Nova ScotiaEnvironmental NetworkConnecting for a Sustainable Future

BIOSOLIDS & WASTE WATER CAUCUS

Kenneth Moses, CADMunicipality of the District of Yarmouth932 Hwy #1, P.O. Box 21Hebron, Nova ScotiaBOW 1XO

Dear Mr. Moses:

115 Eden Row, R.R. #2 Wolfville, NS, B4P 2R2www. http://nsen .ca/biosol ids. ph p

October 14th, 2010

Some months ago, the Biosolids & Waste Water Caucus has raised numerous concerns to your members ofCouncil in the Municipality of the District of Yarmouth about the unknown fate of multiple organic and inorganiccontaminants, in addition to numerous other pathogens and carcinogens that exist in sewage sludge.

To briefly summarize, we spoke about the mechanisms during treatment processes for removal of thesesubstances as being largely non-existent. It is speculated that there is a potential for the spread of infectiousviral, prlon, parasitic or bacterial diseases via air, food or water transport mechanisms. The Caucus has alsoraised concerns that the onus of responsibility for negative impacts to the environment, livestock, and publicsafety may fall onto the end use, the farmer. Farmers are being told that biosolids are safe when, in fact, noevidence exists to demonstrate such a claim. New research findings are determining the opposite and numerousscientific papers have been published to show that land application of biosolids is contaminating the soils,groundwater and surface waters with persistent pollutants and carcinogens. These substances, over time, affectsoil fertility, wildlife reproductive health, and are responsible for increased incidences of food-borne illnesses andother diseases in humans and livestock.

The Caucus has brought these issues to the attention of numerous other municipalities in Nova Scotia to broadentheir awareness of this farming practice within their boundaries and to warn of the potential risks to theenvironment from the use of biosolids being utilized as a fertilizer on agricultural land.

Kings County Council made a motion, in a packed Council Chamber on October 29th, 2009, that they would be

notifying the Department of Environment of their intention to seek approval to ban the land application ofbiosolids in the county. In a letter dated November 2nd

, 2009, Kings County Council requested that theDepartment of Environment take immediate action to halt the application of biosolids on farmland in KingsCounty until the questions raised about heavy metals and persistent chemicals were addressed. MinisterBelliveau responded by stating, "The department does not have a mandate to restrict the use of approvedproducts or to prevent land use activities in specific counties of the Province." After sending correspondencefrom the Caucus, regarding the same request to the Department of Municipal Affairs, Minister Jennex respondedthat, " .....the Municipal Government Act does not give municipalities the ability to prohibit the application ofproducts such as biosolids on private property ..•..."

Since that time, the Biosolids Caucus has collaborated with East Coast Environmental Law to retain a lawyer toresearch the question whether municipal governments have the authority to enact and impose by-laws thatprohibit the use of treated sewage sludge (biosolids) on private property. I have attached a copy of that letter

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(File No. 1038169) from the Lawfirm of Burchells LLP,which confirms that municipalities do, in fact, have thatright under the Municipal Government Act. A copy of this legal opinion is attached for your files.

The Biosolids Caucus has compiled an extensive list of farms who do not use biosolids and who have indicatedthat they wish their farms to be included on this list. A copy of the List of Farms Not Using Biosolids is attachedfor your use. (Updated versions at: http://nsen.ca/biosolids.php).

An additional 1,000+ signatures have been obtained - in addition to the 3,200 signatures already presented tothe House of Assembly in May, 2010 - on a Petition asking for a moratorium on the land application of biosolidsand that our local and provincial governments seek alternative strategies for disposing of or utilizing biosolids asan energy source. These signatures will be presented to the House of Assembly in the very near future by a partycaucus member on our behalf. (Kings County holds, for safe keeping, a copy of the majority of all petitionsignatures collected throughout the province).

The Caucus has recently finished its response to the Canada-wide approach to managing municipal wastewaterbiosolids. I have attached our document for your review. It was very interesting to note the findings and finalrecommendations of the researchers who had completed this study on some of the emerging substances ofconcern (ESOC). A few pertinent points include the statement that researchers faced "budgetary constraints"and had to limit the range of contaminants to study and report onl Why would a federally-commission study ofhealth and environmental risks of land applying biosolids have any budgetary constraints? That is notacceptable. It was unfortunate that thallium was not included (a real concern in cement kiln dust which is used ingreat quantity in the N-Viro product) in the heavy metal study. Out of hundreds of potential pharmaceuticals inuse, only a few dozen were chosen and no other major contaminants of concern were included in this study-such as the personal care products, prions, nanoparticles, industrial chemicals (ie. flame retardants), andhormones. Researchers found that the N-Viro treatment process utilized at the Halifax facility, earned a lowscore for removal efficiency for pharmaceuticals and heavy metals when compared to other biological treatmentprocesses. In fact, N-Viro's final product consistently showed higher heavy metal concentrations than what wasdetermined in the starting feed product.

Finally, the researchers recommended that: risk assessments be conducted on the ESOCto see if they pose risksto health or environment when biosolids are land applied; that many other ESOCsubstances be included in thestudy to round out the knowledge of ESOCbehavior in biosolids treatment processes; and, that more studies bedone on certain treatment processes to determine whether they could be improved upon (a copy of that CCMEstudy has been enclosed).

Unfortunately, the CCME's approach to establishing a Canada-wide approach to manage biosolids is to just glossover the scientific conclusions and recommendations and favour the continued application of contaminant-ladenbiosolids to our soils. Very little discussion in the CCME's approach to managing biosolids concerns the beneficialconversion of wastewater sewage sludge into renewable energy sources.

Recently, the province has asked the Caucus to identify the names of these farmers using biosolids. The provincecertainly has access to a complete list of all users. Although the Caucus does have firsthand knowledge aboutseveral farms utilizing the product, it is not our "position" to expose the identity of users for fear of creating harmto them or to members of our Caucus. We have elected, instead, to highlight those farms that do not usebiosolids. The Biosolids Caucus has filed a FOIPOP application for a list of users and the distribution of wherebiosolids are being land applied (agricultural, forestry, parks, recreational, landscaping, sod companies, etc.) byeach approved processor in Nova Scotia.

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The Biosolids Caucus is hopeful that an interest in establishing a ban on the use of biosolids on agricultural landsby the majority of municipalities within the province of Nova Scotia will be demonstrated and that your concernswill be brought forward to members of the UNSM for consideration at the next board meeting.

We look forward to hearing from you in the near future of such a welcome initiative and would appreciate anyassistance from your municipality in advancing my proposal for a presentation to the UNSM within the nextmonth or so.

Dr. Marilyn Cameron,Chair, Biosolids & Waste Water Caucus(tel) 902 542-5330(email)p.m.cameron@ns.sympatico.ca

Cc: Janelle Frail, Executive Director, Nova Scotia Environmental NetworkLyle Goldberg, Union of Nova Scotia Municipalities

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LLSLLP

August 31,2010

VIA E-MAil: P.M.CAMERON@NS.SYMPATICO.CA

PRIVilEGED AND CONFIDENTIAL

Dr. Marilyn Cameron, ChairBiosolids and Wastewater CaucusNova Scotia Environmental Network115 Eden Row, R.R. #2Wolfville, N.S. B4P 2R2

Dear Dr. Cameron:

Re: Municipal Authority to Restrict Application of Biosolids

Facts

Barristers & Solicitors1801 Hollis Street, Suite 1800Halifax. Nova ScotiaCanada 83J 3N4t. 902.423.6361f. 902.420.9326www.burchells.ca

Derek A. Simondir. 902.423.8363dsimon@burchells.ca

File No: 1038169

The Halifax Regional City (HRM), as part of its new wastewater treatment project, has builta biosolids processing facility (BPF). Biosolids from the three new wastewater treatmentplants and the existing Aerotech plant are trucked to the BPF. A company named N-Virohas an operating contract for complete operations of the BPF plus approvals, marketingand distribution of the product. Approximately 35,000 tonnes of N-Viro Soil is produced peryear. It is anticipated that 60% will be distributed for agricultural purposes and 40% will beused for topsoil manufacture, sod growing, horticulture and land reclamation.

The Nova Scotia Environmental Network is a non-partisan umbrella organization forenvironmental organizations in the Province. The Biosolids and Wastewater Caucus of theNSEN is made up of citizens and representatives of organizations who are deeplyconcerned about the application of biosolids-based fertilizer to agricultural lands for anumber of reasons related to public health. In particular, the fate of multiple organic andinorganic contaminants in the material, in addition to numerous other pathogens andcarcinogens, is largely unknown. Mechanisms for removal of these substances are largelynon-existent. It is speculated that there is a potential for the spread of infectious viral orbacterial diseases via air, food, or water transport mechanisms. The Caucus is concernedthat the onus of responsibility for environmental, livestock, and public safety may fall ontothe end user, the farmer. The high cost of fertilizers is making biosolids a more attractivechoice as a soil amendment for some struggling producers in rural Nova Scotia.

#472197.2

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The Caucus has raised this issue with numerous municipalities in Nova Scotia. TheMunicipality of the County of Kings has been in correspondencewith the provincial Ministerof Environment regarding this issue. Their Council's Committee of the Whole passed thefollowing resolution, which they sent to the Minister of Environment in a letter datedNovember 2, 2009:

That Council ask the Minister of Environment take immediate action to halt theapplication of biosolids on farmland in Kings County until the questions raised aboutheavy metals and persistent chemicals are addressed.

The Minister responded in a letter dated November 19, 2009. The Minister cited therevised Guidelines for Land Application and Storage of Municipal Biosolids in Nova Scotia(the "Guidelines"). The Minister then went on to state:

The department does not have a mandate to restrict the use of approved products orto prevent land use activities in specific counties of the Province.

The Caucus has written directly to the provincial Minister for Service Nova Scotia andMunicipal Relations to express their concerns. In an e-mail dated December 11, 2009, theMinister of SNSMR noted the Guidelines, and suggested the Caucus express theirconcerns to the Minister of Environment. In an e-mail dated January 12, 2010, the Ministerof SNSMR stated that:

Service Nova Scotia and Municipal Relations has taken the position that MunicipalGovernment Act does not give municipalities the ability to prohibit the application ofproducts such as biosolids, on private property. The application of biosolids ismanaged through the Guidelines for Land Application and Storage of MunicipalBiosolids.

You provided us with a copy of the Guidelines, revised in March 2010. The documentstates that its purpose is "to define quality standards for municipal biosolids, to facilitate theuse and storage of municipal biosolids on land and to establish when such land applicationand storage would require an Approval from the Department." The Guidelines set out twoclasses of municipal biosolids:

• Class A, which are treated and stabilized to meet certain standards, and which arenot considered to be generated waste, wastewater or wastewater sludge whichwould require an approval in accordance with section 23 of the Activities DesignationRegulations (the "Regulations") under the Environment Act (the "Act"); and

• Class B, which are not treated and stabilized to meet certain standards, and whichare considered to be generated waste, wastewater or wastewater sludge whichwould require an approval in accordance with section 23 of the Regulations.

The Guidelines go on to-set out the quality criteria and standards. Section 5.6 is entitled"Conformity with Municipal By-Laws" and states that:

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An application for Approval of land application and/or storage of Class B municipalbiosolids must include a letter from the municipality stating that the proposed activityis in conformity with municipal by-laws as outlined in Schedule 3. Proponents mustalso obtain any required municipal approval, permit or other authorization from thelocal municipality. Applicants must check with municipalities to identify thelocation(s) of source water protection areas and to determine whether or not landapplication and/or storage of Class B municipal biosolids is permitted in these areas.

Schedule 3 does not address municipal by-laws, and there is no schedule that does so.

Section 3(1) of the Regulations states that "Any activity designated in these regulationsrequires an approval from the Minister or an Administrator designated by the Minister."Section 23 of the Regulations states that "The application to land of non-livestockgenerated wastes, wastewater and wastewater sludges is designated as an activity."

Issue

You stated the issue as follows:

Biosolids manufactured from treated sewage sludge are being used as fertilizer onagricultural lands in Nova Scotia. Citizens and communities are concerned that thismaterial is detrimental to human health and the environment. The Committee of theWhole of Kings County Council passed a motion to send a letter informing theProvincial government that they intend on placing a ban on the spreading of treatedsewage sludge (biosolids) in Kings County. The Minister has responded that themunicipality does not have the authority to do so.

You requested our advice and opinion on whether a municipality in Nova Scotia hasauthority to prohibit the application of products such as biosolids on private property.

Summary of Opinion

It appears that a municipality in Nova Scotia has the authority to pass a by-law to prohibitthe application of biosolids on private property if such a by-law were passed to protect thehealth, well being, and safety of persons or property in that municipality. The municipalitywould have to show some proof of the potential for harm to health, safety or well-being.The proof should be sufficient to show a risk of serious or irreversible damage. Proofshould include evidence of resident's concerns, as well as scientific evidence such asscientific studies or papers.

A prohibition should not be in operational conflict with provincial law and policy on biosolids.Municipal by-laws can set a stricter standard than federal or provincial laws.

The by-law would have to be local in nature. It is doubtful that it could prohibit thetransportation of biosolids through the municipality. The by-law should avoid discriminatingbetween users or uses or types of land, unless this is necessary to the by-law's purpose.

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Finally, the by-law should include enforcement provisions to ensure that it is followed. Thiswould include compliance and inspection procedures, fines, penalties and offences,directing the remedy of a breach, and impounding and disposing of vehicles or machinery.

Analysis of Law

The leading case on municipal authority to pass by-laws regarding environmental matters isthe 2001 decision of the Supreme Court of Canada in Spray- Tech1

• The court consideredthe authority of a municipality to pass a bylaw which restricted the use of certain pesticideswhich were approved under the provincial Pesticides Act. The court looked at two mainissues:

1) whether the municipality had the authority to pass the by-law; and2) whether the by-law was inoperative because it conflicted with federal or provincial

law.

Courts will also consider other related issues including whether the by-law is prohibitive orregulatory, and whether the by-law is local in nature.

Municipal Authority

A municipality is a statutory body with delegated powers under the Municipal GovernmentAct (the "MGA'). Municipalities may exercise only those powers expressly conferred by theMGA, those powers necessarily or fairly implied by the expressed power in the MGA, andthose indispensable powers essential to effecting the purposes of the municipalcorporation." This includes what are called "general welfare" powers. General welfarepowers allow municipalities to "respond expeditiously to new challenges facing localcommunities, without requiring amendment of the provincial enabling legislation"? In NovaScotia, The general welfare provisions are found in section 172 of the MGA, which reads:

172 (1) A council may make by-laws, for municipal purposes, respecting(a) the health, well being, safety and protection of persons;(b) the safety and protection of property;[...]

Courts will generally respect the responsibility of elected municipal bodies, and should onlyfind that a municipality has acted beyond its powers where this is clearly demonstrated.Where powers are not expressly stated, but can be implied, courts apply the "benevolentconstruction" rule to determine whether the power was implied."

1Hudson v Spray-Tech, 2001 sec 402 Spray tech, at paragraph 183 Spray tech, at paragraph 194 .Spray tech, at paragraph 23, quoting with approval the following statement by McLachlin J. (asshe then was) in Shell

Canada Products Ltd. v. Vancouver (City), [1994J 1 S.c.R. 231, at p. 244

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Municipal by-laws should be interpreted so that they are in line with the purposes ofmunicipal corporation. By-laws "must have a reasonable connection to the municipality'spermissible objectives"." In Nova Scotia, the functions of a municipality are to:

(i) provide good government,

(ii) provide services, facilities and other things that, in the opinion of the council, arenecessary or desirable for all or part of the municipality, and

(iii) develop and maintain safe and viable communitles."

In Spraytech, the court found that the Town's pesticide by-law fell within their power underthe general welfare provisions of the Quebec municipal legislation. The court stated thatthe by-law "responded to concerns of its residents about alleged health risks caused bynon-essential uses of pesticides within Town limits." The court went on to say that "it isreasonable to conclude that the Town by-law's purpose is to minimize the use of allegedlyharmful pesticides in order to promote the health of its inhabitants. This purpose fallssquarely within the "health" component of s. 410(1)."

The court in Spraytech also observed that to read the general welfare provision so as topermit the pesticide by-law is in accord with international law and policy, including theprecautionary principle, which it defined as "Where there are threats of serious orirreversible damage, lack of full scientific certainty should not be used as a reason forpostponing measures to prevent environmental degradation."?

The Spray tech decision has been followed in a number of other cases." Most significantly,in Ferme I'Evasion,9 The Quebec Superior Court upheld a municipal by-law prohibiting theimportation, storage and application of biosolids in the municipality.

In Ferme I'Evasion the by-law had been passed primarily due to concerns about the effectof biosolids on rivers and streams in the municipality. The court found that the by-law wasa valid use of the municipal authority over matters relating to the environment, asspecifically set out in the Quebec Act (there is no equivalent provision in the MGA).However, the court considered the decision in Spray tech , and the general welfareprovisions. The court noted that the municipality was trying to protect the health of its

s Spray tech, paragraph 266 Municipal Government Act, s. 2(c)7 Spray tech, note 1, above, at paragraph 27sIn 4500911 Manitoba Ltd. v. Stuartburn (Rural Municipality), 2003 MBCA122, the Manitoba Court of Appeal upheld amunicipal by-law which regulated intensive livestock operations. In Croplife Canada v. Toronto (CitY),2005 Canlll15709(ON C.A.), the Ontario Court of Appeal upheld the authority of the City of Toronto to passa by-law restricting the useofpesticides, finding that the Ontario Municipal Act was not significantly different than the Quebec legislation consideredin Spray tech.9 Ferme l'Evasion inc. c. Elgin (Municipalite du canton d'}, 2009 QCCS4386. This caseis currently under appeal to theQuebec Court of Appeal.

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citizens,"? and seemed to imply that it would have been prepared to uphold the by-lawbased on the general welfare provisions.

In Ferme CEvasion, the municipality employed an environmental consultant who conducteda study on the effects of biosolids. Although the evidence of the municipality's expert hadbeen attacked by the expert for the plaintiff, the court noted that the absence of scientificcertainty should not serve as a pretext to prevent the adoption of measures to protect theenvironment." In other words, the court again applied the precautionary principle.

Operational Conflict with Federal and Provincial Laws

In considering whether a municipal by-laws conflicts with federal or provincial laws, courtswill apply what is called the "impossibility of dual compliance" test: there is only conflict if itis impossible to comply with both sets of laws at once. A by-law is not void or ineffectivemerely because it imposes a higher standard of control than federal or provinciallegislation. A true and outright conflict only arises when one enactment requires one to dowhat the other forbids. The mere fact that there is provincial (or federal) legislation relatedto a certain subject matter does not prevent the municipality from regulating the subjectmatter. A potential inconsistency is not sufficient to invalidate a by-law; there must be areal connlot."

