Vermilion River Stewardship submitted comments on the Draft Greater Sudbury Source Protection Area Plan – see correspondence below:2012-08-10-VRS-CommentstoNDCA
Vermilion River Stewardship has registered as a stakeholder in this proposal, as the Ferrechrome Production Facility would be located in the Vermilion River Watershed.
Cliffs website indicates they are currently in the early planning stages for this Project and are undergoing a coordinated Environmental Assessment under the Canadian Environmental Assessment Act and the Ontario Environmental Assessment Act. Cliffs announced that they have chosen the Caperol site for the smelter on May 10th, 2012 – check out the CBC interview with Cliff’s VP, Bill Bloor.
If you are a stakeholder, or have concerns, you may register to receive all updates and notices by contacting Cliffs by email at firstname.lastname@example.org, or by Telephone at 1-855-353-4766 to register as a stakeholder. For a detailed Project Description – click here.
The Green Energy Act and Green Economy Act don’t allow municipalities to have a say in green energy proposals, however, the Township of Nairn and Hyman, through this Motion, are sending a strong message to the public, developers, and the government that these hydroelectric proposals carry with them significant environmental, ecological, economic and social costs; present unnecessary threats to public health and safety; and are not wanted in this area.
4 January 2012
Nickel District Conservation Authority
200 Brady Street, 1st Floor,
Tom Davies Square
Attention: Paul Sajatovic, General Manager
Dear Mr. Sajatovic:
Re: Water Quality
The Vermilion River Stewardship (VRS) is a Not-for-Profit organization, acting as a voice for the Vermilion River and its stakeholder Communities, to support a healthy, natural and sustainable river ecosystem. VRS is very concerned about a public health and safety issue that occurred on the Vermilion River last fall, and is looking to Nickel District Conservation Authority (NDCA) for help in addressing our questions and concerns.
In October of last year a Cyanobacteria outbreak was reported on Simon Lake, McCharles Lake, and the Vermilion River, all the way through to Wabagishik Lake. The water flow and levels on the Vermilion, both this year and last, throughout the late summer and early fall months were extremely low, and that, combined with the effluent discharge from 9 Waste Water Treatment Facilities (WWTF), numerous lift stations, transfer stations, and sewage lagoons, has created the prime conditions for this toxic algae.
In a study by D.W. Schindleri, it was revealed that phosphorus is the limiting factor in determining whether algal blooms will occur in a water body, and that combined with these low flow and warm weather conditions was a likely cause of the Cyanobacteria bloom this year. As you know exposure to these blooms through drinking, swimming, bathing, or even breathing their toxic vapours in saunas, creates a health and safety threat to both humans and animals.
In the “Greater Sudbury Source Drinking Water Protection Proposed Assessment Report”, I assume Table 5.7ii addresses the additional risks of the 5 WWT plants and their related facilities, located above the Vale Public Water Intake (PIPZ10S – pathogens in an IPZ with a vulnerability of 10 where threats are significant). However, it is not clear if they are considered as a risk since these facilities are outside of IPZ 1 and 2, or if their cumulative effects are considered in this risk assessment report – please clarify. We also have the additional stress of the 4 WWT plants and their related facilities feeding into the lower Vermilion River Watershed through Junction Creek, and on into the Lower Vermilion River. The cumulative effects of the effluent discharge from all these WWTF is also heightened when heavy rain events necessitate bypassing of untreated or undertreated effluent into the environment.
To date there has been no Cyanobacteria reported on the northern arm of the Vermilion River where the Vale Public Water Intake is located; however, there is a likelihood of this occurring as scientists predict that climate change will increase the number of extreme rain and drought events, and our City of Sudbury waste water facilities were not built to deal with these extreme weather events.
VRS realizes the water going into the Vale Public Water Intake is treated; however, there are numerous questions that we would like answered with respect to the cumulative effects of treated and undertreated effluent discharge, and the threats that Cyanobacteria outbreaks could pose:
- Is there a communication protocol between CGS Water Wastewater and NDCA when a sewage bypass occurs?
- How are the 5 upstream CGS WWTF accounted for in the Greater Sudbury Source Drinking Water Protection Proposed Assessment Report?
- Please clarify how the CGS WWTFs’ cumulative effects are accounted for in this risk assessment report.
- To what degree would cyanobacteria toxins be eliminated from treated drinking water at the Vale Public Water Intake and private residences?
