Sunday, August 18, 2013

Dr. Gerald Graham's Sewage Treatment Expertise

Part of Dr. Gerald Graham's interest in the Victoria sewage treatment issue stems from his involvement over twenty years ago in the World Bank's Urban Environment Project in Banjul, the capital of The Gambia. Dr. Graham participated in two short-term consulting missions to this West African coastal country, which at the time was flushing raw, untreated sewage into, among other places, the Tourist Development Zone on the outskirts of the capital.

The Urban Environment Project included a component to install sewage pipes throughout the capital, as well as a facility to treat the sewage so that it would no longer end up on the beaches, tourism being one of the country's principal sources of economic activity.

Dr. Graham participated in the feasibility study phase of this World Bank-financed Gambian initiative.

It is Dr. Graham's fervent hope that his adopted city of Victoria, British Columbia, Canada, which also depends heavily upon tourism, will now follow the lead of this poor West African nation and treat its sewage.

To be fair, at least we have sewage pipes that collect our sewage before dumping it into the sea. In the case of The Gambia, most of the downtown area at least had open trenches where raw sewage collected.

In 2006 Dr. Graham was commissioned to write a report entitled "Is Victoria Sewage Contaminating Southern Resident Killer Whales?", which was submitted to the SETAC panel tasked with reviewing the issue of Victoria sewage.

In 2012 Dr. Graham was part of a team representing the pro-treatment side in a public forum on sewage treatment that took place in Oak Bay, a suburb of Victoria.

In 2013 Dr. Graham made a presentation on sewage treatment before the Capital Regional District Board in Victoria.

Dr. Graham has a keen personal interest in sewage treatment as well. In both Ottawa and Central Saanich, for instance, he and his wife toured the local sewage treatment plants, to get a better feel for what sewage looks and smells like, to see how it is treated and what the end product is. This first hand exposure to sewage treatment is more than can be said for most of the opponents of sewage treatment in Victoria, who probably have never set foot inside such a facility, even though one exists right in their own backyard, so to speak.

Finally, Dr. Graham has visited the site of the proposed secondary treatment facility at McLoughlin Pt. in Esquimalt.

Why I'm In Favour of Sewage Treatment for Victoria

People often ask me: “Why are you in favour of sewage treatment?” or “What have you got against the current practice of dumping raw, untreated sewage into the ocean?” Here’s my answer.

Let me preface my remarks by saying that my position on sewage treatment is not, contrary to what supporters of the current liquid waste management practice would like to think, based on emotional or moral grounds. Rather, my position is based purely on scientific and technical grounds. The fact of the matter is that the current system we have for disposing of sewage, consisting of screening and pumping it out into the ocean via outfall pipes and diffusers, has too many risks associated with it.

We can’t completely control what goes into the system. Source control works to some extent, but we don’t really know what people put down their toilets and drains. The same goes for businesses. For these reasons, the SETAC Victoria sewage panel reminded us in their 2006 report that the best way to control what gets into the ocean is to treat sewage before it gets there.

Nor do we really know for sure what really happens to the sewage once it leaves the outfall pipes. The presumption is that the cold, fast-moving waters of the Strait break the human waste down and disperse it. But, microbiologist Ed Ishiguro claims the waters are too cold to break excrement down. Also, where does all that sewage really go? Where do all the chemicals go, for instance? Do they just get deposited on the seafloor or are they dispersed in marine waters far from the outfall pipes? If the latter, surely that is not a good thing over time. Just think of the mercury, for instance, which could eventually bioaccumulate in fish and whales.

A strong case can be made that we’re also creating a toxic cocktail. Does anyone really know for sure what the impact is of mixing all those contaminants, drugs and bacteria together?

In short, the current liquid waste management practice is not a closed system. In fact, from a purely management perspective, it is more like a leaky boat. Basically, too many things have to go right for those in favour of the current practice to be right when they say that the existing practice is harmless. For instance, the source control system has to be effective; local waters in the vicinity of the outfall pipe have to break the sewage down and diffuse it; the contaminants that end up on the seabed in the vicinity of the outfall pipes can’t be having a significant adverse impact, etc. The real problem is that supporters of the current system only have to be wrong on one of their assumptions for the system to be proved unsafe or unworkable, or both.

Opponents of sewage treatment like to have it both ways. They decry the dangers of piping tons of toxic sludge via a pipeline from McLoughlin Pt. to Hartland landfill, and yet refuse to acknowledge that absent treatment, all that sludge is being dumped into the ocean right now, 24 hours a day, seven days a week, 365 days a year. How logical is that, I ask?

