pollutant threshold industry consultation

DEDICATED TO PROVIDING SERVICE EXCELLENCE: QUALITY DRINKING WATER - WASTEWATER TREATMENT - STORMWATER MANAGEMENT

Environmental Monitoring and Protection Business Operations Management

Toronto Water

Thursday May 29, 2014 Stakeholder Group: Environmental Groups/NGOs

Stakeholder Consultation: Proposed Pollution Prevention (P2) and

Sewers By-law Changes

WELCOME


• Overview – Environmental Monitoring and Protection Unit (EM&P) – Toronto’s Sewers By-law & Biosolids Management – Pollution Prevention (P2) Program

• Proposed P2 / Sewers By-law Changes • Next Steps • Discussion

Agenda


Sewers Bylaw Compliance & Monitoring (Industrial & Commercial)

Technical Advice (Road Salt)

Transportation

All Divisions

Training

Public Outreach

Enforcement (Courts)

Pollution Prevention Program

Monitoring Toronto Beaches, Special Monitoring Projects

Backflow Prevention Program

(Water Supply Bylaw)

Environmental Monitoring

& Protection Spills/Complaints

Block 2 Industrial Water Rate Program

(Compliance End)

Staff Reports to Committees

Outfall Monitoring Program

-Day to Day Core Activities

- Required

Manage & Create Agreements/ Permits under

Sewers Bylaw: •Industrial Waste Surcharge •Sanitary Discharge


• 48 FTEs - Management, Program Staff, Provincial Offences Officers

• Sewers & Water Supply By-laws

• Compliance & Enforcement • 2 Key Groups:

1. Industrial Waste Control Group 2. Stormwater Quality Group

Environmental Monitoring and Protection (EM&P)


• Monitor industrial discharges & on-site P2 Plan

• Inspect for backflow prevention devices

• Respond to water pollution complaints, industrial-commercial spills

• Enforce Sewers & Water Supply Bylaws

• 15 areas within the City

EM&P – Industrial Waste Control Group


• Outfall Monitoring Program • Monitor storm outfall discharges; find cross

connections and correct/eliminate • 6 Tributary Watersheds and Lake Ontario • Perform dye testing & sampling • work to stopping illicit discharges to storm

sewers

• Beach & Water Quality Monitoring • Assist TPH with Beaches Program

• Special Stormwater Projects i.e. Inner Harbour Surface Water Monitoring Road Salt Study Don River Environmental Assessment

EM&P – Stormwater Quality Group

From 2006-2012, 634 cross connections

identified and 592 corrected


• Provincial Legislation – Ontario Environmental Protection Act – Ontario Water Resources Act

• Legal Instruments: Certificate of Approvals & Environmental Certificate of Approvals

• Federal Legislation − Fisheries Act *City responsible for discharge entering its storm sewer system and discharging into surface water

• Penalties: fines up to Millions $ and/or jail

Relevant Legislation


Sewers By-law

Sewers By-law sets limits on heavy metals, biochemical oxygen demand (BOD), total phosphorus, total suspended solids (TSS), total kjeldahl nitrogen (TKN), oil & grease and toxic organic compounds in wastewater discharge to sanitary and storm sewers.

Municipal Code Chapter 681

Sewers enacted in 2000

Protect aquatic

environment

Ensure the health & safety of City staff &

public

Protect sewer infrastructure

from obstruction and deterioration

due to harmful discharges

To meet legislative & regulatory

requirements

To control biosolids quality

Protect wastewater treatment

plant operations


Sewage Biosolids

• 2002: Biosolids incineration ceased at the Ashbridges Bay Wastewater Treatment Plant.

• 2009: City Council adopted the Biosolids Master Plan for the City’s WWTPs with “Beneficial Use Option” as primary biosolids management strategy.

• Biosolids for land application provide an economic benefit in addition to their environmental advantages. – Nutrient and soil conditioning benefits to farms – Reuse of key resources such as Phosphorous & Nitrogen – Costs $250/tonne to incinerate compared to $85/tonne to recycle biosolids


MOE regulations on biosolids for land application All municipalities must meet the

requirements for land application of biosolids under the Nutrient Management Act (NMA).

