This notice is for informational purposes only. There is no requirement to consult on this initiative on the Environmental Registry of Ontario. Learn more about the types of notices on the registry.
Why consultation isn't required
The City of Stratford’s Water Pollution Control Plant was subject to the Municipal Engineers Association’s Municipal Class Environmental Assessment. Section 32 of the Environmental Bill of Rights exempts proposals for instruments that are issued as a step toward implementing an undertaking (or project) that was approved under the Environmental Assessment Act.
Given the level of public interest on this proposal, we are posting this bulletin to inform the public about our decision on:
- the city’s Environmental Compliance Approval application
- the effects of the public’s comments, received through the neighbor consultation process, on our decision
Please note that as the ministry’s decision on this application is exempt from requiring an environmental registry posting, Leave to Appeal rights do not apply.
Bulletin details
Site address
Stratford Water Pollution Control Plant
701 West Gore Rd
Stratford City, County of Perth
N5A 6W1
Proponent
The Corporation of the City of Stratford
82 Erie St
Stratford, Ontario
N5A 2M4
Decision details
On June 10, 2020, we approved a new multi-media Environmental Compliance Approval (Municipal and Private Sewage) No. 9501-BG3JPF for a new waste processing facility within Stratford’s Water Pollution Control Plant so they can:
- receive source separated organic waste from residential, industrial, commercial and institutional waste sources generated in Ontario
- process (anaerobic digestion) the source separated organic waste mixed with sludge generated at the Water Pollution Control Plant to produce soil supplements and renewable natural gas
The Water Pollution Control Plant will be the first net-zero energy wastewater treatment plant in Ontario.
The Waste Processing Facility will receive the organic waste for storage and pre-processing in the receiving building. The organic waste will be mixed with the sludge generated at the Water Pollution Control Plant for co-digestion within the existing anaerobic digestors to produce:
- digestate (soil supplement)
- biogas
Generated biogas will then be upgraded into renewable natural gas prior to its injection into the natural gas distribution infrastructure. The existing flare will be replaced with a larger flare to burn any extra biogas or biogas unsuitable for injection into the natural gas distribution infrastructure.
The approval expands the existing processing (anaerobic digestion) system at the Water Pollution Control Plant and consists of new and existing infrastructure, including:
- three (3) new 50 cubic metre sludge hydrolysis tanks
- one (1) new organic waste receiving building
- one (1) new tank yard, which includes:
- one (1) 50 cubic metre liquid organic waste reception tank
- one (1) 500 cubic metre organic waste buffer storage/hydrolysis tank
- three (3) 4 cubic metre pasteurization tanks
- two (2) existing 1,600 cubic metre anaerobic digestors
- one (1) modified 2,850 cubic metre digestate storage tank
- one (1) new screw press
- one (1) new photoionization system
- one (1) new post digestate skid odour treatment system
- one (1) new biogas upgrading system
- one (1) expanded flare
The existing sludge storage lagoon will be repurposed for use as emergency spill containment. The existing anaerobic digester and the associated equipment and structures have been built in compliance with all applicable regulatory requirements.
The maximum daily waste to be received at the site is:
- 150 tonnes of solid organic waste (e.g., green bin waste from residential homes)
- 40 cubic metres of liquid organic waste (e.g., fat, oil and grease from restaurants)
The maximum annual waste receipt rate is:
- 5,000 tonnes of solid organic waste
- 20,900 tonnes of liquid organic waste
The maximum waste storage includes:
- a maximum of 228 tonnes of solid organic waste will be temporarily stored in the receiving building
- a maximum of 40 cubic metres of liquid organic was will be stored in the liquid waste reception tank
- a maximum of 5,312 cubic metres of organic waste (unprocessed, in-process and processed waste) will be stored in tanks outdoors, at any one time
- a maximum of 15 cubic metres of solid residual waste resulting from the waste management activities will be stored in a bin inside the receiving building, at any one time
The service area will be the Province of Ontario. The anaerobic digester operates 24 hours a day, 7 days a week and the hours of operation for the receipt of organic waste at the facility will be Monday to Friday from 5 am to 6 pm.
Effects of consultation
Although proposals subject to Class Environmental Assessment are not required to be posted on the Environmental Registry of Ontario for public consultation, neighbour consultation was required as part of the review process.
Between June 7, 2019 and November 31, 2019, we received a total of 42 emails and letters from the public through the neighbour consultation process.
Considering the public interest on this proposal, we want to provide detailed information to the public on how the comments received through the neighbour consultation effected our decision.
The information below summarizes the issues identified in the comments and how we considered and addressed them as part of our decision:
- Concerns regarding the location, zoning, traffic (volume, safety, noise and air impacts) on municipal roads, municipal road conditions, project funding and depreciating property values
Response: Location, zoning, traffic (volume, safety, noise and air impacts) on municipal roads, municipal road conditions, project funding and depreciating property values are under municipal jurisdiction which are out-of-scope of the Environmental Compliance Approval review process. The city’s website includes information relating to some of these concerns.
- Concerns about the possible air impacts, including odours, from the proposed Waste Processing Facility
Response: The conditions of the Environmental Compliance Approval require the owner to address potential odour impacts by including proper maintenance and operation of odour control units, complaint response procedures, nuisance impact control, odour control measures, odour performance requirements, odour management plan requirements, ventilation assessment requirements and source testing requirements.
