The following is a reminder and recommendation to consider checking in with your First Nation, in relation to both the federal Fuel Storage Tank Regulations and the Wastewater Systems Effluent Regulations.
The federal Storage Tank Systems for Petroleum Products and Allied Petroleum Products Regulations, a regulation made under the Canadian Environmental Protection Act (CEPA), came into force in 2008 and applies to all underground storage tanks and all aboveground storage tanks greater than or equal to 2,500L.
At a minimum please ensure that the First Nation is aware of the fuel tank regulation and has all tanks 2500+L registered with Environment Canada. Once registered Environment Canada will issue the tank an identification number (this is NOT the number that INAC inspectors sprayed on the tanks when they assessed them a couple years ago). The EC number must be sprayed/displayed prominently on the tank. Technically without this number suppliers should not be delivering fuel to the tank however it appears that some may still be doing so.
The Wastewater Systems Effluent Regulation is new and only some of the provisions are now in force. This regulation is made under the federal Fisheries Act.
Specifically as of Jan 1/13 a First Nation must be:
- monitoring effluent quality,
- monitoring effluent quantity,
- keeping records, and
- reporting to Environment Canada
To ensure your First Nations are compliant with the regulation as of now, I recommend that you check to see if the plant has:
- the components required to monitor flow (some plants do not have the equipment in which case minor capital upgrades will be required) and whether they are in fact conducting this monitoring;
- a record-keeping system in place; and
- ensure they are prepared to do their own sampling of the effluent including an agreement with an accredited lab (Health Canada will no longer be providing this service if they did in the past, and the sampling frequency especially for RBCs and mechanical plants is more frequent then most communities are accustomed to).
Environment Canada will be requiring all Wastewater plants with an average daily influent of 100 m3 or more to submit an identification report by May 15, 2013. We expect Environment Canada to send out specific information on this in the coming months.
Monitoring reports are due to Environment Canada starting May 15, 2013 for those plants subject to quarterly reporting, and Feb. 14, 2014 for those plants subject to annual reporting. Environment Canada is developing an online system for this reporting.
The requirement to actually meet the effluent quality standards comes into force Jan. 1/15. If the FN is now monitoring the effluent the results will help them to assess if the plant is prepared to meet the standards (CBOD, total suspended solids, un-ionized ammonia, and free available chlorine).
The OFNTSC CRTP program is developing training in relation to the new Wastewater regulations. Please check in with Mathew Hoppe or Jason Henry if your First Nation requires training or assistance through CRTP.
More information on the Storage Tank Systems for Petroleum Products and Allied Petroleum Products Regulations is available at: www.ec.gc.ca/rs-st
The Ontario Regional EC contact is: Lisa McClemens tel. (613) 949-8278, email Lisa.Mcclemens@ec.gc.ca
More information on the Wastewater Systems Effluent Regulation is available at: http://www.ec.gc.ca/eu-ww/default.asp?lang=en&n=BC799641-1
The Ontario Regional EC contact is: Shawn Michajluk tel. (416) 739-5888, email email@example.com
If you require further information or have any questions about either regulation please do not hesitate to contact OFNTSC.