Based on these biosolids quality requirements,

• Sewer Bylaw created a list of Subject Sectors & 38 Subject Pollutants and newly added Hexavalent Chromium • Heavy Metal Subject Pollutants match those of the biosolids regulated by MOE

11 Regulated Metals Under NMA (2002)

Arsenic Mercury

Cadmium Molybdenum

Cobalt Nickel

Chromium Lead

Copper Selenium

Zinc


Pollution Prevention (P2) Program • Pollution Prevention (P2) Program introduced through the Sewers By-law

in July 2000 – first municipality in Canada to include mandatory reporting of P2 planning in Bylaw – P2 Plan submissions every six years with P2 Update submissions in the second and

fourth year on 38 subject pollutants present in effluent discharged from property

• Best Management Practices (BMP) was introduced to certain commercial sectors due to lack of technical expertise, similar operating practices and equipment set up and use of similar products in those sectors – automotive repair, vehicle wash and fueling stations (2005) – photo finishing (2007) – BMP focuses on operations to minimize pollutants rather than products, which they

have no control over


P2 Program Successes (Appendix B of PW27.8 Staff Report)

• Metal concentration decline in wastewater with 5 of the 11 tested heavy metals showing an appreciable downward trend – average results of the remaining 6 heavy metals were below the by-law limits

• Declining concentration of pollutants in industrial wastewater, including industrial facilities, metal finishers and hospitals

• Manufacturers reformulated products to eliminate or reduce subject pollutants so that Toronto customers could comply with P2 – many facilities became exempt from P2 Planning by eliminating the use of subject

pollutants

• Amalgam separators installed for all affected dental offices – drop in mercury concentration in wastewater treatment plants’ influent and sludge

in 2002 with continual decline – 40-70% reduction of mercury in the biosolids during initial P2 Program years


0.35

0.25 0.22

0.24 0.21

0.30

0.20

0.25

0

0.05

0.1

0.15

0.2

0.25

0.3

0.35

0.4

0.45

0.5

2005 2006 2007 2008 2009 2010 2011 2012

Mer

cury

Con

cent

ratio

n (u

g/L)

Highland Creek Treatment Plant Average Influent Mercury Concentrations from 2005-2012


20.26

15.06 13.79 14.26

11.20 8.90 8.66

6.42

0

5

10

15

20

25

2005 2006 2007 2008 2009 2010 2011 2012

Mer

cury

Con

cent

ratio

n (u

g/L)

Highland Creek Treatment Plant Average Dewatering Sludge Mercury Concentrations from 2005-2012


P2 Program Successes (Appendix B of PW27.8 Staff Report)

• Requirement for installation of silver-recovery units in photofinishing operations

• 35% of Printers are now exempt from P2 submissions due to eliminating/modifying subject pollutants

• Elimination of cleaners containing nonylphenol ethoxylates (NPEs) by Canadian Association of Textile Colourists and Chemists (CATCC) and Canadian Petroleum Products Institute (CPPI) – 89% of textile facilities have complied with P2 reporting requirement

• Reduction of NPEs in the Industrial Laundry sector by over 60,000 kg annually as a result of NPE elimination by detergent manufacturers

• Elimination of 8,000 kg per year of NPEs by Lester B. Pearson International airport from the de-icing fluid through product substitution


P2 Program Recent Changes In December 2013, City Council adopted the ‘Sewers By-law Pollution Prevention Program (P2) and Hexavalent Chromium Stakeholder Update Report’ PW27.8: • Instead of P2 Update submissions in the second and fourth year after a

P2 Plan is initially submitted; only one P2 Update is required by the end of the third year after an initial P2 Plan submission – more in line with three and six year targets of P2 Plan – came into effect January 1, 2014

• Hexavalent Chromium has been added as the 39th subject pollutant – every industry which discharges Hexavalent Chromium has until

Dec. 31, 2014 to amend its latest plan to include hexavalent chromium and must thereafter include it in all plans until no longer discharged


P2 Program Proposed Changes In December 2013, City Council directed City staff to undertake consultations in 2014 regarding the proposed changes to the Pollution Prevention (P2) Program and subsequent Sewers By-law, Municipal Code Chapter 681. These changes include:

• changes to the dental office submission requirement; • changes to the grease interceptor requirement; • creation of a Best Management Practice (BMP) for the automotive

refinishing sector; • creation of a Best Management Practice (BMP) for mobile washing

business operations; and • creation of a subject pollutant threshold reporting list.