All these are in place to ensure the facility operates in a manner that protects health of the public and the environment.
- Concerns about possible noise impacts from the proposed Waste Processing Facility
Response: This proposal demonstrates that the operations of this facility will meet the ministry’s noise limits at the receptors if the proponent constructs, implements and operates the equipment/facility as outlined in the Acoustic Assessment Report, and complies with all specific noise conditions (including conditions for the truck traffic and trucks noise emissions from the facility) as stated in the Environmental Compliance Approval.
The conditions of the Environmental Compliance Approval require the proponent to conduct an acoustic audit to verify the ongoing compliance of this facility with the applicable ministry’s noise limits at all receptors.
- Concerns about the quality of the incoming wastes
Response: The conditions of the Environmental Compliance Approval limit the waste types that are approved for receipt and require characterization and/or testing of these waste types prior to acceptance at the Water Pollution Control Plant.
- Concerns about emergency spills
Response: The conditions of the Environmental Compliance Approval require spill containment measures for all tanks and vessels containing liquid wastes. Spill containment protocols already in place for the existing tanks and vessels will continue to be followed.
- Concerns about emergency situations (specifically methane leaks ad explosions)
Response: The Environmental Compliance Approval includes a flare to ensure that any excess or off-specification biogas is combusted instead of being directly released to the natural environment. Should there be a methane leak which cannot be flared, this would be considered a spill by the ministry and the spill handling requirements from the Environmental Protection Act will need to be followed. Furthermore, the conditions of the Environmental Compliance Approval require that the spill is immediately reported to the ministry and addressed. Lastly, the Environmental Compliance Approval has conditions which require the proponent to develop an emergency response plan for responding to any emergency situations, including spills.
Plant and equipment safety (e.g., explosion-proof design) are the Technical Standards and Safety Authority’s (TSSA) jurisdiction and will be addressed through the building permit that will be issued by the municipality. The city’s website includes some information relating to health and safety concerns.
- Concerns about municipal lack of notice to the public
Response: The waste disposal site application review process had public consultation requirements and this notification process was followed. Furthermore, the municipality conducted public notification and consultation (e.g., public meetings on June 13th, July 4th and November 6th, 2019).
- Concerns about construction on the floodplain
Response: The Water Pollution Control Plant is existing and most of it is located within the floodplain of Avon River. The municipality has consulted with the Upper Thames Conservation Authority and a permit will be obtained as required prior to construction of any structures or equipment located within the floodplain.
- Concerns about the odour from the trucks traveling to and from the facility
Response: The Environmental Compliance Approval includes conditions to minimize the risk of odour emissions from the trucks carrying waste to and from the facility (for example, a requirement for the trucks to be covered).
- Concerns about pathogens spreading to the community from the Water Pollution Control Plant
Response: The facility was designed to contain and control the impacts of receipt and processing of wastes at the facility by enclosing tanks/vessels and maintaining the receiving and pre-processing and the digestate management buildings under negative pressure and venting to air pollution control equipment. Domestic sewage receipt and processing at the site are not being changed, other than adding a sludge hydrolysis step in enclosed tanks and subsequent co-digestion with organic wastes in the existing anaerobic digesters. Furthermore, the Environmental Compliance Approval includes a requirement to follow-up if a truck is found to be leaking waste.
- Concerns about why an air amendment was needed if there are no expected impacts
Response: The requirement for an amended approval for air is governed under section 9 of the Environmental Protection Act for the addition of any new equipment that discharges to the natural environment other than water. The approval relates to the addition of a Waste Processing Facility and the modification of the existing Water Pollution Control Plant, including activities that involve contaminants discharge into the natural environment other than water.
The conditions of the approval require the owner to address potential impacts of odour, odour-causing contaminants and combustion gases from the facility, including proper maintenance and operation of equipment, complaint response procedures, nuisance impact control, odour control measures, odour performance requirements, odour management plan requirements, ventilation assessment requirements and source testing requirements.
All these are in place to ensure the facility operates in a manner that protect health of the public and the environment.
- Concerns about the effects of CO2 emissions on humans and the local environment
Response: The proposal demonstrated that the facility can operate in accordance with Regulation 419/05 Air Pollution - Local Air Quality (Regulation 419/05). The limits in Regulation 419/05 are contaminant specific air quality standards, including that of carbon dioxide, that have been developed to be protective of human health and the environment. The owner is required to meet the requirements of Regulation 419/05 at all times, including the limits for all contaminants emitted from the facility.
- Concerns regarding the approval of equipment which requires constant monitoring
Response: Regular monitoring and proactive maintenance of equipment handling volatile gasses is an existing requirement of the Water Pollution Control Plant’s Environmental Compliance Approval. The requirement ensures that equipment is maintained and functioned as intended in the design for the safety and protection of humans and the environment.
Leave to appeal provisions
Third-party leave to appeal rights do not apply to the ministry’s decision pertaining to this instrument.
Supporting materials
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Contact
Client Services and Permissions Branch
135 St Clair Ave West
1st Floor
Toronto,
ON
M4V 1P5
Canada