The court in Spray tech considered the argument that the pesticide by-law conflicted withthe federal Pest Control Products Act and the Quebec Pesticides Act. According to s. 102of the Pesticides Act, as it was at the time By-law 270 was passed:

The provisions of the Pesticide Management Code and of the other regulations ofthis Act prevail over any inconsistent provision of any by-law passed by amunicipality or an urban community.

The court found that the Pesticides Act envisioned the existence of complementarymunicipal by-laws and gave the municipalities the right to regulate pesticides, provided thatthe by-law was not incompatible with the regulations and the Management Code enactedunder the Pesticides Act. And in this case, it was found that By-law 270 and the PesticidesAct could coexist. The court also noted that the definition of "pesticide" in the by-law wasthe same as in the provincial laws.

In Ferme rEvasion, the plaintiff tried to argue that the municipal by-law was in conflict withthe provincial Environment Act and a provincial policy on biosolids. However, the courtnoted that the policy actually seemed to contemplate the involvement of municipalities inregulation of biosolids. The court concluded the by-law was not incompatible with theprovincial laws or policies, noting (at paragraph 206) that it was possible to follow the by-

10 Ferme L'Evasion, at paragraph 18111 Ferme L'Evasion, at paragraph 17712 Spray tech, paragraphs 36-39. 41

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law and the provincial laws and policies, even if the policy was considered to be more thanjust a statement of intention. As such, the court upheld the by-law.

It is worth noting that in this case the Province's Guidelines contain a section regardingconformity with municipal by-laws. This section clearly contemplates that both the provinceand the municipality may have regulationswith respect to biosolids.

Prohibition vs. Regulation

The court in Sprayteoh also considered two principles of delegated legislation: that a by-lawmay not be prohibitory and may not discriminate unless the enabling legislation soauthorizes. The court found that although the by-law on its face was drafted as aprohibition with exceptions, it was not purely prohibitive in nature. The court also found thatwhile it discriminated between cosmetic and non-cosmetic uses of pesticides, that thediscrimination was necessary to achieve the by-laws objectives.13

However, the MGA states, at s. 172(2} that "subject to Part VIII, a council may, in any by-law (a) regulate or prohibit;". In other words, municipal by-laws in Nova Scotia can beprohibitory.

Local in Nature

The court in Ferme L'Ev8sion made the point that by-laws cannot have the object ofexercising influence outside of the municipality, and have to bring a specific benefit for thecitizens of the rnuniclpality." The court found that there was a benefit for the environmentand the citizens of the municipality.

Enforcement

There are a number of enforcement options available to a municipality under the MGA. Inparticular, section 172(1)(1} provides that a council may make by-laws for municipalpurposes respecting the enforcement of by-laws made under the authority of a statute,including

(i) procedures to determine if by-laws are being complied with, including enteringupon or into private property for the purposes of inspection, maintenance andenforcement,

(ii) remedies for the contravention of by-laws, including undertaking or directing theremedying of a contravention, apprehending, removing, impounding or disposing,including the sale or destruction, of plants, animals, vehicles, improvements or otherthings and charging and collecting the costs thereof as a first lien on the propertyaffected,

13 Spray tech, at paragraph 5514 Ferme L'Evasion, at paragraph 188

Page 8August 31, 2010

(iii) the creation of offences,

(iv) for each offence, imposing a fine not exceeding ten thousand dollars orimprisonment for not more than one year or both, including the imposition of aminimum fine,

(v) providing for the imposition of a penalty for an offence that is in addition to a fineor imprisonment if the penalty relates to a fee, cost, rate, toll or charge that isassociated with the conduct that gives rise to the offence,

(vi) providing for imprisonment, for not more than one year, for non-payment of a fineor penalty,

(vii) providing that a person who contravenes a by-law may pay an amountestablished by by-law and if the amount is paid the personwill not be prosecuted forthe contravention,

(viii) providing, with respect to a by-law, that in a prosecution for violation of the by-law, evidence that one person is disturbed or offended is prima facie evidence thatthe public, or the neighbourhood, is disturbed or offended.

Conclusion

Based on the decisions in Spray tech and Ferme L'Evasion, and the wording of s. 172(1) ofthe MGA, it appears that a municipality in Nova Scotia has the authority to pass a by-law toprohibit the application of biosolids on private property if such a by-law were passed toprotect the health, well being, and safety of persons or property in that municipality.

The municipality would have to be able to show some proof of the potential for harm tohealth, safety or well-being. The proof does not have to be conclusive, but it should be'sufficient to show a risk of serious or irreversible damage. This should include evidence ofcitizen concerns and scientific evidence.

A prohibition should not be in operational conflict with provincial law and policy on biosolids.Municipal by-laws can set a stricter standard than federal or provincial laws, so long as theydo not require something that another law forbids. In this case, the provincial Guidelinesactually contemplate the involvement of municipalities in the regulation of biosolids. Inorder to avoid conflict, it would be best if the definitions of biosolids in the municipal by-lawmatched those in the provincial laws.

The by-law would have to be local in nature. It is doubtful that a municipality could prohibitthe transportation of biosolids through the municipality if they are being applied and storedelsewhere. The by-law should also be non-discriminatory to the extent possible: it shouldnot discriminate between different users or uses or types of land, unless this is necessaryfor the by-law to achieve its purpose.

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Finally, the by-law should include enforcement provisions to ensure that it is followed. Thiswould likely include compliance procedures (including the ability to conduct inspections onprivate land), fines, penalties and offence provisions, the ability to direct remedy of abreach, and the ability to impound and dispose of vehicles or machinery that are beingused in the illegal spreading of biosolids.

Yours very truly,

DASEnel.c: Deborah Carver, East Coast Environmental Law, via e-mail

UST OF FARMS *** FOOD DISTRIBUTORS *** FOOD ASSOCIATIONS

NOT USING BIOSOUDS

• 10 Sheep Farm (Robert Cram) - Rose Bay (Iamb)• Acadian Maple Products (William Allaway) - Tantallan (maple syrup & products)• Addington Farm (George & Anne Baxter) - Antigonish (beef, lamb)• Agri-Growers (Jim Daigle) - Port Williams (fruits, vegetables)• Aldermeadow Farms (Janet Rose) - Linden (vegetables, fruit, chicken & pork)• Andres Wines ltd. (Ken Smith) - Windsor area (wines)• Annapolis Valley Peat Moss Co ltd - Berwick (growing mediums, soil products)• Ansems (Robert) Farm - Centreville (raspberries, strawberries, corn)• Anstrum's Farm Market (Erwin Andres) - Hantsport (vegetables, fruits, preserves)• Apple Tree Farm (Bruno Spieser) - Glendale (highland beef, horses)• Archibald (Lester) Farm - Upper Musquodoboit (beef, hay, grains)• Arland Farm (Andrew Marsh) - Falmouth (hay & beef)• ASL Ranch (Arnold LeBlanc) - Fort Lawrence• Austin (Wilfred) Farm - Collingwood Corner (high bush blueberries)• Autumn View Farms (Craig, Sherri, Alex Greenough) - Newport (dairy)• Avonview Farm (Allan & Joy Palmer) - Newport (beef, hay)• Bailie's Angus Meat Shop (Shirley Roberts) - River John (grass fed beef)• Balsam Country Farms (Cyril, Kathy & Jay Hiltz) - New Ross (beef, Christmas trees)• Barkhouse (Edmund) Farm - Newport (Hay)• Basinview Farms Ltd. (Arthur Woolaver) - Canning (potatoes, cabbage, broccoli, cauliflower)

• Battist (Gerald) Farm - Pictou (hay)• Barteaux (Dwayne) Farms - Annapolis Royal (fruits and vegetables)• Bayview Poultry Farms ltd. (Glen Jennings) - Masstown (eggs)• Bellemeade Farm Shoppe (Cate & David Lake-Thompson) - Mabou (dairy, lamb)• Belmont Farm & Vineyard (Andrew Daniels) - Windsor (tree fruits, wine grapes, hay, forages)• Bezanson & Chase Cranberry Co. (Blake Johnston) - Aylesford (cranberries)• Bezanson Family Christmas Tree Farm (Steve & Deb) - Waterville (u-plck balsam fir)• Bezanson Heritage Livestock (Steve & Deb) - Waterville (goat)• Blackburn (Glenda) Farm - East Noel (beef)• Blois Family Farm/East Coast Family Market (Lloyd Blois & Shelley Skedden) - Upper Nine Mile

River (vegetables, goat, lamb, beef, veal)• Blomidon Estate Winery (Janet Woodworth) - Canning (wine)• Blomidon Farms ltd./Peach Pit Farm Market (Geoff Hennigar) - Blomidon (fruits)• Blomidon Produce/Rustic Ridge Farms Ltd. (Graham Hennigar) - Centreville (tree fruits)• Blue Barn Farms (Brian Murray) - Hammonds Plains (beef, chicken)• Blue Harvest Farm (Wayne Reid) - Pugwash (wild blueberries)• Blue Ridge Farm (Jay Barkman) - Waterville (blueberries, apples)• Boates (Keith) Farm - Woodville (tree fruits, cider, vinegar, wine, U-pick fruit)• Bonderosa Farm (Jean & Donald Bond) - Upper Nine Mile River/East Gore (dairy)• Bosveld's (Hank) Fruit Farm - Lakeville (vegetables, fruits, eggs)• Bourgeois (Minnie) Farm - Lower Maccan(wild blueberries)

hard/sweet cider)• Elliott (Robert) Farm - Upper Rawdon (beef)• Ells (James) Farm - Canning (beef, hay, forage, grains)• Ellsmere Farms ltd. (Terry & Patricia Ells) - Canning (chicken, hay, grains)• Elmridge Farm (Greg & Suzanne Gerrits) - Centreville (fruits, vegetables)• Embree (Blair & Carol) Farm - Port Williams (blueberries)• Evan's (Amy & Terry) Family Farm Market and Wilmot Station Quality Produce ltd. - Wilmot

(strawberries, vegetables, eggs, chicken, turkey, lamb, sausages)• Eyking Brothers Farm (John Eyking) - Millville (field and hothouse vegetables)• Eyking Under Glass (Theodore Eyking) - Millville (field and hothouse vegetables)• Fairn (Tom & Jeff) Orchards - Annapolis Royal (fruits, vegetables)• Fancy Lake Farm (Joseph & Rae Sylvain Plante) - Bridgewater (pumpkins, strawberries)• Ferguson Brothers Farm (John & William) - Pictou (dairy)• Ferguson (Dan & Pauline) Farm - Wallace (Iamb, beef)• Foote (Trina) Family Farm - Cambridge Station (fruits, honey, cider, juice, U-pick fruits)• Forest Hills Farm (George R. Johnson) - Great Village (wild blueberries)• Forrest (Wayne) Farm - Newport (grass-fed beef)• Forshner (David & Sylvia) Farm - Pugwash (beef, hay, softwood)• Four A's Farm (Elwood MacDonald) - Stewiacke (beef, pork, goat, poultry)• Fox Hill Farm (Rick & Geneta Rand) - Port Williams (dairy products)• Frosty Maple Products (Harold David Langille)- Southampton (maple syrup, blueberries)• Fuller (Dave) Family Farm - Blomidon (chicken, grain, cold vegetable crops, corn)• G & H Beef Farm (Gary & Heather Crossland) - Mahone Bay (beef)• Gallagher (Arnold & Barbara) Farm - Kempt Shore (beef)• Galloping Cows Farm Market & Fine Foods (J. Schmidt) - Port Hood (pepper jellies, jams, fruit

sauces, wine jellies, fruit beverages)• Gamborganic Farms (Pat Gamborg) - Bear River East - (garlic, free-range chicken and eggs)• Garvie (Bill & Almira) Farm - West River Antigonish (beef)• Gates Mountain Vineyard (Margaret & Mel Waldner) - Middleton (grapes)• Gates (Doug & Marianne) U-Pick - Port Williams (fruit)• Gaspereau Vineyards (Kim Strickland) - Gaspereau Valley (wine)• Geser (Hans) Farm - Cambridge Station (fruits, vegetables, beef)• Gilbert (Karen) Farms/Spirit Reins Ranch - Parrsboro (horses)• Glencrest Farm (Jill Sutton & Harold Hill) - Maitland (vegetables, apples, beef, pork)• Glendyer Holsteins (Robert Sutherland and Mary MacPhee) - Inverness County (dairy)• Gore-Jus Greenhouses (T. Morgan) - East Gore (salad mix greens, herbs)• Goucher (Gerald) Farm & Market - Kingston (vegetables, grass fed beef, orchard fruit)• Grand Pre Wines ltd. (Hanspeter, Jurg & Anna Stutz) - Grand Pre (wine)• Grazing Acres Farm (Ken Beazley) - Nine Mile River (beef)• Haley (Wayne & Marilyn) Farm - South Rawdon (beef)• Haliburton (Richard) Farm ltd. - Avonport (grains, vegetables, tree fruits)• Halliday (Francis H.) Farm - Granville Beach (blueberries, beef, woodlot)• Hamilton (Neil & Eleanor) Farm - Upper Musquodoboit (beef, low bush blueberries)• Hank's Family Farm & Market (Conrad Diesten) - Millville (field and hothouse vegetables)• Hanna, D.L & Sons ltd. (Michael) - Parrsboro (strawberries, blueberries, rhubarb, beef, maple

syrup)

pork, veal)• Little River Shorthorns (Lealon MacPhee) - Nine Mile River (beef)• Loblaws - Super Store - GAP Program and OFFScertification - all Canadian produce• Long Point Farm (Morris & Gordon MacKinnon) - River John (beef, hay, silage)• Longspell Point Farms (Jeff McMahon) - Kingsport (grass-fed beef, free-range chicken, pork)• Lore's Strawberry Farm (Jackson Lore) - Mabou (strawberries)• Lowland Gardens (Tony & Gerrie van den Hoek) - Great Village (perennials, annuals)• Luckett (Pete) Retail Management Inc. - West Brooklyn (tree fruits, berries, grapes, melons,

artichokes, asparagus)• Lyndell (James) Farm - Enfield (Iamb)• MC Poultry (Matthew Harvie) - Canning (poultry, grain feeds)• MacBerry Farms ltd. (Dean MacAllister) - Centreville (raspberries, high bush blueberries,

arctic kiwi)• MacDonald (Douglas) Farm - Mabou• MacDonald (Doug) Farm - St. Andrews• MacKenzie (Cliff) Farm - Westville• MacKinnon (Joseph) Farm - Antigonish (beef)• MacLean, L.G. & Sons Farms - Durham (strawberries)• MacNeil's (Brendan) Family Farm - Centreville (free-range chicken & turkey, grass-fed beef)• Maple Grove Greenhouses & Farms Reg'd (Edward & Sandra Amos) - Farmington

(vegetables, herbs, flowers, greenhouse vegetables)• Maritime Pride Poultry Inc. (Bonnie Shipley) - St. Francois (eggs)• Marsh (Glen & Jean) Farm - Five Islands (beef, oats, hay, lamb)• Mason (William & Margo) Farm - Upper Nine Mile River (beef, pork, free-range eggs)• MassTown Market (Laurie Jennings) - MassTown (fruits, vegetables & meats)• Maxwell (Peter G.) Farm - Caledonia (donkeys, mules, hay, Christmas trees)• McLearn (Eric) Farm - Mount Uniacke (Iamb, hay)• McMasters (Joyce) Farm - Oxford (blueberries)• McNutt (Jim, Carole Anne, Gary & Rhonda) Farms - Springhill (blueberries)• Meadow Brook Meat Market & Farm (Jim & Margie Lamb) - Berwick (beef, pork, poultry)• Meiko Farms Ltd. (Derek Mostert) Shubenacadie (dairy, hay, mixed forages)• Meisner's, T. & P. Poultry ltd (Todd Meisner) - New Germany (eggs)• Menkhorst Farm Ltd. (Michael Te Bogt) - Grand Pre (dairy, poultry)• Millview Farm (Frank and Gail Crouse) - Stewiack (dairy)• Misty Blue Farms Inc. (Byron Balcom) - Upper Rawdon (blueberries)• Mistyhills Farm (Duncan Macintosh & Marian MacLellan) - Antigonish (dairy)• Moon Fire Farm (Kimm Kent & Domenic Padula) - Lower Burlington (vegetables, peaches,

poultry, eggs, pickles, jams, tomatoe sauces)• Morse (Andrew) Farm - Berwick (strawberries)• Morse (Harry) Farm - Berwick (strawberries, cantaloupe, vegetables)• Morse View Farm (Jeff & Josee Morse) - Kingston (dairy, beef)• Morton's Apple Acres (James Morton) - Liverpool (apples, peaches, plums, pears)• Muise Farm (Ernest Muise & Linda Boudreau) - River Philip (beef)• Mumford (Jim & Betty) Farm - Scotch Village (beef)• Murphy (W. Bowden) Farm - Port Hood (grass fed beef)• Nature's Script Farm (Franklin & Marguerite Phillips) - Great Village (grass-fed beef, pork,

• Rainbow Springs Holsteins ltd. (Craig Sarty) - Bridgewater (dairy)• Ran-Cher Acres (Cheryl Hiltz) - Aylesford (goat products)• Randsland (Bruce Rand) - Delhaven (broccoli)• Rankinville Farms (Joe van den Hoogen) - Mabou (dairy)• Ravencrest Farm (Keith & Corinne Silver) - Bewick (tree fruits, goat, lamb)• Raven Winds Vineyard (Robert & Phyllis Woods) - Bear River (grapes)• Ray & Ron Farms (Raymond & Ronald Smith) - Southampton (blueberries, hay, wood)• Redden (Angus & Debbie) Family Farm - Middle Musquodoboit (vegetables)• Redmond (Harry) Farm - River John (Iamb)• Reid (George) Farm - Halifax (blueberries)• Reimer (Henry & Anna) Farm - Upper Kennetcook (vegetables, beef, eggs, rabbit)• Rendell (Edward) Farms - Antigonish (field and hothouse vegetables)• Richards Royal Honey (Dale Richards) - Truro (honey)• River Bend Cranberries (Donald & Anne Taylor) - Lawrencetown (cranberries)• Rivers of Avondale Vineyard (LorraineVassalo) - Newport Landing (grapes)• Roberts (Cyril & Virginia) Farm - Merigomish (blueberries, vegetables, beef, hay, oats, draft

horses)• Rocaro Alpacas (Carolyn) - Upper Kennetcook (vegetables and natural alpaca fibres)• Rockloaf Farm (Sarah Nettle) - Arichat• Rocky Ridge Nursery Farms (Peter Hiam) - Port Hood (U-pick)• Rocky Top Farm (Nelson Millett & Isabel Hackney) - New Ross (grass fed beef, lamb, pork,

eggs, chicken, turkey)• Rosemere Farm (Julian& D. Phil Gwyn) - Berwick (berries, rhubarb, hay, vegetables)• Ryer (Donald & Ernest) & Sons Farm - Shelburne• Sanford (Richard & Darlene) - Centre Burlington (beef)• Sanford (Ronald) Farm - Windsor (beef, grass haylage, hay)• Sarsfield Farms Inc. (Blake Sarsfield) - Canning (apples)• Sarty (Merrill) Farm - Conquerall Mills (beef)• Sawler (Peter) Gardens - Berwick (fruits, vegetables)• Schaad (Susanne) Farm - Tatamagouche (hay, forages)• Schmidt (Daryl & Genesta) Farm - Tatamagouche• Scotian Gold Cooperative (David Parrish) - Coldbrook (apples, potatoes)• Seven Gulches Forest Products (Peter Spicer) - Parrsborro (blueberries)• Shani's Farm (Cheryl Williams) - Scotch Village (free range turkey, chicken, lamb, pork)• Sharpe (Harold & Patti) Farm - Great Village (turnips)• Sherman (Kurt & Loretta) Farm - Collingwood (beef, lamb, blueberries, Christmas trees)• Silver Rooster Farm (Alexander & Madelyn McLain) - Lawrencetown (chicken, beef, squash)• Simpson's (G & L ) Produce - Lower Debert (grapes, raspberries)• Six Season's Farms (Jeffrey & Anne Orr) - Antigonish (wild blueberries, honeybees)• Smeltzer, G.G. & Son Quality Honey Products (Gary Smeltzer) - Shubenacadie (honey)• Smit (Robert & Audrey) Farm - Shubenacadie (dairy)• Smith (Arthur) Farm - Newport (forages)• Smith (Tony) Farm - Stewiacke (beef)• Smith's Cove Estates Winery (Avril Robinson) - Smith's Cove - (wine)• South Harbour Farm (Claudia Gahlinger & Rejean Chamberland) - Dingwall (berries,

asparagus)

, .

