so it is not known if the difference in yield between spring and fall application would hold for the recommended nitrogen rate (NA 21.0). PFB applications were only tested on corn and soybean crops. Both were suitable crops in that no net negative effects due to PFB applications were observed if appropriate levels of nitrogen were included. 5. Recommendations for improving fertilizer program For corn, it is recommended (Section 12.2, p86) that a supplemental nitrogen rate of NA = 1.0 or 1.5 be applied at the higher PFB rates (100 and 150 t/ha) ; NA = 0.5, is sufficient 7 626 at a low PFB application rate. This is consistent with the data as it was presented. However, the methodology, as has been stated, adds doubt to the overall conclusion. The recommended procedure for calculation of the total N to be applied for a crop includes a pre-plant soil N test, a calculation of the crop requirement, and a calculation of the supplemental nitrogen required for PFB decomposition. It is noted in this section that the CN ratio of the PFB should be taken into account; however, this apparently was not included in the calculations presented in Section 5.5, p 27-28. The stated purpose of the laboratory incubation study was to enable a calculation of the supplemental nitrogen required based on a controlled temperature incubation study. It is acknowledged that this was not done in sufficient time to enable this calculation to be made. That aside, the study as reported used only one nitrogen rate (calculated to be sufficient to encourage microbial decomposition of the material). Nor were the results discussed in terms of the stated objective. Therefore it is difficult to see what purpose it served in the study. 6. Additional measures to maintain and protect environmental quality No additional measures to maintain and protect environmental quality were recommended 7. Assessment of the specification of organisms present An independent study was undertaken to do a microbiological analysis of fresh, stockpiled and land applied bulk PFB samples. Although it is stated in the main report that this study is for information only, the Benefits Study criteria specifically state a requirement for microbiological speciation. Therefore, the report will be briefly discussed here. The aim of the study was to asses the potential for PFB application to present a bioaerosol nuisance. Specific opportunistic pathogens looked for were either not found (Stachybotris chartarum), or present only in the treated soil sample, and most likely originated from the soil itself (Aspergillus fumigatus). The sampling procedure would have been improved by taking composite samples from different areas of the stored PFB, but it's unlikely that the overall results obtained would have changed. The overall conclusion reached was that, based on this study and a comparison with other comparable situations (leaf and yard waste compost), PFB land application would not be expected to release significant bioaerosols. This is supported by the data. It was also acknowledged that this was not an examination of actual bioaerosols produced during application of PFBs. 8 627 B) Evaluation of the Scope of the Study to Assess Benefits of Soil Quality and Crop Growth The scope of the study was sufficient to evaluate the soil and crop benefits. However, questions on the duration of experiments and methodologies employ raise questions on the validity of results. The 2-year duration of the study would be considered the minimum time that would be expected for the soil and crop benefits arising from any soil treatment. While the N x PFB experiment was conducted for 2 years, the management experiments on the timing and method of PFB application were only conducted for a single year. A single year of data is certainly not sufficient to make any management recommendations. Details on the experimental design and methods of the soil quality assessments are absent or incomplete. Similarly, descriptions of methodologies for the N x PFB experiment do not provide enough information on actual N application rates. Without this information, it is difficult to understand or interpret the treatment comparisons. The incomplete description of methodologies frequently left members of the review team trying to guess what researchers had done. Conclusions: The Soil Resource Group has concluded that the benefits study as submitted does not satisfy all of the criteria set out in Section 43 (d) of the Provisional Certificate of Approval. The benefits study is clearly wanting in scientific rigor in both analysis and interpretation of the resulting data. Failure to provide detailed descriptions of methods used in the study further complicates the ability of a reviewer to evaluate the conclusions and recommendations. Many of the conclusions of the benefit study are not supported by the data. The Soil Resource Group recommends that the Regional Municipality of Durham not accept this report. 