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William A. Stubblefield, PhD, Chai

Mark Servos, PhD, Co-Chair

Richard M. Gersberg, PhD

Craig Riley, PE

David Simpson, PhD

Daniel Smith, PEng, PhD

Peter Wells, PhD

Scientific and Technical ReviewCapital Regional District Core Area Liquid Waste Management Plan

Submitted to the CapitalRegional District Victoria, BC

Submitted July 12, 2006, bythe Scientific and TechnicalReview Panel


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July 12 2006

Chair Alan Lowe

Capital Regional District Board

625 Fisgard Street

PO Box 1000

Victoria, British Columbia V8W 2S6

The Panel is pleased to present their technical and scientific report on the management of liquid waste

to the Capital Regional District (CRD) Board.

The CRDs intent to conduct a technical and scientific review was implicit in their decision to choose the

Society of Environmental Toxicology and Chemistry (SETAC) North America to establish and manage theindependent panel. As a science-based group, the Panel was equipped to provide the CRD Board with

technical advice. One of the challenges the Panel faced in its work was determining what was in and

what was out of the Panels scope of work. For example, there were many discussions about whether

regulatory and policy issues should be considered in making conclusions and recommendations. The

Panel decided that their role was technical in nature and that their report should be offered to the Board

in that context. Our advice is best considered along with other kinds of information (e.g., societal, fea-

sibility, engineering, and regulatory) that the CRD Board should seek in making decisions about liquid

waste management.

This report represents the consensus of all Panel members. Thank you for the opportunity to engage in

debate on the challenges that lie ahead.

Sincerely,

Dr. William A. Stubblefield

Panel Chair

Scientific and Technical ReviewCapital Regional District Core Area Liquid Waste Management Plan


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William A. Stubblefield, PhD, (Panel Chair)is a senior environmental toxicologist with Parametrix,Inc., and serves as a faculty member at Oregon StateUniversity, Department of Molecular and EnvironmentalToxicology. He has more than 20 years of experience inenvironmental toxicology, ecological risk assessment,

water quality criteria derivation, and aquatic and wildlifetoxicology studies. Dr. Stubblefield has authored morethan 50 peer-reviewed publications and technicalpresentations in aquatic and wildlife toxicology andenvironmental risk assessment. He is a co-editor of arecently published book, Re-evaluation of the State of theScience for Water Quality Criteria, which examines theissues and approaches to be used in the evaluation ofenvironmental impacts associated with contaminants.

Mark Servos, PhD, (Panel Co-Chair) holds aCanada Research Chair in Water Quality Protection inthe Department of Biology, University of Waterloo. He isthe Scientific Director of the Canadian Water Network, anational Network of Centres of Excellence on innovationin the water sector. His research and teaching programis focused on ecotoxicology, integrated water resourcesmanagement, risk assessment, and management ofemerging threats to water quality. His research includesexamination of the risk management of pharmaceuticals

and endocrine disruptors in municipal and industrialeffluents and agricultural best practices.

Richard M. Gersberg, PhD, is currently aProfessor (and Head of the Division) of EnvironmentalHealth in the Graduate School of Public Health at SanDiego State University (SDSU), and Director of theCoastal and Marine Institute at SDSU. He has an M.S.degree in biology from the University of Houston anda PhD degree in microbiology from the University ofCalifornia, Davis. Dr. Gersberg specializes in water

quality research and has broad experience working withboth chemical and microbiological pollutants and humanhealth risk assessments. He has more than 55 scientific

publications in these areas. Dr. Gersberg has conducted anumber of studies on the detection, quantification, andrisk posed by pathogens, including hepatitis A virus andenterovirus in estuaries and the ocean. He has conducted

watershed modeling to evaluate loading of fecal bacterialindicators to various environments.

Craig L. Riley, PE, holds bachelors and mastersdegrees in civil engineering from Montana StateUniversity. He is a registered professional engineer in twostates with more than 30 years of professional experiencein both private and public sectors. His experienceincludes all aspects of planning, design, construction,operation, and management of public municipal utilities,including potable water, wastewater, storm water, and

water reclamation and reuse facilities. He is currently theProgram Lead for the Washington State Department ofHealth, Water Reclamation and Reuse Program wherehe is involved in the review and approval of reclamationplanning and construction documents, promotionof water reclamation in the development of technicalpolicies, treatment standards, and new regulations.Mr. Riley is active on planning, water reuse and water

resources committees of the Water EnvironmentFederation and American Water Works Association aswell as several publication review committees.

R. David Simpson, PhD, is an economist withthe United States Environmental Protection AgencysNational Center for Environmental Economics.Beginning in September 2006 he will take up anappointment as HRH Prince Sultan bin Abdul AzizChair in Environmental Policy at Johns HopkinsUniversitys School of Advanced International Studies.

Left to right: William Stubblefield,

David Simpson, Peter Wells, Craig

Riley, Richard Gersberg, Daniel

Smith, and Mark Servos

Scientific and Technical Review Panel Members


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Previously Dr. Simpson was a Senior Fellow at Resourcesfor the Future and a Visiting Professor at UniversityCollege London. His work has focused on the economicsof biological diversity and biological resources, as wellas technology and industrial policy. He participatedin the Millennium Ecosystem Assessment and otherinternational undertakings, has edited several books,

and written many journal articles, book chapters, andcontributions to policy publications. Dr. Simpsonreceived his PhD in economics from MassachusettsInstitute of Technology and his BA in economics from

Whitman College.

Daniel W. Smith, PEng, PhD, is the CanadaResearch Chair in Environmental Engineering anda Fellow of the Academy of Science of The RoyalSociety of Canada. As a Professor of the EnvironmentalEngineering and Science Program at the University of

Alberta, he has guided more than 80 masters and 20doctorate graduate students to the completion of theirdegrees and has published more than 400 scientific andtechnical articles. Dr. Smith is one of three Co-Directorsof the new Alberta Ingenuity Centre for Water Researchand a Co-Principal Investigator in the Forest Watershedand Riparian Disturbance Project. Following receiptof his doctorate in Environmental Health Engineeringfrom the University of Kansas and 8 years of servicefor various agencies, Dr. Smith joined the Universityof Alberta in 1978. Dr. Smith has served in numerousother professional capacities, including President of theCanadian Society for Civil Engineering in 198788,the Rudolph Hering Medal 2002 for the best Journal ofEnvironmental Engineering paper, Elbert F. Rice, Can-

Am Awards and the Harold R. Peyton Award for ColdRegions Engineering (2004) from ASCE, and memberof the Water Environment Federation Research andProgram Committees.

Peter Wells, PhD, has worked as a Senior ResearchScientist and Environmental Manager for EnvironmentCanada (Dartmouth, NS) for more than 30 years. Hislong-term research interests are aquatic and marine

ecotoxicology, coastal ecology, and science for integratedcoastal management, most recently addressing issues inthe Bay of Fundy and Gulf of Maine. Dr. Wells holdsacademic appointments at the School for Resource andEnvironmental Studies and the Marine Affairs Program,Dalhousie University, Halifax; the Acadia Centre forEstuarine Research, Acadia University, Wolfville, NS; andthe Bermuda Biological Station for Research, St. Georges,Bermuda. He teaches and supervises graduate studentsin marine ecotoxicology and ecological risk assessment.Dr. Wells has served on various technical committees in

North America and has served Canada on the UnitedNations Joint Group of Experts on Scientific Aspects ofMarine Environmental Protection (GESAMP) for 16years. He has written, contributed to, or edited morethan 250 publications in his field. Dr. Wells is a Fellow ofthe American Association for the Advancement of Science(2000), a recipient of the Society of Environmental

Toxicology and Chemistry (SETAC) Presidential Citationfor Outstanding Service to the field (2002), and arecipient of Dalhousie Universitys highest award forTeaching Excellence by Part-Time Faculty (2003).

Panel Support

The Panels work was supported by a number ofindividuals. Beth Power, MSc RPBio, of AzimuthConsulting Group Inc. was contracted to manage the

overall project and provide liaison with the CRD. Sheis an environmental consultant with a strong interest inscience policy and decision-making. Leslie Rodgers ofPraxis Pacific coordinated the public submissions processand communications.

SETAC North America staff provided ongoing supportduring the Panels work. Taylor Mitchell was responsiblefor administrative support, media contact, and documentproduction, which was all much appreciated by the Panel.Linda Stivers handled invoicing and budget tracking.Mimi Meredith assisted with document production.

About SETAC

The Society of Environmental Toxicology and Chemistry(SETAC) is a nonprofit, worldwide professional societycomprised of individuals and institutions engaged in:

the study, analysis, and solution of environmentalproblems

the management and regulation of naturalresources

environmental education

research and development .

SETACs mission is to support the development ofprinciples and practices for protection, enhancement andmanagement of sustainable environmental quality andecosystem integrity.

