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Atlantic Packaging Ltd. Paper Fibre Biosolids:
Regulation 347 Waste Classification

Introduction

Atlantic Packaging Ltd. is a paper recycling company. Wastewater produced at the plant during the paper-making process contains suspended solids consisting of clay and short paper fibres. Subsequent de-watering leaves a paper fibre biosolid waste, which is used by Courtice Auto Wreckers Ltd. to produce a material called Sound-Sorb. Sound-Sorb is produced by mixing the paper fibre waste with mineral soil. Sound-Sorb is currently being used to construct sound and bullet attenuation berms at gun clubs in Ontario. Once the paper fibre waste has been used to produce Sound-Sorb, it is no longer subject to the Ministry of the Environment’s waste management regulations and the Environmental Protection Act. The ministry’s waste management regulation, Regulation 347, contains a provision that exempts wastes that are transferred directly to a site, wholly used in a process for purposes other than waste management, and then offered for retail sale.

The public has expressed concern that berms built of Sound-Sorb will adversely affect human and environmental health. In response, the ministry tested the Atlantic Packaging paper fibre biosolids and the Sound-Sorb material for over 90 different elements and compounds. A report describing the results of this testing was completed in June, 2002. With the exception of total petroleum hydrocarbons (TPH), toluene, free cyanide and chloride, all parameters measured were present in concentrations lower than those found in soils in Ontario which have not been subject to contamination by commercial or industrial activity (Table F. Guideline for Use at Contaminated Sites in Ontario). Only TPH was found in the berm at a level which would prompt remedial action if the soil on the site contained a similar TPH concentration and the site were to be redeveloped. The risks to human and environmental health associated with the TPH levels in the berm are currently being addressed in a Site Specific Risk Assessment (SSRA). In addition to the SSRA, other work currently under way to address recommendations made in the June, 2002 report, include well monitoring and further testing of the Sound-Sorb material. A study that assessed the potential for the berm to generate aerosols containing harmful bacterial and fungal spores has recently been completed and a panel of scientific experts to review all existing and new scientific information has been established.

Concerned citizens also asked the ministry if the paper fibre waste used to produce Sound-Sorb would be considered as a hazardous waste under our waste management regulations. Regulation 347 provides the process and structure under which waste is classified as either hazardous or non-hazardous. The Toxicity Characteristic Leaching Procedure is one measure used to determine if waste is hazardous. The procedure involves mixing the waste material with a prescribed solution for a prescribed length of time to determine if there are measurable contaminants. This procedure is outlined in Regulation 347. It is designed to represent the contaminant concentrations that might be expected through prolonged leaching of a material under natural environmental conditions.

In order to classify the waste used in the making of Sound-Sorb, the ministry performed the Toxicity Characteristic Leaching Procedure prescribed in Regulation 347, on paper fibre biosolid waste produced by the Whitby and Scarborough plants of Atlantic Packaging Ltd. This report discusses the results obtained from the leach test.

Sampling and Analysis

The Toxicity Characteristic Leaching Procedure prescribed in Regulation 347 is the process used to characterize waste for the purpose of classifying it for disposal. The procedure involves leaching a sample of the waste with acetic acid and measuring the concentrations of a large number of contaminants. The result for each contaminant is compared to the concentration listed for that contaminant in Schedule 4, Regulation 347 of the Environmental Protection Act. If the concentration equals or exceeds the prescribed concentration listed in Schedule 4, the waste is considered to be a “leachate-toxic waste”. Disposal of leachate-toxic wastes must occur at an approved facility in accordance with the generator registration and manifesting requirements of Regulation 347. If the concentrations for all contaminants are lower than those listed in Regulation 347, the waste is characterized as non-hazardous waste and the waste is not subject to generator registration and/or manifesting requirements.

Results and Conclusions

Attached are the results as compared to Schedule 4 of Regulation 347. Regulation 347, Schedule 4 consists of a total of 88 parameters, including Benzene, Benzo(a)pyrene, Cadium, Dioxins/Furans and Vinyl Chloride. There were no exceedances of any of the Schedule 4 parameters in either the Whitby or Scarborough plant biosolids. The results presented indicate that the paper fibre biosolid waste produced by Atlantic Packaging Ltd. is not a “leachate-toxic waste” and, therefore, not a hazardous waste.

References

Ontario Ministry of Environment and Energy, (2002). Atlantic Packaging Ltd. Paper Fibre Biosolids and Sound-Sorb Berm, Oshawa Skeet and Gun Club: Results of Chemical and Microbiological Testing. Central Region, June 2002.

 

Ontario Ministry of Environment and Energy, (1997). Guideline for Use at Contaminated Sites in Ontario (Revised, Feb.1997), Queen’s Printer, Ontario.
Ontario Environmental Protection Act, Ontario Regulation 347