Sludge Watch ==> In the 'They Told You So' Dept - Ontario paper sludge berm fails

[Maureen Reilly]

Sludgewatch Admin:

Here is one for the Ontario Environment 'Wall of Shame'.

The Ontario government has been taking an increasingly bizarre approach to 
waste.
They have been achieving 'waste diversion' by letting industry call its a 
waste a 'product' and then allows them to buy a farm field and load that 
field 30 feet deep with a decomposing industrial waste.

In Pelham Ontario, Lyle and David Brenzil of Empire Agri-Services (remember 
these guys? ... the ones putting hot Toronto sludge pellets in storage in 
Thorold until the fire dept came?)  brought out hundreds of thousands of 
tons of paper sludge to a farm field saying they were making a berm to 
protect a cucumber greenhouse from the sound of passing trains.  (yes...you 
heard me right)
So the Ministry of Environment says..."ok.  Great idea.  Good thing you 
aren't calling it fertilizer or else you would be polluting the environment 
with a pile 30 feet high. But since you call the stuff a 'berm' then its ok" 
(!)

The Brenzils don't even have a waste hauling license (somehow they lost it 
when they stopped working for Terratec -American Water Services- Ontario's 
megasludgers), but since they claimed to be hauling berm materials, the 
Ministry said it was a product, not a waste.

Where does the stuff come from?  Abitibi Paper Mill in Thorold Ontario 
provided the putrescing paper sludge.

Now I see the ownership of the site has changed hands.  But why did our 
government allow this gross contamination of this neighbourhood with 
pathogenic waste?  Why put drinking water sources, groundwater, surface 
water at risk? Why destroy the quality of life in this nice rural 
neighbourhood?

Because this government's idea of waste management is to allow industry to 
rename its waste...and then after they contaminate the environment the gov't 
runs after them with pathetic and expensive remediation requests.

Why doesn't the government follow the advice of their own Expert Panel, and 
require this paper sludge to be managed as the waste that it is and always 
was?


Go to the website of the Association of Public Health Associations and 
follow their recommendations.
All  these recommendations to protect public health are being ignored by the 
Ministry of the Environment.

http://www.alphaweb.org/land_use1.asp



............................................................................




Ontario  Ministry of the Environment Provincial Officer Order Number 
7567-6WQGKS


To
Greenland Greenhouses Inc.
4027 Aberdeen Rd
Lincoln, Ontario, LOR 1 B6
Canada

Dirk Breugem
4027 Aberdeen Rd
Lincoln, Ontario, LOR 1B6
Canada
S
Site
325 Church Street
Pelham, Regional Municipality of Niagara
Observations


In May, June, July and August 2006. a berm consisting of a mix of pulp and 
paper biosolids (PPB) and mineral soil was constructed (hereafter referred 
to as the “PPB berm”) on the above noted site which operates as Greenland 
Greenhouses Inc. (“the site”). The site was previously owned by Mara 
Greenhouses Inc. and was transferred to Greenland Greenhouses Inc. on August 
24, 2006- Greenland Greenhouses Inc. is the current registered owner of the 
site, as listed on Land Registry Office #59 Property Identifier 64028-0050 
(LT). Dirk Breugem is a Director of Greenland Greenhouses Inc. and as such 
has management and control of the site- The PPB benn was constructed on the 
south east side of the site, adjacent to a Canadian Pacific Railway (CPR) 
railroad track.
The site is currently under order as outlined in Provincial Officer Order 
6268-6RGQ2U (which is attached to this Provincial Officer’s Order 
7567-6WQGKS as Schedule 1), which was issued to Mara Greenhouses Inc. and 
James Grove, director and officer of Mara Greenhouses Inc., who also has a 
financial interest in Greenland Greenhouses Inc. This order is also binding 
on successors Dirk Breugem and Greenland Greenhouses Inc. as outlined under 
Section 190) of the Environmental Protection Act.
Between May 17,2006 and January 10, 2007 I inspected the site on numerous 
occasions and observed evidence of visible seeps discharging from the toe of 
the PFB

