ECO Annual Report: Sound-Sorb Berms

Below are excerpts from the Environmental Commissioner of Ontario's Annual Report for 2001-2002 regarding Sound-Sorb berms in Ontario.
http://www.eco.on.ca/english/newsrel/02sep26a.htm


ECO ANNUAL REPORT PAGE 129-130

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Sound-Sorb

A number of gun clubs across southern Ontario are beginning to build high berms
on their properties to comply with new federal regulations to reduce noise and
dangers from bullets. A hauling company is encouraging gun clubs to build berms
using a mixture of approximately 30 per cent sand and 70 per cent paper mill sludge
from a newsprint recycling plant. The hauling company supplies this material free
of charge, and at trucking costs that are a small fraction of the normal charge.

The mixture of paper mill sludge and sand, called Sound-Sorb, is considered a
product rather than a waste by MOEE. Therefore, the ministry does not regulate this
material nor control how it is placed on land. Instead, if this material were deemed
to be a waste, it would be subject to controls to protect the environment.

Local residents have raised the concern that the impact of these paper mill sludge
berms on surface water and groundwater has not been examined. They note that
high levels of E. coli have been found in some samples of the paper mill sludge.
In December 2001 the ECO received an application for review concerning Sound-Sorb.

This application under the EBR requested a review of MOEE's policy exempting
Sound-Sorb from the Environmental Protection Act (EPA) and Section 3 of Ontario
Regulation 347. The applicants noted that Sound-Sorb is being applied directly to land
without any leachate control. They also stated that the paper mill sludge is not being
stabilized or changed in any way by adding sand, and that it continues to undergo
decomposition in the high berms. In addition, they pointed out that in 1997, an MOEE
district office determined that this material was a waste and ordered it removed
from a race track in Peterborough, where it had been placed as a noise barrier. They
also noted that tests of liquid at the base of a Sound-Sorb berm, carried out for the
Durham Region Health Department in 2001, found high levels of both fecal coliform
bacteria and E. coli. The source of these bacteria remains uncertain.

MOEE has agreed to undertake a review of the issues raised by the applicants, and
has informed the applicants that the review will be completed by November 2002.

The ECO will report on the outcome of MOEE's review in the next annual report.

(For ministry comments, see page 180.)


ECO ANNUAL REPORT PAGE 180
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Sound-Sorb

MOEE: A report detailing the results of monitoring conducted at the Oshawa Gun Club is posted on the
ministry's Web Site. The ministry is currently undertaking a review on the use of Sound-Sorb material.
The review will be completed by November with a final report to be issued in December 2002.


ECO ANNUAL REPORT SUPPLEMENT PAGE 247

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Preview of Application: R2001010: (Sound-Sorb)

A number of gun clubs across southern Ontario are beginning to build high berms on their
properties to comply with new federal regulations to reduce noise and dangers from bullets. A
hauling company is encouraging gun clubs to build berms using a mixture of approximately 30
per cent sand and 70 per cent paper mill sludge from a newsprint recycling plant. The hauling
company supplies this material free of charge, and at trucking costs which are a small fraction of
the normal charge. The mixture of paper mill sludge and sand is called Sound-Sorb and is
considered a product rather than a waste by MOEE. Therefore, the ministry does not regulate
this material, or control how it is placed on land. If this material was deemed to be a waste, it
would be subject to controls to protect the environment.

Local residents have raised the concern that the impact of these paper mill sludge berms on
surface water and groundwater has not been examined. They note that high levels of E. coli have
been found in some samples of the paper mill sludge.

In December 2001 the ECO received an application for review concerning Sound-Sorb. This
application under the EBR requested a review of MOEE's policy exempting Sound-Sorb from the
Environmental Protection Act (EPA) and Section 3 of Ontario Regulation 347. The applicants
noted that Sound-Sorb is being applied directly to land without any leachate control. They also
stated that the paper mill sludge is not being stabilized or changed in any way by adding sand,
and that it continues to undergo decomposition in the high berms. In addition, they pointed out
that in 1997, an MOEE District office determined that Sound-Sorb was a waste and ordered it
removed from a race track in Peterborough, where it had been placed as a noise barrier. They
also noted that tests of liquid at the base of a Sound-Sorb berm were carried out for the Durham
Region Health Department in 2001. These tests found high levels of both fecal coliform bacteria
and E. coli. The source of these bacteria remains uncertain.

MOEE has agreed to undertake a review of the issues raised by the applicants, and has informed
the applicants that the review will be completed by November 2002. MOEE has informed the
ECO that the final report will be issued in December 2002. The ECO will report on the outcome
of MOEE's review in the next annual report.
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Jode Roberts
Communications Coordinator
Sierra Legal Defence Fund
(416) 368-7533 ext. 25
www.sierralegal.org

Sierra Legal Defence Fund is Canada's foremost national non-profit organization dedicated to enforcing and strengthening the laws that safeguard our environment, wildlife and public health.