In effect, what we’re doing here in Victoria is conducting a gigantic, long-term experiment with respect to our sewage. We’re saying, we don’t think it does any harm, or at least we’re hoping it doesn’t, but in any case we’ll monitor the situation, and if we’re wrong and it does prove harmful, then we’ll treat it! The problem with this approach is that by the time you find out the system is causing harm, it’s too late: the lead time to design, build and operate a treatment plant is about seven years.

As for the aforementioned SETAC report, what it basically concluded was that while there was not much evidence of environmental harm or risk to human health at present, the inherent inadequacy of any source control program, the threat posed by emerging chemicals, and the region’s demographic trends all combined to make the current liquid waste management system unsustainable in the long-term. Now, while that may not sound like a ringing endorsement of the need for sewage treatment for Victoria, we would be unwise to ignore the warning of these experts. And to those critics who say the SETAC report was never peer-reviewed, these people miss the point entirely: the SETAC report, which scoured over two hundred scientific and technical reports in the course of their work, was itself a peer review!

For all these reasons, I say, let’s stop playing Russian roulette with nature. Let’s stop dumping raw, untreated sewage into an area where fish swim, windsurfers surf and killer whales roam freely. Instead, let’s do the prudent thing and treat our sewage, now, before it’s too late. Not in 2040, but now, in our lifetimes.

Is it going to cost a lot? Well, like most things, it depends on how you look at it. Victoria has had a free ride for years, and if we had gone to treatment years ago, as we probably would have but for the fact that our local MP, the Environment Minister at the time, was and is a staunch opponent of sewage treatment for Victoria, it would undoubtedly have cost a lot less. And the longer we wait, the more expensive it is going to become. If we do it now it might cost the average household around $365 per year. So, as Victoria’s Mayor Fortin recently pointed out, a family of four has unlimited access to the toilet for $1 per household per day, or 25 cents each. That sounds like a pretty good deal, don’t you think? What the heck are people complaining about, I ask?

In short, let’s just suck it up and get on with it, shall we?

Wednesday, August 14, 2013

Transcript of Sewage Treatment Presentation to Capital Regional District Board

NB A Video Version of this Presentation Is Available on YouTube

Thank you. My name is Dr. Gerald Graham, and I am a strong supporter of sewage treatment. An independent review of the CRD’s current treatment plan, as proposed in this Motion, would undo years of effort and cast doubt on the region’s ability to meet the 2020 federal secondary treatment deadline. Failure to meet that deadline has serious legal implications. Trashing the plan also jeopardises half a billion dollars in infrastructure grants.

Environment Canada can’t be “lobbied” to relax the new requirements for the CRD. You’ve been told that no exemptions or extensions are possible. And to suggest that there is an “open marine waters” clause in the rules which will exempt the CRD from treatment is fanciful: the CRD’s wastewater application already describes the receiving environment as “open marine waters”, with no impact on the region’s ultimate “high risk” classification.

The CRD could have been prosecuted years ago for pumping raw, untreated sewage into the sea, in violation of the federal Fisheries Act. If it becomes clear that the 2020 wastewater effluent deadline will not be met, what is to prevent the authorities from taking you to court before then?

Opponents of treatment euphemistically describe our current disposal practice as “natural, marine-based sewage treatment”, in contrast to the proposed “artificial, land-based sewage treatment”, as if some higher power had laid down our two outfall pipes and all that human waste just sort of found its way into them. Let’s get real: you either treat your sewage on land, or you dispose of it into the sea. We choose the latter, Dickensian-style appraoch.

In my 2006 submission to the SETAC Victoria sewage panel, I cited a possible link between contaminants in our sewage and contaminants in local killer whales- the world’s most contaminated marine mammals. Toxins found in orcas, such as PCBs, are also found in Victoria’s sewage, much of which flows into Haro Strait- critical habitat for the orcas.

A recent court case confirmed that under the Species at Risk Act Ottawa must act to protect critical habitat for endangered orcas- a listed species. Admittedly, raw sewage is not the only threat to the orcas, or even the main one. But, as the SETAC report states “…the argument can be made that, where we can control bioaccumulative compounds (such as PCBs) through practical means, we should do so” (Pp. 38, 39). This echoes a point I made in my submission to the panel.