Dental Office Submission Requirement Currently dental owners: – submit a P2 Plan every six years – submit a P2 Update to the City by the end of the third year from the date

of the initial P2 Plan submission – install and properly maintain dental amalgam separator(s)

Proposed Changes: – dental owners will be required to submit a P2 Plan only ONCE followed by

annual submission of proof of maintenance of the amalgam separator

Benefits: – reduced P2 Plan submissions, thereby reducing administration on the part

of the dentist and City staff resources – ensure amalgam separators are properly maintained, thereby reducing

levels of mercury entering the sewer


Grease Interceptors Currently restaurants/food premise owners: – shall take all necessary measures to ensure that oil and grease are

prevented from entering the sewer (vague for enforcement) – shall install and properly maintain a grease interceptor

Proposed Changes: – restaurant/food premise owners will be required to follow a Code of

Practice based on the CSA Standard B481 Series-12 Grease Interceptors, which includes maintenance, size, location and other preventative measures identified by the City

Benefits: – ensure grease interceptors are properly installed/maintained to reduce oil

& grease entering the sewer; protect public health & environment – reduced sewer back-ups and water infrastructure remediation


BMP for Automotive Refinishing Sector Currently automotive refinishing businesses: – submit a P2 Plan every six years – submit a P2 Update to the City by the end of the third year from the date

of the P2 Plan submission

Proposed Changes: – automotive refinishing businesses will be required to comply with the

newly created Best Management Practices (BMP) – submit a declaration form confirming compliance with BMP

Benefits: – reduced P2 Plan submissions, thereby using City staff resources efficiently

& meaningfully and reducing administration for the sector – ensure compliance with BMP to keep pollutants from being discharged into

the sewer, thereby protecting water quality – promote good housekeeping techniques & P2 practices


BMP for Mobile Washing Business Operations Currently mobile washing business operations: – have no specific requirements other than to comply with the Sewers Bylaw

Proposed Changes: – mobile washing business operations will be required to comply with a

newly created Best Management Practices (BMP) – submit a declaration form confirming compliance with BMP

Benefits: – ensure compliance with BMP to keep pollutants from being discharged into

the storm sewer, thereby protecting water quality and the environment


Subject Pollutant Threshold Reporting List Currently industrial, commercial and institutional facilities: – are required to submit a detailed six-year plan to the City that

identifies operations or activities of an owner or operator of commercial, institutional or industrial premises identifying specific pollution prevention methods (under § 681-5)

– must identify pollution prevention methods, which may include product substitution, product reduction, operational modifications, equipment upgrade or wastewater treatment

– are required to submit a P2 Update to the City by the end of the third year from the date that a P2 Plan was required to be submitted

– must include in the P2 Plan and P2 Update any amount of a subject pollutant present in the effluent discharged from a property

NEW 2014


Subject Pollutant Threshold Reporting List Proposed Change: – creating a subject pollutant threshold reporting list, which would

include the minimum level of a subject pollutant that requires a P2 Plan and subsequent P2 Update submission

P2 Program Goals: – minimize subject pollutants from entering the sewer – make industry aware of their operations through the reporting

process and identify methods to reduce/eliminate subject pollutants

A subject pollutant threshold reporting list will not affect P2 Program goals as it will only eliminate the reporting of trace amounts

• E.g.. Total Chromium of 0.004 mg/L found naturally when washing broccoli at a food premise


Threshold Reporting List Benefits By creating a subject pollutant threshold reporting list:

– the City can eliminate the requirement of industries to report trace amounts of subject pollutants discharged, thereby allocating its resources on more problematic subject pollutants, industries, sectors etc…

– some industries that are required to prepare a P2 Plan may not have to submit a P2 Plan for the subject pollutants that are below the proposed thresholds ,thereby allocating their resources on problematic subject pollutants present in the effluent discharged from their property

– in line with ChemTRAC and MPRI threshold approaches

Note: these threshold changes will not impact those sectors that are on a Best Management Practice (BMP), such as dental offices and dry cleaners.


• May/June 2014 – Stakeholder Consultations oIndustry Associations oConsultants oFood/Grocery Franchises oEnvironmental Groups / NGOs

• June 2014 – On Line and/or Paper Surveys to Individual Businesses/Operators

• Late 2014 – Follow up Stakeholder Consultations with Draft Proposals

• 2015 – Staff Report to PW&I Committee

Next Steps

13


Discussion: 1. Do you think that the current requirement to prepare

a P2 Plan for any amount of a subject pollutant is reasonable?

2. Do you see benefits with setting a baseline concentration for P2 planning requirements?

3. We would like to hear from you and appreciate your feedback on what type of threshold to set.

4. Do you have any comments/suggestions regarding any other of the proposed changes?


Please submit your comments & feedback by June 30, 2014

Contact: Mae Lee City of Toronto

Public Consultation Unit Email: [email protected]

Tel: 416-392-3787 Fax: 416-392-2974 TTY: 416-338-0889

mailto:[email protected]

mailto:[email protected]

pollutant threshold industry consultation

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