9 628 Appendix: Further Detailed Comments of the Review Team Table of Contents: References and Appendices missing Executive summary: . What is the "definition of benefit" accepted by the Steering Committee? A clear statement of the definition is required. . Comment on why Campden was added. . Define "RCB". . "Significant increase in soil microbial biomass C at 3 of the 4 sites" seems to exaggerate the situation. My reading of it is, for spring application (3 months on the field) there was an increase for 2 sites, no change at one, and a decrease at one. For the fall application (10 months on the field), there was no change at one, possibly a decrease at one, and a definite decrease at one. . Soil concentrations of the elemental contaminants were not measured; the measurements were of the concentrations of the elements in the PFB. These came below the MOE guidelines, but successive applications would have to be closely monitored for copper in particular. For example, two successive applications of 150T ww/ha would likely exceed the 5 year guideline. . In Elora, Cambridge and Vineland, did all the plots have 2 applications over the two year study - spring'99 followed by fall'99 or spring"OOapplied? Or were all of the plots separate? It is very unclear in this study exactly how the plots were treated. And this makes interpretation difficult, and if there are successive applications in the same plots, the treatment effects will be skewed. Introduction l.l Background . P7, 2nd paragraph Cite references. . MOE guidelines limit application to 30T/ha; this level was not used in the study. . Part 4 ?? (erosion study) not present. . Part 5, microbiology was specifically listed in the requirement criteria"(#7), therefore it should not be "for information only". 1.2 Contents of Draft Report . Only 2 sections listed, not the 5 stated. Literature Review . 2.1 Discuss differences in PFB, papermill biosolids, and primary, secondary and tertiary biosolids. Not all of the studies referred to utilized primary biosolids, as were used in the current study. The differences may not significantly affect the result, but they should be made clear. Also it should be made clear that some of the studies refer to reclamation of 10 629 strip mine sites, which are likely to be significantly different from the agricultural lands used in the current study. o Effect of the time limitation of this study made apparent in 2.2.2 and 2.2.3 (Zibilski et al 2000). o Gregorich et al. Reference is 1994 in the Reference section. o There is duplication of the last part of page 9 on the top of page 10. o There is several lines missing between pg 10 and 11. o 2.4 The discussion of Henry'91 would be better in 2.5 (Crop performance). Also, explain primary and secondary PFB (see previous comments). Benefits Study Research Program Laboratory studies o 3.1 Give details of the "moisture content, pH" and "sufficient nutrients" used, particularly with respect to N. Field research o 3.2.1, Quantification of impact with increasing rates of PFB application was not achieved. o 3.2.1, pg 15 Should read 2 loamy soils. o The soil in Durham and Victoria counties (where the PFB is currently being spread) is largely heavy clays. Why wasn't this soil type chosen initially? o Table 3 does not list initial metals in soils, as stated at the bottom of pl6 (nor are there final soil concentrations reported in this study). o Table 3: Elora P level of 2.25 is likely an error in view of the previous site use. o Table 4: define TS, LOI, and TKN for the reader. o Table 5: add pH data, since this was measured in the field (Results, p63). o Table 6: Exec. Summary states that soybeans were planted in '99 followed by com in '00. Table 6 gives com and soybeans for Spring and soybeans for fall, so what were the treatments for the successive years? o 3.2.3.2 State that "delayed incorporation" was ca 6 wks. o 3.2.4: How were the plots sampled? Would the variability have been reduced by using a composite sampling technique for each of the plots? Soil Quality Indicators o Table 8: Change to "Processes" o Table 8: infiltration (under Aggregation) is the same as Water Infiltration Field Research Program o Describe the sampling procedures. o Table 9: Define what theta measurement is for the reader. 11 630 · Table 9: Irregular management practices were used, ego irrigation. Furthermore, the schedules for some soil parameters sampling were not shown. · Somehow make it clear to the reader the sequence of plots from one year to the next: ego Are the same plots treated with the same PFB concentration in the two years succeeding? Are the fall plots also treated in the spring? If the first answer is yes, and the second no, then a comparison of spring and fall data do not does not reflect the same level of PFB application. Without being clear on this sort of methodology, an analysis of the report relies on a lot of guesswork. · 5.2 Uniformity of application using the equipment described is questionable. · 5.2 What was the source of the fall application PFB? . 