The founding principles of SETAC are: Multidisciplinary approaches to solving

environmental problems

Sectorial balance: Academia, Business, Government

Objectivity: Science-based.

For more information visit www.setac.org.


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iv

The Capital Regional District (CRD) established a Scientific and Technical Review Panel to review liquid waste management issues in

the core area. Panel members were identified and selected by the Society of Environmental Toxicology and Chemistry North America

(SETAC North America). The Panel was independent of the CRD and SETAC North America. The findings of the Panel do not represent

the view of SETAC North America, the organizations of individual panel members, or the CRD.

Contents

1 Section 1: Introduction

7 Section 2: Public Submissions

11 Section 3: Synthesis of Panels Findings

17 Section 4.1: Review of Liquid Waste Management Plan

27 Section 4.2: Assessment of Impacts of Wastewater Discharges

41 Section 4.3: Review of Early Indication and Seafloor Trigger Processes

47 Section 4.4: Risk Assessment of Landfill Leachate

53 Section 4.5: Future Risks of Wastewater Management

59 Section 4.6: Emerging Chemicals of Concern

69 Section 4.7: Review of Liquid Waste Management Systems

77 Section 4.8: Review of Other Coastal Communities

87 Section 4.9: To Treat or Not to Treat Sewage: A Risk Management Decision

101 References

107 Glossary

123 Acronyms and Abbreviations


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Scientific and Technical Review: CRD Core Area Liquid Waste Management Plan

Background

The Capital Regional District (CRD) ap-proached the Society of EnvironmentalToxicology and Chemistry North America

(SETAC North America) to establish an in-dependent Scientific and Technical ReviewPanel (hereafter referred to as the Panel) toevaluate aspects of the CRDs Core Area Li-quid Waste Management Plan (LWMP; CRD2000). The physical extent of the Core Area isshown in Figures 1-1 and 1-2.

The provincially approved Core Area LWMPoutlines the plans of the CRD and its muni-cipal partners for the management of liquidwaste from communities within the plan area

for the next 25 years. Specific commitmentsare made in the following subject areas:

Source control

Management of inflow and infiltration

Wastewater and marine assessment

Stormwater quality management

Harbours environmental action

Management of trucked liquid waste

Management of sewerage system over-flows

Wastewater treatment and disposal forareas serviced by municipal collectionsystems

Wastewater treatment and disposal forareas not serviced by municipal collec-tion systems.

1

IntroductionThe CRD considered that an independentreview of aspects of the LWMP was necessarybecause

the last independent analysis was con-ducted in the mid 1990s,

new technologies have been developed,and

there are new concerns related to emer-ging contaminants and their effects onthe environment.

On 4 May 2004, the Core Area Liquid WasteManagement Committee authorized CRDstaff to commence negotiations with SETACNorth America to coordinate the independentreview. The Terms of Reference for the Panel

were developed by the CRD and reviewed bythe CRD Board (Appendix A). The purposeand values of the Panel and the principles ofthe review are described in Box 1.

Selection of the Scientific and

Technical Review Panel

SETAC North America established an in-dependent selections committee composedof Canadian and American members of theSociety representing academia, business, and

government (the 3 membership sectors ofSETAC). The selections committee aimed fora panel composition that mirrored the cross-sectoral principles of SETAC.

A 7-person Panel was appointed in the winterof 2005. SETAC North America providedproject management and administrative sup-port for the Panel. The individuals on the


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Figure 1-1: Physical extent of the Core Area LWMP (see Terms of Reference inAppendix A)


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Section 1: Introduction

Panel covered the main topics of the Panelswork:

William A. Stubblefield, PhD, Chair:environmental toxicology

Richard M. Gersberg, PhD: public health

Craig L. Riley, PE: wastewater treatment,water reuse

Mark Servos, PhD: risk assessment, ef-fects of emerging chemicals

R. David Simpson, PhD: economics ofenvironmental systems

Daniel W. Smith, PEng, PhD: wastewatertreatment design

Peter Wells, PhD: ecotoxicology and mar-ine ecology

The Panels Terms of Reference

and Process

The CRD Scientific and Technical ReviewPanel was asked to conduct a broad review ofthe CRDs Core Area LWMP in 4 areas (with-

Figure 1-2: Wastewater infrastructure of the Core Area (see Terms of Reference inAppendix A)

in each of these areas, multiple questions wereposed; see Terms of Reference in Appendix A):

A. The components of the CRDs Core AreaLWMP (including leachate)

B. Future risks related to population growth,intensification of human uses of the en-vironment, and emerging concerns relatedto specific chemicals

C. Alternative and new liquid waste manage-ment systems

D. The CRDs overall approach and assump-tions regarding liquid waste management.

In December 2005, the Panel Chair and SE-TAC North America Project Manager metwith CRD staff to clarify the Terms of Refer-ence and the specific questions posed, beginthe process of accessing technical informa-tion, and discuss the required site visit. At thistime, the Panel signaled to the CRD that theresponses to the questions would be technical,


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and as a result, the CRD would need to seekbroader inputs on some issues.

After the initial meeting with the CRD, fur-ther liaison with CRD staff was always throughthe SETAC North America Project Manager.Early in the Panels process, CRD staff or theirconsultants to the CRD were invited on twooccasions to make presentations and answerquestions on 1) an introduction to aspects ofthe LWMP and marine monitoring and 2)

1 The process used to select consultants was necessarily accelerated and included the following components: long-listing candidates onthe basis of expertise; short-listing candidates on the basis of experience, proposed team members, absence of conflict of interestand availability; and then interviewing with standardized questions.

Box 1: From the Panels Terms of Reference

Purpose of Panel

The purpose of the scientific and technical review is to ensure the protection and quality of the environment andpublic health in the area of liquid waste management

to engage a world-class, professional organization to reviewthe Core Area LWMP and its assumptions

to assess the adequacy of the approved LWMP to meet theneeds of the region

Values of Panel

The scientific and technical review will be undertaken accordingto the following values:

protection of public health protection of the environment

sound scientific reasoning

cost effectiveness

Principles of Review

The scientific and technical review will be guided by the follow-ing principles:

1. The CRD is committed to maintaining and enhancing thequality of the environment.

2. The CRD is committed to integrated coastal management

whereby all sources of contaminant discharges to the coastalenvironment are evaluated and priority is given to solutionsthat produce the greatest benefits.

3. If any significant negative environmental effects are detectedas a result of a CRD business practice, the organization willmove immediately to correct the problem.

results of recent marine discharge plume mod-eling work. CRD staff also guided the site visitof CRD facilities on 20 February 2006 (Panelstrip report is provided as Appendix B).

Components of the Panels work that requiredexternal technical support were identifiedearly on, so that the additional work could getunderway and be provided to the Panel. Onbehalf of the Panel, SETAC North Americacommissioned work from a number of con-sultants on specific topics or to fulfill specificcontract requirements. A competitive process1

was used. While most of the consultants to thePanel worked under the direction of the Panel,the Terms of Reference also required SETAC

North America to identify and contract athird party to conduct a compliance review ofthe LWMP. Following a competitive process,Jacques Whitford was selected to conduct thisreview; they delivered their audit report (Ap-pendix C) to SETAC North America, whothen provided it to the CRD.

The following consultants reports were pre-pared for the Panel, each of which is cited inthe text as an appendix:

Public Submissions Report (Praxis Pacific;

Appendix D) Landfill Risk Assessment (Parametrix

Inc., Appendix F)

Wastewater Treatment Options Review(NAGM; Appendix H)

To facilitate their work, the Panel held fourmeetings in the first half of 2006, along withmultiple conference calls. The schedule for thePanels work was aggressive, necessitating con-sistent interaction among Panel members.

The Panels Terms of Reference (Appendix A)identified a series of questions, each of whichbecame the subject of the work of a subgroupcomposed of one or more Panel members.Some Panel members served on more than onesubgroup. The CRD provided a bibliographyof some 237 documents that might be relevantto the Panels work, from which about 141


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Section 1: Introduction

documents were downloaded to an FTP sitefor access by Panel members.

The Panel had extensive discussions about theirmethodology and approach, particularly onhow to integrate the copious amount of exist-ing and new information in the time available.The following principles were applied:

A large number and a great variety ofreports and publications were reviewedby the Panel. This review allowed for in-depth analysis in several areas where itwas needed, with a high-level approach inothers.

The role of appointed panels (such as

this Panel) is to provide added value toexisting information by integrating whatis known and then providing opinionsand advice. Necessarily, the Panel oftenrelied on the analysis and interpretationof others, as opposed to re-evaluating ori-ginal data.

The Panel believes that the CRD Boardwants their consensus view to be based ontheir training and experience and wantsthe Panel to advise on key issues for liquid

waste management in the CRD CoreArea.

The questions posed to the Panel were acombination of general and specific with, insome cases, significant overlap. Therefore, thePanel has re-ordered the CRDs questions [ori-ginal questions are in the Terms of Reference(TOR; Appendix A)] and combined two of thequestions. The questions are given in Box 2;the Panels response to the questions comprisesSection 4.