A precautionary approach means treating our sewage now- not in 2030 or 2040, by which time the orcas, a veritable icon of the Pacific Northwest and big contributor to the local economy, could be extinct.

For all these reasons I urge you to reject the Motion at hand.

Thank you!

Wednesday, June 12, 2013

Links to Active Worldocean Consulting Web Sites

This blog is no longer active, mainly because it does not easily support tables, graphs, etc. Please visit the Worldocean Consulting Ltd web site as well as Worldocean Consulting's web site for a comprehensive selection of Gerald Graham's postings and publications, past and present.

Saturday, February 23, 2013

Enbridge Northern Gateway Tanker Spill Risk Calculations Discussed during Questioning Phase of Final Hearings

During Enbridge Northern Gateway Joint Review Panel cross examination February 22, 2013, MP Nathan Cullen had a rather lengthy exchange with the Applicant about the way they present tanker spill risks in their Application. The relevant exchange takes place between lines 14356 and 14414 [Adobe pp. 119-124] in this transcript .

In the course of his cross examination, Mr. Cullen specifically mentioned Dr. Gerald Graham’s calculation of between an 8.7 and 14.1% chance of a spill greater than 31,500 barrels occurring. He also asked Enbridge Northern Gateway why, when calculating the chances of tanker spills occurring, they don't use ITOPF's classification system for tanker spills. Interestingly enough, Enbridge Northern Gateway itself cites the ITOPF system in its own evidence filed with the JRP, on Page 4-3 [Adobe P. 13] of this document: Section 3.8: Casualty Data Survey, TERMPOL Surveys and Studies, April 30, 2010 as follows:

"Another indicator of oil tanker performance is the number of oil spills recorded by the International Tanker Owners Pollution Federation Ltd (ITOPF). ITOPF records oil spill data in the following three categories:

• Small spills less than 7 tonnes (≈10 m3).

• Medium spills of 7 to 700 tonnes (≈10 to 1,000 m3).

• Large spills greater than 700 tonnes."

Not surprisingly, Enbridge Northern Gateway’s responses to Mr. Cullen's enquiries were somewhat inconclusive. However, Mr. Cullen deserves credit for raising these issues before the Panel, and getting them on the official record.

If any Enbridge Northern Gateway Intervenor wishes to take this a step further, when the Applicant is cross examined in the course of the Shipping and Navigation Witness Panel ( which is expected to convene March 18, 2013 ) they could be asked, via an Undertaking, perhaps, to formally present their tanker spill risk calculations in terms of barrels ( the Application, for instance, refers to a pipeline with a capacity of 525,000 barrels per day- not 83,468.3298 m3! ) and probabilities, and to classify spill sizes the way ITOPF does. And even if they balk at these suggestions, if enough Intervenors raise the same issue, the Joint Review Panel itself might feel inclined or compelled to require Enbridge Northern Gateway to do so, under an Information Request, for instance.

Friday, February 15, 2013

Musings on Tanker Risks

The Enbridge Northern Gateway tanker project Marine Quantitative Risk Analysis (QRA) calculations are based on tanker casualties ( that's the lingo! ) over the course of X number of decades past. As the mutual fund ads warn, "past performance is no guarantee of future returns". Furthermore, NGP has already argued that because tanker safety has improved dramatically and steadily over the course of the past two decades, taking the average figure skews the results negatively against their project. In other words, they think their safety performance will be better than the predicted outcome. They have also argued that because the historical stats are global in nature, they reflect ( poor ) performance in parts of the world where standards are less rigorous than in countries such as Canada- in the areas of inspection and enforcement, for instance. For this reason as well, then, they would argue that the Canadian performance in future can be expected to be better than the world average in the past.

One of the problems with each of these caveats is that there is an unwritten assumption that things always improve, or are at least maintained at their current level. Deepwater Horizon taught us that this is not necessarily so. It's not exactly a straight line up- industry pressure, fierce competition, cost-cutting measures, etc. could lead to a relaxation of tanker standards and/or of enforcement, as well as a reduction in response capability. Also, Black Swan-type events have to be anticipated. Complacency can also set in after years without a 'catastrophic' tanker incident, leading, for instance, to a reduction in response capacity. Enbridge Northern Gateway has also argued that if oil is going to be transported by sea ( and on a worldwide basis the bulk of it is! ), then it's better to do it in Canada than in countries where laws and safety standards are not as strictly enforced. That's small consolation for the coastal communities of northern and central BC, I should think.

