Presentation to the CRD Core Area Liquid Waste Management Committee February 24th 2010 by Dr Shaun Peck
Thank you for the opportunity to speak to you again.
Speaking to agenda item #5 – report on the Environmental Impact of a wastewater treatment plant that may be going to be built in the Saanich East (Haro Woods) location.
On page 101 or this 120 page report it states “even without a detailed analysis of the study area, examination of aerial photographs or a cursory field inspection leads to the conclusion that existing development in the study area constitutes a high magnitude, long-term, irreversible impact on the environment that must be considered significant.”
“A treatment facility and its supporting ancillary infrastructure will affect a total of 2 to 3 ha of land.”
The report then goes on to say the impact will be less than significant because of the offsetting marine benefits of treatment. I have seen no definition of any measurable benefit there will be to the marine environment. In fact with the creation of another outfall at Finnerty Cove there will be some marine impact there which was not present before. I also find this statement lacking in a logical argument as to why the impact will be “less than significant”. It is just an opinion not well grounded in any facts presented.
Moving on to Agenda item # 7 – the February 9th letter from Minister Barry Penner. I wish to draw your attention to a statement in the letter “Our provincial regulations provide opportunities for beneficial use of Biosolids, while safeguarding human health and the environment”. When the Minister ordered the CRD to plan for treatment in June 2006 he used as a justification a report requested by Sierra Legal Defense that made a preliminary assessment that the ocean floor around the deep sea outfalls was a contaminated site. What is illogical is that the Organic Matter Recycling Regulations, referenced by the Minister, allow greater concentrations of substances when Sludge or Biosolids are applied to the land than they do on the ocean floor based on the Contaminated Sites regulation. In addition the levels allowed on land are higher than those that exist on the ocean floor at this time around the Macaulay and Clover point outfalls. (Some examples – in micrograms/gram dry weight (Arsenic: Clover 7.06, Macaulay 11.5 Class A Biosolids (Composting) 13 and Class B Biosolids 75 (Composting and Biosolids); Cadmium : Clover 0.62, Macaulay 1.13 Class A 3, Class B 20; Copper: Clover 221, Macaulay 270 Class A 400 Class B 2200. When you consider the potential human exposure on land versus the ocean floor around the deep sea outfalls it is absurd to allow a greater concentration of chemicals applied to the land. (Rather than provide you with a lot of numbers I have sent to CRD Scientific programs who can advise you on the analysis by a University of Victoria Chemical Oceanographer Dr Jay Cullen that provides detailed data).
Lastly I would like to comment on the DRAFT Water Systems Effluent Regulations that is now available from Environment Canada for review.
There is one particular definition in the DRAFT regulation which I found of interest.
“final discharge point” means the point, other than an overflow point, of a wastewater system beyond which its owner or operator no longer exercises control over the quality of the wastewater before its deposit as effluent in water or a place.
These draft regulations do not require secondary sewage treatment – they just require meeting the 25 mg/l Total Suspended Solids and Biological Oxygen Demand.
As a result of this I have a proposal for you that you evaluate constructing 2 mm screens (instead of the present 6 mm) at Macaulay and Clover Points (similar to which is being considered for the proposed Saanich East Plant) and that following the screens that there be a design developed that would by means of pumping or a Venturi effect introduce sea water into the effluent stream prior to discharge through the deep sea ocean diffuser. There would need to be a redesign of the diffusers and possibly duplication of the outfall pipe at Macaulay point to allow for increased flows in the future. I am assured by two civil engineers that I have discussed this with that this would be feasible and would meet the requirement of the Federal Regulation. As you know the deep sea outfalls already meet the 45 mg/l TSS and BOD that is the outcome required by Provincial Municipal Sewage regulation after an initial dilution zone of 100 Meters.
This solution would also create a much smaller burden on the Municipal, Provincial and Federal taxpayers. I urge you therefore as you begin to take a sober second look at what your present plans are that have been called a “Billion Dollar Boondoggle” and that will cost as much as 14 new Blue Bridges. Please request staff and the consultants to carefully review this suggestion to determine whether it would enable the CRD to meet the proposed Federal regulation.
Thank you,
Dr Shaun Peck, Public Health Consultant
Member of Responsible Sewage Treatment Victoria
Member of the Association for Responsible and Environmentally Sustainable Sewage Treatment.
Presentation to the CRD Core Area Liquid Waste Management Committee Feburary 24th by Mr Bob Furber, resident of Saanich and retired chemical engineer who hates seeing the pointless destruction of an irreplaceable old growth forest and, like many on this committee, hates to see money and resources wasted.
STOP THE SNOB TREATMENT PLANT BEFORE IT IS TOO LATE
While the Environmental Impact Study of Core Area Wastewater Treatment Facilities: Terrestrial Environment. Part 1: Saanich East Facilities report does address the issues related to the SENOB plant's environmental impact, it is unfortunate this report was prepared before the release of the Stantec Resource Recovery reports. I say unfortunate, because the resource recovery reports shot down the only arguably credible justification for this plant: Resource recovery. Had Westland known this, they would have addressed the zero impact scenario and asked the fundamental question: Is the SENOB plant even needed.
The CRD's July/August 2009 Wastewater Update lists five rationales for the SENOB plant:
So, if the stated rationales are no longer valid, how can we justify even thinking of building the SENOB plant? Work on this plant has to be stopped now, before we spend pointless $millions more.
What is preventing us from stopping this? Is it because we have already invested millions of dollars in studies related to the SENOB plant, design is about to start and construction is scheduled to start before the end of the year? Is it embarrassment or fear of loss of face to stop it at this late date?
In the December 9th CRD meeting that decided to send the amended Liquid Waste Management Plan to the Minister of Environment, many directors expressed their unhappiness with the plan. Rightly so. It is a flawed plan. But, the worst part is the SENOB plant ..specially since it's main, and arguably, sole justification was resource recovery which we now know is neither economical nor viable.
Surely it is time for the members of this committee have the courage to do what is right and ask the Minister to remove the SENOB plant from the Liquid Waste Management Plan to save about $100 Million. Failure to do this will be a vote for the tragic and needless destruction of Haro Woods to make way for a costly sewage treatment plant that has no business being there?
Thank you,
Bob Furber
Retired Chemical Engineer
Member of Association for Responsible and Environmentally Sustainable Sewage Treatment
www.aresst.ca