Finally, the Panel felt strongly that some of thequestions (particularly the to treat or not totreat question) were not questions that couldbe answered through technical and scientificinput alone. The Panels work was neither de-signed nor directed to account for social, polit-ical, regulatory, or policy considerations; how-ever, the Panel has indicated in their responsesto the questions where these other inputswould benefit any decision-making process.

Box 2: Questions from the Panels Terms ofReference (see Appendix A)

The CRD has a series of liquid waste management programs

laid out in the Core Area LWMP. Evaluate the effectivenessof these programs to manage risks associated with the CRDswastewater practices and provide recommendations on thoseprograms that may need to be reprioritized or restructured.[Question A2; Section 4.1 in the Panels report]

Assess the current environmental and human health impactsof the Clover and Macaulay points wastewater discharges.Discuss the significance of these impacts. [Question A1; Sec-tion 4.2 in the Panels report]

Review and assess the effectiveness of the early indicationprocess and seafloor trigger process to signal when advancedsewage treatment is required. [Question A3; Section 4.3 in the

Panels report] Review the need for treating leachate to protect human health

and the environment before the leachate is discharged to thesewer from Hartland Landfill. Document the risks associatedwith the current practices. If treatment is necessary, recom-mend treatment options. [Question A4; Section 4.4 in thePanels report]

Identify and evaluate the future risks of the CRDs wastewatermanagement practices under reasonably plausible scenarios.Discuss the significance of these risks. [Question B1; Section4.5 in the Panels report]

Considering the CRDs current liquid waste managementpractices, analyze the significance of the risks associated withemerging chemical contaminants of concern and persistentorganic chemicals on the receiving environment and publichealth, both now and in the future. Gauge how the impactsof the CRDs approach to liquid waste management practicesand the risks associated with emerging chemicals of concernchange with the implementation of sewage treatment. [Ques-tions B2 and D2 combined; Section 4.6 in the Panels report]

Identify and rank the alternative and new liquid waste man-agement systems that may be applicable to the CRD. [Ques-tion C1; Section 4.7 in the Panels report]

Review the effectiveness of the CRDs approach to liquidwaste management compared to other coastal communities.[Question D1; Section 4.8 in the Panels report]

Determine if the CRD should implement sewage treatmentto manage the discharge of wastewater at Clover and Macau-lay points. If so, identify what level of sewage treatment isrequired and why. [Question D3; Section 4.9 in the Panelsreport]


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A schematic summarizing the Panels processis shown in Figure 1-3, resulting in this reportand its appendices.

Road Map to the Panels Report

One of the challenges that the Panel faced washow to respond to the questions being posed(which are complex and technically difficult toanswer) in a way that would be understandableto the public. This report is designed to havemultiple layers of increasing complexity:

Readers who want the highlights shouldread Section 3.

Readers who are interested in more com-prehensive findings should read blue-

highlighted text in Section 4. Readers who want the detailed answers

posed to the questions in the PanelsTerms of Reference should read Section 4.This section is aimed at persons who arefamiliar with the topics being addressed.

The more detailed analyses and informa-tion that form the background of thePanels work are provided as appendices

Figure 1-3: Schematic of Panels process, showing inputs and outputs

outputs

inputs

hardcopy

cd

panels report

consultants to panel(reports)

panel Meetings & dialogue

other docuMents &knowledge

crds reports (237)publics technical

subMissions (62)

on a CD-ROM inserted in the back coverof this report.

A glossary of terms and a list of acronyms areprovided following the list of references cited.


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2

Public SubmissionsProcess

The Panels public submissions process wasdeveloped and managed in accordance withItem 2.3 of the Panels Terms of Reference

(TOR; see Appendix A): SETACwillcoordinateaprocesswherebythepublicisinvitedtomaketechnicalsub-missionsfortheReviewPanelsconsidera-tioninrelationtotheReviewPanelsscopeofwork.SETACwillworkwiththepublicconsultationspecialisttodeterminewhichsubmissionsarerelevanttothetechnicalscopeofwork.ThosesubmissionsthatarerelevantwillbecompiledandforwardedtotheReviewPanelforitsconsiderationandinclusioninthefinalreport.Thosesubmis-

sionsthatarenotdirectlyrelevantwillbereviewedandcompiledbythepublicpolicyconsultant,withtheassistanceofSETAC,andthefindingsincorporatedintheRe-viewPanelsfinalreport.

To design and manage the submissions pro-cess, SETAC North America engaged theprofessional services of Praxis Pacific, a firmspecializing in public involvement. In addi-tion to meeting the TOR, the objective of thesubmissions process was to:

Provideanopen,accessibleandresponsivepublicprocesswhilemeetingtheReviewPanelsneedforthemostcomprehensivescience-basedinformationonliquidwasteissuescurrentlyavailable.

Appendix D contains the full report describ-ing the public submissions process. The pro-cess focused on eliciting written submissions

from the public. Written submissions werefelt to be the most efficient and appropri-ate mechanism for the Panel to amass, siftthrough, assimilate, and consider all availabletechnical information. The 8-week public

process was launched on 14 February 2006,with a submissions deadline of 7 April.

Activities to Support

Public Submissions

Process

Stakeholder database and contact

The Panel collaborated with CRD Environ-mental Services staff to identify a startingbase of 41 stakeholder groups and individualswho might have interest and new or addi-tional technical information relative to thereview and/or be interested in participatingin the submissions process. A letter from thePanel Chair inviting submissions was mailedto stakeholders on 10 February 2006 andemailed on 14 February. On 12 March, a fol-

low-up email with a reminder of the 7 Aprilsubmissions deadline was sent to all stake-holders who had not yet acknowledged receiptof the Chairs letter or submitted information.Additions to the stakeholder database werealso solicited, and any new contacts identi-fied were sent information about the Panelsprocess.


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Paid advertising

The Panels call for submissions was advertisedvia paid ads in the 15 and 22 February and1 March 2006 editions of the Victoria Times

Colonist and 6 Vancouver Island News Group(VING) papers: Esquimalt, Oak Bay, Penin-sula, Saanich, Victoria, and Goldstream News.An additional ad (part of a 4-ad package) ap-peared in the VING newspapers on 8 March2006.

Press releases and media liaison

Press releases and media liaison were initiatedin an effort to augment paid advertising aboutthe call for submissions and to keep the Vic-toria-area public informed of key milestones inthe process. The Panel issued 3 press releases,and the Review Panel Coordinator (SETACNorth America representative) responded to,and in several cases initiated, media contact,resulting in several telephoneinterviews over the course of theprocess.

Website

A website (www.setaccrdpanel.org)was developed for the Panels pub-

lic submission process and man-aged through the SETAC server. It included in-formation about the process, the Panels Termsof Reference and background, instructions forWeb-based submissions, a form to downloadfor mail-in submissions, and a direct emaillink. The website was launched on 13 February2006 and opened for online submissions on20 February through midnight on 7 April, thesubmissions closing date. Online submitterswere guided to a user-friendly Data Submis-sion Form. People submitting via the websitewere sent an automated reply acknowledgingreceipt and assigning a file number.

Contact options

A dedicated postal box was established andpublicized for mail-in submissions. A link fromthe website was provided to the Panel emailaddress. The Praxis Pacific phone number with

voice mail was publicized in paid ads and inpress releases as the contact number for anyphone inquiries.

Processing

The public consultation coordinator, in liaisonwith the SETAC North America project man-ager, reviewed all submissions1 to sort themas technical and other. Submissions weredeemed to be technical if they provided sci-entific or technical data or information thatmight help inform the Panels scope of review,and other if they dealt with social or publicvalues or opinions.

Response

The process garnered submissions from 52 dif-ferent groups and individuals for a total of 82submissions, as summarized in Table 2-1.

Submitters were made up of 9 groups or organ-izations and 43 individuals, the latter includ-ing scientists, university professors, medicaldoctors, engineers, consultants, and concernedcitizens. The submitting organizations were asfollows:

Non-government organizations:

- BC Sustainable Energy Association

- Georgia Strait Alliance

- Portage Island Protection Society

- Sierra Legal Defense Fund

- T Buck Suzuki Environmental Foun-dation

- Victoria Sewage Alliance

Government agencies

- Environment Canada

- Ministry of Environment

- Vancouver Island Health Authority

Table 2-1: Summary of submissions to the Panel

Technical Other Total

Number of submitters 32 20 52

Number of submissions 62 20 2

1 A submission is defined as a contribution to the Panel that arrived together on a given date/time. Some contributors submittedmultiple submissions.


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Section 2: Public Submissions

The topic garnering the greatest interest wassewage waste, its treatment and discharge.

Similarly, the keywords submitters used tocharacterize their submissions largely reflected

data, information, interest in, and/or concernsabout the effects of wastewater on the marineenvironment. Several technical submissionsdescribed new or emerging technologies forwastewater treatment.

