Comments on the storage and…

Comments on the storage and spreading of the raw human sewage in Armstrong Twp.

Since the construction of the lagoon first came to our attention, our office has been involved with shortcomings in both the design and approval of the project as well as the spreading operation. The response from the Ministry has been concerning and has left constituents in the area with little faith in the Minister’s capacity to actually ensure the site is operated safely.
When we first brought up the fact that the site was a former dairy farm and that part of the approved lagoon site was actually the former dairy lagoon, the initial response from the MOE was that the we were wrong and that the site was in fact, a greenfield site. Strangely enough, some of the former dairy infrastructure was used in the design, but it was still denied at the time.
When asked if the well that supplied the water to the former dairy farm was identified in the plans. The MOE responded that there was no well. That turned out to be factuallyichincorrect as well. It seems the only people who did not know that the well existed were the owner of the site, the engineer who designed the site, and the MOE who approved its design.
When the MOE acknowledged the existence of the well, immediate action needed to be taken because the former dairy infrastructure that was used in the approved design could also provide a pathway to the well.
There are still questions about whether the systematic tile drainage installed on the farm could in some way create a pathway for contamination.
While these mistakes and questions may not apply directly to the reapplication for a license to spread this sewage, they do indicate a lack of supervision capability of the MOE and or a reluctance from the owner operator to disclose possible problems. More importantly, these issues also could have an impact on the safety of the spreading program at the site.
It has come to our attention that the operator has spread sewage during a significant rain event when the ECA application said that they would not spread liquid manure. There was runoff from that incident.
The operator has also spread beyond the boundaries of the approved spread area.
It has also come to our attention that raw sewage does not fall under the Agricultural Nutrient Management Act. If other biosolids etc. are spread on land where a Nutrient Management Plan is in place, A Non-Agricultural Source Management Plan has to be filed with the Minister of Agriculture. This is to ensure that the overall nutrient load does not exceed the capacity of the soil to maintain the safety of surface and groundwater. Since no NASM is required for raw sewage, this task falls to the MOE. How does the MOE monitor this at this site considering that the operators have shown a willingness to ignore normal good farming practices, or environmental stewardship for that matter?
Crops have been grown on the spread area and have been sold. Does the MOE monitor whether or not these crops have entered the human food chain? If so, can it provide supporting documentation? As far as our office can see, an ECA only asks what type of crops will be planted and if there will be crops, it does not seem to track where they go thereafter.
My office does not usually comment on ECA applications, but since the MOE’s response to our initial inquiry was wrong, we remain concerned.