CERTIFIED ORGANIC (also NOT using btosollds]

• Angelhoeve Farm (Angela Patterson) - Canning (pork, lamb, goat, berries, apples, cider)• Annapolis Herbs & Products ltd. - West Paradise (herbs)• Apple Lane Farm (Doug Nichols) - Berwick (apples)• Ballymena Farm (Andrew Kernohan) - Parrsboro (rye, barley, oats)• Beach Lane Lavender Farm (Dave & Suzy Belt) - River John (lavender, essential oils)• Boates Farm (Brian Boates) - Woodville (apples, pears, cider vinegar, cider, U-Pick)• Bruce Family Farm (Danny Bruce & Sandie Troop) - Bridgetown (chicken, beef, fruits,

vegetables)• Casson Family Farm (Marcus Casson) - Tatamagouche (vegetables)• Coldspring Farm (Paul & Ruth Colville) - Middleton (greens, vegetables, herbs)• Crown Jewel Resort Ranch Inc. (Nahman Korem) - Baddeck (maple syrup, honey products)• Denma Farm (Geoff Crinean & Nancy Newhall) - Tatamagouche (blueberries)• Ecocentric Farm (Eric Frank) - Avonport (vegetables, herbs)• Embree's Tree Ripened Organics (Charles Embree) - Port Williams (apples, pears)• Farmer John's Herbs (John & Heather Lohr) - Medford (herbs)• Forever Green Organic Farm & Gardens (Terrance Boyle) - Antigonish (grass-fed beef, free-

range chicken, lamb, pork, vegetables)• Four Seasons Farm (Owen, David & Nancy Roberts) - Maitland (vegetables, greens, herbs,

fruits)• Foxmill Ltd. (Peter Fuchs) - Indian Harbour (vegetable oils)• Gaia-Tree/Pinnacle Farms (Rick & Sue Cheeseman) - Roslin (heritage beef, goat, chicken,

turkey, duck" eggs)• Glenmore Industries (Jim Burgess) - Middle Musquodoboit (maple syrup, blueberries)• Glenryan Farms (Glen Covey & Kimberly Tilsley) - Margaree Harbour (free-range chicken,

grass-fed lamb, fruits, vegetables)• Goldfinch Farm (Henry & Dora Penner) - Berwick (vegetables)• Green Dragon Organic Farm (Stephan Hederich) - Tatamagouche (deer meat, greens)• Green Lane Farm (Richard Murphy) - Falmouth (hay, wine grapes)• Highland Farm (Alex DeNicola) - Newport (vegetables, sprouts, cheese)• Hinners {Richard & Barbara Jack)Farm - Southampton (wild blueberries)• Inglis Orchard View Farm (Jim & Loretta Inglis) - Tupperville (apples, apple cider, pears,

peaches, plums, cherries)• Ironwood Farm (Rupert Jannasch) - Summerville (fruits, vegetables, heirloom tomatoes)• J.C:s Certified Organic Wheat Juice Company (Joe Cogswell) - Chipman Brook (wheat grass

juice)• King Limousin Farm (Heather King) - Yarmouth (Limousin beef, haylage)• Kipawo Holsteins ltd. (Herman Mentink) - Grand Pre (dairy)• Knoydart Farm ltd. (Frazer Hunter) - Merigomish (dairy, lamb)• L'Acadie Vineyards (Bruce Ewert) - Wolfville (grapes)• Lazy Brook Farm (Darlene Hill & Gary Messom) - Waterville (blueberries, juice)• Lighthouse Herb Farm (Lloyd & Joan Ransom) - Bridgetown (berries, herbs, vegetables)• MacDonald Organic Farm (Susan Willey) - Englishtown (blueberries, wild herbs)• Maple Shade Gardens (Bernhard & Linda Loewen) - Upper Kennetcook (vegetables, hay)• Mason, J.W. & Sons ltd. (Gordon Lemmon) - Windsor (apples)

NOVA SCOTIA ENVIRONMENTAL NETWORK (NSEN)BIOSOUDS & WASTE WATER CAUCUS

POSITION STATEMENT ON SOIL APPLICATION OF BIOSOLIDS ONTONOVA SCOTIA'S RURALAGRICULTURAL LAND

Our Position:The BioSolids & Waste Water Caucus does not support the use of biosolids on agricultural soils in the Province ofNova Scotia. The Nova Scotia Environmental Network's BioSolids Waste Water Caucus promotes responsibleagricultural land stewardship practices which adhere to sustainable and ethical use of land for growing food orraising livestock. Biosolids, although recognized by the Organic Council of Nova Scotia to have some benefits asa slow release nitrogen delivery system, are deemed incompatible with organic agriculture or any other sociallyor environmentally responsible land stewardship practice and is listed as a prohibited substance by the CanadianGovernment within its own 2008 Canadian Organic Standards.

About Biosolids:Biosolids are derived from human sewage sludge from residential, commercial, industrial, hospital, and street runoff sources and are mixed at waste water plants, dewatered and transported to a facility (N-Viro Systems Canadain Halifax) for processing. During processing equal amounts of an industrial waste product, known as cementkiln dust, is added to the sludge with the intended purpose of sterilizing the product of any harmful pathogens.Although hundreds, if not thousands, of pollutants have been detected in urban sewage sludges, testing in NovaScotia is limited to 11 heavy metals, two bacteria, a handful of other substances, and nutrient composition. As of2009, N-Viro's cost for processing biosolids is $175 per tonne. The final product is currently being sold tofarmers for $19 per tonne.

The Concerns:The BWWC has numerous concerns about the overall safety of the product being used on agricultural land andsubsequently entering our local food chain and the environment of rural communities. Some classesofcontaminants that are giving cause for concern are heavy metals, volatile organics, pharmaceuticals (includinghormones, steroids, and chemotherapy drugs), flame retardants, poly-aromatic hydrocarbons, dioxins, personalcare products, pesticides, viruses, bacteria, prions, and parasites. Current industrial technologies may becreating risks of unknown magnitude for public health and these risks could last for generations given that manyof the components found in biosolids are bio-accumulative and persistent. Other components have been knownto leach into groundwater or reach other water systems via field run off while others are up-taken by plants andingested directly by livestock or humans. The fate of multiple organic and inorganic contaminants, in addition tonumerous other pathogens, is largely unknown. It is speculated that there is a potential for the spread ofinfectious viral or bacterial diseases via air, food, or water transport mechanisms. The BWWC worries that theonus of responsibility for environmental, livestock, and public safety may fall onto the end user, the farmer. Thehigh cost of fertilizers is making bio-solids a more attractive choice as a soil amendment for struggling producersin rural Nova Scotia. Concerns about the interpretation, application and enforcement of the guidelines forbiosolids use in Nova Scotia and that the risks of liability to farmers are currently not being addressed adequatelyor responsibly by government. Consumers have recently been expressing concerns that there is a lack of publicconsultation, transparency and communication with regards to the production, distribution, location of use, andcosts associated with biosolids use in Nova Scotia. Speculation exists that the increased use of biosolids in localagriculture will have a very negative impact on recent gains made promoting the Buy Local movement and that,without labeling, processors avoid being held responsible for resultant harms.

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Marilyn Cameron

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"Maureen Reilly" <maureen.reilly@sympatico.ca>"asludgewatch" <sludgewatch-I@list.web.net>Wednesday, September 29,201012:56 PMSludge Watch ==> Virginia Tech Scientists Find Nanosilver in SewageSludge

Virginia Tech Scientists Find Nanosilver in Sewage Sludgeby Gwyneth K. Shaw I Sep 29, 2010 6:53 am

Posted to: Health Care, Nanotech, Science/ Medical

Virginia Tech Scientists Find Nanosilver in Sewage Sludgehttp://ncwhavcnindependent.org/index.php/archives/entrv/virginia tech scientists find nanosilv\

(NHI Nanoblog)A team of researchers at Virginia Tech are adding to the growing body ofevidence suggesting that nanosilver-which is growing in popularity as an anti-bacterial agent-is invading our water and sewer system.Led by Michael Hochella (pictured), a geosciences professor, the team used an electronmicroscope to pinpoint nano-sized silver sulfide particles in the end-stage sludge of a municipalwater plant (in other words, they found the silver after the sewage had been treated).Their paper, which is published in the October issue of the journal Environmental Science &Technology, echoes findings of previous studies, which show bits of the material can tum up inthe water when you wash socks or aT-shirt impregnated with nanosilver, as well as in artificialsweat. As Sarah Webb reports in an item posted at Chemical & Engineering News, Hochellathinks that the nanosilver bits are binding with sulfur in the sluge, creating a new material.Hochella adds that this work underscores some of the complexity in studying environmentaleffects ofnanoparticles: "What we start with is not what ends up in nature."Nanosilver remains largely unregulated, although the U.S. Environmental Protection Agency isin the process of certifying one brand of the material, used in workout gear, as apestihttp://newhavenindependent.org/index. phpl archives/entry Ivirginia_tech_scientists _find_nan<cide.

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Marilyn Cameron

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"Maureen Reilly" <maureen.reilly@sympatico.ca>"asludgewatch" <sludgewatch-I@list.web.net>Monday, September 13, 201012:27 AMSludge Watch ==> (no subject)

http://www.emagazine.com/view/?5293

Fish on DrugsThe Mellowing of Minnows and Other Consequences of Antidepressants in the WaterBy Melissa Knopper

Minnows don't swim away from predators after they're exposed to antidepressants.© Photos: U.S. Fish & Wildlife ServiceBack in the 1990s, Theo Colborn, then-senior scientist with the World Wildlife Fund, soundedthe first alarms about endocrine disrupters. In the book Our Stolen Future (Plume) Colborndescribes her early findings that connected these endocrine disruptors-via chemicals in plastics,pesticides and. pharmaceuticals-with male fish laying eggs and bald eagle eggs crumbling intotiny pieces. Soon, scientists developed new research techniques to study these estrogen-likecompounds, which are highly active at trace levels. Now, those new research tools are putting thespotlight on an extremely persistent, and perhaps equally disruptive, group of contaminants:antidepressants.A new body of evidence is building. Study after study shows widely prescribed drugs such asProzac, Effexor and Celexa disrupt the natural order when they are excreted into the water.Scientists in Mississippi discovered antidepressants are interfering with the way tadpoles developinto frogs. They also interfere with the ability of tiny minnows to escape predators. Experts saythese early signs could point to long-term problems for the aquatic food chain as a whole.Edward T. Furlong, Ph.D., a research chemist for the United States Geological Survey's (USGS)National Water Quality laboratory in Denver, Colorado, says the reasons antidepressants wreakhavoc on fish is because they work on the body's serotonin system. Most organisms on Earthhave this important neurotransmitter in their bodies, from the tiniest nematode (microorganismsin soil) to the largest mammals and humans. Once antidepressants disperse in the environment(in this case by traveling down streams in wastewater effluent), they can affect a wide range ofliving creatures.In fish, Furlong explains, serotonin is associated with aggression, predation and escape instincts."The fish is in water continuously," he says, "so dissolved antidepressants can cross the gills24/7."USGS scientists wanted to learn more about how these compounds-found in both water andsediment-might affect fish behavior. One 2010 study produced a surprising discovery: Theantidepressants most common in stream water were not the ones that showed up in fish brains."There are many reasons why this selective uptake may occur-including differences in fatversus water solubilities of the antidepressants," Furlong says.

So what happens when fish have antidepressants in their brains? Just like people, they mellowout. Some studies showed striped bass that uncharacteristically didn't pursuse smaller fish.Another important finding showed tiny fathead minnows who neglected to swim away whenthreatened by a simulated predator.

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Dana Kolpin, a researcher with the USGS Toxic Substances Hydrology Program, says that minnowsusually react to predators with what is a called a C-start mechanism. These fish didn't. "It's an innatebehavior for fish. It's how they escape predators," he says. "They bend into a 'C' and escape with highervelocity."The researchers are still trying to discover why this affected only the minnows in the larval stage-avery vulnerable part of their lifecycle. What's clear is that this is not a good sign for the fish. "A slowerresponse to predators is not helpful when you are on the lower end of the food chain," Furlong says.And what about the long-term impact on the environment? It's still early to say, scientists say. Butfathead minnows are a key food source for other fish species, such as trout and bass. Also, USGSresearch shows antidepressants persist in the water and travel as far as five miles downstream fromwastewater treatment plants. "As with many contaminants, there is the potential for them to move up thefood chain," Kolpin says.Officials from the U. S. Environmental Protection Agency (EPA) say they are aware of the new researchon antidepressants and fish. "We value the data collected by other agencies and organizations as it willcontribute to EPA's ongoing work to better understand the occurrence, risk and treatment ofpharmaceuticals in water, as well as methods for preventing pharmaceuticals from entering water," theagency said in a statement. U.S. Food and Drug Administration officials said they are also keeping trackofthe latest USGS fish research. However, FDA officials add, "We don't believe these low levels ofpharmaceuticals in the waterway pose any risk to human health."Environmentalists like Renee Sharp, senior scientist with the Environmental Working Group (EWG),say this new research on fish and antidepressants points to the need for better testing. "It speaks to theneed for more testing to look for ecological impacts," Sharp says. "There are gaping holes in manyaspects of our regulatory system."Sharp points to one promising solution: the green pharmaceutical movement. "We need to think aboutredesigning drugs so they're effective, but they don't cause problems," she says.Meanwhile, EWG urges consumers who have leftover antidepressants or prescription drugs to dispose ofthem responsibly, instead of flushing them. Prescription drug take-back programs are available in manycommunities. "Antidepressants are definitely helping to heal a lot of suffering," Sharp says. "But wehave a lot of chemicals at very low levels that are all interacting with one another. It's a real concern."MELISSA KNaPPER is an environmental journalist living in Denver, Colorado, who has written twobooks on medicine and the environment.

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Marilyn Cameron

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"Maureen Reilly" <maureen.reilly@sympatico.ca>"asludgewatch" <sludgewatch-I@list.web.net>Monday, August 30,201010:13 AMSludge Watch ==> Plants take up drugs, antibacterials from biosolids (sewage sludge) used asfertilizers.

Sludgewatch Admin:

This fact sheet is mounted on a page at this website. It is best to visit the site itself.

http://vrvvw.enviromnentalhealthnews.org/ ehs/newsciencel soy-plants-accumulate-drugs-antibacterials-from-biosolids

Plants take up drugs, antibacterials from biosolids used as fertilizers.Aug 30,2010Wu, C, AL Sponberg, JD Witter, M Fang and KP Czajkowski. 2010. Uptake of pharmaceuticalsand personal care products by soybean plants from soils applied with biosolids and irrigated withcontaminated water. Environmental Science and Technologyhttp://dx.doi.org/1O.10211es1011115.Context

What did they do?What did they find?What does it mean?ResourcesMore new science from ERN,. .

--------------------------------------------------------------------------------Synopsis by Heather Stapleton and Wendy Hessler

ShareThis

CityofGenevaiflickr

New research shows that the drugs and contaminants that often contaminant sewage sludge thatis used as fertilizer can be taken up by the plants grown in fertilized fields and gardens. Alsocalled 'biosolids' these fertilizers are regularly applied to agricultural fields and are sometimespackaged as organic soil fertilizers sold in home improvement stores. The results raise significantpublic health concerns about use ofbiosolids on croplands and in gardens used to grow producefor consumption.

ContextWastewater treatment plants are important in maintaining a healthy environment. Their primary

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function is to clean dirty water of pathogens, metals, certain nutrients and some pollutants that exithomes and businesses through showers, toilets, laundry machines, dishwashers and other drains.During treatment, the sewage is separated into liquids and solids. The extent of treatment can vary, but,generally, bacteria help to break down chemicals present in the dirty water. The water can be aeratedand disinfected to kill disease-causing pathogens. The cleaner water - now called effluent - is releasedinto the environment, either directly into rivers, oceans and other natural waterbodies or reused toirrigate crops.Any solids in the sewage are filtered out. The solid materials - called sewage sludge, or "biosolids'' -are dried before disposal. But, getting rid of the solids can be expensive. They can be put in a landfill,incinerated or composted for reuse as fertilizers for crops or home garden/lawn use.Today, most biosolids are land applied to recover nutrients in the solids. Biosolids are currentlyregulated by the U.S. Evironmental Protection Agency (EPA) for metals and pathogens, but not fororganic contaminants, including pharmaceuticals, cleaning product ingredients and persistent chemicals.The EPA requires testing for only nine pollutants, about 1 percent of the hazardous materials that couldbe found in sewage.Based on recent studies, some scientists are now questioning whether land application ofbiosolids maybe harmful to the environment and to people's health. A main concern is the release of thesecontaminants back to the environment, and possible human exposure to the chemicals in crops grown inbiosolid-treated fields. Previous studies have focused mainly on identifying and measuring the organiccontaminants in the biosolids and in the fields and soils treated with biosolids. Some research has foundthe pollutants do not always stay put. They can run off into waterways, soak into groundwater orbecome airborne and blow away in the wind. Whether the contaminants can get into crops or be passedon to livestock and people who eat them is not known.What did they do?A group of U.S. scientists collected biosolids - also called sewage sludge - and wastewater effluentfrom a local wastewater treatment plant in Oregon, Ohio. The biosolids were mixed with local soil andadded to nursery pots sowed with soybean seeds. The plants grew in a greenhouse for up to 110 days.Some plants were also grown in other nursery pots that contained local soil only (i.e. without thebiosolids.) Some pots were irrigated with wastewater effluent and some with clean water.