- What long-term effects would drinking this treated water have on human health and safety?
- What protection is provided for the hundreds of Vermilion River shoreline residents who rely on the River and/or its often highly vulnerable aquifers for all their drinking water and household requirements? Most residents do not:
- Have the facilities to detect these toxins in their well water, or to filter them out, and/or
- Have another convenient source of water available to them.
- What are the associated risks of a Cyanobacteria outbreak, or a waste water bypass, to shoreline residents who rely on the Vermilion River for their drinking water and household water needs?
VRS makes the following requests:
- Onaping Lake drawdown already begins in September, but could measures be taken to increase the rate of drawdown during the low flow months of September and October to increase water levels and flow in the Vermilion River?
- VRS requests a warning protocol to shoreline residents when WWTF bypasses or toxic algae events occur and water quality is compromised – similar to the one already established with the Ramsay Lake Algae Watch?
- VRS requests that private water intakes along the Vermilion River and its connecting lakes be included in NDCA’s Source Water Protection Risk Assessment protocol, and are formally included under the Clean Water Act.
- VRS requests NDCA develop a plan to adequately deal with reduction of risks, and that these risks be considered and included in the Source Water Protection Risk Assessment Report.
Many shoreline residents who rely on the Vermilion River system for their drinking water and household needs were extremely distressed and inconvenienced with the Cyanobacteria outbreak which occurred during the month of October, and VRS is requesting action be taken to avoid similar or more serious problems in the future.
VRS looks forward to your reply.
Chair, Vermilion River Stewardship
CC: Nick Benkovich, Director Water/Waste Water – Nick.Benkovich@greatersudbury.ca
Judy Sewell, Project Co-ordinator – Judy.Sewell@sudbury.ca
Jacques Barbeau, Councillor Ward 4 – Jacques.Barbeau@city.greatersudbury.on.ca
France Gelinas, NDP, MPP – FGelinasemail@example.com
Chief Steven Miller, Atikameksheng Anishnawbek – Chief@wlfn.com
Stephen Monet, City of Sudbury – Stephen.Monet@city.greatersudbury.on.ca
Stephen Butcher, Chair, GSWA – firstname.lastname@example.org
Perry Sarvas, Simon Lake Community Stewardship Group – Sarvas@vianet.ca
i Eutrophication and Recovery in Experimental Lakes: Implications for Lake Management, by D.W. Schindler, Fisheries & Marine Services, Freshwater Institute, Winnipeg, Manitoba.
ii Greater Sudbury Source Protection Assessment – Amended Property Assessment Report, Table 5.7, P 5-14
Dear Ms. Flowers:
Thank you for your letter of November 29,2011, expressing your concerns about how the Sudbury & District Health Unit handled the early October blue-green algae bloom in the vermillion River. comments from the public we serve are always
The Health Unit and the Ministry of the Environment (MOE) have, over the past several years, developed a protocol that is to be followed by both agencies. The following explains that protocol.
The Health Unit and the Ministry of the Environment do not proactively check local waterways for the presence of blue-green algae. There are several reasons for this, one of which is the number and size of our waterways. With current levels of
staffing, it would be impossible for either agency to undertake such a process. That is why the investigation of blue-green algae is a complaint-driven process that relies on sightings reported by the public and, in particular, people who own or occupy waterfront properties.
The key issue relates to risk. Blue-green algae are natural phenomena and common in our waterways. However, they are not a potential risk to health until there is a “bloom”, or large numbers of blue-green algae in one area. When the Health Unit receives a report of a suspected blue-green algae bloom, a public health inspector is immediately sent to investigate. Because not all blue-green algae blooms contain toxins, the investigation is done to determine whether or not the bloom contains a species of blue-green algae that can produce toxins. The investigation consists of:
- a visual check to confirm that the growth in the water does in fact appear to be blue-green algae;
- taking photographs as evidence in case the bloom dissipates or moves to another location; and
- taking samples that are sent to the MOE laboratory in Toronto to determine if a toxin-producing species of blue-green algae is present.
Once the lab receives the sample, it usually takes from two to four business days for analysis. The MOE lab, which is the only lab in Ontario certified to do this kind of detailed analysis, sends the results to the local MOE office, which then forwards
them to the Health Unit. Thank you for your comment regarding the time it takes for lab results. we have forwarded your concern to the local MOE office attention Brian McMahon (Brian.McMahon@ontario.ca).