Pg 2

berm, which has a characteristic sheen and odour. I have also observed 
“contaminated run-off’. which consists of leachate, leachate-contaminated 
surface water and any other run-off which has come into contact with the PPB 
benn on the site, particularly along the east side of the PPB berm, which is 
currently surrounded by a containment berm and ditch which was erected 
on-site in an attempt to prevent off-site discharges of contaminated 
run-off. There is also a large quantity of contaminated mn-off which is 
being collected in a pond and containment area located north west of the PPB 
helm.
Since May 2006, I have continued to inspect the site on over 40 occasions 
and have observed on-going leachate seeps discharging from the PPB berm and 
have also observed contaminated run-off migrating off-site onto the CPR 
railway ditch, consisting of discoloured brown and black surface water which 
is puddling in a depressed area outside the containment helm and ditch and 
migrating for approximately 10 metres along the CPR ditch towards the Nunn 
Drain, which forms part of Coyle and Crane Creeks and eventually discharges 
to the Welland River. samples taken of the standing water located off-site 
indicate that the ponded areas around the PPB berm are showing impacts from 
leachate to levels that are of concern, including such parameters as BOD and 
total ammonia.
Between June 2006 and December 2006. numerous samples of this contaminated 
run-off have been taken by the Ministry of the Environment (“the Ministry”). 
The results have been reviewed by the Ministry’s surface water experts who 
have commented that the contaminated run-off has been shown to have high 
concentrations of phosphorus, Biochemical Oxygen Demand. tin-ionized 
Ammonia, TKN,. E coli, Total Alkalinity and Conductivity. It is the Ministry 
surface water experts’ opinion that if discharged to a receiving 
watercourse, the contaminated run-off has the potential to cause off-site 
impacts to the natural environment and could cause an adverse effect to the 
aquatic environment in the Nunn Drain.

Numerous e-mails, including correspondences dated September 20, 2006, 
October 12, 2006 and December 6, 2006 have been sent to Mr. Breugem, 
advising him of the on-site and off-site conditions which have been observed 
by the Ministry and requesting that he undertake measures to ensure adequate 
containment of contaminated run-off on-site. To date, adequate measures have 
not been undertaken by the owner to address off-site migration of 
contaminated run-off

I attended the site most recently on December 21, 2006 and January 10, 2007 
and once again observed numerous leachate seeps near and at the base of the 
PPB berm and contaminated run-off which had accumulated on the east side of 
the PPB berm and outside the containment berm and ditch area, indicating 
that contaminants have migrated off-site. I have also observed flow of 
contaminated run-off discharging from the containment berm area migrating 
off-site and accumulating on the GPR property. The accumulated contaminated 
run-off within the containment berm area was noted to be brown in colour 
with some light surface foam/scum in areas and had a detectable sewage-type 
odour.
Betwcen June 2006 and December 2006, field measurements have been taken on 
and off-site of this contaminated run-off in. The dissolved oxygen (DO) 
readings of the contaminated run-off sampled within the containment berm 
area and along the CPR property ranged from less than


Pg 3

0.39 mg/L - 1.53 mg/L and had high conductivity readings ranging from 1713 
-2820 uS/cm. The DO and conductivity levels found in the contaminated 
run-off which is accumulating in the containment berm and migrating off-site 
are indicative of leachate impacts and impaired water quality which if 
discharged, may adversely impact the natural environment.
Various assessments have been undertaken on-site, as required by Provincial 
Officer Order 6268-6RGQ2U to assess the integrity and adequacy of the 
current contaimnent measures on-site. A report prepared by AeonEgmond Ltd. 
entitled “Report on Site Findings MOE Order:
6268-6RGQ2U, Sound-Sorb Berm, Man Greenhouses Inc., 325 Church Street, 
Pelham” dated August 11, 2006 was submitted to the Ministry. The report 
included an evaluation of the current on-site contaimnent measures and 
recommendations for long-term containment Options to prevent the discharge 
of any contaminated run-off from the site. The report concluded that the 
current contaimnent berm erected on-site was “of poor construction, of 
uneven compaction and uneven strength ... and unsuitable for long term 
containment of the surface. leachate or other water flows “. The consultants 
also commented that “on-site containment measures appeared inadequate and 
recommendations were made to remove the clay containment berm and replace it 
with a new clay berm and drain “.
Furthermore, a site assessment report dated December 6, 2006 conducted by 
Jagger Films Limited also commented that the containment beat, ‘appears to 
he poorly constructed and water is able to seep through or beneath the 
containment berm, especially the north-east and eastern portions of the PFB 
berm “. The engineering firm further concluded that ‘surface water adjacent 
to the containment berm east of the property is likely influenced to some 
degree by impacted water from the PFB berm area ... and that there is a 
potential that run-off and leachate from the PFB berm area could adversely 
impact local surface water “.