The plants grown with the biosolids in the soil were compared with plants grown in clean soil. Theywere also compared with the plants irrigated with the wastewater, but grown in clean soil. Samples ofsoil and plant tissues were collected halfway through the study and at the end of the study. They wereanalyzed for three different types of pharmaceuticals - carbamazepine (an anticonvulsant),diphenhydramine (a histimine) and fluoxetine (an antidepressant) - and two anti-microbial compounds-triclosan and triclocarban, which are typically found in anti-bacterial soaps and toothpastes.The investigators determined whether these chemicals could be taken up by the roots of the soybeanplant and transferred to the leaves and other parts of the plant. After harvesting, the concentrations of thechemicals were measured and compared in the roots, stems, leaves and beans.What did they fmd?With the exception of fluoxetine, all of the chemicals accumulated in the plant tissues from exposure toboth wastewater and biosolids. The greatest accumulation was observed for carbamazepine, triclosanand tricloarban. Concentrations increased in the plant tissues up to six times the levels present in thebiosolid amended soils. Greater accumulation of all chemicals was found in the soybeans exposed tosoils treated with biosolids; however, this may be partially due to the naturally higher concentrations ofthese chemicals in the biosolids versus the wastewater.The two anti-microbial chemicals triclosan and triclocarban were found to have the highestconcentrations in the leaves of the soybean plants relative to the root, suggesting these chemicals had agreater potential to move upward in the plant tissues. This has implications for exposure since mostlivestock feed upon the leaves and upper part of the plants, as opposed to the roots.In addition, uptake of these chemicals from roots to leaves was greater for the plants exposed to the

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wastewater, not the biosolids, suggesting differences in remobilization of the chemicals based on routeof exposure.What does it mean?The research demonstrates that chemical contaminants found in wastewater and sewage sludge mayaccumulate in plants grown in fields receiving applications ofbiosolids and/or wastewater effluent. Thelevels and accumulations varied among the chemicals measured and between the two treatment types.This was one of the first studies to explore uptake of pharmaceutical compounds in plants grown undergreenhouse laboratory conditions. Additionally, this was the first study to explore movement of thesechemicals from the roots to the leaves.The researchers report that the antimicrobial chemicals concentrated in the plants leaves and weremeasured at the highest levels of the five chemicals analyzed. As the biocides move from soil andwastewater to the leaves, human, wildlife and livestock could be exposed to these drugs.This leads to a two-fold problem. First, more exposures could cause increased antibiotic resistance.Antibiotic resistance occurs when disease-causing bacteria become resistant to the antibiotics intendedto control them. This serious problem is on the rise due to the high use of antimicrobial agents ineveryday personal care products and the overuse of antibiotics in health care. Second, bothantimicrobials and antibiotic resistance bacteria could be passed from livestock to people.Previous studies have measured contaminants in biosolids from different areas of the country, andseveral studies have investigated contaminant residues in soils/fields treated with biosolids over a fewyears to decades. Many different types of organic pollutants have been found in biosolids and in fieldstreated with biosolids all over the country, including polychlorinated biphenyls (PCBs), pesticides,dioxins/furans, polycyclic aromatic hydrocarbons (PARs) and flame retardant chemicals such aspolybrominated diphenyl ethers (PBDEs).

Both the application ofbiosolids as fertilizers and irrigatation with wastewater are popular practices dueto the increasing volumes of sewage sludge and wastewater generated and the high costs of disposal.Biosolids are even now applied to forested areas to increase timber production.Unsuspecting people may be buying the biosolids, sometimes labeled as organic, from their local homeimprovement store and then using them on vegetable gardens and flower beds. If they can move toleaves, people may be eating contaminants taken up by garden plants and not know it.Given all this information, the study has some limitiations. The authors used biosolids with a very highwater content, which may not represent actual land application practices. They also added more of thechemical contaminants to the biosolids to increase their concentrations, instead of monitoring thechemical levels present in the biosolids and wastewater. This may alter how the chemicals disperse andresult in more chemicals available to the roots of the soybean plants in the experiment than would beunder real-world applications.Further research studies should examine uptake of these chemicals in plants grown in biosolids that arenot "spiked" with these chemical contaminants.

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10/812010

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Marilyn Cameron

From:To:Sent:Subject:

"Maureen Reilly" <maureen.reilly@sympatico.ca>"asludgewatch" <sludgewatch-I@list.web.net>Thursday, August 12, 2010 1:02 PMSludge Watch ==> Nature: Leaky Science: Questionable sampling techniques have led to murkyconclusions about the contents of waste water

http://www.nature.com/news/20 10/100802/full/news.20 10.3 87 .html

2 August 2010 I Nature I doi:10.1038/news.2010.387NewsSewer studies based on leaky scienceQuestionable sampling techniques have led to murky conclusions about the contents of wastewater.Hannah Hoag

Many reports claiming to find high concentrations of chemicals in waste water could be getting itwrong.Jim RichardsoniCORBISChemicals flushing into sewer systems have been in the news for years.From opiates and hormones to heart medications, studies have detected a range of pollutants.Tests of sewage from hospitals have uncovered antibiotics, and investigations of sewage systemshave exposed widespread illicit drug use in cities worldwide.But now a group of water-management scientists claim that some of these studies may bemaking exaggerated claims, producing dramatic variation in concentration estimates or notdetecting substances because of fundamental flaws in sampling protocols.

Christoph Ort, an environmental engineer at the University of Queensland in Brisbane, Australia,and his colleagues looked at 87 peer-reviewed journal articles that investigated the fate ofpharmaceuticals, illicit drugs and personal-care products such as cosmetics. The articlesquantified the concentrations or fluxes of these compounds based on samples taken fromsewers1."There can be cases where you really get the wrong conclusions," says Ort. Less than 5% of thestudies offered a proper analysis of the system under investigation, and they didn't take intoaccount sewer type, substance and source when setting up their sampling methods, he says.

Mosaic of discharges

Rather than suggesting that there isn't a problem with pharmaceuticals and other substances inwaste water, the review questions the legitimacy ofthe assigned values.Ort hopes that the review leads scientists to scrutinize their methods. "I really think it isignorance. I'm not accusing anyone of doing it on purpose," he says.Although the sewage en route to a treatment plant may seem to be a continuous foul-smellingstream, it is in fact a mosaic of wastewater pulses discharged from toilets, dishwashers, hospitalsand industries."The study is a wake-up call," says Chris Metcalfe, an environmental scientist at TrentUniversity in Peterborough, Ontario, who has analysed ~-blocker drugs in sludge and wastewater in Canada and Germany. "It's the kind of thing that analytical chemists will read and say,'Maybe we need to clean up our act a little bit in terms of not only designing our samplingschemes but also how we interpret our data and the limitations of the data we're collecting'."

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Although some will see the review as a swipe at the literature and those behind it, art chose not to pointfingers at any single paper included in the analysis. Instead, he and his colleagues demonstrated thesampling risks in an accompanying study2 of pharmaceuticals in two different sewer systems using avariety of sampling methods. The magnitude of the sampling artefacts ranged from not significant tomore than 100%.art and co-author Michael Lawrence, now at the Department of Environment and ResourceManagement in Queensland, had previously questioned the behaviour of gadolinium, a medical-imagingcontrast agent, during wastewater collection and treatment because they deemed the field samplingstrategy to be lacking3."Sampling becomes more of an issue for compounds that aren't as widely used," says Patrick Phillips, ahydrologist at the United States Geological Survey in Troy, New York. A daily 'grab sample' - dunking abottle into a sewage stream for little more than a second - can fail to detect peaks and underestimateconcentration.Focus on reproducibilityEnvironmental chemists used to look for the presence of personal-care products in wastewaters.However, it is now more important to quantify those substances to understand their environmental flux,the options for controlling their entry into the system and their removal by sewage treatment plants.They can also help reveal the number of drug users in a catchment area, facilitating public-healthplanning."The issue that Christoph studies is an important one, especially if one is trying to make decisions aboutwhat wastewater data means," says Jennifer Field, an environmental chemist at Oregon State Universityin Corvallis, who is currently collaborating with art on a study of illicit drugs in waste water.ADVERTISEMENT

"If we're getting to the point where the wastewater treatment plant is going to spend millions of dollarsto put in a technology, we need to have data that's as accurate as possible to let them know how thetechnology will benefit them," says Metcalfe.Although he's pained by the current situation, art says it can be fixed. "If only a small fraction of theeffort that is being put into the analytical chemistry is put into understanding the potential dynamics insewers and developing the sampling, we would not have this problem," he says."Taking a representative sample and quantifying full-scale environmental flows is an extremelychallenging task," says art. "But researchers should not only rely on luck, but on reproducibility."References1.0rt, C., Lawrence, M. G., Rieckermann, J. & Joss, A. Environ. Sci. Technol. advance onlinepublication doi:10.1021/es100779n (2010).2.0rt, C., Lawrence, M. G., Reungoat, 1. & Mueller, J. F. Environ. Sci. Technol. advance onlinepublication doi:10.1021/es100778d (2010).3.Lawrence, M. G. & art, C. Environ. Sci. Techno!. 43, 5547-5548 (2009). I Article I PubMed IChemPort I

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Marilyn Cameron

From:To:Sent:Subject:

"Maureen Reilly" <maureen.reilly@sympatico.ca>"asludgewatch" <sludgewatch-I@list.web.net>Monday, August 02,20108:14 PMSludge Watch ==> Crops Absorb Pharmaceuticals From Treated Sewage

Crops Absorb Pharmaceuticals From Treated Sewage

Environmental Pollutants:

Soybeans can accumulate drugs and personalcare products commonly found in wastewater andsolid waste

Rachel A. ZurerChemical & Engineering News AUGUST 2,2010

Each year, U.S. farmers fertilize their fields with millions of tonsof treated sewage and irrigatewith billions of gallons of recycledwater. Through this treated waste, an array of pharmaceuticalandpersonal care products (PPCPs) make their way unregulated fromconsumers' homes into farmfields.

Now researchers find that at leastone crop, soybeans, can readily absorb these chemicals, whichraisesconcems about the possible effects on people and animals that consumethe PPCP-containing plants (Environ. Sci. Technol., DOI:10.1021/es1011115). Researchers havepreviously shown that food crops take up veterinarymedicines from manure fertilizer and somecabbage species absorb humanpharmaceuticals when grown in hydroponic conditions.

But environmental scientist Chenxi Wu and colleagues at the University of Toledo in Ohiowantedto determine if a major food crop could absorb common PPCPsunder more realistic agriculturalconditions, such as plants grown insoil. If the chemicals do find their way into the cropsunderreal-life conditions, they could be toxic to the plants, Wu says. "Orthey could accumulatethrough the food chain, and eventually end up inhuman consumers," he adds.

In a greenhouse experiment, the scientists focused on soybeans, thesecond most-widely growncrop in the U.S. Half the plants grew inPPCP-tainted soil, to simulate fertilization with treatedsolid waste,while the researchers irrigated the other half with chemical-spikedwater, to replicatewastewater irrigation. They laced water and soilwith three pharmaceuticals-earbamazepine,diphenhydramine, andfluoxetine-and two antimicrobial compounds found in personalcareproducts-triclosan and triclocarban.

The scientists analyzed plant tissue samples by mass spectrometry attwo life stages: just beforethe soybeans flowered and after theysprouted beans. Wu and colleagues found thatcarbamazepine, triclosan,and triclocarban concentrated in root tissues, eventually moving into thestems and leaves. The antimicrobial compounds triclosan andtriclocarban also accumulated inthe beans themselves. But the soybeanplants barely absorbed diphenhydramine and fluoxetine-the chemicalsonly appeared at low concentrations in the roots. Overall, the plantsabsorbed thechemicals more efficiently by irrigation than through thesoil.

The researchers are still trying to determine why. Environmental chemist Chad Kinney ofColorado State University,Pueblo, says the study underscores the need for further research

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intohow Pl'Cl's behave in agricultural settings. "The first thing you haveto consider with humanexposure through agriculture is whether it'seven possible," Kinney says.

"That's what was answered by this study."

Wu thinks that more toxicology studies should come next: "If you findthose compounds in the plant,what are they going to do to the plantsor to animals that eat the plants?"

http://pubs.acs.org/cen/news/8 8/i32/8 832news.html

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10/8/2010

September 24, 2010

Liz Dykman, Programs CoordinatorCanadian Council of Ministers of the Environment360 - 123 Main Street,Winnipeg, ManitobaR3C 1A3

Dear Liz:

Myname is Dr. Marilyn Cameron and I am Chair of the Biosolids & Waste Water Caucus with theNova Scotia Environmental Network.

I have completed and enclosed my responses to the Questionnaire regarding the Canada-wideApproach to the Management of Municipal Wastewater Biosolids.

I represent over 4,400 concerned citizens in Nova Scotia who have signed a Petition asking ourprovincial government to ban the land application of municipal wastewater biosolids on NovaScotia's lands. I also represent over 400 farm owners who have written letters asking that theirfarms be placed on a List of Farms Not Using Biosolids and who have refused the use oftreatedsewage sludge on their soils for fear of contaminating groundwater sources, reducing soil fertility,contributing to public or livestock disease and damaging the reputation of the agriculturalcommunity by using such a product.

I hope that my concerns and recommendations, as set out below, will be considered in formulatingthe final draft of this document. As a strong stakeholder within the province of Nova Scotia, Iwould very much appreciate a personal response to my questionnaireanswers jrecommendations.

Sincerely,

Dr. Marilyn Cameron, DVMChair, Biosolids & Waste Water CaucusNova Scotia Environmental Network115 Eden Row, RR #2Wolfville, N.S. B4P 2R2

(tel) 902 542-5330(email)p.m.cameron@ns.sympatico.ca

Cc: Minister Stirling Belliveau, Department of EnvironmentMinister John MacDonell, Department of Agriculture

Consultation on Canada-Wide Approach to Management of MunicipalWastewater Biosolids: Stakeholder Consultation Questionnaire

Question 1: What changes are required to the way biosolids are currently managed in Canada?

Although biosolids processors tout their soil amendment product as an "acceptable" alternative to chemicalfertilizers, it is also a potentially toxic mixture of chemical substances and pathogens. Therefore, it is myopinion that biosolids are not being managed adequately in Canada. Provincial guidelines, as in the case inNova Scotia, do little more than provide the users with a list of suggestions for the use of biosolids. Thefocus of the guidelines is on Class Bbiosolids. The use of Biosolids is not "regulated", thus, misuse of theproduct is not punishable. In addition, too little information is provided to the end users about potentialrisks to their soils and groundwater sources about contaminants or pathogens that may be present inbiosolids. Any and all liability associated with the use of the product will fall onto the end user - thefarmer. Too little emphasis is placed on the potential risks that biosolids pose to public health, theenvironment and wildlife.

In your introduction of the Consultation Background Document, you state that, "Biosolids are managed in amanner that is protective of human health and the environment". This statement is misleading and ignoresthe existence of scores of research documents published which question the "beneficial" and "safe" use ofbiosolids once introduced into the environment.

In order to manage the use of biosolids safely and responsibly, the following steps should be immediatelyimplemented:

(a) That the Guidelines for its use be changed to Regulations for its use. Inappropriate use will bepunished.

(b) The provincial government will bear all liability and remediation for any and all negative impacts topublic health, environment (soil fertility/water contamination), wildlife health & habitat andlivestock health. The burden of proof for reported negative impacts shall not fall on the victims.

(c) The provincial government is to annually notify each municipality (including all members ofCouncil) of the intent of farmers' use of biosolids within their boundaries. The municipalgovernment will notify the public, via local and provincial media, and will host public consultationmeetings in advance of biosolids being used in the area. Users must be identified to themunicipality and be granted a municipal Permit before land application ensues. Signage must beposted for a minimum of thirty days before and after application on any properties that use anyClass ofbiosolids in order to notify neighbors.

(d) All foods that result from the use of biosolids must be labeled to ensure consumers are fairly andadequately informed of its use.

(e) All commercial soil amendment products /fertilizers sold or distributed for no charge to the publicthat contain any municipal sewage wastewater biosolids must be labeled as such and the contentpercentage be included on the label.

(fJ Landscaping and sod companies must disclose, in writing, the use of biosolids on their products toproperty owners.

Question 2: How would a Canada-wide approach for the Management of Municipal Wastewaterbiosolids improve biosolids management?

Until complete testing ofbiosolids for contaminants and other emerging substances of concern can becompleted and it be determined that treatment processes are efficient in removing these substances, it isunacceptable and irresponsible to utilize biosolids for land application. It is unacceptable that "budgetary

constraints" have limited the number of substances that were included in the federal study of Canadianbiosolids! It is also unacceptable that a Canada wide management approach for biosolids document isbeing drafted before priority research and risk assessments concerning ESOCis complete. The list ofsubstances that should be included in the study are more pharmaceuticals, natural and synthetic humanhormones, industrial chemicals (phthalate esters, polybrominated diphenyl ethers, perflourinated organicsubstances, alkylphenor thoxylates, quaternary ammonium compounds), nanoparticles, personal careproducts (insect repellants, sunscreens, parabens, organic siloxanes, fabric softeners, fluorescent whiteningagents, etc.], numerous pathogens (more bacteria, viruses and parasites) and all heavy metals (not justthe11 that were tested for).

Biosolids are increasingly being used around the globe as a source of renewable, clean energy. In manycountries and cities - because of public unacceptance on food sources and the risks to soil/water/wildlife _land application is being discarded in favour of energy production from this waste product. Canada couldand should be a leader in sewage-to-energy technology and must abandon plans that continue to degradeour agricultural and forestry soils. Our wastewater treatment plants are designed to filter out as manypollutants, nutrients, and pathogens as possible that are present in wastewater before releasing it to theenvironment. This process costs taxpayers considerable amounts of money each year. The bulk of thesefiltered substances are being concentrated in the residual sludge. It does not make any sense to spendmillions of dollars to build treatment plants to remove pollutants from sewage, only to spread these samecontaminants back on the land where they could adversely affect public health, livestock, soils,groundwater, and wildlife.

Question 3: Is the draft policy statement on beneficial use ofbiosolids clear?

No, the draft policy statement is not clear. On one hand the statement says that, u ••••The CCMEpromotes the"beneficial use" of the nutrients, organic matter and energy contained within municipal waste waterbiosolids ....." while, on the other hand, land application is listed as one of those beneficial uses. Landapplication is a "use" which clearly does not minimize potential risks to the environment and humanhealth. In fact, land application increases the risk to public health and our environment because of thepotential pollutants treated biosolids contains.

