Report to / Rapport au :
Planning and Environment Committee
Comité de l'urbanisme et de l'environnement
and Council / et au Conseil
Submitted by/Soumis par : R.G. Hewitt,
Acting Deputy City Manager / Directeur municipale adjointe intérimaire
Ref N°: ACS2006-PWS-UTL-0006
SUBJECT: REVIEW OF THE BIOSOLIDS MANAGEMENT PLAN AND TECHNICAL OPTIONS FOR LONG-TERM BIOSOLIDS MANAGEMENT
OBJET : Examen du plan de gestion des biosolides et des options techniques pour une gestion des biosolides à long terme
That the Planning and Environment Committee recommend that Council:
1. Reaffirm the 2001 Biosolids Management Plan
2. Add the following options to the list of technologies to undergo detailed review:
· Energy from waste
· Land application with storage
· Co-composting with MSW organics
· Conversion of the digesters to either Auto-heated Thermophilic Aerobic Digestion (ATAD) or Two-phase Anaerobic Digestion
3. Accept for information the Audit Report of the Biosolids Management System.
Le Comité de l’urbanisme et de l’environnement recommande au Conseil municipal :
1. de réitérer le Plan de gestion des biosolides 2001
2. d’ajouter les options suivantes à la liste des technologies qui doivent subir un examen détaillé :
· l’énergie des déchets
· l’épandage et le stockage
· la collecte de composte et des déchets urbains organiques
· la conversion des digesteurs en stabilisation aérobie thermophile (SAT) ou en digestion anaérobie à deux étapes
3. d’accepter, à titre d’information, le rapport de vérification du Système de gestion des biosolides.
In 1996, the City of Ottawa prepared its first Biosolids Management Plan. The Plan underwent significant review and revision in 2001 following extensive consultation with the public and an analysis of technical options. Completed in accordance with the Municipal Class Environmental Assessment process, the 2001 Biosolids Management Plan Update contains recommendations concerning the short and long-term management of the City’s biosolids including a commitment to develop multiple end uses for the biosolids, implementing an environmental management system, and improving industrial source control. The Plan also identified four technical options ranked as “High” during the evaluation process. These options are intended to undergo further review in support of the Multiple-End Use recommendation:
· Heat drying;
· Lime stabilization; and
Since Council adopted the Plan in 2001, staff has undertaken the following:
The Biosolids Management System was implemented in 2005 and underwent its first audit in January 2006. The auditors reviewed the various systems put in place to manage, monitor, and control the biosolids program, and interviewed a variety of staff. In summary, the auditors concluded that “based upon the evidence collected…the BMS is a functioning management system that provides assurance that biosolids are being managed in accordance with City policy. Given the short period of time that the system has been functioning this is a credit to those involved.” Matters raised by the auditors as requiring attention are within the operating budgets of the program and will be completed this year. Staff will report back in one year on the progress made. The complete Audit is contained in Attachment 1.
Staff plans to commence work on review of the technical options short-listed in the 2001 Plan this year. Under the Municipal Class Environmental Assessment process, master plans such as the Biosolids Management Plan must be reviewed at least once every five years to remain valid. Therefore, staff requires Council to reconfirm both the Plan and the short-listed options before proceeding, as the Plan will otherwise expire during the course of the technical review.
Staff has undertaken a review of the 2001 Biosolids Management Plan Update and considered changes that could influence the need to modify the Plan. The issues considered included the following:
Based upon consideration of the above factors, and input obtained from the public and commenting agencies, staff concludes that the short and long-term strategies set out in the 2001 Master Plan remain current and appropriate to the needs of the City for two key reasons.
First, in many ways the 2001 Plan was ahead of its time because it recommended measures that the rest of the biosolids industry is only now beginning to embrace and implement. Secondly, during the review of the City’s land application program in September 2004, Council chose to implement Best Management Practices that exceed all others employed elsewhere in Ontario. The Plan remains forward-looking, and is compatible with the long-term vision of the City as set out in Ottawa 20/20, the Infrastructure Master Plan, and the Environmental Strategy. These reasons are more fully examined and explained in the body of this report.
With respect to the short-listed technical options, staff recommends the following additions:
At present the City has no storage facility for its biosolids. When the update was conducted in 2001 biosolids could be stored for up to 90 days on the land prior to spreading and incorporation. With adoption of the 2002 Nutrient Management Act and its regulation, on-site storage cannot exceed 10 days. Accordingly, it is appropriate that the City investigate storage options if it is to continue to land apply biosolids.
Energy from waste (e.g. plasma gasification) is gaining recognition as a viable means of managing certain wastes while recovering heat that can be used in the generation of electricity. This method of waste disposal is considered desirable under the Kyoto Accord, would help reduce total disposal volumes, could be added to the co-generation plant already located at the Robert O. Pickard Environmental Centre (or potential facility at Trail Road), and could be used to heat dry a portion of the biosolids produced at ROPEC.
Co-composting with the organics waste stream may be an option if Council chooses to implement a City Wide program in accordance with the recommendations of the Integrated Waste Management Master Plan. If staff are to investigate development of a composting facility, it would be prudent to investigate the potential cost savings that could be accrued by co-mingling and processing of the two waste streams.
Conversion of digester operations to either Two-phase Anaerobic Digestion (TPAD) or Auto-heated Thermophilic Aerobic Digestion (ATAD) could enable production of a Class A biosolids product. This would enable greater assurance in implementation of the City’s Land Application Program. Neither process had proven full-scale operations in 2001 but have since demonstrated their viability.
En 1996, la Ville d’Ottawa a élaboré son premier Plan de gestion des biosolides. En 2001, le Plan a subi un examen et des révisions importantes à la suite d’une vaste consultation du public et d’une analyse des options techniques. Rédigé conformément au Processus municipal d’évaluation environnementale de portée générale, la Mise à jour du plan de gestion des biosolides de 2001 comprend certaines recommandations portant sur la gestion à court et à long terme des biosolides de la Ville, notamment un engagement dans l’élaboration de diverses utilisations finales pour les biosolides, la mise en place d’un système de gestion environnementale et l’amélioration du contrôle des sources industrielles. Le plan a également servi à déterminer quatre options techniques ayant obtenu une cote élevée au cours du processus d’évaluation. Ces options devront subir un examen approfondi en appui aux recommandations des diverses utilisations ultimes :
· séchage thermique;
· stabilisation à la chaux;
Depuis l’adoption en 2001 du Plan par le Conseil, le personnel a entrepris les actions suivantes :
En 2005, le Système de gestion des biosolides a été mis en œuvre et il a subi sa première vérification en janvier 2006. Les vérificateurs ont examiné les divers systèmes mis en place dans le but de gérer, de surveiller et de contrôler le programme des biosolides, et ont interviewé plusieurs membres du personnel. En bref, les vérificateurs ont conclu : « qu’en fonction des données recueillies… le SGB est un système de gestion fonctionnel qui garantit la gestion des biosolides conformément aux politiques de la Ville. Étant donné le court laps de temps écoulé depuis l’entrée en fonction de ce système, cette évaluation doit être interprétée comme un éloge au personnel. » Les problèmes qui ont été soulevés par les vérificateurs sont déjà prévus dans le budget de fonctionnement du programme et seront donc réglés cette année. Le personnel présentera ses conclusions sur les progrès effectués dans un an. La vérification complète se trouve à l’annexe 1.
Le personnel prévoit débuter cette année l’examen des options techniques présélectionnées dans le Plan de 2001. Selon le Processus municipal d’évaluation environnementale de portée générale, les plans directeurs tels que le Plan de gestion des biosolides doivent être homologués tous les cinq ans. De plus, le personnel demande au Conseil municipal de réitérer le Plan et les options présélectionnées avant d’entreprendre l’examen technique afin d’éviter que le Plan n’arrive à échéance, alors que l’examen soit commencé.
Le personnel a examiné la Mise à jour du plan de gestion des biosolides de 2001 et a déterminé les changements qui pourraient mener à la modification du Plan. Les questions soulevées sont :
En raison des facteurs susmentionnés et des commentaires obtenus du public et des organismes chargés de formuler des commentaires, le personnel a conclu que les stratégies à court et à long terme prévues dans le Plan directeur de 2001 sont toujours actuelles et appropriées aux besoins de la Ville et ce, pour deux principales raisons.
D’abord, le Plan de 2001 était de toute évidence en avance sur son temps puisqu’il recommandait des mesures que le reste de l’industrie des biosolides commençait à peine à comprendre et à mettre en place. De plus, au cours de l’examen du programme d’épandage de la Ville en septembre 2004, le Conseil a choisi de mettre en place des pratiques de gestion exemplaires supérieures au reste de l’Ontario. Le Plan est tourné vers l’avenir et est compatible à la vision à long terme de la Ville précisée dans Ottawa 20/20, le Plan directeur de l’infrastructure et la Stratégie environnementale. Ces raisons font l’objet d’un examen approfondi dont le détail se trouve dans le présent rapport.