Technical submissions

All technical submissions were reviewed by oneor more Panel members. No new site-specificdata were provided, although the 62 technicalsubmissions added to the breadth of technical

opinions on the issues the Panel was mandatedto consider. The submissions provided a senseof completeness and confirmation of the pointsof current scientific debate concerning liquidwaste management, particularly within thecontext of the CRD. The Panel has integratedthe results of their review of these submissionsinto this report to the CRD Board.

Summary of other submissions

All 20 of the submissions dealing with public

and social values addressed some aspect of sew-age treatment in the CRD.

Support for treatment

Seventeen people spoke in favour of sewagetreatment, several using strong adjectives todescribe their sense of outrage that raw sew-age is discharged into the ocean, for example,embarrassing, arrogant, disgusted,ashamed, appalled, and unbelievable.People spoke of concerns about impacts in the

immediate CRD area (sewage smells nearoutfalls, plastic tampons washed up on Cad-boro Beach, skin and eye infections for divers),the surrounding Straits (pollutants in the sea-bed, depleted fish stocks, high levels of toxicityin whales), and cumulative effects on the oceanas a whole (the diminishment and toxicity ofsea-floor life, affecting the food chain, and anincreasingly fragile oceanic system).

Several submitters suggested that the lack ofsewage treatment tarnishes Victorias reputa-

tion provincially, nationally, and internation-ally, resulting in bad press, reduced tourism,and closed beaches. One found it grating thatsmaller, less wealthy coastal British Columbiacommunities treat their sewage, while wealthyurban Victoria does not.

A number of people suggested that treatment isthe morally right thing to do no matter whatthe scientific community says; they do notperceive science to be entirely accurate or com-plete. As one person put it, there is no equa-tion that can capture the entire cost of pollu-tion from raw sewage to the environment.

Three people said that dilution, perhaps ap-propriate at one time in the past, is no longeradequate, given a larger and growing popula-tion, better knowledge about detrimentalenvironmental effects, and an increase in toxicnon-human wastes being flushed down sinksand toilets (for example, household and indus-trial cleaners) and off roadways.

Four submitters encouraged investigation intonew and emerging treatment technologies(transform biosolids into healthy compost,


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Scientific and Technical Review: CRD Core Area Liquid Waste Management Plan10

capture and use methane gas produced in di-gestion). One said the CRD should provideinformation on environmentally friendly toiletsand ways to deal with household grey water.

Four people said they were willing to payhigher taxes (one said considerably higher)for sewage treatment. One person urged actionnow, rather than in the future, when the costof clean-up will be too great.

Caution about investing in sewage

treatment

Three submitters cautioned against focusingon sewage when other discharges may be re-sponsible for greater environmental impacts.One favoured an objectives-based approach toeliminating environmental impacts, believingthat sewage treatment would be far down thelist of effective strategies. Further, this submit-ter felt federal and provincial funding wouldbe forthcoming for effective solutions on thecutting edge of alternative waste management.Another submitter said that the highly oxygen-ated water at the mouth of the outfalls in effectprovides very thorough primary treatment.2The third asserted that dilution works if it iscoupled with effective source control and up-

graded filtration and separation equipment.

2 Due, in the submitters words, to the exceptional currents and up to 4 daily tides churning the water at the mouths of the outfalls.


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Scientific and Technical Review: CRD Core Area Liquid Waste Management Plan 11

3

Synthesis of PanelsFindings

he Capital Regional District (CRD) isresponsible or the programs that manageliquid wastes in the Victoria area. o meetthese responsibilities, the CRD developed theCore Area Liquid Waste Management Plan

(LWMP), which was approved by the Brit-ish Columbia Ministry o the Environmentin March 2003 and is still in eect. he planmakes a number o speciic commitments toprotect human health and the environmentagainst adverse eects associated with liquidwastes, including the ollowing:

Control contaminant inputs at theirsource, or example, photographic shopsand dentist oices.

Develop and conduct a wastewater and

marine monitoring program to assess theenvironmental consequences o wastewa-ter discharged into the Strait o Juan deFuca.

Manage and control inlow and iniltra-tion o groundwater and/or surace waterinto the regions sewer system.

Develop a stormwater quality manage-ment program to minimize stormwater-related detrimental eects to humanhealth and the environment.1

Develop an environmental action pro-gram to remediate and protect Victoriaand Esquimalt Harbours.

Ensure that trucked liquid wastes (non-domestic and septage liquid wastes) are

handled and disposed o in an appropri-ate and responsible manner to protecthuman health and the environment.

Eliminate overlows o wastewater to the

environment.

reat and dispose o wastewater or areasserved by the municipal collection sys-tems.

reat and dispose o wastewater or areasnot served by the municipal collectionsystems.

CRD aces similar issues to those being ad-

dressed in other urban coastal communities inCanada that are responsible or the develop-ment, administration, operation, and man-agement o multiple liquid waste programs.CRD diers rom most other coastal commu-nities in North America in the level o waste-water treatment; virtually all other communi-ties provide a minimum o primary treatment,while the CRD only screens its wastewaterbeore it is discharged to the environment.Also, in a review o other coastal jurisdictions,only the CRD and the Greater Vancouver

Regional District (GVRD) were identiied asrelying on an environmental trigger process asthe basis or wastewater treatment decisions.

1 Stormwaters are the ows that collect on suraces (or example, roads, parking lots, and agricultural areas) and then go intoditches and drains leading to streams and marine waters


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Liquid Waste Management

Plan

he Core Area LWMP provides a compre-

hensive management program or addressingall aspects o liquid waste management in theCRD, and the Panel commends the CRD orthe scope and magnitude o the plan. Resultso the recent independent audit2 indicate thatthe LWMP, or the most part, is being imple-mented successully. he Panel encourages theCRD to implement the recommendations inthat audit and to ensure that any uture com-mitments are SMAR (Speciic, Measurable,Achievable, Realistic, and Time-bound).

As part o the Panels scope o work, we re-viewed the eectiveness o the LWMP. Onekey inding is that, although adequate liquidwaste management policies are ormulated anddescribed in the LWMP, the CRD lacks the au-thority to properly implement and/or enorcesome o these policies. Any eective manage-ment plan not only must describe a programo action but also must award the necessaryauthority or its implementation.

he Panel oers these additional, speciic com-

ments regarding the LWMP: he Source Control Program is well de-veloped and represents the current stateo the science. he CRD should con-tinue to support and expand the program.However, the CRD should consider thatsuch programs are eective only or tar-geted contaminants and will only reducethe amount o selected contaminants dis-charged to the environment, not totallyeliminate them.

Some areas o the CRD have high inlowand iniltration lows into the sewer sys-tem. Reducing these lows is an importantcomponent o total sewerage manage-ment.

Like other jurisdictions, the CRD acesthe common dilemma o how to assess,prioritize, and manage stormwaters be-cause o their variability and potential or

adverse environmental eects. Becausestormwater discharges occur intermit-tently, the public health and environmen-tal risks oten are perceived as minimal. In

act, stormwater quality can be very poor;thereore, the risks to the public and tothe environment may be much greaterthan expected. While the CRD is respon-sible or stormwater quality management,it lacks the authority to enorce stormwa-ter bylaws.

he decision-making process in theCore Area LWMP related to the need orwastewater treatment is highly dependenton the trigger process, which the Panelhas reviewed in detail (see below). Funda-mentally, the Panel is not o the view thatthe sealoor trigger process will unctionas designed.

he CRD coordinates harbour envi-ronmental protection and improvementeorts with its partners, but it lacks theauthority to enorce related LWMP com-mitments. Given the extent and magni-tude o contamination in the harbours,and given their potential contributionto contaminant issues in the region, the

CRD should ocus additional attentionon coordination eorts, ensuring that thestressors are managed in relative priorityto the waterways they aect.

Although the CRD operates a programto inventory and manage trucked liquidwaste, it apparently lacks the authority toensure proper disposal o that waste.

With signiicant potential to contaminateland and near-shore environments andto expose humans to wastewater, sanitary

and combined sewer overlows deserveparticular attention rom the CRD.

he Panel challenges the CRD to move or-ward and manage the LWMP within an overalldesign that respects the watershed and consid-ers water to be an integrated resource withinour ecosystems. he Panel recommends thatthe management o liquid wastes should em-

2 Te Panels erms o Reerence required SEAC North America to identiy and contract a third party to conduct a compliancereview o the LWMP. Te audit is Appendix C o the Panels report.


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Section 3: Synthesis of Panels Findings 13

phasize the relationships between the variouscomponents o the LWMP, particularly when itcomes to coastal zone management.