Question 4: Are the six principals that support the draft policy statement clear?

No, four of the six principals that support the draft policy statement are not clear.For example:In #1, it states that, "Land application of municipal wastewater biosolids and treated septage is a beneficialuse ....." and, it goes on to state that, "Safety is achieved through regulatory standards and guidelines".Neither of these statements is truthful. Many farmers in Nova Scotia question the usefulness of a soilamendment product generated by the addition of hot cement kiln dust to urban sludges which could beladen with numerous chemical substances. In your Final Report - Field Sampling Program, it clearlydemonstrates that the non-biological N-Viro process to generate biosolids is one of the least effectivetreatment processes that can remove pharmaceuticals and heavy metals. Safety is not necessarily achievedthrough regulatory standards or guidelines when the product itself is not guaranteed to be safe to disperseinto the environment. Guidelines do little to prevent or correct misuse of the product in Nova Scotia.

In #2, it states that, " all jurisdictions should encourage and support the continuous improvement ofbiosolids in order to maximize their inherent benefit to the environment". In fact, to encourage maximumbenefit to the environment, biosolids should be utilized to generate useful, clean energy rather than tocontinue spreading potentially contaminant-laden biosolids on our valuable farmland/forestry /parklandssoils.

In #4, it makes a false assumption that once renewable, carbon-neutral energy is extracted via anaerobicdigestionjmethanization that the biosolids produced are of "enhanced" quality for use on soils. Finalresearch has not determined whether biological digestion technologies remove all harmful substances insludge. In fact, the Final Report points out the exact opposite in its "Conclusions".

In #5, it is falsely assumed that composting of sludge results in an "enhanced" quality ofbiosolids for useas a soil amendment. Final research has not determined whether composting sludge removes all harmfulcontaminants in sludge.

Question 5: Are there changes you would recommend to any of the principles?

Yes.I recommend that land application of municipal wastewater biosolids, listed as a "beneficial" use, beremoved from the policy statement principles until complete testing and priority risk assessments are done- including research on toxicity, persistence and bioaccumulative effects - for all contaminants thatpotentially exist in typical Canadian municipal wastewaters. To further that, land application must notoccur until removal efficiency data is complete for all contaminants for each treatment process.

Question 6: Are there additional principles which should be included?

Yes, the principles should encompass the entirety of research findings rather than just glossing over thescientific conclusions. For example, in the Final Report of the Field Sampling Program, there is absolutelyno assurance provided to the reader than treatment processes remove all contaminants or that treatmenteliminates all risk of harm to public health or the environment. On page E15-16 of this report, there are 22listed study conclusions - and these conclusions are based on only a handful of emerging substances ofconcern.

To summarize this list:• Metal contaminants are generally unaffected by treatment processes;• Only 11 out of 30+ heavy metals were tested (ie. of concern and missing was thallium - of

particular concern for the N-Viro product (Nova Scotia)). Above "acceptable levels" in numeroussamples were copper, molybdenum, and mercury - all of which can have negative impacts onlivestock and human health.

• 75% of sewage sludges contained a minimum of 24 pharmaceuticals, alkylphenolic and fragrancecompounds.

• Antibacterial compounds like Triclosan and triclocarban were detected at high levels in mostsewage sludges tested. (These compounds are thought to be contributing significantly to theformation of antibiotic resistant bacteria in the environment.)

• Canadian sludges and American sludges have similar frequencies of occurrence and concentrationof contaminants.

• Some treatment processes are more efficient than others at removing some contaminants. (TheNova Scotian N-Viro non-biological process has low removal efficiencies for contaminants - yet thecompany claims, in their promotional literature, that they are able to remove all harmfulsubstances from their product.)

• A number of pharmaceutical compounds were difficult to remove in almost all processesexamined. Some compounds increased in concentration following treatment.

• Some of the pharmaceuticals removed during treatment were lost in aqueous processsidestreams. (Where are these drugs going once collected in side streams?)

• Finally, it is recommended that, "The ESOCconcentration data in sludges and biosolidsproduced in this sampling program are insufficient alone, without applying formal riskassessment methods, to determine human health or environmental risks of managed biosolidsland application, land reclamation and production of commercial and soil amendments.

Study Recommendations included: conducting risk assessments on the ESOCto see if they pose risks tohealth or environment when biosolids are land applied; that many other ESOCsubstances be included inthe study to round out the knowledge of ESOCbehavior in biosolids treatment processes; and, that morestudies should be done on certain treatment processes to determine if they could be improved upon.

In fairness to the public, the Principles need to include the above-stated critical scientific information.This study was funded, at great cost, by the taxpayers of Canada who would likely prefer a completescientific study of all biosolids contaminants. However, it would be essential that complete disclosure beprovided to the public about those scientific findings. As it stands, this approach does not seem evident.

Question 7: Please indicate your level of support for the draft policy statement.

Do NOTsupport.

Question 8: What changes should be made to the draft policy statement?

The Policy Statement should read as follows:

The Canadian Council of Ministers of Environment (CCME)promotes the "beneficial use" of theenergy units contained within municipal wastewater sludges, rather than wasting these valuableenergy sources and degrading the soil and water through land application.

A beneficial use must:- demonstrate product efficacy (utilize technologies that produce the best net gain of usable energy)- minimize potential risks to the environment and human health (build energy capture facilities inclose proximity to WWTP and utilize cleanest, most sustainable technologies available for energyproduction)- minimize GHGemissions (utilize technologies that produce the cleanest forms of energy)- utilize the energy produced in an efficient manner (heating government buildings, fueling publictransit, etc.]- disposing of residuals following energy capture in secure landfill sites for future harvest of usablenutrients (ie phosphate recovery)

Signed: _

Dated: _

EMERGING SUBSTANCES OF CONCERN IN BIOSOLIDS:CONCENTRA TIONS AND EFFECTS OF TREA TMENT PROCESSES

Final Report - Field Sampling ProgramCCME Project # 447-2009

Submitted to:

CANADIAN COUNCIL OF MINISTERS OF THE ENVIRONMENT123 Main Street, Suite 360

Winnipeg, MBR3C 1A3

June 30, 2010

Submitted by:

Hydromantis, Inc.Hamilton, ON

GST No. 102382843

University of WaterlooWaterloo, ON

Trent UniversityPeterborough, ON

This report was prepared by Hydromantis, Inc., University of Waterloo and TrentUniversity, under contract to the Canadian Council of Ministers of the Environment (CCME).It contains information which has been prepared for, but not approved by, CCME. CCME isnot responsible for the accuracy of the information contained herein and does not warrant, ornecessarily share or affirm, in any way, any opinions expressed therein.

PN 1448© Canadian Council of Ministers of the Environment, 2010

Hyd:romantis, Inc.COilsulill1;@: Emgllle'n'S

ACKNOWLEDGEMENTSThis report was prepared for the Biosolids Task Group (BTG) of the Canadian Council ofMinisters of the Environment (CCME).

This report was prepared for CCME's BTG by Hydromantis, Inc. of Hamilton, ON.Hugh Monteith, P.Eng. (Project Manager)Lars Sterne, P.Eng.Shujun Dong, P .Eng.

Contributions to the report and helpful comments and were contributed by:Wayne J. Parker, Ph.D., P.Eng., Dept. of Civil and Environmental Engineering, University ofWaterloo, ON

Chris Metcalfe, Ph.D., Environmental and Resource Studies, Trent University, Peterborough,ON.

The authors wish to acknowledge the cooperation and support of the wastewater treatment plantpersonnel at the sites included in the report during sample collection and shipment, and for plantdesign and operating data.

Richard Grace ofAxys Analytical Services Ltd. was very helpful in discussions of analytical listsof pharmaceutical and personal care products that could be evaluated using EPA Method 1694.

The authors also acknowledge the logistical support, patience and timely responses of laboratoryproject managers:

Teresa Rawsthorne, AXYS Analytical Services Ltd. of Sydney, BC,Lindsay Zuiker, ALS Laboratory Group in Waterloo, ON, andTracy Metcalfe, Environmental and Resource Studies, Trent University, Peterborough, ON.

Tim Anderson of Hydromantis was very helpful in acquiring and organizing sampling equipmentused by the treatment plant staff at the different sites.

Hydromantis, Inc., University of Waterloo and Trent University

CCMEESOC in Biosolids: Field Sampling Program

EXECUTIVE SUMMARY

Final Report

Background to StudyThe Biosolids Task Group (BTG) established by the Canadian Council of Ministers of theEnvironment (CCME) is mandated to study and make recommendations on biosolidsmanagement at the national level. Wastewater treatment facilities (WWTF) across Canadagenerate residual wastewater solids (sludge) that may require further treatment for safeguardinghuman health and the environment prior to their use or disposal. When treated sludge quality isappropriate for land application, it is called biosolids. Options for managing biosolids includedisposal (e.g. landfill, incineration), energy recovery (e.g. thermal treatment), agriculturalapplication as a nutrient, land reclamation and remediation (e.g. mines and quarries), forestry,and commercial product recovery (compost and pellets).

The end use of the biosolids is often governed by the constituent quality of the biosolids, such asnutrients, metals, pathogens and trace constituents. Land application ofbiosolids has beenpracticed in Canada for many decades. Currently, 11 inorganic trace/micro constituents, such ascadmium, lead and mercury, and pathogen/pathogen standards are monitored in biosolids on aroutine basis, prior to land application. Other constituents thought possibly to be of concern inbiosolids in the 1990's, such as PCBs, dioxins and furans, and polyaromatic hydrocarbons(PAHs) were extensively studied at that time. These classes of compounds were included in theliterature review that accompanied the field study (Hydromantis et al., 2009). As these studiesfound low concentrations in biosolids, biosolids are not being tested for these constituents bymost jurisdictions. Consequently, they were not included in the potential list of target analytes inthis study.

At present, the risks associated with detecting in biosolids certain classes of micro-constituents(termed Emerging Substances of Concern (ESOC) herein), which include an array ofpharmaceuticals, personal care products and industrial contaminants (such as plasticizers,surfactants and brominated flame retardants) are not well understood. While there is somedocumentation of ESOC in biosolids, no focused study has been completed yet on an inventoryofESOC in Canadian biosolids. Consequently, CCME issued a Request for Proposals todocument the occurrence of ESOC in biosolids and septage; to conduct a targeted samplingprogram at selected representative Canadian wastewater treatment plants to provide a focusedCanadian study and an inventory of ESOC in Canadian biosolids; and to assess the removalefficiencies of various treatment processes, if any. The sampling study results will contribute tothe knowledge basis which will assist CCME in evaluating and managing the risks associatedwith ESOC in biosolids with respect to managed land application, land reclamation, andproduction of commercial and soil amendments.

StUdy ObjectivesThe objectives of the whole project are to:1. Prepare a comprehensive review of research on ESOC in biosolids within Canada and

elsewhere based on technical literature and wastewater sector contacts;

Hydromantis, Inc., University of Waterloo and Trent University ES-1

CCMEESOC in Biosolids: Field Sampling Program

Final Report

2. Complete a field survey and analyze Canadian biosolids and septage samples with respect toESOC;

3. Identify the occurrence and concentration ranges of those ESOC in Canadian biosolids withinthe scope of this study;

4. Review and recommend treatment technologies that mitigate ESOC concentrations inbiosolids;

5. Suggest Best Management Practices (BMPs);6. Identify knowledge gaps and research needs for ESOC with respect to biosolids;7. Produce a final report of the project to the Contract and Project Authorities.

A previous report for this project consisted of a detailed literature review of the occurrence ofESOC in municipal wastewater residual solids and biosolids from different treatment processes(Hydromantis et al., 2009) and corresponded to Project Objective. The following report,responding to Objectives 2 through 7, constitutes the results obtained from a detailed filedsampling program for the characterization of ESOC in residual solids and biosolids from 11wastewater treatment facilities across Canada.

Biosolids and Sludge Treatment Processes StudiedThe processes investigated in this report are summarised in Table ES-l. Some processesintegrate many process units (e.g. biological treatment + dewatering; liming + composting) whileothers only cover a specific process unit (e.g.: geotextile bag dewatering, filter press dewatering).Table ES-l also indicates the class of stabilisation (A or B) of the final biosolids produced fromthese treatments according to the U.S. Environmental Protection Agency (EPA) criteria forpathogen reduction. According to U.S. EPA criteria, "treated" dewatered sludges that do not meetClass A or Class B standards are not termed "biosolids", but treated sludges. The residualwastewater solids delivered to the treatment processes studied are referred to in this report as"feed sludge".

1

231112

e and Biosolids Treatment Processes Investigated in This Study

Autothermal thermophilicaerobic digestionMeso hilic anaerobic digestionCom ostingAlkaline stabilisationThermal drying ( elletisation)Geotextile ba dewaterinFilter press dewatering

Eleven sites were selected by the BTG of CCME based on a number of considerations includingthe implementation of a biosolids land application program at the site, plant capacity,geographical location, and type ofbiosolids treatment process. Plant hydraulic capacity andextent of municipal urbanization were not identified as primary factors of interest by the BTG.Site information is provided in Table ES-2.

Hydromantis, Inc., University of Waterloo and Trent University ES-2

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CCMEESOC in Biosolids: Field Sampling Program

Final Report

Sampling ProceduresSamples of both feed sludge before the treatment process and the resulting dewatered solids orbiosolids were collected between July and November of2009 on three separate occasions at nineof the eleven targeted Canadian municipalities; at the remaining two sites, two rounds of sampleswere collected rather than three due to mechanical problems with the biosolids treatment processor due to funding agreements. To account for potential losses ofthe ESOC in processsidestreams, such as digester supernatant or leachate from compo sting pads, samples of theseprocess sidestreams were also collected concurrently and analysed in an attempt to better closemass balances around the different biosolids treatment processes.

At the treatment plant sites, sample collection devices such as spoons, rods and scoops weremade of stainless steel, glass or Teflon", Pre-cleaned sample containers were shipped from theanalytical laboratories to the sites in the return shipment coolers along with sample packinginstructions, gel-type freezer packages, additional packing materials and chain-of-custody forms.

From the outset, the sampling program was to be conducted by operating plant staff at each site.To ensure proper procedures for sample collection and shipment to analytical laboratories werefollowed, a series of internet-based presentations was provided to the operating staff. Topicscovered included definition of sampling terms, acceptable materials for sampling devices,compo siting of grab samples from different process streams or locations in stockpiles, properpacking of coolers used for shipment, shipping logistics and health and safety issues in samplecollection. Telephone and email were also used to respond to immediate questions from the fieldstaff during sample collection and shipment. Samples were shipped from the collection sites byovernight courier to the laboratories, with shipments no later than Thursday afternoon to avoidsitting in courier depots over weekends. On arrival at the laboratories, samples were processedand refrigerated or frozen until analysis.

Selection of AnalytesThe potential list of classes of ESOC that might be analysed in this study is extensive. Theliterature review produced as part of this report (Hydromantis et al., 2009) identified many typesof ESOC which have been studied, including brominated flame retardants (polybrominateddiphenyl ethers and others) plastics and plasticizer agents, alkylphenols and their ethoxylates,linear alkylbenzene sulphonates, perfluorinated organic compounds, natural and synthetichormone, pharmaceuticals, synthetic musk fragrances, antibacterial compounds, quaternaryammonium compounds, and volatile methyl siloxanes.

The literature review examined the occurrence and removal of ESOC in biosolids treatmentprocesses, but did not examine any human health or environmental risks due to ESOC present inbiosolids. It was useful guide in the selection of the analytes in that it identified the near-complete lack of data on the fate of ESOC in treatment processes other than anaerobic digestion.

Three main considerations were responsible for the selection of the ESOC targeted as analytes inthis study, namely:

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(1) their potential environmental and human health significance based on other literaturereviews and professional judgement,

(2) the availability of suitable analytical methods to determine concentrations in sludges andbiosolids, which are difficult matrices for analysis ofESOC in the ng!l to ug/Lconcentration range, and

(3) budgetary constraints

Of these considerations, budgetary constraints had the greatest impact in narrowing the potentialESOC test groups to be analysed. The majority of the pharmaceutical that can be detected inwastewater and sludge matrices can be captured in five different analytical lists (Grace, 2009),with each list associated with a unit cost. Based on discussions with the analytical laboratoriesinvolved in the study (AXYS Analytical Services, ALS Analytical Group and Trent University),a proposed list of target analytes was developed for the project that was deemed to meet the threeconsiderations outlined above. The list can in general be considered to include 57 pharmaceuticalcompounds, 3 alkylphenolic compounds (including Bisphenol A), 11 synthetic musk fragrances,11 metals and macronutrients including forms of nitrogen and phosphorus. Although it wouldclearly be desirable to include additional test groups in the sampling program, budgetarylimitations precluded this. The finalised list of analytes for the study is indicated in Table ES-3.

Acetamino henAzithromycinCaffeineCarbadoxCarbamaze ineCefotaximeCi rofloxacinClarithromycinClinafloxacinCloxacillinDeh dronifedi ineDi henhydramineDiltiazemDigoxinDigoxigeninEnrofloxacinErythromycin-H20Flume uineFluoxetineLincomycinLomefloxacinMiconazoleNorfloxacin

Nor estimateOfloxacinOrmeto rimOxacillinOxolinic AcidPenicillin GPenicillin VRoxithromycinSarafloxacinSulfachloro yridazineSulfadiazineSulfadimethoxineSulfamerazineSulfamethazineSulfamethizoleSulfamethoxazoleSulfanilamideSulfathiazoleThiabendazoleTrimetho rimT losinVirginiamycin1,7-Dimeth lxanthine

DPMIADBIAHDIHHCBAHTNATIIMusk MoskeneMusk TibeteneMusk KetoneMusk AmbretteMuskX lene

Arsenic (As)- TotalCadmium (Cd)-TotalChromium (Cr)- TotalCobalt (Co)-TotalCo er (Cu)- TotalLead Pb -TotalMercury (Hg)Molybdenum (Mo -TotalNickel i-TotalSelenium (Se)- TotalZinc Zn -Total

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Pharmaceutical Test Group 1 includes a number of frequently detected antibiotics and otherrelevant pharmaceutical groups (fluoroquinolones, macrolides and sulfa compounds, as well asthe anti-convulsives carbamazepine and trimethoprim, the analgesic acetaminophen, andstimulants such as caffeine and diphenhydramine). As such Test Group 1 encompasses a rangeof compounds in biosolids that could potentially be of environmental significance. Test Group 2is a shorter list of pharmaceuticals, but includes a number of frequently detected and widely usedpharmaceuticals including the non-steroidal anti-inflammatory drugs ibuprofen and naproxen, theanti-bacterial compounds triclosan and triclocarban, and the lipid regulator gemfibozil. BothTests Groups 1 and 2 are acidic pharmaceuticals based on the extraction procedure for analysis.The difference between the Test Groups results from the analytical technique involving positiveelectro spray (Group 1) or negative electrospray (Group2) ionisation mass spectrometry.