En ce qui touche les options techniques présélectionnées, le personnel recommande les ajouts suivants :
Actuellement, la Ville n’a pas d’installation de stockage pour ses biosolides. Au moment de la mise à jour du programme en 2001, les biosolides pouvaient être stockés jusqu’à 90 jours avant d’être épandus et incorporés au sol. Avec l’adoption de la Loi sur la gestion des éléments nutritifs de 2002 et des règlements connexes, le stockage sur place ne peut maintenant dépasser 10 jours. La détermination d’options de stockage par la Ville est donc appropriée, ne serait-ce que pour poursuivre le programme d’épandage des biosolides.
L’énergie des déchets (p. ex., gazéification au plasma) est de plus en plus populaire comme moyen viable de gérer certains déchets tout en récupérant la chaleur dégagée en la convertissant en électricité. Cette méthode d’élimination des déchets est souhaitable en vertu de l’Accord de Kyoto; elle aiderait à réduire le volume total de déchets; elle pourrait s’ajouter à l’usine de cogénération située au Centre environnemental Robert O. Pickard (ou autre installation possible sur le chemin Trail) et elle pourrait servir au séchage thermique d’une portion des biosolides produits au CEROP.
La collecte de composte et des déchets urbains organiques est une option envisageable si le Conseil choisit de mettre en place un programme panmunicipal conformément aux recommandations du Plan directeur de la gestion intégrée des déchets. Si le personnel doit étudier la mise en place d’une installation de compostage, il serait prudent d’examiner les économies possibles qui pourraient s’accumuler en mélangeant et en traitant deux systèmes de gestion des déchets.
La conversion des opérations des digesteurs en la digestion anaérobie à deux phases et la stabilisation aérobie thermophile (SAT) permettrait la production de biosolides de classe A. Cette production garantirait la mise en place du programme d’épandage de la Ville. Aucun de ces processus n’a fait ses preuves par un fonctionnement à plein rendement en 2001, mais ils ont tout de même démontré leur viabilité.
Prior to 1993, when the new Robert O. Pickard Plant Environmental Centre (ROPEC) was commissioned, the City used 12 aeration lagoons situated at the plant to hold solids generated during the treatment of Ottawa’s wastewater. With installation of new equipment and processes, liquid and solid waste streams were divided, and “biosolids” were generated that required separate handling and disposal.
During the 1990’s the City undertook agricultural land application and land filling of the biosolids. As volumes increased and the challenge of their disposal grew, the City prepared a Biosolids Management Plan in 1996 to help guide their handling and disposal. In 2000, a major review of the Management Plan was commissioned to develop a long-term strategy. To facilitate implementation of the study’s recommendations, the initiative was undertaken in accordance with the Municipal Class Environmental Assessment process, covering Phases I and II of the planning process (problem definition and selection of preferred approach).
Over the ensuing year, a Public Advisory Committee was created which met several times, two public information meetings were held and a workshop was undertaken, with the recommended Plan going before Council in December 2001. The updated Plan contained the following key recommendations:
Diversification of the current biosolids management strategy will reduce the risk to the City that regulatory, policy, or technical changes will result in loss of a reuse/disposal strategy without a suitable replacement. In support of the multiple end-use strategy, the 2001 Plan identified four suitable biosolids strategies for further evaluation:
· Heat drying;
· Lime stabilization; and
Council adopted the Plan in its entirety in December 2001, but adopted a motion in April 2002 to discontinue the Land Application Program. Council revisited this matter in September 2004, at which time it was decided to resume land application of up to 50% of the City’s biosolids, but only in accordance with the Best Management Practices (BMPs) recommended by the Medical Officer of Health. With the Fall 2004 decision, the Biosolids Management Plan Update was adopted in its entirety.
Table 1 identifies how the City’s biosolids can be used, and the end-uses that are possible depending upon the quality of biosolids produced. The table shows that the City’s Class B biosolids are buried and land applied, and that a portion of the City’s biosolids undergoes further processing through composting to become a Class A product. The composted product is blended with other materials by the City’s contractor GSI Environnement Incorporated and marketed as a commercial soil amendment.
Treatment and management methods currently employed by the City are underlined. Items in bold reflect technologies that were either not considered in 2001, or that did not make the short-list of technologies and which staff believe should be considered during the upcoming review.
Table 1: Biosolids Management Technologies and Disposal Options
Management Options and End-Use
§ ROPEC High Rate Mesophilic Anaerobic Digestion
§ Daily cover at a landfill
§ Agricultural land application
§ Site reclamation / restoration
§ Sale of commercial soil amendment
§ Forest land application
§ Class A only - Public contact: parks, golf courses, highway medians, etc.
§ Co-compost with municipal organic waste
§ Auto-heated Thermophilic Aerobic Digestion (ATAD)
§ Two-phase Anaerobic Digestion (TPAD)
Class A Exceptional
§ Alkaline (lime) Stabilization
§ Produce commercial fuel
§ Produce commercial fertilizer
§ Generate heat and energy
§ Bury or land apply the ash
Underlined = methods currently employed; Bold = technologies recommended for consideration
The Robert O. Pickard Environmental Centre uses anaerobic mesophilic digesters (oxygen free, moderate temperature) to produce a Class B biosolids product. In the U.S.A., “Class A” and “Class B” are terms used to distinguish biosolids of different composition and containing different levels of pathogen density. Where Class A is considered to be practically pathogen-free, Class B is not. Both Class A and B biosolids can be land applied, however, Class A products generally do not have the same odour issues.
Since its adoption, work has been undertaken to implement various elements of the Plan. Specifically, staff has:
Phased implementation of the draft Biosolids Management System began in 2005. The system underwent its first third-party audit in January 2006 with key findings and recommendations identified in Table 2:
Table 2: 2006 BMS Audit Key Results
§ Work planning and performance measurement are undertaken in accordance with the BMS.
§ Hazard Identification and Risk Analysis were completed.
§ Copies of all relevant legal requirements and operating authorities are maintained.
§ The BMS is electronic and uses hyperlinks to important documents.
§ The one incident that occurred in 2005 was reported and documented, and preventative action taken. (Truck slid off icy road and spilled load.)
§ Improve clarity in the use of terminology.
§ Improve clarity regarding roles and responsibilities.
§ BMS to be finalized and communicated to all relevant staff and stakeholders.
§ BMS to be approved at the Director level.
§ BMS policies to be placed on the City’s website.
§ Follow through with planned staff and contractor training.
In summary, the auditors concluded that “based upon the evidence collected…the BMS is a functioning management system that provides assurance that biosolids are being managed in accordance with City policy. Given the short period of time that the system has been functioning this is a credit to those involved.” All of the recommendations are within the staff and budget resources of the Branch, and will be undertaken in 2006. A copy of the complete audit is contained in Attachment 1.
While staff will continue to use the BMS to manage current operations, it is important that the City study and work towards commissioning any new treatment/disposal process that may be desired when the current contract with GSI Environnement Incorporated expires 31 December 2009. As many capital works of this nature can take up to five years to plan, design, construct, and commission, selection of the preferred approach should be decided upon this year. Accordingly, staff must commence detailed evaluation of the short-listed technical options put forward in the 2001 Biosolids Management Plan Update this fall and bring forward a preferred solution(s) this spring 2007 for Committee and Council consideration.
Under the Municipal Class Environmental Assessment process, master plans such as the Biosolids Management Plan must be reviewed at least once every five years to remain valid. Therefore, before proceeding with the detailed evaluation, staff requires Council to reconfirm, amend, or adopt a new Plan otherwise the current Plan will expire during the course of the technical review. Following adoption by Council, a notice of the decision and the Plan will be placed on public record for comment, and potential appeal to the Minister of Environment.
The following sections of this report set out staff’s evaluation of the existing Plan. Specifically, changes in the following matters are addressed:
Based upon an evaluation of these matters, staff conclude that the 2001 Plan remains current, but requires minor modifications to the list of short-listed technical options to address changes that have occurred in the areas noted, as discussed in greater detail below. These findings are supported by a review of the Master Plan conducted by consultants in 2005 (refer to Attachment 2.)
Municipal Policy Direction
While the Biosolids Management Plan Update predates Ottawa 20/20, it reflects many of the same values, as shown in Table 3:
Table 3: Policy Comparison
Biosolids Management Plan
Manage material resources as efficiently as possible.
Multiple end-uses focused on waste diversion and beneficial use: compost, land application, and landfill daily cover.
Establish a transparent and accountable monitoring and reporting process.
Biosolids Management System (continuing phased implementation; first audit completed).
Protect surface and groundwater.
Medical Officer of Health Best Management Practices (in use today);
Sewer Use By-Law significantly amended in 2004.
Nutrient Management Strategy.
Completed and approved by the Province in December 2004.
If the Energy-from-Waste and co-composting (with source separated organic waste) options are carried forward as recommended, the City could also make progress towards the following Ottawa 20/20 policies:
· Manage greenhouse gas emissions to meet targets; and
· Develop partnerships to maximize available resources.
