Open Letter to CRD Board: Strike a task force to address CRD's first annual report on biosolids treatment failures
The Capital Regional District’s (CRD’s) just released first annual report on disposal of biosolids outlines:
Multiple failures of the new Residuals Treatment Plant’s ability to produce Class A biosolids,
CRD’s failure to safely dispose of the toxic biosolids in a way not posing harm to ecosystems,
That CRD has been either landfilling or spreading these toxic biosolids at Hartland immediately adjacent to Mount Work Park and Durrance Lake,
That of the 2220 tons produced in 2021 that did meet the standard for Class A biosolids, just 631 tons, or less than 30% was shipped to Lafarge, and
That the remaining 1589 tons were spread at Hartland–more than double the maximum amount that the public was assured would be spread at the Landfill site, not to mention the 5000 tons that had to be buried.
Hugh Stephens, of Mount Work Coalition, pens an open letter to Colin Plant, CRD Board, in response the troubling CRD report.
February 6, 2022
Dear Colin Plant
It was almost 2 years ago, March 13, 2020, to be exact, when you generously offered a meeting between yourself, CAO Bob Lapham and me to listen to concerns that I had expressed on behalf of the Mount Work Coalition regarding the CRD's sudden change of plans with regard to disposal of biosolids. In February 2020, without any warning or public consultation, the CRD Board reversed its policy of not allowing the spreading of biosolids in the Region, a policy adopted in 2011 and reaffirmed in 2013. The reason given was that the provincial Ministry of the Environment had informed the CRD that a "beneficial use" was required for any biosolids not shipped to the Lafarge Cement Plant in Richmond for use as fuel in the cement making process.
When the CRD reached agreement with Lafarge to take the Class A biosolid output from the Residual Treatment Facility that was to be built at Hartland, I believe there was an understanding that Lafarge would close for approximately 6 weeks a year for annual maintenance. The original plan was to store or landfill the biosolids during that down period. However, having just learned of the requirement for a so-called beneficial use even during the period when Lafarge was closed, CRD staff proposed to spread the biosolids at Hartland during that shut-down period. The Board accepted this proposal. When we met you indicated that you regretted that there had not been opportunity for public engagement, but the Board was presented with a difficult choice and limited land application in the confined environment of Hartland seemed like the best alternative. In any event, this solution was "interim and temporary", and would apply only to the relatively short period of time when Lafarge was closed for maintenance. I, and the public, were told that no more than ten percent of the annual production of 7000 tons of Class A biosolids would be spread at Hartland, i.e. about 700 tons per year.
The Mount Work Coalition and a number of other groups were, and are, opposed to the land application of biosolids for several good reasons, including concerns related to downstream water contamination, contamination of aquifers, potential airborne contamination and the long-term impact of the presence of the "forever chemicals" present even in Class A biosolids. This concern is particularly acute because of the close proximity of heavily used recreational areas such as Durrance Lake and Mount Work, neighbouring farms and residential areas, an elementary school and a major tourist attraction that provides many jobs in the area. We are also concerned because the Organic Matter Recycling Regulations (OMRR), which govern the classification of biosolids, have not been updated since 2002. Since then, much more has become known about the residual toxic elements contained in biosolids despite having been produced to "Class A" standards. Finally, we are particularly concerned with land application of heavy concentrations of toxic biosolids in a very limited area such as the active surface of Hartland. Repeated application in such a small area invalidates many of the studies that purport to show that carefully supervised, "limited" application of biosolids can be done safely. Repeated applications in a small area less than 500 metres from a major regional park is, frankly, irresponsible and a violation of undertakings given to the public.
If we were concerned two years ago over the planned land application, the experience of the past year has validated and heightened that concern. The CRD's first annual report regarding the disposal of biosolids has just been released, and the results raise major concerns that you should be aware of. In the event that you or other members of the Board have not yet had a chance to peruse it, let me give you the highlights. In 2021, the new Regional Treatment Facility produced 7261 tons of biosolids, although just 2220 met the Province's Class A standard. In other words, this multi-million dollar facility did not work most of the time as just 30% of the product met the required standard. The other 5041 tons were landfilled at Hartland. CRD staff use the excuse of "commissioning problems" to explain this but the plant has been in operation for over a year now and this excuse is becoming somewhat threadbare. There was a failure of the digester in the summer but even in the last months of this year, some of the production did not meet Class A standards. For example, seventeen percent of December's production, or 64 tons, failed to meet Class A standards. Of the 2220 tons produced in 2021 that did meet the standard, just 631 tons, or less than 30% was shipped to Lafarge. The remaining 1589 tons were spread at Hartland. This is more than double the maximum amount that the public was assured would be spread at the Landfill site, not to mention the 5000 tons that had to be buried. There was never public licence for this activity, but the first year's results indicate an even more serious breaking of faith with the public.
It is clear that Plan A (producing Class A solids and shipping them to Lafarge) is not working, and there doesn't seem to be a feasible Plan B. Meanwhile day after day, more biosolids (Class A or not) continue to be produced at the RTF and have to be disposed of somewhere and somehow. Repeated assurances by staff that they "are working on it" and blaming "commissioning problems" is becoming less and less credible. It is clear that a total rethink is required. In this regard I am pleased to learn that the CRD will cooperate with Esquimalt with regard to their pilot gasification project to determine if a clean, safe, non-polluting technical solution can be found for disposal of the region's biosolids. Beyond that, other measures need to be taken. Hartland cannot remain the dumping ground for thousands of tons of the region's semi-processed sewage residue annually.
The CRD needs to strike a task force to address this situation urgently, including getting a dispensation from the Province to cease land application of the biosolids on the limited surface space of Hartland. New thinking needs to be brought into the equation and solutions such as gasification must be explored as a priority.
The December biosolid report, which shows the annual total, is attached. (Access report here)
I look forward to seeing what action the Board intends to take to remedy this serious policy and technical failure.
Sincerely,
Hugh Stephens
Mount Work Coalition