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CACG/RFU Letter to Province re: Sludge as Fertilizer |
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.....What we do understand is that pulp mill waste sludge is a cocktail of
solid chemical residue left over from the industrial processes going
into manufacturing and bleaching pulp and paper. It is known to
contain heavy metals and a variety of persistent organic pollutants
such as dioxins and furans. Fly ash also contains dangerous levels of
toxic chemicals. To consider these materials as ‘soil enhancement’ is
surely a distortion.....
November 24,
2005
Cindy Bertram
C Rankin and Associates
Suite 4 – 1462 Rockland Ave.
Victoria BC V8S 1W1
Ms. Bertram,
In response to the recently posted intentions paper
entitled Soil Enhancement Using WastesCode of Practice, the Crofton
Airshed Citizens Group (CACG) and Reach for Unbleached (RFU) would like
to express their adamant protest of passing such legislation.
Despite repeated attempts to discover the chemical composition of the
sludge from the Crofton mill of Catalyst Paper that is burned in the
power boiler, we have to date received no information. There is a
clear absence of information on what would be introduced into the
environment with such a practice. It is critical that any
practice as potentially damaging as this proposal be introduced with
full information and clear parameters for the decontamination and
testing to ensure no harm to human health, wildlife or the environment.
What we do understand is that pulp mill waste sludge is a cocktail of
solid chemical residue left over from the industrial processes going
into manufacturing and bleaching pulp and paper. It is known to
contain heavy metals and a variety of persistent organic pollutants
such as dioxins and furans. Fly ash also contains dangerous levels of
toxic chemicals. To consider these materials as ‘soil
enhancement’ is surely a distortion.
While our position remains that there is no problem with landspreading
composted and decontaminated waste sludge if it can be proven that
there are no dangerous toxins left in it, the current proposal includes
no decontamination criteria or testing regimen. This is essential to
ensure that there is no chance of exposing the food chain to persistent
pollutants that bioaccumulate in humans and wildlife.”
The intentions paper refers to a limit on dioxins and furans for waste
that would be eligible for landspreading, but such a limit is
necessarily arbitrary with no reliable testing criteria to ensure
compliance. There is no exclusion for any other chemicals or
compounds of concern.
We believe that the acceptable limit for some of the most dangerous
chemicals known is zero. There should be no allowance for release
of waste into the environment that has any chance of containing these
chemicals. The waste from pulp mills is well known to contain
levels of dioxins, furans and other persistent organic pollutants.
We submit that this proposal for a code of practice allowing use of
hazardous material as soil enhancement is shortsighted, dangerous and
should proceed no further without detailed analysis and examination to
ensure the protection of health and the environment.
Thank you for your time,
Rob Wiltzen for
Crofton Airshed Citizens Group
Delores Broten for
Reach for Unbleached
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