In summary, Ottawa 20/20 and the Biosolids Management Plan
share a common policy direction and no changes to the Management Plan are
required at this time. There is,
however, an opportunity to explore options that look more favourable in 2006
(??) than they did in 2001; therefore,
staff recommend amendment to the short-listed technologies to include
energy-from-waste and co-composting options.
Since adoption of the Biosolids Management Plan Update in December 2001, four significant changes have occurred in the biosolids regulatory environment:
1. Adoption of the Nutrient Management Act and implementing regulations by the Province of Ontario;
2. Drafting of the Clean Water Act (formerly known as the Drinking Water Source Protection Act) by the Province of Ontario;
3. Drafting of proposed amendments to the Fertilizer Act by the federal government; and
4. Ratification of the Kyoto Accord by the federal government.
1. The Nutrient Management Act governs the use of nutrients (e.g. fertilizers such as nitrogen and phosphorous) on agricultural land, including municipal biosolids. Key changes imposed under the 2002 Act and regulations are the following:
Many of the restrictions now imposed under the Nutrient Management Act are reflected in the Best Management Practices recommended by Ottawa’s Medical Officer of Health and adopted by Council. Accordingly, they have little impact on the City’s Land Application Program. However, new restrictions to on-site storage will impact the viability of the program over time, therefore, staff recommend that storage in combination with land application be added to the short-list of management options to be considered.
2. The draft Clean Water Act requires, amongst other things, the creation of Source Protection Plans. These plans will delineate areas of particular sensitivity or need of protection, and could further reduce areas available for land application. Authority may also be given to the Source Protection Committees, administered by local conservation authorities, to impose more stringent requirements on biosolids management activities in some areas. In short, as source water protection initiatives increase, opportunities for land application may decrease.
As with the Nutrient Management Act, the City’s Best Management Practices may already address many of the matters raised in the draft Clean Water Act. For example, with respect to the creation of wellhead protection zones, the City has already established land application set backs of 450 metres from any population centres (e.g. hamlets) and 90 metres from any well or residence. Staff will ensure that any new requirements are adopted, and monitor for potential impacts on the long-term viability of this management option.
3. Changes proposed to the Fertilizer Act and related legislation are far reaching and could have implications on all commercial fertilizers that contain animal by-products. The intent of the proposed changes is to eliminate the potential for livestock ingestion of products that may contain Bovine Spongiform Encephalopathy (BSE). At present, fertilizers that meet current standards, such as the City’s composted biosolids, are sold for unrestricted use. Under the new legislation their use may be prohibited on hay crops and pastureland. If adopted, this could impact the end-use markets for the composted biosolids. The Canadian Water and Wastewater Association (CWWA) provided input disputing the rationale of several elements of this regulation, which were supported by City staff.
4. The Kyoto Accord represents both an opportunity and a constraint to the management of municipal biosolids. The intent of the Accord is to reduce the emission of greenhouse gases (GHGs). Some biosolids management options (such as heat drying) consume fossil fuels and release GHGs. If, however, biosolids are used as the fuel, and/or recovers/generates energy, then the facility would be considered beneficial.
Ottawa’s Environmental Strategy identifies ratification of the Kyoto Accord by Canada as a key matter impacting City policies and activities, particularly the federal government’s 2003 Climate Change Plan which notes “municipalities have direct and indirect control of approximately 50% of energy use.”
An Energy-from-Waste facility (e.g. plasma gasification) would help to reduce total disposal volumes, and could be added to the co-generation plant already located at the Robert O. Pickard Environmental Centre, or the new facility planned at Trail Road. In conclusion, staff recommend that Energy-from-Waste be added to the list of alternatives to be examined in addition to or instead of incineration, with the potential for use as a biosolids heat drying facility.
The above regulatory changes underscore the need to maintain the City’s current policy of “multiple end-use”. The City needs to have other disposal methods available to help offset increasing restrictions governing land application and the use of composted materials. Staff monitors regulatory changes and the development of new management approaches through participation in local public works associations.
Little has changed in biosolids management in Ontario since 2001, with the exception of operational changes required to address the new Nutrient Management Act. Land application remains the primary means of biosolids management. However, many municipal authorities recognize that agricultural outlets are decreasing with urban expansion, while at the same time total biosolids production is increasing with population growth. Accordingly, several municipalities are developing other management options to help balance their disposal program. Other methods being pursued or already in use elsewhere in the Province include: incineration, landfilling, lime stabilization, and heat drying.
All four of the above methods are on the City’s short-list of alternative technologies to be examined, and support the City’s policy of “multiple end use.” That policy, set in 2001, remains current and reflects where the biosolids industry is heading in Ontario. In examining these alternative approaches, staff will investigate the lessons learned by municipalities with experience in these areas.
Changes At ROPEC
This spring, construction began on two new digesters at ROPEC. The new digesters will effectively double the capacity for biosolids production at the plant when commissioned in 2007, and were designed to accommodate increased solids entering the sewer system from the City’s two water purification plants.
While the digesters are designed to operate similarly to the existing digesters on site, they could, with some modifications be altered to produce a Class A biosolids product. One of two processes is possible:
· Auto-heated Thermophilic Aerobic Digestion (ATAD); and
· Two-phase Anaerobic Digestion.
Both of these processes could be used to generate a high quality biosolids product. Neither process had proven full-scale operations in 2001, but both have since demonstrated some potential and viability at ROPEC. Accordingly, staff recommend that conversion of the existing and new digesters be added to the short-list of technical options.
The list of alternatives contained in the 2001 Biosolids Management Plan Update reflects very much what is in use today, including leading edge technologies. The one exception is Energy-from-Waste, which was not identified as a specific alternative. Staff recommend that Energy-from-Waste (EFW) be added to the short-list for the following reasons:
· It could be powered using biosolids or mixed waste streams (e.g. MSW), and surplus methane generated at ROPEC;
· It could be situated at ROPEC or Trail Road;
· It would reduce total biosolids volumes; and
· Heat generated by the EFW could be used to treat a portion of the biosolids to a Class A standard, or for another beneficial purpose.
Three technologies were considered in 2001, but did not make the short-list because they were not feasible or proven at that time. Staff recommend that the following three technologies be added to the short-list for consideration:
· Co-composting – This may be a viable option as the City moves towards collection and management of source separated organic waste. Economies of scale could be achieved without significantly increasing total volumes produced.
· Auto-heated Thermophilic Aerobic Digestion (ATAD) – With construction of the two new digesters this process is now possible and would enable production of a Class A product.
· Two-phase Anaerobic Digestion (TPAD) – With construction of the two new digesters this process is now possible and would enable production of a Class A product.
The policies set out in the Biosolids Management Plan Update are current and forward looking, and do not require revision. The short-listed technical options:
· Heat drying;
· Lime stabilization; and
should be amended to include the following five additional options:
· Land application with storage;
· Auto-heated Thermophilic Aerobic Digestion (ATAD); and
· Two-phase Anaerobic Digestion.
With respect to the Biosolids Management System (BMS), the first third-party audit confirms that the system is functioning and is being used to help achieve the City’s objective of consistent and transparent compliance with regulatory standards and the City’s best management practices. The audit identifies several opportunities for continuous improvement. All of the audit recommendations are within the staff and budget resources of the branch and will be undertaken this year.
The Biosolids Management Plan, amended as recommended, will have limited impacts on the natural environment. The purpose of the Plan is to ensure the safe management and disposal of the City’s biosolids. Environmental impacts of the short-listed alternatives recommended herein will be assessed and evaluated during the next phase of the technical review, to be completed in spring 2007.
In September 2004, Council adopted a plan to move towards 50% land application of the City’s biosolids over the next five years. The Biosolids Management Plan, amended as recommended, will enable the potential generation of higher quality product for land application, and the implementation of alternative disposal methods. As well, by maintaining the current approach of land applying a percentage of the biosolids, local farmers benefit from the free application of this nutrient rich soil amendment.
A Public Notice was published in the Ottawa Citizen and Le Droit on Friday, 13 May 2005. A copy of the Notice and an invitation to comment was sent to members of the Public Advisory Committee who participated in the 2000-2001 review of the Biosolids Management Plan, along with a copy of the 2001 Plan. The notice, letter, and Plan were also sent to key regulatory and interested agencies.
Staff met with members of the Environmental Advisory Committee to discuss the updated work in June 2005, and again on February 23 and March 9 2006. A verbal report on feedback received from Environmental Advisory Committee members will be provided at Planning & Environment Committee on March 28, 2006.
Generally, there has been limited public concern in response to the increased notification and signage requirements that were implemented in accordance with the City’s new best management practices. Over 80 households received notification about the 2005 land application program. City staff and the contractor fielded 12 calls expressing concern about the practice of land application. Only one complaint was received which was the result of a misunderstanding about the date on which the biosolids were to be delivered and spread, and was resolved between the City’s contractor and the farmer receiving the biosolids. While not universal, there appears to be greater comfort with the City’s program, which includes implementation of the Biosolids Management System, third party monitoring and auditing, and well testing, in addition to regulation by the Province.