5.2/5.3 How was the Fall application of PFB done? · 5.4 How did the soybean and corn seeding and fertilization procedures differ? With a range of P soil test of 2 to 50 and a K test of 57 to 166 (Table 3), it is unlikely a 0-20-20 fertilizer would meet the OMAFRA fertility recommendations. · 5.5 Calculations are given re the N addition based on PFB application rate. Tables list NA for 0 PFB rates as well; what are these levels based on ? · p28 Since the initial level of nitrogen fertility at all cites exceeded OMAFRA recommendations, the probability of a nitrogen response was low. · Table 13: doesn't agree with Tables 9 and 10 for crops. . p29, 2nd last paragraph, 4th last line: remove "received" · p29, second last line, the time difference between PFB application and corn seeding is ca 6 weeks according to Table 9, not the two weeks stated. · Table 14: This table doesn't seem to make sense; 3'd and 5th columns are the same. Would a statement suffice? Impact of PFB application on soil quality indicators Bulk Density · To what depth was the core removed for measurements. · Discuss the changes in control bulk densities from '99 to '00, especially at Elora. · Tables 15 & 16. The data would be more striking if it were presented in graphical format including the resulting linear regression equation and the statistical parameters of the regression equation. A table of the simple relevant ANOV A data should accompany the presentation of the data. · p34, 6.2.2 A significant increase was observed. Surface Water Infiltration . Should the value for infiltration read X IO~s and not X lO-os? · p34, Why discuss Block effects? A significant Block effect indicates that the variation between the spatial positions of treatments in the field was large and indicates a lack of uniformity in the site for this particular soil parameter. The author should simply state "no differences were observed". 12 631 Surface soil moisture · 6.3.1, p36: Is there any speculation for why the soil moisture content decreases with increasing N? They seem quite unconnected. . The data presented in Tables 20 to 23 does not permit the reader to analyze the N effects. . Discussion of all the Block effects does little to help answer the question. Does PFB influence the ability of the soil to retain water? Soil Aggregation . 6.4, 2nd paragraph, Angers and Mehuys'93 not in References . second line, insert "carried out". . 2nd last line, should read "should not be used" . 6.4, 3n1 paragraph, Pofasok and Kay'90 not in References. . P43, insert measured "the effects of papermill sludge in agricultural soils on" soil aggregation "by" ... . This section is filler and should be deleted. Earthworm populations · The literature should remain together in the Literature Review. It would be more useful to include a summary at the end of each Results section, and then those could be brought together in a discussion of the overall results/conclusions. . 6.5, We assume the quadrat size 0.25m X 0.25m rather than cm. · Is November late for measuring earthworm populations? To what depth does the formaldhyde penetrate, and to what depth do earthworms migrate in the fall/winter? · 6.5.3: This discussion is confusing and the statements seem contradictory. . There is no spring Vineland data reported. . Fall '00 data (from Table 10) is not reported. · p48: Again there is a long discussion of block effects which add nothing to the agronomic interpretation of the data. Soil Microbial Biomass . Seems to be glossed over and the N effect not considered. . Voroney et al'93 not in References · Table 9&10 indicate that sampling time was at com tasselling time only in '99 and in September in 2000. . 4th paragraph: add" Full results in ... " · Does the "Spring PFB application" refer to '99 or 'OO? · For the fall application, the PFB has been on the land for 10 months. For the spring application, it has either been there for only 3 months ('99) or for 16 months ('00), and have either single or double doses of PFB and N. This makes the data very difficult to assess. 