When the Health Unit receives positive test results, it immediately starts the notification process. This consists of hand delivering a letter from the Medical Officer of Health, along with a fact sheet from the Ministry of the Environment, to residents in the immediate area of the bloom. The Health Unit then issues a news release to local media. The resident notification process does not occur when blooms are identified in an area that is accessible by water only, in remote areas, and in areas where blue-green algae have been previously identified.
Blue-green algae are not anchored in one place and are easily moved by wind and water currents. You can see blue-green algae in front of your property in the morning and it can be gone by the afternoon. To thrive, blue-green algae prefer slow-moving or stagnant, shallow water with an abundant supply of nutrients (usually phosphates and nitrates). ln a rapidly flowing or moving body of water, ihe algae are normally dispersed and diluted. Blue-green algae can also raise and lovuer ihemselves in the water to catch the sunshine they need to grow.
ln the case of the blue-green algae sighting on the Vermillion River, the Health Unit followed the protocol described above. As an added precaution, Health Unit staff also inspected the intake area of the Vermillion Water Treatment Plant and determined that a blue-green algae bloom was not present there.
The information that the Health Unit distributes door-to-door advises people who draw their water from the surface body to find an alternative supply of water for consumption-not just while the blue-green algae bloom is present, but on a permanent basis. Once a water body has experienced a blue-green algae bloom, it will most likely experience it again under similar circumstances. As far as swimming, bathing, or laundry are concerned, the information distributed by the Health Unit advises against such activities as long as the bloom is present and close to water intake lines or beach fronts’ Repeated sampling would not reduce the risks from blue-green algae. The blooms are mobile and can be dispersed, but they can also reoccur without warning. Once blue-green algae have been detected in a water body, the water body will always be at risk. That is why we ask residents in the area of a blue-green algae bloom to be on the lookout for it and to report any sightings to the Health Unit’
I hope that this letter has addressed your concerns. lf you would like to discuss the matter further, please call Allan McDougall, Environmental Support Officer at705.522.9200, ext.442.
Penny Sutcliffe, MD, MHSc, FRCPC
Medical Officer of Health/Chief Executive Officer
cc: Marianne Matichuck, Mayor, City of Greater Sudbury
France Gelinas, MPP
Jacques Barbeau, Councillor, Ward 2
Linda Heron, Vermillion River Stewardship
Dr. Penny Sutcliffe, Medical Officer of Health
Sudbury and District Health Unit
1300 Paris St.
Sudbury ON P3E 3A3
November 29, 2011
Dear Dr. Sutcliffe:
I am writing to you regarding concerns over the handling of the Cyanobacteria (Blue-Green Algae) out break on the lower Vermillion River in early October of 2011. A neighbour and I both contacted a health inspector with the Sudbury and District Health Unit to report suspicious looking algae in the river. An inspector came that day and sampled the water at the neighbour’s dock. We were pleased with this prompt response. Unfortunately there are a number of areas that need remediation.
First, as you know the sample is then given to the Ministry of the Environment for testing which takes 7 days to report results. During that time except for a few people who we personally knew and warned, most people using the river would have continued using it normally for drinking water, use in saunas, fishing, watering of livestock and gardening. The waiting time for test results is unacceptable. Surely there are alternatives to this process and facilities closer to Sudbury.
Once the results were available, the neighbour and I, and a few houses along River Road were informed in person with hand delivered notices of the hazards of Cyanobacteria. To my knowledge we were the only members of the public living upstream and downstream of the test area to be notified personally. Others on the river were left to find out via media and word of mouth. Since the outbreak was in the current of the river rather than shallow areas and bays, this too is unacceptable given the potential for serious health consequences.
Fortunately, leadership on the part of The Vermillion River Stewards resulted in a public information session on October 11, 2011 in which Dr. Charles Ramcharan gave us pertinent information, an interpretation of test results and a protocol to follow while the outbreak continued to run its course.
Now, as common sense might dictate we think that the Cyanobacteria is dead and no longer a risk to health because the water is now cold and there has been a large influx of new water from heavy rainfall into the system. So do we draw drinking water from the river again? Do we eat the fish? Do we use our saunas again? Should the water have been tested again in several areas? Should testing occur in the spring and summer regardless of sightings of algae? Does the Sudbury and District Health unit investigate the likely causes so that preventative measures can be taken? The lack of follow up and communication on the part of the Health Unit is also unacceptable.
