FRIENDS OF THE JOCK RIVER - Presentation to Ottawa Environment Committee of Council

The Friends of the Jock River

A non-profit, charitable environmental organization
managed and supported by volunteers in the Jock River watershed

www.geocities.com/jockriver

P.O. Box 764, Richmond, ON, K0A 2Z0

Presentation to
Environmental Services Committee, City of Ottawa
May 27, 2003

MUNSTER HAMLET WASTEWATER TREATMENT FACILITY –
RE-EVALUATION OF ALTERNATIVES AND RECOMMENDED SOLUTIONS

Over the past several years, the Friends of the Jock River has gathered a considerable amount of technical information from engineers and other experts on the different sewage treatment and sewage transport options being considered for Munster Hamlet. We first commented on the Environmental Assessment by Connestoga- Rovers and Associates (CRA) and then we became more actively with the request for a Bump-Up to the Minister of the Environment, the Ontario Municipal Board Appeal (over three weeks of mostly technical testimony) and the R.V. Anderson re-evaluation. We have listened to proponents, engineers and other experts, both for and against each of the options, namely: forcemain pipe; tertiary on-site treatment with discharge to the Jock River (CMS); and lagoon/sand filtration with summer spray/snow-making (Northern Watertek/Snowfluent).

Even before we make our views known to the former Regional Council and before we filed our Bump-Up Request to MOE, the Friends of the Jock River had reached a similar conclusion to that reached by R.V. Anderson in its December 2002 re-evaluation report - that on-site treatment is the appropriate solution for Munster Hamlet’s sewage problems. We now know much more about all three options than we did then. Nevertheless, we have consistently rated the pipe solution a distant third.

Of the three different options, the Friends of the Jock River favors the CMS option. The Snowfluent option, because it is based on proprietary technology, and is both operator and land sensitive, has been difficult for us to evaluate effectively.

In our review of the Staff Report and of the whole Munster sewage issue, we make to following comments and observations:

The CMS option does not require a lagoon back-up. Throughout the time the Friends of the Jock River has been involved in this issue (1998) there has never been any mention of a need for a back-up lagoon for this option. The technology involves the sequential connection of rotating biological contactor (RBC), sand filter and UV filter in a module. The number of these modules operating in parallel (Munster would have 3), is determined by peak flow. At non-peak times, non-operating modules become back-up.

Interestingly, ROPEC does not have a back-up. It dumps untreated sewage into the Ottawa River during peak flow events (4,000,000 litres in 1998, the last date for which I have data).

We believe that the addition of a lagoon back-up to the CMS proposal is an artificial requirement added by Staff and its consultant to serve several functions: to put all options on an artificially equal footing with respect to the disturbing lagoon/West Nile virus issue; to increase the cost of the CMS option; and to render null the concerns of most Munster residents who want a solution that gets rid of the lagoons.

Time of implementation - The Friends of the Jock River has always maintained and will reaffirm that the Munster sewage problem needs a timely solution. The Staff report indicates time is extremely important and on every occasion the issue has come to RMOC or to the current City councils, time was mentioned. However, curiously, timeliness was never part of the consultant’s decision matrix (May 1999). If the importance of this criterion had been conceded by the City’s lawyers, staff and consultant at the OMB, on-site treatment would have been selected and the plant would have been running in late 2001. (In fact, if several other facts now accepted by Staff had been conceded, any one of them would have changed the decision matrix outcome.) The savings to the City would have been at least $179,000 + $50,000 (for the two studies by R.V. Anderson) plus $2,600,000 (the costs of hauling Munster sewage at $650,000 per winter from 2001 to the earliest completion in May 2005) - in round terms $2.85M. I believe that City staff bears the responsibility for this needless waste of our tax dollar.

Implementation- The route through Richmond has not been selected. Quite a few of the bump-up requests to the MOE claimed that route selection should have been part of the original Environmental Assessment (EA). The MOE Minister refused the bump-up. The outcome is not surprising as I have yet to hear of the acceptance of a bump-up request by the Environment minister under the current Conservative government.

The residents of Richmond are to be consulted on the route selection process after the start of the project during the design stage. However, the residents of Richmond have had their right of redress under the EA process removed completely. How many councilors would accept the placement of about 1.5 km of forcemain sewage pipe through one of the communities in his or her ward without involving the community in the EA.

Requirement of environmental assessment of on-site options- Staff has said that the on-site options would have to go through another environmental assessment. Engineers who have written EA Addenda without repeating the EA have told us that there is no such legal requirement.

- it must cross through the Richmond Fen Wetland (1.7 km) in the road bed of the Franktown road. In this section, it would have to go down the centre of the road to prevent damage to the wetland.

- the pipe must cross the route of one major gas pipeline (largest number of accidental pipe ruptures relate to gas)

- it must run past more than 140 homes that rely on shallow wells for their water

- the City has assured everyone that dangers to these will be mitigated at the design and implementation stages.

