Are You Ready For The Proposed Fisheries Act “Wastewater Systems Effluent Regulations”?
1. A Review of the CCME’s Canada-wide Strategy for the Management of Municipal Wastewater Effluent and the Fisheries Act Regulations Tony Van Rossum, City of London Barry Kobryn, City of Calgary Wastewater And Stormwater Committee, CWWA Webinar May 05, 2010
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4. Relationship between CCME Strategy and Fisheries Act Regulations Based on2007 Draft Strategy For Illustration Only Some FA Reg. pathways and relationships different Ammonia “ Rest of Strategy” Fisheries Act Regulation
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8. Requirements Vary with Size, cont. Acute Lethality Testing (s8) 4(2) The averages referred to in paragraphs (1)( a) to ( c) and the maximum referred to in paragraph (1)( d) must be determined on a quarterly or monthly basis, as follows: ( a) quarterly, if the annual average daily volume of effluent deposited via the final discharge point during the previous year — namely, the year that ends at the beginning of the quarter — was less than or equal to 17 500 m3; and Averaging Period for CBOD and SS and “compliance review”
9. Requirements Vary with Size, cont. Schedule 3: System of Points – Final Discharge Point There may be more… read carefully.
Will focus on the FA Regs, as we are into the final stretch to influence these.
Could dispense with this slide.
The second exception is interesting. This and the lack of specification on “municipal” facilities in the regulations would seem to mean they could apply to private systems.
The underlying flow chart summarizes the CCME Strategy, as presented in 2007. Some of the details have changed, but is still useful for illustration. The four major perspectives, represented by the green diamonds, remain the same.
Deal with proposed Fisheries Act First. The proposed regulations are written in legalese. The legal way of enforcing the NPS under the Fisheries Act is to make the NPS substances deleterious – in any amount – and they also specify ammonia as a deleterious substance . Then they authorize discharges which are not acutely toxic and which meet the NPS and add a limit to meet for ammonia. So, the pathway for dealing with toxicity has changed, with its diamond moving above an expanded NPS diamond [use pointer]
Tony: The green line is the one which was in the proposed regulatory framework in 2007 and is still in Tech Supp 2 of the Strategy. The blue line is the 1.25 mg/L un-ionized ammonia at at 15°C ± 1°C converted to total ammonia-N vs. pH.
Note that “general authorization” is our term, not FA Regs’.
Even you are in complete compliance and don’t need to apply for an authorization, there are still other requirements such as the identification report, monitoring, reporting, etc. described later.
Tony: Not having CSOs, I haven’t focused on this yet. Have you figured this out yet?
Tony: Not having CSOs, I haven’t focused on this yet. Have you figured this out yet?
Potentially a very big item which will take longer to prepare than the 45 days allowed.
Gets worse in areas with more water.
More detailed look.
There are likely many more problems with the regulations than being presented here, but these are perhaps the biggest.
So, timelines need a lot of work
Tony: The first bullet may be a little out of synch, but where do we draw the lines w.r.t describing problems? Maybe you just want to talk about the previous slide as the biggest problem and then use the last tow bullets on this one.