Give us responsible, rational sewage stewardship
By Brian Burchill, March 1, 2016
Is it time to head to Ottawa to discuss Victoria’s mistaken and expensive risk classification for sewage treatment?
CRITICS OF OUR EXISTING sewage treatment system seem to be unaware of, or unwilling to accept, the sound scientific evidence that certain regions of the ocean are sufficiently rich in oxygen and microbes to subject sewage effluent to the same processes of degradation and oxidation that occur in land-based sewage treatment plants. The Strait of Juan de Fuca is one such region of the ocean.
The World Bank has labelled this marine treatment process auto-purification, and institutions such as the World Health Organization, a British Royal Commission, the US Congress, and the US National Research Council have concluded that it is a viable, acceptable, sometimes preferable, treatment option. The process is driven by the non-polluting, renewable, reliable, and free, energy of ocean currents, which aligns with commitments to reduce greenhouse gas emissions to combat climate change.
Many US coastal communities, such as San Diego, as well as Guernsey in the UK, use this treatment option. Victoria does too, and the claims that Victoria is the only city in the civilized world with such a system are simply false.
The design and engineering of our existing marine-based treatment system using long deep-sea outfalls is based on research done at the University of California at Berkeley and at the California Institute of Technology. In 1968, the BC Pollution Control Branch approved the CRD’s application to install this system, but with the proviso that the CRD constantly monitor it and keep the data available for assurance that it really does work.
About 40 years of monitoring data and studies have consistently shown that our system is indeed effective. The accusations that Victoria’s discharges are causing vast fecal coliform contamination of our waterfront, spewing toxic metals, and fouling Puget Sound, are egregious misrepresentations.
A study determined that metals in our wastewater are not at toxic concentrations, but are as low as 1000 times less than drinking water standards, which is due to the CRD’s exemplary source control program and lack of heavy industry in Greater Victoria.
A study of 1700 samples taken over a 13-year period determined that, by 400 metres (0.4 km) from the outfalls, fecal coliforms diminished to natural background levels. The coliforms, which thrive in the warmth of the human gut, quickly succumb to the cold of the deep seawater or to attack by marine microbes.
The joint claim by three environmental groups in October, 2012, that our discharges were causing vast fecal coliform contamination across the Victoria waterfront was a hoax. Their claim was based on a mere 7 samples taken one afternoon at distances of 2 to 10.5 km from the outfalls, far beyond the 0.4 km. The coliforms detected at those distances were what naturally carpet the seabed from the teeming life in the ocean.
Sadly, television news amplified the groups’ misinformation by giving it 140 seconds of coverage, but gave a mere 13 seconds for a public health officer to try to dispel fears and assure the public that the groups’ claim was a fallacy. No illness has been attributed to the discharge from the system’s deep-sea outfalls in the four decades of their operation.
When pharmaceuticals and personal care products (PPCPs) in our wastewater are discharged into the ocean, they rapidly dissipate to infinitesimal concentrations and degrade in the harsh saline environment. The cumulative effects of continual low-dose loadings of PPCPs into the environment are unknown, and what concentrations are toxic for marine species are also unknown. It’s recommended that studies be done to determine these. Without such data, we can’t determine whether any secondary or tertiary treatment plan would provide sufficient benefit to justify its cost.
As has been done with freon, dioxins, PCB, and PBDEs (flame retardants), the recommended way to deal with PPCPs of concern is source control. For example Triclosan, a non-essential ingredient in some personal care products, has been targeted by Environment Canada for voluntary removal from them. Source control is the method being accepted to also control micro-plastics.
Plastic micro-beads from personal care products and micro-fibers from clothing are being touted as justification to replace our present treatment system. The consensus of treatment plant operators elsewhere is that implementing tertiary treatment is too expensive a solution to the micro-plastics issue and, once again, source control is the preferred solution.
Major corporations which manufacture products which contain micro-beads are voluntarily planning to discontinue the beads within two to three years. Also, the Canadian and US federal governments are taking action to ban products with microbeads within a similar time span. Until those source controls take effect, and until similar actions are taken to tackle micro-fibres, each of us has the power to begin right now to reduce the effect of micro-plastics by not purchasing products which contain them.
Regarding Puget Sound, studies of the currents in Juan de Fuca Strait have determined that it would be a rare event if they ever carried matter from Victoria’s discharges into the Sound. The complaints that Victoria’s discharges are fouling the Sound are made by uninformed Washington State politicians and journalists, and are not supported by their own scientists. In 1994, a joint study by BC and Washington state marine scientists concluded that the effect of our discharges on the Strait of Juan de Fuca was negligible. A study in 2005 for the CRD reaffirmed that 1994 study.
The new federal Wastewater Regulations, which the CRD claims are forcing them to develop their wastewater plan, are in the Fisheries Act, a statute of the Department of Fisheries and Oceans (DFO). The absurdity is that a DFO study in 2014 concluded that the secondary treatment mandated by the Regulations will have a negligible effect on the levels of nitrogen, organic carbon, and PCBs in the Straits.
Justin Trudeau has stated that, “There will be no net environmental benefit from this secondary treatment plant” and that the CRD’s insistence to proceed with it is a “push of ideology over sound scientific evidence.” His Mandate Letters instruct his Ministers to fulfill his election promise of evidence-based decision-making.
On the website of the Canadian Council of Ministers of the Environment (CCME), policy for implementation of the Regulations states clearly that it is no longer acceptable to simply assume that the benefits of a wastewater treatment facility will exceed the costs. Policy requires that a cost-benefit analysis be done.
Given the above evidence, and given that the impact on organisms living in the sediments around the present outfalls is no more than that around the outfalls of secondary treatment systems elsewhere, there seems to be substantial reason to doubt that we will gain an environmental benefit that will justify hundreds of millions, or billions, of dollars for an alternative treatment system. It seems critical that the CRD conduct the cost-benefit analysis.
A document on the CCME website identifies that the classification of “high risk” applies only to treatment systems which discharge into fresh water receiving environments. Their definition of “low risk” applies perfectly to our existing system. Hence, by the regulators’ own definitions, our system has been incorrectly classified as high risk.
Correction of the risk classification would change the CRD’s compliance deadline from 2020 to 2040. Victorians could then be proud of not receiving federal funding 20 years prematurely so that it can be directed to replacement of systems in Canada that truly are high risk.
Brian Burchill is chairperson of the Association for Responsible and Environmentally Sustainable Sewage Treatment. http://aresst.ca/