Another argument has been made ( by, among others, a retired provincial oil spill expert who happens to be working for one of the NGOs in opposition to NGP ), that if it’s a choice of transporting oil on either the north coast of BC or the south coast, then better to go north, because the tankers will generally speaking be bigger ( VLCCs, for example ), the theory being that bigger tankers means less transits, which translates into less risk. Of course, the counterargument to this is that bigger tankers means potentially more oil spilled in any given incident. In other words, that knife cuts both ways.

Wednesday, February 13, 2013

Turning the Tables on Northern Gateway

The best way to deep six the Enbridge Northern Gateway project currently undergoing federal environmental assessment is to focus on Table 8-8 of the Marine Shipping Quantitative Risk Analysis filed by Enbridge as part of its application currently before the NEB and CEAA. Within that Table there is one mitigated risk statistic that is so damning that it could stop the project in its tracks. That statistic claims that the return period for a spill greater than 5000 cubic metres is 550 years. Sounds innocuous enough- right? Not so fast, Buckwheat! Leaving aside the question as to what on earth a ‘return period’ is, it turns out that the statistic in question translates into somewhere between an 8.7 and 14.1% chance of one or more spills greater than 31,500 barrels of oil occurring over the fifty year lifespan of the project. If the pipeline capacity is 525,000 barrels per day, then the chance is 8.7%. If, on the other hand, as one suspects, the pipeline will instead be built to its maximum, expanded capacity of 850,000 barrels per day from the outset, then 14.1% is the magic number. Now, Enbridge does not classify tanker spills according to whether they are small, medium or large. However, the International Tanker Owners Pollution Federation (ITOPF) does, for statistical purposes, and it is noteworthy that they classify a large spill as being anything over 700 tonnes, or approximately 5131 barrels. In other words, by international standards a 31,500 barrel spill is a large spill indeed- roughly six times larger, in fact, than ITOPF's threshold for what constitutes a large spill. And with up to a 14.1% chance of at least one spill of this magnitude occurring from a Northern Gateway tanker, this project is little more than a game of Russian Roulette.

Why, one might ask, is this particular statistic so important? The answer is because the Joint Review Panel’s recommendation as to whether Northern Gateway should proceed is likely to turn on risk; all other considerations, however important they may be, are secondary. Also, as the saying goes, a chain is only as strong as its weakest link. Thus, if it can be shown that one of three components of the project- the marine transportation component ( the other two being the pipeline and the marine terminal ), is too risky, then standard environmental practice dictates that the project should not proceed. To be more precise, if a proposed project could have significant adverse environmental effects, then it should not move forward- period, whatever the anticipated benefits! And who would doubt that a marine oil spill somewhere within the Project Area involving 31,500 barrels of oil could have significant adverse environmental effects? A spill of that magnitude could actually have catastrophic and irreversible effects, especially if it were to occur during the winter, say, in the middle of Hecate Strait, when cleanup would be next to impossible most of the time, and where wind and waves could whip the oil around, impacting hundreds if not thousands of miles of coastline in the aftermath of an incident.

Thus, a winning strategy for those opposed to the project on environmental grounds would be to cross-examine Enbridge on this particular point during the Questioning phase of the Hearings currently underway in Prince Rupert. The beauty of this approach is that it does not require the introduction of new evidence on the part of Intervenors in opposition to Northern Gateway. On the contrary, it relies on Northern Gateway’s own evidence, merely showing it in a different light. And for the record, the author has already drawn this particular risk calculation to the Joint Review Panel’s attention, first in his August 28, 2012 Letter of Comment, and more recently in his January 7, 2013 Oral Statement to the Panel in the course of the Community Hearings in Victoria. Furthermore, at least two other people who made Oral Statements at the Community Hearings quoted this statistic from the author’s Victoria presentation, one in Vancouver and one in Kelowna. But not only is the Panel fully aware of this statistic; the proponent itself had one or more representatives present at the Community Hearings.

So, anyone who does challenge Northern Gateway on this risk calculation during cross-examination in Prince Rupert is free to cite the statistical calculation the author came up with through persistent digging. If you do mention it, feel free to cite this Letter of Comment, as well as this Oral Statement. If the Panel itself had any credibility, it would have already asked Northern Gateway for its views on this statistical interpretation, just as it has on other points and statistics raised during the Hearings. Northern Gateway should be asked, for example, whether they consider a 14.1% chance of what by any standards would be a major oil spill occurring as a result of tanker shipments represents an acceptable level of risk, from their standpoint. And the Panel itself has little choice but to pass judgment on the same statistical probability in its Final Report, due by the end of 2013. Ditto for the Government of Canada, which will make the ultimate decision as to whether this project should proceed, unless of course the proponent itself sees the light and walks away from it, approval or no approval.