CRD Environmental

Monitoring Program

Since the late 1980s, the CRD has been moni-toring the wastewater discharges, the suracewaters, and the communities o sealoor-dwell-ing organisms in the vicinity o the Cloverand Macaulay Point discharges. he marinemonitoring program is comprehensive and isdesigned to evaluate the eects o sewage in

the marine environment in and around thedischarge points. he breadth and scope othe program is impressive, and the Panel com-mends the CRD or their intent to incorporatethe best available science in the monitoringprogram. he existence o a voluntary, inde-pendent panel o experts, the Marine Moni-toring Advisory Group (MMAG), as advisersto the CRD is an important strength o theprogram; the Panel encourages their continuedinvolvement as well as adequate resourcing orthe MMAGs unction.

Fate and distribution

Approximately 130 megalitres o screened sew-age are discharged daily rom the combinedoutputs o Clover and Macaulay Points intothe marine environment o the Strait o Juande Fuca. he eluents contain a wide varietyo chemical and microbiological constituents,are rich in nutrients, and have, at times, beenshown to be toxic. Upon release at the outalls,

the constituents o the discharges disperse ac-cording to their physical and chemical proper-ties and the prevailing environmental condi-tions o the Strait. here is no doubt that theeluents are rapidly diluted and transportedaway rom the discharge location; however, wedo not have a complete understanding o theate and distribution o the eluents. hereis conclusive chemical, microbiological, andobservational evidence that, under certainenvironmental conditions, the diluted sewage

plumes or their constituents reach the oceanssurace.

Human health concerns

A great deal o uncertainty surrounds the hu-man health eects o sewage discharged bythe CRD into the Strait, with respect to bothbacterial contamination in water and chemicalcontamination in seaood. Anecdotal inorma-tion suggests that ew persons requent theareas in and around the discharge points, andthereore, human exposure and its related risksare limited. Despite the uncertainty and theperceived inrequency o exposure, data indi-cate that when the diluted plume (and there-ore bacteria) does come to the waters surace,persons exposed to the water are at increasedrisk or adverse health eects. his uncertaintyabout human health risk is due, in part, to thesampling regime and the choice o bacterialindicators. he Panel thereore recommendsreducing the uncertainly by increasing the re-quency o monitoring and by includingEntero-coccias a monitoring parameter. In addition,ish tissue monitoring and risk assessment isalso recommended, particularly or chemicalswith the potential to accumulate in animals

and move up the ood chain.

Environmental concerns

Overall, the CRDs program to evaluate theeects o sewage in marine environments isone o the more comprehensive programs be-ing implemented anywhere in the world. Likemany monitoring programs, it ocuses on thesealoor. Documented impacts on sealoororganisms and communities are restricted tothose areas immediately around the outalls.

Sediments and mussel tissues close to the out-alls relect the burden o discharged chemicals,speciically:

1) At Macaulay Point, community diversityis reduced and pollution-tolerant inver-tebrates dominate the sediment-dwellingorganisms.

2) At Clover Point, mussel tissue monitor-ing or chemical bioaccumulation showsthat levels o a number o substances (orexample, copper and lead) are elevated in


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mussels at the outall (and in some cases,at both the near-ield and ar-ield sta-tions), compared to the reerence stations.In terms o chemicals with the potential

to move up the ood chain (or example,persistent chemicals that are not brokendown in the environment and can getconcentrated in animals), polychlorinatedbiphenyl (PCB) concentrations show asmall increase near the outall, where con-centrations in mussel tissues were low, butthey are nearly double the concentrationsat the ar-ield stations. Polybrominateddiphenyl ether (PBDE) concentrationshave the widest ootprint in mussels tis-sues around the outall; levels at the out-

all and at both near-ield and ar-ieldmonitoring sites (out to 800 m) were el-evated, compared to the reerence station.Available ecological thresholds or screen-ing-level risk assessments or these chemi-cals indicate that observed tissue concen-trations are well below those shown tocause adverse eects. Although Victoriascontribution o persistent organic con-taminants is undoubtedly minor, the con-cern about these contaminants is height-ened in the local area because Orca whalesin the Georgia Basin have been identiiedas among the most contaminated ceta-ceans in the world.

However, because the present monitoring pro-gram is highly ocused on sealoor sediments,it overlooks some other key components othe marine ecological community. While theCRDs marine monitoring program is a com-prehensive one, given the eluent is untreatedand a higher degree o caution is merited, thereare numerous gaps:

direct toxicity o the eluent,

eect o the eluent on water-columndwelling organisms,

eect on the surace micro-layer,

monitoring o ar-ield eects,

predictive capability or estimating ateand distribution o the plumes,

suicient reerence sites to use or com-parison (additional sites are needed withincreased replication), and

potential eects and risks o persistent

organic contaminants through ood chaintranser.

he CRDs analytical monitoring programincludes a wide range o contaminants, butgiven the lack o signiicant sewage treatment,the Panel elt it prudent that the CRDs moni-toring program be more inclusive than similarprograms or other jurisdictions. he CRDhas recently added high-resolution analyseso persistent organics such as PCBs and PB-DEs; the Panel commends this approach and

believes it should continue. he Panel notedthat some o the traditional contaminantsare missing rom the monitoring program (orexample, chlorinated pesticides), and theiraddition should be considered. Additionally,the Panel appreciates the CRDs initiative tomonitor new compounds o concern, suchas pharmaceuticals and endocrine-disruptingcompounds,3 and urges them to include newcompounds in the program as appropriate.

Seafloor Trigger process

A triggering process incorporated in theCRD monitoring program and the CoreArea LWMP is intended to signal when un-acceptable biological consequences occur inthe sediments adjacent to the sewage outallsand to indicate when wastewater treatment isnecessary. Conceptually, the trigger process isbased on sound marine sediment and environ-mental monitoring principles, and the datacollected to date and their analyses have beenconsistent with these same sound scientiic

principles. However, the diiculties associatedwith designing and implementing a triggerprocess create considerable uncertainty aboutthe programs potential eectiveness to protectthe ecosystems near the CRD outalls. As de-signed, the magnitude o environmental eectsnecessary to indicate the need or treatmentand the time necessary to observe and conirm

3 Substances that cause adverse biological eects by interering with the endocrine system and disrupting the physiologic unction ohormones


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Section 3: Synthesis of Panels Findings 15

these environmental impacts seems lengthy.Further, the time speciied to implement re-medial actions as a result o observed adverseenvironmental eects is underestimated. Addi-

tional speciic concerns the Panel identiied inthe triggering process are these:

he Panel was concerned with the valid-ity o the mussel length and weight-at-ageendpoint as a sensitive and/or predictive(that is, time-responsive) tool.

he Panel elt that the use o musselreproductive development as an earlyindicator, as is currently done, is inap-propriate because the results cannot beinterpreted.

he selection and location o the siteswithin the compliance zone do not appro-priately account or the area inluencedby the eluent plume. I the plume is notuniormly distributed, requiring 4 o 8sites (100 m) in the compliance zone toexceed triggers may underestimate eectsto the receiving environment.

Reerence sites must be added and rep-lication must be increased in order toestablish reliable reerence conditions

and to improve the interpretation o themonitoring results.

Future Concerns

What will happen in the uture, with respectto population growth and emerging issues?Because o its desirability as a city, Victoriaspopulation will no doubt increase substantiallyin the uture. his increase will result in a con-

comitant increase in sewage load to the waste-water systems. Prudent planning that incorpo-rates the most current and accurate populationorecasts allows communities to prepare oruture needs. For public utilities, conservativeplanning is considered the best approach. Dueto the length o time required to plan, design,and implement essential public utilities, theuture literally begins tomorrow.

he Panel does not view reducing selected con-taminants through source control as a meansto signiicantly lower the annual discharge osuch chemicals in the long term. While some

sources can be eliminated and the chemicalconcentrations can be reduced, the increase inlows containing reduced concentrations gener-ated by new residents will likely carry nearlythe same annual mass o these chemicals to thedischarge sites. he Panel concludes that theenvironmental ootprint o the wastewaterdischarges will increase proportionately with anincrease in volume o discharged wastes. helocation o the release and the overall qualityo the wastewater will also aect the ootprint.Source control eorts will help reduce inputs

o certain contaminants, and these programsshould continue to be supported and expand-ed. However, adequate control o all poten-tially toxic wastewater constituents via sourcecontrol eorts is unlikely, and alternative ap-proaches must be considered. Wastewater dis-posal inherently creates public health and en-vironmental risks, and those risks increase withthe generation and disposal o more wastewaterresulting rom urban growth, particularly whenthe wastewater is not treated.

Emerging contaminants

A wide variety o emerging contaminants (orexample, endocrine-disrupting compounds)have been identiied in municipal wastewaters;however, the importance o many o the newersubstances rom an environmental risk perspec-tive remains unclear. hese chemicals havevarying physical, chemical, and toxicologicalproperties, making it extremely diicult to

characterize and/or generalize their ate, distri-bution, and eects in the environment, espe-cially as complex mixtures. Many o the emerg-ing chemicals will be diicult or impossible tocontrol in the current CRD collection systemi deemed necessary. he weight o evidencesuggests that untreated eluents will result inestrogenic responses in exposed organisms.4Chemicals that bind to sediments will

4 A biological response controlled through the estrogen receptor, or example, when male fsh develop emale characteristics such asegg development in male sex organs.