Three different laboratories were involved in the analytical program because of the diversity ofthe target analytes. AXYS Analytical Services Ltd. in Sydney BC performed the analysis of acidpositive and acid negative pharmaceutical compounds using EPA Method 1694 (EPA, 2007).The Worsfold Water Quality Centre of Trent University in Peterborough, ON analyzed thesamples for synthetic musk fragrances and alkylphenolic compounds, including Bisphenol A byliquid chromatography followed by tandem mass spectrometry (LC/MS/MS). For logisticalreasons, samples destined for analysis by the Trent University laboratory were shipped from thesites to the AXYS laboratory, and then to the Trent University laboratory. ALS Laboratory Groupof Waterloo, ON completed the analyses of target metals and nutrients.

Results of Sampling ProgramMetalsThe metals analysed are not technically considered as ESOC since they have been widelydocumented in the literature and regulated by provincial standards for land application. Metalswere analyzed only in the first round ofbiosolids collected at the different survey sites to providea high-level comparison with historical data. The results are presented in Table ES-4. Medianvalues of both detected and non-detected metal concentration in this study are all below limitsused by jurisdictions in Canada for biosolids. For example, limits for metals in unrestricted useof compost (among the most stringent) are provided in the table for comparison. Cadmium wasdetected in only two of the biosolids samples from the eleven sites. Copper, mercury and zincwere found in biosolids samples from all eleven sites. Although maximum concentration valuesof copper, mercury and molybdenum exceeded the limits for unrestricted use at 2, 4 and 1 sites,respectively, these elevated concentrations may still be acceptable for other beneficial uses forsoil amendment.

Most metals are conservative materials through biosolids treatment processes, i.e., the processescannot specifically reduce the mass of metals in the feed sludge. Metals may be lost from thebiosolids treatment process in aqueous side streams such as leachates, filtrates or supernatants.Because metals cannot be removed by the biosolids treatment processes, the only method tofurther reduce concentrations in the biosolids, if needed, is to restrict them at the source.

Over the past three decades, very positive steps have been taken in Canada to reduce theconcentrations of all metals in the biosolids. Current concentrations of cadmium, chromium, lead

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Table ES-4. Metal Concentration Data in 11 Canadian Treated Sludge and BiosolidsSam les

Arsenic (As) 7 1.4 2.6 6.7 13Cadmium Cd 2 <1.0 1.1 1.2 3Chromium (Cr) 10 18.1 20.3 120 210Cobalt (Co) 7 2.6 2.9 4.2 34Co er Cu 11 271 271 890 400Lead (Pb) 9 22.5 24.7 55.5 150Mercu H 11 0.68 0.68 3.2 0.8Mol bdenum 8 1.8 3.5 8.6 5Nickel (Ni) 9 9.9 10.5 21.1 62Selenium (Se) 6 1.3 2.2 3.2 2Zinc Zn 11 331 331 647 700

Samples in bold font are detected in all samples of treated biosolids

and nickel are reduced by greater than 90% compared to the 1981 levels. The literature reviewassociated with this field survey (Hydromantis et al. 2009) noted that reductions of metalconcentrations, such as nickel, chromium and cadmium, were effectively accomplished in the1980s and 1990s by source control, pre-treatment and sewer use limits. When comparing metalconcentrations in composted septage (Gatineau Valley) to median biosolids values, the metalconcentrations are approximately the same, an observation also reported by (Perron and Hebert,2007) who evaluated a higher number of septage locations. All median metal concentration insludge and biosolids, with the exception of selenium, met the current most stringent qualitycriteria for land application, although a limited number of exceedances were observed for copper,mercury and molybdenum on a site-specific basis. The data reinforce the success of sourcereduction of metals from industries, with metals contributed to biosolids now mainly originatingfrom domestic rather than industrial sources.

Pharmaceutical, Alkylphenolic and Fragrance CompoundsThe pharmaceutical analyses included lists of both acid positive and acid negative compounds; intotal 57 compounds were included in the scans ofthe two lists. Of the 57 candidatepharmaceutical compounds, twenty were never observed above the detection level in the treatedsludge and biosolids, as indicated in Table ES-S. Nonylphenol and four nitro musk compoundswere also never detected. Sample detection limits were determined for each compound in eachmatrix, and as a result no single "representative" detection limit is provided.

Only four of 57 pharmaceutical compounds (7%) were found in detectable concentrations in all31 samples of treated sludges and biosolids. These four pharmaceutical compounds includedtriclocarban, carbamazepine, diphenhydramine and miconazole. Two polycyclic fragrancecompounds, HHCB and AHTN were also detected in all samples of treated sludges and biosolids.The frequency of occurrence and median concentrations of the organic analytes is presented inTable ES-6.

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Acetamino henCarbadoxCefotaximeClinafloxacinCloxacillinFlume uineLomefloxacinNor estimateOrmeto rimOxacillin

Penicillin GSarafloxacinSulfachloro yridazineSulfadiazineSulfadimethoxineSulfamethazineSulfamethizoleSulfathiazoleT losinWarfarin

Non I henolMusk MoskeneMusk TibeteneMusk KetoneMusk Ambrette

Table ES-6. Occurrence and Median Concentrations of Organic Analytes in TreatedSlud es and Biosolids in this Stud

HHCB 100% 3470 52% 56Triclocarban 100% 1930 42% 31.2AHlN 100% 1340 42% 7

100% 441 39% 5.2100% 420 32% 543

ine 100% 66.6 26% 49797% 6085 23% 22.2

ATII 96% 255 Oc I henol 18% 50Ci rofloxacin 94% 3610 1,7-Dimethy lxanthine 13% 378Ofloxacin 87% 276 Sulfanilamide 13% 63.1Bis henol A 86% 325 GI buride 13% 11.5Azithromycin 84% 205 Hydrochlorothiazide 10% 143Fluoxetine 84% 53.9 Sulfamerazine 10% 17.9Na roxen 81% 98.1 6% 197Clarithromycin 74% 41.8 6% 192Thiabendazole 74% 17.9 6% 128Er throm cin-HzO 74% 12.5 5% 530DPMI 73% 82.5 ADBI 5% 60Ibu rofen 68% 522 Lincom cin 3% 71.1Diltiazem 68% 29.8 Penicillin V 3% 59.3AHDI 64% 158 Gli izide 3% 11.4Caffeine 61% 266 Oxolinic Acid 3% 1.9Norfloxacin 58% 558 Roxithrom cin 3% 0.8

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Although 20 pharmaceuticals were found in detectable concentrations in more than 75% of thefeed sludge samples, only 10 of 57 pharmaceuticals (18%) were found in more than 75% of thetreated biosolids samples likely to be land applied. A greater proportion of pharmaceuticals weredetected when septage was the feed sludge (49 % at Gatineau Valley) rather than from on-sitewastewater processes.

A shift in the frequency distribution occurred such that a greater number of the pharmaceuticalswere detected less frequently after the biosolids treatment, compared to frequency in the feedsludge samples, suggesting that on a broad overview, biosolids treatment processes reduce thenumber of detectable concentrations of ESOC in the feed sludge. The ability to reduce ESOC inbiosolids is process dependent, however. The frequency of occurrence of fragrance compoundswas relatively similar in both feed sludge and treated sludges or biosolids.

A small number (12/57) of pharmaceutical compounds were observed at concentrationsexceeding 1,000 ng/g TS dw (1 mg/kg TS dw) in the final sludge or biosolids products from thetest sites. The antibacterial compounds triclosan and triclocarban, and the antibioticciprofloxacin were the compounds most frequently detected (9 of 11 sites) above 1000 ng/g TSdw. At a few sites, the concentrations of triclosan and ciprofloxacin in the final sludge orbiosolids exceeded 10,000 ng/g TS dw. The fragrance compounds HHCB and AHTN wereobserved at median concentrations greater than 1,000 ng/g TS in 10 and six of the eleven sitesrespectively. The median concentration of Bisphenol A exceeded 1,000 ng/g TS in 3 of the 11sites tested.

Elevated concentrations ofESOC such as triclosan, ciprofloxacin, BPA, HHCB and AHTN maybe one criterion used for identifying ESOC that should be considered for detailed riskassessment. There are other criteria, however, such as persistence, potential for bioaccumulation,and toxicity, that are at least as important and also need to be considered for targeting the ESOCfor priority risk assessment.

Many pharmaceuticals (nearly 30 % of those tested) were not detected in the final biosolidsproducts. For those substances that were still detected after process treatments, the statisticsprovided in Table ES-6 may help scientists to evaluate whether or not these concentrations maystill pose risk with land application.

Biosolids or sludge treatment processes at four of the sampling locations involve the productionof sidestreams (e.g. dewatering press filtrate, compost pad leachate) that contain elevatedconcentrations of some of the hydrophilic pharmaceuticals, which can represent a significantpercentage of the input mass of the ESOC. In a few cases, the pharmaceutical mass calculated inthe filtrate was greater than the input mass (e.g., ibuprofen and carbamazepine at Eganville,acetaminophen and dehydronifedipine at Gander). Because some compound mass in the feedsludge may be transferred to the aqueous sidestream, the change in frequency of occurrence ofdetectable concentrations from feed sludge to treated biosolids cannot be interpretedsimplistically as a reduction or removal efficiency. With the exception of the concentration ofBisphenol A in the Gander press filtrate, the mass of the BPA in the leachate represented between1% and 7% of the mass in the feed sludge. The mass of the fragrances in the side streams orleachates represented less than 1% of the mass in the feed sludges. In general, there is a very

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minor loss of the fragrance compounds and BPA from the feed sludge to the leachate, as wouldbe expected of hydrophobic compounds.

It was observed that compo sting of sludges (aerobic treatment) generally resulted in the highestremoval efficiencies of most ESOC, including pharmaceutical and fragrance compounds. Manyother pharmaceuticals were effectively removed in the aerobic environment compared to theanaerobic environment. Compounds with this behaviour included azithromycin, ciprofloxacin,miconazole, triclosan, triclocarban, diphenhydramine, gemfibrozil, thiabendazole andcarbamazepine. A limited number of pharmaceuticals, such as naproxen, however, survived andapparently increased through the compo sting process. Mesophilic anaerobic digestion of sludges,conversely, was found to substantially reduce concentrations ofnaproxen, as was noted in theproject's literature review (Hydromantis et al., 2009). There was also limited evidence thatanaerobic digestion may result in higher removal efficiencies of acetaminophen than compo sting,based on one location of each process type with quantifiable results. In general, however,anaerobic digestion was less successful in overall removal ofESOC than the compo sting process.

A very few compounds appeared to be susceptible to removal by both aerobic and anaerobicbiological treatment. These included sulfamethoxazole, trimethoprim, diltiazem and caffeine. Alimited number of pharmaceutical compounds appeared to be difficult to remove in almost allprocesses examined, when present at detectable concentrations. These included the diureticfurosemide, the anti-epileptic carbamazepine, and the antibiotic ofloxacin.

For the most part, the corresponding compounds in this study and the U.S. EPA's TargetedNational Sewage Sludge Survey (TNSSS) are comparable in frequency of occurrence andconcentrations. Of the nine compounds that can be compared directly, the ratio of the medianconcentrations (TNSSS/this study) of seven of the compounds falls between 0.6 and 2.7. Forthese seven compounds, the ratio is greater than unity for 6 compounds, indicating that medianlevels in U.S. sludges are slightly higher than in the Canadian sludges and biosolids examined inthis study. For the other two pharmaceutical compounds (triclocarban and ofloxacin), medianconcentrations in the U.S. sludges were an order of magnitude higher than observed in thesludges and biosolids tested in this study. The higher median concentrations in the U.S. TNSSSthan in this study may be reflective of a greater proportion of untreated sludges included in theU.S. study compared to this, as the extent of sludge treatment was not of primary consideration inthe U.S. study. The results of this analysis suggest that data from the U.S. TNSSS can be used asa general indicator of compounds found in Canadian sludges and biosolids, with somecompounds in Canadian samples being substantially lower than the levels in the U.S. TNSSS.

When the results of this field study were compared to the observations documented in theaccompanying literature review, similar trends were noted. In both the literature and this fieldstudy, anaerobic digestion readily removed the antibiotic sulfamethoxazole and the non-steroidalanti-inflammatory drug naproxen, with ibuprofen removed to a lesser extent. Compounds suchas the anti-epileptic carbamazepine, the anti-microbials triclosan and triclocarban, Bisphenol A,and the polycyclic musk fragrances HHCB and AHTN either remained unaffected by anaerobicdigestion or increased in concentration through the process. Effectiveness of other sludge orbiosolids treatment processes was uncertain because the literature documenting such informationwas sparse.

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Overall Effectiveness of Processes for ESOC RemovalAs a test of the different process capabilities for removing pharmaceuticals, alkylphenolic andfragrance compounds, the different removal efficiency ranges were assigned a numerical score,ranging from 1 for compounds which were removed by over 90%, to a value of 5 for compoundswith calculated removal efficiencies that had a magnitude greater than -50%. (A negativeremoval means that the total mass leaving the biosolids treatment unit is greater than the massentering the unit.) By summing the points assigned to each process for each compound, anddividing by the number of detections of the compound per site (i.e., counts) included in theassessment, a mean score for each process was calculated. The interpretation of this procedureconsiders that the lower the mean score (i.e. closer to unity), the more effective the process is atremoving the pharmaceuticals. The results of this process comparison are presented in TableES-7.

Table ES-7 identifies in general terms the ability of a process to reduce ESOC loading from thefeed sludge to the treated sludge or biosolids. A higher score is not a criticism of the process: thetreatment processes were neither designed nor implemented specifically for removal of thesecontaminants. The removal efficiencies are also not a reflection on the overall operation of allprocesses at a WWTP.

Table ES-7. Ranking of Sludge and Biosolids Treatment Processes for ESOC Removal inthe Field Stud

Gatineau Valle Biological- aerobic Com ost) 49 27 1.81Moncton Biological- aerobic (Compost) 57 31 1.84Prince Albert Biological- aerobic (Com ost) 72 29 2.48Eganville (Se tage) Physical - geotextile bag dewatering 85 28 3.04Halifax N-Viro Physical-chemical (alkaline stabilisation) 115 35 3.29Red Deer Biological- meso hilic anaerobic digestion 115 34 3.38Salmon Arm Biological- autothermal aerobic digestion III 32 3.47Saskatoon Biolo ical- meso hilic anaerobic di estion 118 34 3.47Smiths Falls Physical - thermal drying 101 27 3.74Gander Ph sical - filter ress dewaterin 102 27 3.78Saguenay Physical- filter ress dewatering 108 27 4.00

Compo sting was the most effective treatment for reducing loadings of the target analytes in thefeed sludges. Anaerobic digestion was less successful than the aerobic composting processes.One of the more surprising results from this assessment was the lower removal efficiencies ofpharmaceutical compounds than might have been expected in the autothermal aerobic digestionprocess, considering it is an aerobic process that operates at an elevated temperature, whichshould result in faster removal rates. The reasons for this observed performance are not clear andhave been identified below as a knowledge gap.

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The geotextile bag filtration and alkaline stabilisation processes were the most effective of thenon-biological processes. The processes involving solids dewatering alone were the leasteffective; however, because they operate only as physical separation devices, they are notdesigned for removal of ESOC. The low rating for theses processes is therefore not surprising.Dewatering may remain helpful in a series ofbiosolids treatment processes, however, to reduceconcentration of water-soluble compounds.

Best Management PracticesThe sampling survey reported here provided an interesting look at different biosolids and sludgetreatment processes, and their ability to remove metals, pharmaceutical, fragrance andalkylphenolic compounds present in the process feed sludge streams. The different treatmentprocesses examined, however, are not replicated sufficiently to draw statistical inferences. Someof the processes in fact were represented by only one site. It is therefore difficult to statedefinitively from this initial survey which processes should be categorized as "Best ManagementPractices" .

MetalsMost of the metals of industrial significance (e.g., electro-plating and surface finishing)concentrations in biosolids have been reduced very substantially over the past two to threedecades. The reductions of these metals are almost entirely due to source control measures orsubstitution (e.g. substituting cadmium-plating with other metals). Such measures shouldcontinue to be implemented and enforced. The two metals that were regularly observed at thehighest concentrations in the biosolids and sludges are copper and zinc, which are commonlyused in residential, commercial and institutional plumbing. Further reductions of these twometals in biosolids can be accomplished by a substitution of plumbing pipes and appurtenanceswith other materials such as polyvinyl chloride (PVC) or high density polyethylene (HDPE) iftheconcentrations in the biosolids warrant this expenditure

Pharmaceutical, Alkylphenolic and Fragrance CompoundsWith respect to removal of pharmaceutical compounds by biosolids or sludge treatment, thetechnology that appears to be more effective than others is composting, an aerobic biologicalprocess that operates at thermophilic (e.g. approximately 55°C) temperatures. Anaerobicdigestion removes a limited number of different pharmaceutical compounds, presumably becauseof the different microbial consortia present in the two environments and the absence of oxygen.If greater reduction of ESOC in biosolids is determined by risk assessment to be necessary, acombination of treatments may act as a multi-barrier approach for reducing concentrations intreated biosolids. For smaller municipalities, the geotextile bag filter dewatering process mayoffer some reduction in pharmaceuticals at low cost.

If some pharmaceutical compounds of concern are difficult to remove by the biosolids treatmentprocesses examined herein, consideration may be given to preventing their deposition in thesludge feed streams for the biosolids processes. This prevention concept could be implementedby two potential design and operating changes. First, many of the pharmaceutical compounds arehydrophobic, and are thus associated with primary clarifier underflows. Consequently, they arenot subject to aerobic biological treatment, which could enhance their overall removal from the

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incoming wastewater. Overall reduction in pharmaceutical compounds could potentially beimproved without a primary clarification step, as is often practiced with the extended aerationprocess and aerated lagoons used at smaller municipalities. Implementation of such a practice inconventional activated sludge processes would represent a radical departure from existing designand operating philosophies, however. Alternatively, preliminary separate treatment of theprimary sludge, for example by either aerobic digestion or other treatment such as ozonation,prior to mixing with secondary sludge, may provide reduced concentrations of pharmaceuticalsentering the biosolids or sludge treatment processes. Pre-ozonation of the combined feed sludgemay also provide some beneficial effect on removal in the biosolids treatment processes.Source control of pharmaceutical compounds may be accomplished to some extent throughpharmaceutical take-back programs and education of the public that they should not flush unusedmedications via toilets to the sanitary sewer system. Product substitution is likely difficult toimplement, as the public needs their medications. Other ESOC, such as fragrances, surfactantsand anti-microbials could be candidates for product substitution, however.

