I continue to have concerns…


I continue to have concerns on recycling spent asphalt (RAP) and road concrete on the floor of an aggregate operation, 2 m above the water table/30 m away from a body of surface water, without any measures to mitigate leaching (retaining barriers as an example). As I understand the state of Illinois has banned RAP at aggregate sites. In Europe, outside Amsterdam, RAP is processed inside a specially designed facility, to control leaching and air-born particulates. Better controls, based on sciences, ought to be studied and incorporated into the rules and regulations as more and more pits are encouraged to recycle. Please note the attached MSDS from the aggregate industry.

I have spoken at length with MOECC who states the following in an email chain (available upon request)

- The MOECC has stated “possible environmental concerns related to storage and processing of RAP may include leaching to groundwater, runoff (surface erosion) of RAP, runoff of leachate and deposition of airborne material to soil.” And that “Asphalt is a complex, high molecular weight mixture that often contains metals like lead, arsenic and nickel; volatile organic compounds (VOCs); polycyclic aromatic hydrocarbons (PAHs) and crystalline silica. RAP material contains asphalt plus a variety of chemicals generated from traffic. There can be considerable variability in the composition of RAP.”

- The MOEC further states “Environmental concerns could potentially be addressed via best management practices (e.g., leachate testing, dust suppression, controls to prevent runoff, etc).”

Up to now, to my knowledge the subject of recycling asphalt has not been adequately discussed by the MNRF, MOECC nor the Ministry of Health.