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Figure 3-1: Inputs to risk management decisions (adapted withpermission from Stahl et al. 2001, Risk Management: EcologicalRisk-Based Management, SETAC)

be bioavailable5 to local species and also to ma-rine ecosystems (through the ood chain). hemajority o emerging chemicals can be greatlyreduced or removed rom eluents with a

combination o sewage treatment processes andoxidation techniques. reatment o wastewatereluents reduces the risk o environmental im-pacts. However, treatment will produce sludgesthat must also be treated and managed.

To Treat or Not to Treat: A

Risk Management Decision

How to handle the disposal o wastewaterin the CRD now and in the uture is a risk

management decision that should involveinputs rom a variety o disciplines. he Panelprovides the CRD with scientiic, technologi-cal, and engineering perspectives, but otherimportant inputs include social and politicalconsiderations, economic concerns, and regula-tory drivers (see Figure 3-1). he CRD Scien-tiic and echnical Review Panel emphasizesthat the Panels advice must be viewed in thecontext o these other inputs.

he Panel expended considerable eort in ad-

dressing the to treat or not to treat question,as documented in this report. Scientiic riskconcerns, public values, and the prevailing reg-

ulatory climate argue or the CRD to improvethe overall quality o its discharged wastewater.Relying on the dilution and natural dispersionprocesses o the Strait o Juan de Fuca is not

a long-term answer to wastewater disposal,especially considering the growth predicted orthe CRD and adjacent communities that alsocontribute contaminant loads to the Strait andto Puget Sound.

Improvements to wastewater eluents could bemade using a variety o approaches that shouldinclude not only a continuation o existingprograms (or example, source control) butalso consideration o approaches not currentlyin eect, such as wastewater treatment. Ourreview o waste management and treatmenttechnologies ound a wide range o plausibleoptions with a range o post-treatment waste-water qualities. Human and environmentalhealth concerns should establish the minimumcriteria or wastewater quality that would beconsidered acceptable. he Panel suggests thatany decisions about liquid waste managementshould take into account the local watershedand its ecosystems. Speciic eorts should bemade to address the responsibility versus au-thority issues highlighted previously.

Inormation made available to the panel under-lies the notion that the populace o the CRD,the province o British Columbia, and Canada

support the concept o wastewaterquality improvement in the CRD. Inrecent years, the CRD has taken sig-niicant steps toward controlling risksto human health and the environmentin the Victoria area, and many o theprograms implemented to date rep-resent the state o the science. Future

improvements in wastewater handlingin the CRD no doubt will relect thiscutting-edge approach and will re-sult in signiicant reductions in risk tohuman health and the biologically richmarine environment in the Strait oJuan de Fuca.

5 Te degree to which a substance i s absorbed or becomes available at the site o physiological activity ater exposure; chemicals bindto environmental media in varying degrees or are present in dierent orms, thus altering their availability to organisms.


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Scientific and Technical Review: CRD Core Area Liquid Waste Management Plan 17

4.1

Review of Liquid WasteManagement Plan

The CRD has a series of liquid waste management programs

laid out in the Core Area LWMP. Evaluate the effectiveness of

these programs to manage risks associated with the CRDs

wastewater practices and provide recommendations on those

programs that may need to be reprioritized or restructured.

Introduction

The Capital Regional District (CRD) CoreArea Liquid Waste Management Plan (CRD2000) provides a thorough approach to manyaspects of liquid waste management in theCore Area, aiming to protect public health,

protect environmental health, and maintainand improve the aesthetic environment.

The Panel reviewed the major sections of theLiquid Waste Management Plan (LWMP), asdescribed in the following sections, but thereare some overarching comments from thePanel:

Where possible, future updates to theLWMP should establish goals and com-mitments that are SMART, meaningSpecific, Measurable, Achievable, Realis-

tic, and Time-Bound. While the LWMP is thorough and de-

tailed, CRDs ability to affect practicesdiffers greatly across the different aspectsof the LWMP. Of significant concern isthat the LWMP identifies several areasof program responsibilities without cor-

responding authority; the Panel believesthere is a weak system of power forprogram implementation in some cases.CRD can be most effective in managingthose elements which it controls mostdirectly; at a minimum, for those aspectswhere CRD shares responsibility with

other bodies, coordination among theparticipating bodies is key to effective-ness. In this regard, the Panel recom-mends that the watersheds making upthe region be managed by a common au-thority. Adequate management requirescoordination among the many aspects ofthe plan, and this would best be accom-plished by a common authority with anecosystem- and watershed-level perspec-tive.

A brief review and evaluation of the elementsof the LWMP follows, after which conclu-sions are provided.


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Core Area Liquid Waste

Management Plan

Source control

A source control program must consist ofseveral components, including point sourceidentification, enforcement of controls, sam-pling to confirm control, and disposal pro-grams for managing the material removed fromthe wastewater streams. The CRDs RegionalSource Control Program (RSCP) has a set ofgoals, including the following:

1) Point source identificationThe RSCPhas made an excellent effort at identifica-tion of various non-domestic wastes dis-

chargers. The Waste Discharge Permits,the Codes of Practice for 11commercial and institutionalsectors, and the letters of au-thorization provide a systemfor understanding variations inthe quantity and quality of thewastewater and imposing re-quirements for discharges fromparticular sources.

2) Enforcement of controlsEn-forcement through the SewerUse Bylaw by identificationas a Discharger Under Review(DUR) and the ability to issuetickets or file charges provide astrong deterrent and encourage-ment for waste discharge con-trol at the sources. The annual reports ofthe RSCP testify to what has been, gener-ally, an effective program with high levelsof compliance among affected businesses.

3) Sampling to confirm controlRandom

sampling without prior notification, incombination with the self-monitoringprogram, provides a comparative step toensure compliance. Also, the key access-hole monitoring program aids in the loca-tion and identification of other pollutionsources.

4) Disposal programsThe disposal of thematerial separated from the wastewaterflow is the last of the steps to make a

source control program work. Reportkeeping and tracking disposal practicesare critical to the program and must con-tinue to be important enforcement steps.

This program has developed very well andis making a difference in the quality of thedischarges to the receiving environment. TheRSCP has been effective and should be con-tinued, but because it cannot be applied tohouseholds, it cannot fully address all issuesin the management of wastewater in theCRD. Also, source control only reduces theamount of selected contaminants dischargedinto the environment; it does not eliminatethem. Many organic and inorganic, hydro-philic, and hydrophobic materials will not beeliminated by source control activities.

Inflow and infiltration control

The CRD has been pursuing an aggressive in-flow and infiltration (I&I) evaluation programwhich has produced some very enlighteningresults. The ratio of peak wet-weather flow to

average dry-weather flow in the sewers is anindication of the degree of I&I experienced.A ratio that exceeds 4.5 indicates that I&I is aconcern (July 2005 Core Area Inflow and In-filtration Program). Table 4.1-1 indicates thatthis ratio is often greatly exceeded in the CRDsewers.

The areas of Colwood, Oak Bay, and Victoriahave very high ratios, indicating a serious needfor significant I&I corrective action. Also, notethat at some locations, there were suspected


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Section 4.1: Review of Liquid Waste Management Plan 19

upstream overflows (where the sewer capacity

was exceeded) which were not accounted for in

the analysis. The reduction of high I&I flows is

a very important sewerage management effort

that will influence any wastewater treatmentplant design and that must continue.

Also, the portion of the inflow coming from

the environment controls of large buildings,

like cooling and other intermittent or continu-

ous-flow units, should be identified. The water

from these units is usually clean and does not

require wastewater treatment, and it should be

diverted elsewhere.

Another important source of inflow is the pen-etrations in the access-hole covers. Depending

on the topography of the area around an access

hole, water may flow through access holes and

run into the sewerage. In locations with large

or long rain events, this can be a major source

of inflow. Sewer inspection and monitoring

through camera systems help to identify seri-

ous infiltration locations. A sewer repair and

replacement program will reduce the magni-

tude of the I&I problem.

In summary, some areas of the CRD have

high inflow and infiltration flows into the

sewer system; reducing these flows is import-

ant to sewerage management. An ongoing,

prioritized sewer repair and replacement

program will reduce the magnitude of the

I&I problem.

Wastewater and marine assessment

The CRDs program for wastewater and ma-rine assessment at Macaulay and Clover Pointoutfalls consists of

the trigger process (which includes sea-floor monitoring),

effluent monitoring and analysis,

surface water monitoring and analysis forhuman health risk, and

water column investigations.

