Responsible Sewage Treatment Victoria

Beach Contamination

Argument: Our beaches and coastline are contaminated with sewage from the Clover and Macaulay Point outfalls.

Counter Argument: Stormwater discharges from the land are responsible for the biological and chemical contaminants found at our beaches and near shore areas. The deep ocean discharges at Clover and Macaulay Points do not contaminate the beaches.

Analysis: Extensive bi-annual monitoring by the CRD of municipal stormwater discharges at the coastline in the Victoria area, has shown that a number of these discharges carry elevated levels of fecal coliform bacteria and chemical contaminants. The primary sources of sewage contamination (as indicated by fecal coliform counts) are from cross connections between the sewage collection systems and the stormwater collection systems and from failing municipal infrastructure (leaking or broken pipes). Chemical contaminants enter stormwater as runoff from roads and from the inappropriate waste disposal practices of businesses and householders. There were 42 sanitary sewer overflows to the environment in January 2007 (a month of high rainfall).

Ongoing investigations by the CRD and municipalities are being undertaken to identify and eliminate the contaminants as indicated in the existing Liquid Waste Management Plan. Municipalities continue to repair leaking sewer pipes and replace undersized sewer pipes. These efforts will reduce both the frequency and duration of sewage overflows during high intensity rainfall events.

In addition to the shoreline monitoring, a number of ocean water surveys have been carried out by the CRD. These surveys have clearly demonstrated that the source of beach contamination is from stormwater discharges and not the long deep ocean outfalls.

The Medical Officer of Health has advised the CRD that the beach contamination is a public health risk (because of potential from human exposure to sewage contaminated water) but that the deep sea ocean discharges are not a risk to public health.

The only effective methods of eliminating contaminants at our beaches and coastline are through stormwater source controls and by increasing the capacity of the sewage (pipe) system. The additional levels of sewage treatment that are being planned as a result of the Minister’s order will have no effect on the beach contamination that is presently occurring. There is no connection between beach and coastline contamination and the discharge of screened effluent from the Clover and Macaulay Point deep sea outfalls.

The 2005 CRD Storm Water Quality Annual report is available on the CRD website at:

http://www.crd.bc.ca/es/environmental_programs/stormwater/monitoring.htm

You can also direct link to individual parts such as the exec summary at :

http://www.crd.bc.ca/es/environmental_programs/stormwater/documents/ExecutiveSummary_001.pdf#view=fit

Health risks to mariners and other water users

Argument: Onshore sewage treatment plants will reduce the health risks to mariners and other water users. Sewage carrying faecal coliform bacteria rises to the ocean surface for up to eight months/year. Wind surfers, leisure boats, eco-tourist, fishing, and other vessels routinely travel through these polluted surface waters, exposing the public to third-world health risks.

Counter-Argument: Mariners, sailors, wind-surfers, scuba divers, other water users are not harmed or undergo any significant health risks from Victoria’s natural sewage treatment system primarily because they are not exposed to the plume.

Analysis: Most of the year, the effluent plume is dispersed well below sea level. In the winter months, the diluted effluent plume (diluted by 1600 times before it reaches the surface) surfaces only 4.8% of the time at the Macaulay outfall and 1.7% at Clover point. Occasional bacterial tests have detected this diluted plume. There is no evidence that this represents a public health risk – based on a comprehensive study of potential human exposure. (Reference: “Qualitative Risk Assessment of Marine-Based Puplic activities in the vicinity of McCauley Point and Clover Point wastewater outfalls, CRD, BC – Archipelago Marine Research Ltd September 2002 and SETAC report July 12^th 2006).

Pollution only occurs when some measure of significant harm to humans or marine biota has been observed. No such harm has been observed to date nor is likely to occur in the foreseeable future. (Reference: “Potential Environmental Effects of the Macaulay and Clover Point Outfalls and review of the wastewater and marine environment program” Golder Associates December 2005 and SETAC report July 12^th 2006)

Conclusions/Advocacy: The Straits of Georgia and Juan de Fuca meet in the waters off southern Vancouver Island, creating a wonderful diversity of marine life. Diving in Victoria ranks amongst the world's best . At Ogden Point, divers continuously plunge off the breakwater - every day of the year. Off Ten Mile Point you will see a spectacular display of swimming scallops scurrying off in all directions, like a school of false teeth. There is excellent diving from Race Rocks. The West Wall is considered to be the top dive site in the Victoria area, where divers claim to have seen the most marine life anywhere. It is host to a combination of protected-water sea life, and outer west coast wildlife .