13 632 · A time series of successive measurements on the same set of plots would have been more useful in determining effects. PFB degradation will happen over a prolonged period of time due to its high lignin content, and the nature of the microorganisms will change over time. It is likely that fungi will become more significant since they are largely responsible for the biodegradation of cellulose, hemi-cellulose and especially, lignins. Fungi also have a higher C:N ratio than bacteria, and this will affect the microbial biomass C and N ratios. All of this leads to difficulty in interpreting such single point (wrt time) data. Other authors have shown an increase in biomass C over time (cf Chantigny, MH et al '00) · An explanation(speculative or not) of the decrease in microbial biomass C at the Cambridge site is necessary. · Some of the data and interpretation of results do not agree: 6.6.2 Elora - fall application. Microbial biomass N showed no significant difference (Ab2a-2 statistical analysis) rather than a significant increase. . Note: In the January draft, the Table and subsequent Figure for Elora-Fall have an error in transcription of the decimal for 0 N. The corresponding statistical data appear to be correct. · Overall comments/conclusions should be added. Impact of PFB application on soil nitrogen fertility Laboratory incubation studies · 3m paragraph, last sentence: make it more clear.. ."activity" of what? . 7.1. I Include the high temperature incubation study experimental design. · 7.1.1 Does the description of the N addition mean that at each application rate NA=J? Was the N addition rate 0 at PFB = O? · 0,30,60,90 application rates did not match the field study application rates · p54 Table 24: 120, 150 and 180 tonnes/ha were not mentioned in the experimental design (p52). A separate description of the high temperature protocol would be appropriate. Why were the PFB rates so different in the two studies? · Why was the data put into an Appendix, and no stats given? · Appendix II, Figures 1. I to 1.3 have only NO] measurements, yet inorganic nitrogen (NO] + NH4) is discussed. Also, Fig 1.3 does not have treatment symbols. · P55, 4th paragraph: Cumulative CO2 production did not consistently decrease with increasing temperature.(Figs 2. I -2.6) · The purpose of this study was stated to be "to determine what rate of supplemental nitrogen to add to the treatments"(p27) No indication is found in the interpretation of this section to indicate what the rate should be. Field Studies · 7.3.1, Table 25, Is the post-harvest inorganic N, really all 0 - agrees with discussion, pg 57, but doesn't seem likely . p57, define PAN (plant available N?). Not all readers of this report will be well versed in scientific acronyms. This comment applies throughout the document. 14 633 '. . p54-62 Why is there no interpretation of any of this data? · Appendix Table AI.I: Why is there such consistent results for soil inorganic nitrogen on 1O/14/99? Absolutely no variability between treatments? . P60, line 5: What is the control? Impact of PFBs on Soil Total N, Total C, EC, and pH . Only N=I data is given. · Is there any significance in the change of pH in some applied plots? · "control" for these measurements is N=I; this should not be referred to as the control. · A statement that that no statistically significant difference was shown for increasing PFB rates in %Total C, %Total N, E.C. and pH should be made. It is only stated for %Total C . PFB Impact on Soil Metals · This information should be turned into a proper table, including calculated loads at the various PFB application rates. Include a wetdry ratio; the reader shouldn't have to search for this information. · Based on approximately 50% solids (dry weight - I assume), the application of copper at 150 ww T/ha would be about 7000g Cu/year, which is over half the total application allowed for 5 years. A comment needs to be made regarding multiple applications of high amounts of PFB over time. · Metals in soil should also have been measured - see previous comments on Executive summary. Crop Yields · P66: Standard corn moisture content is 15.5%, not 15%. · In the crop yield comparisons, it is assumed that the control referred to is the PFBO NO treatment and the PFBO NI rate is the crop required N rate (from spring soil N test) and PFBO NO.5 or PBFO N1.5 are N rates of 50% or 150% of the PFBO NI rate. These ratios are the case in 2 of 7 site/years only! The use of these NO.5 and N1.5 treatments is unclear and assumed to be... useless. · It is assumed that all the plots are receiving the same 2kgN/t PFB rate for all sites and years (without recognizing incubation study results).. . and this is always represented by the N 1.0 label when used with a PFB rate of application (>0) · If so, then the crop required N application (above and beyond the decomposition N rate) for all the com plots should be based on either I) a common rate to determine the PFB rate and N rate effects OR 2) if soil N test used by plot with OMAFRA_ recommendations to apply balance of crop required N. Neither method was used consistently throughout the study sites making comparisons of any kind (PFB rate, N rate, soil