In summary, the Sudbury and District Health Unit needs to revisit and rework the protocol for Cyanobacteria outbreaks and increase its diligence and support for those affected so that health can be protected.
Cc: France Gelinas MPP
Mayor Matichuck, Mayor City of Greater Sudbury
Jacques Barbeau, Councillor Ward 2
Linda Heron, Vermillion River Stewardship
December 13, 2011
Dear Ms. Flowers:
Re: Vermilion River Watershed Concerns
Thank you very much for your letter dated November 30, 2011 which was received by the Nickel District
Conservation Authority (NDCA) on December 7,2OL1.
I have read your letter and note that you have outlined four main issues of concern. First, the blue-green
algae bloom which was confirmed on a portion of the lower Vermilion River in early Fall. Second, the
potential impacts on water quality from sewage treatment plant facilities located in different subwatersheds
which feed into the Vermilion River watershed. Third, the low water levels and flows in the
Vermilion River and Junction Creek (McCharles Lake area) this past Summer. Fourth, how the issue of
low water response is addressed and what agencies have responsibilities in that regard.
I have reviewed your issues of concern with Paul Sajatovic the NDCA’s General Manager. It would be
best to meet with you to discuss the issues you have raised as well as the complexities associated with
water management in the Vermilion River watershed. Following our meeting, we would summarize our
discussions in writing so that you might share them with the stewardship group. Please contact Paul at
the NDCA office to arrange a meeting at a mutually convenient time in the near future.
You are, perhaps, aware that Linda Heron the Chair of the Vermilion River Stewardship group will be
appearing before the NDCA General Board on January 19,2012. You may want to attend with Linda. We
welcome watershed residents to our meetings. We can provide up to 15 minutes for presentations
followed by a question and answer period.
On behalf of the Nickel District Conservation Authority, I thank you for your submission. Let me assure
you that as the stewards of our watersheds in Greater Sudbury, the NDCA takes its responsibilities very
seriously. Lesley, we look forward to meeting with you very soon.
cc. NDCA General Board Members
Ms. Linda Heron, Vermilion River Stewardship
Paul Sajatovic, NDCA General Manager.
Chair, Nickel District Conservation Authority Board
200 Brady St. Tom Davies Square
Sudbury ON P3E 5K3
November 30, 2011
Dear Mr. Rogers:
I would like to make the Nickel District Conservation Authority aware of a condition that emerged on the lower Vermillion River in early October of this year and ask for help to prevent a recurrence. During the warm weather with very low water levels, the river supported a considerable Blue-Green Algae bloom until plenty of rain and colder temperatures seemed to kill it. The bloom was in the current of the river, rather than in bays and shallow areas so it came in the flow as opposed to developing from nutrients coming from the shoreline.
The nutrients are likely a result of waste water effluent from the upstream sewage treatment plants and the weather was unseasonably warm and sunny. Hopefully in time, sewage treatment will improve but unfortunately climate change might not. The water level of the river at this time was very low since there was little rain fall and the waters flowing from the north were much reduced.
What might be worth looking at through the N.D.C.A. is the amount of water, in the Vermillion River north of Highway 17, that was available to the lower part of the river. The falls visible from Regional Road 55 under the railway bridge were reduced to a very small stream in the late summer and early fall. Could the possibility of a bloom have been mitigated if less water had been held back at Stobie Dam? Usually the stream from McCharles Lake and back to Junction Creek is diluted with this water from the north. Is this part of the N.D.C.A.’s mandate? Is water level monitored at all levels of the Vermillion River? Is it only flooding that is a concern and not low water?
I am unsure of the role N.D.C.A. plays in low water situations, although I did read the information on the website and on the website of the Ministry of Natural Resources which did indicate a protocol for low water problems. I just do not understand what would constitute low water and whether a Blue-Green Algae bloom would constitute reason for action.
I am writing this letter as an individual but I am a member of the community that lives along the lower Vermillion River and I will share the letter and response with the Vermillion River Stewardship. I hope that answers to my questions can help this community deal with this problem.
Cc: Paul Sajatovic, N.D.C.A.
Linda Heron, Vermillion River Stewardship