Review of alternative biosolids technologies is identified in the Long Range Financial Plan and the 2006–2014 Capital Forecast. Funds are available in the 2006 Capital Budget, Internal Order 900421 Biosolids Management Plan Initiatives.
Attachment 1 - Stratos Inc., Management Systems Audit of the City of Ottawa Draft Biosolids Management System, January 2006.
Attachment 2 - CH2M Hill, Review of the Biosolids Management Plan Update, May 2005.
1. Public Works and Services staff edit and publish the Biosolids Management Plan as amended.
2. Public Works and Services staff conduct a detailed review of the short-list of technical options, as amended, and report to Committee and Council in the third quarter of 2006 with a preferred solution(s).
3. Public Works and Services staff implement the recommendations of the Biosolids Management Systems Audit, and report to Committee and Council in a year on progress made.
Management Systems Audit of the
City of Ottawa Draft Biosolids Management System
Purpose and Objectives
The purpose of this report is to document the results of an audit of the City of Ottawa’s draft Biosolids Management System. This audit is based on a terms of reference provided in the Request for Proposals dated November 7th, 2005, and the Audit Plan dated December 21st, 2005.
The objectives of this audit were to:
This audit assessed the degree to which biosolids management activities at the City of Ottawa conform with the requirements of the Utility Management System and the Biosolids Management System.
The scope of this audit was the draft Biosolids Management System within the overall Utility Management System, at the City of Ottawa.
The time period reviewed was from the date of initiation of the draft Biosolids Management System early in 2005 to the date of the audit.
For the purpose of this audit, the audit entity included all organizational units and activities within the City of Ottawa’s Biosolids Program that may impact the environment, the health and safety of employees and the public, and the quality of biosolids. Many biosolid management activities are carried out by contractors, and as a result the audit entity also included the contractual relationship between the City of Ottawa and those contractors, in particular GSI Environment.
The audit was carried out in accordance with CAN/CSA-ISO 19011:03 Guidelines for Quality and/or Environmental Management Systems Auditing.
The audit assessed conformance of biosolids management activities at the City of Ottawa with the requirements of the UMS and BMS. 18 audit criteria were assessed at one of four possible levels:
The results were as follows:
Some action initiated
In the opinion of the auditor, based on the evidence collected and presented above, the BMS is a functioning management system that provides assurance that biosolids are being managed in accordance with City policy. Given the short period of time that the system has been functioning, this is a credit to those involved.
The item that was assessed at the level “No Action” falls under section 3.6 of the UMS - Project Management. This section of the UMS specifies that if a project relates to a new development and new or modified activities, products or services, programs shall be amended where relevant to ensure that environmental, health and safety and quality applies to such projects. Given the relatively recent implementation of the BMS, there has not been an opportunity to implement this requirement. If a new project or activity were to be initiated, there should be a process in place to ensure environmental, health and safety and quality issues would be considered.
The items that were assessed at the level “Some Action Initiated” included the following:
Key areas that require attention or where there is room for improvement include:
Based on the observations and findings presented in the report, the following recommendations are submitted for consideration and action:
· Submit the Biosolids Management Policy Statement to the Director of Utility Services for review and endorsement. Once approved, post the policy in city locations where Biosolids Management activities occur (i.e. ROPEC and Environmental Programs), and make the policy available to the public by posting it on the Biosolids web site;
· Clarify and document roles and responsibilities in line with the guidance provided in the document control procedure:
o Define Top Management as the Director of Utility Services; and
o Define the management representative as Program Manager, Environmental Programs;
· Make final revisions to the UMS and BMS and communicate to City Staff and all stakeholders that the UMS and BMS are approved and implemented;
· In making revisions to the BMS, clarify terminology related to contingency, emergency response, and business continuity plans. Finalize these documents and provide training on approved plans; and
· Implement a full compliance auditing process of all biosolids management activities.
Review of Management Plan Update
Review of Alternative Biosolids Management Strategies from the Biosolids Management Plan Update Study, July 2001
Sally McIntyre/City of Ottawa
Peter Burrowes/CH2M HILL
Janice Patterson/CH2M HILL
On March 15, 2005, the City of Ottawa retained CH2M HILL to review the four Alternative Strategies for Biosolids Management, as well as continued land application, as recommended in the Biosolids Management Plan Update Report from July 2001.
The purpose of the review was to determine whether the context within which the 2001 Update was undertaken had changed significantly, and whether any such changes necessitated amending the recommendations contained in the Biosolids Management Plan.
To that end, this technical memorandum reviews and discusses the recommended Alternative Strategies for Biosolids Management and evaluates the implications of the following on the management strategies of the 2001 Update Report:
· Industry trends,
· New and emerging regulatory implications,
· Technology advances, and
· Co-treatment of biosolids and municipal organic waste.
The overall objective of the Biosolids Management Plan Update Study was to establish a comprehensive strategy that indicated how all biosolids produced in the City could be managed in a beneficial, efficient, cost-effective, and sustainable manner. As a result of this study, a two-stage approach was recommended over the short- and long-term periods.
· Develop multiple end-uses
· Develop an Environmental Management Strategy (EMS)
· Continue with the existing land application and landfill practices
· Develop improved Industrial Source Control
· Conduct further research to investigate/improve viability of some of the alternatives
· Implement multiple end uses
· Implement EMS
· Implement improved Industrial Source Control
In parallel with the development of multiple end-uses and an EMS to improve both regulation of and public confidence in the program, it was recommended that the City continue its historical practice for the short term and land apply the anaerobically digested dewatered biosolids when possible and, during non-application periods, transfer the biosolids to landfill.
Further processing by low-rate composting of the biosolids as landfill cover material was recommended as long as there demand existed for this material. Once the demand was exceeded, landfilling of the biosolids, blended with municipal solids waste, was recommended.
While this alternative received only a “medium” overall ranking, other alternatives with “high” ranking required several years to develop. The review of the historical biosolids management program and the analysis of alternative biosolids management options indicated that the existing method of management was the most economical for the City in the short term, as long as there was sufficient agricultural land available to land apply the biosolids and there were no political or social barriers to this method of management. Furthermore, it was noted that the practice of land application lends itself well to the beneficial use of nutrients and organic matter in the biosolids, and thereby supported Ottawa’s agricultural community. When compared to other alternatives with a “medium” ranking, selection of this alternative for the short term provides the City with the most long-term flexibility by maintaining an excellent relationship with the agricultural community.
A storage facility that would allow land application of all biosolids was not recommended. The comprehensive review of storage technologies found them to be either expensive, technologically unproven, or both. Furthermore, if changes in the technical/regulatory environment dictated changes in biosolids treatment technology, a current facility design may not be suitable for product in the future.
Four biosolids strategies evaluated received a “high” ranking in the comparison of technology alternatives for producing products which may allow for multiple end-uses. These strategies were Composting, Heat Drying, Lime Stabilization, and Incineration. These strategies were recommended for further investigation and, possibly, implementation over the long-term. These four strategies, along with land application (the recommended short-term strategy), are reviewed in this Technical Memorandum.
In Ontario, land application is still the primary end-use for most municipalities. Regulations currently under development, review, and revision are unlikely to have a large impact on the viability of land application.
However, due to the issue of storage, municipalities are looking for other management options during the winter months. For the past five to ten years, long periods of inclement weather have resulted in reduced application periods and increasing volumes of biosolids requiring storage. While the Nutrient Management Regulation requires 240 days storage for new and expanding facilities, if no other management alternatives are available (other than contingency alternatives), most existing facilities have significantly less available storage. Furthermore, any amount of storage, even 240 days capacity, does not guarantee that all biosolids may be land applied, as land application programs must respond not only to weather conditions, but land availability, cropping practices, equipment availability, timely site approvals, etc.
There is an awareness of the lack of sustainability of land application as a single management method, so to strengthen their programs, some municipalities are looking at product diversification. Diversification typically involves the ability to further process a portion, or all, of the biosolids produced, and/or utilize the biosolids in different markets or for different end-use applications.
An example in Ontario is the Regional Municipality of Niagara, which has generally land applied all of the liquid biosolids produced at its wastewater treatment plants (WWTP). In Niagara, the historical practice has been to use the municipality’s centralized storage facility for liquid biosolids from all of its WWTPs when direct land application was not available. Following recommendations in their Biosolids Master Plan, the municipality installed dewatering at the centralized storage facility, allowing for contingency disposal in sanitary waste landfills. Furthermore, an alkaline stabilization facility is currently being designed and constructed, which will process up to 50 percent of the municipality’s biosolids. The biosolids will be processed, and the alkaline product marketed and distributed by a private agricultural co-operative, at a price guaranteed under contract to the municipality.
We can identify this trend in other Ontario municipalities, as well as across Canada. Where possible, municipalities prefer to land apply biosolids, due to the economic value and the recycling aspect of the program. The Cities of Guelph, Calgary and Winnipeg, and the Regional Municipality of Durham are excellent examples. These municipalities utilize storage facilities, or other end-use options when land application is not available, in order to sustain their programs.