(see http://www.vancouverisland.com/recreation/?id=161 )

When Race Rocks (less than 20 km –one strong ebb tide – downstream from Victoria’s deep sea outfalls) was declared Canada’s first underwater marine protected area, Divers from the National Geographic declared the waters the most pristine that they had seen anywhere in North America. Dare we suggest that it is because of increased nutrient levels from Victoria Sewage? No. Victoria sewage (although beneficial to marine biota) contributes minute quantities to nutrient levels compared to nutrients from other sources. In 1990, Race Rocks was designated Canada’s first Marine Protected Area.

(see: http://www.racerocks.com/racerock/mpa/sept14/mpasept14.htm )

Enhanced Treatment of Marine Outfalls

Consequences, Opportunity Costs and Public Health

(The CRD Commissioned the SETAC panel to provide an international independant assessment of the science related to Victoria's two deep sea outfalls. The following was the submission from three local public health officials.)

Submitted by:

Dr. Richard Stanwick, Chief Medical Health Officer, Vancouver Island Health Authority

Dr. Murray Fyfe, Associate Chief Medical Health Officer, Vancouver Island Health Authority

Dr. Shaun Peck, Former Regional Medical Health Officer, Capital Regional District

Submitted to:

William A. Stubblefield, PhD

Chair, CRD Scientific and Technical Review Panel

#108 – 720 Sixth St .

New Westminster , BC V3L 5S6

Historical Perspective:

Dr Perry Kendall, CRD Medical Officer of Health from 1987 to 1989 and currently BC’s Provincial Health Officer, is quoted as saying in 1989, "as far as I am aware there was no evidence of adverse environmental impact once one moved from the proximity of the diffusers, similarly there was no evidence of adverse human health effect...”

A presentation by a University of Victoria Oceanographer, Dr Jack Littlepage in 1989 was included in this publication. It provides analysis and opinion on the ocean currents around the two deep outfalls. 

In 1991, there was considerable public demand for increased sewage treatment at the Macaulay and Clover point deep-sea outfalls. The Capital Regional District (CRD) was planning to conduct a referendum on the issue. Dr. Shaun Peck, then Regional Medical Health Officer, reviewed the potential need for increased sewage treatment from a Public Health perspective.  He found there was evidence of risk to public health due to shoreline discharges from storm drains and from poor source control that allowed unwanted chemicals into sewers. He supported efforts to address these issues and advocated continued monitoring.

However, there was no evidence that the two deep-sea outfalls were harming public health and, consequently, the benefits of increased sewage treatment were unclear. He concluded that it was not reasonable to commit to a very large public expenditure for increased sewage treatment at the Macaulay and Clover point deep-sea outfalls without defining the expected benefits.

In 1991 J.E. Dew-Jones, P Eng, a previous director of the waste management branch of the BC Ministry of Environment published a booklet titled “Victoria’s Sewage Circus” [1] . This booklet reviewed the history of progress that had been made since 1965 on improving the sewage discharge from the Victoria area.

In September 1992, prior to the public referendum, the CRD prepared the following eight public information papers as part of the Liquid Waste Management plan:

1. The planning process and public involvement
2. Public health aspects
3. Shoreline discharges to the beaches and foreshore waters
4. Sewage discharge: effects on the offshore marine environment
5. Chemicals in wastewater
6. The existing sanitary sewer system
7. Liquid waste management options
8. Making your decision about the sewage treatment referendum

On November 21, 1992, about 23 percent of the 149,400 eligible voters in Victoria, Saanich, Oak Bay, Esquimalt, View Royal, Colwood and Langford cast ballots in a referendum. They were asked what level of sewage treatment (in addition to liquid waste control programs) they wanted in the next five years. The referendum results were as follows:

· The existing method of treatment, in which sewage is passed through 6 mm (one quarter inch) screens and the solids are removed and taken to a landfill, received 19,181 votes.

· Secondary treatment received 7,481 votes.

· Primary treatment received 7,186 votes.

All options included source control programs. $650,000 new annual costs were approved but no expenditure was approved for capital costs.

