Editor’s note: The following letter was received from Minister of Environment Dr Terry Lake following a one half hour meeting with him and attended by members of ARESST and Dr Jay Cullen, Chemical Oceanographer. Editorial comments (in italics) follow some of the points made in the Ministers letter. Much of the critique that was presented to the Minister and his staff has been ignored in this response and is included here.
June 28, 2011
Dear Dr. Peck:
I am writing to thank you for meeting with me on May 17, 2011, to discuss sewage treatment in the Capital Regional District (CRD). I appreciated the opportunity to meet you and enjoyed our discussion.
I would like to follow up on a few points we discussed at our meeting.
As we discussed, the CRD’s current practice of discharging untreated sewage into the Strait of Juan de Fuca does not meet provincial and federal Fisheries Act standards.
The standards referred to are CBOD5 [Carbonaceous biochemical oxygen demand] and TSS [total suspended solids]. These measurements are not of concern in Victoria’s dynamic marine environment.The waters in the receiving environment are vigorously mixed by tidal action and are well oxygenated.
The proposed Federal Wastewater Systems Effluent Regulations have been delayed and may be modified before being proclaimed by the Government under the Fisheries Act.
TSS are not an issue in our local waters. Note that the Fraser River would fail the proposed effluent regulations as it has an average TSS concentration that routinely exceed the 25 mg/L standard sometimes by more than 30-fold (900 mg/L) [Kostaschuk, Stephan et al. 1993].
Monitoring at the outfalls confirms that contamination of the seabed near the outfalls exceeds British Columbia (BC) contaminated sites standards, indicating that the local marine environment provides insufficient natural treatment of the sewage.
There is inadequate data and poor sampling to support this conclusion. Indeed, the authors [of the Macdonald and Smorong report (2006)] use 1 sample per year over 5 years to characterize the entire initial dilution zone (IDZ) as contaminated. The single sample is collected right next to the outfall. This single sample is a sediment grab the size of a cafeteria tray and it is used to characterize the entire IDZ, an area roughly the size of 70 NHL hockey rinks.
The area of assumed seabed contaminated (the size of 70 NHL hockey rinks) is of little concern when compared to the potential environmental harm from disposing of sewage sludge (where contaminants are concentrated) either on the land or by incineration.
These are evidence based, scientific standards, established to ensure protection of human health and the environment.
There is no evidence from the scientific papers presented to the CCME (Canadian Council of Ministers of the Environment) that there will be any public health benefit from building sewage treatment plans for Victoria’s liquid waste – if the sewage discharge was into a fresh water lake or river then there would be potential for public health and environmental benefit.
I would like to take this opportunity to reiterate that the following scientific evidence supports treatment:
- In 2006, the Society of Environmental Toxicology and Chemistry (SETAC) conducted a review of over 200 scientific and technical reports and over 80 written submissions, which concluded that reliance on dilution is not a long-term answer and that scientific risk concerns, public values and regulations argue for the CRD to improve treatment.
The SETAC report did conclude this but other sections of the report clearly indicated that there would be no definable benefit from providing secondary sewage treatment for Victoria. The SETAC report also noted that land-based sewage treatment in Victoria is a low priority for protecting the marine environment. The panel noted that "if citizens' concern is with contaminants with distant effects, and especially with their impacts on endangered species and ecosystems, it can be argued that other policies would provide a greater return per dollar."
- A 2006 review of the CRD monitoring data confirmed that the contamination of the seabed near the outfalls exceeded provincial contaminated site standards for a number of toxic metals and polyaromatic hydrocarbons.
The 2006 (Macdonald and Smorong) report has not undergone rigorous peer review. A review of the scientific approach and interpretation of the Contaminated Sites Regulation suggest that the conclusions of the report are not supported by the CRD monitoring data. Indeed, there is inadequate data to allow for the application of the contaminated sites standards especially in the sediments within the IDZ at both Macaulay and Clover Point outfalls.
- CRD studies have shown that sediments in the vicinity of the outfalls are toxic to marine biota, biodiversity is depressed and elevated levels of contaminants in nearby organisms have been reported.
In a majority of cases the levels of contaminants in Horse Mussels (the organism used to monitor bioaccumulation) are actually lower in organisms proximate to the outfalls when compared to mussels growing further afield. This is likely related to the larger size and more rapid growth of mussels taking advantage of nutrients released by the outfall diffusers.
There is a net neutral to positive effect outside the Initial Dulution Zone relative to reference. Some impairment inside the IDZ in the form of slightly reduced taxonomic richness and decreased abundance of specific species but no major impairment was observed. Compare this with the impact on the terrestrial environment with new treatment plants and tonnes of biosolids.