Depending on the mode of action, some pharmaceuticals can be metabolized in the body andexcreted in urine. Others are excreted in feces. For those pharmaceuticals that are excreted inurine, use of toilets equipped with urine traps may help to remove the compounds from enteringthe wastewater stream. Such a shift in technology substitution would require a long period toimplement across the country.

Knowledge Gaps and Research NeedsThis study afforded an opportunity to investigate in detail the potential removal of ESOC bysludge and biosolids treatment processes commonly used in Canada. The study produced muchvaluable information on the fate of the ESOC selected for investigation, but as is often the casethe acquisition of new knowledge leads to additional questions. Below are listed some of theknowledge gaps and research needs arising from this survey and from the literature review

-(Hydromantis, 2009) in no particular order of importance.

This study looked at a select group of pharmaceuticals, fragrance and alkylphenolic compounds.Due to budgetary limitations, it did not look at other classes of ESOC, including otherpharmaceutical compounds, natural and synthetic human hormones, industrial chemicals (e.g.phthalate esters, polybrominated diphenyl ethers and other flame retardants, perfluorinatedorganic substances, alkylphenol ethoxylates, quaternary ammonium compounds), and personalcare products (insect repellents, sunscreens, parabens, organic siloxanes, fabric softeners,fluorescent whitening agents, etc.). Research at full-scale similar to this study for these manytypes of ESOC is encouraged to round out the knowledge of ESOC behaviour in biosolidstreatment processes. [At the time of preparing this report, another field study was conducted byEnvironment Canada under the Chemical Management Plan to analyse sample of wastewaterliquid and solids process streams for a range of substances including selected pharmaceutical andpersonal care products, brominated flame retardants, perfluorinated organic compounds, volatilemethyl siloxanes nonylphenol ethoxylates and a suite of 18 metals (Smythe, 2010).]Some unexpected results were obtained in this study, both positive and otherwise. Anunexpected result was the reduction of a number of organic ESOC by the geotextile bag filterdewatering process at the Eganville, ON treatment plant. Only one application of this type of

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dewatering process was included in this sampling survey. Additional sites using this technologyshould be tested in a similar manner to determine if the process does offer a low-cost means ofdewatering wastewater sludge with better removal efficiencies of more ESOC than otherprocesses examined herein. Factors to consider in additional testing should include the type offeed solids (primary sludge, septage, waste activated sludge) to the process, loss of ESOC in bagfiltrate, possible effect of freezing and thawing, and retention time and possible aerobic/anaerobicmicrobial activity in the geotextile bags.

The autothermal aerobic digestion process exhibited lower removal efficiencies ofpharmaceutical, fragrance and alkylphenolic compounds than might have been expectedconsidering it is an aerobic process that operates at an elevated temperature, which should resultin faster removal rates. The possible reason may be that the relatively short detention time at theelevated temperature ofthermophilic operation (e.g. approximately 55°C) reduces the numberand types of microbes that can biodegrade the ESOC. Compo sting is an aerobic process in whichtemperatures reach thermophilic conditions, which is similar to those experienced in the ATADprocess. Additional studies with this type of process should be undertaken to determine thisdiscrepancy.

It was observed that compo sting of sludges to produce biosolids generally resulted in the highestremoval efficiencies of most ESOC. A limited number of pharmaceuticals, such as naproxen,however, survived and apparently increased through the compo sting process. Mesophilicanaerobic digestion of sludges was found to substantially reduce concentrations of naproxen, butwas less successful in overall removal ofESOC. The ability of a combination of anaerobicdigestion, followed by dewatering and composting, for example, might provide a means ofreducing more ofthe ESOC, including other that were not tested in this program. Such a study,either at pilot-scale or at existing full-scale facilities with this treatment combination would behelpful in determining the possible benefits of different redox environments for ESOC removal.

The biological treatment processes for biosolids in general were able to reduce ESOC in the feedsludge more efficiently than were the physical (including physical-chemical) processes. Ofthephysical-chemical processes, the N-Viro alkaline stabilisation process appeared to offer the bestperformance for ESOC removal. Only one example of this process was included in this survey(i.e. the Halifax site). Moncton, NB uses a partially lime-stabilised biosolids as the feed materialfor the compo sting operation, but the focus there was on the compo sting process, rather than onlime stabilisation. Additional testing of lime- and alkaline-stabilisation processes for reduction ofESOC should be undertaken.

The thermal drying process (pelletisation) was not efficient in the reduction of ESOC, with theknowledge that it was not intended for that purpose. It may be possible, however, to accomplishgreater reduction of ESOC to take advantage of thermal or chemical decomposition by a changein process operating conditions.

It is of high importance to evaluate whether the detected concentrations of pharmaceuticals andother ESOC in land applied biosolids could are of concern for either human health orenvironmental risk. The U.S. EPA is currently conducting such risk assessments (Hebert, 2010).The results of such studies will help to determine if further reductions in concentration of specific

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compounds may be needed. Studies by Carballa et al. (2007b) indicated that pre-ozonation of thefeed sludge to the anaerobic digestion process generally resulted in improved removal of severalclasses of ESOC. Because it is unlikely that source control can restrict inputs of pharmaceuticalsto wastewater treatment plants, improving the removal of the compounds by biosolids treatmentprocesses by pre-ozonation or other processes should be investigated, including sludge feeds toall the different biosolids treatment processes (i.e., not just anaerobic digestion).

Study ConclusionsThe conclusions that follow relate to the suite of target ESOC evaluated in this study.

1. Metal contaminants in biosolids are in general unaffected by the biosolids stabilisationprocess employed, as compared to organic constituents. A potential exception may bemercury, which can be biologically activated in anaerobic environments, and also undergotransfer from biosolids to the gas phase by stripping or volatilisation.

2. All median metal concentration in sludge and biosolids, with the exception of selenium,met the current most stringent quality criteria for land application, although a limitednumber of exceedances were observed for copper, mercury and molybdenum on a site-specific basis.

3. Metal concentration ofbiosolids and septage were quite similar, indicating that metals inbiosolids now mainly originate from domestic rather than industrial sources.

4. Although 24 pharmaceutical, alkylphenolic and fragrance compounds were found indetectable concentrations in more than 75% of the feed sludge samples, only 14 of71pharmaceutical, alkylphenolic and fragrance compounds (20%) were found in more than75% of the treated biosolids samples likely to be land applied.

5. The antibacterial compounds triclosan and triclocarban, the antibiotic ciprofloxacin, andthe fragrance compound HHCB were the compounds most frequently detected (9 or moreof 11 sites) above 1000 ng/g TS dw.

6. For the most part, the corresponding compounds in this study and the U. S. EPA'sTargeted National Sewage Sludge Survey (TNSSS) are comparable in frequency ofoccurrence and concentrations.

7. Biosolids stabilisation processes using some form of biological treatment are moreefficient at reducing the organic ESOC concentrations than are non-biological processes.

8. Of the biological treatment processes, the compo sting process (aerobic) appears to bemore effective in overall reduction (in number and degradation) of ESOC than doesmesophilic anaerobic digestion.

9. ESOC removed efficiently by compo sting, but not well reduced by anaerobic digestioninclude compounds such as ciprofloxacin, miconazole, triclosan, gemfibrozil,thiabendazole, carbamazepine, Bisphenol A, HHCB, AHTN, AHDI, and ATII.

10. The autothermal aerobic digestion process was much less effective in reducing ESOCthan was either compo sting or mesophilic anaerobic digestion.

11. The geotextile bag filter used for dewatering sludge and septage was capable of reducinga number ofESOC, although the exact mechanism is unclear at.this time.

12. Ofthe physical processes (including physical-chemical) processes, the N-Viro alkalinestabilisation process appeared to offer the best performance for ESOC removal

13. The thermal drying process (pelletisation) alone was not efficient in the reduction ofESOC, acknowledging that it was not intended for that purpose.

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14. Mechanical sludge dewatering processes alone are among the least effective for reducingconcentrations of ESOC in the feed sludge.

15. A few pharmaceutical compounds appear to be removed readily by either aerobic oranaerobic biological treatment, including sulfamethoxazole, trimethoprim, caffeine anddiltiazem.

16. A limited number of pharmaceutical compounds appeared to be difficult to remove inalmost all processes examined, when present at detectable concentrations. These includedthe diuretic furosemide, the anti-epileptic carbamazepine, and the antibiotic ofloxacin.

17. Naproxen appears to increase substantially through aerobic composting, possibly due tobiotransformation from other compounds, but it appears to be more efficiently removedby anaerobic digestion.

18. While many of the ESOC remain associated with the solid phase ofthe sludges orbiosolids, a number of compounds can be lost in any aqueous process side stream (e.g.,dewatering filtrate, leachate, digester supernatant), including furosemide, ibuprofen and 2-hydroxy-ibuprofen, naproxen, acetaminophen, caffeine, carbamazepine, clarithromycin,dehydronifedipine, erythromycin-Hit), sulfamethoxazole and trimethoprim.

19. Less than 1% of the mass of fragrance compounds in feed sludge resides in the processsidestreams or leachates from the treatment processes, while between 1% and 6% of themass of Bisphenol A in the feed sludges was transferred to the process sidestreams orleachates.

20. A combination of processes (e.g. anaerobic digestion plus dewatering plus composting asat Prince Albert; lime stabilisation plus compo sting as at Moncton) result in the highestreductions of many ESOC.

21. The treatment efficiencies ofESOC by anaerobic digestion observed in this field study arecomparable to results reported in the technical literature; published removal efficienciesof ESOC in other biosolids treatment processes are sparse.

22. The ESOC concentration data in sludges and biosolids produced in this sampling programare insufficient alone, without applying formal risk assessment methods, to determinehuman health or environmental risks of managed biosolids land application, landreclamation, and production of commercial and soil amendments.

Study Recommendations1. Risk assessments should be conducted with ESOC to evaluate if they may pose risk to

human health or the environment when applied to land amended with biosolids. Based onfrequency and concentrations observed in the treated sludges and biosolids, candidatecompounds for initial risk assessment may include triclosan and triclocarban,ciprofloxacin, the fragrances HHCB and AHTN, and BPA, although other factors such aspersistence, bioaccumulation potential and toxicity also need to be considered.

2. Research at full-scale, similar to this study, for many other types ofESOC (other classesof pharmaceutical compounds, natural and synthetic human hormones, industrialchemicals (e.g. phthalate esters, brominated flame retardants, perfluorinated organicsubstances, alkylphenol ethoxylates, quaternary ammonium compounds), and personalcare products (insect repellents, sunscreens, parabens, organic siloxanes, fabric softeners,fluorescent whitening agents, etc.) is encouraged to round out the knowledge ofESOCbehaviour in biosolids treatment processes.

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3. Additional sites using the geotextile bag filtration technology should be tested in amanner similar to this survey to determine if the process offers a low-cost means ofdewatering wastewater sludge with substantial removal efficiencies of certain ESOC.Factors to consider in additional testing should include the type of feed solids (primarysludge, septage, waste activated sludge) to the process, loss of in bag filtrate, possibleeffect of freezing and thawing, and retention time in the geotextile bags.

4. Additional sampling of the autothermal aerobic digestion process at other locationsshould be undertaken to determine if the lower removal efficiencies of pharmaceutical,fragrance and alkylphenolic compounds observed at the one site tested (compared to otheraerobic processes such as composting), was an isolated event, or is representative of theprocess behaviour with respect to ESOC.

5. Because only one example of lime- or alkaline-stabilisation processes was included in thissurvey, and because the alkaline stabilisation process appeared to offer the bestperformance for ESOC removal of any ofthe physical (including physical-chemical)processes, additional testing should be undertaken for confirmation and optimization ofESOC reduction.

6. A study examining the ability of a combination of processes (e.g. anaerobic digestion,followed by dewatering and composting; alkaline/lime stabilization followed bycomposting), either at pilot- or full-scale, is recommended for determining the possiblebenefits of different redox environments for reducing ESOC, including others that werenot tested in this program.

7. Because only one example of lime- or alkaline-stabilisation processes was included in thissurvey, and because the alkaline stabilisation process appeared to offer the bestperformance for ESOC removal of any ofthe physical (including physical-chemical)processes, additional testing to document reduction of ESOC by this type of processshould be undertaken.

8. Studies of pre-treatment of feed sludges, such as by ozonation, prior to the biosolidstreatment processes should be investigated to determined the potential beneficial effectsand cost-effectiveness for overall improvement in ESOC removal efficiencies.

9. Data produced by this and similar investigations need to be transferred out to appropriatedepartments and agencies, federal and provincial regulators, municipalities and academicresearchers for risk assessment purposes.

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Bisphenol A was detected in both the lime stabilised feed solids and compost in the twocampaigns. It was substantially reduced in concentration through the composting process, from amedian concentration of 965 ng/g TS dw in the lime-stabilised feed sludge, to a median value of125 ng/g TS dw in the finished compost. None of the polycyclic musks was detected atconcentrations greater than 1000 ng/g TS in the finished compost, although the medianconcentration ofHHCB and AHTN were both greater than 1,000 ng/g TS dw. None of the nitromusk compounds were observed above the limit of quantification. Many compounds in thecompost were observed at lower concentrations than in the feed sludge. The mass balanceassessment indicated a high removal efficiency (92%) of Bisphenol A through the compo stingprocess. The calculated negative removal efficiency for octylphenol was attributed to a single setof concentrations close to the limit of quantitation. Removal efficiencies for the polycyclic muskfragrances in general were high, ranging from 51% (DPMI) to 95% (AHDI).

The data for the compo sting process at Moncton indicate that high removal efficiencies areobtained for many pharmaceutical compounds, BPA and polycyclic fragrance compounds. Itmay be possible that implementing lime stabilisation of the dewatered primary sludge cake priorto composting has a beneficial effect on removal of pharmaceutical compounds in the compo stingprocess. Furthermore it is worth noting this system treated lime stabilised raw primary solidsonly, and none of the material had been previously exposed to a biological process that mighthave reduced masses entering the compo sting process. These potential effects could not bedetermined from the data collected.

4.11 N- Viro Alkaline Stabilisation Process, Halifax, NS

4.11.1 Site DescriptionThe N-Viro process in Halifax is owned and operated by N-Viro Systems Canada and is designedto receive dewatered cake from five wastewater treatment facilities: Halifax, Aerotech, HerringCove, Bedford and Dartmouth.

4.11.2 N-Viro Process DescriptionThe Halifax wastewater treatment facility is currently not operating and so no sludge is being sentto the N- Viro Process. The Herring Cove facility will come on line later in 2009. TheDartmouth facility is an enhanced primary treatment plant utilizing alum and polymer. TheBedford facility is a pure oxygen system with mesophilic anaerobic digestion. After digestion,the biosolids are taken to the Aerotech facility for dewatering. The Aerotech facility is a SBR(sequencing batch reactor) sewage plant. It receives waste from the airport, an industrial park andalso septage.

The N-Viro facility receives dewatered biosolids cake from the Aerotech and Dartmouthfacilities. The system is designed to blend the incoming cake, but currently this is not practiced.It is currently done in batch mode for the cake of one facility and then the cake of anotherfacility. Because of the mix of inputs sludges, it was not possible to determine which were beingprocessed during the sampling periods. The average feed rate of the dewatered cake and alkaline

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admixture to the N-Viro biosolids dryer is 9 wet tonnes/hour. The average N-Viro production rateis 7 wet tonnes/hour. During this study, the solids concentration in the feed sludge to the N-Virodryer ranged from 44.7% to 50.4%, while the solids concentration in the final N-Viro productafter curing and storage ranged from 67.4% to 69.6%. The processed biosolids are sent toagricultural lands.

For this project assessment, the biosolids treatment process of interest was the N-Viro system.The two sampling locations included the sludge feed (i.e. the dewatered cake and alkalineadmixture) to dryer (i.e. the collection point was after mechanical mixing and before dryer) andfinal curing products (72 hours has elapsed after between when the product left the drier andwhen the sample was collected, which means the product is 72 hours old). A process schematicof the N-Viro treatment process is shown in Figure 18.

The plant was considered by plant staff to be in normal operation during the tree samplingcampaigns. Samples were collected and shipped to the analytical laboratories on June 22,September 2 and October 7, 2009 respectively.

N-Viro Productafter Final Curing

BiosolidsCuring andStorage

BiosolidsDryer

r------------------------------------------ _Feed Sludge (i.e. : N-Viro Systemdewatered cake and:

I

alkaline admixture :I:.IIIIIIIII--------- J

Figure 18. Schematic of Halifax N-Viro Biosolids Process and Sampling Locations

4.11.3 Sampling Results

4.11.3.1 Nutrients

A higher concentration ofnitrate-N was observed in the N-Viro product than in feed sludge afteradmixture (Table 89). The observed differences may be due to variations in the composition ofthe two process streams at the time of sampling, considering the batch mode operation. Theconcentrations of total Kjeldahl nitrogen (TKN) and ammonia-N (a component ofTKN togetherwith organic-N) were lower in the N-Viro products than in the feed sludge. The observeddifferences may be due to the high temperature during the biosolids drying process, which woulddrive off some ammonia and organic nitrogen containing compounds such as amines. Theconcentrations oftotal and ortho-phosphorus were observed to be similar, as expected duringbiosolids drying and curing processes.

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31.9<5.012100128051800.795

675000

<5.0<5.01650023606570

. 0.626437000

Table 89. Nutrients in Feed Sludge after Admixture and N-Viro Products after FinalCurin , Halifax NS

4.11.3.2 MetalsAll the metals except Cadmium were observed at detectable concentrations in both feed sludge tothe N-Viro system and the finished N-Viro product, as shown in Table 90. Zinc and copper weredetected at the highest concentrations in both feed sludge and finished product. Mercury had thelowest detectable concentration of the metals examined.

Table 90. Metals in Feed Sludge after Admixture and N-Viro Products after Final Curing,Halifax NS

5.2<1.09.02.411157.90.1502.78.45.9231

6.7<1.011.32.910855.50.2793.38.33.0224

675000

At

4.11.3.3 PharmaceuticalsThe frequency of detection and median detected concentrations of the pharmaceutical compoundsin the sludge feed after admixture and N-Viro product after final curing at the Halifax N-Viro

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facility are presented in Table 91. The raw analytical data are provided in Appendix Table A19.A total of 19 pharmaceuticals were detected in the sludge feed samples in all three samplingcampaigns; 14 pharmaceuticals were detected in N-Viro after final curing samples from the threecampaigns. The compounds detected at the highest concentrations (above 1,000 ng/g TS) in theN-Viro product were the anti-microbials triclosan and triclocarban. Slightly lower concentrationswere found for the antibiotic ciprofloxacin and the non-steroidal anti-inflammatory ibuprofen.

