Centre for Alternative Wastewater Treatment

12 Analysis of Technical Supplement 3 and Impacts on Nunavut

Element of Technical Supplement 3	Details on Strategy Objectives/Requirements	Impacts on Nunavut
1.2 Standard Method Objective and 1.3 A Step-by-Step Standard Method	The draft strategy has a standard method or methodology for implementing the requirements of the strategy.	A standard method should be developed for Arctic communities.
2.0 Substances of Potential Concern	Primary treatment is estimated to reduce CBOD5 and TSS by 30% and 60% respectively.	Primary treatment, through lagoon treatment is standard approach. Additional treatment is achieved through wetland treatment in some communities. 30% reduction in CBOD5 is unlikely to meet NPS. The strategy imposes the measurement of CBOD5 as the main sewage strength indicator. No explanation or justification for this parameter is provided other than it is a conventional parameter. Many wastewater researchers are leaning toward adoption of Chemical Oxygen Demand (COD) as a more consistent method of measuring sewage strength. BOD5 originated as a method in England because maximum travel time of rivers in England is 5 days and can be highly inconsistent between samples because of biological activity and sample transport requirements. COD, however, can be adequately correlated with CBOD5 and is far easier to analyze. CAEAL now accredits “test in the tube” methods for COD that can be done with only 20mL of sample and done with a benchtop heating block and spectrophotometer in less than 2 hours. Hamlet employees could be trained to measure COD in the community or could send samples to a regional municipal lab allowing for far more frequent monitoring that would also eliminate sample quality problems associated with transportation. CBOD5, however, is sufficiently complicated to require dedicated commercial labs to perform the test but is in fact less reliable. TSS is more complicated than COD but could also be undertaken by a municipality with some upfront capital costs and employee training. A cost-benefit analysis should be undertaken to see if communities in Nunavut should establish a dedicated COD/TSS lab in the region for the purposes of municipal wastewater monitoring. It should be noted that this would only be feasible if CAEAL PT accreditation was sufficient. Requirements for full accreditation would be prohibitively expensive. Cost savings through combined in-house drinking water analyses would also be prohibitively expensive because of the extra requirements for drinking water lab accreditation.
3.0 Initial Characterization Program		See above.
3.1 Facility Categorization		See above.
3.2 Perform MWWE Characterization		Comments in strategy on assessing effects of weather conditions must be adapted to Arctic conditions and constraints. For example, the supplement recommends sampling during and after high precipitation events but this is the most probable time for fly delays and cancellations in the Arctic.
4.0 Implementation of Initial Characterization Program		See above.
5.0 Environmental Risk Assessment – Single Discharge Approach		See above.
6.0 Environmental Risk Assessment – Watershed Approach		See above.
7.0 Selection of Substances for Compliance Monitoring		See above.
Appendix A Sampling, Preservation and Storage		See above.

13 Overview of Implications of Draft Strategy for Region

The majority of Nunavut communities have limited community capacity to meet current monitoring and reporting requirements. The capacity shortfall does not only exist at the community level—there is limited capacity within all levels of government in the Arctic to monitor, assess, interpret and enforce.

A five year window has been created for researching treatment efficiencies of lagoons and wetlands in the Arctic, for the development of Arctic or Alternate Performance Standards (APS). Within the same window, communities will be required to complete risk assessments, including initial characterization. The implementation timeline for this requirement is not realistic for communities in Nunavut, based on current financial and human resource capacity. Further, short-term funding mechanisms prioritize high risk facilities; as most communities are likely to be low-risk, according to the Strategy, assistance from senior levels of government will not be available until after the 5-year window, when the risk assessment and initial characterization are to be completed. At the same time, the cost for completing a site-specific environmental risk assessment and initial characterization are much higher in the North than the Strategy suggests, at approximately $20 to 30K each (Ken Johnson, personal communication).
All but three communities in Nunavut have only trucked water service, which is associated with a much lower per capita water use than for piped—the GN design values for per capita water consumption are 90 L/person/day for trucked water delivery, and 225 L/person/day for piped delivery. If the APS are concentration-based, this could in effect penalize communities with trucked service for using less water than communities with piped delivery. Higher concentrated effluent could also skew toxicity testing failure rates. In addition, the appropriateness of the rainbow trout toxicity test is questionable, as it is a non-native species and the test could be extremely onerous for communities. As the majority of communities have lagoons and some form of treatment wetlands, there may be difficulties identifying the final discharge point. Further technical issues are identified for each element of the Strategy in Section 10 to 12.
Taken together, these implications clearly point to the need for an alternate approach, grounded in Northern social, economic and environmental realities. An Arctic-specific wastewater management framework must be developed in collaboration Northern partners, including Inuit, to ensure that the important goal of protecting the environment and human health from the impact of wastewater is achieved.