Land application programs are most successful though, where product diversity or multiple end-uses are put into practice. For instance, Moncton employs a small alkaline stabilization facility, mixes some biosolids with soil for sale as a soil amendment, and composts the remainder with leaf and yard waste. Edmonton runs a liquid land application program as well as co-composting with municipal solid waste. The Greater Vancouver Regional District dewaters and utilizes their biosolids in mining restoration projects.
A smaller number of municipalities process and dispose of their biosolids via incineration. These include London, Peel Region, and Montreal. These municipalities typically spend an order of magnitude more dollars on their management programs. While these incineration programs typically operate without negative public response, there is seldom a public consultation component to decision-making within these municipalities. And, we have yet to witness a successful example of a municipality siting a new incinerator, as historically the Ontario public has presented great opposition to construction of new incinerator facilities.
The Biocycle 2000 Survey of biosolids management in the United States found that sixteen states had one or more counties and/or towns with restrictions, bans or ordinances on land application of biosolids. California (16), New Hampshire (40), and Virginia (29) had the greatest number, and seemed to be experiencing the most negative impact on beneficial use programs. New Jersey noted that state law preempts any local bans or ordinances.
The restrictions, bans, or ordinances on land application are typically for Class “B” biosolids (as classified under United States Environmental Protection Agency Guidelines and Regulations for the Use and Disposal of Sewage Sludge [40 CFR 503]). A number of these restrictions were implemented following public concern by well-organized groups. However, most US municipalities tend to fight these bans, and continue with land application programs.
In Ontario, we have seen municipalities and small public groups try to ban land application in their neighbourhoods, but, by law, their attempts do not stand since the program is regulated provincially.
Odour at land application sites has been the root cause for many land application restrictions, bans, or ordinances. Odour issues have been more prevalent with dewatered biosolids than with liquid biosolids. Unlike the case in Ontario, in the US, dewatered biosolids are not typically incorporated into the soil, following application.
Therefore, there has been a tendency for municipalities to move towards investigating and implementing improved Class “A” treatment technologies, where land application is a major part of the end-use, and/or using dedicated land which is solely managed within the biosolids program. There has also been research on odours from biosolids, most notably by WERF.
Similar to experiences in the US however, odourous land application programs tend to draw more negative public attention, and subsequently have more challenges in operating a successful land application program. Canadian municipalities with odourous biosolids products have contributed to the WERF odour investigations, and have invested in their own investigations as well. However, the only improvement we have experienced in Ontario is on the management side. Through the use of direct-injection equipment for dewatered material developed by one of the contractors, Terratec Environmental, an American Water Canada corporation, odours have been reduced so successfully that MOE has lifted the severe setback distances imposed for programs that utilize this new technology. Municipalities that dispose of biosolids in the land (for example, by landfilling dewatered cake or biosolids treatment products such as ash), and have reviewed their management methods, are continuing to manage biosolids using a method that does not involve land application. For example, St. Paul, MN, and Cleveland, OH, have both recently determined that improving incineration facilities was the preferable solution in their Biosolids Master Plans. It was not recommended to land apply the ash in either case.
A similar trend is being seen in the European Union, where new regulations tighten restrictions on Class “B” biosolids land application. Furthermore, public concern and food processing companies are dictating more stringent biosolids treatment and use/disposal methods, overriding existing biosolids land application regulations in many parts of Europe.
In some European countries land application has been banned completely (Switzerland) or regulatory restrictions have been imposed that effectively eliminate biosolids application on farmland (such as Holland, due to legislation of very low metal concentration limits). These are typically due to sensitive environmental features, or increased vulnerability to risk, such as shallow overburden or high water tables.
The general biosolids management market trend in Europe is towards increasing levels of treatment where land application is still an acceptable practice, and away from land application where restrictions are becoming limiting. It should be noted that the largest factor impacting these decisions seems to be the competition for land availability, an issue that does not presently exist in Ontario.
4. New and Emerging Regulatory Implications
The Kyoto Protocol was ratified by Canada on December 10, 2002 and entered into force on February 16, 2005. Canada's target is to reduce its greenhouse gas (GHG) emissions to six percent below 1990 levels between the period of 2008 and 2012. GHGs are measured as the equivalent in carbon dioxide of the six main constituents: carbon dioxide; methane; nitrous oxide; hydrofluorocarbons; perfluorocarbons; and sulphur hexafluoride.
The Kyoto Protocol provides for inclusion of sinks as part of a country's strategy to meet its obligations. A “sink” is defined as “any process, activity or mechanism which removes a greenhouse gas, an aerosol or a precursor of a greenhouse gas from the atmosphere”. For example, forests and agricultural soils, which can remove and store carbon dioxide from the atmosphere (carbon dioxide sequestration activities) are sinks. Sinks can be enhanced through sustainable management practices in forestry and on farms.
In this respect, heat recovery from combustion of biogas or biosolids is a positive mechanism under the Kyoto Protocol. The carbon dioxide generated from combusting biogas or biosolids is not counted in the emission side of the GHG inventory as they offset GHG emissions from producing and burning fossil fuels.
The Kyoto Protocol and subsequent action plans in Canada may affect options that generate greenhouse gases, such as heat drying, alkaline stabilization with heat, and incineration (with no energy recovery). These alternatives require the use of fossil fuels and increase GHG emissions. Biosolids programs which have significant transportation requirements may also be affected.
Canada will decide how it will fully meet its target when agreement has been reached on the rules to implement the Kyoto Protocol and it becomes clear how the country’s major trading partners plan to proceed. Measures contained in the Government’s Action Plan 2000 are intended to take the country one third of the way to the target. Most provincial and territorial governments have also indicated support for the program in their jurisdictions. It is unlikely biosolids management programs will be directly affected by the Kyoto Protocol. Biosolids are not a primary generator of GHG emissions, such as the burning of fossil fuels. The primary foreseeable impact on biosolids management programs is a potential increase in cost for energy.
The Canadian Food Inspection Agency has proposed amendments to the Fertilizer Regulation, made under the Federal Fertilizer’s Act. These proposed amendments are linked to the Feeds Act, Health of Animals Act and the Meat Inspection Act, and are intended to reduce the risk of Bovine Spongiform Encephalopathy (BSE) in Canada.
Currently products containing biosolids that are sold under the Act and Regulations must meet prescribed quality standards. In addition, the required label recommends appropriate uses and application rates, but use of the products is essentially unrestricted.
The proposed changes would require products containing biosolids, as well as household wastes and composted materials, to be registered under the Act. Also, application of these products would no longer be allowed on hay crops and pastureland. It is unclear whether or when these proposed amendments may come into effect.
Nutrients (biosolids produced and destined for land application) from wastewater treatment plants in Ontario are subject to the requirements under the Nutrient Management Act (NMA, 2002) and the Regulation and Protocols made under that Act.
The legislation is intended to provide a comprehensive province-wide approach to managing all nutrients on agricultural land. The purpose of the Act is to protect soil and water quality in Ontario’s rural environment, while ensuring that farmers can invest in and operate their farms with confidence. The Ontario Ministry of Agriculture and Food (OMAF) and the MOE are responsible for governing the Act, as well as the 13-part Regulation that outlines standards and the four protocols which provide more detail to the Regulation. The Regulation and related protocols were enacted July 1, 2003, with implementation beginning September 30, 2003.
At this point in time, the Regulation primarily pertains to livestock farmers, but there are some land application standards that apply to biosolids (non-agricultural source material), as well as some requirements for municipal generators. As of September 30, 2003, no biosolids can be applied within 20 m of a watercourse (as defined by the NMA Regulation), the use of high trajectory irrigation guns for land application is banned, and no application of municipal biosolids can take place between December 1 and March 31 of the following year. In addition, the Regulation sets out a schedule for implementation of Nutrient Management Strategies (NMS) for municipal generators of nutrients, dependent upon size.
The City of Ottawa received approval for its NMS in December of 2004. The NMS is a tool to document the volume of prescribed materials, or biosolids, that are generated, how they are stored, and how they will be used. The NMS must also link to documents related to end‑use, such as land application Certificates of Approval and farm nutrient management plans, as well as broker agreements for any intermediate handlers, such as a hauler or land application contractor. Another key component is a contingency plan that documents actions to be taken during times when the intended end-use cannot be carried out.
Once a municipal generator has an NMS in place, the Regulation requires 240 days of storage for municipal biosolids. The Regulation also limits temporary in-field storage to a maximum of 10 days, where site and soil conditions are suitable.
A Nutrient Management Plan (NMP) documents the land application portion of handling nutrients. Specifically, it is an assessment of what application rate is appropriate for the land base, and the crops to be grown, as well as any other standards that must be followed, such as separation distances or waiting periods. At this point in time, the Regulation only requires new, expanding, and large livestock operations to implement NMPs. If biosolids are applied on a farm that is required to implement a plan, then those biosolids must be accounted for in that plan. Biosolids land application, as an activity, does NOT require a farmer to have a plan. The provincial government has left the Regulation open and will likely build upon the document, so it is reasonable to expect that NMPs will be required for all farms at some point in time. When plans are required, additional land application standards will be implemented for biosolids, additional waiting periods and a sampling and analysis protocol. Presently some biosolids contractors complete nutrient management plans for their farm clients as a ‘best management practice’.