texture, etc.) difficult to interpret. · Furthermore, this is not the case as the reported "Fertilizer N Applied" (decomposition N plus crop N) indicated that i) the crop N rate where PFB applied was highly variable between PFB rates ii) the crop N rate where PFB applied was highly variable between N rates with PFB application iii) the crop N rate where PFB applied was well below the 15 634 crop N baseline PFBO NI rate (crop required N) in 5 of7 site/years iv) "Fertilizer N Applied" rates were highly inadequate to meet even the decomposition rate N at 2 site/years taking into consideration soil test results v) only at Campden in I year was a uniform rate equal to crop N requirement used for all treatments to carry out a valid statistical factorial comparison between treatments. · Again in the PBF management experiment, the reported "Fertilizer N Applied" rates of the fall applied PFB treatments do not follow suggested methodology with N fertilizer applied on control plots as well as N rates on treatment plots that do not come close to required crop N, or required decomposition N rates. · Low yield results in 2000 at Cambridge (<60bu/ac), Elora (<25bu/ac) and Campden add a lowered level of confidence with treatment comparisons in the PFBxN experiment and the PFB management experiment. · Tables 33-39: To interpret the interaction, the table should be designed as a NA rate vs PFB rate, with nitrogen applications and N03 rates in an accompanying table. Interactions are much easier to see. · Tables 35, 37: Why is there no PFB-O / N-O.5 treatment? Elimination of the treatment gives an unbalanced statistical design. · Table 37: The interpretation of the interaction is simply with N=O there was a decrease in yield due to the application of PFB, whereas at N=I.5, increasing the rate of application has no influence on the yield. · Table 39: Where there is an interaction, a polynomial contrast on the N rate main effects is not permissible because it is dependent on the rate of PFE. The interpretation of the interaction is the same as for Table 37. · Table 40, 41: Reformat incorporation letters in column. Setting up the table as incorporation method vs PFB rate is more informative · pp73-75: Why is the statistical presentation changed throughout? Cf: Tables 26, 28 and 40. None of these provide the simple ANOV A required for the basic understanding of the data being presented. · p75, 10.4: The first sentence should also be included in the procedures section in order to make things clearer. It is assumed that these plots hact no PFB's added in spring'99; what about spring' OO? · p75, 10.4.1: The discussion is different from Table 42. 100T/ha appears to have had a lower yield than the 0 application rate. . p76. Paragraph I should refer to the page number for the spring results (pg 68). · 10.4.2: Second last line: should it read "lower" rather than "higher yields" · p77: Refer to p70 for the spring results. · p78: Refer to p72 for the spring results. . p78: last sentence: "For...not a significant result". It is a very significant <esult because it demonstrates that the trend toward higher yield with PFB was true. but at a lower level of significance. In other words, it shows that PFS did not have a detrimental effect. · A preferable presentation would be to have the average yields for PFB vs N, spring and fall, for Cambridge, Elora and Vineland, presented together. Again it makes the interactions much easier to see. . p79, 10.5.2: Statistically significant Block effects do not add to the study. 16 635 " Summary . pS2, 11.1, 4th line: Bulk density measurements were only done on the soybean plots. . pS2, 11.1, Sth line: Soil infiltration was increased... at some of the research sites. . pS2, 11.2: Again, the metal concentrations (esp. Cu) seem to indicate the possibility of accumulation of levels in excess of MOE guidelines if applications were made in successive years. No data is reported on metal concentrations. . pS3, 11.3: No data was presented which could be used to suggest any effect on com or soybean germination. . pS3, 11.3: There is no comment on the effect on microbial biomass. If this is a summary, then all parameters measured should be comment on. . PS3, 2nd para., Is the control referred to N=O or N=I.O? If N=1.0, then most PFB treatments received insufficient crop N. . pS3, last sentence: The author drops this comment in the Summary for data not yet presented, and which was not a part of the original objective of the experiment. Management recommendations . 12.1.1: What data supports these recommendations? If recommendations based on general principals are to be made, they should be discussed as such. (Note: general comments on storage cover should also then be included.) . 12.1.2: No evidence was presented to indicate there is any preferred texture or any texture that should be rejected. . 