In 1993, CRD Chairman Frank Leonard spoke to the Port Angeles Chamber of commerce and advocated for Integrated Coast Management (ICM), as proposed by the US National Research Council, rather than the best available control technology (BACT) that was being advocated prior to this time. [2]

Under the Health Act, the Chief Medical Health Officer for the CRD is responsible to monitor the health of the population and take action to prevent human illness or adverse human health effects. Health risks are assessed for direct and indirect human exposure.

The Marine Monitoring Advisory Group (MMAG) [3] is a multidisciplinary committee that provides independent scientific advice on the wastewater and marine-monitoring program. Its role is to supply independent science-based advice and comments. Since 1995 a qualified public health staff member has participated as a member of the MMAG and is responsible to apprise the Chief Medical Health Officer of emerging public health issues from sewage discharges managed by the CRD. The MMAG also comments on the need for further areas of study and makes recommendations to the CRD and the Minister of Environment.

The Vancouver Island Health Authority (VIHA) carries out an annual bacteriologic beach sampling program for the presence of the indicator bacteria, faecal coliforms. Fifty-one beaches in the region are sampled. The beaches are chosen because of potential recreational marine water use. The program begins in mid-April with weekly samples taken from each site for five weeks. Sampling is timed to provide a mean running log faecal coliform result for each site prior to the May long weekend.

After the initial five-week sampling period, bathing beaches are sampled weekly, bi-weekly or monthly. Sampling schedules depend on the historical data for each site, perceived risk and the general use or popularity of the beach. Beach results are posted weekly on the VIHA Web site and distributed to the local media. Beach advisories are generally posted if the running log mean exceeds 200 faecal coliform per 100 milliliters. In addition, VIHA monitors any illness reported to them that could have been the result of exposure to polluted water. The results are expressed as “low” (0-50 faecal coliform per 100 milliliters), “moderate” (51-200 faecal coliform per 100 milliliters), and “high” (200+ faecal coliform per 100 milliliters, or fluctuating dramatically).

There are three locations that are in the vicinity of the deep-sea outfalls at Macaulay and Clover points. These are Gonzales Bay, Beach Drive (at the foot of Lewis street), and Ross Bay. The last five years of monitoring results for these three locations have been reviewed. On June 4, and June 11, 2001, Ross Bay had moderate readings of 59 coliforms per 100 milliliters. There were no other readings that exceeded 50 coliforms per 100 milliliters for these three beaches during the five-year period. During this time, there have been no reports to public health authorities of illness associated with swimming.

It should be noted that, in 1991, intense monitoring of Ross Bay showed that increased counts at that time were clearly the result of the storm-water drains rather than the deep-sea outfall at Clover point. The city of Victoria has since diverted the storm drains into the deep-sea outfall to prevent beach pollution. In 1994, the Medical Health Officer removed the permanent public warning posted for the Ross Bay beach area because monitoring results for faecal coliforms showed the beach was no longer contaminated and did not indicate a human exposure risk, based on the Canadian Recreational Water Quality Guidelines.

VIHA uses the Canadian Recreational Water Guidelines (CRWQG) 1992 [4] as the basis for interpreting health risks of marine water exposure. Appendix C includes section 3.2 of the CRWQG and describes the recommendation for marine waters. Based on British Columbia public health policy, faecal coliforms have continued to be used to monitor marine recreational water rather than the enteroccocci.

The MMAG recommended that the CRD investigate the use of enteroccocci vs. faecal coliforms for monitoring the marine waters. In addition the Medical Health Officer recommended modifying the CRD’s faecal coliform monitoring and sampling program, within a meter of the surface to enable the results to be more realistically interpreted using the standard established by the Canadian Recreational Water Quality Guidelines. (CRWQG).

The World Health Organization (WHO) has developed guidelines, [5] including “the Annapolis protocol,” for monitoring recreational waters. [6] It is of interest that the CRWQG were not referenced in the Annapolis protocol. A comparison shows that the indicator organisms in the CRWQG (E.Coli for fresh waters, Faecal Coliforms or Enterococci for marine waters) are similar to those in the Annapolis protocol. The CRWQG provide more evidence from epidemiological studies to support the indicator bacteria standards. It is also of interest that there is a great deal of variation between jurisdictions as to the acceptable “safe” level for marine recreational water monitoring.