As a result of the implementation of nutrient management, we can expect a requirement for municipalities to dedicate more resources to their land application programs. Time and funding will be required to complete NMS training and prepare the documentation. Additional resources will be needed to review existing contracts for compliance, and increased costs may be experienced as contractors have new obligations to meet. Likely the most expensive aspect of complying with the NMA and Regulation will be the implementation of 240 days storage and associated odour control technologies. At such time as NMPs are required for most farms, municipalities can expect an increase in the land base required to utilize biosolids, which results in additional contractor effort and as well as an increase in cost. The implementation of NMPs and the resulting increase in land requirements is considered to be the biggest impact to a land application program, however the requirements would have to be exceptionally stringent to increase the land base such that land application was no longer an economically feasible option, particularly when compared with the costs of further processing or traditional disposal methods.
The Ontario Ministry of Environment (MOE) proposed a new “Guide for the Beneficial Use of Non-Agricultural Source Material on Agricultural Land” in November 2004. The MOE is currently considering comments received on the proposed policy, and has not indicated when the new Guide will be implemented.
The new Guide is intended to replace the “Guidelines for the Utilization of Biosolids and Other Wastes on Agricultural Land” from March 1996. The proposed new Guide is applied to new or renewed site Certificate of Approval (CofA), and the 1996 Guidelines will remain for existing CofAs that expire within 5 years. This is to ensure that a site with an existing CofA, which may have received some nutrient application already, will be managed consistently during the period of that CofA.
Stakeholder concerns are primarily focused on the requirement to use the OMAF’s “NMAN” software to determine application rates, phase-in dates, and costs. The phase-in dates in the proposed Guide do not follow the Nutrient Management Act phasing in schedule, requiring accelerated compliance for farms accepting biosolids.
Stakeholders reported in the WEAO Biosolids Management Specialty Seminar, held February 15, 2005, that while investigating the use of NMAN for certain sites may not result in a significantly reduced application rate overall (during the 5-year period that a site CofA is valid), the single-time application rate would likely be affected (that is, not all biosolids could be applied in a single application) and, in particular, fall applications would likely require significantly reduced application rates. These factors would have impacts on the cost of biosolids land application programs, and likely increase land base and storage requirements.
The MOE is committed to end the land application of untreated septage. Currently contractors are having difficulty securing insurance and new site CofAs for land application of untreated septage, making the practice more difficult to undertake.
The MOE and Ontario Ministry of Agriculture and Food (OMAF) are currently working to develop standards for treatment and disposal of septage, including lime stabilization, composting, treatment lagoons and dewatering trenches. At this time, there is no intent to mandate municipalities to treat septage.
It is anticipated that land application of treated septage will be subject to the requirements for other non-agricultural source materials. Acceptance of treated septage for land application will reduce the land base available for other nutrients.
As part of its strategy to protect Ontario’s drinking water from source to tap, the government released draft legislation on the development and approval of watershed-based source protection plans. Watershed-based source protection was a key recommendation of the Walkerton Inquiry. The proposed legislative provisions are the first part of the government’s approach to drinking water source protection.
Implementation is the next step in developing the drinking water source protection legislation. The government has released the recommendations of two expert advisory committees on watershed-based source protection for public comment: “Wastershed Based Source Protection: Implementation Committee Report to the Minister of the Environment” and “Science-based Decision-making for Protecting Ontario’s Drinking Water Resources: A Threats Assessment Framework”.
In “Wastershed Based Source Protection: Implementation Committee Report to the Minister of the Environment” two recommendations were made in regard to the management of biosolids.
· Recommendation #69: The provincial government should, where necessary, revise existing or provide additional biosolids management standards to align them with source protection objectives and to address issues related to vulnerable areas of the watershed. In particular, the province should:
- Review standards for storage and land application of biosolids as they apply to wellhead protection areas, intake protection zones and other vulnerable areas, and make any necessary modifications;
- Ensure that the standards include provincially uniform outcomes in order to ensure consistency across the province; and
- Coordinate and integrate nutrient management planning and source protection planning as much as possible.
· Recommendation #70: Any future authorization or approval system for land application of biosolids and/or treated septage should include linkages to the Nutrient Management Act, 2002, and/or Farm Water Protection Plans, and should be consistent with the relevant approved source protection plan(s).
In “Science-based Decision-making for Protecting Ontario’s Drinking Water Resources: A Threats Assessment Framework”, potential sources of pathogens, including biosolids, were identified as a potential threat to drinking water sources and it was noted that these sources may require special management to protect drinking water in vulnerable areas. However, it should be noted that source protection is inherent in the current regulatory approach to biosolids land application in Ontario, and a recent review of relevant scientific literature conducted by CH2M HILL does not identify land application of biosolids as a contributing factor in pathogen movement to groundwater.
The proposed Source Water Protection legislation may impact the available land base for biosolids and manure application and may result in additional, more stringent conditions in certain areas. While MOE is committed to this proposed legislation, it has not yet indicated a timeframe to enact it, or any of the technical details. It is also unclear how source protection legislation will interact with the existing regulatory framework for environmental protection and nutrient management.
The Ontario government has set a goal of diverting 60 percent of Ontario’s waste from disposal by the end of 2008, up from the current diversion rate of 28 percent. Waste disposed of includes waste sent to landfill and to thermal energy from waste (EFW) facilities3. Reaching this goal will be determined in large part by finding better ways of dealing with the large portion of solid waste that is made up of organic materials. For example, co-processing biosolids with organics from solid waste could be an opportunity for an alternative biosolids management practice.
Many provinces are targeting organics in their diversion strategies. Both Prince Edward Island and British Columbia have established aggressive diversion targets with an emphasis on organics. Nova Scotia is the only province to have implemented a ban on organics – it banned compostable organic material from landfills in 1998. The ban includes food waste (including meat, fish, bones and dairy products), leaf and yard waste, and non-recyclable paper products.
The Government of Ontario states that it is important that a ban on organics in landfill would only be enforceable if it applied to all waste generators. This would mean that the industrial, commercial and institutional sectors would also need to be subject to the ban. The greatest success would come from full participation, which would likely require additional efforts in enforcement. Diverting more of these materials means that adequate alternatives to disposal must be made available. Alternatives could include residential and industrial, commercial, and institutional (IC&I) source separation programs and the provision of recycling containers or depots in public areas. Where adequate alternatives for managing these materials do not exist, time would be required to put appropriate alternatives in place. This means that any ban would likely have to be phased in over a reasonable period of time.
There appears to be no intent at this time to ban biosolids in landfills, but the development of waste diversion strategies should be monitored in the future.
A number of municipalities in Ontario, from Toronto to Windsor, currently landfill biosolids in Michigan due to the lack of landfill availability in Ontario and the competitive price of this management method.
Recent amendments (2004) to the State of Michigan’s waste laws provide additional motivation for diverting waste that Ontario communities and industries currently send for disposal. These new Michigan state requirements prohibit the disposal in landfills of certain materials in domestic or imported waste, including tires, beverage containers, yard waste, sewage, and used oil. Furthermore, there is a public and political push to reduce or eliminate out-of-state landfill materials in Michigan. Incidents in Michigan such as the March 23, 2005 spill of Toronto biosolids being transported to the landfill reported in a local newspaper may increase focus on this matter.
While there appears to be no intent at this time to ban out-of state biosolids in Michigan, this should be monitored in the future. Other states may follow similar trends in the future, and should also be monitored.
As discussed in Section 3.2, in 2000 sixteen states in the US had one or more counties and/or towns with restrictions, bans or ordinances on land application of biosolids, with California, New Hampshire, and Virginia feeling the most negative impact on beneficial use programs. In European countries, biosolids land application varies from similar practices to Ontario ones (such as in the United Kingdom), to a complete country-wide ban (in Switzerland), with a general trend towards more restrictive practices, such as a move away from Class "B" application.
Without scientific evidence to prove that land application biosolids is hazardous, most international restrictions and/or (local) bans have tended to be a political move requested by vocal and well-organized public groups. The trend appears to be continuing towards more restrictive practices in areas which are suitable for land application, and moving away from land application in more vulnerable areas, such as those with a shallow overburden. Overall there continues to be support for land application in most US states, particularly those focused on agricultural production. In Europe, the trend to move away from land application is largely driven by lack of available land, high water tables, shallow overburden over bedrock, and negative public perception that biosolids are utilized directly in food crop production.
5. Technology Advances
Emerging technologies for anaerobic digestion are primarily focused on improving volatile solids destruction and producing Class “A” biosolids. Studies continue on a number of technologies, but full-scale proven ability, reliability and implementation remains limited. Where such emerging technologies are being demonstrated, it is typically in response to a municipality’s needs or desire to upgrade facilities rather than being primarily driven by their biosolids management program.