- currently, for 3 seasons of the year, Munster sewage is sprayed onto fields near the Jock River where as surface and ground water, it ends up in the Jock. While of questionable quality, it augments the flow in the River. The pipe would steal this water, making the low flow problems of the Jock River even worse.

- the sewage will go through 60 km of pipe and 7-8 lifts (pumped up) and will end up eventually at the City’s ROPEC treatment plant on the other side of the City.

- sewage in long forcemains has a history of becoming septic. The hydrogen sulfide produced by the septic sewage smells, is toxic and corrodes equipment. Further, septic sewage is expensive to treat. Septic sewage is a problem with the current Richmond-Glencairn sewage forcemain.

- ROPEC currently treats sewage to a secondary level and discharges it to the Ottawa River. The phosphorous discharged is 25-30 times that of the CMS system.

- ROPEC must use chlorine to disinfect the effluent in the warmer months. The chlorine is toxic to aquatic life.

- ROPEC routinely discharges untreated sewage directly to the Ottawa River (4,000,000 litres in 1998, the last date for which I have data). Shame.

- the ROPEC facility is the second largest point source of water pollution in the province.

- while the sewage facility may be in compliance with current provincial requirements, the City must recognize that Walkerton has and will continue to influence the Ontario government’s approach to sewage and water treatment. The Ontario government will likely soon require treatment plants to be upgraded to tertiary treatment level to protect our no-longer unlimited supply of clean water. Now is the time to get started by removing new demand. (Munsters sewage would represent about 0.7% of ROPEC’s current production. Munster’s proportionate cost of upgrading the ROPEC facility must be added to the price of the pipe option!)

- there have been many statements about the reliability of and the risk of the on-site treatment options but there has been nothing on the reliability of forcemain sewage pipes. Failure to do so is negligent. Please remember that we are not talking about the gravity sewer pipes that run by the houses of most City residents. Forcemain sewer systems are under pressure and are a different kettle of fish. The forcemain pipe option is considered to be highly reliable by “pipe” engineers but the Richmond-Glencairn pipe, a similar kind of forcemain to that envisioned for Munster, has ruptured 5 times since its construction in the 1980’s. If PE pipe is to last 60 years, we can expect ruptures over its lifetime, perhaps as many as 15. Consider the effect of ruptures on: the Richmond Fen Wetland (1.7 km or 15% of the Munster to Richmond pipe); the crossing under the Jock River (2 of the recent ruptures near Richmond have been related to the crossing); and the 140+ homes that rely on wells for their water. The proven degree of “reliability” is most disturbing when one thinks of environmental damage, of the inevitable clean-up costs and of Walkerton. The reliability of long sewage forcemains is a myth.

- the City has assured everyone that these dangers will be mitigated at the design and implementation stage.

- look up the definitions of “mitigation” or “mitigate”. They relate to reducing the severity of or moderating something which is negative. Staff or its consultants who try to placate with the word “mitigate” are telling you and me that there are dangers to the pipe.

- Staff has said that pipe is acceptable to the MOE but Staff is hiding behind MOE and not doing following the lead of the previous and present Official Plans. Both plans dealt with protection of the environment and the need to be innovative. City Staff and the consultants it has hired have been the severely lacking in this department.

- greenhouse gas emissions related to the operation of the pipe are significantly greater that those for either of the on-site treatment options. Pipe requires an 88 horsepower pump and then the sewage must be pumped up 7-8 times before it gets to ROPEC. Treatment involves big motors as well. The CMS option operates on 5 HP motors for each RBC and there are a few other smaller motors. If the City has to deal with reducing its greenhouse gas footprint - pay attention.

- the sewage would be treated to a tertiary level (limit for Ontario’s swimmable water requirements).

- the discharge from the CMS treatment plant would represent most if not all of the summer surface flow of the river in the Copeland Road portion in drought years (3 of last 4 summers).

- the three main components of the treatment process are all proven, well known and reliable technologies. There are over 2,500 RBCs in use in North America and the technology is used extensively in Europe. The combination of the three components is new because of Ontario’s stringent Policy 2 discharge requirements. Nevertheless, the combination has been tested and accepted by the City and the Ontario Ministry of Environment (MOE). The MOE has granted a certificate of approval for a facility in Manotick employing the identical technology for the same discharge requirements.

- tests in New York State have proven the technology will exceed discharge requirements.

On the issue of consultants, an article on the front page of Sunday’s Ottawa Citizen on Mr. Himelfarb’s report to government indicated that “government does not get any better advice from consultants … because they deliver whatever the manager paying the bill wants to deliver.”

I believe that Mr. Himelfarb’s words are applicable at most level’s of government.

I ask you, the members of the Environmental Services Committee, to seriously consider how this issue has been handled (mishandled in our opinion), to correct the situation by rejecting the staff report and to direct staff to implement an on-site treatment solution.