A WHO publication provides a guide to epidemiological studies into recreational water quality health effects. [7]

Enteric and Environmental Communicable Diseases:

The Medical Health Officer monitors reportable enteric and communicable diseases, as required by BC’s Health Act and Communicable Disease Regulation.

Table 1 shows the rates of enteric (intestinal) communicable diseases for VIHA’s health service delivery areas (HSDAs), compared with the rates for BC as a whole, for the years 2001-2005. South VIHA is the same geographic area as the CRD. The reporting rates were similar between VIHA’s HSDAs and the province, with a couple of exceptions. Reports of Yersiniosis and campylobacteriosis were higher in south VIHA, but this may be due to differences in lab methods. An outpatient lab that provides service to Victoria has historically used cold enrichment and Cary Blair media, which enhance isolation of these pathogens. It is known that other areas of the province that are served by this lab also show higher rates of these two pathogens. Other labs that provide service to many other areas of the province do not use these same methods. Reporting rates of Vibrio parahaemolyticus, associated with shellfish consumption, is higher for Vancouver Island than for BC as a whole. Vibrio parahaemolyticus is a naturally occurring bacteria in coastal waters and is not associated with sewage.

In summary, these numbers do not support an increase in disease rates that could potentially be associated with sewage in the CRD (South VIHA).

Table l Selected Disease Data for VIHA by HSDA and for BC, 2001-2005

Chemical Contaminants:

The presence of endocrine-disrupting chemicals, persistent organic pollutants and other micro-contaminants such as pharmaceutical drugs in sewage are of scientific interest. However, not enough is known about their effects on the environment or possible human health to influence a decision on sewage treatment.

The MMAG has reviewed this issue and concluded that, although these contaminants warrant attention and control at source, their significance in Victoria’s sewage and implications for increased sewage treatment are unknown at this time.

Many studies have been carried out on animals and often these studies include compounds at much greater concentration than is found in sewage effluent.

To hypothesize that there will be a human health effect there must be an exposure pathway and sufficient dose of a chemical to potentially cause an adverse health outcome.

We have cited evidence that increased sewage treatment at the Macaulay and Clover point deep-sea outfalls would result in no measurable change to the health of the residents of the CRD. Given the magnitude of the proposed expenditure, serious consideration should be given to the ethics and economic sensibility in proceeding with an enhanced sewage treatment project.

From CRD estimates, primary treatment would cost $237 million plus $5.8 million per year in operating costs. This translates into an annual additional cost of $277 per CRD household. Secondary treatment would cost $447 million plus $16.7 million per year in operating costs, constituting an additional annual cost of $573 per CRD household. Furthermore, new estimates will include costs for land acquisition, transmission pipes, treatment-plant construction, ongoing maintenance, energy, sludge transportation and safe sludge disposal.

A Population Health Approach to Public Spending :

In 2006 the Public Health Agency of Canada endorsed a definition of population health:

Population health is an approach to health that aims to improve the health of the entire population and to reduce health inequities among population groups. In order to reach these objectives, it looks and acts upon the broad range of factors and conditions that have a strong influence on our health.

The population health approach recognizes that health is a capacity or resource rather than a state, a definition which corresponds more to the notion of being able to pursue one’s goals, to acquire skills and education, and to grow. This broader notion of health recognizes the range of social, economic and physical environmental factors that contribute to health. (Public Health Agency of Canada 2006)

This holistic approach takes into consideration economic and social factors that influence health in a population, and enables us to examine expenditures on sewage treatment in Victoria within a larger context of alternative expenditures to improve human health.

In order to determine the economic benefits of expenditures on increased treatment for the CRD’s two deep-sea outfalls, it is important to understand what objectives are in place for the environment and human health. What is the socially cost-effective solution?

Using a population health approach, we present three examples of comparative expenditures that may contribute to improvement in human health: health facilities, social housing, and light rapid transit.

CRD Health Facilities Planning has supplied the following data. When the Victoria General Hospital at Helmcken Road was built 20 years ago the capital cost was over $58 million, and it would cost over $100 million today 10 . More recently, the CRD’s total capital expenditure on health facilities for the ten-year period 1994-2003 was $221,151,000 (including the 60 percent provincial share and 40 percent CRD share). Included in that figure is the $123,828,694 capital cost of the recently constructed Royal Jubilee Hospital Diagnostic and Treatment building. The cost of the proposed secondary treatment would build four Victoria General Hospitals.