Such an example is a two-phase anaerobic digestion system, which separates the acid- and methane-forming stages of sludge digestion, resulting in higher volatile and pathogen destruction. Because pathogens are destroyed below detectable limits, the resulting biosolids are typically rated Class “A”. The benefits include reduced total hydraulic retention time (HRT), which means smaller digesters can be used, associated costs are lower, and aeration is not required, as well as a smaller amount of solids to be managed. The benefit of reduced total HRT may not be realized in Ontario, however, because at present the MOE insists on a minimum HRT of 15 days.
Odour control remains an important component of land application programs, particularly for dewatered cake. Odour is generated both during storage of the material and land application.
Odour control methods for processing and storage of biosolids include chemical and biological technologies. In the chemical field, emerging technologies include spray products (for example, as ODOR-ARMOR™ provided by Benzaco Scientific, Inc.), and oxidation-reduction methods, such as by ozone and ionization. Biological technology advances include longer lasting (inorganic) media for biofilters and biotowers, reducing maintenance requirements and costs.
It should be noted that while odour control methodologies for processing and storage of biosolids are continuously being researched, when dewatered cake is disturbed, such as when moving from a storage location, and during land application, odour is more difficult to control. Odour control is typically addressed on a program-specific basis, and may require trial and error to find an acceptable solution.
Some biosolids land application programs have been severely impacted by odour issues in North America. In Ontario, the MOE is conducting research on odours from land applied nutrients, with the goal of introducing standards that would be specific to the type of nutrient being managed.
Land application contractors are investigating ways to improve incorporation and mitigate odours of dewatered cake. For example, Terratec Environmental Ltd., is developing equipment to “inject” dewatered cake under the surface of an application site in a similar manner to the injection of liquid biosolids. These technological advances are in the initial stages and are currently specific to the contractor.
Similarly, research is continuously being conducted on treatment processes to improve biosolids product features. One example of this is the proprietary process developed by Lystek™, which produces a “solid” material, with about 14 percent solids content, but with the fluid characteristics of a liquid.
Three methods of composting wastewater residuals into biosolids are common: aerated static pile, windrow and in-vessel. No additional composting technologies show large-scale applicability for biosolids (or municipal organic waste) composting. Technological advances in composting are primarily focused on improving existing system efficiencies, in terms of producing better products and using less effort to do so, and are typically developed on a site-specific basis.
Improvements in odour control also remain a focus for composting facilities, as odour generation can have a significant impact on the operation of a composting facility. Cured compost, however, does not usually pose odour issues. Odour control advances are similar to those discussed above, in Section 5.2.
In Ontario, biosolids composting remains in the background as the MOE continues to maintain and defend its position that compost containing biosolids should not be distributed as an unrestricted product.
Heat drying of biosolids is becoming increasingly popular, both in North America and internationally, due to the desirable product characteristics of reduced volume and nutrient richness (concentration). However, some installations, specifically locally, have experienced problems such as the recent fires at the biosolids drying facilities in Toronto and Windsor. These problems are typically related to design and/or installation faults of ancillary systems, as well as poor operations or maintenance, but can result in catastrophic failure of the facility.
Fluidized bed driers are now being promoted by manufacturers in North America as an alternative to the more common technologies such as direct-heat rotary drum driers. In November 2004, Andritz completed the purchase of German based VA TECH WABAG Fluid Bed Systems Business Area. Fluidized bed driers have been used in Europe for some time, and this technology could be considered by municipalities interested in implementing heat drying technology. However, the impacts of utilizing heat drying technologies in Canada on the Kyoto commitments is not yet well understood, and should be investigated in pursuing any installation of heat drying equipment.
While continuous improvements and development of alkaline stabilization facilities are investigated, there appear to be no significant new technology advances for this biosolids management method.
Alkaline stabilization is also becoming an increasingly popular technology, reflecting the market trend towards high level/Class “A” biosolids treatment and diversified products. It is also popular due to the success of product marketing, primarily by the equipment vendors, such as N-Viro.
Alkaline soil amendment products, while valuable in areas which require soil pH to be increased, have less nutrient value, and therefore less economic value as a soil amendment. Therefore, these products should be considered most viable in a specialty market, as a pH-amending product rather than a nutrient source.
The 2001 Update Study concluded that incineration could only be considered beneficial if less energy was required to incinerate the biosolids than would be recovered. The Study also recognized that if land application of biosolids should ever be discontinued, incineration should be strongly considered as an alternative to landfilling of the material.
With sufficient dewatering (22 to 25 percent solids or more), incineration of biosolids can be autogenous, meaning that no fuel is required during normal operation. The heat content (commonly referred to as the Btu content) of dewatered undigested biosolids is similar to that of a low quality wood waste. While fuel is typically required for start-up and shut-down of biosolids incinerators, there is potential to collect at least as much energy as is required for these operations during steady-state operating conditions. Typically heat is recovered, which may be used for space heating and/or power generation.
The fluidized bed incinerator is the current state-of-the-art for biosolids incineration. An emerging technology is the Minergy vitrification process. In the process, dried biosolids are combusted in a cyclonic furnace at high temperatures (1,400 °C to 1,600 °C), resulting in melting of the inorganic portion, which is quenched in a water bath to produce aggregate. Waste heat recovered from the flue gas can be used to dry the biosolids, in combination with a fluid bed dryer. The process uses oxygen enriched combustion air to assist with combustion efficiency and the resulting emissions are reported to be lower than conventional incineration. Minergy has a 34 dry tonnes per day facility under construction at the North Shore Sanitary District’s Waukegan Wastewater Treatment plant in Illinois.
The payback period for incineration systems with energy recovery should be compared to incineration without energy recovery to determine the financial implications. Incineration of biosolids with energy recovery is an energy-from-waste technology with respective environmental benefits, such as reducing the need for fossil fuels and reducing greenhouse gas emissions.
Co-combustion of biosolids with municipal solid waste (MSW) in waste-to-energy (WTE) facilities has been used in both the United States and Europe for many years. This method of biosolids management was not addressed in the 2001 Update. This section will give a brief overview of technologies used and some of the applications.
Co-combustion has been practiced in mass-burn type grate furnaces, as well as in dedicated furnaces with refused derived fuel (RDF). One such facility, Duluth, MN, utilized a fluidized bed furnace to combust a mixture of RDF and dewatered biosolids for close to 20 years. Another facility, Glen Cove, NY, sprayed liquid biosolids on top of the MSW bed in a grate furnace. A more recent facility, located in Huntington, AL, co-combusts MSW with biosolids. Biosolids feed to co-combustion is effectively limited to about 10% of the MSW feed to eliminate scaling problems, as well as to maintain efficient combustion without the addition of auxiliary fuel.
While operating facilities have been successful in co-combusting MSW and biosolids, the practice is not widespread. For example, there are approximately 100 WTE plants in operation in the United States and there are less than 10 that co-combust biosolids with MSW. There are two major reasons. The first is that the heating value of the biosolids is lower than MSW and reduces the efficiency of energy recovery. The second is the reluctance to complicate the permitting of WTE plants, which in itself is a complex process. There have been few WTE plants constructed in North America in the last decade. There are two operating WTE plants in Ontario: SWARU in Hamilton and Peel Resource Recovery Facility in Brampton. There are currently no proposals to construct a WTE in Ontario.
One new technology that is being marketed by EneryAnswers is called the eco/Technologies Sludge Recycling System. This technology can be retrofitted to existing WTE plants or installed in new ones. Liquid biosolids are injected into the combustion zone of WTE incinerators, using a proprietary injection and control system. The system has been demonstrated at the Pioneer Valley Resource Recovery Facility in Agwan, MA at a 400 tonnes per day WTE plant. EnergyAnswers plans to add the system to other WTE plants.
The 2001 Update reviewed a number of other thermal processing technologies. However, due to lack of biosolids commercial or operating experience, these were not carried forward for detailed evaluation. There has been some recent interest by proponents of these technologies, so this section briefly recaps some of these technologies and their full-scale biosolids experience:
· Pyrolysis – a breakdown of organic matter at high temperature and pressure, in the absence of oxygen to typically produce a char and/or fuel oil. There are several different variations and some of these are summarized following:
- Low Temperature Pyrolysis - takes place at approximately 315 °C and produces a char with a heating value, an effluent stream from the post pyrolysis dewatering that is high in ammonia and organics, and air emissions that consist primarily of carbon dioxide with some VOCs and other compounds. Two vendors have been promoting this technology in the United States: Enertech and ThermoEnergy Corporation. Neither has full-scale biosolids processing plants. Enertech is proposing a facility in California. ThermoEnergy installed a 5 tonne per day facility at the Colton Wastewater Treatment Plant and is proposing to build a biosolids processing plant.
- Mid Temperature Pyrolysis - takes place at between approximately 425 °C and 530 °C and produces fuel oil and a char with a heating value. Environmental Solutions International owns the Enersludge process and has one full-scale biosolids facility located at the Subiaco Wastewater Plant in Perth, Australia, with a rated a capacity of 22 dry tonnes per day. This plant has reportedly been plagued with problems since its commissioning in 2001 and has not produced a good enough quality of oil for marketing.