Tn December 2006, Totten. Sims Rubicki Associates (TSR) conducted an 
assessment of the current on-site containment measures and made 
recommendations in an e-mail correspondence dated December 23, 2006 (which 
is attached to this Provincial Officer’s Order 7567-6WQGKS as Schedule 2) to 
address off-site migration of contaminated run-off, which included:

• Re-grading and building up of the containment berm along the CPR rail line 
and south side of the site to direct the surface water to the existing 
containment pond and to prevent surface water from migrating off-site;

• Repairing the slumped areas of the containment berm by adding clay and 
compacting as much as possible given the site conditions and water content 
of the clay; and

• Pumping the ponded water on-site and disposal of contaminated run-off at 
an approved treatment works.

Furthermore, a correspondence dated January 9, 2007 from TSR (which is 
attached to this Provincial Officer’s Order 7567-6WQGKS as Schedule 3) 
included additional recommendations to mitigate off-site migration of 
contaminated run-off from PPB berm and the site, which included:



Pg 4

• Filling the existing pond and low-lying areas with on-site clay to prevent 
the accumulation and potential migration of contaminated water off-site;

• Raising the containment berm along the CPR track to prevent off-site 
surface water migration;

• Developing a swale between the PPB berm and the containment berm along the 
CPR track and east side of the PPB berm which would allow surface water to 
flow from the east side of the site to the main collection pond;

• Re-profiling the existing swale along the west side of the PPB berm to 
allow surface water to flow to the main containment pond; and

• Continuing to withdraw surface water from the main containment pond for 
discharge to an off-site location.

I have spoken with Mr. Breugem on numerous occasions and have advised him 
that additional actions are required to ensure that there are no off-site 
discharges of contaminated run-off. I have repeatedly informed him of my 
site observations and advised him that as owner of the site, he must ensure 
that all necessary measures are undertaken to maintain containment of any 
contaminated nm-off on the site. In particular, Mr. Breugem was verbally 
directed to forthwith take measures to ensure containment of contaminated 
run-off on-site in a meeting held at the Niagara District Office on December 
22. 2006.

It is my opinion as a Provincial Officer that although numerous requests and 
directions have been provided to the owner to maintain containment of 
contaminated run-off in the contaimment berm, ditch and collection pond on 
the site, there is evidence of off-site migration of contaminated run-off 
and appropriate steps have not been taken to date by the owner to prevent 
these on-going discharges. The sample results of the contaminated run-off 
on-site show this material to be characteristic of sewage. Given the sample 
results, the above noted site observations, and report submissions produced 
by AeonEgmond Ltd., Jagger Rims Ltd. and Totten Sims Rubicki Associates, it 
is my opinion that the potential exists for off-site adverse effects from 
the contaminated run-off, Therefore, the requirements of this Order are 
necessary so as to prevent the risk of discharge of a contaminant into the 
natural environment from the site.
This Order is being issued pursuant to my authority under Sections 157.1 of 
the Environmental
Protection Act (EPA ). This Provincial Officer’s Report forms part of 
Provincial Officer’s Order
7567-6WQGKS. This Provincial Officer’s Order is supplementary to Provincial 
Officer’s Order
6268-6RGQ2U, which has not been revoked and remains in effect.

Sylvie Chartrand
Provincial Officer
Badge Number: 746
Date: 2007/01/19
District Office: Niagara District Office