Comments regarding An…

Comments regarding An improved regulatory framework for non-agricultural source materials - Draft EBR Consultation only December 20, 2007 Authors: Elisabeth Groeneveld, biologist, M.Sc. and Marc Hébert, agr., M.Sc. Ministère du Développement durable, de l'Environnement et des Parcs Direction des politiques en milieu terrestre, Service agricole 675, boulevard René-Lévesque Est, 9e étage, boîte 71 Québec (Québec) G1R 5V7 Téléphone: Elisabeth (418) 521-3950 # 4978 | Marc (418) 521-3950 # 4826 Courriel : elisabeth.groeneveld@mddep.gouv.qc.ca | marc.hebert@mddep.gouv.qc.ca 1.General comments Categories and sub-categories: The overall method of categorizing materials based on the six categories, with sub-categories for metals, pathogens and odour is useful and easy to understand. A similar approach is used in Québec. However, single letter-number abbreviations would be visually simpler (e.g. M1-P1-O1 versus CM1-CP-1-COA1) References: It would useful to have references cited in text – this would indicate to the reader the scientific basis (or other) for the regulation. Metals: For the sake of harmonizing various criteria across Canada, we suggest that the best category (CM1) correspond completely to the CCME category A for composts. To have a limit of 100 mg Cu is not justified, as this number cannot be met by many farm manure composts. This leads to a double standard in Ontario for copper. On the other hand, residuals with higher trace element content than CCME category B for compost should not be allowed. Ontario is the only province in Canada to allow such high levels of heavy metals (34 for cadmium, 1100 for lead and 11 ppm for mercury). Most countries in Europe do not allow these kinds of residuals to be land applied. Furthermore, these high numbers do not promote source reduction. Since attaining the CCME category B criteria is feasible in Ontario (according to calculations by Michael Payne), why keep the old numbers? 2.Section 16.0 Minimum beneficial quality requirement (page 15) In Québec, we also include NASM that improve the physical properties and biological activity of the soil. For example, a NASM that is high in organic matter but low in plant nutrients could be a NASM. Also, a NASM not meeting the requirements for nitrogen, phosphorus or potassium may increase crop growth (as demonstrated by field trials), due to micronutrients, for example, but would not be included in this framework, according to your definition. Is slaughterhouse sludge considered a NASM? 3.Section 18.0 Criteria for pathogens The use of E. coli as an indicator: In Québec, all purpose biosolids and composts (P1) are not analysed for E. coli since there may be regrowth, particularly with paper mill biosolids and mature composts. A slight regrowth of E.coli is not a risk indicator. We rely on salmonella as an indicator of pathogenic bacteria destruction for the P1 category. We discussed these issues with Mrs Fleming. What allowances are made if a single sample has a higher level of E .coli than permitted, but the mean still meets the requirements for CP1? 4.Section 18.1 Designation and determination of pathogen sub-categories Papermill biosolid sub-categories: Québec no longer requires the analysis of E. coli to determine the pathogen status for P1 categories, for all biosolids, including paper mill biosolids. To be considered CP1, paper mill biosolids which have not been contaminated by human fecal matter must meet the following criteria: Salmonella undetected in 10 g wet weight, for residuals with a ≥ 15 % dryness (or in 50 g wet for other residuals), and written attestation from the paper mill’s environmental officer that no municipal or domestic wastewater is discharged into the industrial wastewater treatment system. “Special case: a paper mill biosolid that has not been contaminated by human fecal matter, and which is accompanied with the necessary attestation to this effect, will be deemed category P1 if no salmonella is detected in at least two-thirds of samples tested over the last 12 months.” In Québec, papermill biosolids contaminated with human fecal matter are considered municipal biosolids, and are subject to the same pathogen rules. We have abandoned the use of fecal coliforms for paper mill biosolids, because of false positives due to Klebsiella, which led to an unstable pathogen classification for certain paper mill biosolids (sometimes P1, sometimes P2) and thus, higher costs for the mills. See the references below, and Addenda #1 and 2 on the internet: -Archibald, F. 2000. The Presence of Coliform Bacteria in Canadian Pulp and Paper Mill Water Systems – a Cause for Concern? Water Qual. Res. J. Canada. Vol. 35 no. 1, pp: 1-22. -Beauchamp, C.J., A.-M. Simao-Beaunoir, C. Beaulieu et F.-P. Chalifour. 2003. Coliform bacteria in paper sludges: where are they coming from? In: Proceedings of the 2nd Canadian Organic Residuals Recycling Conference. Penticton, B.C. April 24 and 25, 2003. pp.:248-258. -Gauthier, F. and F. Archibald. 2001. The ecology of “fecal indicator” bacteria commonly found in pulp and paper mill water systems. Wat. Res. Vol. 35, no 9. pp. 2207-2218. -Hébert, M. 2005. Pathogènes dans les biosolides municipaux et autres MRF : normes et critères de bonnes pratiques. Agrosol, December 2005. [On line] http://www.mddep.gouv.qc.ca/matieres/articles/index.htm 5.Section 19.6 Winter application The main risks from fall/winter application of NASM are linked to the NH4 loadings and impacts on surface waters. In Québec, the agrologist who writes the agro-environmental reclamation plan must include the risk of N and P loss from fall/winter application in the plan. Marc Hébert, of the MDDEP has written an article on this topic: Fall spreading of fertilizing residuals  environmental risks and preventive measures. Agrosol 16(1) June 2005 http://www.mddep.gouv.qc.ca/matieres/articles/index-en.htm The Ordre des Agronomes du Québec has issued directives concerning fall spreading based on the C/N ratio. The same rules apply to both manure and residuals. Therefore, criteria for nitrogen in the Québec regulation or Guidelines are not necessary. 6.Section 23 Sampling and analysis (page 30) In Québec, an independent quality control is required for biosolids. This quality control is performed by accredited sampling firms. Both sampling and analyses are done by certified organizations. This reduces the need for verification by MDDEP staff. 7.Other minor comments -The scientific names of organisms should be italicized, e.g. E. coli. See http://www.journal.au.edu/au_techno/2001/oct2001/howto.pdf for more details. -Page 27, last paragraph Instead of using a analytical results -Page 31, 3rd paragraph, 2nd line the NASM must be sampled and analysed for pathogen once -Page 30, section 23.0. Please define cessation trigger.

[Original Comment ID: 104695]