12.1.4: This section does not provide useful information. . 12.1.5: Differences resulting from the 3 management practices used did not seem that clear cut in the results. . 12.1.5: The weed data presented does not support the conclusion that surface application is better than immediate incorporation treatment. . 12.2 Increased com yields were not proven for PFB application. At best, it can be stated that overall, at N=O, there was a decrease in crop yield, whereas at N=1.5, crop yield was maintained with increasing PFB rates. . pS6, 12.3: "The results of this study suggest that soybeans grown on a variety of soil types will benefit... "Soybean yields responded well to ratios of PFB application... ""However, the overall results indicated that PFB applications had no significant effect on soybean yields. Which of these statements is correct? . P86, 12.3: last paragraph: Strictly guessing. References . Several references are missing. . Gregorich el al is out of order 17 636 ~t:.r- 1 ( C\O\01 1\0=::10 rr<. .....U"dlM'.1 ~L.1.:l1Uf'l Mt::.HLlnt:J.J '-tvu .lJ;:J.l r-.\:::Ic:/06 r-. Gartner Lee Limited 1 ~o Renfrew DrIVe SU~e 102 Markham,Ontc:ulo L3R 683 Tel: (905) ~77.8400 Fax: (905) ~77 -1456 www.QClrfnerlQs.com r- Environmental Services SJhce 1973 Offices . vancouver . Wltllel'loA;8 . VeJJowtnlfe . co/gary . TO/onto . Sf. CafhariMS . BraCJ3bfJdge . Montreal . Hal/fa:.! ~ A Member 01 ffipvimnmental ,:)trategles ALLIANCE I V ,,:;:n::.l.JOc::....J:.:J (.1 r July 30. 2001 ATTACHMENT 2 GLL 21-348 Mr. A.C. Wong Manager, Environmenllll Health Health Department The Regional Municipality of Durham 1615 Dundas Street East Suite 210 Whitby, Ontario LIN 2Ll OO[j({f'OW~@ JUL 3 1 2001 HEAlTH DEPARTMENT: Dear Mr. Wong: Re: SamDlinl! and Analvsis of Pal)el' Sludl!e at Oshawa Skeet and Gun Club. Oshawa We are pleased to present the results of a sampling and chemical analysis program recently carried out at the Oshawa Skeet and Gun Club, just north of Oshawa on Purple Hill Road. A henn, comprised of approximately 27,000 m3 of "Sound-Sorb" was recently constructed on-site and has raised concern with a local citizen's group, Protect the Ridges, about the potential migration of contaminants from the berm by inftltrating leachate and airborne solids. The citizen's group also indicated that the illegal disposal of sewage WElSte may have excurred during construction of the benn and that contaminanlS nonnally associated with sewage may also exist. Backl!:round A literature review and a background investigation were carried ouLprior to the field component of the project. "Sound-Sorb" Is a mixture of waste paper sludge, also known as paper fibre biosolids (PFBs). and 30 % sand. The PFBs are a by-product of the paper recycling process and are regulated by the MinislIy of the Environment (MOE) for disposal on agricultural lands, in an effort to reduce the quantity disposed at landfill sires. The PFBs' were hauled by C6urtice Amo Wreckers who also haul sewage sludge under MOE authority. Concern was raised over the composition ofPFBs and sewage sludge and their potential as a source of contamination when applied intensely to the smail footprint of the berm. The literature indicated that waste paper sludge varies in composition depending on the source marerials and their manufacturing prexess. Typically, the PFBs contain short paper fibres, clay. and chemicals such as [hose used for deinking, ink and dye residues and surfaclants. Regular testing of PFBs is carried OU[ prior to their use as a soil amendment, however, the analytical protocol is typically restricted to nutrients and heavy metals. Also of concern is the possibility of bacteria; fungi including toxic molds; organic contaminants such as dioxins and forans. known to exist in some sludges; and additives such as nonylphenol emoxylale, which has been linked to human health problems. The identified compounds could also be found in sewage sludges. 637 ..:1'-1 ! I <-"-'''-'-L -L"-"o-"'-' .., -~"'''''' "~'""~......." "....".......- , . ~~. "'-'U .~ Page 2 The Regional Municipality of Durham July 30. 