The LWMPs goals for this component of theprogram are largely based on implementa-tion of the trigger process and a monitoringprogram. The reader is referred to the Panelsdetailed review of both these aspects (Sections

4.2 and 4.3). In that review, the Panel foundthat the monitoring work being conductedis generally sound and consistent with bestpractice in other jurisdictions. The issuesthat the Panel identified (see Sections 4.2and 4.3) relate to how the monitoring toolsare being used, rather than to issues with thetools themselves. The Panel concurs that anongoing annual monitoring program is appro-priate and that one-time investigations shouldbe used to fill in information gaps, as needed,

in consultation with the Marine MonitoringAdvisory Group. The Panel is very supportiveof a rotating review (every 6 years) of the mar-ine monitoring aspects of the LWMP, provid-ing it is adequately resourced and can bring inindependent specialists.

The trigger process described in the LWMP in-cludes a step (if warning levels are exceeded)

for source identification andtrends analysis to aid in thedetermination of the mostappropriate course of ac-tion. If warning levels wereexceeded, the first step wouldbe to identify the chemicalsof concern and their sources.In real life, this would likelybe very difficult to achieve,particularly in the indicated3-month time period. Again,this speaks to the issue ofhow the monitoring tools are

Table 4.1-1: Ratios of peak wet-weather to average

dry-weather flows in sewersArea Ratio (PWWF / ADWF) Flow-weighted average

Colwood 4.3 to 9.8 8.0

Oak Bay 13.8 to 34.5 19.0

Saanich 3.1 to 14.5 4.9

Victoria 5.6 to 22.0 9.9

View Royal 3.3 to 5.3 4.7

PWWF = peak wastewater flow

ADWF = average dry-weather flow


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applied for decision-making, as opposed to thetools themselves.

An early warning process for surface water lev-els of indicator bacteria is under development,

but it was not available for review by the Panel.

Stormwater

Background

Stormwater issues involve both quantity andquality. With regard to quantity, several factorsmust be accounted for in the analysis, such asthe types of storms, the pattern of the storms,and soil or surface characteristics. With regardto quality, precipitation events can flush a

number of contaminants through drainage sys-tems and into marine and other environments.The range of contaminants in stormwater isastounding (Makepeace et al. 1995; Novotny2003). Each element of a flow event will have adifferent effect on stormwater quality. The pe-riod identified as the first flush may contain amajor portion of the washed-off contaminants.Because the composition of stormwater de-pends so much on the rate and volume of flowof previous rain events and the length of dryperiods, it is important that sampling programs

intended to assess stormwater draw from adetailed series of data that will characterize thebreadth of its variation.

Stormwater monitoring

The Panels review of data collected for storm-water monitoring by the CRD identified sev-eral issues:

The stormwater monitoring programmeasures fecal coliforms in stormwaterusing an extensive program, which is ap-

propriate. However, for beaches that aremoderately to highly used by the publicand that are under the influence of storm-waters, enterococci should be the mea-surement of choice and is recommendedby Canadian authorities (see discussion inSection 4.2).

The stormwater monitoring programmeasures sediment quality in the storm-water system, as opposed to the stormwa-ter itself (which is appropriate for priori-

tization but which is not representative ofthe stormwaters contaminant concentra-tions and form).

At nearly a third of the access holes used

for sampling (10 out of 33), no sedimentswere present for sampling. This is to beexpected because properly designed accessholes should result in little or no sedimentaccumulation. However, the lack of sedi-ment results in an inability to characterizethe stormwater.

Sediments contain only materials with adensitysize relationship that allows themto settle in the hydrodynamic environ-ment of the access hole. Finally, only aportion of the water column materialsthat preferentially attach to sediments (forexample, depending on speciation andthe adsorption relationships between thesolids and the water column).

The ecological consequences of thestormwater discharges to the harbourdo not appear to have been evaluated,particularly in context of other stressors(for example, contaminated harbour sedi-ments, habitat alteration).

In summary, while the CRDs existing storm-water monitoring approach does have merit, itshould be augmented with

1) collection of enterococci data in marineareas frequented by humans,

2) monitoring that describes stormwaterquality and quantity with respect tochemical contaminants (this is likely toinvolve automated time-series samplingover various stormwater scenarios, per-haps initially for high-priority stormwaterdischarges), and

3) consideration of assessing the ecologicaleffects of stormwater, in context with oth-er stressors and overall harbour quality.

Stormwater infrastructure

The common problem of cross-connectioncontrol requires attention in the Core Area. Atsome locations, sanitary wastewater pipes maybe connected into the stormwater sewers. Thissituation leads to contamination of stormwa-


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ter that would otherwise have been relativelyclean. Such cross-connection sources can oftenbe detected by elevated fecal coliform valuesin the low-flow condition in the stormwater

sewer. Other cross-connection situations in-volve quantity and/or quality variations whichcan be identified only through collection andanalysis of data.

It is also important that the CRD has a geore-ferenced inventory of the stormwater system,in relation to other major utilities and the envi-ronment, the stormwater outfall capacities, andtheir discharge characteristics. Realizing that alltypes of wastes deposited in the drainage areaof each outfall will make their way to the dis-

charge point, it is important to ensure that thelocation of each discharge point is compatiblewith public health and environmental protec-tion objectives. The discharge rating systemused by the CRD (Drinnan 1997) allows clas-sification of discharges based on public healthand environmental concerns. The rating sys-tem incorporates fecal coliform and sedimentmetals along with flushing and human use esti-mates for determining the need for monitoringand mitigative measures. As in any rankingapproach, the importance of individual factors

may be missed. The 2005 report by Cameronand Green addresses the magnitude of the ef-fort to understand and initiate corrective mea-sures where concerns were identified.

Stormwater management

Based on the information the Panel reviewed,the CRDs approach to stormwater has evolvedpositively over time. The CRD is committed toworking in partnership with the municipalitiesand other stakeholders to address stormwater

issues, and significant progress has been made.The Panel understands that the CRD is facingthe same dilemma as other jurisdictions: howto assess, prioritize, and manage stormwaters,given their variability and potential for effects.Perhaps the most significant challenge theCRD faces is that it appears to have responsi-bility for stormwater, while at the same time itdoes not have authority to regulate stormwater.In addition, the LMWP identifies that ad-ditional statutory powers may be required by

municipalities and regional districts to imple-ment stormwater strategies.

The LWMP Audit (Appendix C) highlightedthis issue, stating It appears that only one

municipality out of 7 has adopted the CRDmodel stormwater quality bylaw, while anothermunicipality reported that it is before their ad-ministration for review. Barriers to implemen-tation seem to include:

modification of the bylaw to reflect thenew Riparian Areas regulations;

varying priorities between the involvedparties; and

the increase in workload that would resultfrom bylaw implementation and enforce-

ment.The CRD recognizes that revisions to reflectthe Riparian Areas regulations are required andis in the process of revising the bylaw.

The CRD is responsible for stormwater, butonly the municipal authorities appear to havethe authority to enforce stormwater bylaws.Watershed management plans seem to be ap-proved at a political level. The Panel poses thequestion to the CRD about whether theireffectiveness in delivering on their commit-

ments in the LWMP is hindered by presentinstitutional arrangements.

Also of particular importance is the CRDscommitment to provide input and informationon stormwater quality to the harbours envi-ronmental enhancement and marine assess-ment programs. It was difficult for the Panel toassess the CRDs effectiveness in meeting thiscommitment. If no mechanism exists amongthe various stakeholders in the Victoria andEsquimalt Harbours Environmental Action

Program (VEHEAP) to consider the humanand ecological effects of stormwater relative toother stressors (for example, habitat changes,existing seabed sediment contamination,food chain effects of contamination), thenthis should be remedied. The CRD shouldconsider expanding on their commitmentto provide input and information to theharbours environmental enhancement andmarine assessment programs. This is in viewof one of the CRDs stated goals (see Box


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1) to practice integrated coastal manage-ment. Integrated assessment can be achievedonly by drawing information and practitionerstogether to discuss how to achieve the optimal

environmental quality for the agreed wateruses and for the effort and monies expended(see also next section on the CRDs Harboursprogram).

The Panels view is that ongoing stormwatermonitoring and management by the CRDneeds to remain a high priority (coordinatedwith other harbour environmental pro-grams), regardless of any decision taken bythe CRD on treatment of wastewater.

Harbours environmental action

The CRDs Harbours Environmental Actionprogram is implemented through a multi-party organization called the Victoria andEsquimalt Harbours Environmental ActionProgram (VEHEAP). The CRD coordinates

harbour environmental protection and im-provement efforts among the VEHEAP part-ners, within a memorandum of understanding(MOU) signed in 1994 by

Capital Regional District,

Ministry of Environment,

Department of National Defence,

Environment Canada,

Fisheries and Oceans Canada,

Transport Canada, and

Public Works & Government ServicesCanada.

The CRD has shown leadership in its role withVEHEAP, and the fundamental principles of

the program are sound. The EnvironmentalManagement Strategy (VEHEAP 1999) estab-lishes a sensible purpose and clear goals andobjectives. In 2004, based on feedback from aprogram review, VEHEAP shifted to an area-based structure with different initiatives invarious waterways.