Lastly, Intervenors in opposition to Northern Gateway should get the Panel to require the Applicant to calculate the chances of spills for each of ITOPF's three spill size categories:

-Small spills less than 7 tonnes (≈10 m3);

-Medium spills of 7 to 700 tonnes (≈10 to 1,000 m3);

-Large spills greater than 700 tonnes.

For the record, the author's recent critique of the Enbridge Northern Gateway proposal is the subject of several press articles, including these two in particular:

1) “Tankers too risky on B.C.’s North Coast, oil-spill consultant says”, Larry Pynn, Vancouver Sun, January 12, 2013;

2) “A significant risk”, Leslie Campbell, Focus, February, 2013, pp. 4,5.

Saturday, January 19, 2013

Dr. Gerald Graham's Letter of Comment to Enbridge Northern Gateway Project Joint Review Panel

Enbridge Northern Gateway's characterization of the risks of tanker spills associated with the marine transportation component of its project are so opaque that it begs the question as to whether a deliberate attempt is being made to conceal the true risks from the general public.

In the Marine Shipping Quantitative Risk Analysis ( QRA ) Enbridge submitted in support of its application for approval, terminology is used that even a highly educated lay person would find hard to understand. Thus, the QRA talks of “return periods” for spills, rather than probabilities, chances or odds. Similarly, it measures the amounts of oil potentially spilled in cubic meters ( m3 ) rather than barrels, which is the way most people think of oil spills, if they ever do think of them.

A case in point is Enbridge’s calculations for a “major” or “extremely large” spill which they define as a tanker spill of 40,000 m3 or greater ( >40,000 m3 ). The company estimates the return period for this category of spill, with return period basically defined as the period within which one can expect at least one such spill to occur, at roughly 15,000 years.

Applying a formula for converting return periods into probabilities that was developed by Professor Shane Rollans, a Mathematics professor, for Mr. Kelly Marsh, and relying on calculations that were made, using that formula, by Professor Shane Rollans and Dr. Tom Haslam-Jones, a tanker spill of >40,000 m3 with a return period of 15,000 years translates, in layman’s terms, into a .3% chance of at least one spill greater than c. 252,000 barrels occurring over the fifty year lifespan of the project. So, not much chance of that happening, if Northern Gateway’s estimates are accurate. For the record, that's about the same size spill as the Exxon Valdez incident in Alaska in 1989.

But the risks are significantly higher for some of the other spill ranges for which Enbridge provides calculations; for instance, spills <5000 m3, and spills >5000 m3. The estimated return periods for these types of spill are 570 and 550 years respectively. Put these into layman’s terms, and there is a 10.0% chance that at least one spill under 31,500 barrels will occur, plus an 8.7 % chance of at least one spill over 31,500 barrels. All told, there is an 18.1% chance that at least one spill of any size will occur.

Moreover, if the pipeline is expanded from the outset to 850,000 barrels per day capacity, as Enbridge has indicated it could be, up from the 525,000 barrels per day capacity that the company is currently applying for, then, et ceteris paribus, the chances that at least one spill <31,500 barrels and at least one spill >31,500 barrels will occur increase by sixty two percent each- to 16.2% and 14.1% respectively. That's as much as a one in six chance of at least one potentially significant size spill occurring. Plus, at that higher throughput, the chance of at least one spill of any size occurring rises to 29.3%.

This will seem like an acceptable level of risk to some observers, while others will view the marine transportation component of the project as little more than a crapshoot. At the very least, it undermines Enbridge's assertion that a tanker spill is "...very unlikely to occur", and a similar assertion by the President and CEO of the Pacific Pilotage Authority that the chances of such a spill are "...extremely small". And now, thanks to the work of Shane Rollans, Kelly Marsh, Tom Haslam-Jones and myself, a lay person should be in a better position to visualize these risks, before making an informed decision as to whether the project should go ahead. Because if the Joint Review Panel currently reviewing the application had only one factor it could consider in making a go/no go decision vis a vis this project, that factor would undoubtedly be risk; everything else is secondary.

Gerald Graham, Ph. D