200 1 r-- Exlstlnt! Site Conditions The berm lies in a valley between two treed ~as at Ihe south end of the rifle range. The lop is relatively flat and the sides ~ sloped at approximately 1:1. It was recently covered by 0.15 to 0.30 m of compost material and was graded smooth. No vegetation was growing on the berm when we visited the site. We were informed by members of the Protect the Ridges group that the berm. prior to covering, had a relatively hard crust approximately 2.5 cm thick: over its surface. Two drainage pipes exist beneath the berm. One protrudes from the lowest-lying area of the north side of the benn and had a small trickle of dark: coloured liquid from it. The glOI1Ild surface at the outlet was dark coloured. wet with some puddles, and had a pungent odour similar to sewage. A larger diameter pipe protruded above the ground surface in the lower-lying western end of the south side of the berm and Sloped downward into the berm. The purpose of these pipes was not apparent other than to possibly conduct drainage beneath and a way from the base of the berm. The ground surface surrounding the berm was dry except at the outlet of the northern pipe. SamDlint! and AnalYsis r-- On June 21, 2001, Gartner Lee limited staff. in the presence of a local council nl"mtw>r and representatives of the Regional Municipality of Durham Health Department and the Protect the Ridges group, collected representative samples of the "Sound-Sorb" material and leachate trickling from the pipe beneath the north side of the berm. A backhoe, dperatedoy a specialized contractor, was utilized to. dig ten test pits within the berm to depths of up to approximately 1.5 m. The compost cover material was SClaped aside before digging into the "Sound-Sorb". The samples were collected from the south side of the berm with five test pits dug on the eastern half of the berm at a higher elevation than the five test pits dug on the western half. The test pits walls were inspected and samples of the material from each test pit were collected and mixed in plastic bags to produce two composite samples representing the eastern and western materials. A dark coloured, odouriferous liquid with fine sediments was trickling from the pipe located on the north side of the berm at its base. SmaIl puddles of the liquid existed and were sampled. The samples were placed on ice in a cooler while in transit to Philips Analytical Services in Mississauga. who performed the analyses. The PFBs samples (east and west) were divided for solid analysis and acid leach to represent natwa.lleaching conditions. Based on the background review and lhe potential comaminants identified, the PFBs and liquid samples were analyzed for heavy metals, bacteria. fungal agents. BTEX compounds (benzene, toluene, ethylbenzene and xylenes), and nonylphenol ethol(ylates. r--- 638 (2]341) ~, L..t::.JUJ. J.t::.J........... '" -~""..," r<:.CUJ.V''l ".....n.....,IIU..... ...........'-' !..J;::IJ. IV ~\::..I..JCI'-..J-'f! r t-'.U4/0E ..~ Page 3 The Regional Municipality of Durham July 30, 2001 r- Visual observation of the test pits revealed a sand content.ofless than 10 % to perhaps as high as 25 % mixed with the grey PFBs. The sand's grain size varied from flne to coarse and tnce amounts of fine gravel existed in some locations. At the west end of the belm, a test pit revealed that a If"" stump and wood were mixed with the PFBs. Members of the Proteclthe Ridges group indicated that the PFBs material had come from a stockpile in a gravel pit nearby, and the stump may have been transported with it. Also apparent within the test pits were isolated layers of dark fine grained material. The moisture content. varied with depth in the berm, as did the temperature. At the base of the deeper test pits (1.5 00) the berm material was wetter, hot to touch and more odouriferoWi. These conditions reflect the biological activity that is occurring within the berm. Results of Chemical Analvses r-- The results of chemical analyses are summarized on Table 1 for the solid PFBs samples, their respective leachates and the liquid collected on-site. The metal and ion scans indicated aluminum. arsenic, calcium, chromium, copper, iron, magnesium, manganese, nickel, strontium, titanium, vanadium, zinc. potassium, sodium, and phosphorus had concentrations above the method detection limits in the solid phase. Based on the expected composition of the PFBs including clay and paper fibres. inks and dyes, the identified par.uneters were predicted. The leachate concentrations of the compounds analyzed. which approximate the available concentntions resulting from in situ leaching that are available for runoff and infiltration, were greatly reduced, typically to below detection. Concenlrations of BTEX compounds and nonylphenol ethoxylates were reported as below method detection limits or non detectable. The solid samples were analyzed for E. coli. total colifonns and Klebsiella. Of these bacteria, only total coliforms were identified at concentrations of 1,400 and 9.700 CFU/IOO mL for the east and west samples, respectively. The fungal agents, Aspergillus and Stachybotrys, were not detected in the solid samples. The results of chemical analyses of the liquid sampled from the discharge of the pipe indicated detectable concentrations of heavy metals, major ions and bacteria. The results indicate a contribution from organic matter resulting in high concentrations of potassium (2,610 mgIL) and phosphorus (11.8 mgIL). Relatively high concentrations of calcium, magnesium, aluminum and sodium and a more basic pH (8.25) suggest a potential impact from the clay component of the PFBs. Relatively high concentrations of iron and manganese suggest reducing conditions are likely within the berm. Nonylphenol ethoxylates were Dot measured above the method detection limit. Bacteria were measured within the liquid at the following concentrations; E. coli 10,000 CFUlIoo mI.; fecal colifonns 40.000 CFUIIOO rnL; total coliforms 900.000 CFU/lOO rnL; and a heterotrophic plate count of 8.000 CFU/l rnL. The heterotrophic plate count indicates an organic carbon SOurce is present. The presence of E. coli and fecal coliforms links the liquid to human/animal sewage. .