Compliance Program with Monetary Concession -

Christie Brown & Co. (Ward 19)

The Works Committee recommends the adoption of the following report (June 29, 1999) from the Commissioner of Works and Emergency Services:

Purpose:

To issue a Compliance Program with Monetary Concession to Christie Brown & Co., 2150 Lakeshore Boulevard West, to allow them to pay 50 percent of the new re-assessed surcharge for three years in order to facilitate the installation of an on-site pretreatment system.

Funding Sources, Financial Implications and Impact Statement:

This Department currently maintains 157 Industrial Waste Surcharge Agreements, which allow for the recovery of approximately $7.5 million per year in additional treatment costs. These charges reflect a user pay philosophy and directly offset the cost of the operation of our treatment plants. Christie Brown & Co.'s new surcharge is $17,086.40 per quarter, an increase of $15,971.58 over their old surcharge of $1,114.82 per quarter. By allowing the company to pay at a reduced rate of 50 percent of the new surcharge rate per quarter would mean a reduction in revenue of $34,172.80 per year for a total of $102,518.40 for three years.

Recommendation:

It is recommended that a Compliance Program with Monetary Concession be granted to Christie Brown & Co., 2150 Lakeshore Boulevard West, as described herein, to allow for payment of 50 percent of their re-assessed surcharge for three years, subject to Christie Brown & Co.'s investment of the avoided surcharge payment in the purchase and installation of an on-site pretreatment system.

Council Reference/Background/History:

On November 9, 1989, Metropolitan Council, by adoption of Clause No. 6 of Report No. 16 of The Works Committee, authorized execution of agreements with industries permitting them to discharge wastewater in excess of the limits set out under By-law No.153-89, providing that the overstrength discharges are amenable to treatment at our treatment plants. Industries are required to pay for the additional cost of treatment above the limit of the by-law.

Section 6 of this by-law allows the owner of industrial premises who has an existing surcharge agreement or who is entering into a new surcharge agreement to apply for a Compliance Program with Monetary Concession by submitting to the Commissioner of Works and Emergency Services a Compliance Program to carry out works or improvements to reduce their waste loading in order to avoid up to 50 percent of the payment of the new or existing surcharge assessment, for up to three years. The Commissioner of Works and Emergency Services may then issue an approval known as a "Compliance Program" to the person who submitted the program. The person to whom a Compliance Program has been issued shall not be prosecuted under the by-law during the period within which the Compliance Program is applicable, provided that the person complies fully with the terms of the Compliance Program.

Comments and/or Discussion and/or Justification:

Recently, several companies have complained that their new surcharge assessment or increased surcharge assessment on existing agreements is creating financial hardship and have expressed an unwillingness to pay the surcharge. These companies would like to reduce these costs, however, they would have to install treatment facilities which would add further costs.

Recognizing that some industries are already facing financial hardship, we recommend that industries facing significant increases in surcharges for new agreements or amendment to existing agreements could apply for a surcharge reduction of 50 percent of the new agreement or the increase to the existing agreement, for up to three years, if they commit under a Compliance Program to invest the reduced surcharge payment for specific pollution control equipment. In this way, the discharger benefits in the long term because they permanently reduce their surcharge costs. We also benefit in that more treatment capacity is free for additional development.

The following are the guidelines for considering for Compliance Program with Monetary Concessions:

(1)all companies who have existing surcharge agreements, including new companies seeking their first surcharge agreement and companies facing substantial increase in their surcharge costs, are eligible to apply;

(2)the applicant must commit in writing, in the form of a Compliance Program, with specific program activities, commencement dates, completion dates and program costs, to reduce their waste loading by at least 50 percent by a specified date;

(3)the reduction in surcharge could be for a period of between one and three years, depending on the time required to complete the program for waste reduction;

(4)pollution prevention would be the preferred option for waste reduction; end-of-pipe treatment would be approved only if there are no pollution prevention options available;

(5)an applicant can only be granted one Compliance Program with Monetary Concession per lifetime; and

(6)at the end of the Compliance Program period, the companies who are unsuccessful in reducing their waste loading to within by-law limits must resume paying surcharge based on the actual waste loading at that time.

The type of waste generated by Christie Brown & Co. is biodegradable and amenable to treatment at our Humber Treatment Plant.

On June 21, 1999, Christie Brown & Co. submitted an application to have the industrial waste surcharge amount reduced. The company will undertake a study to evaluate their production processes in order to identify sources of contaminant in the plant, evaluate and implement methods to reduce amount of contaminants by 50 percent by December 31, 2001. They have provided us with the following schedule for their Compliance Program.

ComplianceScheduledScheduledProject

Program ActivitiesStart DateCompletion DateCosts ($)

(a)Chemical Treatment Feb., 1999May, 1999$ 49,500

Installation Program

-Install flocculant and

coagulant addition system

-Purchase and install pumps,

meters, piping, controls

(b)Chemical TreatmentFeb., 1999Dec., 2001$237,600

Operation Program

-Chemical costs -

flocculant, coagulant

-Sludge removal costs

-Labout costs - turbidity

tests, rate adjustments

(c)Stream Rerouting ProgramJan., 2000Dec., 2001$ 36,000

-Increase no. of contaminant

source points connected to

DAF

-Purchase and install piping,

pumps, sump pits, controls

(d)Engineering Study ProgramSept., 1999Dec., 2001$ 29,000

-Identify locations of sourceSept., 1999Jan., 2000

points and prepare drawings

-Develop process flowOct., 1999Feb., 2000

drawings of waste processes

-Quantify amount of wasteJan., 2000Mar., 2000

for each point by BOD/SS

testing

-Investigate alternate methodsJan., 2000June, 2000

of waste management

-Research new processes Nov., 1999July, 2000

for waste reduction

-Develop revised proceduresAug., 2000Mar , 2001

for waste management

-Evaluate and implementMar., 2001June, 2001

new processes/procedures

-Prepare operator trainingJune, 2001Sept., 2001

manual

-Provide operator trainingOct., 2001Dec., 2001

Total Program Cost$352,100

Christie Brown & Co. is currently under a surcharge agreement with the City. The surcharge is based on an average suspended solids concentration of 1144 mg/L at an annual discharge of 152,269 cubic metres. The average biochemical oxygen demand concentration is 928 mg/L. The estimated annual S.S. and B.O.D. loading from the facility before the proposed treatment is 174,196 kg per year and 141,306 kg per year, respectively. With the assumption that the pretreatment will reduce the B.O.D. and S.S. concentrations by 50 percent, the estimated loading for S.S. and B.O.D. after pretreatment will be 87,098 kg per year and 70,653 kg per year, respectively.

Conclusions:

In accordance with section 6, Compliance Program, of our Sewer Use By-Law No. 153-89, a Compliance Program with Monetary Concession should be issued to Christie Brown & Co. to provide a mechanism by which the overstrength effluent which exceeds the by-law limit for B.O.D. and S.S. can be discharged on a 50 percent reduced fee basis while the company implements further wastewater treatment controls, under the conditions previously stated in this report.

Contact Name:

Mr. Vic Lim, P.Eng.

Manager, Industrial Waste and Storm Water Quality

Quality Control and System Planning

Telephone: (416) 392-2966; Fax: (416) 397-0908

e-mail: victor_lim@metrodesk.metrotor.on.ca