Looking to the future, the outlay required to establish secondary sewage treatment would cover the entire cost of all capital projects proposed for the south island in VIHA’s Draft Strategic Plan 2010. Such an expenditure would fund a much-needed patient tower as well as all long-term care facility construction. This would greatly enhance the health care available to residents of the CRD.

Victoria has a well-documented problem of homelessness. The CRD’s housing department estimates the cost of one social housing unit at $60,000 for land and $150,000 for a family dwelling, bringing the total to $210,000. The capital cost for primary treatment ($237 million) would buy 1129 social housing units. The capital cost for secondary treatment ($447 million) would buy 2129 social housing units. This would go a long way towards providing accommodation for the region’s homeless and improving their health.

The capital region is experiencing an increasing problem with traffic due to population expansion, increasing numbers of motor vehicles, and resultant air pollution. The “Colwood crawl” means that many people from the western communities spend a great deal of time each day in traffic gridlock. The $237 million for primary treatment, or $447 million for secondary treatment, would contribute significantly towards developing the much-needed light rapid transit to link the center of Victoria with the Western Communities. There would be benefits to family health and reduction in air pollution from traffic.

For the last 20 years, the CRD’s Regional Medical Health Officers have been monitoring potential human health concerns with respect to the CRD’s two deep-sea outfalls at Macaulay and Clover points. It was clearly shown in the early 1990s that beach pollution in the vicinity of the outfalls was a result of storm-water discharges, and not a result of the deep-sea outfalls. During the 1990s, considerable progress was made in diverting the storm-water discharges from Ross Bay, so that the beach was no longer posted as contaminated.

For there to be human health concerns there must be either direct or indirect human exposure to polluted water. Human exposure assessments have shown there is negligible risk to human health from exposure to surface waters as a result of the deep-sea outfalls.

Extensive monitoring, reviews and assessments by the MMAG, and reports such as the 2002 Golder report [8] have not been able to identify any significant human health exposure from the two deep-sea sewage outfalls, with the current level of preliminary treatment.

Potential human health risks from effluent contaminants such as viruses and bacteria, endocrine-disrupting chemicals, persistent organic pollutants and other micro-contaminants such as pharmaceutical drugs have been considered. No known public health risks have been identified.

In October 2005, Chief Medical Health Officer Dr. Stanwick responded to a request by the Minister of the Environment to identify a seawater trigger. He stated that it did not make sense, from a human health perspective, to have a microbiological trigger at the sea floor because there was no likelihood of human exposure.(9)

We have provided three examples of alternative expenditures (health facilities, social housing and light rapid transit) that would, without a doubt, improve public health.

From a public health perspective, there would be no measurable improvement in human health by implementing increased sewage treatment at the two deep-sea outfalls at Macaulay and Clover points. This is because there is currently no measurable human health impact from the outfalls.

While we recognize there may be other considerations affecting the decision of whether to provide increased treatment at the CRD’s two deep-sea outfalls, we view this submission as an accurate summary of assessment of public health risk with respect to sewage treatment at the CRD’s two deep-sea outfalls at Macaulay and Clover points.

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[1] http://nisoftware.com/sewage-circus/ (accessed 18^th March 2006)

[2] CRD Newsletter No 2 June 1993.

[3] C apital Regional District Marine Monitoring Advisory Group (MMAG) Terms of Reference. Revised September 2003

[4] http://www.hc-sc.gc.ca/ewh-semt/water-eau/recreat/index_e.html (Accessed March 20th 2006)

[5] http://www.who.int/water_sanitation_health/bathing/srwe1/en/ (Accessed March 20^th 2006).

[6] http://www.who.int/water_sanitation_health/bathing/Annapolis.pdf (Accessed March 20^th 2006)

[7] http://www.who.int/water_sanitation_health/bathing/bathwatchap13.pdf (Accessed Mar ch 20th 2006).

(8) Archipelago Marine Research Ltd. Q u a l itative risk assessment of marine-based public a ctivities in the vicinity of macaulay point and clover point wastewater outfalls, CRD,BC. September 2002.

(9) Stanwick RS, Assessment of the Human Health Impacts of the Macaulay Point and Clover Point Wastewater Outfalls of the Capital Regional District, October 19^th, 2005.