- CRD modeling shows that, in the vicinity of the outfall, sewage surfaces regularly at slack tide up to eight months of the year.
There are some times in the year that fecal coliform bacteria samples have been detected that indicate that the very dilute plume surfaces. What is the risk of exposure for the population to effluent born contaminants in this scenario? What is the risk of exposure with treatment plants on land that produce biosolids?
Here is some of the text about modeling and the actual observations from the Marine Monitoring 2009 report:
“Surface water fecal coliform sampling results show that the potential for human exposure to fecal coliforms in the marine environment from the wastewaters is low. Overall, the fecal coliform results indicate that the surface water effects of the outfalls were limited, with the core of the plumes being predominantly trapped at depth for most of the year and only substantially diluted effluent occasionally reaching the surface.”
“In 2009, the CRD increased sampling frequency to five samples in 30 days for one summer month, as per MMAG and SETAC recommendations. This was intended to determine if fecal coliform levels exceed BC MoE WQG for recreational primary contact as they were defined, during the time of year when the most recreational activity is expected around the outfalls. Geometric mean results were far below the BC MoE WQG, confirming that the potential for human exposure to harmful levels of effluent derived fecal coliforms was very unlikely.”
This last paragraph is most important. High resolution sampling in 2009 has indicated that the potential for human exposure to harmful levels of effluent was very unlikely…despite what modeling studies might suggest/predict.
- The current CRD practice does not address persistent pollutants like heavy metals and endocrine disruptors. Secondary treatment is considered effective in addressing these contaminants. Although improved source control is an integral part of the CRD’s Liquid Waste Management Plan (LWMP), it has limited capacity to reduce contaminants, only targets specific contaminants and, compared to treatment, may take several decades to achieve contaminant reductions.
Secondary treatment concentrates heavy metals in the sludge which then has to be disposed of. The concentrations of endocrine disruptors are much too low to be a problem. Research to date shows no effects on marine life from levels of these chemicals typically found in the receiving environment. There is, however, a concern that some chemicals that are present in the effluent in very diluted form can be concentrated by various processes, taken up by marine organisms, and further concentrated as they move up the food chain. Given the extreme dilution off Victoria, it is unlikely that this biomagnification leads to significant concentrations in higher organisms such as marine mammals resulting from Victoria’s wastewater discharges, though other sources may be a cause for concern. While some of the chemicals would be rendered harmless during secondary treatment and some would be trapped in the sewage sludge, many would remain in the discharged effluent. There is a need for further research to identify the chemicals of concern, establish their sources (which may be mainly other than sewage discharges), and determine any necessary remedial strategies.
The best approach is to prevent the chemicals from being manufactured and improperly disposed of. Treatment is not a magic wand that makes contaminants disappear.
Adherence with the BC Municipal Sewage Regulation and the pending federal Wastewater Systems Effluent Regulations, expected to be finalized in the fall of 2011, will require implementation of secondary treatment for the CRD. Based on the draft federal legislation, the CRD would be required to implement secondary treatment by 2020.
There is still time for the Federal Government to rethink the “one size fits all” approach adopted in the proposed Federal Wastewater Systems Effluent Regulations. These regulations have been repeatedly delayed and may be modified before being approved by the Federal Treasury Board and proclaimed by the Government under the Fisheries Act.
The LWMP approved by the CRD Board and the Honourable Barry Penner, former Minister of Environment, follows four years of planning, engineering and sustainability analysis, as well as a broad range of consultation initiatives. The CRD has undertaken “triple bottom line” (social, economic and environmental) assessments of options and has engaged international experts in peer review processes.
The Minister and the CRD have been repeatedly asked to include the current discharge of Victoria’s liquid waste after screening through the two deep sea outfalls at Macaulay and Clover Points as part of the “triple bottom line” assessment but this has not occurred.
The LWMP amendment, approved by the CRD Board in June 2007, commits to implementing sewage treatment by the end of 2016. The decision to move forward with treatment is supported by the federal government and the CRD Board. The CRD is working with federal and provincial (Community Development) agencies to finalize funding arrangements.
In November 2010 the CRD submitted a “Business case” to the Province for funding. This has not yet been approved. The “Business Case” will likely need to be revised since currently the CRD is searching for another site for sludge treatment (other than the plan to pipe the sludge 18 KM to the Hartland Land Fill for further processing). The final treatment of the sludge has yet to be determined as the CRD Board has resolved that land application of sludge is unacceptable and whether the sludge will be incinerated locally or in the lower mainland in a cement kiln remains to be decided.
Thank you again for meeting with me to discuss this important issue.
Sincerely,
Original Signed By
Terry Lake
Minister of Environment
Editorial comments in italics as of September 16th 2011.