Comment
We have very significant concerns regarding Dwayne Wilson's proposal (ERO 019-6708).
This is Dwayne Wilson's second attempt to get this proposal approved. The first attempt (ERO 019-3689) from 2021 was withdrawn by Mr. Wilson. Only when a decision is made (in this case a withdrawal by the applicant) could comments be posted for this original proposal on the ERO website. There were 26 posted comments from neighbours and concerned citizens against this type of activity and none were in favour of it. Upon researching this type of proposal, this is a significantly high number of comments. No one living in the area wants this. When the original proposal from 2021 was withdrawn the community breathed a sigh of relief speculating that Mr. Wilson had come to his senses and realized that this is not a good idea. Clearly we were wrong and now we are in a "here we go again" scenario. This is a vacant property and Mr. Wilson conveniently lives nowhere near it. Dumping of raw septage will not affect Mr. Wilson's residence but will negatively affect many area property owners and devalue their properties.
With the current proposal, the area he is proposing is slightly smaller (14.5 acres originally to about 11 acres currently). We have attached a map that outlines Mr. Wilson's property and it clearly shows that the Government No. 1 drain runs through the back side of it. Our property has this drain running through it and it is directly downstream from Mr. Wilson's property. If this proposed spreading occurs anywhere near this drain, there is the potential to contaminate it. The rain levels in recent years in this direct area were extremely high. For example in 2020 during a 2 week period there was 20 to 24 inches of rainfall. In weather conditions as stated the ground saturation caused flooding of the drain that runs through Mr. Wilson's and neighbouring properties holding on yards and fields for days. We have attached a pictures showing the spilling of this very drain into our yard. One does not need to be a so called expert to see what is going to happen with downburst rains that will cause surface runoff. Septage on grade or not, will be at the mercy of the runoff and accumulated standing water. We don't want our water well contaminated by this septage.
This proposed septage disposal site currently has a large dug pond on it. Is this where the septage will be dumped? Is it vaulted? Surface spreading as stated is not identifying a controlled method of land application.
Who will be monitoring that the set procedures will be properly followed? Operator developed procedures means nothing to secure the liability and effects to the highly vulnerable aquifers and surface ground waters located throughout this area in Strathroy-Caradoc and Ekfrid townships. The high water table and close to surface ground water affected by contaminants will have a devastating effect on local water quality impact and proper notification of this proposal has been withheld from all affected residents and farms in this area.
The proposal sets out a maximum spreading rate, who is responsible for the spreading rates, and really how much spreading can 11 acres take? This is a septage hauling and pumping operation that uses how many trucks and loads per day? How much septage spread or overburden will be allowed on this site?? We see this site having an estimated 6000 to 10,000 gallons of potential raw septage coming in on site daily, based on the 2 trucks known to this operation. Who else from the area service pumping providers will be using this site to unload, instead of hauling to proper environmental facilities that actually treat the septage?
What real qualifications do personnel have being responsible for operations on this site? This operation has risk of impacting a complete watershed of highly vulnerable aquifers. Being aware of spill prevention and training appears to be very vague and has no substance in actually immediately dealing with a hazmat situation threatening the Government No. 1 drain and highly vulnerable aquifers. These water infrastructure’s poses potential rapid vessels to transport raw septage quickly based on the flow rate through Strathroy-Caradoc into Ekfrid townships. In the event of a hazmat incident, this will be affecting properties, environmental protected areas, and the sources of fresh water that supply multimillion dollar homes and farms.
Strathroy-Caradoc and Ekfrid townships are at risk for ground water, well water supplies and surface water contamination. If this proposal is endorsed by the ERO, MOE, the immediate (local) residents of this site and townships will face the direct impact of their decision.
All one has to do is search the internet for "Ontario Raw Sewage" and you are in for hours of reading stories, government reports, health reports, of direct impact to communities, water ways, and our great lakes, that provide a false trusted water supply for Ontario.
On rural properties and during new construction builds, we are required to install infrastructure that is engineered and approved to support the development plan. Thousands of dollars are spent to ensure septic tanks and fields are installed to code and to prevent ground and water contamination.
All stakeholders in the municipality should be stewards of their properties, which most do take great pride where they live. When such properties are threatened by potential impacts it is our responsibility to respond and do what is right for our direct environment. In this case, a business is proposing to dump septage as they call it, on a property bought by this business. Based on research the ERO is a stepping stone to assist the process of approval. The business then applies for municipal permits to dump the septage on the site in question for a fee. These fees feed the municipal office, saves the business thousands of dollars in operating costs that would otherwise be required to transport the septage to an approved sewage treatment facility.
We have no insight to what levels of sewage is going to be permitted on the site.
Who in the municipality/county/ MOE has our backs to ensure and guaranties proper monitoring of this site, the operators books and logs are not enough when it comes to the all mighty dollar?
Our area is not a Regulated Water Source as defined by the Ministries, which really tells us we are wide open for potential disaster.
Below discusses information for the spread of treated septage. Applicable regulations and considerations should overlap with raw septage procedure.
Biosolids may be used as a soil conditioner for agricultural, horticultural or reclamation purposes depending on the degree of stabilization provided. The quantity of solids generated by the selected treatment process should be calculated or estimated from similar full-scale facilities or pilot facilities. Pathogen levels and concentrations of metals in sludge should be determined using standard laboratory test procedures. Pathogen levels and concentration of metals should be less than the levels specified in O. Reg. 267/03 if land application is used. A mass balance approach should be used to determine the quantity of biosolids produced at the facility.
Important design considerations include but are not necessarily limited to:
• Type of sludge/biosolids stabilization process;
• Pathogen and vector attraction reduction to levels specified in O. Reg. 267/03;
• Biosolids characteristics including the presence of inorganic and organic chemicals;
• Application site characteristics (e.g. soils, groundwater elevations, setback distance requirements);
• Local topography and hydrology;
• Type of crop and land to which biosolids can be applied in accordance with O. Reg. 267/03. For STP which are not phased in under the Nutrient Management Act, requirements are set out in the Certificate of Approval (C of A), based on the MOE and the Ministry of Agriculture, Food and Rural Affairs' Guidelines for the Utilization of Biosolids and Other Wastes on Agricultural Land, 1996.
• Cropping practices, spreading and incorporation techniques;
• Population density and odour control; and
• Sampling, health and safety requirements in accordance with O. Reg. 267/03.
A contingency plan should be provided for flexibility in the event of equipment failure or conditions that prevent the primary use or disposal method. The design should account for weather factors such as rainfall, wind conditions and humidity in the selection of the use or disposal of sewage sludge. Due to inclement weather and cropping practices, alternative storage or disposal options are recommended to ensure the biosolids are properly managed. Mixing equipment or provisions to assist in the monitoring of land-applied biosolids should be considered in the design of biosolids handling and storage facilities.
Municipal sewage treatment plants that apply sewage biosolids on agricultural land are required under O. Reg. 267/03 to have prepared a nutrient management strategy (NMS) and have the strategy approved by the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA).
Links of interest are attached as a word document.
We have a responsibility to protect our properties, neighbours, environment where we live, and outright challenge every threat that may attempt to invade our space and wellbeing. We do not want raw human waste dumped in our community.
Supporting documents
Submitted March 22, 2023 12:56 PM
Comment on
Dwayne Andrew Wilson operating as The Stool Bus - Environmental Compliance Approval (waste)
ERO number
019-6708
Comment ID
83223
Commenting on behalf of
Comment status