- Changing World Technologies (CWT) has developed a thermo-depolymerization process called the Thermal Conversion Process to convert organic material into gases, hydrocarbon oils, solid/carbon and solid/mineral. CWT indicates that the latter is suitable as a fertilizer. CWT has built a 185 tonnes per day processing facility in Carthage, Missouri that processes food waste, mostly consisting of turkeys. Although CWT indicates that municipal sewage sludge is a potential feed material, it has no actual processing experience.
- High Temperature Pyrolysis - takes place at between approximately 650 °C and 820 °C and produces a char with a heating value. One such system in Romoland, Riverside, California, developed by International Environmental Solutions (IES), was designed primarily as a waste to energy system using municipal solid waste. IES proposes to use biosolids as feedstock for this process.
· Gasification/Starved Air Combustion – a cross between pyrolysis and incineration, with insufficient oxygen to allow complete combustion. The process produces a biogas with a low heating value and a char, also with a low heating value. The biogas can be used in combination with natural gas for cogeneration or other similar uses. The biogas needs cleaning and conditioning prior to use as a fuel. The biosolids would have to be dried prior to gasification. There are a few manufacturers in the United States, but none have any operating experience with biosolids and would not guarantee the performance of their equipment on biogas.
In summary, while there are companies marketing technologies for converting biosolids into fuels, there are no commercial facilities processing biosolids in existence. Additionally, some of these technologies may be considered as small add-on processes, rather than full-scale implementations only. There are also a suite of additional technologies available on the market for add-on or full scale implementation, but as they have not been satisfactorily proven, CH2M HILL recommends further investigation prior to identifying those technologies as potential options for the City of Ottawa.
The 2001 Update recognized that municipal solid waste, leaf and yard waste, and recyclables are managed by the City of Ottawa separately from the biosolids. By including biosolids in waste management strategies for beneficial reuse and waste diversion, a holistic approach could be taken.
Co-composting of biosolids and other organic waste is a fairly common practice in North America in small facilities, although not in Ontario, due to regulatory restrictions. Large-scale facilities are relatively new and limited in quantity.
Ontario’s Aerobic Compost Guidelines are very restrictive and would not allow composted material, including biosolids, to qualify as “compost” suitable for unrestricted use, without a special exemption being obtained from the Province. Co-composted biosolids would be suitable for agricultural land application under a site CofA or utilized for landfill cover. Biosolids could be processed with organic waste to produce other products, such as processed soil, however the resulting product would have to be registered under the federal Fertilizers Act in order to qualify for unrestricted use and distribution.
An example of a large-scale co-composting facility in Canada is the 1,100-tonnes-per-day facility in Edmonton, Alberta. Design quantities processed are in the neighborhood of 180,000 tonnes/ year of residential municipal solid waste (RMSW) and 22,500 dry tonnes/year of biosolids.
Delivered to the facility’s tipping building, the RMSW waste undergoes manual presorting on the tipping floor in a process referred to as feedstock recovery. Some items need to be removed from the waste stream because they are ‘nonprocessable,’ such as carpets, bicycles, and dimensional lumber. Others items are ‘noncompostable’ and therefore are removed because they can adversely affect compost quality. After presorting, the RMSW and dewatered biosolids are metered into each of the facilities five mixing drums. The material remains in the rotating mixing drums for 24 hours.
In 24 hours, the drums meet all of the feedstock-preparation objectives except for particle size. The feedstock’s carbon-to-nitrogen ratio, moisture content, and pH are all set to prescribed levels. Air is forced into each drum to maintain aerobic conditions and to adjust the pH. To achieve the desired particle size, the otherwise prepared feedstocks pass through one of the facility’s large trommel screens. After trommeling, the less-than-80-mm fraction of the prepared feedstock transfers to the 2.5-hectare stressed-skin stainless steel aeration building for a 28 day composting process.
Three “SCT Biomax” systems are used, which are essentially a bridge crane on rails straddling each bay, with twin augers hanging from the bridge that affect turning. After 28 days of aeration, the compost goes through a screening and refining system. Recognizing that odour management is the composting industry’s number-one challenge, a negative-aeration system to aerate the approximately 28,300 m3 of compost residing in the aeration hall was selected. The total electrical demand for the whole plant is 3 to 4 megawatts.
The composted product is suitable for specific markets, such as mine reclamation, and may be shipped directly to end users, or it may be further cured at the facility. The TransAlta Energy Marketing Corporation is providing a design-build-own-operate service. TransAlta also provides a major marketing potential to the project in its large surface coal mining reclamation activities just west of Edmonton.
Co-composting of Ottawa’s biosolids and municipal organic waste would require a comprehensive waste management strategy for the City. If the municipal organic waste is limited to yard waste, sufficient carbon may not be available for composting and additional amendment (carbon) material may be required during certain periods. Due to the lack of acceptability in Ontario of biosolids as a feedstock in compost for unrestricted use at this time, a study would have to be conducted to investigate the economics and advantages of such a system for the City of Ottawa, including the product market.
7. Summary Findings
Since the 2001 Update Study, the following trends have been observed:
- Land application of biosolids is still the primary choice for most municipalities in Ontario, North America and internationally, in locations where environmental conditions and land availability favour this beneficial use management alternative.
- Due to increasing focus on sustainability of land application programs alone, municipalities are increasingly investigating and implementing diversification in their biosolids management programs.
- In Ontario, regulations currently under development, review and revision are unlikely to have a large impact on the viability of land application.
- Restrictions, ordinances and local bans in North America are generally the result of public and political pressure, as there is no scientific evidence that land application of biosolids is harmful when the governing guidelines and regulations are followed, regardless of the product designation as Class A or Class B.
- The regulation of biosolids land applicaton already accounts for the protection of source water. However, it is possible that additional restrictions on biosolids land application will be implemented in Ontario’s source water protection vulnerable areas (eg. well head protected zones).
- Energy generating (conserving) or “sink” type biosolids management processes will be beneficial to meet Canada’s commitments under the Kyoto Protocol.
- While biosolids treatment technologies are continuously being researched and improved, no significant changes to the science and treatment mechanisms have occurred since the 2001 Update Study.
- The technologies that have seen the most advances since the 2001 Update Study are: Class “A” digestion processes; heat drying using alternative technologies (such as the fluid bed drier and belt drier for smaller applications); improved odour control; incineration with energy recovery; and large-scale co-composting of biosolids and municipal organic waste.
- Co-composted biosolids and municipal organic waste would assist in waste diversion strategies.
- Composted biosolids products may be used for soil amendment, if registered under the Fertilizers Act. The MOE has stated, compost that includes biosolids is not suitable for unrestrictive use in Ontario. Current regulations enforce this and a composted biosolids product requires special exemption to be “compost” suitable for unrestricted use.
The findings discussed in this Technical Memorandum do not adversely impact the recommendations of the 2001 Update Study, namely:
· Develop Multiple End-uses
· Develop an Environmental Management System
· Continue with the Land Application and Landfill Strategy
· Develop improved Industrial Source Control
· Conduct Further Research which may improve the viability of some of the alternatives
· Implement Multiple End-uses
· Implement an Environmental Management System
· Implement improved Industrial Source Control
Land application of biosolids remains a viable and cost effective solution for the City of Ottawa. However, many municipalities are focusing additional effort on their land application programs, to address the more formalized requirements in the changing regulatory framework. In particular, these efforts typically involve more stringent data collection, review and record keeping; land application program quality assurance/quality control; formalized contingency planning; and medium to long term improved storage and/or product diversification programs. Land application program costs are likely to increase, due in part, to increasing requirements for the land base. Accordingly, development and use of different processes and end uses continues to make sense for the City of Ottawa. Those processes short listed in 2001 remain the most appropriate viable options available to the City at this time.
 The City ships approximately 1150 loads (42,000 t) of biosolids from ROPEC each year. The spill that occurred on 15 February 2005 was the result of freezing rain and icy road conditions experienced along the local road leading to one of the disposal sites. The spill did not cause any injuries, and was reported and cleaned-up in accordance with provincial laws and to the satisfaction of those involved. No legal proceedings resulted from the incident. The hauler and its drivers have been instructed that, under similar conditions, they are to wait until the road has been salted before making any deliveries.
 June 2004, as reported by the MOE
 ONTARIO’S 60% WASTE DIVERSION GOAL: A Discussion Paper; June 11, 2004 http://www.ene.gov.on.ca/programs/4651e.htm
 Refer to http://www.michigan.gov/deq/0,1607,7-135-3312-96663--,00.html
 An example is shown on the Michigan Democratic Party website at http://www.mi-democrats.com/topics/trashimports.htm
 “Spill in Michigan Town Raises Stink”, March 24, 2005, Jeff Gray, as reported by firstname.lastname@example.org
 Refer to http://www.benzaco.com/pages/624821/index.htm
 Refer to http://www.andritz.com/ANONIDZ7F538AB27266FB4B/news.htm?id=31464&count=3
 Stated by a representative of the MOE in the February 2004 Composting Council of Canada conference in Burlington, ON.