--. 639 (21.348.) <-t.JUJ. It:,.Jo'-''-t "~ --.'"'''' r-;.C.U!VI'l IILnLllleJ..J ....WW J.-'-Jl r'.l15/06 Parameter UnilS PFB. -East Leachate . PFBI- Leachate - Uquld Solid /LIquid East West West DR 7.93 7.73 8.25 SiI_er DDm IDldl. <1 <0.01 <I <0.01 <0.001 AlwniDum DDm mg/L 2.900 3,830 45.5 Al"IJenic DDm mg/L 33 <0.2 43 <0.2 0.07 Barium mWL 0." 0.4 0.60 Beryllium rnwL <0.01 Bismuth mgJL <0.01 Boron Ill2Il. <0.1 <0.1 2.21 Calciom DPm m..n. 80.800 83,200 537 Cadmium Dom IIWl <0.5 <0.05 <0.5 <0.05 0.003 Cobalt Dom mgll <2 <2 0.215 Chromium DUm Il1g/L 8 <0.1 13 <0.1 0.1] CODner Dom m~ 96 0.007 109 <0.005 0.176 Iron DUm mil 1980 3,440 59.3 Potassium ppm mil 251 592 2,610 Mallll..;um ppm IIIJfIL 1,670 2,130 151 Muluneoe "IlIlm mWl. 105 140 2.58 Mercury mwL <0.01 <0.01 Mol_beI.num ""Ill mwL <3 <0.0] <3 <0.01 0.01 Sodium DUm ml!1L 575 599 822 1II1ckel ppm m2IL 4 7 0.48 PhOSDhorus ""m m211. 4fr7 464 11.8 Lead ppm moil <S <0.1 10 <0.1 0.486 AnUmony . IIlllIl 0.007 SeleuiUDI . . mgll <0.1 <0.1 0.02 sm..... IIlllIl 58.2 nn moil 1.56 Strontium ppm mwL 74.5 97.6 1.28 TitaJdum .ppm IDldl. 53 107 . 1.56 Tha1Ilum mWL 0.0007 Uranium mg/L <0.01 <0.01 0.003 VaDadium oom mg/L 5 9 0.118 Zinc DDm mlllL 63 0.18 76 0.10 0.601 Benzene DOm ml!1L <0.02 NO <0.02 NO ToIu.ne ppm IDldl. <0.02 NO <0.02 NO . ElhTlbeuo.ne Will IIlRIl <0.02 NO <0.02 NO mllcp.XyI...... ppm ml!iL <0.04 NO <0.04 NO ...Xvlene DUm IIIJfIL <0.02 NO <0.02 NO E. ""U CFU/. CFU/loo lllL NO NO 10,000 Fecal CoIitorms CFU/loo rnL 40,000 Total CoUtorlDS CFU/I CAJ/loo lllL 1,400 9,700 900,000 Total Plat. Coun. CFUII lllL 8,000 KkbJielJJz spp. CFU/. NO NO MDe",iJIMJ 'pp. CFU/. NO NO St4ehybotn. ."", CFU/I NO NO Nony]ph.no] mg/L <0.1 <0.1 <O.OS ethOXYla~ .,.~ Page 4 The Regional Municipality of Durham July 30, 2001 f" Table 1. ,-- ,-- Note: ND indicates pt1.n:J.tr,,:ter was non derer:rable. '(\ ,<oJ '-'eJ'-'wL0.....rll Results of Chemical Analysis 640 m,.., SEf-' 1( C:IOI:::JJ. J.I:::J~.J",* Ir<. .lJur<.nHI.1 r-<::t:.l.:Il UI'4 nc.nl.... I Il~-' .....'-''-' 1...J~! . '-' -'LO-,.......~......-"..' ..100./106 ~'.~ Page 5 The Regional Municipality of Durbam Jttly 30, 2001 1". Interuretatlon The presence of a hard crust on the steeply sloped sides of the berm suggests that the majority of falling precipitation hitting the berm would runoff rather than infiltrate. The moist conditions observed within the test pilS dug, however, indicate that some infiltration does occur, Due to the absorbency of the paper fibre it is unlikely that much leachate is fanned and released from the berm. Moreover, resnlts of chemical analyses of the leachate fonned from acid leaching of the "Sound-Sorb" material indicate low concentmtions of metals and major ions would be present in any leachate formed in situ, Bacteria and fungal agents (based on those specifically analyzed) are nOl of concern. Only tol8l colifonns were present lUld these bacter18 are ubiqllitous in nature. The liquid trickling from the base of the berm is questionable. Measured concena:ations of boron, chromium, copper, molybdenum, lead, and zinc were higher than the respective concentrations in the paper sludge leachate. Since the liquid samples were collected from puddles, these higher concentmtions could be the result of concentration of the liquid due to evaporation. The presence of E. coli in the liquid, wben it was nOt detected in the solid phase, and the presence of feeal colifonns suggests a strong link of the liquid to human/animal sewage but nOl to the "Sound-Sorb" material. From this, one would have to cOIlclude that anOlher Source of the bacteria, other than the paper sludge, exists within the berm. It may be concluded, that this source of bacteria is likely sewage sludge that ,...--.. was disposed of near the base of the berm. We trust the infonnation presented in this repon meets your present requirements. Should you have questions or ~ish to discuss the findings further, please call the undersigned at extension 216. Yours very tnJIy, GAR'INER LEE LIMITBD ~ir~ Donald F. McQuay. B.A.,P.Ag. Earth Scientist Principal OL T:lm<: ,... 641 <"W> ** TOTAL PAGE.06 **