Table 91. Frequency of Detection and Median Concentrations of PharmaceuticalCompounds in Feed Sludge after Admixture and N-Viro Product after Final Curing,Halifax, NS

Furosemide 1 1 137 a 259 a <89.4-137 <153-259Gemfibrozil 3 3 12.2 13.8 10.1-12.4 9.86-21.9Glipizide 0 0 NA NA <22.7 b <23 b

Glvburide 1 0 12a NA <5.42-12 <11.5 b

Hydrochlorothiazide 1 1 166 a 91.4 a <36.2-166 <40.5-91.42-Hydroxy-ibuprofen 2 1 200 189 a <145-228 <162-189Ibuprofen 3 3 319 522 315-623 369-528Naproxen 3 3 169 178 155-169 126-212Triclocarban 3 3 3780 1590 1540-9200 1260-1790Triclosan 3 3 7700 6120 5730-11500 4780-6520Warfarin 0 0 NA NA <5.68 b <5.74 b

Acetaminophen 0 0 NA NA <543 b <230 b

Azithromycin 3 3 349 36.8 223-469 5.27-157Caffeine 3 3 355 240 334-1120 143-386Carbadox 0 0 NA NA <5.68 b <5.74 b

Carbamazepine 3 3 137 79.4 114-349 40.7-100Cefotaxime 0 0 NA NA <129 b <161 b

Cinrofloxacin 3 3 1170 587 724-1840 560-605Clarithromvcin 3 1 31.1 11.5a 19.4-50.8 <3.05-11.5Clinafloxacin 1 0 17a NA <11.8-17 <67 b

Cloxacillin 0 0 NA NA <11.4b <11.5 b

Dehydronifedlnine 3 2 2.4 2.36 1.29-3.01 <1.22-2.79Diphenhydramine 3 3 656 140 298-900 87.4-216Diltiazem 3 0 2.79 NA 0.66-3.86 <1.15 b

Digoxin 0 0 NA NA <56.8 b <57.4 b

Dizoxizenin 0 0 NA NA <94.4 b <69.4 b

Enrofloxacin 1 0 12.6 a NA <5.44-12.6 <24.8Erythromycln-Hjf) 3 3 22 8.88 12.5-32.5 6.02-14.6Flumequine 0 0 NA NA <5.68 b <5.74 b

Fluoxetine 3 2 23.3 9.23 23-48.3 <3.05-9.67

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I (continued)

a indicates median value is from one detectable concentration onlyb indicates highest identified detection limit for compoundData in bold font are detected in all three sampling campaignsNA = not applicable (no median for all non-detectable concentrations)

Table 91 continued

Lincomycin 0 0 NA NA <25.3 <24.6Lomefloxacin 0 0 NA NA <11.4 b <13.7 b

Miconazole 3 3 517 319 448-664 230-400Norfloxacin 3 2 105 99 84.9-218 <30.5-99.2Norgestimate 0 0 NA NA <16.6 b <15.3 b

Ofloxacin 3 3 206 276 121-399 125-325Ormetoprim 0 0 NA NA <2.27 b <2.27 b

Oxacillin 0 0 NA NA <11.4b <11.5 b

Oxolinic Acid 0 0 NA NA <2.8 b <2.9 b

Penicillin G 0 0 NA NA <11.4b <11.5 b

Penicillin V 0 0 NA NA <11.4 b <11.5 b

Roxithromycin 0 0 NA NA <1.30 b <1.79 b

Sarafloxacin 0 0 NA NA <170 b <279 b

Sulfachloropyridazine 0 0 NA NA <5.68 b <5.74 b

Sulfadiazine 0 0 NA NA <5.68 b <5.74 b

Sulfadimethoxine 0 0 NA NA <1.41 b <6.64 b

Sulfamerazine 0 0 NA NA <3.08 b <2.33 b

Sulfamethazine 0 0 NA NA <3.73 b <4.72 b

Sulfamethizole 0 0 NA NA <2.84 b <3.97 b

Sulfamethoxazole 2 1 2.07 2.22 a <1.09-2.48 <1.22-2.22Sulfanilamide 0 1 NA 49 a <56.8 b <30.5-49Sulfathiazo le 0 0 NA NA <5.68 b <5.74 b

Thiabendazole 3 3 6.67 7.7 5.93-12.4 5.61-8.03Trimethoprim 2 1 20.5 17.2 a <3.71-33.1 <11.6-17.2Tylosin 0 0 NA NA <127 b <154 b

Virginiamycin 1 1 309 a 409 a <54.4-309 <90.3-4091,7-Dimethy lxanthine 2 1 517 378 a <272-727 <305-378

The distribution of detectable concentrations in the sludge feed after admixture and N-Viro afterfinal curing samples from the three sampling campaigns is found in Table 92. The distributionof detectable concentrations in the digester feed is somewhat different compared to the finishedstabilised product. The number of compounds detected in all three campaigns declines from 19 inthe sludge feed samples to 14 in the N-Viro after final curing samples, while the number ofcompounds never detected in any of the three campaigns rises from 28 in sludge feed samples to31 after final curing.

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Table 92. Summary of Pharmaceutical Compound Detections Metals in Feed Sludge afterAdmixture and Alkaline Stabilised Product after Final Curin , Halifax, NS

321

oTotal

1946

2857

1439

3157

4.11.3.4 Fragrance and Alkylphenolic CompoundsConcentration data for the fragrance and alkylphenolic compounds are provided in Table 93. Theraw analytical data are provided in Appendix Table A20. Bisphenol A was the onlyalkylphenolic compound detected at this site. BPA was detected in the feed sludge afteradmixture, and in the N-Viro product after curing, in both sampling campaigns. The medianvalue of BPA in the product at 790 ng!g TS dw was substantially higher than was the

Table 93. Frequency of Detection and Median and Range of Detected Concentrations ofFragrance and Alkylphenolic Compounds in Feed Sludge after Admixture and AlkalineStabilised Product after Final Curin Halifax, NS

DPMI 2 1 55 50 50-60 <40-50ADBI 0 0 NA NA <20 <20AHDI 1 0 70 NA <30-70 <30HHCB 2 2 3750 4115 3090-4410 2880-5350AHTN 2 2 480 690 300-660 620-760ATII 2 2 110 110 90-130 70-150Musk Moskene 0 0 NA NA <50 <50Musk Tibetene 0 0 NA NA <80 <80Musk Ketone 0 0 NA NA 0.04-60 <120Musk Ambrette 0 0 NA NA <140 <140MuskX lene 0 0 NA NA <70 <70

Data in bold font are detected in both sampling campaigns

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median concentration in the sludge feed (200 ng/g TS dw). The difference is most likely due tothe temporal difference in the composition of the various sludge streams that are combined as theprocess feed. No nitro musks were detected in any samples in either ofthe two samplingcampaigns. The polycyclic musk HHCB was observed at the highest median concentration of4115 ng/g TS dw in the finished biosolids product. The other synthetic musks detected in thefinished product were observed at substantially lower median concentrations ranging from 50 to690 ng/g TS dw. The concentrations ofthe fragrances in the finished biosolids product weresimilar but slightly elevated relative to the concentrations in the feed sludge samples.

4.11.4 Data Interpretation

4.11.4.1 Total Solids Mass Balance EstimateConcentrations for metals and pharmaceutical compounds are expressed on a dry weight basis(i.e., mg/kg TS dw for metals, ng/g TS dw for pharmaceuticals), and so the mass balances for theboth types of contaminants are based on a total solids balance around the alkaline stabilisationprocess. The solids balance around the N-Viro process is estimated using the mean values of thetotal solids concentrations in the feed dewatered sludge cake (following alkali amendment) andcured, stabilised biosolids out of the process from the three sampling campaigns. The pertinentsolids concentration and flow data are:

Mass feed rate of dewatered cake = 9 wet tonnes/hMean measured total solids concentration in dewatered cake feed = 48.1 % TSMass exit rate of cured, stabilised product = 7 wet tonnes/hMean measured total solids concentration in dried biosolids pellets = 68.6 % TS

In the balance, it was assumed the difference in the mass of dewatered cake solids entering andproduct leaving the process was the mass of water evaporated through the process. The totalsolids balance is depicted in Figure 19. The calculated masses of solids in and out of the processare approximately equal; the higher mass of solids leaving the drier than the mass entering thedrier is considered an artifact of the variability associated with sampling sludge and biosolids,and estimating the flow rates.

Water lost 2 wet t/h

Dewatered Cake Sludge in Dried Biosolids Pellets out

Feed RateTS Concn inTS mass in

9 wet t/h48.1 %4329 kg/d

N-ViroProcess

Exit RateTS Concn outTS mass out

'7 wett/h68.6 %4802 kg/d

Figure 19. Total Solids Balance around N-Viro Alkaline Stabilisation Process, Halifax, NS

4.11.4.2 MetalsThe mass balance closures for metals around the N-Viro process is provided in Table 94. Themass closures ranged from a low of 56% for selenium to a high value of 206% for mercury. With

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the exception of selenium, the mass closure values were all greater than 100%, suggesting themore of the metal mass was measured in the final product than in the feed. Possible reasons forthis observation include differences in composition between the dewatered sludge feed and finalproduct, and possible inaccuracies in the estimated feed and product mass flow rates.

Table 94. Mass Balance Closures for Metals in N-Viro Alkaline Stabilisation Process,Halifax NS

5.2 6.7<1.0 <1.09.0 11.3 39.0 54.3 139%2.4 2.9 10.4 13.9 134%111 108 480.5 518.6 108%57.9 55.5 250.6 266.5 106%

0.150 0.279 0.6 1.3 206%2.7 3.3 11.7 15.8 136%8.4 8.3 36.4 39.9 110%5.9 3.0 25.5 14.4 56%231 224 1,000.0 1,075.6 108%

4.11.4.3 PharmaceuticalsConcentrations of the pharmaceutical compounds measured on a dry weight basis (i.e. ng/g TSdw) were converted to a mass flow rate (mg/d) for comparison of input and output masses. Theresults of the mass estimates are provided in Table 95. Pharmaceutical compounds that were notdetected in both the feed sludge and digested biosolids were not included in Table 95.

Compounds that are removed to the greatest extent through the alkaline stabilisation processinclude the antibiotic azithromycin (88%), the stimulant diphenhydramine (76%) and the anti-angina medicine diltiazem (>76%). No compounds are removed in excess of 90% by theprocess. Among the poorest removal efficiencies (i.e., the mass out of the process is greater thanthe mass in) are the diuretic furosemide and the non-steroidal anti-inflammatory drug ibuprofen.

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Table 95. Mass Balance and Removal Calculations for Pharmaceutical Compounds in N-Viro Alkaline Stabilisation Process, Halifax, NS

137 259 593 1244 -110%12.2 13.8 52.8 66.3 -25%12 <6.15 51.95 <29.5 >43%166 91.4 719 439 39%200 189 866 908 -5%319 522 1381 2507 -82%169 178 732 855 -17%

3780 1590 16364 7635 53%7700 6120 33333 29388 12%349 36.8 1511 177 88%355 240 1537 1152 25%137 79.4 593 381 36%1170 587 5065 2819 44%31.1 11.5 135 55.2 59%17 <23 73.6 <110 >-50%2.4 2.36 10.4 11.3 -9%656 140 2840 672 76%2.79 <0.615 12.1 <2.95 >76%12.6 <11.5 54.5 <55.2 >-1%22 8.88 95.2 42.6 55%

23.3 9.23 101 44.3 56%517 319 2238 1532 32%105 99 455 475 -5%206 276 892 1325 -49%2.07 2.22 9.0 10.7 -19%6.67 7.7 28.9 37.0 -28%

20.495 17.2 88.7 82.6 7%309 409 1338 1964 -47%

516.5 378 2236 1815 19%

Removal efficiencies of the pharmaceutical compounds are categorised in Table 96. A total ofseven compounds were reduced by between 50 to 89% by the process. As many pharmaceuticalcompounds were removed in the 0 to 49% efficiency range as there were compounds removed inthe -49 to -1% range.

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Table 96. Categorised Removal Efficiencies of Pharmaceutical Compounds by N-ViroAlkaline Stabilisation Process Halifax, NS

Furosemide Glyburide TriclocarbanIbu rofen H drochlorothiazide Azithrom cin

Triclosan ClarithromycinCaffeine Di henh dramine

DiltiazemErythromycin-Hjt)

Enrofloxacin FluoxetineMiconazoleTrimetho rim

Virginiamycin 1,7-Dimethy lxanthinen=2 n=10 n=10 n=7 n=O

4.11.4.4 Fragrance and Alkylphenolic CompoundsThe mass balance and removal calculations for BPA and the detected synthetic musk fragrancesappear in Table 97. The observed higher concentration of Bisphenol A in the finished productrelative to the feed results in a negative removal efficiency. As explained earlier in this Section,the difference between feed and product masses is likely due to the variability in the mixture ofthe different feed sludges. The polycyclic musk compounds also exhibited negative removalefficiencies, although to a lesser extent than for BPA. The probable reason for the negativeremoval efficiencies calculated for the fragrances is the same as that for BPA.

Table 97. Mass Balance and Removal Calculations for Alkylphenolic and FragranceCom ounds in N-Viro Alkaline Stabilisation Process Halifax NS

DPMI 55 50 238 240 -1%AHDI 70 <30 303 <144 >52%HHCB 3750 4115 16234 19760 -22%AHTN 480 690 2078 3313 -59%ATII 110 110 476 528 -11%

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4.11.4.5 Effectiveness of Process for ESOC RemovalBased on the categorised removal efficiencies in Table 96, there appears to be a modest removalof the pharmaceutical compounds. There is a higher number of compounds (17) with positiveremoval efficiencies greater than 0 than the number (12) with removal efficiencies less than O.Seven pharmaceuticals have removal efficiencies between 50% and 90%. The removalmechanism for pharmaceuticals cannot be determined from the collected data, but may includechemical reaction at the higher pH caused by the addition of alkaline material, temperature-mediated chemical reaction or breakdown, or volatilization from the mixture during the period ofelevated temperatures in the process. There is no comparable positive removal of Bisphenol A orany of the polycyclic musk fragrances, which appear to be unaffected by the stabilisation process.

4.11.5 Section SummaryA higher concentration of nitrate-N was observed in the N-Viro product than in feed sludge afteradmixture. The concentrations oftotal Kjeldahl nitrogen (TKN) and ammonia-N (a componentofTKN together with organic-N) were lower in the N-Viro products than in the feed sludge. Theconcentrations of total and ortho-phosphorus were observed similar or conservative, as expectedduring biosolids drying and curing processes.

All the metals except cadmium were observed at detectable concentrations in both feed sludge tothe N-Viro system and the finished N-Viro product. Zinc and copper were detected at the highestconcentrations in both feed sludge and finished product. Mercury had the lowest detectableconcentration of the metals examined. The mass balance closures for the metals ranged from alow of 56% for selenium to a high value of 206% for mercury. With the exception of selenium,the mass closure values were all greater than 100%, suggesting the more of the metal mass wasmeasured in the final product than in the feed. Possible reasons for this observation includedifferences in composition between the dewatered sludge feed and final product, and possibleinaccuracies in the estimated feed and product mass flow rates.

A total of 19 pharmaceuticals were detected in the sludge feed samples in all three samplingcampaigns; 14 pharmaceuticals were detected in N-Viro after final curing samples from the threecampaigns. The compounds detected at the highest concentrations (above 1,000 ng/g TS) in theN-Viro product were the anti-microbials triclosan and triclocarban. Slightly lower concentrationswere found for the antibiotic ciprofloxacin and the non-steroidal anti-inflammatory ibuprofen.Compounds that are removed to the greatest extent through the alkaline stabilisation processinclude the antibiotic azithromycin (88%), the stimulant diphenhydramine (76%) and the anti-angina medicine diltiazem (>76%). Among the poorest removal efficiencies (i.e., the mass outof the process is greater than the mass in) are the diuretic furosemide and the non-steroidal anti-inflammatory drug ibuprofen.

Bisphenol A was the only alkylphenolic compound detected at this site. BPA was detected in thefeed sludge after admixture, and in the N-Viro product after curing, in both sampling campaigns.The median value ofBPA in the product at 790 ng/g TS was substantially higher than was themedian concentration in the sludge feed (200 ng/g TS). The difference is most likely due to thetemporal difference in the composition of the various sludge streams that are combined as theprocess feed. The observed higher concentration of Bisphenol A in the finished product relative

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to the feed results in a negative removal efficiency. No nitro musks were detected in any samplesin either of the two sampling campaigns. The polycyclic musk HHCB was observed at thehighest median concentration of 4115 ng/ g TS in the finished biosolids product. The othersynthetic musks detected in the finished product were observed at substantially lower medianconcentrations ranging from 50 to 690 ng/g TS. The concentrations of the fragrances in thefinished biosolids product were similar but slightly elevated relative to the concentrations in thefeed sludge samples. The polycyclic musk compounds also exhibited negative removalefficiencies, although to a lesser extent than for BPA. The probable reason for the negativeremoval efficiencies calculated for the fragrances is the same as that for BPA discussed above.

There appears to be a modest net benefit to the process for removal of the pharmaceuticalcompounds. There is a higher number of compounds (17) with positive removal efficienciesgreater than 0 than the number (12) with removal efficiencies less than O. Seven pharmaceuticalshave removal efficiencies between 50% and 90%. No compounds are removed in excess of90%by the process. There is no comparable positive removal of Bisphenol A or any of the polycyclicmusk fragrances, which appear to be unaffected by the stabilisation process.

4.12 Filter Press Sludge Dewatering, Gander, NL

4.12.1 Site DescriptionThe Gander facility (the Beaverwood Sewage Treatment Plant), is a hydrodynamic separatorfacility with chlorination disinfection of the treated effluent prior to discharge to the Gander Lakevia Soulis Brook. The design capacity of the existing treatment plant is 80,000 m3/d, while theaverage daily dry weather flow is 16,000 m3/d.

4.12.2 Belt Filter Press Dewatering Process DescriptionThe primary sludge from hydrodynamic separator is sent to the sludge thickening tank forthickening. The supernatant from the sludge thickening process is returned to the plant headworkfor treatment. The flow rate of supernatant is not measured by the plant due to the fact that rawwater is also introduced at this point for clearing processes making the calculations complex.The thickened primary sludge is pumped to the sludge holding tank, from where it is sent to thebelt press for dewatering. The pumping rate of feed sludge to the belt press is about 21.6 m31d.During this study, the solids concentration in the belt press feed (i.e. thickened primary sludge)ranged from 0.5% to 3.3%, while the dewatered biosolids cake solids concentration ranged from8.9% to 14.4%. The dewatered biosolids cake is sent to agricultural lands. The filtrate from thedewatering of primary sludge is directed back to the headworks of the treatment plant.For this proj ect assessment, the treatment process of interest was the belt press dewateringprocess. The three sampling locations included the belt press feed (i.e. thickened primary sludge),dewatered biosolids cake and filtrate. A process schematic of the Gander biosolids treatmentprocess is shown in Figure 20.

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