Environmental Science & Engineering - www.esemag.com - November 2003
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Proposed federal ammonia regulations cause CWWA concern

By George Powell, P.Eng.,
Senior Vice President,
CH2M HILL


On June 7, 2003, Environment Canada published in the Canada Gazette, a notice requiring the Preparation and Implementation of Pollution Prevention Plans for Ammonia Dissolved in Water, Inorganic Chloramines and Chlorinated Wastewater Effluents. This notice has created considerable reaction across Canada in those municipalities discharging 5,000 m3/d or more of sewage effluent to surface water. There will be many municipalities for which this requirement has a very significant price tag, estimated by the Canadian Water and Wastewater Association (CWWA) to be in excess of $5 billion.

Most of us in the wastewater profession welcome legislation that protects public health and the environment. As an example, the requirement to reduce the total residual chlorine in wastewater effluents is broadly supported since chlorine is a persistent substance that bio-accumulates in the environment, and there is scientific evidence that it is harmful. And it is recognized that disinfection is required to protect water supplies and the recreational use of our waterways in Canada.

Many in the profession, however, find it difficult to support the announced requirement to reduce ammonia nitrogen to 16 mg/L or less at any time during the period of June 1, 2004 to September 30, 2004.

Ammonia does not bio-accumulate in the aquatic environment; on the contrary, it dissipates rapidly. Ammonia cannot be controlled by P2 planning since the major source is domestic wastewater and not industrial discharges. Further, runoff from agricultural land is also a significant contributor, and would not be controlled by this regulation.

This is not to say there are not specific cases where ammonia controls would be effective, such as discharges to sensitive receiving waters where ammonia would impact the dissolved oxygen and aquatic life in the receiver. In these specific cases ammonia removal to prevent dissolved oxygen depletion and toxic levels that impact the aquatic environment are most definitely required, and have been implemented in locations such as Guelph and Kemptville, Ontario. The Fisheries Act and provincial water quality objectives already protect against these circumstances.

There are, however, many large wastewater facilities discharging to lakes and large rivers where ammonia discharges have never been observed to be a problem. These include the large secondary treatment facilities in the Greater Toronto Area, in Hamilton, in Winnipeg, Edmonton and Vancouver. To my knowledge, fish kills have not been a problem reported in these areas despite the fact ammonia levels are higher than the proposed limits.

Prior to the Gazette announcement in June, Environment Canada held consultation sessions in 13 centres across Canada in 2002. While this process was intended to inform stakeholders and to receive feedback, Environment Canada has not in my opinion acknowledged nor reflected the concerns expressed at these meetings.

Under the Canadian Environmental Protection Act the federal government has the right to become involved in municipal systems. Such involvement is most welcome when it is constructive; however, the continued downloading of all matters of governance on municipalities without treating them as equal partners has been a continuing political problem. Most municipalities are not aware of any justification for the specific ammonia controls being mandated for their discharges, and question such a blanket regulation. It is the one shoe fits all approach that is primarily at issue with Environment Canada's present proposal.

At a meeting with the Canadian Water and Wastewater Association in July, the federal government alluded to other initiatives in the federal “Grand Plan” but could not, or would not, share with the major stakeholders present where they were going. Without a well-defined and agreed plan, how can municipalities properly plan for what is going or coming down the pipe under future regulations to be announced by Environment Canada? Clarification of federal and provincial roles and responsibilities is needed. Municipalities would like to have one gatekeeper and consistent policies.

Sustainable environmental policies are built by involving stakeholders in a meaningful way to develop proper understanding and consensus on the path forward. Environmental policy should be based on knowledge and consensus; however, to date Environment Canada has not provided the needed information nor scientific basis to justify the conclusions and policy they have announced. The CWWA estimates the cost of this program at $5.1 billion – to date Environment Canada has not been able to identify any social, environmental or economic benefit that will result.

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