The VEHEAP experience demonstrates thatre-focusing efforts to work with multi-stake-holder groups that are largely community-driven is an effective approach to watershed

and harbour management. CRD itself appearsto be very active in implementation of this ap-proach, as do a number of the partners, as evi-denced by the Panels review of various docu-ments and meeting minutes; however, it is notclear to what extent the partners in VEHEAPembrace the concept of integrated coastal zonemanagement in assessing and protecting thehealth of the harbours.

Similar to the finding of the LWMP auditreport (Appendix C), the Panel finds that the

CRDs involvement in VEHEAP is only aseffective as the real commitments of the VE-HEAP partners. The CRD has a responsibilitybut no authority to address the issue if a VE-HEAP member does not live up to the com-mitments made in the VEHEAP MOU. Forexample, stormwater clearly has a strong influ-ence on harbour quality, but it is the primaryresponsibility of the municipalities. Seabedsediments also influence the environmentalhealth of the harbours, but the harbour floor islargely owned and managed by federal depart-ments (Department of National Defence, Pub-lic Works and Transport Canada). Significantstudies are underway and will be reporting in2006 and 2007, and the Panel encourages theCRD to aid in sharing and integrating findingsinto watershed-level planning.

While good work is being done, it may bethat a higher level of resourcing and action isneeded to integrate that work at an ecosystemor watershed level and to achieve a net benefit


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to the health of Victoria, Esquimalt, and otherharbours. Any decision by the CRD or othermembers of VEHEAP to go beyond the statusquo with respect to the harbours action pro-

gram should be taken in view of relative priori-ties, in a watershed or ecosystem context. ThePanels review of CRDs documents did notshed light on whether the various stakeholdershave agreed goals for protection for the har-bours, which would harmonize and prioritizetheir various activities.

The Panel recommends that the CRDs Storm-water, Harbours and Watersheds program,in conjunction with VEHEAPmembers and other CRD pro-grams, should consider therelative priority of differentenvironmental stressors in theirwork to improve environmentalquality (not only with respect toharbours but also with respectto stormwater runoff to theharbour). The goals for protec-tion for the harbours shouldbe clearly stated and agreedin terms of the measurementsbeing made and interpreted by

the various stakeholders (forexample, benthic communityhealth, food chain transfer ofcontaminants, stormwater quality, habitatquality, sediment toxicity).

Trucked liquid waste

The CRD has initiated and progressed effi-ciently with a program to inventory and man-age liquid, non-domestic wastes which must betrucked to a suitable treatment and/or disposallocation (Earth Tech [Canada] 2002: Beauche-min and Rahman 2003). Rough estimatesindicate that about 25 ML of trucked liquidwastes (TLW) are generated annually in theCRD, with 85% as oily material, 11% as en-gine coolants, and the remaining 4% from oth-er commercial sectors. The food industry pro-duces about 1.3 ML per year, of which about60% is collected and 0.36 ML per year is TLW.The overall program appears to be working to

protect the environment and reduce contami-nant loadings going to wastewater treatment.

More effort is needed to insure proper disposalof the TLW and the wastes from catchbasins

and oil-water separators (Earth Tech 2002).The CRD does not have the needed regulatoryauthority to reduce problems and improve themanagement of the TLW system (Beaucheminand Rahman 2003). The CRD has a programto inventory and manage trucked liquidwaste but does not have the authority to en-sure its proper disposal.

Wastewater overflows

Overflows of wastewater to the environmentoccur periodically at several locations in theCRD and municipal systems (CRD 2000).The overflows occur primarily because waste-water flow exceeds system capacity duringheavy rainfall, or because mechanical or electri-cal systems fail. As a source, overflows can re-sult in the greatest contamination of land and

near-shore environments, resulting in exposureof both humans and important ecological sys-tems to contaminants.

Based on the January 2004 summary preparedby the CRD, 21 overflow facilities exist in theDistrict, and the LWMP (CRD 2000) presentsa table of receiving environment sensitivities,mitigation, and action plans for some of theoverflows. It appears that limited sampling hasbeen done on these sources, and no treatment


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has been implemented. Reduction of I&I up-stream would help in reducing the contamina-tion of nearshore areas. One of the greatestpotential sources for contamination of land

and nearshore environments and human ex-posure to wastewater is from overflows.

As for other liquid waste issues, the Panel rec-ognizes that the municipalities are responsiblefor some of the overflows. Both the CRD andthe municipalities should continue with theirpolicies to design or replace trunk sewers, re-ducing overflows, on a prioritized basis.

Treatment and disposal in areas

served by municipal collection

systemsIn the LWMP, the Capital Regional Districtcommits to

use the trigger process to determine, inadvance, when the health of the receivingenvironment in the vicinity of the Ma-caulay Point and Clover Point outfalls isthreatened and additional source controlmeasures or additional wastewater treat-ment is required;

acquire land at Clover Point and Macau-

lay Point to hold in reserve for provisionof treatment, subject to the agreement ofthe owners to sell the land; and

commence a process for the acquisitionof land for sludge processing when a deci-sion is made to proceed with treatment.

The decision-making process in the CoreArea LWMP related to the need for waste-water treatment is highly dependent on thetrigger process, which the Panel has reviewedthe seafloor trigger in detail (see Section 4.3).

Fundamentally, the Panel is not of the viewthat the seafloor trigger process will function asdesigned. Also, in our review of LWMP prac-tices for other jurisdictions, the Panel found(Section 4.8), that only one other jurisdictionuses a trigger process in this manner. Guidanceon preparing LWMPs from the BC Ministry ofEnvironment (MOE, undated) discusses howwastewater treatment can be implemented instages, taking into account the assimilative ca-pacity of the receiving environment, the ability

to finance the upgraded sewage facilities, andpublic input to the waste management plan-ning process. This perspective dovetails withthe Panels independent view (see Section 4.9),

that a decision on wastewater treatment needsto take into account more than technical andscientific factors (as suggested by the CRDsLWMP). The fact that the trigger process isfundamentally a scientifictechnical inputinto decision-making, and may be flawed(based on the Panels analysis, Section 4.3),highlights the Panels concern that the trig-ger process should not be the sole mecha-nism to determine the need for wastewatertreatment. The CRD has a substantial andwell-designed annual monitoring program

that should also be used as the basis for deci-sion-making.

It is instructive to review, in principle, the deci-sion process that is generally used for most ju-risdictions. The goals of wastewater treatmentand disposal are, generally,

1) protection of public health,

2) protection of environmental health, and

3) maintenance and improvement of the aes-thetic environment.

All 3 goals require evaluation of existingknowledge, both locally developed and fromthe international scientific community. A greatdeal of the data collection and modeling thatis needed to evaluate the need for wastewatertreatment (WWT) before discharge, as prac-ticed in the CRD, has been undertaken. Thisdatabase underlines 3 principal elements ofsuch a program:

1) The collection of a scientifically completeand sound data set is very complicated

and expensive in time and personnel.

2) It is wise to tap into the results of themany published works that focused onmany of the details of wastewater treat-ment and wastewater disposal in the ma-rine environment.

3) It is very difficult to develop the detaileddatabase required to verify a dynamic hy-drotechnical and contaminant transportmodel in a complex marine environment.


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These factors, in combination with publicvalues and legislative or regulatory initiativesby many governments, have resulted in many

communities deciding to return water to the

environment at a quality similar to that usedby humans. If the CRD were to take the deci-sion to treat their wastewater, the final decision

as to the quality required and the challenges tobe met by the treatment facility would have tobe carefully investigated.

The location of a plant or series of WWTplants requires careful consideration of the de-

gree of treatment and the space required, andthe time period for its operation. In the latter

case, the time should be very long in a practi-cal sense (100 to 200 years). Also, it wouldmake sense to plan for the likely eventuality

that higher effluent quality standards will beimposed in the future. Thus, the capacity and

space for potential future treatment improve-ments should be planned for. Third, the quali-

ty of life in Western society is highly influencedby the availability of water to the individual,so retaining this service must be a high priority

of all communities. Water conservation effortswill impact water consumption, and as a result,

wastewater strength characteristics. Also, re-ducing inflow and infiltration will reduce flow

to the WWTP during and after storm events.

As recognized in the Core Area LWMP, sludgecollection, treatment, and disposal are criti-

cal components of the wastewater treatmentprocess. There will not be uncontrolled losses

to the environment because the majority ofthe contaminants will be consolidated into the

sludge and treated or disposed safely, and theliquid from the sludge will be returned to thewastewater treatment plant (WWTP).

All of the above lead to the need for totalsystem management; the Core Area LWMP

addresses these issues and is in need of ad-justments in only a few areas. In the Panelsview, the LWMPs decision-making process

related to the need for wastewater treatmentshould be revisited.

Treatment and disposal in areas

not served by municipal colle

set acc rd final report

Documents